What is it? How do we manage it?

What is it? How do we manage it?

RACS vs. Non-RACS vs. Not RACS Recently become aware of confusion between these three categories of materials

Is it RACS? This is now the main question that needs to be asked about any material being managed Section 5.5.1(B) - asbestos determination for suspect materials Section 5.5.1(B)(6) - RACS determination RACS can consist of either friable or nonfriable asbestos containing material, or a combination of both

Make a RACS Determination RACS Determination means a determination, conducted in the field by a CABI, of the friability of ACM and probability of non-friable ACM to release fibers based on the condition of the material and forces that are expected to act on it during disturbance

RACS Determination Cont d Determinations of the probability for non-friable ACM to release fibers during disturbance shall be based on the following: The condition of the material prior to disturbance, based on observations of weathering, the integrity of the material, historical mechanical impact, or fire damage; The potential for the material to be broken, resized or damaged during the planned disturbance,

RACS Determination Cont d The material shall be considered RACS if the planned disturbance includes any of the following: Augers, rotary style trenchers, driving on ACM lying on the surface (vehicles or equipment), blasting or other detonation, intentional burning Other types of direct mechanical impact which are: In direct contact with ACM or result in observation of ACM after disturbance, and Causing damage to the ACM

RACS Regulatory Definition RACS means soil, ash, or debris (plus 6 in all directions of surrounding material) containing: 1) Friable ACM

RACS Regulatory Definition Cont d 2) Previously non-friable ACM that is now friable

RACS Regulatory Definition Cont d 3) Non-friable ACM that have a high potential to release fibers based on forces expected to act on it

RACS Regulatory Definition Cont d 4) Deteriorated non-friable ACM in poor condition

RACS Regulatory Definition Cont d 5) All of the following: Asbestos cement materials Plaster Brittle caulking, glazing and sealants Powdery concrete masonry unit (CMU) sealant Powdery floor leveling compound Drywall/wallboard and assoc. joint compound Firebrick Other material as determined by the Dept. Does not contemplate friability, these materials are ALWAYS RACS

RACS Regulatory Definition Cont d 6) Soil or ash known to contain non-visible asbestos fibers based on documented evidence Typically from sampling results

So, what is non-racs? Non-RACS regulatory definition Non-RACS means soil or debris that contains only: 1) Intact non-damaged, non-friable ACM

Non-RACS Regulatory Definition Cont d 2) Damaged non-friable ACM(s) that do not have a high probability to release fibers based on the forces expected to act on the material Resin based materials (Bakelite) Resilient flooring (excluding friable felt backing on sheet vinyl) Tar impregnated or asphaltic materials that are not brittle

Non-RACS Regulatory Definition Cont d 3) Elastic, pliable, or rubberized materials Pliable materials Duct sealant, fiberglass insulation sealant, fire-stop/caulking/sealants, window or door caulking Extremely hard/durable materials Lab countertop/sinks, epoxy type CMU sealant, epoxy type panel adhesive, duct sealant, ceiling tile adhesive 4) Other ACM(s) as approved by the Dept.

NOT RACS Not RACS is non-asbestos material Or, soil containing material that is less than 1% asbestos (trace material) Does not include soil with non-visible fibers at any concentration Management under Section 5.5 does not apply

So, How do we Dispose of Each? Not RACS disposal: Solid waste disposal at a landfill under a profile OR beneficial reuse Non-RACS disposal: Does not require packaging, but this is still asbestos material, and as such, needs to be declared to the landfill accepting the waste

RACS Disposal RACS w/ more than 1% friable ACM in the load: Disposal in manner similar to friable asbestos Leak tight packaging Section 5.3 requires a minimum of 2 layers of 6 mil or equivalent approved by Dept.

RACS Disposal Cont d RACS with less than 1% friable ACM in the load or RACS with no visible ACM Disposal in a manner similar to non-friable asbestos Section 5.5.8 specifies leak tight packaging Traditionally = at least one layer of 6 mil

Disposal and 1% Bed of Disposal Truck Friable ACM (>1% asbestos) Soil (<1% asbestos) The total disposal load is less than 1% asbestos = disposal in a leak tight container in a manner similar to non-friable

RACS Management Options Project Specific RACS Management Plan (PSRMP) Standard Operating Procedures (SOPs) Remediation plan Standard requirements of Section 5.5.7 of the Solid Waste Regulations Risk based approach

Requirements of a Typical Project Specific RACS Management Plan (PSRMP) Regulated work area PPE Wetting Wind Air monitoring Work practices Loading & placement Staging, stockpiling, & storage Decontamination Spill response RACS remaining in place Documentation Training Packaging & disposal

Required Training Anyone in RWA needs annual awareness training provided by a CABI General asbestos awareness including health effects Overview of Section 5.5 and its implementation Overview of suspect ACM that requires CABI evaluation RACS vs. Non-RACS Worker Protection Decontamination Engineering controls for visible emissions

Required Training Cont d Anyone in the RWA during RACS disturbance also needs per-project site specific training provided by a CABI Tailor annual training requirements to site specific conditions if necessary Project chain-of-command and personnel w/ stop work authority Hands on training specific to the soil disturbing activities they will perform

Required Training Cont d Section 5.5.3 training requirements don t address OSHA requirements There may be additional OSHA training requirements OSHA stands on its own Also additional PPE considerations Section 5.5 PPE requirements are meant to address cross contamination not respiratory protection

Submittals Notification Requires Map / figure / drawing

Submittals Cont d PSRMP submit at least 10 days prior to project SOP submit at least 30 days prior to project Remediation submit at least 45 days prior to project Risk based approach submit way before project

Submittals Cont d Additional submittals may be requested depending on the site specific conditions Excavation in historic landfill may require a Materials Management Plan (MMP) or a plan detailing how the cover will be replaced If reuse of solid waste is planned a beneficial use determination may be required Other submittals may be required depending on site conditions

Contact Information Brian T. Long Solid Waste Compliance Assurance Unit briant.long@state.co.us (303) 691-4033 Link to asbestos in soil regulation and notification form www.colorado.gov/pacific/cdphe/asbestoswaste