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Asbestos Site Investigations/Remediation

Air, Soil Sampling and Analytical Topics

Prepared for OSC Readiness 2009 Presented by: Brian Brass, CIH Environmental Response Team Las Vegas, NV

Asbestos- It's different!

Chorus: But it's not all that different than any other contaminant!

Asbestos Sites are Complex

1% "rule" gone! OSWER Directive (#9345.4) (AUG 2004)

Develop risk-based site-specific action levels

Soils concentrations <1% demonstrated to represent significant inhalation risk Correlation between potential release of asbestos from soil and inhalable fibers not well defined & methods not standardized

Asbestos Sites are Complex (cont.)

Analytical method for asbestos in soil limited to 0.25%. Determining risk requires estimating exposure. Activity Based Sampling (ABS) When is the Site "clean"?

Utilize Asbestos TRW Tools for Asbestos Site Investigations/Remediation

Asbestos Framework Contact info:

e-mail: [email protected] TRW Hotline at 1-866-282-8622

Knowledgeable team members Toolbox (http://intranet.epa.gov/osrtinet/hottopic.htm) Access to Regional Contacts

No need to re-create the wheel

ERT Can Support OSCs with Asbestos Site Investigations/Remediation

Experienced Personnel Experienced Contractors Appropriate Equipment Standard Operating Procedures Scalable Support (appropriate, timely) ABS SOP (www.ert.org/products/2084.PDF)

Benefits of Using TRW Framework

Approach consistent w/ National Guidelines

(Primarily because it is the guideline)

Experience Team (scalable) Access to vetted laboratories Training/guidance to Regions/Contractors

Sites

Waukegan, Il Quincy Smelter, MI El Dorado, CA Clear Creek Management Area, CA Lowry Air Force Base, CO N-forcer Site, Detroit (Dearborne) MI. Libby, MT Ambler, AK North Ridge Estates, OR Swift Creek, WA Troy, MT Coalinga, Ca Sapphire Asbestos Mine, NC Illinois Beach State Park, IL Alviso, Ca Borit, PA Big Tex, TX Lupe Road, WY Pueblo, CO Cappadocia, Turkey Dunn County, ND

Framework Process in a Nut Shell

Step 1 ­ Review historical and current data (same as any other contaminant!) Step 2 ­ Has there been (or is there a threat of a release to the environment? Step 3 ­ Is human exposure likely under current or future site conditions? Step 4 ­ Preliminary (screening level) environmental sampling (same as any other contaminant?????)

Framework Process in a Nut Shell

Step 5 ­ Environmental sampling: Sitespecific activity based sampling (ABS) for indoor and outdoor scenarios Step 6 ­ Response Action and/or Institutional Controls Step BB ­ Verification of "clean"

Step 1 ­ Review historical and current data

Asbestos-containing materials (ACM) or asbestos-contaminated sources. Manufactured products, Libby vermiculite. ACM in on-site buildings. Prior to 1970s, asbestos was used in wide variety of building materials. "naturally occurring asbestos" (NOA).

Asbestos occurs in mineral deposits throughout US. Resources: USGS, State geological offices, BLM, DOI,etc.

Step 2 ­ Has there been (or is there a threat of a release to the environment?

Conduct reviewed to determine if a release of asbestos has occurred Or could occur in the future Professional Judgment!

Step 3 ­ Is human exposure likely under current/future site conditions?

Develop a conceptual site model & perform exposure assessment (Possibly collect and analyze soil samples per NCP). Current and potential future accessibility of the site, & community awareness of exposure should be considered. Exposure pathways: inhalation of asbestos from disturbed soils/mat'ls, disturbed settled dust Risks assessment should pass reasonability test.

Step 4 ­ Preliminary (screening level) environmental sampling

Soil sampling using VSP Outdoor ABS (Raking/Generic ABS) Indoor ABS (Sweeping or similar)

Microvac sampling

Risk Management Decision Point #1 ND No Further Evaluation Detected Further Evaluation Required

Step 4 ­ Preliminary environmental sampling. Additional Guidance

Seeing ACM, Libby Vermiculite, >0.25% in soil? May want to cleanup- moving dirt is comparatively cheap

How Long does it Take to Conduct ABS

Each sample takes minimum of 100 minutes

Set-up Travel Decon Breaks Variables such as weather

Sample results can take months to obtain

Dependent on number of samples and lab load Build in time for analysis and QA/QC

Asbestos- It's different!

Chorus: But it's not all that different than any other contaminant!

Equipment Requirements

Pump capable of drawing 10 L/min through a 0.8 µ pore size filter (high backpressure!)

SKC QuickTake 30 (semi-personnel) Gilian Aircon 2 Stablex asbestos pump, etc.

Meteorological station

Where can you Obtain Equipment?

Pumps

http://www.skcinc.com/Rental/default.asp Standard environmental Equipment Rentals

Meteorological Stations

http://rentals.cleanair.com/equip/metauto.html

Filters

http://www.skcwest.com/ http://www.zefon.com/store/25mm-asbestospcm-cassette.html

Assume Site w/ Asbestos Contamination and Exposure Pathway

Big Tex Site Location

Detailed Location

Visual Sampling Plan Output and Maps

Grid Site using VSP and Sample

Decision Process

Air dispersion data Weather patterns- primarily wind direction VSP software

determine sample locations. number of samples

Professional judgement to divide into high, medium, and low priority areas

High Red, Medium Yellow, Low Blue

Note Different Sized Grids!

Recommended ABS Sampling Locations

HZ-65 Sandy Clayey Silt (SCS) Fiberous Amphibole (FA) LZ-17 SCS FA LZ-13 Silty Clay (SC) FA HZ-20 SCS FA LZ-08 Clayey Silt (CS) ND HZ-71 Clay ND HZ-73 SCS Trace HZ-35 SCS Trace MZ-09 SC Trace LZ-31 SCS Trace DP-03 SC ND (top of Dirt Pile) One to two discretionary ABS locations, possibly the road towards the center of the Site and rail spur area between bldgs 22 and 23.

ABS Locations in Yellow (10*10)

ABS Sampling Location Decision Process

All locations were asbestos detected above method detection limit (0.25%) Percentage of the locations where asbestos reported as "trace" A few locations where asbestos was ND. Evaluate all of the soil types reported (USCS). Cover a broad portion of the overall Site, especially likely use or deposition area.

Variability of ABS Samples

Raking Scenario Variability (Low exposure)

Medium exposure

High Exposure

Buildings Clearance Sampling

Microvac Sampling 5000 S/cm2 action level AHERA clearance sampling in buildings subsequent to decon Confounding contamination (floor tiles, joint compound, insulation, etc)

Interference?

ABS Results--What does it mean?

ABS Sample Types

Actual ABS-high value Upwind- important info-upwind source? Downwind-asbestos not reaching breathing zone? Perimeter- off-site transport-reference Reference samples-off-site upwind-process check Value?

Value of Up and Downwind Samples

Area samples

Predictor of the surrounding airborne particulate concentration and potential exposure. Provide additional data for evaluating: Exposure Releasability of asbestos/particulate from substrates Effectiveness of engineering controls Selection of PPE

Additional source of data to estimate exposure, provided limitations considered.

Reference ABS Sampling

Reference (off-site) ABS is strongly recommended and will be incorporated into Asbestos Framework and SOP Collect 5 of more off-site ABS samples at a reference location

Ref. Loc. similar environment, proximal, similar soils, same time-frame as site ABS, etc.

Why? --- Compare apples to apples ABS to ABS not to ambient air!

Removal Action

How Did They Decide Where to Excavate Based on Limited ABS Data?

Identified grids with unacceptable risk as determined by ABS Did not sample all grids using ABS!!!!!! Extrapolated to non-ABS grids based on asbestos levels in soil and soil type.

Remember- conducted ABS in each soil type and for each range of asbestos contamination in soil. Visible vermiculite Professional judgment (historical knowledge of storage and use areas)

Removal Action

We're workin' with a excavator. Not a scalpel!

Asbestos- It's different!

Chorus: But it's not all that different than any other contaminant!

Soil Removal

Soil Removal

Interior Decontamination

Note Vermiculite Insulation >

AHERA Clearance Sampling

Clean-up Decision Process

ABS Risk > action level (1e6?) Soil contamination >0.25%? $ (ABS risk level?) Land use- what makes sense? Logical clean-up (excavator not scalpel) Soil type same as contaminated areas? Visual clues? Cost of excavation?

Project Conclusion-walk away

No visible vermiculite in soil (on-site microscopist) Soils visually clean and undisturbed Building pass AHERA clearance criteriavisual inspection and air sampling Confirmation ABS

AHERA Clearance

Avg. asbestos conc. of 5 air samples collected within the affected space (analyzed by TEM), not significantly different (Z-test) from the avg. conc. of 5 samples collected at the same time outside the affected space. And avg. asbestos conc. of three field blanks below the filter background level of 70 structures per square millimeter (70 s/mm 2).

Air Sampling Issues

Develop Activity Based Scenarios (ERT SOP)

Details! Personnel Change Outs Documentation

Sampling Logistics

Multiple Samples: short turn-around Multiple flow rates & location

Sampling Procedures

Calibration!

Activity Based Sampling (ABS)

Generic & Site-specific ABS

Generic ABS utilizes a rake to disturb the soil over a known area in conjunction with the collection of air samples.

Used to evaluate the potential for fiber release from soil over a large area.

Site Specific ABS utilizes activities based on land use

Used to simulate likely site activities to evaluate exposure

ABS Scripts

Raking (metal garden rake) Raking (leaf rake) (generic ABS) ATV riding Rototilling Digging Child Playing in the dirt Weed Wacking Lawn Mowing Walking with Stroller Bicycling Basketball

Perimeter & Background/reference Samples

Collect perimeter or fenceline samples to document migration concurrent w/ ABS Collect Background/reference samples concurrent w/ & in general area as the ABS, upwind at distance sufficient to prevent being influenced by the simulated activities.

Ref. Sample Locations--To the degree practical free of known asbestos contamination.

Background/reference Samples (cont.)

Reflect defensible reference conc. of asbestos to evaluate if release from site or activity occurred.

do not necessarily represent pre-release conditions or the absence of influence from site sources

Use stationary sampling pumps and a detection limit ~ an order of magnitude below that of the ABS detection limit.

Laboratory Analysis

Method ISO 10312

Standard recording spreadsheet

NADES Spreadsheet

Laboratory Selection

Qualified labs

PE samples

Required for Pre-qualification? How notified?

Filter Loading

ISO 10312:

DataRam Spreadsheet

25 g/cm2 of filter surface

On site screening by microscopist Eyeball method Use indirect method ISO 13794 $$$

Additional Site Information

Met Data

WS, WD, bar pressure, temp, solar rad, and rainfall (5 min Avg.)

Soil Moisture

On-site Lab confirmation

Sieve Analysis Asbestos % (May permit extrapolation of ABS results to other areas of Site)

ABS Video

Where to obtain Guidance/Assistance

Asbestos Technical Review Work Group (TRW) Co-Chairs, Chuck Nace, Arnold Den e-mail: [email protected] TRW Hotline at 1-866-282-8622 ERT Edison 732-321-6700 ERT Las Vegas 702-784-8000

Analytical and Data Issues

What analysis should you request?

ISO 10312

What data should you use?

PCME ­IRIS risk based on PCM Total TEM (use in uncertainty analysis)

Asbestos Images TEM

Crocidolite TEM images: L to R Brightfield, darkfield, diffraction

Chrysotile Diffraction Pattern

Quincy Smelter

El Dorado

Level of Effort Estimate to Investigate Generic Asbestos site

Estimates based on 10 + sites Assumptions

Each site is approx. 5 acres in size. Waste not distributed to community. Gross contamination such as piles of asbestos, vermiculite, ore, etc. have been removed. No more than 3 buildings (<10, 000 square foot/building) or structures remain on site. Historic aerial photos and site history information is readily available

Four Major Phases

Background investigation, Soil sampling/characterization, Activity Based Sampling (ABS) Risk Assessment

Process Costs

Background review/research

20 to 80 labor hours @ $75/hr

Soil Sampling/Characterization

Develop QAPP & SAP using templates & VSP- 5 to10 hours. VSP set-up & transfer to a GIS-- 4 hours 25 Soil samples - CARB 435 w/ Libby ISSI-Libby -01 prep. @ $95/sample = $2400 (Assumes 5 soil samples will be required to characterize each acre and a 5 acre). Three people for one 8 hour day Sample analysis will take a minimum of 2 to 3 weeks.

Activity Based Sampling (ABS) Costs

Five acre site, assuming uniform soil type and trace as well as 0.25% to 0.50% asbestos reported in the soil samples 5 to 10 ABS samples to characterize site. Estimate will vary depending on the complexity of the site, distribution of asbestos & proposed land use. Number of ABS samples to characterize site is probably the least accurate estimate in presentation.

ABS Costs Cont.

3 additional air samples with each ABS sample Duplicates at a rate of 10% 3 reference samples per day of ABS sampling. Estimate 8 ABS samples/per day.

ABS Costs

Assume 9 ABS samples (includes 1 duplicate) 24 perimeter samples 3 reference samples Plus blanks for a total of 40 air samples for ISO10312 analysis @ $400/sample equals $16,000

ABS Labor Requirements

Sampling will require ~6 people for a day plus per diem plus travel.

Four of the personnel- technicians Two professionals (calibrate equipment, set up meteorological station, GPS in the sample locations, process the data.

Work 12 + hour days (excluding travel). 6 persons * 12 hours at $50/hour (average salary) equals approximately $3600. Plus 4 hours/person mobilization & travel adds an additional $1200 $1000 for shipping and $1000 for supplies (PPE, cassettes, expendables)

Risk Assessment Costs

Report preparation and data reduction approximately 25 hours @ $75/hour for an additional $2000. Risk assessor 40 hours preparing a report and reviewing data. 40 *$75=$3000.

Asbestos Site Investigation Total Costs

EPA OSC or RPM to supervise the project (25 hours @ $75/hour). Regional EPA staff to direct and task contractor personnel (25 hours @ $75/hour) Estimates do not include G&A or overhead costs for contractors. Estimates assume Up-front time spent developing standard approach to investigating sites Personnel performing work familiar w/ procedures & protocols. Economy of scale for sites larger than 5 acres, but not much. Travel costs are unknown and local staffing at the technician level would definitely help control costs.

Total Cost

Single 5 acre site $39,000 to $60,000. Contingency closer to $75,000 per site.

Clear Creek Management Area

Lowry Air Force Base

Assisted Air Force with implementation of ABS plan

Libby, MT

Ambler, AK

Swift Creek

Sapphire Valley Mine

Sapphire Valley Mine

The End

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