AIRBORNE ASBESTOS CONCENTRATIONS THREE YEARS AFTER ABATEMENT
IN SEVENTEEN SCHOOLS
by
John R. Kominsky and Ronald W. Freyberg
Environmental Quality Management, Inc.
Cincinnati, Ohio 45240
James A. Brownlee, Donald R. Gerber and Gary Centifonti
Environmental Health Service
New Jersey Department of Health
Trenton, New Jersey 08625
Kim A. Brackett
International Technology Corporation
Cincinnati, Ohio 45246
EPA Contract No.: 68-D2-0058
EPA Project Officer -- Aaron R. Martin
Stationary Source Compliance Division
U.S. Environmental Protection Agency
Washington, DC 20460
Technical Project Manager - Thomas J. Powers
Water and Hazardous Waste Treatment Research Division
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
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DISCLAIMER
The information in this document has been funded wholly or in part by the United
States Environmental Protection Agency under Contract 68-D2-0058 to Pacific
Environmental Services, Inc., and under Subcontract No. SSCD-92-01 to
Environmental Quality Management, Inc. It has been subjected to the Agency's peer
and administrative review, and it has been approved for publication as an EPA
document. Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
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FOREWORD
Today's rapidly developing and changing technologies and industrial products
and practices frequently carry with them the increased generation of materials that, if
improperly dealt with, can threaten both public health and the environment. The U.S.
Environmental Protection Agency (EPA) is charged by Congress with protecting the
Nation's land, air, and water resources. Under a mandate of national environmental
laws, the Agency strives to formulate and implement actions leading to a compatible
balance between human activities and the ability of natural systems to support and
nurture life. These laws direct the EPA to perform research to define our
environmental problems, to measure the impacts, and to search for solutions.
The Risk Reduction Engineering Laboratory is responsible for planning,
implementing, and managing research, development, and demonstration programs to
provide an authoritative, defensible, engineering basis in support of the policies,
programs, and regulations of the EPA with respect to drinking water, wastewater,
pesticides, toxic substances, solid and hazardous wastes, and Superfund-related
activities. This publication is one of the products of that research and provides a vital
communication link between the researcher and the user community.
This report provides information on airborne asbestos concentrations measured
three years after asbestos abatement at 17 schools in New Jersey. Air monitoring
was conducted to determine the effectiveness of the asbestos control programs in
these schools.
E. Timothy Oppelt, Director
Risk Reduction Engineering Laboratory
Hi
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ABSTRACT
From 1988 through 1991, the U.S. Environmental Protection Agency's Risk
Reduction Engineering Laboratory and the New Jersey Department of Health's
Environmental Health Service conducted air monitoring in 17 schools in New Jersey to
determine the effectiveness of their asbestos control programs.
In 1988, a study was conducted to document Asbestos Hazard Emergency
Response Act final clearance concentrations of asbestos at these 17 schools. The
findings of this study prompted a follow-up study in 1990 to determine the airborne
asbestos concentrations 2 years after the abatement efforts in these schools.
Although the data from the 1990 study provided information regarding airborne
asbestos levels during simulated occupancy conditions 2 years after abatement,
whether these data were representative of levels during actual occupancy was
equivocal.
Another follow-up study was conducted in May 1991 to determine the airborne
asbestos concentrations in these 17 schools during actual occupied conditions.
Results showed elevated levels of airborne asbestos at seven of the schools.
Reentrainment of residual asbestos-containing debris from the 1988 abatement or
operations and maintenance activities may have contributed to the elevated airborne
asbestos concentrations measured during the May 1991 study.
Environmental Quality Management, Inc., submitted this document to the U.S.
Environmental Protection Agency's Office of Research and Development, Risk
Reduction Engineering Laboratory, in fulfillment of Contract No. 68-D2-0058. The
report covers the period of July to December 1992, and work was completed as of
December 31, 1992.
IV
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CONTENTS
Disclaimer .!!
Foreword
Abstract ™.
Figures
Tables Vl"
Acknowledgments
1. Introduction
Background ^
Objectives
2. Conclusions and Recommendations |
Conclusions ^
Recommendations 4
3. Study Design and Methods jj
Air Sampling Strategy |
Previous Air Monitoring Strategies 9
Site Documentation «
NJDOH Visual Inspection *
Sampling Methods ] }
Analytical Methods ] J
Statistical Methods ""'
4. Quality Assurance J®
Sample Chain of Custody ^
Sample Analysis '3
5. Results and Discussion ^
Site Descriptions '/
Airborne Asbestos Levels During Occupied
Conditions in May 1991 JZ
Phase III Follow-up Air Monitoring 27
NJDOH Visual Inspections 27
Comparison of 1988, 1990, and 1991 Results 31
39
References
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CONTENTS (continued)
Appendices
A Individual Estimates of Airborne Asbestos Concentrations
Three Years After Abatement (1991) at 20 Sites 40
B Structure Type and Morphology Distributions for Site A Through T 50
C Phase III Case Histories 55
D Average Airborne Asbestos Concentrations Measured in
1988, 1990, and 1991 "
vi
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FIGURES
Number Page
1 Average Airborne Asbestos Concentrations (s/cm3) in the Previously
Abated Area Measured During Occupied Conditions in May 1991 20
2 Average Airborne Asbestos Concentrations (s/cm3) in the Perimeter
Area Measured During Occupied Conditions in May 1991 21
3 Average Concentration of Asbestos Structures per Square Millimeter
(s/mm2) in the Previously Abated Area Measured During Occupied
Conditions in May 1991 22
4 Average Concentration of Asbestos Structures per Square Millimeter
(s/mm2) in the Perimeter Area Measured During Occupied Conditions
in May 1991 23
vii
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TABLES
Number Page
1 Summary of Air Sampling Strategy 6
2 Number of Area Air Samples Collected at Each Site During
Occupied Conditions in May 1991 7
3 Data Summary for Replicate Analyses 15
4 Data Summary for Duplicate Analyses 16
5 Post-1988 Abatement History and Remaining Asbestos-Containing
Building Material (ACBM) at the 20 Sites 18
6 Airborne Asbestos Concentrations Measured During Periods of
Occupancy at 17 Schools in May 1991 19
7 Summary of ANOVA Results for Airborne Asbestos Concentrations
During Occupied Conditions in 1991 24
8 Overall Distribution of Asbestos Structures Measured
During Occupied Conditions at 20 Sites (percentages) 26
9 Overall Cumulative Size Distribution of Asbestos Structures
Measured During Occupied Conditions at 20 Sites (percentages) 26
10 Follow-up Air Monitoring Results at Ten Sites (Phase Ilia) 28
11 Follow-up Air Monitoring Results at Four Sites (Phase Illb) 29
12 Comparison of Air Monitoring Results at Sites Requiring Follow-up 30
13 Summary of NJDOH-EHS Visual Inspections Conducted in August 1991 30
14 Mean Concentrations of Airborne Asbestos Measured at 20 Sites
in 1988, 1990, and May 1991 32
Vill
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TABLES (continued
Number Page
15 Summary of ANOVA Results for Airborne Asbestos Concentrations
Measured in 1988,1990, and 1991 at 20 Sites 33
IX
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ACKNOWLEDGMENTS
This document was prepared for EPA's Office of Research and Development in
fulfillment of Contract No. 68-D2-0058. Aaron R. Martin served as the EPA Project
Officer, Thomas J. Powers served as the EPA Work Assignment Manager, and Alva
Edwards served as the EPA Technical Project Officer. Special appreciation is
extended to Patrick J. Clark of EPA's Risk Reduction Engineering Laboratory (RREL)
and to the staff of RREL's Transmission Electron Microscopy Laboratory for
conducting the analyses of the air samples. Also greatly appreciated are the
administrative efforts of Roger C. Wilmoth and Bruce A. Hollett of RREL.
This document was written by John R. Kominsky and Ronald W. Freyberg of
Environmental Quality Management, Inc. (EQ) and James A. Brownlee, Donald R.
Gerber, Gary J. Centifonti, and Richard M. Ritota of the New Jersey Department of
Health, Environmental Health Service(NJDOH-EHS). The authors also acknowledge
Mr. Edward Millerick of NJDOH-EHS for conducting the visual inspections of the eight
schools in August 1991.
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SECTION 1
INTRODUCTION
The ultimate goal of every asbestos abatement project is to eliminate or reduce, to
the extent possible, the actual or potential hazard presented by airborne asbestos
structures. From 1988 through 1991, the Risk Reduction Engineering Laboratory
(RREL) of the U.S. Environmental Protection Agency (EPA) and the Environmental
Health Service (EHS) of the New Jersey Department of Health (NJDOH) conducted a
series of studies to determine the effectiveness of asbestos control programs in 17
schools in New Jersey.1'2
Background
In 1988, the EPA-RREL and NJDOH-EHS conducted a study to document
Asbestos Hazard Emergency Response Act (AHERA) clearance air-sampling practices
and final clearance concentrations of airborne asbestos at 20 abatement projects in 17
New Jersey schools.1 The results of the study prompted a follow-up study in 1990
(Phase II) to determine the airborne asbestos concentrations in these 17 schools 2
years after abatement.2 Although the data from the 1990 study provided information
regarding airborne asbestos levels under simulated occupancy conditions, whether the
data were representative of conditions during actual occupancy remained equivocal.
Therefore, an additional follow-up study was conducted in May 1991 (Phase 111) to
determine the airborne asbestos levels during actual occupied conditions 3 years after
abatement in these same schools.
The purpose of this research study was to measure airborne asbestos
concentrations during occupied conditions at the seventeen schools that underwent
asbestos abatements in 1988. The seventeen schools were not a statistical random
sample and were initially selected based largely on availability. Furthermore, the
seventeen schools were likely to differ in their abatement history and status with
1
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1
respect to the presence of asbestos-containing material. Therefore, a site-by-site
evaluation was performed. There was no consideration given to combining data
across all sites to reach a general conclusion.
Objectives
The objectives of this study were as follows:
o To determine the airborne asbestos levels measured under occupied
conditions in 17 schools that underwent abatement in 1988.
0 To determine whether the airborne asbestos levels measured under
occupied conditions in 1991 were significantly different than those
measured outdoors.
o To determine whether the airborne asbestos concentrations measured in
1991 were significantly different from the AHERA clearance
concentrations measured in 1988.
o To determine whether the airborne asbestos concentrations measured
under occupied conditions in 1991 were significantly different from those
measured under simulated occupancy conditions in 1990.
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SECTION 2
CONCLUSIONS AND RECOMMENDATIONS
Conclusions
The following are the principal conclusions reached during this study:
0 Seven of the 20 sites (five of the 17 schools) sampled under occupied
conditions in 1991 showed significantly higher airborne asbestos
concentrations in the previously abated area and/or the perimeter area
than those existing outdoors. Differences in mean concentrations
between those measured inside the schools and those existing outdoors
were not statistically significant at the other 13 sites.
0 Eight of the 20 sites showed average airborne asbestos concentrations
above the AHERA initial screening criterion of 70 structures per square
millimeter. Visual inspections conducted by the New Jersey Department
of Health indicated that reentrainment of residual asbestos-containing
debris from the 1988 abatement or operations and maintenance activities
may have contributed to the elevated asbestos concentrations measured
in these schools.
0 Visual inspections conducted by the New Jersey Department of Health at
10 of the 20 sites showed that 6 sites had at least one asbestos-
containing material (ACM) that was not identified in the Asbestos
Management Plan. At one of these six sites, the Asbestos Management
Plan was in error regarding the identification, location, and condition of
ACM.
0 Three of the 20 sites showed significantly higher airborne asbestos
concentrations in the previously abated area and/or the perimeter area, in
1991 than those measured in 1988. Conversely, 9 of the 20 sites
showed significantly lower airborne asbestos concentrations in the
previously abated area and/or perimeter areas in 1991 than those
measured in 1988. Differences between mean concentrations measured
in 1988 and 1991 at the other 8 sites were not statistically significant.
0 The mean airborne asbestos concentrations measured in the previously
abated area and/or the perimeter area at 7 of the 20 sites during
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occupied conditions in 1991 were significantly greater than those
measured under simulated occupancy conditions in 1990. Conversely,
one site showed significantly lower concentrations during occupied
conditions than during simulated occupancy. Differences in mean
concentrations measured in 1990 and 1991 at the other 12 sites were
not statistically significant.
Recommendations
Follow-up air monitoring should be conducted at these sites to determine if
elevated post-abatement airborne concentrations of asbestos is continuing at these
schools. The follow-up air monitoring should be coupled with detailed visual
inspections to determine the sources of the asbestos and to identify appropriate
remedial measures. The results of the follow-up study will provide information
regarding the long-term effectiveness of asbestos control programs. This information
may assist EPA in evaluating the need for issuance of guidance on asbestos
management practices.
4
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SECTION 3
STUDY DESIGN AND METHODS
This study was conducted at the same 17 schools involved in the 1988 EPA-
RREL/NJDOH-EHS study, which documented Asbestos Hazard Emergency Response
Act (AHERA) air monitoring practices and final clearance concentrations of airborne
asbestos,1 and in the 1990 EPA-RREL/NJDOH-EHS study, which measured airborne
asbestos concentrations 2 years after abatement.2
The 17 schools involved 20 abatement sites. Access to each school was
coordinated directly by NJDOH-EHS. Area airborne asbestos concentrations were
measured at each site in the same three areas as in the previous studies: 1) the
previously abated area, 2) the perimeter area (outside the abated area but inside the
building), and 3) outdoors. The actual abatement and perimeter areas could not be
separated because the containment barriers present during the 1988 abatement had
been removed. Also recognized was the fact that, in the interim since 1988, other
sources (e.g., routine maintenance of asbestos-containing resilient floor tile or other
operations and maintenance activities) may have contributed to the current
concentrations of airborne asbestos.
Air Sampling Strategy
The air sampling strategy for the study consisted of monitoring during periods of
occupancy at all sites. In consideration of the resulting data, follow-up sampling was
conducted using a modified aggressive protocol at sites with average airborne
asbestos concentrations above 0.02 s/cm2. This follow-up monitoring was performed
to both 1) determine the need for response actions and 2) determine the completion of
the response actions. Table 1 summarizes the air sampling strategy.
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TABLE 1. SUMMARY OF AIR SAMPLING STRATEGY
Phase
III
Ilia
Illb
I lie
Period
May 1991
Early August
1991
Late August
1991
September 1991
No. of
Sites
20
10
4
1
Type of
Sampling
Occupied
Conditions
Modified
Aggressive
Modified
Aggressive
Modified
Aggressive
Criteria
All sites monitored to determine levels
8 sites - Average asbestos concentration >0.02
s/cm3 (70 s/mm2)
2 sites - in same schools as one of the eight
above
Following response action to attain <0.02 s/cm3
Following additional response action to attain
<0.02 s/cm3
Phase III - May 1991
At each site, five area air samples were collected in each of three areas: 1) the
previously abated work area, 2) the perimeter area (outside the previously abated
work area but inside the building), and 3) outdoors. Table 2 shows the number of air
samples collected at each site. The air samples were collected at approximately the
same locations as those collected during the 1988 and 1990 studies. In addition to
the area air samples, three quality assurance samples (one closed and two open field
blanks) were collected at each school.
The samples were collected during periods of occupancy (i.e., during school
hours, 8:00 am to 3:00 pm). Because certain sampling situations (e.g., inside a
classroom) could not tolerate noise from an electrically powered sampling pump, the
pumps were placed in special acoustical cases designed to attenuate the noise of the
sampling pump to a sound pressure level of <40 dB (RE 20 N/m2) at a distance of 3 ft.
A noise level of 40 dB is rated as "quiet" for private offices and conference rooms.3
Phase III Follow-up - Summer 1991
Follow-up air sampling in the previously abated work area and the perimeter
area was conducted during unoccupied conditions in accordance with a modified
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1
aggressive sampling protocol designed to simulate normal building activity. The
protocol involved sweeping only the floors with the exhaust of a 1-hp leaf blower at a
TABLE 2. NUMBER OF AREA AIR SAMPLES COLLECTED AT EACH SITE
DURING OCCUPIED CONDITIONS IN MAY 1991
Site
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
S
T
Total samples
Number of samples and location
Previously abated area
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
100
Perimeter
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
(5)°
5
5
5
95
Outdoors
5
5
5
5
5
5
5
5
5
5
5
5
(5)a
(5)b
5
5
(5)°
5
5
5
85
a Same samples as collected at Site C (i.e., Site M was the second abatement
project at this school).
b Same samples as collected at Site K (i.e., Site N was the second abatement
project at this school).
c Same samples as collected at Site B (i.e., Site Q was the second abatement
project at this school).
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rate of 5 minutes per 1,000 ft2 of floor space. One stationary fan (18-in. diameter,
axial flow) per 10,000 ft3 was positioned with the air directed toward the ceiling to
maintain air movement during sampling.
Phase Ilia - Early August 1991
Follow-up air monitoring was conducted in August 1991 at 10 of the 20 sites
(Sites B, D-H, K, M ,N, and Q). Sites B, D-G, K and M were selected because the
average airborne asbestos concentration in the previously abated area and/or
perimeter area exceeded 0.02 s/cm3. Sites N and Q were also monitored because
these sites were in the same schools as sites K and B, respectively, which had levels
exceeding 0.02 s/cm3. Site H was monitored because replicate analyses of selected
samples at this site showed average levels above 0.02 s/cm3 (derived from the
AHERA initial screening criteria of 70 s/mm2-40 CFR 763). At each of the 10 sites,
five area air samples were collected in the same three areas as the samples collected
during occupied conditions in May 1991: 1) the previously abated work area, 2) the
perimeter area, and 3) outdoors. Three quality assurance samples (one closed and
two open field blanks) also were collected at each school.
Phase Illb - Late August 1991
Based on the results of the Phase Ilia monitoring, four schools (Sites F, G, H,
and M) were required to conduct response actions (i.e., cleaning) in the previously
abated area and/or perimeter area to reduce residual airborne asbestos
contamination. Subsequent to these response actions, additional area air samples
were collected in the affected areas at these sites. At each of the four sites, five area
air samples were collected in the same areas as the Phase III and Phase Ilia samples
(no outdoor samples were collected at Site M). Three quality assurance samples (one
closed and two open blanks) also were collected at each school.
Phase I lie - September 1991
Airborne asbestos concentrations at Site M were still elevated after the Phase
Illb monitoring. Therefore, the previously abated area and the perimeter area
8
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response actions were again conducted, and additional samples were collected. Five
samples were collected in the previously abated area and five were collected in the
perimeter area. One closed and two open field blanks were also collected.
Previous Air Monitoring Strategies
Samples collected previously in 1988 were collected during the AHERA
clearance phase of the abatement. In the abatement work area, samples were
collected under the sampling conditions that existed during the final-clearance air
sampling. The perimeter area samples were collected under static conditions.
Samples collected previously in 1990 were collected in accordance with
modified aggressive sampling protocol designed to simulate normal building activity.
The protocol involved sweeping only the floors with the exhaust of a 1-hp leaf blower
and positioning one stationary fan per 10,000 ft3 with the air directed toward the ceiling
to maintain air movement during sampling. The air samples were collected at
approximately the same locations as those collected in 1988.
Site Documentation
For each of the 17 schools monitored in May 1991, the NJDOH-EHS
documented the history of the abatement activities between 1988 and 1991 and
operations and maintenance (O&M) activities on any remaining asbestos-containing
building material (ACBM) in the previously abated area and perimeter area. This
information was obtained from abatement notices required under the New Jersey
Administrative Codes (NJ.A.C. 8:60-7 and N.J.A.C. 12:120-7), AHERA Asbestos
Management Plans, and information provided by the designated person and/or school
officials who were interviewed.
NJDOH Visual inspection
Subsequent to conducting the follow-up air monitoring at the eight schools in
August 1991 (Phase Ilia), a certified AHERA building inspector from NJDOH-EHS
conducted a visual inspection at each of these schools.
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Prior to conducting the inspection, the inspector reviewed each school's
Asbestos Management Plan. The review included 1) recording the material category
(e.g., thermal system insulation), amount of material (e.g., linear feet), and condition of
material (e.g., damaged thermal system insulation) for the ACBM remaining in the
previously abated area and perimeter area; 2) recording completed response actions
(including O&M); and 3) recording any renovations that had occurred.
The visual inspection was not intended to be a comprehensive assessment of
the ACBM in the school; rather, it was designed to focus on the areas monitored (i.e.,
previously abated areas and perimeter areas) in an attempt to locate the possible
sources of the airborne asbestos contamination measured in May 1991. The
inspection included identification and condition of ACBM not recorded in the
Management Plan as well as the condition of the ACBM recorded in the Management
Plan, and the documentation of the presence of asbestos-containing dust and debris
located in the areas monitored.
Sampling Methods
Fixed-Station Area Air Samples
Air samples were collected on open-face, 25-mm-diameter, 0.45-jim-pore-size,
mixed cellulose ester (MCE) membrane filters with a 5-jim-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 approximately a 45-degree angle toward the floor. The filter assembly
was attached to a 1/6-hp electrically powered vacuum pump operating at a flow rate of
approximately 9 L/min. Air volumes ranged from 943 to 2536 L. At the end of the
sampling period, the filters were turned upright before being disconnected from the
vacuum pump; they were then stored in this position. The sampling pumps were
calibrated with a calibrated precision rotameter both immediately before and after
sampling.
10
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Bulk Samples
Bulk samples of suspect ACBM (e.g., thermal system insulation, fireproofing, and
resilient floor tile) or debris were collected by the NJDOH inspector for laboratory
analysis to determine the asbestos content. The samples were collected by either a
standard coring tool or the collection of debris. Both types of samples were placed in
labeled containers.
Analytical Methods
Air Samples
The MCE filters were prepared and analyzed in accordance with the
nonmandatory transmission electron microscopy (TEM) method, as described in the
AHERA final rule (40 CFR 763). A sufficient number of grid openings were analyzed
for each sample 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. The
samples were prepared and analyzed by U.S. EPA's TEM laboratory in Cincinnati,
Ohio.
Bulk Samples
The type and percentage of asbestos in the bulk samples were determined by
polarized light microscopy (PLM) and X-ray diffraction (XRD). The samples were
prepared and analyzed in accordance with the "Interim Method for Determination of
Asbestos in Bulk Insulation Samples" (EPA 600/M4-82-020). The samples were
prepared and analyzed by the NJDOH's Public Health and Environmental Laboratories
in Trenton, New Jersey.
Statistical Methods
All estimated concentrations were based on the number of asbestos structures
counted. If no asbestos structures were counted in a sample, that sample was
11
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assigned an estimated concentration of 0 s/cm3. Results of the quality assurance
sample analyses were not included in the statistical analysis of these data.
Airborne asbestos concentrations measured in each of the three sampling
locations were characterized by the use of descriptive statistics. Because the 20 sites
were likely to differ in their abatement history and status with respect to the presence
of asbestos-containing material, each site was considered separately. The descriptive
statistics included the arithmetic mean, minimum and maximum concentrations, and
sample size.
A single-factor analysis of variance (ANOVA) was used to examine differences
between concentrations measured in the previously abated work area, perimeter area,
and outdoors in 1991. Each site was evaluated separately. When overall differences
were detected among the three sampling locations, the Tukey multiple comparison
procedure was used to evaluate the pairwise differences. A single-factor ANOVA
analysis was also used to compare airborne asbestos concentrations measured in
1988, 1990, and 1991. Each sampling location was considered separately. The
transformation ln(x + 0.002), where x is the measured airborne asbestos
concentration, was applied to each measurement before the ANOVA or t-test was
performed. The transformation was used to make variances more equal and to
provide data that are better approximated by a normal distribution. The constant
0.002, a value chosen to be smaller than the majority of analytical sensitivities, was
used because some zero values were present (the natural logarithm of zero is
undefined). The transformation was used only for the ANOVA analysis; it was not
used for any other part of the data analysis (e.g., plots or descriptive statistics). All
statistical comparisons were performed at the 0.05 level of significance. Any
reference in this report to a "significant" difference between mean concentrations
implies that the difference is statistically significant.
12
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SECTION 4
QUALITY ASSURANCE
Sample Chain of Custody
During the study, sample chain-of-custody procedures were an integral part of
both the sampling and analytical activities and were followed for all air and bulk
samples collected. The field custody procedures documented each sample from the
time of its collection until its receipt by the analytical laboratory. Internal laboratory
records then documented the custody of the sample through its final disposition.
Standard sample chain-of-custody procedures were used. Each air sample was
labeled with a unique project identification number, which was recorded on a sample
data sheet along with other information, such as sampling date, location of the
sampler, sampling flow rate, sampling start/stop time, and conditions of sampling.
Sample Analysis
Specific quality assurance procedures outlined in the AHERA rule were used to
ensure the precision of the collection and analysis of air samples, including filter lot
blanks, open and closed field blanks, and repeated sample analyses.
Filter lot blanks, which are samples selected at random from the lot of filters
used in this study, were analyzed to determine background asbestos contamination on
the filters. Five percent (50 filters) of the total number of filters (2000 filters) from the
lot used in this research study were analyzed by the EPA-RREL TEM laboratory. The
filters were prepared and analyzed in accordance with the nonmandatory AHERA TEM
method. The TEM analysis of the 50 MCE filters showed a background contamination
level of 0 asbestos structures per 10 grid openings on each filter.
Open field blanks are filter cassettes that have been transported to the
sampling site, opened for a short time (<30 sec) without air having passed through the
13
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filter, and then sent to the laboratory. Closed field blanks are filter cassettes that have
been transported to the sampling site and sent to the laboratory without being opened.
Two open and one closed field blank were collected at each site. Ten grid openings
were examined on each filter. One asbestos structure was detected on an open field
blank and on a closed field blank.
The reproducibility and precision of the TEM analyses were determined by an
evaluation of repeated analyses of randomly selected samples. Repeated analyses
included replicate and duplicate analyses. A replicate analysis of 16 samples was
performed to assess the uniformity of the distribution of asbestos structures on a
single grid preparation. A replicate analysis is a second analysis of the same grid
performed by the same microscopist as the original analysis. The microscopist uses
the same grid preparation but counts different grid openings from those originally read.
The results of the replicate analyses are shown in Table 3.
A duplicate sample analysis of six samples was performed to assess the
reproducibility of the TEM analysis and to quantify any analytical variability resulting
from the filter preparation procedure. A duplicate analysis is the analysis of a second
TEM grid prepared from a different area of the sample filter but analyzed by the same
microscopist who performed the original analysis. The results of the duplicate
analyses are shown in Table 4.
The coefficient of variation (CV) for the replicate and duplicate analyses was
estimated by assuming a lognormal distribution for the data on the original scale and
estimating the variance on the log scale. The variance was estimated by the mean
square error obtained from a one-way ANOVA of the log-transformed data with the
sample identification number as the main factor. The transformation ln(x + 0.002),
where x is the measured airborne asbestos concentration, was applied to each
measurement before the ANOVA was performed. The constant 0.002, a value chosen
to be smaller than the minimum analytical sensitivity, was used because many zero
values were present. The CVs associated with the replicate and duplicate analyses
were 135 and 42 percent, respectively.
14
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TABLE 3. DATA SUMMARY FOR REPLICATE ANALYSES3
Sample
number
A91-09-P
D91-13-A
F91-11-A
H91-11-A
H91-12-A
H91-13-A
H91-14-A
H91-15-A
1-91 -01 -O
L91-07-P
N91-08-P
O91-07-P
P91-09-P
R91-13-A
S91-11-A
T91-15-A
Original analysis
Nb
0
2
10
5
1
0
1
0
0
2
1
0
0
1
0
2
s/cm3
0
0.006
0.035
0.014
0.003
0
0.003
0
0
0.006
0.003
0
0
0.003
0
0.007
Replicate analysis
Nb
1
4
8
1
5
33,3°
1
8
0
0
0
0
1
1
2
0
s/cm3
0.003
0.014
0.028
0.003
0.015
0.102, 0.009°
0.003
0.025
0
0
0
0
0.004
0.003
0.008
0
a Different grid openings from the same grid preparation were counted by the
same microscopist.
b Number of asbestos structures.
0 Two replicate analyses were performed on this sample.
15
-------
TABLE 4. DATA SUMMARY FOR DUPLICATE ANALYSES8
Sample
number
F91-12-A
F91-09-P
F91-10-P
H91-02-O
J91-15-A
O91-11-A
T91-05-O
Original analysis
Nb
10
7
15
1
0
7
0
s/cm3
0.066
0.025
0.054
0.003
0
0.022
0
Duplicate analysis
Nb
8
2
13
0
0
3
0
s/cm3
0.038
0.007
0.047
0
0
0.010
0
a A second TEM grid preparation was analyzed by the same microscopist.
b Number of asbestos structures.
Counts from the original sample analysis were also compared to the counts
from the corresponding replicate or duplicate sample analyses according to the
methods specified in the original Yamate air method,4 the Asbestos Hazard
Emergency Response Act (AHERA) Final Rule (40 CFR Part 763),5 and the original
QA guidelines from the EPA "Gold Book."6 The Yamate method calculates a 95
percent confidence interval for the observed number of asbestos structures on a
sample, assuming a Poisson distribution. If the counts for the replicate and/or
duplicate fall within the 95 percent confidence interval, then there is no statistically
significant difference between the counts. Only four samples exhibited statistically
significant differences between the original and replicate counts (H91-11-A, H91-12-A,
H91-13-A and H91-15-A). All four samples were from the same school and were
selected for replicate analysis because the original samples showed an uneven
distribution of counts from one grid opening to the next. Although the duplicate counts
were consistently lower than the original analyses, none of the differences were
statistically significant.
16
-------
SECTION 5
RESULTS AND DISCUSSION
Site Descriptions
Table 5 presents the post-1988 abatement history and the remaining ACBM at
the 20 sites. Post-1988 abatement occurred at 1 of the 20 sites (Site O) in the
previously abated area and 4 of the 20 sites (Sites A, D, L, and N) in the perimeter
area. At 15 sites, ACBM is still present in the previously abated areas; at all of the
sites, ACBM is still present in the perimeter areas.
Airborne Asbestos Levels During Occupied Conditions in May 1991
Table 6 presents the mean, minimum, and maximum airborne asbestos
concentrations measured at each of the 20 sites in the 17 schools. Figures 1 and 2
illustrate the average airborne asbestos concentrations in the previously abated and
perimeter areas, respectively. Figures 3 and 4 illustrate the average concentration of
asbestos structures per square millimeter (s/mm2) of filter in the previously abated
area and perimeter area, respectively, at each of the 20 sites. Eight of the 20 sites
showed levels above the AHERA initial screening criterion of 70 s/mm2 (40 CFR 763)
and above 0.02 s/cm3 (NJDOH clearance criteria). Individual measurements of the
airborne asbestos concentrations at each of the 20 sites are presented in Appendix A.
Individual single-factor ANOVAs were used to compare mean concentrations
measured in each of the three sampling locations at each site. The results of the
ANOVA analyses, along with the results from the Tukey multiple comparison
procedure, are presented separately for each site in Table 7. The remaining
subsections summarize the pairwise comparisons between mean concentrations in the
three sampling locations.
17
-------
TABLE 5. POST-1988 ABATEMENT HISTORY AND REMAINING ASBESTOS-
CONTAINING BUILDING MATERIAL (ACBM) AT THE 20 SITES
Site
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
S
T
Abatement afteM 988
Abatement
area
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
Perimeter
area
Yes
No
No
Yes
No
No
No
No
No
No
No
Yes
No
Yes
No
No
No
No
No
No
Material
abated3
AP, TSl
-
-
TSl
-
-
-
-
-
-
-
FT.TR
-
AP
TSl
-
-
-
-
-
Remaining ACBMa
Abatement
area
FT
FT, AP
P (<1%)b
TSl
FT, TSl
TSl
None
AP, TSl
None
TSl
None
FT.TR
P(<1%)
None
TR
FT
FT, AP
FT
FT
None
Perimeter
area
FT
FT, TSl
P (<1%)
TSl, FT
FT
FT, TSl
FT, P (<1%)
FT, AP
FT
FT
FT, TSl
FT
P(<1%)
FT, TSl
FT
FT
FT, TSl
FT
FT
FT.CT
a AP = Acoustical Plaster
TSl = Thermal System Insulation
FT = Floor Tile
TR = Transite
CT = Ceiling Tile
P = Wall Plaster
Asbestos is present at a concentration of less than 1 percent
18
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1
TABLE 7. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS DURING OCCUPIED CONDITIONS IN 1991
Site
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
S
T
ANOVA p-Valuea
0.1665
0.0002
0.8823
0.0899
0.0069
0.0001
0.0005
0.8699
0.6961
0.2878
0.0001
0.0752
0.1924
0.0125
0.2345
0.0891
0.0059
0,3899
0.5776
0.4214
Statistically significant differences in mean airborne
asbestos concentrationb|Cid
P(0.003) O(0.003) AfO.OOD
A(0.027) P(0.012) 0(0.001)
A(0.005) O(0.003) P(0.001)
A(0.020) P(0.004) O(0.004)
A(0.037) P(0.010) 0(0.003)
A(0.043) P(0.036) 0(0.001)
A(0.027) P(0.005) O(0.001)
P(0.005) A(0.004) O(0.003)
P(0.005) O(0.005) A(0.004)
A(0.003) O(0.001) P(0)
A(0.041) P(0.003) O(0)
A(0.006) P(0.003) O(0)
A(0.023) P(0.004) O(0.003)
P(0.015) A(0.004) O(0)
A(0.005) O(0.001) P(0)
A(0.004) PfO.OOD O(0)
P(0.012) A(0.009) O(0.001)
A(0.005) O(0.004) PfO.OOD
P(0.003) A(0.001) 0(0.001)
AfO.OOD P(0.001) O(0)
a If the ANOVA p-value was less than 0.05, then the Tukey multiple comparison
procedure was used to distinguish pairwise differences between sampling
locations.
b A = previously abated area; P = perimeter area; O = outdoors.
c Parenthetical entries are mean airborne asbestos concentrations (s/cm3)
associated with that sampling location.
rf Sampling locations (means) connected by a line are not statistically significantly
different. For example, at Site B, the average levels in the previously abated area and
perimeter area are not significantly different, but are both significantly greater than the average
level outdoors.
24
-------
Comparison of Previously Abated Area With Outdoors
At 6 of the 20 sites (Sites B, E, F, G, K, and Q) mean airborne asbestos
concentrations in the previously abated area were significantly higher than those
outdoors. Mean concentrations in the previously abated area were at least one order
of magnitude (i.e., 10 times) greater than the mean concentrations outdoors. At all of
the other 14 sites, the difference between mean levels in the previously abated areas
and outdoors was not statistically significant.
Comparison of Perimeter Area With Outdoors
At 4 of the 20 sites (Sites B, F, N, and Q) mean airborne asbestos
concentrations in the perimeter area were significantly higher (at least one order of
magnitude) than those outdoors. At the remaining 16 sites, the difference between
mean levels in the perimeter areas and outdoors was not statistically significant.
Comparison of Previously Abated Area With the Perimeter Area
At 3 of the 20 sites (Sites E, G, and K) mean airborne asbestos concentrations
in the previously abated area were significantly greater than those in the perimeter
area. Mean concentrations in the previously abated area were approximately 4 times
greater than those in the perimeter area at Site E, approximately 5 times greater at
Site G, and approximately 14 times greater at Site K. At all of the other 17 sites, the
difference between mean concentrations in the previously abated area and the
perimeter areas was not statistically significant.
Overall Structure Morphology and Length Distributions
Table 8 presents the overall distribution of structure type and morphology at
each sampling location. The TEM analysis of 100 samples collected during occupied
conditions in the previously abated area, 94 samples collected in the perimeter area,
and 85 samples collected outdoors yielded a total of 601 asbestos structures, 99.7
percent of which were chrysotile asbestos and 0.3 percent were amphibole. Overall,
the asbestos structures were primarily fibers (66 percent), and to a lesser extent,
25
-------
matrices, bundles, and clusters. Appendix B contains the asbestos type and structure
morphology distributions individually for Sites A through T.
TABLE 8. OVERALL DISTRIBUTION OF ASBESTOS STRUCTURES
MEASURED DURING OCCUPIED CONDITIONS AT 20 SITES
(percentages)
Sampling location
Previously abated area
Perimeter area
Outdoors
Type of asbestos
Chrysotile
99.7
100
99.4
Amphibole
0.3
0
0.6
Structure morphology
Fibers
67.1
85.7
59.2
Bundles
4.2
0
3.6
Clusters
3.7
0
2.4
Matrices
25.1
14.3
34.9
Table 9 presents the overall cumulative size distribution of asbestos structures
from samples collected at the 20 sites during occupied conditions. Overall, 1.5
percent of the measured asbestos structures were greater than 5 |im in length; most
of the structures (92 percent) were less than 2 jirn in length.
TABLE 9. OVERALL CUMULATIVE SIZE DISTRIBUTION OF ASBESTOS
STRUCTURES MEASURED DURING OCCUPIED CONDITIONS AT 20 SITES
(percentages)
Sample
location
Previously abated area
Perimeter area
Outdoors
Structure length, u.m
<1
70.5
61.5
67.3
<2
94.5
87.6
91.8
<3
98.4
94.1
93.9
<4
99.0
97.0
93.9
<5
99.0
98.2
95.9
<10
99.2
100
100
26
-------
Phase III Follow-up Air Monitoring - August 1991
Follow-up air monitoring was conducted by EPA-RREL/NJDOH-EHS in August
1991 at 10 of the 20 sites (B, D-H, K, M, N, and Q). Table 10 presents the results of
the follow-up air monitoring at these 10 sites. These results indicate that four sites (F:,
G, H, and M) showed average levels exceeding 0.02 s/cm3 (NJDOH clearance criteria)
in both the previously abated area and the perimeter areas. Based on the results at
these four sites, NJDOH-EHS required response action at each of the four schools.
Three of the four schools employed licensed asbestos-abatement contractors and one
used in-house, trained staff to conduct response actions to reduce the levels of
airborne asbestos.
Subsequent to the response actions at these four schools, EPA-RREL7NJDOH-
EHS conducted follow-up air monitoring to determine the residual levels of airborne
asbestos. Table 11 presents the results of this follow-up monitoring. Based on these
results, NJDOH-EHS determined that further action was required at Site M. Further
response actions were performed at this school, and NJDOH-EHS collected additional
samples. The final results showed an average concentration of 0.005 s/cm3 in the
previously abated area and 0 s/cm3 in the perimeter area; therefore, no further action
was required at this school. Table 12 presents a comparison of the air monitoring
results at the sites requiring follow-up from the initial monitoring through completion of
the response actions.
NJDOH Visual Inspections
Table 13 presents a summary of the visual inspections conducted by the
NJDOH-EHS in August 1991. The case history for each of the sites is provided in
Appendix C.
Asbestos-containing debris (including fireproofing, TSI, ceiling tile, and plaster
dust) was present at all of the 10 sites. The sources of the debris were the 1988
abatement, abatements that occurred after 1988, and/or O&M activities.
27
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TABLE 12. COMPARISON OF AIR MONITORING RESULTS AT SITES
REQUIRING FOLLOW-UP
Site
F
K
E
H
B
G
M
D
N
Q
Previously abated area
Mean asbestos concentration, s/cm3
III
May
1991
0.043
0.041
0.037
0.004a
0.027
0.027
0.023
0.020
0.004
0.009
Ilia
Early Aug.
1991
0.023
0.004
0.005
0.035
0.018
0.048
0.033
0.016
0.003
0.005
Illb
Late Aug.
1991
0
0.016
0.010
0.001
flic
Sept.
1991
0.005
Perimeter area
Mean asbestos concentration, s/cm3
III
May
1991
0.036
0.003
0.010
0.005
0.012
0.005
0.004
0.004
0.015
0.012
Ilia
Early Aug.
1991
0.024
0.001
0.010
0.013
0.001
0.063
0.013
0
0.002
0.001
Illb
Late Aug.
1991
0.003
0
0.004
0.029
life
Sept.
1991
0
If the QA/QC replicate analyses are included, the average concentration is 0.03 s/cm3.
TABLE 13. SUMMARY OF NJDOH-EHS VISUAL INSPECTIONS
CONDUCTED IN AUGUST 1991
Asbestos-containing debris present
ACBM present, not identified in
Management Plan
Misidentification and location of ACBM
in Management Plan
Sites
B
X
X
C
X
D
X
E
X
X
F
X
X
X
G
X
H
X
X
K
X
X
M
X
o
X
X
Total
10
6
1
30
-------
Six sites (B, E, F, K, H and Q) contained at least one asbestos-containing
building material not identified in the original AHERA inspection; i.e., the original
AHERA inspection did not record the presence of this material in the Management
Plan for the school. The previously unidentified materials included ventilation duct
insulation and TSI. (These data were provided to the school officials, and the schools
have reportedly corrected their Management Plans accordingly.)
At one site (Site F), the Management Plan was in error regarding the
identification and location of ACM. The Management Plan indicated the presence of
spray-on materials. No spray-on materials were present; however, TSi was found.
(These data were provided to the school officials, and the school has reportedly
corrected its Management Plan accordingly.)
Comparison of 1988,1990, and 1991 Results
Table 14 presents the arithmetic mean concentrations of airborne asbestos
measured in the previously abated area, perimeter area, and outdoors during Phase I
(post-abatement, 1988), Phase II (simulated occupancy, 1990), and Phase HI
(occupied conditions, 1991) for all 20 sites. Individual single-factor ANOVAs were
used to compare mean concentrations measured in 1988,1990, and 1991. Each site
and sampling location was evaluated separately. The results of the ANOVA analyses
along with the results from the Tukey multiple comparison procedure are presented in
Table 15. The remaining subsections summarize the pairwise comparisons of mean
concentrations measured in 1988, 1990, and 1991. Figures D-1 through D-20 in
Appendix D illustrate the average airborne asbestos concentrations in 1988,1990, and
1991 in all three sampling locations.
Post-Abatement (1988) vs. Simulated Occupancy (1990)
Previously Abated Area
On average, concentrations measured during simulated occupancy (1990) in
the previously abated area were significantly less than the post-abatement
31
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32
-------
TABLE 15. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, AND 1991 AT 20 SITES
Site
Location
ANOVA
p-valuea
Statistically significant differences
in mean airborne asbestos
concentrations"'0
Previously abated area
Perimeter area
Outdoors
0.4892
0.3819
0.0007
1990(0.007) 1988(0.002) 1991(0.001)
1990(0.011) 1991(0.003) 1988(0.001)
1991(0.003) 1990(0) 1988(0)
B
Previously abated area
Perimeter area
Outdoors
0.4446
0.4684
0.9941
1991(0.027) 1988(0.016) 1990(0.015)
1991(0.012) 1990(0.010) 1988(0.008)
1991(0) 1990(0) 1988(0)
Previously abated area
Perimeter area
Outdoors
0.0042
0.9308
0.2473
1988(0.060) 1991(0.005) 1990(0.001)
1988(0.002) 1991(0.001) 1990(0.001)
1988(0.004) 1991(0.003) 1990(0)
Previously abated area
Perimeter area
Outdoors
0.0002
0.0001
0.0003
1988(0.070) 1991(0.020) 1990(0.001)
1988(0.062) 1991(0.004) 1990(0.001)
1988(0.052) 1991(0.004) 1990(0)
Previously abated area
Perimeter area
Outdoors
0.0001
0.0690
0.0213
1991(0.037) 1990(0.004) 1988(0)
1991(0.010) 1990(0.006) 1988(0)
1991(0.003) 1990(0) 1988(0)
(continued)
33
-------
TABLE 15 (continued)
Site
F
G
H
I
J
K
Location
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
ANOVA
p-valuea
0.0001
0.0013
0.6080
0.0010
0.2247
0.3974
0.0024
0.0004
0.1151
0.1102
0.2217
0.5078
0.0144
0.0797
0.6186
0.001
0.5854
0.3966
Statistically significant differences
in mean airborne asbestos
concentrations"3-0
1991(0.043) 1988(0.024) 1990(0.001)
1991(0.036) 1990(0.005) 1988(0.002)
1991(0.001) 1988(0.001) 1990(0)
1991(0.027) 1988(0.007) 1990(0.001)
1988(0.010) 1991(0.005) 1990(0.001)
1991(0.001) 1990(0.001) 1988(0)
1988(0.016) 1991(0.004) 1990(0)
1988(0.062) 1991(0.005) 1990(0)
1988(0.003) 1991(0.003) 1990(0)
1991(0.003) 1990(0.001) 1988(0)
1990(0.011) 1991(0.005) 1988(0)
1991(0.005) 1988(0.005) 1990(0.001)
1988(0.004) 1991(0.003) 1990(0)
1990(0.003) 1988(0.001) 1991(0)
1991(0.001) 1988(0.001) 1990(0)
1988(0.063) 1991(0.041) 1990(0)
1988(0.008) 1990(0.007) 1991(0.003)
1990(0.001) 1991(0) 1988(0)
(continued)
34
-------
TABLE 15 (continued)
Site
L
M
N
0
P
Q
Location
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
ANOVA
p-valuea
0.0001
0.0001
0.1453
0.0001
0.0597
0.1078
0.0001
0.2257
0.0004
0.2858
0.3603
0.8955
0.8002
0.0118
0.3966
0.0047
0.1365
0.1927
Statistically significant differences
in mean airborne asbestos
concentrations"'0
1988(0.118) 1991(0.006) 1990(0.002}
1988(0.060) 1991(0.003) 1990(0.001)
1988(0.004) 1990(0) 1991(0)
1988(0.322) 1991(0.023) 1990(0)
1991(0.004) 1988(0.002) 1990(0)
1991(0.003) 1988(0.002) 1990(0)
1988(0.100) 1990(0.007) 1991(0.004)
1991(0.015) 1990(0.004) 1988(0.003)
1988(0.004) 1990(0.001) 1991(0)
1988(0.040) 1991(0.005) 1990(0.001)
1990(0.018) 1988(0.003) 1991(0)
1988(0.001) 1990(0.001) 1991(0.001)
1988(0.005) 1990(0.005) 1991(0.004)
1988(0.007) 1991(0.001) 1990(0)
1988(0.003) 1990(0) 1991(0)
1988(0.099) 1990(0.019) 1991(0.009)
1988(0.055) 1991(0.012) 1990(0.010)
1988(0.007) 1990(0.001) 1991(0.001)
(continued)
35
-------
TABLE 15 (continued)
Site
R
S
T
Location
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
Previously abated area
Perimeter area
Outdoors
ANOVA
p-valuea
0.0423
0.0086
0.0336
0.1587
0.5419
0.3966
0.0001
0.0129
0.2324
Statistically significant differences
in mean airborne asbestos
concentrations"-0
1991(0.005) 1988(0.002) 1990(0)
1990(0.011) 1991(0.001) 1988(0)
1990(0.013) 1991(0.004) 1988(0)
1988(0.012) 1990(0.003) 1991(0.001)
1988(0.003) 1991(0.003) 1990(0.001)
1991(0.001) 1988(0) 1990(0)
1988(0.049) 1990(0.001) 1991(0.001)
1988(0.030) 1990(0.001) 1991(0.001)
1988(0.015) 1990(0.005) 1991(0)
a If the ANOVA p-value was less than 0.05, then the Tukey multiple comparison
procedure was used to distinguish pain/vise differences between mean
concentrations measured in 1988, 1990, 1991.
b Parenthetical entries are mean airborne asbestos concentrations (s/cm3)
associated with that year's monitoring.
c Years (means) connected by a line are not statistically significantly different. For
example, the average level measured in the previously abated area at Site C was
significantly greater in 1988 than in 1990 and 1991; the difference between the average
levels measured in 1990 and 1991 was not statistically significant.
36
-------
concentrations (1988) at 11 of the 20 sites (Sites C, D, F, H, J-N, Q, and T). At the
remaining nine sites, no significant differences were noted.
Perimeter Area
On average, concentrations measured during simulated occupancy (1990) in
the perimeter area were significantly less than the post-abatement concentrations
(1988), at 5 of the 20 sites (Sites D, H, L, P, and T). At only one of the sites was the
mean concentration significantly greater during simulated occupancy than during post
abatement (Site R). At the remaining 14 sites, no significant differences were noted.
Outdoors
On average, concentrations measured outdoors in 1990 were significantly less
than concentrations measured in 1988 at 2 of the 20 sites (Sites D and N). At only
one site was the mean outdoor concentration greater in 1990 than in 1988 (Site R).
At the remaining 17 sites, no significant differences were noted.
Post-Abatement (1988) vs. Occupied Conditions (1991)
Previously Abated Area
On average, concentrations measured in the previously abated area during
occupied conditions (1991) were significantly less than the post-abatement
concentrations (1988) at 8 of the 20 sites (Sites C, D, H, L-N, Q, and T). At two sites
(Sites E and G), mean concentrations of airborne asbestos were significantly higher in
the previously abated area during occupied conditions in 1991 than post-abatement in
1988. At the remaining 10 sites, no significant differences were noted.
Perimeter Area
On average, concentrations measured in the perimeter area during occupied
conditions (1991) were significantly less than the post-abatement concentrations
(1988) at 5 of the 20 sites (Sites D, H, L, P, and T). At only one of the sites (Site F)
was the mean concentration significantly greater during occupied conditions than post
abatement. At the remaining 14 sites, no significant differences were noted.
37
-------
Outdoors
On average, concentrations measured outdoors in 1991 were significantly less
than concentrations measured in 1988 at 2 of the 20 sites (Sites D and N). The mean
outdoor concentration was greater in 1991 than in 1988 at two sites (Sites A and E).
At the remaining 16 sites, no significant differences were noted.
Simulated Occupancy (1990) vs. Occupied Conditions (1991)
Previously Abated Area
On average, concentrations measured in the previously abated area during
occupied conditions (1991) were significantly greater than those measured during
simulated occupancy (1990) at 7 of the 20 sites (Sites D-G, K, M, and R). At the
remaining 13 sites, no significant differences were noted.
Perimeter Area
On average, concentrations measured during occupied conditions (1991) were
significantly greater than those measured in the perimeter area during simulated
occupancy (1990) at only 1 of the 20 sites (Site F). Conversely, on average, Site R
showed significantly greater concentrations during simulated occupancy than during
actual occupied conditions. At the remaining 12 sites, no significant differences were
noted.
Outdoors
Mean outdoor concentrations of airborne asbestos measured in 1991 were
significantly greater than concentrations measured in 1990 at 2 of the 20 sites (Sites A
and E). At the remaining 16 sites, no significant differences were noted.
38
-------
REFERENCES
1. Kominsky, J. R., R. W. Freyberg, J. A. Brownlee, D. R. Gerber, and J. H.
Lucas. Observational Study of Final Cleaning and AHERA Clearance
Sampling. EPA/600/S2-89/047, U.S. Environmental Protection Agency,
Cincinnati, Ohio, January 1990.
2. Kominsky, J. R., R. W. Freyberg, J. A. Brownlee, and D. R. Gerber. Asbestos
Concentrations Two Years After Abatement in Seventeen Schools. Final
Report. U.S. Environmental Protection Agency, Cincinnati, Ohio, September
1991.
3. Beranek, L. L, J. L Marshall, A. L Cudworth, and A. P. G. Peterson. The
Calculation and Measurement of the Loudness of Sounds. J. Acoust. Soc. of
Am., 23(3):261-269, 1951.
4. Yamate, G., S.C. Agarwal, and R.D. Gibbons, Methodology for the
measurement of airborne asbestos by electron microscopy. Draft Report,
USEPA Contract 68-02-3266, 1984.
5. United States Environmental Protection Agency. Asbestos-Containing Materials
in Schools: Final Rule and Notice. Federal Register, 40 CFR Part 763,
Appendix A to Subpart E., October 30, 1987.
6. United States Environmental Protection Agency. Transmission Electron
Microscopy Asbestos Laboratories Quality Assurance Guidelines. EPA 560/5-
90-002, December, 1989.
39
-------
APPENDIX A
INDIVIDUAL ESTIMATES OF AIRBORNE ASBESTOS CONCENTRATIONS
THREE YEARS AFTER ABATEMENT (1991) AT 20 SITES
40
-------
APPENDIX A
INDIVIDUAL ESTIMATES OF AIRBORNE ASBESTOS CONCENTRATIONS
THREE YEARS AFTER ABATEMENT (1991) AT 20 SITES
Sample
Site date
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
C
C
C
C
C
C
C
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
Sample
number
A91-11-A
A91-12-A
A91-13-A
A91-14-A
A91-15-A
A91-01-0
A9 1-02-0
A9 1-03-0
A91-04-0
A91-05-0
A91-06-P
A91-07-P
A91-08-P
A91-09-P
A91-09-PR
A91-10-P
B91-11-A
B91-12-A
B91-13-A
B91-14-A
B91-15-A
BQ91-01-0
BQ91-02-O
BQ91-03-O
BQ91-04-0
BQ91-05-O
BQ91-06-P
BQ91-07-P
BQ91-08-P
BQ91-09-P
BQ91-10-P
B-891-11A
B-891-12A
B-891-13A
B-891-14A
B-891-15A
BQ-8 91-01
BQ-8 91-02
BQ-891-03
BQ-8 9 1-0 4
BQ-8 91-0 5
BQ-8 91-0 6
BQ-8 9 1-0 7
BQ-8 9 1-0 8
BQ-891-09
BQ-891-10
C91-11-A
C91-12-A
C91-13-A
C91-14-A
C91-15-A
C91-01-0
C91-02-0
Sampling locataion
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Replicate of A91-09-P
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors .
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Concentration
s/cm3 s/mm2
0
0
0
0.003
0
0.003
0.005
Q
0.005
0.003
0.003
o
0.005
o
0.003
0.008
0.014
0.044
0.014
0.055
0.010
o
o
o
0. 004
o
0.014
0.011
0.004
0.007
0.024
0.013
0.009
0.064
0
0.004
0.005
o
o
Q
o
o
0.005
o
Q
o
0.012
0
0.003
0
0.009
0
0
0
0
16
0
16
31
31
16
16
n
\j
31
o
18
47
71
232
71
286
54
o
n
\j
18
71
54
18
36
125
54
36
232
0
18
18
o
n
\j
o
o
18
n
L/
o
63
0
16
0
47
0
Air
Volume, L
2340
2311
2279
2282
1851
2256
2250
2239
2258
2346
2256
2239
2239
2227
2016
2016
2010
2010
1986
1 QOP
J_ -xU O
1 Q7O,
J. y I \J
1 Q44
J. -^*i *i
1 Q4 4
1914
1884
1946
1980
2025
1558
1513
1391
1488
1566
1352
1 & R £
J. T O O
1 R/l 7
JL 3*i /
1^91
1488
i di n
1436
1961
1984
1961
1972
1915
o c o c
^OOQ
2528
(continued)
41
-------
I
I
I
I
I
I
i
i
I
i
i
i
i
i
i
I
i
i
i
APPENDIX A (continued)
Sample
Site date
C
C
C
C
C
C
C
C
D
D
D
D
D
D
D
D
D
D
D
D
D
'D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
08/12/91
08/12/91
08/12/91
Sample
number
C91-03-0
C91-04-0
C91-05-0
C91-06-P
C91-07-P
C91-08-P
C91-09-P
C91-10-P
D91-11-A
D91-12-A
D91-13-A
D91-13-AR
D91-14-A
D91-15-A
D91-01-0
D91-02-0
D91-03-0
D91-04-0
D91-05-0
D91-06-P
D91-07-P
D91-08-P
D91-09-P
D91-10-P
D-891-11A
D-891-12A
D-891-13A
D-891-14A
D-891-15A
D-891-01O
D-891-020
D-891-030
D-891-04O
D-891-050
D-891-06P
D-891-07P
D-891-08P
D-891-09P
D-891-10P
E91-11-A
E91-12-A
E91-13-A
E91-14-A
E91-15-A
E91-01-0
E91-02-0
E91-03-0
E91-04-0
E91-05-0
E91-06-P
E91-07-P
E91-08-P
E91-09-P
E91-10-P
E-891-11A
E-891-12A
E-891-13A
Sampling locataion
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Replicate of D-91-13-A
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Concentration
s/cm3 s/mmz
0.007
0.005
0.002
0
0.003
0
0
0
0.012
0.059
0.006
0.014
0.020
0.003
0.003
0.012
0.002
0.003
0
0.008
0.003
0
0.009
0.003
0
0.058
0.010
0.014
0
0.005
0
o
0
0
0
0
o
0
o
0.011
0.069
0.042
0.029
0.032
0.007
0.007
o
0.003
o
0.003
0.003
0.029
0.015
0
0.025
0
0
47
31
16
0
16
0
0
0
63
297
31
71
109
16
16
63
13
16
0
42
14
0
47
16
0
214
36
54
0
18
0
o
o
0
0
0
0
0
0
54
357
232
161
161
36
36
o
18
o
16
16
143
71
o
89
0
0
Air
Volume, L
2528
2512
2504
1995
2006
1898
1990
1790
2063
1948
2028
2028
2058
2023
1995
1995
1966
1955
1972
2052
2052
2058
2081
2052
1506
1434
1417
1479
1496
1469
1434
1442
1477
1451
1469
1443
1451
1524
1534
1921
1989
2142
2135
1921
2094
2100
1 Q^l
j- y J x
2094
?OQd
£. w y T
1910
1943
1910
1887
1853
1377
1371
1328
(continued)
42
-------
APPENDIX A (continued)
Sample
Site date
E
E
E
E
E
E
E
E
E
E
E
E
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
05/09/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/12/91
08/28/91
08/28/91
08/28/91
08/28/91
08/28/91
08/28/91
08/28/91
08/28/91
08/28/91
08/28/91
08/28/91
Sample
number
E-891-14A
E-891-15A
E-891-010
E-891-02O
E-891-030
E-891-040
E-891-050
E-891-06P
E-891-07P
E-891-08P
E-891-09P
E-891-10P
F91-11-A
F91-11-AR
F91-12-A
F91-12-AD
F91-13-A
F91-14-A
F91-15-A
F91-01-0
F91-02-0
F91-03-0
F91-04-0
F91-05-0
F91-06-P
F91-07-P
F91-08-P
F91-09-P
F91-09-PD
F91-10-P
F91-10-PD
F-891-11A
F-891-12A
F-891-13A
F-891-14A
F-891-15A
F-891-010
F-891-020
F-891-030
F-891-04O
F-891-050
F-891-06P
F-891-07P
F-891-08P
F-891-09P
F-891-10P
F-8B91-11
F-8B91-12
F-8B91-13
F-8B91-14
F-8B91-15
F-8B91-01
F-8B91-02
F-8B91-03
F-8B91-04
F-8B91-05
F-8B91-06
Sampling locataion
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Replicate of F91-11-A
Previously abated area
Duplicate of F91-12-A
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Duplicate of F91-09-P
Perimeter area
Duplicate of F91-10-P
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Concentration
s/crrr' s/mm2
0
0
0.005
0
0
0
0
0.010
0
0.030
0.010
0
0.035
0.028
0.066
0.038
0.039
0.042
0.032
0
0
0.002
0
0
0.010
0.058
0.035
0.025
0.007
0.054
0.047
0.037
0.014
0.029
0.015
0.019
0
0.005
0.010
0.005
0
0.046
0.047
0.010
0
0.019
0
0
0
0
0
0
0.004
0
0
0
0.005
0
0
18
0
0
0
0
36
0
107
36
0
179
143
339
196
196
214
161
0
0
13
0
0
54
304
179
125
36
268
232
143
54
107
54
71
0
18
36
18
0
161
161
36
0
71
0
0
0
0
0
0
18
0
0
0
18
Air
Volume, L
1328
1328
1433
1440
1415
1438
1420
1388
1395
1386
1401
1484
1976
1976
1976
1976
1944
1980
1932
1995
1995
1983
1989
1976
2037
2019
1989
1944
1944
1907
1907
1477
1440
1424
1381
1414
1345
1387
1362
1345
1337
1354
1319
1354
1380
1431
1695
1588
1598
1543
1499
1471
1648
1551'
1410
1419
1527
(continued)
43
-------
APPENDIX A (continued)
Sample
Site date
F
F
F
F
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
H
H
H
H
H
H
H
H
08/28/91
08/28/91
08/28/91
08/28/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/26/91
08/26/91
08/26/91
08/26/91
08/26/91
08/26/91
08/26/91
08/26/91
08/26/91
08/26/91
08/26/91
08/26/91
08/26/91
08/26/91
08/26/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
Sample
number
F-8B91-07
F-8B91-08
F-8B91-09
F-8B91-10
G91-11-A
G91-12-A
G91-13-A
G91-14-A
G91-15-A
G91-01-0
G91-02-0
G91-03-0
G91-04-0
G91-05-0
G91-06-P
G91-07-P
G91-08-P
G91-09-P
G91-10-P
G-891-11A
G-891-12A
G-891-13A
G-891-14A
G-891-15A
G-891-010
G-891-020
G-891-030
G-891-040
G-891-050
G-891-06P
G-891-07P
G-891-08P
G-891-09P
G-891-10P
G-8B91-11
G-8B91-12
G-8B91-13
G-8B91-14
G-8B91-15
G-8B91-01
G-8B91-02
G-8B91-03
G-8B91-04
G-8B91-05
G-8B91-06
G-8B91-07
G-8B91-08
G-8B91-09
G-8B91-10
H91-11-A
H91-11-AR
H91-12-A
H91-12-AR
H91-13-A
H91-13-AR
H91-13-AR
H91-14-A
Sampling locataion
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Replicate of H91-11-A
Previously abated area
Replicate of H91-12-A
Previously abated area
Replicate of H91-13-A
Replicate of H91-13-A
Previously abated area
Concentration
s/cm3 s/mmz
0.004
0.008
0
0
0.032
0.025
0.011
0.030
0.037
0.003
o
0.004
0
0
0
0
0.011
0.007
0.007
0.028
0.080
0.068
0.035
0.029
0.015
0.015
0.013
0.009
0.015
0.022
0.181
0.029
0.034
0.051
0
0.005
0.044
0
0
0.005
o
o
0.004
0 .015
0.009
0.010
0
0
0
0.014
0.003
0.003
0.015
0
0.102
0.009
0.003
18
36
o
0
161
125
54
143
179
18
o
18
o
o
o
o
54
36
36
107
286
250
125
107
54
54
54
36
54
89
643
107
125
196
0
18
161
0
0
18
o
0
18
36
36
0
o
o
78
18
16
89
0
589
54
16
Air
Volume, L
1687
1657
1648
1671
1921
1921
1910
1859
1881
1994
1 Q44
x y^t ^
1921
1882
1910
1904
1938
1927
1926
1835
1452
1381
1417
1390
1443
1389
1416
1544
1480
1416
1543
1371
1444
1426
1479
1587
1385
1394
1424
1404
1440
1287
i ^nn
-LO U \J
1547
1471
-L T £, JL.
1500
1415
1347
1434
144^
-L T ^t -J
2220
2220
2258
2258
2233
2233
2233
2264
(continued)
44
-------
APPENDIX A (continued)
Sample
Site date
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
I
I
I
I
I
I
I
I
I
I
I
I
I
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
04/30/91
08/15/91
08/15/91
08/15/91
08/15/91
08/15/91
08/15/91
08/15/91
08/15/91
08/15/91
08/15/91
08/15/91
08/15/91
08/15/91
08/15/91
08/15/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
05/06/91
Sample
number
H91-14-AR
H91-15-A
H91-15-AR
H91-01-0
H9 1-02-0
H91-02-OD
H9 1-03-0
H91-04-0
H91-05-0
H91-06-P
H91-07-P
H91-08-P
H91-09-P
H91-10-P
H-891-11A
H-891-12A
H-891-13A
H-891-14A
H-891-15A
H-891-010
H-891-020
H-891-030
H-891-040
H-891-050
H-891-06P
H-891-07P
H-891-08P
H-891-09P
H-891-10P
H-8B91-11
H-8B91-12
H-8B91-13
H-8B91-14
H-8B91-15
H-8B91-01
H-8B91-02
H-8B91-03
H-8B91-04
H-8B91-05
H-8B91-06
H-8B91-07
H-8B91-08
H-8B91-09
H-8B91-10
I91-11-A
I91-12-A
I91-13-A
I91-14-A
I91-15-A
191-01-0
I91-01-OR
191-02-0
191-03-0
191-04-0
191-05-0
I91-06-P
I91-07-P
Sampling locataion
Replicate of H91-14-A
Previously abated area
Replicate of H91-15-A
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Replicate of 191-01-0
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Concentration
s/cirr1 s/mmz
0.003
0
0.025
0
0.003
0
0.003
0.005
0.003
0.011
0.008
0
0
0.008
. 0.061
0.005
0.048
0.050
0.011
0
0
0
0
0
0.005
0.020
0
0.014
0.025
0.073
0
0
0
0.005
0
0.005
0
0
0
0
0
0
0
0
0
0.004
0.004
0
0.007
0
0
0
0
0.020
0.004
0.004
0.007
18
0
143
0
16
0
16
31
16
63
47
0
0
47
196
18
179
179
36
0
0
0
0
0
18
71
0
54
89
268
0
0
0
18
0
18
0
0
0
0
0
0
0
0
0
18
18
0
36
0
0
0
0
89
18
18
36
Air
Volume, L
2264
2187
2187
2200
2216
2216
2221
2203
2221
2282
2256
2287
2256
2258
1240
1251
1428
1385
1263
1348
1453
1549
1365
1401
1470
1410
1335
1505
1360
1414
1306
1289
1414
1324
1401
1308
1336
1403
1245
1314
1350
1306
1314
1350
1881
1898
1881
1921
1870
1712
1712
1712
1697
1727
1727
1927
1921
(continued)
45
-------
I
I
I
I
I
I
i
I
I
I
I
I
i
i
!
I
I
i
I
I
I
I
APPENDIX A (continued)
Sample
Site date
I
I
I
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
K
L
L
L
L
L
L
L
L
05/06/91
05/06/91
05/06/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
. 05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
Sample
number
I91-08-P
I91-09-P
I91-10-P
J91-11-A
J91-12-A
J91-13-A
J91-14-A
J91-15-A
J91-15-AD
J91-01-0
J91-02-0
J9 1-03-0
J91-04-0
J91-05-0
J91-06-P
J91-07-P
J91-08-P
J91-09-P
J91-10-P
K91-11-A
K91-12-A
K91-13-A
K91-14-A
K91-15-A
KN91-01-0
KN91-02-0
KN 9 1-0 3-0
KN91-04-0
KN91-05-0
K91-06-P
K91-07-P
K91-08-P
K91-09-P
K91-10-P
K-891-11A
K-891-12A
K-891-13A
K-891-14A
K-891-15A
KN-8 91-01
KN-891-02
KN-8 91-03
KN-8 9 1-0 4
KN-891-05
K-891-06P
K-891-07P
K-891-08P
K-891-09P
K-891-10P
L91-11-A
L91-12-A
L91-13-A
L91-14-A
L91-15-A
L91-01-0
L91-02-0
L91-03-0
Sampling locataion
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Duplicate of J91-15-A
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Concentration
s /cm3 s/mm2
0.011
0.004
0
0
0.004
0.011
0
0
0
0
0.004
0
0
0
0
0
0
0
0
0.097
0.014
0.022
0.040
0.033
0
0
0
0
0
0
0
0.006
0.003
0.007
0.006
0.005
0.005
0
0.005
0
0
0.009
0.006
0
0
0.005
0
0
0
0
0.016
0
0.013
0.003
0
0
0
54
18
0
0
18
54
0
0
0
0
18
0
0
0
0
0
0
0
0
238
42
69
125
100
0
0
0
0
0
0
0
31
16
31
18
18
18
0
18
0
0
36
18
0
0
18
0
0
0
0
89
0
71
18
0
0
0
Air
Volume, L
1898
1932
1466
1878
1841
1827
1859
1922
1922
1853
1853
1853
1827
1815
1878
1823
1804
1589
1847
943
1123
1214
1209
1171
1832
1832
1881
1854
1832
1931
1921
1938
1836
1842
1204
1408
1383
1264
1326
1513
1486
1504
1159
1373
1304
1312
1342
1336
1416
2159
2099
2100
2100
2065
2094
2088
2082
(continued)
46
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
APPENDIX A (continued)
Site
L
L
L
L
L
L
L
L
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
Sample
date
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/07/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
05/01/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
08/29/91
09/03/91
09/03/91
09/03/91
09/03/91
09/03/91
09/03/91
09/03/91
09/03/91
09/03/91
09/03/91
Sample
number
L91-04-0
L91-05-0
L91-06-P
L91-07-P
L91-07-PR
L91-08-P
L91-09-P
L91-10-P
M91-11-A
M91-12-A
M91-13-A
M91-14-A
M91-15-A
M91-06-P
M91-08-P
M91-09-P
M91-10-P
M-891-11A
M-891-12A
M-891-13A
M-891-14A
M-891-15A
M-891-010
M-891-020
M-891-030
M-891-040
M-891-050
M-891-06P
M-891-07P
M-891-08P
M-891-09P
M-891-10P
M-8B91-11
M-8B91-12
M-8B91-13
M-8B91-14
M-8B91-15
M-8B91-01
M-8B91-02
M-8B91-03
M-8B91-04
M-8B91-05
M-8B91-06
M-8B91-07
M-8B91-08
M-8B91-09
M-8B91-10
M-991-14A
M-991-15A
M-991-10P
M-991-19P
M-991-20P
M991-21P
M991-22P
M991-23P
M991-24P
M991-25P
Concentration
Sampling locataion
Outdoors
Outdoors
Perimeter area
Perimeter area
Replicate of L91-07-P
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
s/cmj
0
0
0.003
0.006
0
0
0.003
0.003
0.056
0.038
0.019
0.003
0
0.007
. 0.004
0.007
0
0.008
0.082
0.018
0.009
0.046
0
0
0
0
0.004
0
0
0.025
0.008
0.031
0
0
0
0.005
0
0
0
0
0
0
0
0.005
0.005
0.005
0.131
0.005
0.005
0
0
0
0
0
0
0
0
s/mm2
0
0
18
36
0
0
18
18
281
188
94
16
0
36
18
36
0
36
339
71
36
179
0
0
0
0
18
0
0
107
36
125
0
0
0
18
0
0
0
0
0
0
0
18
18
18
446
18
18
0
0
0
0
0
0
0
0
Air
Volume, L
2059
2071
2129
2117
2117
2099
2111
2087
1921
1892
1892
1770
1835
2041
1938
2012
1807
1726
1590
1534
1554
1489
1511
1609
1609
1570
1560
1540
1723
1673
1725
1543
1429
1450
1383
1386
1328
1319
1263
1317
1273
1430
133"6
1281
1310
1439
1309
1477
1508
1337
1337
1403
1500
1393
1538
1439
1330
(continued)
47
-------
APPENDIX A (continued)
Sample
Site date
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
0
0
0
0
0
O
0
O
O
0
O
0
0
O
0
0
O
p
p
p
p
p
p
p
p
p
p
p
p
p
p
p
p
Q
Q
Q
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
04/29/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
08/14/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/08/91
05/09/91
05/09/91
05/09/91
Sample
number
N91-11-A
N91-12-A
N91-13-A
N91-14-A
N91-15-A
N91-06-P
N91-07-P
N91-08-P
N91-08-PR
N91-09-P
N91-10-P
N-891-11A
N-891-12A
N-891-13A
N-891-14A
N-891-15A
N-891-06P
N-891-07P
N-891-08P
N-891-09P
N-891-10P
091-11-A
091-11-AD
091-12-A
091-13-A
091-14-A
O91-15-A
O91-01-0
091-02-0
091-03-O
O91-04-0
091-05-0
091-06-P
091-07-P
091-07-PR
091-08-P
091-09-P
091-10-P
P91-11-A
P91-12-A
P91-13-A
P91-14-A
P91-15-A
P91-01-O
P91-02-0
P91-03-0
P91-04-0
P91-05-0
P91-06-P
P91-07-P
P91-08-P
P91-09-P
P91-09-PR
P91-10-P
Q91-11-A
Q91-12-A
Q91-13-A
Sampling locataion
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Perimeter area
Perimeter area
Perimeter area
Replicate of N91-08-P
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Duplicate of O91-11-A
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Replicate of O91-07-P
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Replicate of P91-09-P
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Concentration
s/cmj s/mm*
0.009
0.003
0.003
0.003
0.003
0.012
0.015
0.003
0
0
0.046
0
0
0
0
0.013
0
0
0.005
0.005
0
0.022
0.010
0
0
0
0.003
0
0
0
0.003
0.003
0
0
0
0
0
0
0.004
0.004
0
0.011
0
0
0
0
0
0
0
0
0.004
0
0.004
0
0.010
0
0.007
47
16
16
16
16
63
78
16
0
0
203
0
0
0
0
54
0
0
18
18
0
125
54
0
0
0
18
0
0
0
18
18
0
0
0
0
0
0
18
18
0
54
0
0
0
0
0
0
0
0
18
0
18
0
54
0
36
Air
Volume, L
2099
2112
2018
2059
2000
2018
2018
1978
1978
1984
1717
1311
1469
1335
1325
1590
1383
1385
1445
1454
1437
2163
2163
2152
2170
2140
2134
2105
2123
2099
2093
2111
2204
2174
2174
2187
2147
2184
1812
1752
1806
1872
1866
1806
1812
1800
1800
1806
1824
1824
1860
1836
1836
1805
2010
1998
1953
(continued)
48
-------
APPENDIX A (continued)
Sample
Site date
Q
Q
Q
Q
Q
Q
Q
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
S
s
S
s
s
s
s
s
s
s
s
s
s
s
s
s
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
T
05/09/91
05/09/91
08/13/91
08/13/91
08/13/91
08/13/91
08/13/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/02/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91 •
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
05/03/91
Sample
number
Q91-14-A
Q91-15-A
Q-891-11A
Q-891-12A
Q-891-13A
Q-891-14A
Q-891-15A
R91-11-A
R91-12-A
R91-13-A
R91-13-AR
R91-14-A
R91-15-A
R91-01-0
R91-02-0
R9 1-03-0
R91-04-0
R91-05-0
R91-06-P
R91-07-P
R91-08-P
R91-09-P
R91-10-P
S91-11-A
S91-11-AR
S91-12-A
S91-13-A
S91-14-A
S91-15-A
S91-01-0
S9 1-02-0
S 9 1-03-0
S91-04-0
S91-05-0
S91-06-P
S91-07-P
S91-08-P
S91-09-P
S91-10-P
T91-11-A
T91-12-A
T91-13-A
T91-14-A
T91-15-A
T91-15-AR
T91-01-0
T91-02-0
T91-03-0
T91-04-0
T9 1-05-0
T91-05-OD
T91-06-P
T91-07-P
T91-08-P
T91-09-P
T91-10-P
Sampling locataion
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
• Previously abated area
Previously abated area
Previously abated area
Previously abated area
Replicate of R91-13-A
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Replicate of S91-11-A
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Replicate of T91-15-A
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Duplicate of T91-05-O
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Concentration
s/cm3 s/mmz
0.010
0.018
0.005
0.005
0.005
0.005
0.005
0.010
0.003
0.003
0.003
0
0.007
0.003
0.003
• 0.012
0
0.004
0
0
0.003
0
0.008
0
0.004
0
0
0.004
0
0.004
0
0
0.011
0
0
0
0
0.007
0
0
0
0
0.004
0.004
0
54
89
18
18
18
18
18
54
18
18
18
0
36
16
16
63
0
18
0
0
18
0
36
0
18
0
0
16
0
0
18
0
0
54
0
0
0
0
36
0
0
0
0
0
0
0
18
18
0
Air
Volume, L
1968
1956
1356
1453
1391
1462
1436
2012
2007
1995
1995
1989
2007
2024
2048
2036
2007
2013
2007
1955
1995
1995
2053
1785
1785
1900
1853
1841
1829
1662
1647
1691
1691
1898
1852
1801
1830
1841
1840
1919
1902
1959
1952
1935
1935
1931
1931
1931
1931
1958
1958
1965
1925
1925 '
1908
1919
49
-------
APPENDIX B
STRUCTURE TYPE AND MORPHOLOGY
DISTRIBUTIONS FOR SITES A THROUGH T
50
-------
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1
APPENDIX C
PHASE III CASE HISTORIES
55
-------
PHASE III CASE HISTORY
SITES B AND Q
Background
During the summer of 1988, two asbestos abatement projects were conducted at
this school (Sites B and Q). Sprayed-applied acoustical ceiling plaster was removed
from the second floor (Site B) and from the first floor (Site Q). At both sites the
abatement area included corridors, classrooms, and offices. The ceiling plaster
contained approximately 2 to 6 percent chrysotile asbestos. The information regarding
the abated ACM and associated asbestos-content was obtained from the asbestos-
abatement specification for these sites. No additional abatement activity occurred
between 1988 and 1991.
Summary of Phase III Air Monitoring Data
Site B
On May 9, 1991, EPA/NJDOH collected air samples during periods of normal
activity (i.e., occupied conditions) at Site B from the same locations as previous
samples collected in 1988 and 1990. Table C-1 presents the results of the May 9
sampling. Since the average airborne asbestos concentration (0.027 s/cm3) exceeded
0.02 s/cm3 in the previously abated area, EPA/NJDOH conducted follow-up monitoring
under simulated occupancy conditions on August 13, 1991, to determine whether
airborne asbestos was still present at levels similar to those measured in May 1991.
Table C-2 presents the results of the August 13 sampling. The August 13 results
revealed an average airborne asbestos concentration in the previously abated area
was less than 0.02 s/cm3 (0.018 s/cm3); therefore, no further monitoring activity was
required at this school. Intervention continued in order to resolve the elevated
asbestos concentrations at this site.
56
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
TABLE C-1. RESULTS OF MAY 9, 1991, AIR MONITORING AT SITE B
Airborne asbestos concentration, s/cm3
Previously abated area
0.014
0.044
0.014
0.055
0.010
Average: 0.027
Perimeter area
0.014
0.011
0.004
0.007
0.024
Average: 0.012
Outdoors
0
0
0
0.004
0
Average: 0.001
TABLE C-2. RESULTS OF AUGUST 13, 1991, AIR MONITORING AT SITE B
Airborne asbestos concentration, s/cm3
Previously abated area
0.013
0.009
0.064
0
0.004
Average: 0.018
Perimeter area
0
0.005
0
0
0
Average: 0.001
Outdoors
0.005
0
0
0
0
Average: 0.001
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Sit @ Q
On May 9, 1991, EPA/NJDOH collected air samples during periods of normal
activity (i.e., occupied conditions) at Site Q from the same locations as the samples
collected in 1988 and 1990. Table C-3 presents the results of the May 9 sampling.
Although the average airborne asbestos concentration in the previously abated
area and the perimeter area did not exceed 0.02 s/cm3, EPA/NJDOH conducted
follow-up monitoring on August 13,1991, under simulated occupancy conditions
because the average airborne asbestos concentration in the previously abated area
from a second abatement project at this school (Site B) did exceed 0.02 s/cm3. Table
C-4 presents the results of the August 13 sampling. The August 13 results showed
that the average airborne asbestos concentration in the previously abated area and
perimeter areas of Site Q were below 0.02 s/cm3; therefore, no further monitoring
activity was required.
NJOOH Visual Inspection
On August 14, 1991, a NJDOH Visual Inspection was conducted at Sites B and Q
to determine potential sources of airborne asbestos measured by EPA and NJDOH in
May 1991. The visual inspection strategy considered the asbestos-abatement history
of the site, the operations and maintenance (O&M) activities, and other sources of
possible asbestos contamination (i.e., materials not included in the Asbestos
Management Plan). Only those areas indicated in the following subsections were
examined by the NJDOH inspector in August 1991.
1988 Abatement Areas
Second Floor Classrooms-Two samples of overspray and debris were obtained
from the structural steel and closet overhead areas (Table C-5). These samples
tested positive for chrysotile asbestos. All areas examined showed signs of
inadequate encapsulation.
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TABLE C-3. RESULTS OF MAY 9, 1991, AIR MONITORING AT SITE Q
Airborne asbestos concentration, s/cm3
Previously abated area
0.010
0
0.007
0.010
0.018
Average: 0.009
Perimeter area3
0.014
0.011
0.004
0.007
0.024
Average: 0.012
Outdoors3
0
0
0
0.004
0
Average: 0.001
Same samples as collected at Site B.
TABLE C-4. RESULTS OF AUGUST 13, 1991, AIR MONITORING AT SITE Q
Airborne asbestos concentration, s/cm3
Previously abated area
0.005
0.005
0.005
0.005
0.013
Average: 0.005
Perimeter area3
0
0.005
0
0
0
Average: 0.001
Outdoors3
0.005
0
0
0
0
Average: 0.001
Same samples as collected at Site B.
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TABLE C-5. SUMMARY OF BULK SAMPLE RESULTS-SITES B AND Q
REINSPECTION
Location
Type of material
Analysis
1988 Abatement Area
2nd floor classroom,
closet overhead, truss
2nd floor classroom, top
of closet
1 st floor classroom
1 st floor classroom, air
shaft ledge
1988 Perimeter Areas
Basement all-purpose
room
Flakes of spray-on debris
Flakes of spray-on debris
Flakes of spray-on debris
Flakes of spray-on debris
Positive3, chrysotile
asbestos
Positive, chrysotile
asbestos
Positive, chrysotile
asbestos
Negative
Composite, ceiling sample
Negative
a This classification was defined by the NJDOH laboratory to accommodate samples of which there is
not adequate material available to allow a full quantitative evaluation, but are of sufficient size to
determine that asbestos is present and to determine the specific type of asbestos. Based on the
professional Judgement of the analyst, the sample is considered to contain greater than 1%
asbestos.
First Floor C/assrooms-Conditions regarding overspray and debris were the
same as those noted in the second floor classrooms. Two samples were collected
(Table C-5); one sample of spray-on debris tested positive for chrysotile asbestos. A
sample of sandy debris from an air shaft tested negative for asbestos.
1988 Perimeter Areas
In the basement all-purpose room, thermal system insulation (TSI) not identified
in the Asbestos Management Plan was observed in the ceiling overhead spaces in the
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corridor, kitchen, and storage closet. This material appeared to be in generally good
condition.
Conclusions
Incomplete assessment and abatement failed to account for overspray in the
ceiling overhead spaces and the closet recessions. These asbestos-containing
materials could have contributed to the elevated airborne asbestos levels measured in
May 1991.
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PHASE III CASE HISTORY
SITES C AND M
Background
During the summer of 1988, two asbestos abatement projects were conducted
at this school (Sites C and M). At Site C, asbestos-containing thermal system
insulation (TSI) was removed from a boiler, water tank, fan duct, and pipes in the
boiler room located in the basement and from pipes in the corridor adjacent to the
boiler room. At Site M, TSI was removed from pipes in the corridors, classroom,
office, storage room, and gymnasium located in the basement. The TSI contained
approximately 40 to 60 percent chrysotile asbestos. The information regarding the
abated ACM and associated asbestos-content was obtained from the asbestos-
abatement specification for these sites. There has been no additional abatement
activity between 1988 and 1991.
Summary of Phase III Air Monitoring Data
SiteC
On May 1, 1991, EPA/NJDOH collected air samples during periods of normal
activity (i.e., occupied conditions) at Site C in the same locations as previous samples
collected in 1988 and 1990. Table C-6 presents the results of the May 1 sampling.
Since the average airborne asbestos concentrations in the previously abated area
(0.005 s/cm3) and in the perimeter areas (0.001 s/cm3) did not exceed 0.02 s/cm3, no
further monitoring activity was required at this site.
Site M
On May 1, 1991, EPA/NJDOH collected air samples during periods of normal
activity (i.e., occupied conditions) at Site M in the same locations as those collected in
1988 and 1990. Table C-7 presents the results of the May 1 sampling. Since the
average airborne asbestos concentration in the previously abated area (0.023 s/cm3)
exceeded 0.02 s/cm3, EPA/NJDOH conducted follow-up monitoring on August 13,
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1991, under simulated occupancy conditions, to determine whether the airborne
asbestos was still present at levels similar to those measured in May 1991. Table C-8
presents the results of the August 13 sampling. The average airborne asbestos
concentrations in the previously abated area (0.033 s/cm3) still exceeded 0.02 s/cm3;
therefore, NJDOH directed the school to initiate a response action to reduce the
airborne asbestos concentrations in the previously abated area. The school
subsequently employed a licensed asbestos abatement contractor to clean these
areas.
When the response action was complete, EPA/NJDOH conducted follow-up air
monitoring on August 29, 1991, to determine the residual levels of airborne asbestos.
Table C-9 presents the results of the August 29 sampling. Although the average
airborne asbestos concentrations in the previously abated area (0.001 s/cm3) was
below 0.02 s/cm3, the average concentration in the perimeter area (0.029 s/cm3)
exceeded 0.02 s/cm3; therefore, NJDOH directed the school to reclean the perimeter
areas. After the second response action, NJDOH collected additional samples on
September 3, 1991, in the previously abated area and the perimeter area. Average
airborne asbestos concentrations in the previously abated area (0.005 s/cm3, N=2) and
the perimeter area (0 s/cm3, N=8) were both below 0.02 s/cm3; therefore, no further
action was required at this site. Intervention continued in order to resolve the elevated
asbestos concentrations at this site.
NJDOH Visual Inspection
On August 14,1991, a NJDOH Visual Inspection was conducted at Sites C and
M to determine potential sources of airborne asbestos measured by EPA/NJDOH in
May 1991. The visual inspection strategy considered the asbestos-abatement history
of the site, the O&M activities, and other sources of possible asbestos contamination
(i.e., materials not included in the Asbestos Management Plan). Only those areas
indicated in the following subsections were examined.
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TABLE C-6. RESULTS OF MAY 1, 1991, AIR MONITORING AT SITE C
Airborne asbestos concentration, s/cm3
Previously abated area
0.012
0
0.003
0.009
0
Average: 0.005
Perimeter area
0
0.003
0 .
0
0
Average: 0.001
Outdoors
0
0
0.007
0.005
0.002
Average: 0.003
TABLE C-7. RESULTS OF MAY 1, 1991, AIR MONITORING AT SITE M
Airborne asbestos concentration, s/cm3
Previously abated area
0.056
0.038
0.019
0.003
0
Average: 0.023
Perimeter area
0.007
0.004
0.007
0
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Average: 0.004
Outdoors
0
0
0.007
0.005
0.002
Average: 0.003
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TABLE C-8. RESULTS OF AUGUST 13, 1991, AIR MONITORING AT SITE M
Airborne asbestos concentration, s/cm3
Previously abated area
0.008
0.082
0.018
0.009
0.046
Average: 0.033
Perimeter area
0
0
0.025
0.008
0.031
Average: 0.013
Outdoors
0
0
0
0
0.004
Average: 0.001
TABLE C-9. RESULTS OF AUGUST 29, 1991, AIR MONITORING AT SITE M
Airborne asbestos concentration, s/cm3
Previously abated area
0
0
0
0.005
0
Average: 0.001
Perimeter area
0
0
0.025
0.008
0.031
Average: 0.029
Outdoors
0
0
0
0
0
Average: 0
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1988 Abatement Areas
Classroom, Small Gymnasium, and Corridors
No TSI debris was found in these abatement areas. Plaster debris from the
wall and ceiling surfaces was evident in many areas. Top-coat plaster from the
recreation room and hallway did not test positive for asbestos; however, the browncoat
underlay in the adjoining hallway showed trace amounts of chrysotile asbestos (Table
C-10). The storage and office areas were locked and could not be accessed.
TABLE C-10. SUMMARY OF BULK SAMPLE RESULTS-SITES C AND M
REINSPECTION
Location
Type of material
Analysis
1988 Abatement Area
Basement recreation
room/classroom
Basement hallway
Basement hallway
1988 Perimeter Area
Boiler room, coal area
Boiler room, coal area
Boiler room, under stairs
Plaster, top coat
Plaster, top coat
Plaster, browncoat
Debris mixed in coal
TSI debris
TSI debris
Negative
Negative
Positive3, chrysotile
asbestos
3% chrysotile, 19%
amosite, positive,
crocidolite asbestos
Positive, chrysotile
asbestos
67% chrysotile asbestos
a This classification was defined by the NJDOH laboratory to accommodate samples of which there is
not adequate material available to allow a full quantitative evaluation, but are of sufficient size to
determine that asbestos is present and to determine the specific type of asbestos. Based on the
professional judgement of the analyst, the sample is considered to contain greater than 1%
asbestos.
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•
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; Miscellaneous debris mixed in with the coal tested positive for chrysotile (19%),
| amosite (3%), and crocidolite (trace) asbestos (Table C- 10). The TSI debris mixed in
: with the coal tested positive for chrysotile asbestos. The TSI debris found under the
I boiler room stairway tested positive for chrysotile asbestos (67%).
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1988 Perimeter Area
Boiler Room
Large Gymnasium
Plaster dust and debris from renovation work were widespread along the north
wall. No samples of the plaster dust were collected.
Other Considerations
The School's Asbestos Management Plan identified plaster as an asbestos-
containing building material (ACBM). Samples taken by the NJDOH were reported as
either 1% chrysotile asbestos, <1% chrysotile asbestos, or as negative for asbestos
(Table C-1 0). Although none of these materials tested greater than 1 % asbestos, the
Asbestos Management Plan classified them as friable surfacing materials with damage
and indicated that repairs would be made by September 1 , 1989. At the time of the
NJDOH inspection, no repairs had been made, however, the plaster debris on the
floor surfaces in the large gymnasium had been cleaned up.
Conclusions
The deterioration of the plaster in the building and activities involved in the
renovation and repair of the plaster may have contributed to the elevated
concentrations of airborne asbestos measured in May 1991.
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PHASE III CASE HISTORY
SITE D
Background
During the summer of 1988, this school underwent the removal of sprayed-on
ceiling material and thermal system insulation (TSI) from the boiler room and adjoining
mechanical spaces. The spray-on ceiling material was removed from the boiler room,
mechanical equipment room, and electrical equipment room and adjacent corridor.
The TSI was removed from a water tank and pipes in the boiler room. The spray-on
ceiling material and TSI contained approximately 20 to 35 percent chrysotile asbestos
and 40 to 60 percent chrysotile asbestos, respectively. In 1990, 20 square feet of TSI
was removed from a vertical conveyor shaft. The information regarding the abated
ACM and associated asbestos-content was obtained from the asbestos-abatement
specification for this site. No other asbestos-containing material was abated between
1988 and 1991.
Summary of Phase III Air Monitoring Data
On April 30, 1991, EPA/NJDOH collected air samples during periods of normal
activity (i.e., occupied conditions) at Site D from the same locations as previous
samples collected in 1988 and 1990. Table C-11 presents the results of the April 30
sampling. Since the average airborne asbestos concentration in the previously abated
area was 0.02 s/cm3, EPA/NJDOH conducted follow-up monitoring under simulated
occupancy conditions on August 13,1991, to determine whether airborne asbestos
was still present at levels similar to those measured in April 1991. Table C-12
presents the results of the August 13 sampling. The August 13 results revealed an
average airborne asbestos concentration in the previously abated area was less than
0.02 s/cm3 (0.018 s/cm3); therefore, no further monitoring activity was required at this
site. Intervention continued in order to resolve the elevated asbestos concentrations
at this site.
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TABLE C-11. RESULTS OF APRIL 30, 1991, AIR MONITORING AT SITE D
Airborne asbestos concentration, s/cm3
Previously abated area
0.012
0.059
0.006
0.020
0.003
Average: 0.020
Perimeter area
0.008
0.003
0
0.009
0.003
Average: 0.004
Outdoors
0.003
0.012
0.002
0.003
0
Average: 0.004
TABLE C-12. RESULTS OF AUGUST 13, 1991, AIR MONITORING AT SITE D
Airborne asbestos concentration, s/cm3
Previously abated area
0
0.058
0.010
0.014
0
Average: 0.016
Perimeter area
0
0
0
0
0
Average: 0
Outdoors
0.005
0
0
0
0
Average: 0.001
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NJDOH Visual Inspection
On August 14, 1991, a NJDOH Visual Inspection was conducted at Site D to
determine potential sources of airborne asbestos measured by EPA/NJDOH in April
1991. The visual inspection strategy considered the asbestos-abatement history of
the site, the O&M activities, and other sources of possible asbestos contamination
(i.e., materials not included in the Asbestos Management Plan). Only those areas
indicated in the following subsections were examined.
1988 Abatement Area
Electrical Room
Ceiling debris (17% chrysotile asbestos) was present on the top of ductwork,
electrical boxes, and wiring and in wall penetrations (Table C-13).
Generator Room
Ceiling debris (8 to 15% chrysotile asbestos) was present on the top of the
ventilation ducts and the generator exhaust box and on the floors (Table C-13).
Boiler Room
Ceiling debris (17% chrysotile asbestos) was present on the lower window
ledge areas. The ladders provided were too unstable to safely access such areas as
the top of the air-handling unit and pipes (Table C-13).
Boiler Storage Room
Numerous 5-lb cans of asbestos sealant were noted in this area. These
materials were due to be removed from inventory in 1989.
Corridor at the Electrical Room
The top of the suspended ceiling system was heavily contaminated with ceiling
debris (18% chrysotile asbestos) (Table C-13). The wires, pipes, and ductwork in this
space were covered with loose spray-on ceiling debris.
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TABLE C-13. SUMMARY OF BULK SAMPLE RESULTS-SITE D REINSPECTION
Location
Type of material
Analysis
1988 Abatement Area
Electrical room
Electrical room
Basement hallway at
electrical room
Boiler room
Generator room
Generator room
Generator room
Top of electrical box
Top of fire alarm box
Top of ceiling tile
Corner ledge
Top of generator exhaust
box
Top of duct
Floor at windows
17% chrysotile asbestos
Positive3 for chrysotile
asbestos
18% chrysotile asbestos
17% chrysotile asbestos
8% chrysotile asbestos
13% chrysotile asbestos
15% chrysotile asbestos
a This classification was defined by the NJDOH laboratory to accommodate samples of which there Is
not adequate material available to allow a full quantitative evaluation, but are of sufficient size to
determine that asbestos is present and to determine the specific type of asbestos. Based on the
professional judgement of the analyst, the sample is considered to contain greater than 1%
asbestos.
1988 Perimeter Areas
Time limitations prevented the inspection of these areas.
Other Considerations
The crawl space area in the boiler room was locked at the time of the
inspection; however, in a gap between the wall and the deck of the boiler area, stored
thermal system insulation with extensive water damage was noted. Opening the boiler
room windows or activating the boiler air feeds could have caused sufficient air
movement to possibly disturb these damaged materials. The School's Asbestos
Management Plan indicated that these areas were scheduled for abatement in 1989,
however, at the time of the inspection no abatement had occurred.
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Conclusions
A likely source of the elevated airborne asbestos concentrations measured in
May 1991 was the wide-spread spray-on ceiling dust and debris throughout the
• abatement areas. The debris found on top of the corridor ceilings and on the various
equipment and ducts could indicate that the areas were not precleaned before
• erection of the polyethylene containment barriers.
Damaged material in the crawl space also may have contributed to the
• elevated asbestos levels. All other areas of the school, such as the loading dock,
; dumb waiter, book storage, etc. was recommended by NJDOH to be inspected for
I abatement residue, dust and debris.
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PHASE 111 CASE HISTORY
SITE E
Background
During the summer of 1988, 2-ft by 4-ft lay-in ceiling tiles and thermal system
insulation (TSI) on pipes were removed from this school. The ceiling tiles were
removed from classrooms, offices, and recreational areas; the TSI was removed from
corridors, boiler and breech. The ceiling tiles and TSI contained trace to 1 percent
amosite and 2 to 7 percent chrysotile asbestos, respectively. The information
regarding the abated ACM and associated asbestos-content was obtained from the
asbestos-abatement specification for this site. No additional abatement activity
occurred between 1988 and 1991.
Summary of 1991 (Phase III) Air Monitoring Data
On May 6, 1991, EPA/NJDOH collected air samples during periods of normal
activity (i.e., occupied conditions) at Site E from the same locations as those collected
in 1988 and 1990. Table C-14 presents the results of the May 6 sampling. Since the
average airborne asbestos concentration in the previously abated area (0.037 s/cm3)
exceeded 0.02 s/cm3, EPA/NJDOH conducted follow-up monitoring under simulated
occupancy conditions on August 12, 1991, to determine whether airborne asbestos
was still present at levels similar to those measured in May 1991. Table C-15
presents the results of the August 12 sampling. The August 12 results revealed that
the average airborne asbestos concentration in the previously abated area was less
than 0.02 s/cm3 (0.005 s/cm3); therefore, no further monitoring activity was required at
this school. Intervention continued in order to resolve the elevated airborne asbestos
concentrations at this site.
NJDOH Visual Inspection
On August 13, 1991, an NJDOH Visual Inspection was conducted at Site E to
determine potential sources of airborne asbestos measured by EPA/NJDOH in May
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1991. The visual inspection strategy considered the asbestos-abatement history of
the site, the O&M activities, and other sources of possible asbestos contamination
(i.e., materials not included in the Asbestos Management Plan). Only those areas
indicated in the following subsections were examined.
TABLE C-14. RESULTS OF MAY 6, 1991, AIR MONITORING AT SITE E
Airborne asbestos concentration, s/cm3
Previously abated area
0.011
0.069
0.042
0.029
0.032
Average: 0.037
Perimeter area
0.003
0.003
0.029
0.015
0
Average: 0.010
Outdoors
0.007
0.007
0
0.003
0
Average: 0.003
TABLE C-15. RESULTS OF AUGUST 12, 1991, AIR MONITORING AT SITE E
Airborne asbestos concentration, s/cm3
Previously abated area
0.025
0
0
0
0
Average: 0.005
Perimeter area
0.010
0
0.030
0.010
0
Average: 0.010
Outdoors
0.005
0
0
0
0
Average: 0.001
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1988 Abatement Area
Corridors
The tops of the lockers contained small pieces of asbestos-containing ceiling
tiles (Table C-16). At the end of each corridor (above the entry doors), an insulating
barrier was constructed to separate the warm air in the corridor plenum from the cold
air in the exterior foyer. The material in this barrier consisted of asbestos-containing
plaster (7% chrysotile) over construction wire.
Art Storage Room
The TSI debris on top of the partition wall contained 5 percent chrysotile
asbestos (Table C-16).
1988 Perimeter Areas
Boiler room
The TSI debris on the surface of the concrete-masonry block wall tested
positive for asbestos (Table C-16). The TSI that remained on the interior surfaces of
the "pork-chop" type boilers after abatement contained 2 to 5% chrysotile asbestos
(Table C-16).
Conclusions
Asbestos-containing materials not included in the Asbestos Management Plan
were found. These included a thermal insulating barrier (above the entry doors) at the
end of each corridor and TSI lagging on the interior of the boiler.
The May 1991 monitoring revealed elevated concentrations of airborne asbestos.
Because no amosite was present in any of the air samples, the source of the asbestos
was material other than the ceiling tiles. These materials could have included
unencapsulated debris from the 1988 abatement or the friable containing barrier above
the entry doors.
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TABLE C-16. SUMMARY OF BULK SAMPLE RESULTS-SITE E REINSPECTION
Location
1988 Abatement Area
Top of lockers at Room 109
Top of lockers at Room 108
At exit by Room 108
Top of locker No. #403
Top of lockers at Room 111
Top of locker at boiler room
Art storage room
Perimeter Areas
Boiler room
Boiler room
Boiler room
Type of material
Ceiling tile
Ceiling tile
Above drop ceiling, Draft seal
Ceiling tile
Ceiling tile
Ceiling tile
Partition wall, TSI debris
Lagging inside left boiler
Lagging inside right boiler
TSI debris on wall
Analysis
<1 % amosite
Tracea amosite
7% chrysotile
1% amosite
1% amosite
1 % amosite
5% chrysotile
5% chrysotile
2% chrysotile
Positive1*,
chrysotile
Trace =
< 1% asbestos
b This classification was defined by the NJDOH laboratory to accommodate samples of which there is
not adequate material available to allow a full quantitative evaluation, but are of sufficient size to
determine that asbestos is present and to determine the specific type of asbestos. Based on the
professional judgement of the analyst, the sample is considered to contain greater than 1%
asbestos.
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PHASE III CASE HISTORY
SITEF
Background
During the summer of 1988, thermal system insulation (TSI) on the boiler and
pipes was removed from the boiler room at this school. The TSI contained
approximately 30 to 40 percent chrysotile asbestos and trace to 4% amosite. The
information regarding the abated ACM and associated asbestos-content was obtained
from the asbestos-abatement specification for this site. No additional abatement
activity occurred between 1988 and 1991.
Summary of 1991 (Phase III) Air Monitoring Data
On May 9, 1991, EPA/NJDOH collected air samples during periods of normal
activity (i.e., occupied conditions) at Site F from the same locations as those collected
in 1988 and 1990. Table C-17 presents the results of the May 9 sampling. Since the
average airborne asbestos concentration in the previously abated area (0.043 s/cm3)
and in the perimeter area (0.036 s/cm3) exceeded 0.02 s/cm3, EPA/NJDOH conducted
follow-up monitoring under simulated occupancy conditions on August 12,1991, to
determine whether airborne asbestos was still present at levels similar to those
measured in May 1991. Table C-18 presents the results of the August 12 sampling.
The average airborne asbestos concentrations in both the previously abated area
(0.024 s/cm3) and the perimeter area (0.023 s/cm3) still exceeded 0.02 s/cm3;
therefore, NJDOH directed the school to initiate a response action to reduce the
airborne asbestos concentrations in these areas. The school subsequently employed
an asbestos abatement contractor to clean these areas. When the cleaning action
was complete, EPA/NJDOH conducted foliow-up air monitoring on August 28, 1991.
Table C-19 presents the results of the August 28 sampling. The average airborne
asbestos concentrations in the previously abated area and in the perimeter area were
below 0.02 s/cm3; therefore, no further monitoring activity was required at this site.
Intervention continued in order to resolve the elevated asbestos concentrations at this
site.
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TABLE C-17. RESULTS OF MAY 9, 1991, AIR MONITORING AT SITE F
Airborne asbestos concentration, s/cm3
Previously abated area
0.035
0.066
0.039
0.042
0.032
Average: 0.043
Perimeter area
0.010
0.058
0.035
0.025
0.054
Average: 0.036
Outdoors
0
0
0.002
0
0
Average: 0.001
TABLE C-18. RESULTS OF AUGUST 12, 1991, AIR MONITORING AT SITE F
Airborne asbestos concentration, s/cm3
Previously abated area
0.037
0.014
0.029
0.015
0.019
Average: 0.023
Perimeter area
0.046
0.047
0.010
0
0.019
Average: 0.024
Outdoors
0
0.005
0.010
0.005
0
Average: 0.004
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TABLE C-19. RESULTS OF AUGUST 28, 1991, AIR MONITORING AT SITE F
Airborne asbestos concentration, s/crn3
Previously abated area
0
0
0
0
0
Average: 0
Perimeter area
0.005
0.004
0.008
0
0
Average: 0.003
Outdoors
0
0.004
0
0
0
Average: 0.001
NJOOH Visual Inspection
On August 13,1991, an NJDOH Visual Inspection was conducted at Site F to
determine potential sources of airborne asbestos measured by EPA/NJDOH in May
1991. The visual inspection strategy considered the asbestos-abatement history of
the site, the O&M activities, and other sources of possible asbestos contamination
(i.e., materials not included in the Asbestos Management Plan). Only those areas
indicated in the following subsections were examined.
1988 Abatement Area
Boiler Room
The boiler was found to have asbestos-containing TSI (29% chrysotile
asbestos) on its interior. The asbestos-containing TSI on the exterior of the boiler had
been removed, and the boiler had been reinsulated.
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1988 Perimeter Areas
Hallway at the Boiler Room Entry
The School's Asbestos Management Plan indicated the presence of sprayed-
on asbestos above the interlock ceiling in this area. No sprayed-on materials were
noted; however, four different-sized homogeneous pipe runs were observed that were
not included in the Asbestos Management Plan. The School's Asbestos Management
Plan appeared to be in error regarding the types of material and their locations.
Approximately 10 linear feet of this pipe insulation was torn from the pipes directly
below an open roof vent.
School officials indicated that during a retrofit of the school's fire alarm system,
workers had crawled through the suspended ceiling plenums to run wires. Such
activity may have caused a fiber release and/or damage to the thermal materials. A
roof leak and subsequent repair also may have contributed to the TSI damage.
Air Handling Unit Mechanical Rooms in Gymnasium
Thermal system insulation was removed from these areas. A thick
accumulation of dust mixed with flakes of elbow debris (positive, chrysotile asbestos)
was present on the air-handling unit (Table C-20). The duct sealant contained 49%
chrysotile asbestos. The duct sealant had been abated in the north fan room and was
only partly abated in the south air-handling room. Gouged friable sealant remained on
the ducting and was not encapsulated.
Classrooms
The two classrooms farthest from the boiler area (Classrooms 42 and 43) were
inspected for the presence of asbestos-containing debris. Both rooms had heater
units equipped with blowers and external air exchangers. Thermal system insulation
had been removed from the pipes in the closets adjoining these units. Asbestos-
containing debris (30 to 36% chrysotile and Trace to 4% amosite) was recovered from
the base of the units (Table C-20).
80
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TABLE C-20. SUMMARY OF BULK SAMPLE RESULTS-SITE F REINSPECTION
Location
Type of material
Analysis
1988 Abatement Area
Boiler room
1988 Perimeter Areas
S/E air handling room,
gymnasium
S/E air handling room,
gymnasium
Classroom 42
Classroom 43
Interior of Boiler 24
Debris on top of air handler
Remaining duct sealant
TSI debris in closet under
heating unit
TSI debris in closet under
heating unit
29% chrysotile asbestos
Positive3, chrysotile
asbestos
49% chrysotile asbestos
30% chrysotile asbestos
4% amosite asbestos
36% chrysotile asbestos
Trace13, amosite
asbestos
a This classification was defined by the NJDOH laboratory to accommodate samples of which there is
not adequate material available to allow a full quantitative evaluation, but are of sufficient size to
determine that asbestos is present and to determine the specific type of asbestos. Based on the
professional judgement of the analyst, the sample is considered to contain greater than 1%
asbestos.
b Trace = < 1% asbestos.
81
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Conclusions
The School's Asbestos Management Plan did not reflect the residual
asbestos in the boilers. It was likely that this material would be disturbed
during cleaning by aggressive brushing and vacuuming of the interior to
remove the carbonaceous deposits.
The Asbestos Management Plan was in error regarding the types of
materials above the hallway at the boiler room entry. The 10-ft of
severely damaged TSI resulting from a roof leak along with the
installation of electrical cable in the plenum above the hallway may have
resulted in a release of asbestos fibers from the damaged TSI.
The asbestos-containing TSI debris collected in the air-handling rooms
and classrooms indicated that these areas may have been contaminated
as the result of incomplete abatement action. The asbestos-containing
debris may have been reentrained by the air handling system or the
normal activity of building occupants.
82
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PHASE III CASE HISTORY
SITEG
Background
During the summer of 1988, thermal system insulation (TSI) was removed from
the boiler room at this school (Site G). The abatement included removal of boiler
lagging (10 to 15% chrysotile and 35 to 40% amosite), boiler breeching (25 to 30%
chrysolite and 30 to 35% amosite), and the boiler gasket (70 to 75% chrysotiie). The
information regarding the abated ACM and associated asbestos-content was obtained
from the asbestos-abatement specification for this site. No additional abatement
activity occurred between 1988 and 1991.
Summary of 1991 (Phase III) Air Monitoring Data
On May 3,1991, EPA/NJDOH collected air samples during periods of normal
activity (i.e., occupied conditions) at Site G from the same locations as those collected
in 1988 and 1990. Table C-25 presents the results of the May 3 sampling. Since the
average airborne asbestos concentration in the previously abated area (0.027 s/cnf)
exceeded 0.02 s/cm3, EPA/NJDOH conducted follow-up monitoring under simulated
occupancy conditions on August 14,1991, to determine whether airborne asbestos
was still present in the concentrations measured in May 1991. Table C-26 presents
the results of the August 14 sampling. The average airborne asbestos concentrations
in both the previously abated area (0.048 s/cm3) and in the perimeter area (0.063
s/cm3) exceeded 0.02 s/cm3; therefore NJDOH directed the school to initiate a
response action to reduce the airborne asbestos concentrations in these areas. The
school subsequently utilized trained in-house staff to clean these areas.
When the cleaning action was complete, EPA/NJDOH conducted follow-up air
monitoring on August 26, 1991, to determine the residual levels of airborne asbestos.
Table C-27 presents the results of the August 26 sampling. The average airborne
asbestos concentrations in the previously abated area and in the perimeter area were
below 0.02 s/cm3; therefore, no further monitoring activity was required at this school.
83
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Intervention continued in order to resolve the elevated asbestos concentrations at this
site.
TABLE C-25. RESULTS OF MAY 3, 1991, AIR MONITORING AT SITE G
Airborne asbestos concentration, s/cm3
Previously abated area
0.032
0.025
0.011
0.030
0.037
Average: 0.027
Perimeter area
0
0
0.011
0.007
0.007
Average: 0.005
Outdoors
0.003
0
0.004
0
0
Average: 0.001
TABLE C-26. RESULTS OF AUGUST 14, 1991, AIR MONITORING AT SITE G
Airborne asbestos concentration, s/cm3
Previously abated area
0.028
0.080
0.068
0.035
0.029
Average: 0.048
Perimeter area
0.022
0.181
0.029
0.034
0.051
Average: 0.063
Outdoors
0.015
0.015
0.013
0.009
0.015
Average: 0.013
84
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TABLE C-27. RESULTS OF AUGUST 26, 1991, AIR MONITORING AT SITE G
Airborne asbestos concentration, s/cm3
Previously abated area
0
0.005
0.044
0
0
Average: 0.01
==============================
Perimeter area
0.009
0.010
0
0
0
Average: 0.004
================
Outdoors
0.005
0
0
0.004
0.015
Average: 0.005
NJDOH Visual Inspection
On August 15, 1991, a NJDOH Visual Inspection was conducted at Site G to
determine potential sources of airborne asbestos concentrations measured by
EPA/NJDOH in May 1991. The visual inspection strategy considered the asbestos-
abatement history of the site, the O&M activities, and other sources of possible
asbestos contamination (i.e., materials not included in the Asbestos Management
Plan). Only those areas indicated in the following subsections were examined.
19,38 Abatement Area
All areas examined revealed contamination from abatement activities. Wall
penetrations, pipe hangers, tops of tanks, wiring, and electrical panels were all
contaminated with residual material and debris (Table C-28).
85
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TABLE C-28. SUMMARY OF BULK SAMPLE RESULTS-SITE G REINSPECTION
Location
Type of Material
Analysis
1988 Abatement Areas
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
1988 Perimeter Areas
West office
Storage by Room 312
Room between 311 and 312
Third-floor rear corridor
Third-floor rear (NE) room
First-floor corridor
Wall, slurry at extension tank
Wall, slurry on conduit
Remaining insulation on tank
Debris, top of Devlin Elec.
Unit
Debris, brace of Devlin Unit
Debris, pipe hangers
Debris, pipe penetration to
hallway
Debris, sprinkler box
Residue, hole in ceiling
Debris, pipe penetration,
janitors office
Residue, ceiling penetration
Plaster and browncoat
Plaster and browncoat
Plaster and browncoat
Plaster and browncoat
Insulation below floors
Blackboard slate, debris
7% Chrysotile asbestos
8% Amosite asbestos •
8% Chrysotile asbestos
4% Amosite asbestos
42% Chrysotile asbestos
2% Chrysotile asbestos
19% Amosite asbestos
1% Chrysotile asbestos
25% Amosite asbestos
34% Chrysotile asbestos
<1% Chrysotile asbestos
18% Amosite asbestos
3% Chrysotile asbestos
24% Amosite asbestos
1% Chrysotile asbestos
16% Amosite asbestos
2% Chrysotile asbestos
22% Amosite asbestos
Positive", amosite asbestos
Negative
Negative
Negative
Negative
Negative
Negative
1 This classification was defined by the NJDOH laboratory to accommodate samples of which there is
not adequate material available to allow a full quantitative evaluation, but are of sufficient size to
determine that asbestos is present and to determine the specific type of asbestos. Based on the
professional judgement of the analyst, the sample is considered to contain greater than 1%
asbestos.
86
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1988 Perimeter Areas
Various areas throughout the school (classrooms and offices) were undergoing
renovation at the time of the inspection. Plaster walls were being demolished, which
left many areas coated with plaster dust. According to the Asbestos Management
Plan, one of two plaster samples tested positive (1%) for asbestos. Several samples
collected during the inspection, however, showed no detectable levels of asbestos in
either the top-coat or browncoat layer (Table C-28).
Conclusions
The primary source of the elevated airborne asbestos concentrations measured
in May 1991 is from the residual asbestos-containing material and debris on surfaces
in the boiler room remaining from the 1988 abatement.
87
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PHASE III CASE HISTORY
SITE H
Background
During the summer of 1988, asbestos-containing acoustical ceiling material,
spray-applied fireproofing, and thermal system insulation (TSI) insulation were
removed from Site H. The abatement area included corridors and adjacent vestibules,
classrooms, offices, and recreational rooms. The acoustical plaster, fireproofing, and
TSI contained 10 to 25 percent, 25 to 50 percent, and 40 to 60 percent chrysotile
asbestos, respectively. The information regarding the abated ACM and associated
asbestos-content was obtained from the asbestos-abatement specification for this site.
No additional abatement activity occurred between 1988 and 1991.
Summary of 1991 (Phase III) Air Monitoring Data
On April 30,1991, EPA/NJDOH collected air samples during periods of normal
activity (i.e., occupied conditions) at Site H from the same locations as those collected
in 1988 and 1990. Table C-21 presents the results of the April 30 sampling. Although
the average airborne asbestos concentration in the previously abated area and in the
perimeter area did not exceed 0.02 s/cm3, replicate analyses of the samples collected
in the previously abated area revealed an average level above 0.02 s/cm3. Therefore,
EPA/NJDOH conducted follow-up monitoring under simulated occupancy conditions on
August 15, 1991. Table C-22 presents the results of the August 15 sampling. The
average airborne asbestos concentrations in the previously abated area (0.035 s/cm3)
exceeded 0.02 s/cm3; therefore NJDOH directed the school to initiate a response
action to reduce the airborne asbestos concentrations in this area. The school
subsequently employed an asbestos abatement contractor to clean the previously
abated and perimeter areas. When the cleaning action was complete, EPA/NJDOH
conducted follow-up air monitoring on August 29, 1991, to determine the residual
levels of airborne asbestos. Table C-23 presents the results of the August 29
88
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TABLE C-21. RESULTS OF APRIL 30, 1991, AIR MONITORING AT SITE H
:
Airborne asbestos concentration, s/cm3
Previously abated area
Perimeter area
Outdoors
0.014
0.003
0
0.003
0.011
0.008
0.003
0.003
0.005
0
0.008
0.003
Average: 0.003
Average: 0.005
TABLE C-22. RESULTS OF AUGUST 15, 1991, AIR MONITORING AT SITE H
Airborne asbestos concentration, s/cm3
Previously abated area
0.061
0.005
0.048
0.050
0.011
Average: 0.035
1
Perimeter area
0.005
0.020
0
0.014
0.025
Average: 0.013
============================
Outdoors
0
0
0
0
0
Average: 0
=============================^=-1
89
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TABLE C-23. RESULTS OF AUGUST 29, 1991, AIR MONITORING AT SITE H
=== ===
Airborne asbestos concentration, s/cm3
Previously abated area
Perimeter area
Outdoors
0.073
0
0
0
0
0
0
0.005
0
0
Average: 0.016
Average: 0
Average: 0
sampling. The average airborne asbestos concentrations in the previously abated
area and in the perimeter area were below 0.02 s/cm3; therefore, no further monitoring
activity was required at this school. Intervention continued in order to resolve the
elevated asbestos concentrations at this site.
NJDOH Visual Inspection
On August 16, 1991, a NJDOH Visual Inspection was conducted at Site H to
determine potential sources of airborne asbestos measured by EPA/NJDOH in April
1991. The visual inspection strategy considered the asbestos-abatement history of
the site, the O&M activities, and other sources of possible asbestos contamination
(i.e., materials not included in the Asbestos Management Plan). Only those areas of
the 1988 abatement indicated in the following subsections were examined.
1988 Abatement Areas
Corridor by the Shop Areas
Spray applied ceiling debris collected from the top surface of the ceiling access
panels contained 7% chrysotile asbestos (Table C-24). An accumulation of dust found
90
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TABLE C-24. SUMMARY OF BULK SAMPLE RESULTS-SITE H REINSPECTION
Location
Type of material
Analysis
1988 Abatement Area
Drafting storage
Hall at shops
Hall at shops
Hall at shops
Hall to gymnasium
Hall to gymnasium
Hall at shops
Hall intersection (shop-
cafe), access panel
End shop, partition wall
Drafting shop, partition
wall
Drafting shop
1988 Perimeter Area
Hall at Custodian's office
Auditorium stage, wall at
electrical panel
Auditorium stage, by duct
Block pipe insulation debris
Above suspended ceiling, 4-in. block
pipe insulation
Above suspended ceiling, elbow
debris with dark spots
Above suspended ceiling, 7-in. block
pipe insulation with straw
Above suspended ceiling, elbow with
dark spots
Above suspended ceiling, block pipe
insulation with straw
Radiator dust
Residual ceiling material
Dust and debris
Ceiling debris
Radiator dust
Duct insulation
Debris
Debris
Negative
Negative
Negative
Negative
Negative
Negative
Positive", chrysotile asbestos
7% chrysotile asbestos
Positive, chrysotile asbestos
8% chrysotile asbestos
Positive, chrysotile asbestos
1% chrysotile asbestos
6% amosite asbestos
35% chrysotile asbestos
27% chrysotile asbestos
1 This classification was defined by the NJDOH laboratory to accommodate samples of which there is
not adequate material available to allow a full quantitative evaluation, but are of sufficient size to
determine that asbestos is present and to determine the specific type of asbestos. Based on the
professional judgement of the analyst, the sample is considered to contain greater than 1%
asbestos.
91
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I
I on the baseboard heating pipes tested positive for asbestos (Table C-24). The TSI on
_ pipes above the ceiling did not contain asbestos (Table C-24).
Corridor to the Gymnasium
| The TSI on pipes above the ceiling did not contain asbestos (Table C-24).
_ Mechanical Arts Shops
: Metal partition walls along the windows contained ceiling debris (8% chrysotile)
• and dust that tested positive for asbestos (Table C-24). Radiators were also found to
contain debris and dust that tested positive for chrysotile asbestos (Table C-24).
| 1988 Perimeter Areas
m Hallway by the Custodian's Locker Room
; Duct insulation above the ceiling in the hallway outside the mens custodian
£ locker room was friable and contained 1% chrysotile and 6% amosite asbestos (Table
C-24). The duct insulation was not included in the Asbestos Management Plan.
• Auditorium
• A fireproofing type of material adhered to several areas of the stage wall. Two
samples of this material contained 27 and 35% chrysotile asbestos (Table C-24).
| Conclusions
I The asbestos-containing debris and dust on ceiling panels and behind
partition walls was a source of airborne asbestos fibers measured in May
1991.
• « Asbestos-containing duct insulation was not identified in the Asbestos
Management Plan.
• • The Asbestos Management Plan erroneously identified the TSI on pipes
above the corridor ceilings as asbestos-containing material.
I
• 92
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PHASE HI CASE HISTORY
SITES K AND N
Background
During the summer of 1988, asbestos-containing acoustical ceiling plaster was
removed from Sites K and N. The abatement area included corridors, mechanical arts
classrooms, and offices. The acoustical plaster contained 10 to 25% chrysotile
asbestos. The information regarding the abated ACM and associated asbestos-
content was obtained from the asbestos-abatement specification for these sites.
During the summer of 1991, 75,600 square feet of asbestos-containing ceiling
plaster was abated from areas of the school unrelated to the two areas abated in
1988. No other abatement activity occurred between 1988 and 1991.
Summary of 1991 (Phase III) Air Monitoring Data
Site K
On April 29, 1991, EPA/NJDOH collected air samples during periods of normal
activity (i.e., occupied conditions) at Site K from the same locations as those collected
in 1988 and 1990. Table C-29 presents the results of the April 29 sampling. Since
the average airborne asbestos concentration in the previously abated area (0.041
s/cm3) exceeded 0.02 s/cm3, EPA/NJDOH conducted follow-up monitoring under
simulated occupancy conditions on August 14, 1991, to determine whether airborne
asbestos was still present at levels similar to those measured in April 1991. Table C-
30 presents the results of the August 14 sampling. The August 14 results revealed
that the average airborne asbestos concentrations in the previously abated area and
in the perimeter area were below 0.02 s/cm3; therefore, no further monitoring activity
was required at this school. Intervention continued in order to resolve the elevated
asbestos concentrations at this site.
93
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TABLE C-29. RESULTS OF APRIL 29, 1991, AIR MONITORING AT SITE K
Airborne asbestos concentration, s/cm3
Previously abated area
0.097
0.014
0.022
0.040
0.033
Average: 0.041
Perimeter area
0
0
0.006
0.003
0.007
Average: 0.003
Outdoors
0
0
0
0
0
Average: 0
TABLE C-30. RESULTS OF AUGUST 14, 1991, AIR MONITORING AT SITE K
Airborne asbestos concentration, s/cm3
Previously abated area
0.006
0.005
0.005
0
0.005
Average: 0.004
Perimeter area
0
0.005
0
0
0
Average: 0.001
Outdoors
0
0
0.009
0.006
0
Average: 0.003
94
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Site N
On April 29, 1991, EPA/NJDOH collected air samples during periods of normal
activity (i.e., occupied conditions) at Site N from the same locations as those collected
in 1988 and 1990. Table C-31 presents the results of the April 29 sampling. Although
the average airborne asbestos concentrations in the previously abated area and in the
perimeter area did not exceed 0.02 s/cm3, EPA/NJDOH conducted follow-up
monitoring under simulated occupancy conditions on August 14,1991, because the
average airborne asbestos concentration in the previously abated area from a second
abatement project at this school (Site K) did exceed 0.02 s/cm3. Table C-32 presents
the results of the August 14 sampling. The August 14 results revealed that the
average airborne asbestos concentrations in the previously abated area and in
perimeter areas of Site N were below 0.02 s/cm3; therefore, no further monitoring
activity was required at this site.
NJDOH Visual Inspection
On August 15, 1991, an NJDOH Visual Inspection was conducted at Sites K
and N to determine potential sources of airborne asbestos measured by EPA/NJDOH
in April 1991. The visual inspection strategy considered the asbestos-abatement
history of the site, the O&M activities, and other sources of possible asbestos
contamination (i.e., materials not included in the Asbestos Management Plan). Only
those areas indicated in the following subsections were examined.
1988 Abatement Areas
Carpentry Shop and Classroom
Surface dust on building and equipment surfaces tested positive for asbestos
(Table C-33). Floor tile from the carpentry classroom contained 7% chrysotile. The
floor tile was not identified as ACM in the management plan. No apparent source of
the asbestos-containing material associated with the 1988 abatement was identified in
this area.
95
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TABLE C-31. RESULTS OF APRIL 29, 1991, AIR MONITORING AT SITE N
Airborne asbestos concentration, s/cm3
Previously abated area
Perimeter area
Outdoors
0.009
0.012
0
0.003
0.015
0
0.003
0.003
0
0.003
0
0.003
0.046
0
Average: 0.004
Average: 0.015
Average: 0
TABLE C-32. RESULTS OF AUGUST 14, 1991, AIR MONITORING AT SITE N
Airborne asbestos concentration, s/cm3
Previously abated area
0
0
0
0
0.013
Average: 0.003
*"•"• •'• ' ' — <_
Perimeter area
0
0
0.005
0.005
0
Average: 0.002
==================
Outdoors
0
0
0.009
0.006
0
Average: 0.003
====================
96
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TABLE C-33. SUMMARY OF BULK SAMPLE RESULTS
SITES K AND N REINSPECTION
1988 Abatement Area
Dust samples:
Carpentry loft
Carpentry shop
Carpentry shop
Carpentry shop
Carpentry shop
Carpentry shop
Bulk samples:
Carpentry shop
Carpentry classroom
Carpentry shop
Carpentry shop
Carpentry shop
Carpentry shop
Carpentry shop classroom
Carpentry shop
1988 Perimeter Area
Hall outside carpentry shop
Special education
Exterior storage
Duct grill
North Nesbitt heater
South Nesbitt heater
Table saw motor box
Window ledge, north
Window ledge, north
Spray-on ceiling material
Dust, top of ceiling
Roofing felt
Spray flakes, window ledge
Roof shingles (display)
Ceiling tile
Floor tile
Sheetrock (display)
Ceiling tile
Sheetrock (stored)
Mason's sand
Negative
Positive8, amosite asbestos
Positive, chrysolite asbestos
Positive, chrysotile asbestos
Positive, chrysotile asbestos
Positive, chrysotile asbestos
Positive, amosite asbestos
Positive, chrysotile asbestos
Positive, amosite asbestos
Negative
Negative
Negative
Negative
Negative
Negative
7% Chrysotile asbestos
Traceb, chrysotile asbestos
Negative
Negative
Negative
This classification was defined by the NJDOH laboratory to accommodate samples of which there is
not adequate material available to allow a full quantitative evaluation, but are of sufficient size to
determine that asbestos is present and to determine the specific type of asbestos. Based on the
professional judgement of the analyst, the sample is considered to contain greater than 1%
asbestos.
b Trace = <1% asbestos
97
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I 1988 Perimeter Areas
m Hallway and Miscellaneous Classrooms
\ Samples of building materials did not show detectable levels of asbestos. No
I apparent source of the asbestos-containing material was identified.
_ Conclusions
• Although asbestos-containing dust was present on surfaces in the carpentry
shop, no apparent sources of asbestos associated with the 1988 abatement could be
identified in this area or in other perimeter areas.
• Asbestos materials in the brake and clutch assemblies in various high speed
equipment could be a possible source of elevated levels. The misidentification of VAT
in the management plan could also lead to uncontained VAT removals, improper O&M
and possible contamination.
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• 98
!
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APPENDIX D
AVERAGE AIRBORNE ASBESTOS CONCENTRATIONS MEASURED
IN 1988, 1990, AND 1991
99
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