VISUAL INSPECTION AND AHERA CLEARANCE
                      AT ASBESTOS ABATEMENT SITES
                                      by
 John R. Kominsky1, Ronald W. Freyberg1, James A. Brownlee2, Donald R. Gerber2,
                      Thomas J. Powers3, Roger C. Wilmoth3
                             For Presentation at the

                      National Asbestos Council Conference
                                New Orleans, LA
                              February 19-22, 1991
 1IT Environmental Programs, Inc., Cincinnati, OH  45246;
 2New Jersey Department of Health, Trenton, NJ  08625;
 3U.S. Environmental Protection Agency, Risk Reduction Engineering Laboratory,
 Cincinnati, OH 45268
    The NJDOH-ACS inspector first visually examined all substrate surfaces to ensure

that no asbestos-containing material (ACM) remained.  Special attention was given to

pipes, structural members, and irregular surfaces with corners and hard-to-reach

areas.  If any quantity of ACM remained, the site failed the visual inspection, and

additional removal was conducted before another visual inspection was,conducted.

The ACS inspector then determined if the worksite had been adequately cleaned. All

surfaces were examined for dust and debris, especially overhead areas (such as the

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tops of suspended light fixtures) and areas under stationary fixtures.  One or both of

the following techniques were used for examining surfaces to establish that a "no-

dust" criterion had been achieved:


       1.    Use of a damp cloth to collect dust from the surface and then inspecting
            the cloth for evidence of dust.

       2.    Darkening of the room and shining a flashlight so that the light beam just
            glances any smooth horizontal or vertical surface. A gloved finger is then
            run across the illuminated area; if a line  is left on the surface,  dust is still
            present.

    If either of these techniques showed that dust still remained, the ACS inspector

required that the entire work area be recleaned before its reinspection.

Air Sampling

      After the site passed the NJDOH-ACS visual inspection, an Asbestos Safety

Technician (AST) collected AH ERA clearance air samples (which were used to declare

the site clean and to release the abatement contractor). The AST is certified  by the

New Jersey  Department of Community Affairs and is an employee of an Asbestos

Safety Control  Monitor (ASCM) firm, that is employed by the School District or Local

Education Agency.

    Concomitant air sampling was conducted by the EPA at  approximately the same

time and location (within a radius of 5 feet) of the ASCM firm's sampling. The EPA

collected five area air samples in each of three locations: the abatement work area,

the perimeter area outside the abatement area but inside the building, and outdoors.

In the abatement work area, the samples were collected under the sampling

conditions created by the  ASCM for AHERA clearance. The perimeter area samples

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were collected under static conditions (i.e., the activity in the area was minimal, and



the heating, ventilation, and air-conditioning system was not operating).



Sampling Methodology



      The air samples were collected on open-face, 25-mm diameter, 0.45-Mm pore-



size, mixed cellulose ester (MCE) membrane filters with a 5-nm pore-size, MCE



backup diffusing filter and cellulose support pad contained in a three-piece cassette.



The filter cassettes were positioned approximately 5 feet above the floor on tripods,



with the filter face at an approximately 45-degree angle toward the floor.  The filter



assembly was attached to a 1/6-hp electric-powered vacuum pump operating at a  flow



rate of approximately 9 L/min.  The sampling pumps were calibrated with a precision



rotameter both before and after sampling.  The precision rotameter was calibrated in



the field with a primary air flow standard.



Analytical Methodology



      The MCE membrane filters were prepared and analyzed in accordance with  the



nonmandatory TEM method, as described in the AH ERA rule.  For each sample, a



sufficient number of grid openings were analyzed to ensure a sensitivity (the



concentration represented by a single structure) of no greater than 0.005 asbestos



structure per cubic centimeter (s/cm3) of air sampled.  In  addition to the requirements



of the nonmandatory TEM method, the specific length  and width of each structure



were measured and recorded.



AHERA TEM Clearance Test



      The  AHERA TEM clearance criterion is primarily comparative in nature; i.e., it is

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based on a comparison of airborne asbestos concentrations inside the abatement



work area with those outside the abatement work area but not necessarily outside the



building.4 Although inside samples may be collected as a basis for comparison when



air intake to the abatement site is primarily from other areas of the building, outdoor



samples are normally recommended because they are less likely to be affected by



work practices that might contaminate other areas inside the building.



      The AHERA clearance test requires the collection of a minimum of five samples



inside and five samples outside the abatement work area.  A statistical test (the Z-test)



is then used to determine if the average concentration inside the abatement area is



higher than the average concentration outside.  The Z-test  is carried out by the



following equation:




                                      Y.-Y
                              z-	**   °	
                                 o .
where  Yj = the average of the natural log of the inside samples



       Y0 = the average of the natural log of the outside samples



       nf = the number of samples collected inside the work area



       n0 = the number of samples collected outside the work area







If the Z statistic is less than or equal to 1.65, the site passes the AHERA clearance test



and is considered acceptable for reoccupancy.



      The AHERA Z-test is preceded  by two preliminary tests-an initial screening test

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and a blank contamination test.  The initial screening test compares the average
concentration of the five samples collected inside the abatement area against a value
of 70 structures per square millimeter (s/mm2).  If the average concentration is less
than or equal to 70 s/mm2, the work area passes the clearance test without the
analysis of the outside samples being required.  If the work area samples do not pass
this initial screening test, a minimum of three blanks (filters through which no air has
been  drawn) are analyzed to check for the possibility of filter contamination that would
distort the test results. If the filter concentrations are less than or equal to 70 s/mm2,
they are considered indistinguishable from blank contamination levels.  If the three
blanks pass the 70 s/mm2 criterion, the outside samples are then analyzed and the Z-
test is used to compare the results with those of the samples collected inside the work
area.

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                                  RESULTS



Site Descriptions



   Fourteen of the 15 abatement projects involved general occupancy areas



(classrooms, offices, recreational rooms, and corridors), and one involved both



general occupancy areas and a boiler room. The ACM abated at nine of the sites



involved surfacing material (sprayed- or troweled-on), three involved thermal system



insulation, two involved both surfacing material and thermal system insulation, and one



involved suspended ceiling tiles.  The ACM contained chrysotile asbestos (from 2% to



93%) at 14 sites and amosite asbestos (from 5% to 10%) at one site.



Final Visual Inspection



      From one to seven visual inspections were conducted at the 15 abatement



sites.  Figure 1 shows the percentage of sites that passed the NJDOH-ACS visual



inspection per given attempt. The largest percentage (33.5%) of sites passed the



visual inspection on the second attempt.  It should be noted that final  cleaning



activities were completed by the abatement contractor at all of the sites. The data



clearly indicates that the visual inspection by the NJDOH-ACS revealed the inadequacy



of the final cleaning activities for the first attempt.  Additional attempts  were necessary



to successfully pass the NJDOH-ACS visual inspection.  The cumulative percentages



of sites passing the visual inspection were as follows: 40% by the first and second



attempts, 66.7% by the third attempt, and 93.4% by the fourth attempt.
                                      8

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   Table 1 lists the reasons why sites failed the NJDOH-ACS inspectors's visual

inspections at the 15 sites. Fourteen of the 15 sites failed the visual inspection for

more than one reason.  The most commonly identified reason  (cited at 8 of the 15

sites) was the presence of debris on pipes, pipe fittings, and hangers. The  next most

common reason was debris on floors, on horizontal surfaces, and in wall penetrations.

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Relationship Between Visual Inspection andAHERA Clearance Test



      Table 2 summarizes the number of visual inspections and AH ERA TEM



clearance test results based on the U.S. EPA air sampling for each of the 15 sites.



The clearance results are presented based on the initial screening criterion, and based



on the Z-test comparison of the airborne concentration of asbestos in the abatement



area to that in the perimeter area (outside the abatement area, but inside the building)



and outdoors.



    After passing a final visual inspection by the NJDOH-ACS, 27 percent (4 of 15) of



the sites passed the AHERA clearance test based on the initial screening criterion, i.e.,



the average filter concentration for the five samples collected inside the abatement



area was <70 s/mm2.  Including these four sites,  53 percent (8 of 15) passed using



the perimeter area and 46 percent (7 of 15 sites)  passed using outdoors as the



clearance reference point for the Z-test, respectively. It's apparent that failing the initial



screening test does not infer that the site would fail the Z-test.  This situation was



observed at Sites  B, C, H, and S.



    These data demonstrate that final visual inspection is necessary to determine the



completeness of an abatement action and the thoroughness of cleaning the worksite;



i.e., the absence of debris, residue, or dust on surfaces.  As noted in  the low pass rate



of the initial visual inspection, the meticulous and conscientious inspection of surfaces



is necessary to determine the absence of debris, residue, and dust.  Presumably, if



such an inspection had not been conducted at these 15 abatement sites, a higher



percentage of sites would have failed the AHERA TEM clearance test  on the first
                                      11

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attempt. Final clearance air sampling, as described in the AHERA rule, is ultimately

necessary to determine that an abatement site is acceptable for re-occupancy.
        TABLE 2.  RELATIONSHIP BETWEEN VISUAL INSPECTION
                 AND AHERA CLEARANCE TEST
                 Number of     Initial
                 Visual         Screening           Z-test	
        Site      Inspections     Test           Perimeter  Outdoor
        A         4           PASS          PASS      PASS
        B         3           FAIL           PASS      FAIL
        C         1           FAIL           PASS      PASS
        H         2           FAIL           PASS      PASS
        I           4           FAIL           FAIL      PASS
        K         4           FAIL           FAIL      FAIL
        L         2           FAIL           FAIL      FAIL
        M         3           FAIL           FAIL      FAIL
        N         2           FAIL           FAIL      FAIL
        O         2           PASS          PASS      PASS
        P         3           PASS          PASS      PASS
        Q         4           FAIL           FAIL      FAIL
        R         7           PASS          PASS      PASS
        S         3           FAIL           PASS      FAIL
        T         2           FAIL           FAIL      FAIL
                                   12

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                                CONCLUSION







   This paper examined the relationship between passing a thorough final visual



inspection and the AH ERA TEM clearance Z-test. A final visual inspection is



necessary to determine completeness of an abatement action and thoroughness of



the cleaning of the worksite, but can not be substituted in lieu of final clearance air



sampling.
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                                REFERENCES
1. Kominsky, J. R., R. W. Freyberg, J. A. Brownlee, J. H. Lucas, D. R. Gerber.
   Observational Study of Final Cleaning and AH ERA Clearance Sampling at
   Asbestos-Abatement Sites in New Jersey. U.S. Environmental Protection Agency,
   EPA/600/S2-89/047, July, 1989.

2. U.S. Environmental Protection Agency.  Guideline for Controlling Asbestos-
   Containing Materials in Buildings. EPA 560/5-85-024, June 1985.

3. American Society for Testing Materials. Standard Practice for Visual Inspection of
   Asbestos Abatement Projects.  ASTM E1368, ASTM, 1916 Race Street,
   Philadelphia, PA 19103.

4. U.S. Environmental Protection Agency.  Guidelines for Conducting the AHERA TEM
   Clearance Test to Determine Completion of an Asbestos Abatement Project.  EPA
   560/5-89-001, May, 1989.
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