What is the Asbestos NESHAP Adequately Wet Guidance Clause?
The Asbestos NESHAP Adequately Wet Guidance Clause is a document prepared under contract to agencies of the United States Government. The Asbestos NESHAP Adequately Wet Guidance Clause was written by Alliance Technologies, based on discussions with work groups of the Environmental Protection Agency. These groups consisted of Regional Asbestos NESHAP Coordinators and leaders of the Stationary Source Compliance Division as well key members of the Standards Development Branch.
The introduction of The Asbestos NESHAP Adequately Wet Guidance Clause states that the Clean Air Act of 1970 requires the United States Environmental Protection Agency to develop and subsequently enforce regulations to protect the public from exposure to airborne contaminants specifically known to cause cancers or other diseases to human beings. In accordance with the CAA, the Environmental Protection Agency established the National Emissions Standards for Hazardous Air Pollutants to protect the general public. Asbestos was one of the first carcinogens regulated under The Asbestos NESHAP Adequately Wet Guidance Clause. The asbestos portion of The Asbestos NESHAP Adequately Wet Guidance Clause addresses manufacturing, milling and fabricating operations, including renovation, demolition and waste disposal activities.
The Asbestos NESHAP requires owners and operators of facilities involved with demolishing or renovating activities to control emissions of asbestos particles to the outside air because no safe concentration of asbestos has been established by the Environmental Protection Agency.
The Asbestos regulations latent in The Asbestos NESHAP Adequately Wet Guidance Clause requires the aforementioned entities to adequately soak Asbestos Containing materials with wetting agents prior to, during and after renovation and/or demolition activities. The general purpose of The Asbestos NESHAP Adequately Wet Guidance Clause is to provide general guidance to regulated communities and asbestos inspectors concerning how to determine if friable asbestos containing materials are adequately soaked as required by legislation. The recommendations offered in The Asbestos NESHAP Adequately Wet Guidance Clause are solely recommendations—they are not exclusive regulations mandating compliance. Moreover, following of these suggestions is not a guarantee against findings of particular violations. Determinations of whether asbestos containing materials are adequately soaked are made by professional inspectors hired and sent by the Environmental Protection Agency.
How Does the EPA Define “Adequately Wet?”
The Environmental Protection Agency defines adequately wet to mean sufficiently mixed with liquids to prevent the release of asbestos fibers. If visible emissions are observable from asbestos-containing materials, then the EPA will regard the material as not being adequately soaked or wetted. That being said, the absence of visible emissions is not sufficient evidence of being adequately soaked.
The Environmental Protection Agency defines friable asbestos materials as any materials containing more than 1 percent asbestos as determined through Polarized Light Microscopy tests. This percentage is evaluated when dry asbestos can be reduced or pulverized to powder simply by hand pressure.