How to Use Wetting to Reduce Asbestos Particle Release Hazards During Demolition or Removal:
This document series assists building buyers, owners or occupants in reducing the risk of asbestos exposure from flooring that contains or is suspected to contain asbestos. We provide photographs and descriptive text of asbestos insulation and other asbestos-containing products to permit identification of definite, probable, or possible asbestos materials in buildings.
This article describes how to use wetting procedures to reduce asbestos particle hazards during the demolition or clean-up of building products that may contain asbestos. We cite authoritative government and expert sources on safe handling of asbestos-containing waste materials, expanding and illustrating original sources.
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Asbestos is safe and legal to remain in homes or public buildings as long as the asbestos materials are in good condition and the asbestos can not be released into the air.
This document quotes [with formatting & editing for read-ability] from Asbestos NESHAP Adequately Wet Guidance, EPA340/1-90-019 [Asbestos NESHAP Adequately Wet Guidance, EPA340/1-90-019, December 1990, U.S. ENVIRONMENTAL PROTECTION AGENCY, Office of Air Quality Planning and Standards, Stationary Source Compliance Division, Washington, DC 20460,original web source: http://www.epa.gov/region04/air/asbestos/awet.htm]
This document was written by Alliance Technologies, Inc., based on discussions with a work group from EPA. The group consisted of the Regional Asbestos NESHAP Coordinators, Ron Shafer, Scott Throwe, and Omayra Salgado of the Stationary Source Compliance Division, Charles Garlow and Elise Hoerath of the Air Enforcement Division and Sims Roy of the Standards Development Branch. We thank the individuals who reviewed an earlier draft and provided comments, many of which are incorporated in the final version. Their input is gratefully acknowledged.
The Clean Air Act (CAA) of 1970 requires the U.S. Environmental Protection Agency (EPA) to develop and enforce regulations to protect the general public from exposure to airborne contaminants that are known to be hazardous to human health. In accordance with Section 112 of the CAA, EPA established National Emissions Standards for Hazardous Air Pollutants (NESHAP) to protect the public. Asbestos was one of the first hazardous air pollutants regulated under Section 112. The Asbestos NESHAP (40 CFR 61, Subpart M) addresses milling, manufacturing and fabricating operations, demolition and renovation activities, waste disposal issues, active and inactive waste disposal sites and asbestos conversion processes.
The Asbestos NESHAP requires facility owners and/or operators involved in demolition and renovation activities to control emissions of particulate asbestos to the outside air because no safe concentration of airborne asbestos has ever been established. The primary method used to control asbestos emissions is to adequately wet the Asbestos Containing Material (ACM) with a wetting agent prior to, during and after demolition/renovation activities.
The purpose of this document is to provide guidance to asbestos inspectors and the regulated community on how to determine if friable ACM is adequately wet as required by the Asbestos NESHAP.
The recommendations made in this guidance are solely recommendations. They are not the exclusive means of complying with the Asbestos NESHAP requirements. Following these recommendations is not a guarantee against findings of violation. Determinations of whether asbestos materials are adequately wetted are made by EPA inspectors on site.
EPA defines "adequately wet" to mean "sufficiently mix or penetrate with liquid to prevent the release of particulates. If visible emissions are observed coming from asbestos-containing material (ACM), then that material has not been adequately wetted. However, the absence of visible emission is not sufficient evidence of being adequately wet (Section 61.141,Definitions). Amended water is often used to wet ACM during repair/removal operations.
Friable Asbestos Material
Friable asbestos material is any material containing more than 1 percent asbestos as determined using Polarized Light Microscopy (PLM), that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.
Asbestos-Containing Waste Materials (ACWM)
EPA defines ACWM to mean mill tailings or any waste that contains commercial asbestos and is generated by a source subject to the provisions of this subpart. This term includes filters from control devices, friable asbestos waste material, and bags on other similar packaging contaminated with commercial asbestos.
As applied to demolition and renovation operations, this term also includes friable asbestos waste and Category II non-friable ACM waste that becomes crumbled, pulverized, or reduced to powder by forces that acted on the material during the course of demolition and renovation operations regulated by this subpart, and materials contaminated with asbestos including disposal equipment and clothing.
non-friable Asbestos-containing Materials
non-friable asbestos-containing material is any material containing more than 1 percent asbestos as determined using Polarized Light Microscopy (PLM) that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.
Regulated Asbestos-Containing Material (RACM)
Is (a) friable asbestos material, (b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the force expected to act on the material in the course of demolition or renovation operations.
The Asbestos NESHAP defines two categories of non-friable ACM: Category I non-friable ACM (asbestos-containing packings, gaskets, resilient floor covering and asphalt roofing products) and Category II non-friable ACM (any non-friable material not designated as Category I).
The Agency requires that, where the Asbestos NESHAP is applicable, friable ACM and Category II and non-friable ACM that is likely to become disturbed or damaged so that the material could be crumbled, pulverized or reduced to powder during a demolition or renovation be removed, from a facility prior to its demolition/ renovation. The fibrous or fluffy spray-applied asbestos materials found in many buildings for fireproofing, insulating, sound-proofing, or decorative purposes are generally considered friable. Pipe and boiler wrap found in numerous buildings is also considered friable.
non-friable ACM, such as vinyl-asbestos floor tile, generally emits low levels of airborne fibers unless subjected to burning or to sanding, grinding, cutting or abrading operations. Other materials, such as asbestos cement sheet and pipe, can emit asbestos fibers if the materials are crumbled, pulverized or reduced to powder during demolition/renovation activities. Whenever non-friable materials are going to be damaged to the extent that they are crumbled, pulverized or reduced to powder, they must be handled in accordance with the Asbestos NESHAP.
The NESHAP regulation requires that RACM be adequately wetted during the following activities:
a. During cutting or disjoining operations when a facility component which is covered or coated with friable ACM is being removed from that facility as units or in sections (Section 61.145 (c)(2)(i)).
During demolitions or renovations a contractor may choose to remove an entire boiler, a section of pipe, or other facility components without first removing the asbestos insulation from these structures. Any ACM which will be disturbed during cutting or disjoining operations must be adequately wet.
b. During stripping operations when a facility component containing RACM remains in place in the facility. (Section 61.145 (c)(3)).
Stripping operations are the most common form of asbestos removal during renovation activities, since most items that are covered with asbestos are facility components or structural members which will not be removed. Stripping off all of the RACM can generate significant asbestos emissions if the ACM is not adequately wet during removal.
Friable spray-on ACM, which includes fire-proofing materials found on decking and support I-beams, is normally easy to wet throughout because of the absorbing property of the cellulose mixing/binding agent. The Asbestos NESHAP requires that these materials be fully penetrated with the wetting agent during demolition/renovation activities.
Other ACM, however, such as "thermal-block" insulation used on pipes and boilers, certain ceiling and floor tile applications, etc., which do not absorb water readily may be hard to penetrate by water or a wetting agent. For such materials, adequate wetting consists of coating the surfaces of the materials with water or a wetting agent prior to, during, and, in most cases, after removal activities in order to prevent asbestos emissions. Whenever such materials are broken during the removal process, the exposed, dry surfaces must be wetted immediately to reduce emissions.
If pieces of dry ACM are accidentally disturbed, they should be immediately wetted and kept wet until collected for disposal. Removal personnel are commonly assigned to keep the fallen RACM wet prior to its being collected for disposal.
c. After the RACM has been stripped from a facility component, it must remain adequately wet until it has been collected and contained or treated in preparation for disposal. (Section 61.145 (c)(6)(i)).
After removal, adequately wetted ACWM must be sealed in leak-tight containers or wrapping which must be labeled as specified by the Occupational Health and Safety Administration (OSHA) under 29 CFR 1910.1001(j)(2) or 1926.58(k)(2)(iii). Such waste materials destined for off-site transport must additionally be labeled with the name of the generator and location of the waste generation site (Section 61.150 (a)(1)(iv and v)).
d. In demolitions where the RACM was not removed prior to demolition (Section 61.145 (c)(1)(i)(ii)(iii)(iv)).
The Asbestos NESHAP allows two exceptions to wetting RACM during a demolition or renovation project:
Adequate wetting of ACM is typically accomplished by repeatedly spraying it with a liquid or a wetting agent, usually amended water (water to which surfactant chemicals have been added), until it can absorb no more. However, this does not necessarily mean that the ACM will be soaked throughout. Surfactant chemicals reduce the surface tension of the water, thereby increasing its ability to penetrate the ACM and surround the asbestos fibers.
Although amending agents are not required by the Asbestos NESHAP (the NESHAP only requires the use of a liquid), EPA, in its "Guidance for Controlling Asbestos-Containing Materials in buildings", EPA-560/5-85-024 (Purple Book), recommends the use of a 50:50 mixture of polyoxyethylene ester and polyoxyethylene ether, or the equivalent, in a 0.16 percent solution (1 ounce to 5 gallons) of water.
Wetting agents may be applied with garden sprayers or hoses. Garden sprayers are hand-held, portable, and have a one- to five-gallon capacity. Water hoses are usually attached to a faucet tap, fire hydrant or water tank. Generally, the hose has a nozzle attached which spreads the water stream so that a fine mist is created.
An engineering control often used is a misting unit which can be used to create a high level of humidity within a removal area. It is believed that fibers emitted into a saturated environment will absorb the wetting agent and fall out of the air faster, thus reducing airborne fiber levels.
The following procedures describe methods of adequately wetting various applications of ACM.
Thermal System Insulation
The recommended wetting procedure for this type of RACM is to saturate the outer surface with amended water, strip off the wet canvas coating and then re wet the surface in order to thoroughly saturate the ACM. The metal bands supporting the RACM should be removed and the half-round sections carefully separated. While this occurs, the interior side and edges of the sections should be saturated with amended water.
If a section breaks during removal, the exposed surfaces should be wetted immediately. A misting sprayer may also be used to keep the air in the removal area or containment area saturated with amended water to attempt to reduce airborne asbestos fiber levels.
The outer surface of the corrugated paper ("air-cell") pipe insulation, usually a canvas wrap, should be saturated with a wetting agent and then removed. Wetting should continue until all the insulation is permeated with amended water. Metal bands holding the insulation in place should be removed and the corrugated RACM insulation stripped.
Any unsaturated surfaces exposed during the stripping operation must be wetted immediately to reduce asbestos emissions. A misting sprayer may also be used to keep the air in the removal area saturated with amended water to attempt to reduce airborne asbestos fiber levels. Inadequately wetted and adequately wetted corrugated paper pipe insulation can be seen in Figures 1 and 2.
Figure 1. Inadequately wetted corrugated paper, pipe insulation. (Note the fibrous material adjacent to the lagging clamp.)
[FIGURE] - missing
Figure 2. Adequately wetted corrugated paper, pipe insulation. (Note the saturated material adjacent to the lagging clamp.)
[FIGURE] - missing
Asbestos-containing preformed block insulation has been used as thermal insulation on boilers, hot water tanks and heat exchangers in industrial, commercial, institutional and residential applications. The blocks are commonly chalky in nature and may be held in place by chicken wire or expanded metal lath. A plaster-saturated canvas was often applied as a final covering or wrap.
Due to the number, thickness and varying absorbencies of these layers of materials, adequate wetting may be accomplished only by continually wetting the materials with amended water as the various layers are stripped.
One person may be assigned to spray the materials as they are stripped, and a misting sprayer may be used in an attempt to reduce airborne asbestos fiber levels.
Wetting of cementitious fitting insulation is similar to that used when removing asbestos-containing thermal block insulation. The outer surface is saturated with amended water and the outer covering (if applicable) is removed. The fitting insulation is then re wetted and the insulation stripped. To ensure that the fitting remains adequately wet during the removal operation, a person is often assigned to spray the ACM as it is stripped. A misting sprayer may be used to reduce airborne asbestos fiber levels. Inadequately wetted cementitious fitting insulation can be seen in Figure 3.
Figure 3. Inadequately wetted cementitious fitting insulation. (Note that the part of the insulation which has been wetted is dark grey in color, whereas the dry section remains white.)
Asbestos-Containing Surfacing Materials
"Surfacing Material" is a generic term designated by the Asbestos Hazard Emergency Response Act (AHERA; Asbestos Containing Materials in Schools, 40 CFR Part 763, Subpart E) to mean any wall or ceiling material that is sprayed-on or troweled-on, such as acoustical plaster or fireproofing. The recommended wetting method for this type of RACM is to saturate the surfaces, begin the stripping operation and continue to wet the RACM as it is being removed.
A misting sprayer may also be used to keep the air saturated while the removal occurs. Since surfacing materials vary in their ability to absorb a wetting agent, inspectors must consider the type of surfacing material that is being removed in order to determine the required extent of penetration by the amended water. Surfacing materials which easily absorb a wetting agent need to be fully penetrated or permeated to be considered adequately wet, whereas only the exposed surfaces of materials which do not absorb water readily need to be wetted.
The use of high pressure water to remove asbestos-containing surfacing materials, either through a steam-cleaning device or a diesel powered hydroblasting water applicator, should be avoided since such use may unduly disturb RACM and contribute to higher airborne asbestos fiber levels. However, if this removal method is used, contractors must adequately wet the ACM prior to and during the removal.
Miscellaneous Asbestos-Containing Materials
Both friable and non-friable forms of other asbestos-containing building materials exist. Friable materials include asbestos-containing paper (commonly found beneath wooden floors), wallpaper, and joint compound. It has been estimated that 5 to 10 percent of the ceiling tiles currently installed in the U.S. contain asbestos.
Non-friable miscellaneous ACM includes floor tiles, asbestos cement sheet (transite board), siding shingles, asphalt roofing shingles, laboratory bench tops and even chalkboards. These materials may become friable with age, and under harsh conditions. Category I non-friable ACM must be carefully examined to determine if the material is in poor condition, that is, if the binding material is losing its integrity, exhibited by peeling, cracking or crumbling; and is also friable. When Category I non-friable ACM has become friable it is subject to the NESHAP.
If Category I or II ACM is sanded, ground, cut or abraded it is also covered by the NESHAP. Category II non-friable ACM which is damaged to the extent that it has or will become crumbled, pulverized or reduced to powder due to demolition/ renovation activities, is subject to the Asbestos NESHAP.
Miscellaneous materials are wetted in manners similar to those used to wet other categories of RACM. Coverings are saturated with a wetting agent before removal and the asbestos-containing portions fully penetrated with the agent prior to, during and after their removal, while stored in the removal area, and while being placed into disposal containers. Miscellaneous materials that don't absorb water readily (e.g., asbestos-concrete products, and floor tiles) are only required to have wetted surfaces. A misting sprayer may be used to diminish airborne asbestos fiber levels.
The intent of the following guidelines is to provide GUIDANCE ONLY, to the regulated community regarding the inspection procedures recommended to Asbestos NESHAP inspectors for determining compliance with the "Adequately Wet" requirements of the Asbestos NESHAP.
The purpose of the wetting provisions for asbestos containing materials is to require as much wetting as is necessary to prevent airborne emissions of asbestos fibers. In order to achieve this result, RACM and ACWM must be wetted and maintained wet until collected for disposal. The determination of whether RACM or ACWM has been adequately wetted is generally based on observations made by the inspector at the time of inspection.
Lift the bag or container and assess its overall weight. (A bag of dry ACWM can generally be lifted easily with one hand, whereas a bag filled with well-wetted material is substantially heavier.)
If the bag or other container is transparent:
If the waste material is contained in an opaque bag or other container, or if the material is in a transparent bag which appears to be inadequately wetted:
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(Dec 30, 2011) Cathy T said:
We have a 1940's house and we removed the vent covers in order to put some filter fabric behind the vent covers. We did notice that the actual vents where the ducts come up, were attached to the wall with a cement type board. Is there a chance that this could be asbestos related? Was asbestos used
in areas such as these?
Yes that may be a fiber cement or asbestos cement millboard product. See ASBESTOS CEMENT PRODUCTS
(Jan 23, 2012) Connie said:
We began removing flooring in our kitchen. The house was built in 1972 and had 2 layers of sheet vinyl on the floor. The first layer came up easily. The second layer looks similar to the 54282 random mosaic shown in your guide. We had no idea it could contain asbestos until we went to Lowe's for supplies. At this point the flooring is gone and all that remains is the adhesive backing. Up to now we've done everything wrong. What should we do now? How do we know if it is indeed asbestos? How do we contain any damage at this point? Any help you can give us will be appreciated.
You can assume the flooring contains asbestos based on age, or you can have a sample tested if the difference in handling cost will be significant.
also see ASBESTOS REMOVAL GUIDE, FLOORING
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Periodic Visual Re inspections and Air Monitoring
A visual re inspection of all ACM should be conducted at regular intervals as part of the O&M program to help ensure that any ACM damage or deterioration will be detected and corrective action taken.
EPA's Asbestos regulations for schools (the Asbestos Hazard Emergency Response Act, "AHERA") (PDF) [on file as /sickhouse/EPA_Asebstos_Regulations.pdf ] - (96 pp, 589k), web search 08/17/2010, original source: http://www.epa.gov/asbestos/pubs/2003pt763.pdf, require that an accredited inspector re inspect school buildings at least once every three years to reassess the condition of ACM.
The AHERA regulations for schools also require a routine surveillance check of ACM every six months to monitor the ACM's condition. This surveillance can be conducted by a trained school custodian or maintenance worker.
While only school buildings are required to have surveillance checks every six months, it is a good practice for other buildings with ACM. The asbestos program manager (APM) should establish appropriate surveillance and re inspection intervals, based on consultation with the building owner and any other qualified professionals involved in the O&M program.
EPA recommends a visual and physical evaluation of ACM during the re inspections to note the ACM's current condition and physical characteristics. Through this reinspection, it is possible to determine both the relative degree of damage and assess the likelihood of future fiber release.
Maintenance of a set of visual records (photos or video) of the ACM over time can be of great value during re inspections
EPA recommends a visual and physical evaluation of ACM during the re inspections to note the ACM's current condition and physical characteristics.
Additional Prevention Measures
If the ACM is currently in good condition, increases in airborne asbestos fiber levels at some later time may provide an early warning of deterioration or disturbance of the material. In that way, supplemental air monitoring can be a useful management tool. If an owner chooses to use air monitoring in an "early warning" context, a knowledgeable and experienced individual should be consulted to design a proper sampling strategy. (See Useful Links for more information on air monitoring.)
This air monitoring should supplement, not replace, physical and visual inspection. Visual inspection can recognize situations and anticipate future exposure (e.g., worsening water damage), whereas air monitoring can only detect a problem after it has occurred, and fibers have been released.
Note that the collection of air samples for supplementary evaluation should not use aggressive air sampling methods. Aggressive sampling methods, in which air is deliberately disturbed or agitated by use of a leaf blower or fans, should only be used at the completion of an asbestos removal project inside the abatement containment area.
The most accurate and preferred method of analysis of air samples collected under an O&M program requires the use of transmission electron microscopy (TEM). Phase contrast microscopy (PCM), which is commonly used for personal air sample analysis and as a screening tool for area air monitoring, cannot distinguish between asbestos fibers and other kinds of fibers which may be present in the air. PCM analysis also cannot detect thin asbestos fibers, and does not count short fibers. TEM analysis is more expensive than PCM analysis. However, the more accurate information on actual levels of airborne asbestos fibers that can be derived from TEM should be more beneficial to the building owner who elects to use supplemental air monitoring in the asbestos management program. TEM analysis is most reliably performed by laboratories accredited by the National Institute of Standards and Technology and who follow EPA’s quality assurance guidelines. (See References, U.S. EPA, Dec. 1989, Transmission Electron Microscopy Asbestos Laboratories: Quality Assurance Guidelines. Washington, DC: EPA 560/5-90-002).