AN EVALUATION OF ASBESTOS MANAGEMENT
PROGRAMS IN 17 NEW JERSEY SCHOOLS
A Case Studies ^Report
by
Environmental Quality Management, Inc.
Cincinnati, Ohio 45240
and
Environmental Health Service
New Jersey Department of Health
Trenton, New Jersey 08625
EPA Contract No. 68-D2-0058
Project Officer
Aaron R. Martin
Stationary Source Compliance Division
U.S. Environmental Protection Agency
Washington, D.C. 20460
Thomas J. Powers
Technical Project Monitor
Water and Hazardous Waste Treatment Research Division
Risk Reduction Engineering Laboratory
Cincinnati, OH 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
four years after asbestos abatement at 17 schools in New Jersey. Reviews of each
school's Asbestos Management Plan, air monitoring, and thorough visual inspections
were conducted to evaluate the asbestos management programs at these schools.
Case histories of each school are provided, which summarize data collected during
1988, 1990, 1991, and 1992.
E. Timothy Oppelt, Director
Risk Reduction Engineering Laboratory
iii
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ABSTRACT
From 1988 through 1992, the U.S. Environmental Protection Agency's Risk
Reduction Engineering Laboratory (EPA-RREL) and the New Jersey Department of
Health's Environmental Health Service (NJDOH-EHS) conducted studies in 17 schools
in New Jersey to evaluate their asbestos management programs.
Findings of a study conducted in 1988 to document Asbestos Hazard
Emergency Response Act (AHERA) final clearance concentrations of asbestos at
these 17 schools prompted a followup study in 1990 to determine the airborne
asbestos concentrations 2 years after the abatement efforts. Although the 1990 study
provided data regarding airborne asbestos levels during simulated occupancy
conditions 2 years after abatement, whether these data were representative of levels
during actual occupancy was uncertain.
Another followup study conducted in May 1991 to determine the airborne
asbestos concentrations during actual occupied conditions showed airborne asbestos
levels to be above the AHERA initial screening criterion of 70 s/mm2 at eight of the
sites. Reentrainment of residual asbestos-containing debris from the 1988 abatement
or from operations and maintenance activities may have contributed to these elevated
airborne asbestos concentrations.
In 1992, EPA/NJDOH conducted a final study at the 17 schools to measure
airborne asbestos levels during actual occupied conditions 4 years after abatement.
This report presents the results of the 1992 study and integrates the results of the
three previous studies to evaluate the asbestos management programs in these
schools. It also presents case histories of each study site that summarize the findings
of the 1988, 1990, 1991, and 1992 studies.
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 partial fulfillment of Contract No. 68-D2-0058.
The report covers the period of June 1988 through September 1992, and work was
completed as of September 30, 1993.
IV
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CONTENTS
Disclaimer ii
Foreword iii
Abstract iv
Figures vi
Tables vii
Acknowledgments ix
1. Introduction 1
Background 1
Objectives 2
2. Conclusions and Recommendations 3
Conclusions 3
Recommendations 5
3. Study Design and Methods 7
Air Sampling Strategy 7
Site Documentation 10
NJDOH Inspections 10
Sampling Methods 11
Analytical Methods 12
Statistical Methods 12
4. Quality Assurance 15
Sample Chain of Custody 15
Sample Analysis 15
5. Results and Discussion 19
Site Descriptions 19
Airborne Asbestos Levels During Occupied
Conditions in May 1992 19
NJDOH Inspections 27
Comparison of 1988, 1990, 1991 and 1992 Airborne
Asbestos Levels 33
General Observations from 1988, 1990, 1991,
and 1992 Studies 39
References 48
Appendices
A Individual Estimates of Airborne Asbestos Concentrations
Four Years After Abatement (1992) at 20 Sites
B Case Histories
v
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FIGURES
Number Page
1 Average Airborne Asbestos Concentrations (s/cm3) in the 1988 Abatement
Area Measured During Occupied Conditions in May 1992 23
2 Average Airborne Asbestos Concentrations (s/cm3) in the 1988
Perimeter Area Measured During Occupied Conditions in May 1992 24
3 Average Concentration of Asbestos Structures per Square Millimeter
(s/mm2) in the 1988 Abatement Area Measured During Occupied
Conditions in May 1992 25
4 Average Concentration of Asbestos Structures per Square Millimeter
(s/mm2) in the 1988 Perimeter Area Measured During Occupied
Conditions in May 1992 26
VI
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TABLES
Number
1 Summary of Air Sampling Strategies 8
2 Number of Area Air Samples Collected at Each Site During
Occupied Conditions in May 1992 9
3 Data Summary for Replicate Analyses 17
4 Data Summary for Duplicate Analyses 18
5 Abatement History and Remaining ACM at the 20 Sites 20
6 Airborne Asbestos Concentrations Measured During Occupied
Conditions at 20 Sites in May 1992 21
7 Overall Distribution of Asbestos Structures Measured
During Occupied Conditions at 20 Sites in May 1992 27
8 Overall Cumulative Size Distribution of Asbestos Structures
Measured During Occupied Conditions at 20 Sites in May 1992 28
9 Summary of NJDOH-EHS Inspections and Air Monitoring Conducted in
1991 and 1992 29
10 Followup Air Monitoring Results at Eight Sites in 1991 32
11 Followup Air Monitoring Results at Six Sites in 1992 33
12 Mean Concentrations of Airborne Asbestos Measured at 20 Sites
in 1988, 1990, 1991, and 1992 34
13 Comparison of Sampling Locations for Airborne Asbestos Measured
in 1988, 1990, 1991 and 1992 35
14 Comparison of Yearly Concentrations of Airborne Asbestos 38
15 Summary Observations from 1988, 1990, 1991, and 1992 EPA/NJDOH
Studies 40
16 Average Airborne Asbestos Levels Measured in Perimeter Areas
and Outdoors Before the 1988 Abatement 42
17 Average Asbestos Levels in Perimeter Areas at Sites Where
Preabatement Samples Were Collected 42
(continued)
vii
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TABLES (continued)
Number
18 Airborne Asbestos Concentrations Measured Before Final Cleaning
of Abatement Area in 1988 47
VIII
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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. 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 technical guidance and administrative efforts of Roger C. Wilmoth and Bruce
A. Hollett of RREL.
This document was written by John R. Kominsky, Ronald W. Freyberg, and
Carolyn S. Hubert 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 acknowledge Edward Millerick of NJDOH-EHS for reviewing the Asbestos
Management Plans and conducting the visual inspections at the 17 schools. The
authors also gratefully acknowledge the staff of the NJDOH-EHS's Technical Unit and
Field Operations Unit for their contributions.
IX
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SECTION 1
INTRODUCTION
The U.S. Environmental Protection Agency (EPA) recommends a pro-active, in-
place management program whenever asbestos-containing material is present in
buildings.1 Asbestos removal is required only when necessary to prevent significant
public exposure to airborne asbestos structures during building demolition or
renovation activities.2 The ultimate goal of every asbestos abatement project is to
eliminate, or reduce to the extent possible, the actual or potential hazard airborne
asbestos structures may present to building occupants. If all safeguards are not
properly applied,3 asbestos removals may actually elevate airborne levels of asbestos
structures in a building.1-4
The Risk Reduction Engineering Laboratory (RREL) of EPA and the
Environmental Health Service (EHS) of the New Jersey Department of Health
(NJDOH) conducted a series of studies to measure residual airborne asbestos levels
immediately after and 2 to 4 years after abatement in 17 New Jersey Schools.5'6-7-8
The primary purpose of these studies was to evaluate the asbestos management
programs in these schools.
Background
In 1988, EPA-RREL and NJDOH-EHS conducted a study to document
Asbestos Hazard Emergency Response Act (AHERA) air-sampling practices during
final clearance and to measure final clearance concentrations of airborne asbestos at
20 projects involving removal of asbestos-containing material (ACM) in 17 New Jersey
schools.5-6 This study identified significant discrepancies between the airborne
asbestos concentrations measured by the Asbestos Safety Control Monitor (ASCM)
firms employed by the school and those measured independently by EPA/NJDOH. In
general, the EPA/NJDOH samples showed that significant levels of airborne asbestos
remained in 10 of the schools that passed the AHERA clearance tests based on the
ASCM data. These 10 schools would have failed the AHERA initial screening criterion
of 70 asbestos structures per square millimeter (s/mm2), and 7 of the schools would
also have failed the AHERA Z-test.9
In 1990, EPA/NJDOH conducted a study at the same 17 schools to measure
airborne asbestos concentrations 2 years after the abatements in 1988.7 The samples
were collected in August when the schools were unoccupied; however, occupied
conditions were simulated by using a modified aggressive sampling protocol. Fifteen
1
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of the schools showed airborne asbestos levels significantly less than those measured
in 1988; however, two schools showed significantly higher concentrations in 1990 than
in 1988. The reduction in airborne asbestos levels could be attributed to the
monitoring being conducted after the schools completed their summer janitorial
cleaning. Although the 1990 study provided valuable data regarding the residual
levels of asbestos 2 years after abatement, the extent to which these data represented
conditions of actual occupancy remained uncertain.
In 1991, EPA/NJDOH measured airborne asbestos concentrations at the 17
schools 3 years after the 1988 abatement.8 The samples were collected during actual
occupied conditions (i.e., during normal school hours). At the eight schools showing
average airborne asbestos concentrations above the AHERA initial screening criterion
of 70 s/mm2, the NJDOH-EHS required response actions to be taken to lower the
airborne asbestos levels below the criterion of 0.02 asbestos structures per cubic
centimeter (s/cm3) of air sampled.
In 1992, EPA/NJDOH conducted a final study at the 17 schools to measure
airborne asbestos levels under actual occupied conditions 4 years after abatement.
This report presents the results of the 1992 study and integrates the results
from the previous studies to evaluate the asbestos management programs at these
schools. Also presented are case histories of each study site, which summarize the
findings of the 1988,1990,1991, and 1992 studies.
Objectives
The objectives of the study were as follows:
0 To determine the airborne asbestos levels measured during occupied
conditions in 17 schools that underwent abatement in 1988.
0 To evaluate the airborne asbestos levels measured in the 17 schools
over the 4-year period (1988, 1990, 1991, and 1992).
0 To determine the accuracy of each school's Asbestos Management Plan
for the areas monitored.
0 To determine the possible sources of airborne asbestos in schools with
elevated levels.
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SECTION 2
CONCLUSIONS AND RECOMMENDATIONS
Conclusions
The following are the principal conclusions reached during this study:
1) Overall, when all of the 20 sites were considered collectively, there was no
apparent trend toward progressively increasing airborne asbestos
concentrations 2 to 4 years after the 1988 abatements. There were a number
of sites, however, where elevated airborne asbestos concentrations were
measured immediately after and 2 to 4 years after the 1988 abatements.
0 In 1988, 1991, and 1992, the average airborne asbestos concentrations
measured by transmission electron microscopy in the 1988 abatement
and/or perimeter areas exceeded the New Jersey Department of Health
response action criterion of 0.02 s/cm3 at 10, 8, and 6 of the 20 sites,
respectively.
0 Overall, in 1988, 1990, and 1991, postabatement airborne asbestos
concentrations measured in the 1988 abatement and/or perimeter areas
were statistically significantly greater than those measured outdoors.
Although individually the airborne asbestos concentrations in the 1988
abatement and perimeter areas were not significantly different from those
measured outdoors in 1992, when these concentrations were combined,
they were significantly greater than those measured outdoors.
0 Overall, approximately 5 percent of the asbestos structures measured in
1988, 1990,1991, and 1992 at these 17 schools were greater than 5 jim in
length.
0 Overall at nine schools, airborne asbestos concentrations in the perimeter
areas after the 1988 abatement were statistically significantly higher than
those measured before the abatement.
0 Overall, differences between airborne asbestos concentrations measured at
these 17 schools in 1988,1990,1991, and 1992 were not statistically
significant in the perimeter areas. Airborne asbestos concentrations
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measured in the abatement area in 1988 were statistically significantly
greater than those measured in 1990 and 1992.
2) Response actions conducted by the schools in 1991 and 1992 demonstrated
that elevated airborne asbestos levels (i.e., >0.02 s/cm3) can be reduced to
acceptable levels. Response actions reduced the levels of airborne asbestos to
below 0.02 s/cm3; however, five of the eight schools requiring a response action
in 1991, again required a response action in 1992.
3) Asbestos-containing debris from the 1988 abatement and from postabatement
operations and maintenance (O&M) activities may have contributed to the
elevated airborne asbestos levels (>0.02 s/cm3) present in 1991 and/or 1992 at
nine sites.
0 The location of the asbestos-containing debris found at six sites indicates
that the residual debris from the 1988 abatement may have contributed to
the elevated airborne asbestos levels at these sites.
0 O&M activities that disturbed asbestos-containing materials (including
thermal system insulation and plaster, and resilient floor tile) may have
contributed to elevated airborne asbestos levels at three sites.
4) Errors in the Asbestos Management Plans or their implementation were
documented and at several schools may have resulted in the accidental
disturbance of asbestos-containing materials (ACM).
0 At 13 of the 17 schools, the Management Plan contained at least one error
relating to material identification or material location.
0 At two schools, O&M activities that disturbed ACM (not identified in the
Management Plan) may have contributed to the elevated airborne asbestos
levels.
0 At one school, O&M activities that disturbed ACM (identified in the
Management Plan) may have contributed to the elevated airborne asbestos
levels.
5) A standardized visual inspection is an effective tool to determine the presence
of residual asbestos-containing debris that may potentially become reentrained.
6) When the AHERA Z-test is used to clear an abatement project, it is generally
more appropriate to utilize the outdoor samples as the reference point than the
perimeter samples collected inside the building.
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0 At nine schools, airborne asbestos levels in the perimeter areas after the
1988 abatement were significantly higher than those measured before the
abatement. (Results of preabatement samples collected in the perimeter
areas and outdoors did not differ significantly).
0 The Z-test, utilizing outdoor samples as the "outside values", matched the
results of the AHERA initial screening criterion at 18 of the 20 sites.
7) Consultants who conducted the school's clearance air monitoring in 1988 often
did not completely understand and follow the AHERA sampling and analytical
requirements and recommendations. Practices observed during clearance
monitoring included, inadequate drying of the abatement area prior to sampling,
use of improper sampling medium and flow rates, inadequate aggressive air
sweeping of surfaces, and insufficient use of circulating fans to maintain air
movement during sampling.
8) In 1988, AHERA clearance concentration discrepancies existed between results
of sample analyses reported by the school's consultant and those reported
independently by EPA/NJDOH. Twelve of the 20 abatement sites would have
failed the AHERA initial screening test had the EPA/NJDOH sample analyses
been used. Ten of these sites would have subsequently failed the AHERA
Z-test by using outdoor levels in the comparison.
9) Sampling factors typically encountered during the summer in schools (e.g.,
unoccupied conditions, reduced level of activity, major cleaning efforts,
inoperative heating, ventilation, and air-conditioning system) can yield results
that may not be representative of occupied conditions during the school year.
0 Sampling results during unoccupied conditions in 1990 showed no average
airborne asbestos levels above 0.02 s/cm3. Eight sites showed average
levels of airborne asbestos above 0.02 s/cm3 during occupied conditions in
1991, however. Similarly, six sites showed average levels of airborne
asbestos above 0.02 s/cm3 during occupied conditions in 1992.
0 Average airborne asbestos concentrations measured during unoccupied
conditions in 1990 in the 1988 abatement and perimeter areas and
outdoors were numerically lower than the other two years of monitoring.
Recommendations
1) A study should be conducted to evaluate the long-term effectiveness of
asbestos response actions (e.g., cleaning, encapsulation, enclosure, repair) in
schools. This information would assist EPA in evaluating the need for issuance
of guidance on asbestos response actions.
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2) Although not specifically required by AHERA, schools should evaluate the
effectiveness of their asbestos O&M Program and periodic surveillance. Areas
of the building that have undergone an asbestos-removal or O&M activity
(involving ACM) should be thoroughly reinspected for the presence of residual
asbestos-containing debris. If asbestos-containing debris is observed, a
thorough cleaning and follow-up air monitoring should be conducted.
3) Each school should maintain and update its Management Plan to keep it
current with ongoing O&M, periodic surveillance, inspection, reinspection,
response actions, and post-response action activities. The school should
ensure that workers who may disturb ACM are aware of changes in the
Management Plan.
4) EPA cooperatively with State Agencies need to provide further outreach and
education to all responsible parties such as Local Education Agencies, AHERA
designated persons, and consultants, to enhance their understanding of the
intent and requirements of AHERA. Thorough regulatory oversight is necessary
to ensure compliance within the requirements of AHERA.
5) Outdoor air samples should be used as the "outside values" in the AHERA Z-
test because they are less likely to be affected by work practices that may
contaminate other areas inside the building.
6) A standardized visual inspection technique (e.g., ASTM Standard E1368)
should be included in the AHERA final clearance procedure. Furthermore, this
type of standardized visual inspection procedure (or a variation thereof) should
be incorporated into the three-year AHERA Asbestos Management Plan
reinspections (40 CFR 763.85).
7) A comprehensive guidance document should be developed that addresses the
procedures and protocols for conducting a standardized visual inspection and
AHERA clearance air sampling. This document would supplement existing EPA
guidance (Guidelines for Conducting the AHERA TEM Clearance Test to
Determine Completion of an Asbestos Abatement Project-EPA 560/5-89-001)
which emphasizes interpretation of AHERA clearance results.
6
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SECTION 3
STUDY DESIGN AND METHODS
This study was conducted at the same 17 schools involved in the 1988 EPA/
NJDOH study, that documented AHERA air monitoring practices and final clearance
concentrations of airborne asbestos,5'6 in the 1990 EPA/NJDOH study that measured
airborne asbestos concentrations 2 years after abatement,7 and in the 1991 EPA/
NJDOH study that measured airborne asbestos concentrations 3 years after
abatement.8
The 17 schools involved 20 abatement sites. Although the original selection of
the 20 abatement sites in 1988 was based largely on availability, each site also met
specific criteria. The criteria included 1) building used as a school, 2) removal of
various types of ACM (e.g., spray-applied fireproofing), and 3) the abatement project
was cleared in accordance with AHERA clearance procedures. 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 (hereafter referred to ,as the 1988 abatement area), 2) the
perimeter area (outside the 1988 abatement 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. It
was also recognized that, in the interim since 1988, other sources (e.g., routine
maintenance of asbestos-containing resilient floor tile or other O&M activities involving
asbestos-containing building materials) may have contributed to the current
concentrations of airborne asbestos.
One objective of the study was to measure airborne asbestos concentrations
during occupied conditions at the 17 schools that underwent abatements in 1988.
Although these 17 schools did not represent a statistical random sample, there was no
identifiable biases in this sample of schools or in the abatement methods used. The
only likely difference in the schools was their current status with regard to the
presence of ACM. Hence, the data from each of the 20 sites were combined for
statistical analysis to reach conclusions about the 17 schools.
Air Sampling Strategy
The air sampling strategy for this study consisted of monitoring during periods
of occupancy at all 17 schools representing the 20 sites. Response actions were
conducted at sites with average airborne asbestos concentrations above 0.02 s/cm3.
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The 0.02 s/cm3 criterion was derived from the AHERA initial screening criterion of 70
s/mm2 (40 CFR 763) and was used by NJDOH-EHS as a level that, if exceeded,
required the school to initiate a response action to reduce the airborne asbestos
concentration to below 0.02 s/cm3. A modified aggressive air sampling protocol was
used to conduct followup sampling to determine the completion of the response
actions. Table 1 summarizes the air sampling strategy for this study and those for the
three preceding studies in 1988,5'6 1990,7 and 1991.8
TABLE 1. SUMMARY OF AIR SAMPLING STRATEGIES
Period of study
June-July 1988
July-Sept. 1988
July-Sept. 1988
July-Aug. 1990
May 1991
August 1991
August 1991
Sept. 1991
May 1992
July-Aug. 1992
No. of
sites
11
16
20
20
20
10
4
1
20
6
Conditions of sampling
Passive3
Abatement conditions
Aggressive6/ passive
Modified aggressive0
Occupied
Modified aggressive
Modified aggressive
Modified aggressive
Occupied
Modified aggressive
Monitoring criteria
Determine preabatement levels
Determine pre-final cleanup levels
AHERA final clearance
Two-year followup
Three-year followup
Confirm if levels exceeded 0.02 s/cm3
Verify completion of followup response action
Verify completion of followup response action
Four year followup
Verify completion of response action
a Minimal occupant activity in the area.
b Aggressive sampling protocol in accordance with AHERA - 40 CFR 763.
c Sampling protocol to simulate normal occupant activity, including air sweeping of floors with
exhaust of 1-hp leaf blower and positioning of one stationary fan per 10,000 ft3.
May 1992
At each site, five area air samples were collected in each of three areas: 1) the
1988 abatement area 2) the perimeter area (outside the 1988 abatement 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 1988,1990, and 1991 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
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TABLE 2. NUMBER OF AREA AIR SAMPLES COLLECTED AT EACH SITE
DURING OCCUPIED CONDITIONS IN MAY 1992
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
1988 Abatement 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)c
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).
0 Same samples as collected at Site B (i.e., Site Q was the second abatement
project at this school).
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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.10
July-August 1992
Based on the May 1992 sampling, five schools representing six sites were
required to conduct a response action in the 1988 abatement area and/or perimeter
areas to reduce the risk of exposure to airborne asbestos in these school buildings.
The response action taken at each of the schools primarily involved cleaning the areas
to remove all visible dust and debris. Subsequent to the response actions,
EPA/NJDOH collected additional area air samples in the affected areas to establish
that they were below 0.02 s/cm3. The number and locations of the samples were the
same as those collected in May 1992.
Site Documentation
For each of the 17 schools monitored in May of 1991 and 1992, the NJDOH-
EHS documented the history of the abatement activities between 1988 and 1992 and
O&M activities on any remaining asbestos-containing material (ACM) in the 1988
abatement area and perimeter area. This information was obtained from abatement
notices required under the New Jersey Administrative Codes (N.J.A.C. 8:60-7 and
N.J.A.C. 12:120-7), from AHERA Asbestos Management Plans, and by the AHERA
Designated Person and/or school officials who were interviewed.
NJDOH Inspections
In 1991, a certified AHERA building inspector from NJDOH-EHS conducted an
inspection at each of these schools. The inspection included a review of the school's
Asbestos Management Plan relating to the 1988 abatement areas and perimeter areas
and a visual inspection of these areas. In July through August 1992, a followup visual
inspection was conducted at four schools with elevated airborne asbestos levels (i.e.,
>0.02 s/cm3) based on monitoring conducted in May 1992.
Management Plan Review
Prior to conducting the visual inspection, each school's Asbestos Management
Plan was reviewed. The Asbestos Management Plan describes all activities planned
and undertaken by a school to comply with AHERA (40 CFR 763), including building
inspections to identify ACM, response actions, and O&M programs to minimize the risk
of exposure to airborne asbestos in school buildings.
The review included 1) recording the material category (e.g., thermal system
insulation), material type (e.g., pipe insulation), amount of material (e.g., linear feet)
and condition of material (e.g., damaged) remaining in the 1988 abatement areas and
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perimeter areas; 2) recording response actions (e.g., removal, encapsulation,
enclosure, repair, or O&M); and 3) recording renovations or asbestos abatements that
occurred after the 1988 abatement. This information was then compared with that
obtained during the visual inspection of the 1988 abatement and perimeter areas to
determine the accuracy of the original AHERA inspection regarding the identification,
assessment, and location of ACM in these areas.
Visual Inspections
The visual inspection was not intended to be a comprehensive assessment of
the ACM in the school; rather, it was designed to focus on the areas monitored (i.e.,
1988 abatement areas and perimeter areas) in an attempt to locate the possible
sources of the airborne asbestos contamination measured in May of 1991 and 1992.
This approach assumed that the elevated airborne asbestos levels were generated in
the vicinity of the sampling sites.
The visual inspection included 1) identification and condition of ACM not
recorded in the Management Plan as well as the condition of the ACM recorded in the
Management Plan; and 2) documentation of the presence of asbestos-containing
debris in the 1988 abatement and perimeter areas. These areas were inspected for
the presence of debris, as well as residual ACM on the substrate-surface using
procedures in accordance with those specified in ASTM Standard E 1368-90.14 Debris
was defined as materials that were of an amount and size (particles greater than 1
mm in diameter) that could be visually identified as to their source.
Sampling Methods
Fixed-Station Area Air Samples
Air samples were collected on open-face, 25-mm-diameter, 0.45-nm-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 6 L/min. Air volumes ranged from 1488 to 2500 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 immediately before and after sampling.
Bulk Samples
The NJDOH inspector collected bulk samples of suspect ACM (e.g., thermal
system insulation, fireproofing, acoustical plaster, ceiling tile, floor tile, and gypsum
11
-------
wallboard) or suspect asbestos-containing debris for laboratory analysis to determine
the asbestos content. In school buildings, "asbestos-containing material" is any
material that contains more than 1 percent asbestos. A standard coring tool or
chipping tool was used to collect in-place materials, hand pickup was used for debris
and wipe samples were used for dust. The samples were placed in their respective
labeled containers.
Analytical Methods
Air Samples
The MCE filters were prepared by the direct transfer technique and were
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 an analytical
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 by the NJDOH's Public Health and Environmental Laboratories
in Trenton, New Jersey, in accordance with the "Interim Method for Determination of
Asbestos in Bulk Insulation Samples" (EPA 600/M4-82-020).
Statistical Methods
1992 Airborne Asbestos Concentrations
All estimated concentrations were based on the number of asbestos structures
counted. If no asbestos structures were counted in a sample, that sample was
assigned an estimated concentration of 0 s/cm3.
Airborne asbestos concentrations measured in each of the three sampling
locations (i.e., 1988 abatement area, perimeter area, and outdoors) were
characterized for each site by the use of descriptive statistics. The descriptive
statistics included the arithmetic mean, minimum and maximum concentrations, and
sample size.
12
-------
Although the 17 schools did not represent a statistical random sample and were
likely to differ in abatement history and current status with respect to the presence of
asbestos-containing material, the 1992 data were combined across all sites to
examine overall trends in airborne asbestos concentrations at these schools. The
generalities determined by the overall analysis of these schools should not be
extrapolated to the universe of asbestos-abatement sites; rather, they should be
limited to these 17 schools.
The arithmetic mean airborne asbestos concentration was first calculated for
each of the three sampling locations at each of the 20 abatement sites. This provided
a total of 60 estimates of airborne asbestos concentration for analysis. A two-factor
analysis of variance (ANOVA) was used to examine overall differences in
concentrations measured in the 1988 abatement and perimeter areas and outdoors.
The transformation ln(x + 0.002), where In is the natural logarithm and x is the mean
airborne asbestos concentration, was applied to each measurement before the
ANOVA 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). The data were transferred back to the original scale for reporting purposes.
In addition, each site's respective case history contains a separate analysis of
the airborne asbestos concentrations measured at that site in 1992. A single-factor
ANOVA was used to examine differences between concentrations measured in the
1988 abatement and perimeter areas and outdoors. When overall differences were
detected among the three sampling locations, the Tukey multiple comparison
procedure was used to evaluate pain/vise differences.
1988, 1990, 1991, and 1992 Airborne Asbestos Concentration
Airborne asbestos concentrations measured in 1988,1990, 1991, and 1992
were compared by using a three-factor ANOVA with Site, Sampling Location, and
Year as the main factors. All two-factor interactions were also included in the model.
The arithmetic mean concentration was first determined for each combination of year,
site, and sampling location. The transformation In (x + 0.002), where x is the
calculated arithmetic mean concentration and In is the natural logarithm, was applied
to each measurement before the ANOVA was performed. The data were transferred
back to the original scale for reporting purposes. In addition, each site's case history
contains a separate analysis of airborne asbestos concentrations measured in 1988,
1990, 1991, and 1992 at that site. All statistical comparisons were performed at the
0.05 level of significance. Any reference to a "significant" difference between airborne
13
-------
asbestos concentrations in this report implies that the difference is statistically
significant.
14
-------
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 (100 filters) of the total number of filters (2000 filters) from the
lot used in this research study were analyzed by the U.S. EPA, RREL TEM laboratory.
The filters were prepared by the direct transfer technique and analyzed in accordance
with the nonmandatory AHERA TEM method. The TEM analysis of the 100 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
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 one on a closed field blank.
15
-------
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 17 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 seven 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 47 and 26 percent, respectively. These CVs are consistent with the range of
CVs observed in past EPA studies (0 to 35 percent). The higher CV seen with the
replicate analysis was unexpected; one would expect the CV associated with the
duplicate analysis to be higher because the duplicate analysis uses a second grid
preparation from a different area of the filter. In this case, the higher CV associated
with the replicate analysis is probably due to the combined effects of the small number
of replicate and duplicate analyses, the high number of zero concentrations, and the
method used to calculate the CV. For example, if only the samples with nonzero
concentrations were used, the CV for the duplicate analyses (57 percent) is greater
than that for the replicate analysis (30 percent).
16
-------
TABLE 3. DATA SUMMARY FOR REPLICATE ANALYSES8
Sample
number
A92-05-O
A92-06-P
D92-01-O
D92-04-O
D92-08-P
E92-11-A
F92-04-O
I92-05-O
192-11 -A
L92-15-A
M92-15-A
N92-14-A
P92-08-P
Q92-15-A
R92-11-A
T92-15-A
Original analysis
Nb
1
0
0
0
1
3
1
0
0
3
2
1
0
12
2
0
s/cm3
0.003
0
0
0
0.003
0.008
0.003
0
0
0.007
0.005
0.002
0
0.033
0.005
0
Replicate analysis
Nb
0
0
0
0
3
3
1
2
1
2
0
2
0
16
1
0
s/cm3
0
0
0
0
0.009
0.008
0.003
0.006
0.003
0.005
0
0.005
0
0.044
0.003
0
Different grid openings from the same grid preparation were counted by the same
microscopist.
Number of asbestos structures.
17
-------
TABLE 4. DATA SUMMARY FOR DUPLICATE ANALYSES8
Sample
number
A92-01-O
A92-07-P
J92-01-O
J92-12-A
Q92-14-A
R92-10-P
T92-07-P
Original analysis
Nb
4
0
0
0
38
1
0
s/cm3
0.011
0
0
0
0.104
0.003
0
Duplicate analysis
Nb
1
0
0
0
36
1
0
s/cm3
0.003
0
0
0
0.100
0.003
0
a A second TEM grid preparation was analyzed by the same microscopist.
b Number of asbestos structures.
18
-------
SECTION 5
RESULTS AND DISCUSSION
Site Descriptions
Table 5 presents the abatement history and the remaining ACM at the 20 sites.
Since 1988, abatement has occurred at 1 of the 20 sites (Site O) in the 1988
abatement area and at 4 of the 20 sites (A, D, L, and N) in the 1988 perimeter area.
At 15 sites, ACM is still present in the 1988 abatement areas; at all of the sites, ACM
is still present in the 1988 perimeter areas.
Airborne Asbestos Levels During Occupied Conditions in May 1992
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 1988 abatement area
and 1988 perimeter area, respectively. Figures 3 and 4 illustrate the average
concentration of asbestos structures per square millimeter (s/mm2) of filter in the 1988
abatement area and 1988 perimeter area, respectively, at each of the 20 sites. Six of
the 20 sites (B, D, F, G, H, and Q) showed levels above the AHERA initial screening
criterion of 70 s/mm2 (40 CFR 763) and above the NJDOH-EHS response action
criterion of 0.02 s/cm3 (derived from the AHERA initial screening criterion). Individual
measurements of the airborne asbestos concentrations at each of the 20 sites are
presented in Appendix A.
A two-factor ANOVA was used to examine overall differences in airborne
asbestos concentrations measured at the 20 sites in 1992. When averaged across all
sites, airborne asbestos concentrations measured in the 1988 abatement and 1988
perimeter areas were numerically greater than the concentrations measured outdoors,
but the difference was not statistically significant (p = 0.1161). The overall average
concentrations measured in the 1988 abatement and perimeter areas were
0.008 s/cm3 and 0.007 s/cm3, respectively. The overall average concentration
measured outdoors was 0.003 s/cm3. Although individually the overall airborne
asbestos concentrations measured in the abatement and perimeter areas were not
significantly different from concentrations measured outdoors, when combined, the
indoor airborne asbestos concentrations at these 20 sites (overall average =
0.008 s/cm3) were significantly greater (p = 0.0408) than concentrations measured
outdoors (0.003 s/cm3).
19
-------
TABLE 5. ABATEMENT HISTORY AND REMAINING ACM
AT THE 20 SITES
Site
A
B
C
D
E
F
G
H
1
J
K
L
M
N
O
P
Q
R
S
T
Abatement after 1988
1988
Abatement
area
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
1988
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, TSI
-
-
TSI
-
-
-
-
-
-
-
FT, TR
-
AP
TSI
-
-
-
-
-
Remaining ACMa
1988
Abatement
area
FT, TSI
FT, AP
P(<1%)
TSI
FT, TSI
TSI
None
AP, TSI
None
TSI
FT
FT, TR
P (<1%)
FT
TR
FT, TSI
FT, AP
FT
FT
None
, 1988
Perimeter
area
FT
FT, TSI
P (<1%)
TSI, FT
FT, TSI
FT, TSI, TR
FT, P(<1%)
FT, AP, TSI
FT, TSI
FT
FT, TSI
FT
P(<1%)
FT, TSI
FT, TSI
FT, TSI
FT, TSI
FT, TSI
FT, TSI
FT.CT, TSI
a AP = Acoustical Plaster
TSI = Thermal System Insulation
FT = Resilient Floor Tile
TR = Transite
CT = Ceiling Tile
P = Wall Plaster
20
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Overall Structure Morphology and Length Distributions
Table 7 presents the overall distribution of structure type and morphology from
samples collected at the 20 sites. The TEM analysis of 100 samples collected during
occupied conditions in the 1988 abatement area, 94 samples collected in the
perimeter area, and 83 samples collected outdoors yielded a total of 1552 asbestos
structures, of which 99.7 percent were chrysotile asbestos and 0.3 percent were
amphibole. Overall, the asbestos structures were primarily fibers (87 percent), and to
a lesser extent, matrices, bundles, and clusters. The structures morphology
distributions for each site are presented in each site's respective case history in
Appendix B.
TABLE 7. OVERALL DISTRIBUT8ON OF ASBESTOS STRUCTURES
MEASURED DURING OCCUPIED CONDITIONS AT 20 SITES IN MAY 1992
(percentages)
Sampling location
1988 Abatement area
(N = 676)
1988 Perimeter area (N = 754)
Outdoors (N = 122)
Type of asbestos
Chrysotile
99.6
99.9
100
Amphibole
0.4
0.1
0
Structure morphology
Fibers
85.1
87.9
86.9
Bundles
4.1
2.4
4.9
Clusters
1.0
1.1
0
Matrices
9.7
8.6
8.2
Table 8 presents the overall cumulative size distribution of asbestos structures
from samples collected at the 20 sites during occupied conditions in May 1992.
Overall, less than 1 percent of the measured asbestos structures were greater than 5
u.m in length; most of the structures (97 percent) were less than 2 (im in length. The
cumulative size distributions of asbestos structures at each site are presented in each
site's case history in Appendix B.
NJDOH Inspections
In 1991, NJDOH-EHS conducted an inspection at each of the 17 schools, which
represented 20 sites. Each inspection included a review of the school's Asbestos
Management Plan relating to the 1988 abatement areas and perimeter areas and a
visual inspection of these areas. In July through August 1992, a followup visual
inspection was conducted at three schools that represented four sites with elevated
airborne asbestos levels (i.e., >0.02 s/cm3) based on monitoring conducted in May
1992,.
27
-------
TABLE 8. OVERALL CUMULATIVE SIZE DISTRIBUTION OF
ASBESTOS STRUCTURES MEASURED DURING OCCUPIED CONDITIONS AT
20 SITES IN MAY 1992
(percentages)
Sample location
1 988 Abatement area
1988 Perimeter area
Outdoors
Structure length, \m\
<1
74.0
73.3
81.1
<2
95.4
96.7
96.7
<3
97.9
98.3
98.4
<4
98.2
98.8
99.2
<5
98.5
99.5
99.2
1 percent asbestos based on bulk sample analysis by the NJDOH-EHS. At one of
the sites (F), the ACM identified in the Management Plan was spray-on surfacing
28
-------
TABLE 9. SUMMARY OF NJDOH-EHS INSPECTIONS AND AIR MONITORING CONDUCTED
IN 1991 AND 1992
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Asbestos-containing debris present from
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Other asbestos-containing debris present .
X
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Asbestos level 50.02 s/cm3
1991-1988 abatement area
1991-1988 perimeter area
X X
X
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1992-1988 abatement area
|| 1992-1 988 perimeter area
X
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« Sites with elevated asbestos levels where
potential sources were identified
•5-5 0 -E
29
-------
material, but inspections by NJDOH-EHS showed it to be TSI. At the same site, the
Management Plan did not identify the presence of asbestos-containing TSI in the
boiler. At one of the sites (K), the school's Management Plan did not identify the
resilient floor tile as asbestos-containing.
At one site (F), the Management Plan was in error regarding both the
identification and location of an ACM. The Management Plan indicated the presence
of spray-on materials in an area where no spray-on materials were present. Actually,
TSI was present at this site.
Nine of the 16 sites (B, D through H, K, M, and Q) with Management Plan
errors had elevated airborne asbestos levels in either May 1991 or May 1992. At two
of these 9 sites (F and K), O&M activities involving ACM that was not identified in the
Management Plan may have contributed to the elevated airborne asbestos levels.
Site F involved the disturbance of damaged TSI on piping during installation of a fire
protection system; and Site K involved the removal of asbestos-containing resilient
floor tile. At one site (C) asbestos-containing plaster that was "identified in the
Management Plan" was disturbed. This material may have contributed to the elevated
levels measured at this site.
Residual Asbestos-Containing Debris
The 1991 and 1992 visual inspections of the 1988 abatement areas revealed
that 14 sites had residual debris or dust associated with the 1988 abatement. Each
site was inspected to determine the presence of asbestos-containing debris from the
1988 abatement and/or asbestos-containing debris from other activities. The visual
inspections revealed the presence of asbestos-containing debris at 18 sites (A through
K, M, and O through T) (Table 9). At 14 sites (B through H, J, and O through T) the
debris was present in the 1988 abatement area. Eight of these 14 sites (B through D,
F, H, Q, S, and T) also failed the AHERA initial screening criterion of 70 s/mm2 during
the 1988 clearance test, which indicated that asbestos-containing debris remained in
the abatement area.
The debris identified at the 14 sites was believed to have resulted from the
1988 abatements involving fireproofing, acoustical plaster, ceiling tile, and TSI in these
areas. Debris was believed to be from the 1988 abatements based on 1) information
from the original abatement specifications, 2) sample analysis, 3) location of the
material, and 4) residual debris on the original substrates abated (e.g., pipes). Other
asbestos-containing debris present at 12 of the sites (A, B, E, F, H through K, M, O, Q
and S) generally resulted from damaged TSI, fireproofing, and acoustical plaster. At
one site (B), the debris resulted from efflorescence of concrete-masonry block and/or
mortar resulting in a white powdery material along the base of the wall; this debris
contained chrysotile asbestos.
30
-------
Elevated airborne asbestos levels (i.e., >0.02 s/cm3) were measured by
EPA/NJDOH in the 1988 abatement area and/or perimeter areas at eight sites in May
1991 (Table 9) and at six sites in 1992 (Tables 6 and 9). The potential sources of the
elevated levels were believed to be primarily the debris identified during the NJDOH-
EHS visual inspections conducted in 1991 and/or 1992.
The 1991 and 1992 visual inspections of the 1988 abatement areas revealed
that 14 sites had debris or dust associated with the 1988 abatement. At six of these
14 sites (B, D, E, G, H, and Q) the debris was considered to be much greater (i.e.,
"gross debris") than at the eight other sites with minor debris (C, F, J, O, P, R, S, and
T). Airborne asbestos levels measured at the six sites with gross debris from the
1988 abatement were significantly higher in both 1991 (0.016 s/cm3, p = 0.0411) and
1992 (0.029 s/cm3, p = 0.0086) than those measured at the sites with minor debris
(0.004 s/cm3 and 0.004 s/cm3, respectively).
In addition, other sources such as floor care maintenance activities (including
stripping and spray-buffing of asbestos-containing resilient floor tile12 and routine
vacuuming of carpet13) could also contribute to the airborne asbestos levels present in
these school buildings.6
Response Action Evaluation
1991 Response Action
In May 1991, 8 of the 20 sites (B, D through H, K, and M) had average airborne
asbestos levels above 0.02 s/cm3 (Table 9). In August 1991, EPA/NJDOH conducted
followup monitoring at these sites to determine if the elevated levels still existed.
Results of the followup monitoring indicated that four sites (F, G, H, and M) showed
average levels exceeding 0.02 s/cm3. The NJDOH-EHS required each of these
schools to conduct response actions to reduce the asbestos levels below the 0.02
s/cm3 criterion. The most appropriate response action was determined by each school
and/or their consultant, and included dry-vacuuming of horizontal surfaces with a
HEPA-filtered vacuum cleaner, wet-wiping of horizontal surfaces, or encapsulation.
Subsequent to response actions by the schools, monitoring conducted by EPA/NJDOH
showed that one of the four sites (Site M) had an average airborne asbestos level
above 0.02 s/cm3. Further response actions were required at this site, and NJDOH-
EHS collected additional samples. The final results showed levels below 0.02 s/cm3.
Table 10 presents the results of the followup air monitoring in 1991.
1992 Response Action
In May 1992, six sites (B, D, F through H, and Q) had average asbestos levels
above 0.02 s/cm3 (Table 6). The NJDOH-EHS required each of the five schools
(representing the six sites) to conduct response actions to reduce the asbestos levels
31
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below the 0.02 s/cm3 criterion. Subsequent to the response actions at these schools,
EPA/NJDOH conducted followup air monitoring to determine the residual levels of
airborne asbestos. Based on these results (Table 11), NJDOH-EHS determined that
no further response action was required at these schools. One school (Site F) had an
average airborne asbestos level above 0.02 s/cm3. Additional air monitoring following
further response action showed final airborne asbestos levels below 0.02 s/cm3.
TABLE 11. FOLLOWUP AIR MONITORING RESULTS
AT SIX SITES IN 1992
Site
B
D
F
G
H
Q
1988 Abatement area
Asbestos concentration, s/cm3 (N=5)
Mean
0.001
0.008
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0.015
0.009
Minimum
0
0
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0.004
0
Maximum
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0.021
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0.029
0.020
1988 Perimeter area
Asbestos concentration, s/cm3 (N=5)
Mean
0.006
0
0.070"
0.002
0.02
0.007
Minimum
0
0
0.028"
0
0.004
0.003
Maximum
0.021
0
0.121"
0.004
0.034
0.021
a Followup monitoring by school's consultant after study period.
" Mean of 0.004 s/cm3 after an additional response action.
Comparison of 1988,1990,1991, and 1992 Airborne Asbestos Levels
Table 12 presents the arithmetic mean concentrations of airborne asbestos for
all 20 sites measured in the 1988 abatement area, perimeter area, and outdoors
during the AHERA clearance phase of the 1988 abatement, during simulated
occupancy in 1990, and during occupied conditions in 1991 and 1992. A three-factor
ANOVA was used to examine overall differences in airborne asbestos concentrations
measured at the 20 sites with site, sampling location, and year as the main factors.
The ANOVA results showed that the two-factor interactions were all highly significant
(p = 0.0002). A significant interaction indicates that the differences between one
factor depends on the level of the second factor. For example, a significant interaction
between location and year indicates that the differences in airborne asbestos
concentrations measured in the three sampling locations (1988 abatement area,
perimeter area, and outdoors) varied significantly depending on the year of the
sampling. Therefore, it is not appropriate to average across all 4 years to make an
overall comparison of sampling location. Similarly, it would not be appropriate to
33
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average across all three sampling locations to make an overall comparison of the
yearly averages. Consequently, it was necessary to analyze the data separately for
each year, to examine differences between sampling locations. It was also necessary
to analyze the data separately for each sampling location to examine differences
between the different years. Therefore, a separate two-factor ANOVA was used for
each sampling location and for each year.
Comparison of Sampling Locations
A two-factor ANOVA, with Site and Sampling Location as the main factors, was used
to examine overall differences between the three sampling locations. Each year was
analyzed separately. The results of the ANOVAs are summarized in Table 13.
TABLE 13. COMPARISON OF SAMPLING LOCATIONS FOR AIRBORNE
ASBESTOS MEASURED IN 1988,1990, 1991, AND 1992
Year
1988
1990
1991
1992
ANOVA p-valuea
0.0001
0.0030
0.0001
0.1161
Statistically significant differences in airborne
asbestos concentrationsb-Cid
A(0.020) P(0.006) O(0.002)
P(o.oos) Afo.ooa) oro.oon
A(0.008) P(0.004) O(0.001)
P(0.008) AfO.007) 0(0.003}
a If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
b A «1988 abatement area; P = 1988 perimeter area; O = Outdoors.
c Parenthetical entries are average airborne asbestos concentrations (s/cm3) associated with that
sampling location.
d Sampling locations (averages) connected by a line are not significantly different.
1988
The ANOVA results showed significant differences in airborne asbestos
concentrations between the three sampling locations (p = 0.0001). Specifically,
postabatement airborne asbestos concentrations measured in the 1988 abatement
area were significantly greater than those measured in the perimeter area and
outdoors. No overall difference existed between airborne asbestos concentrations
measured in the perimeter areas and outdoors. The overall average concentrations in
36
-------
the abatement and perimeter areas were 0.020 and 0.006 s/cm3, respectively. The
overall average concentration measured outdoors was 0.002 s/cm3.
1990
The ANOVA results showed significant differences in airborne asbestos
concentrations between the three sampling locations (p = 0.0030). Specifically, the
differences in airborne asbestos concentrations measured in the perimeter area were
significantly greater than those measured outdoors. All other differences in airborne
asbestos concentrations between the three sampling locations were not statistically
significant. The overall average airborne asbestos concentrations measured in the
1988 abatement and perimeter areas were 0.002 and 0.003 s/cm3, respectively. The
overall average concentration measured outdoors was 0.001 s/cm3.
1991
The ANOVA results showed significant differences in airborne asbestos
concentrations between the three sampling locations (p = 0.0001). Specifically, the
airborne asbestos concentrations measured in the 1988 abatement and perimeter
areas were significantly higher than those measured outdoors. The asbestos
concentrations measured in the abatement area were significantly greater than those
measured in the perimeter area. The overall average concentrations measured in the
1988 abatement and perimeter areas were 0.008 and 0.004 s/cm3, respectively. The
overall average airborne asbestos concentration measured outdoors was 0.001 s/cm3.
1992
The ANOVA results showed no significant differences in airborne asbestos
concentrations measured in the 1988 abatement and perimeter areas and those
measured outdoors (p = 0.1161). The overall average airborne asbestos
concentrations measured in the 1988 abatement and perimeter areas were 0.008 and
0.007 s/cm3, respectively. The overall average concentration measured outdoors was
0.003 s/cm3. Although individually the airborne asbestos concentrations in the
abatement and perimeter areas were not significantly different from those measured
outdoors, when these concentrations were combined, the indoor airborne asbestos
concentration (overall average = 0.008 s/cm3) was significantly greater than the
concentrations measured outdoors.
Comparison of Years
A two-factor ANOVA, with Site and Year as the main factors, was used to
examine overall differences between the 4 years of sampling results. Each sampling
location was analyzed separately. The results of the ANOVAs are summarized in
Table 14.
37
-------
TABLE 14. COMPARISON OF YEARLY CONCENTRATIONS
OF AIRBORNE ASBESTOS
Sampling Location
1938 Abatement area
1988 Perimeter area
Outdoors
ANOVA
p-valuea
0.0001
0.2725
0.0369
Statistically significant differences in airborne asbestos
concentrationsbiC
1988(0.020) 1991(0.009) 1992(0.007) 1990(0.002)
1992(0.008) 1988(0.006) 1991(0.004) 1990(0.003)
1992(0.003) 1988(0.002) 1991(0.002) 1990(0.001)
a If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between the years.
b Parenthetical entries are average airborne asbestos concentrations (s/cm3) associated with that
year.
c Years (averages) connected by a line are not significantly different.
1988 Abatement Area
The ANOVA results showed significant differences between airborne asbestos
concentrations measured in 1988, 1990, 1991, and 1992 (p » 0.0001). Specifically,
airborne asbestos concentrations measured in 1988 (overall average = 0.020 s/cm3)
were significantly greater than those measured in 1990 (overall average =
0.002 s/cm3) and 1992 (overall average = 0.007 s/cm3). Additionally, airborne
asbestos concentrations measured in 1991 (overall average = 0.009 s/cm3) were
significantly greater than those measured in 1990. All other differences in airborne
asbestos concentrations among the 4 years of sampling were not statistically
significant.
1988 Perimeter Area
In the 1988 perimeter area, the ANOVA results showed no significant
differences between airborne asbestos concentrations measured in 1988, 1990, 1991,
and 1992 (p = 0.2725). Overall average airborne asbestos concentrations ranged
from 0.003 s/cm3 in 1990 to 0.008 s/cm3 in 1988.
Outdoors
The ANOVA results showed significant differences in airborne asbestos
concentrations measured outdoors in 1988, 1990, 1991, and 1992 (p = 0.0369).
Specifically, outdoor airborne asbestos concentrations were significantly greater in
38
-------
1992 (0.003 s/cm3) than in 1990 (0.001 s/cm3). Outdoor airborne asbestos
concentration did not vary significantly in 1988, 1990, and 1991.
General Observations From 1988,1990,1991, and 1992 Studies
Table 15 presents an overall summary of the air monitoring results from the
four EPA/NJDOH studies conducted during the period of 1988 through 1992. The
table also summarizes AHERA clearance test results based on the EPA/NJDOH data,
and information regarding the visual inspections conducted at these sites. A summary
of important observations made during these studies is presented below.
1988 Preabatement Sampling
Unless all safeguards are properly applied,3 asbestos removals may elevate
airborne levels of asbestos fibers in a building.1-3 To determine the effect of the
abatement on the airborne levels of asbestos structures in a building prior to
abatement, preabatement samples were collected in the perimeter area and outdoors
at nine schools.6 The samples were collected under passive building conditions; i.e.,
there was minimal occupant activity in the building. The airborne asbestos
concentrations measured in the perimeter areas (overall average = 0.001 s/cm3) were
not significantly different from those measured outdoors (overall average =
0.001 s/cm3). Table 16 presents the average airborne asbestos concentrations
measured in the perimeter areas and outdoors in 1988.
Table 17 presents the average airborne asbestos concentrations measured
from preabatement through 1992 at nine schools representing 10 sites. Overall,
airborne asbestos concentrations measured in the perimeter areas in 1992 and in the
postabatement period in 1988 were significantly greater than those measured in the
preabatement period in 1988 (p = 0.0017). Airborne asbestos concentrations
measured in the perimeter area in 1990 and 1991 were not significantly different from
those measured in the preabatement period in 1988. The 1992 level at Sites B/Q
(0.438 s/cm3) contributed significantly to the overall concentration measured in 1992.
In fact, if Sites B/Q are omitted, the only significant difference in airborne asbestos
concentrations measured in the perimeter areas was between post-abatement and
preabatement concentrations in 1988 (p - 0.0277). Specifically, levels were
significantly higher, on average, after the abatement than before the abatement at
these eight sites.
The specific cause of the elevated, postabatement levels in the perimeter areas
in 1988 is uncertain. It is known, however, that the airborne asbestos levels in the
perimeter area can be compromised by work practices; breeched containment
barriers; air discharges from torn flexible ductwork of air filtration units; inadequate
decontamination of tools, equipment, and personnel exiting the containment; or the
disturbance of asbestos-containing materials outside of containment area. Outdoor air
39
-------
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41
-------
TABLE 16. AVERAGE AIRBORNE ASBESTOS LEVELS MEASURED IN
PERIMETER AREAS AND OUTDOORS BEFORE THE 1988 ABATEMENT
Site
B/Q
C
D
E
F
G
P
S
T
Average airborne asbestos level, s/cm3
Perimeter area
0.001
0.001
0
0.001
0.003
0
0.001
0.001
0
Outdoors
0
0.003
0
0
0
0
0
0.001
0.003
TABLE 17. AVERAGE ASBESTOS LEVELS IN PERIMETER AREAS AT SITES
WHERE PREABATEMENT SAMPLES WERE COLLECTED
Site
B
C
0
E
F
G
P
Qa
S
T
Airborne asbestos levels, s/cm3
Preabatement
0.001
0.001
0
0.001
0.003
0
0.001
0.001
0.001
0.001
1988
0.008
0.002
0.062
0
0.002
0.010
0.007
0.055
, 0.003
0.030
1990
0.010
0.001
0.001
0.006
0.005
0.001
0
0.010
0.001
0.001
1991
0.012
0.001
0.004
0.010
0.036
0.005
0.001
0.012
0.003
0.001
1992
0.438
0.003
0.001
0.007
0.037
0.011
0.006
. 0.438
0.001
0.001
a Preabatement samples collected in 1988, and samples collected in 1990, 1991, and 1992 are the
same as those collected at Site B.
42
-------
samples are less likely to be affected by these conditions; therefore, it may be more
appropriate to use outdoor samples for AHERA Z-test comparisons to clear an
abatement project.
1988 NJDOH-EHS Final Clearance Visual Inspection
According to AHERA (40 CFR 763) a final visual inspection must be conducted
of the abatement area before final clearance air monitoring takes place. Final visual
inspection involves examining the abatement area to determine that the remedial
actions have been successfully completed, as indicated by the absence of dust or
debris.14 The basic premise of a final visual inspection is that an area where residue
or debris visible to the unaided eye is still present is not clean enough for clearance
air sampling.15
The NJDOH-EHS conducted final visual inspections at 15 of the 20 abatement
sites in 1988, including Sites A through C, H through I, and K through T.5-6 Ten of the
15 sites visually inspected by NJDOH-EHS in 1988 showed no airborne asbestos
levels above 0.02 s/cm3 in 1991 and/or 1992 (Tables 9 and 15). Five of the 15 sites
(B, H, K, M, and Q) that underwent NJDOH visual inspections showed airborne
asbestos levels above 0.02 s/cm3 in 1991 and/or 1992 (Tables 9 and 15). Of these
five sites, two (Sites M and K) had elevated levels likely attributed to O&M activities
that disturbed ACM, two (Sites B and Q) passed the 1988 visual inspection contingent
upon the abatement contractor's encapsulating the area above the abated plaster
wire-mesh substrate (which did not occur), and at one site (Sites H) the residual
material was believed to be beneath the polyethylene sheeting during the visual
inspection.
The five sites where NJDOH-EHS did not conduct a visual inspection were
Sites D E, F, G, and J. Four of these sites (D through G) showed airborne asbestos
levels above 0.02 s/cm3 in 1991 and/or 1992.
Simulated Occupancy v. Occupied Sampling Conditions
Sampling conditions are an extremely important factor in determining the
representativeness of the actual airborne asbestos concentrations measured in a
building (e.g., an occupied building versus an unoccupied building). One concern is
whether modified aggressive sampling techniques can accurately simulate occupancy
conditions. Modified aggressive air sampling involves 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.
Modified aggressive air sampling was conducted at the 20 sites in August 1990
to simulate conditions of occupancy.7 The sampling conducted at the 20 sites in 1991
and 1992 was conducted under conditions of occupancy.8 At 5 of the 20 sites, the
43
-------
average airborne asbestos concentration in the 1988 abatement area measured during
occupied conditions in 1991 was significantly greater than those measured during
simulated occupancy in 1990. Also at 3 of the 20 sites, the average airborne
asbestos concentration in the 1988 abatement area measured during occupied
conditions in 1992 was significantly greater than those measured during simulated
occupancy in 1990.
These comparisons appear to support the conclusion that modified aggressive
sampling does not effectively simulate conditions of occupancy. This may not be a
valid inference, however, because the sampling in 1990 was conducted after the
schools had been cleaned for the new school year. Theoretically, this would have
resulted in considerably less dust and debris for reentrainment than the amount
present at the end of the school year in May of 1991 and 1992. Furthermore, when
sampling was required after the May 1991 or 1992 monitoring, a modified aggressive
sampling protocol during unoccupied conditions was used to determine if the levels of
asbestos were still elevated. The modified aggressive sampling protocol was effective
in indicating the presence of elevated levels while the school was unoccupied. After
response actions were conducted, the modified aggressive protocol was again utilized
and did indicate a decrease in airborne asbestos levels. Whether modified aggressive
sampling techniques can accurately simulate occupancy conditions still remains
uncertain; therefore further evaluation under similar conditions is required.
1988 AHERA Clearance Discrepancies
AHERA clearance concentration discrepancies were noted between the results
of sample analyses reported by the Asbestos Safety Control Monitor (ASCM) firms
employed by the school's consultant and those reported independently by
EPA/NJDOH.5-6
Table 15 summarizes the results of the AHERA initial screening test and the
AHERA Z-test for each abatement site based on the EPA/NJDOH samples. Twelve of
the 20 sites would have failed the initial screening test had the samples collected by
EPA/NJDOH been used. Ten of the 12 sites that would have failed the initial
screening test had the EPA/NJDOH data been used would have subsequently failed
the AHERA Z-test based on the outdoor concentrations in the comparison. The other
two sites (D and H) would have passed the AHERA Z-test, however, relatively high
levels of airborne asbestos were present at these sites after the 1988 abatement.
(The reason(s) for these elevated levels were not apparent.) The remaining eight
sites would have passed both the initial screening test and the Z-test regardless of
whether outdoor or perimeter levels were used in the Z-test comparison.
The choice of either the perimeter area outside the work area but inside the
building or the outdoor air as the "outside" reference point in the AHERA Z-test would
have affected the outcome of the clearance comparison at Sites B and S based on
44
-------
EPA/NJDOH results. In each case, the site would have passed the Z-test if the
perimeter values had been used and failed if the outdoor levels had been used in the
comparison. The perimeter area outside the work area can be affected by work
practices that may contaminate other areas inside the building, by a breach in the
critical barriers surrounding the work area, by the air-filtration systems (e.g., torn
ductwork passing through adjacent building areas), or by preexisting ACM in the area.
Outdoor samples are less likely to be affected by these conditions, and their use in the
clearance comparison would generally provide a more stringent comparison.
AHERA Sampling and Analytical Practices
Specific sampling and analytical requirements for conducting clearance air
monitoring are presented in the AHERA Final Rule (40 CFR Part 763). Observations
made during the 1988 EPA/NJDOH research study indicated that the AHERA
sampling and analytical requirements and recommendations are not completely
understood and followed by consultants conducting the clearance air monitoring.6-6
The following clearance air sampling and analytical practices were observed:
0 Fewer than the required five clearance air samples inside the abatement
area were collected at two sites.
o
Improper sampling media was used to collect clearance air samples, i.e.,
filter pore size at three sites and filter type at two sites.
Recommended air sampling flow rates were exceeded at two sites.
Phase contrast microscopy was improperly used to clear one site.
Eight of the 20 abatement sites failed to meet the EPA-recommended drying
time of 24 hours after completing final cleaning and before conducting final
clearance air monitoring.
Nineteen of the 20 abatement sites used aggressive air sampling
techniques. Fourteen of these 19 sites failed to meet the EPA-
recommended aggressive air sweeping rate of at least 5 minutes per 1000
square feet of floor area.
Fifteen of the 20 abatement sites failed to use the number of circulating fans
recommended by AHERA during final clearance air monitoring. No
circulating fans were used at eight of the sites.
45
-------
Final Cleaning Practices
Upon completion of the abatement process, the work area must be cleaned in
preparation for its restoration to normal use. Various work procedures and practices
are used. The ultimate purpose of each is to ensure that postabatement
concentrations of asbestos fibers are at or below the concentrations present before
the abatement work began and that they are in compliance with the final clearance
requirements under the AHERA final rule.
During the 1988 EPA/NJDOH study,5 final cleaning practices and procedures
were documented at each of the 20 abatement projects. Final cleaning practices
tended to be similar among abatement contractors. The sequence of cleaning
activities depended on the surface from which the asbestos was removed and the
physical structure of the work site. Meticulous attention to detail in cleaning practices
is important to a successful final cleaning.
Airborne asbestos concentrations were measured before the final cleaning
phase at 16 of the abatement sites in 1988. Table 18 summarizes the concentrations
measured at these sites. Average airborne asbestos concentrations ranged from 0 to
1.5 s/cm3. Fourteen of the 16 sites showed an average level above 0.02 s/cm3.
46
-------
TABLE 18. AIRBORNE ASBESTOS CONCENTRATIONS MEASURED
BEFORE FINAL CLEANING OF ABATEMENT AREA IN 1988
Site3
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
S
T
Airborne asbestos concentration, s/cm3
Average
0.123
-
0.378
-
0.010
0.025
0
0.245
0.116
1.491
0.373
0.894
0.654
1.021
0.011
0.257
-
0.329
0.624
-
Minimum
0.059
-
0.010
-
0
0.005
0
0.064
0.035
1.163
0.276
0.567
0.349
0.561
0
0.102
-
0.042
0.151
-
Maximum
0.187
.
1.403
-
0.046
0.065
0
0.477
0.212
2.773
0.426
1.469
1.410
1.440
0.025
0.368
-
0.587
1.198
-
No samples were collected before final cleaning at Sites B, D, Q, and T.
47
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REFERENCES
1. U.S. Environmental Protection Agency. Managing Asbestos In Place: A
Building Owner's Guide to Operations and Maintenance Programs for
Asbestos-Containing Materials. Cincinnati, Ohio. Publication No. 20T-2003,
July 1990.
2. U.S. Environmental Protection Agency. National Emission Standards for
Hazardous Air Pollutants. Title 40, Code of Federal Regulations, Part 61,
Subpart M, April 1984. (Amended November 20, 1990).
3. Kominsky, J. R. and R. W. Freyberg. U.S. Environmental Protection Agency.
Assessment of Asbestos Removal Carried Out Using EPA Purple Book
Guidance. Final Report. Cincinnati, Ohio. May 1988.
4. U.S. Environmental Protection Agency. Guidance for Controlling Asbestos-
Containing Materials in Buildings. EPA 560/5-85-024, June 1985.
5. 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.
6. Kominsky, J. R., R. W. Freyberg, J. A. Brownlee, and D. R. Gerber. AHERA
Clearance at Twenty Abatement Sites. Final Report. U.S. Environmental
Protection Agency, Cincinnati, Ohio, September 1990.
7. 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.
8. Kominsky, J. R., R. W. Freyberg, J. A. Brownlee, D. R. Gerber, G. J. Centifonti,
and R. M. Ritota. U.S. Environmental Protection Agency. Airborne Asbestos
Concentrations Three Years After Abatement in Seventeen Schools. Final
Report. Cincinnati, Ohio. March 1993.
9. U.S. Environmental Protection Agency. Asbestos-Containing Materials in
Schools: Final Rule and Notice. Federal Register, 40 CFR, Part 763, October
30, 1987.
48
-------
10. 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.
11. U.S. Environmental Protection Agency. Asbestos in Schools: Evaluation of the
Asbestos Hazard Emergency Response Act (AHERA) Final Report. EPA
566/4-91-013,1991.
12. Kominsky, J. R., R. W. Freyberg, J. A. Brownlee, D. R. Gerber, G. J. Centifonti,
and R. M. Ritota. U.S. Environmental Protection Agency. Airborne Asbestos
Concentrations During Spray-Buffing of Resilient Floor Tile in New Jersey
Schools. Final Report. Cincinnati, Ohio. September 1992.
13. Kominsky, J. R., R. W. Freyberg, J. Chesson, et al. Evaluation of Two Cleaning
Methods for the Removal of Asbestos Fibers From Carpet, Am. Ind. Hyg.
Assoc. J., 51(9):500-504, 1990.
14. ASTM E1368-90: Standard Practice for Visual Inspection of Asbestos
Abatement Projects. American Society for Testing and Materials. Philadelphia,
PA 19103.
15. Kominsky, J. R., J. A. Brownlee, T. J. Powers, and R. W Freyberg. Achieving
a Transmission Electron Microscopy Clearance Criterion at Asbestos
Abatement Sites in New Jersey. National Asbestos Council Journal, 6(4):25-
29,1989.
49
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APPENDIX A
INDIVIDUAL ESTIMATES OF AIRBORNE ASBESTOS CONCENTRATIONS
FOUR YEARS AFTER ABATEMENT (1992) AT 20 SITES
50
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APPENDIX A
INDIVIDUAL ESTIMATES OF AIRBORNE ASBESTOS CONCENTRATIONS FOUR
YEARS AFTER ABATEMENT (IN 1992) AT 20 SITES
Site
A
A
A
A
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
Date
Sampled
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
07/16/92
07/16/92
07/16/92
07/16/92
07/16/92
07/16/92
Sample
Number
A92-11-A
A92-12-A
A92-13-A
A92-14-A
A92-15-A
A92-01-O
A92-01-OD
A92-02-O
A92-03-O
A92-04-O
A92-05-O
A92-05-OR
A92-18-CB
A92-06-P
A92-06-PR
A92-07-P
A92-07-PD
A92-08-P
A92-09-P
A92-10-P
B92-11-A
B92-12-A
B92-13-A
B92-14-A
B92-15-A
BQ92-01-O
BQ92-02-O
BQ92-03-O
BQ92-04-O
BQ92-05-O
B92-16-OB
BQ92-17OB
BQ92-18CB
BQ92-06-P
BQ92-07-P
BQ92-08-P
BQ92-09-P
BQ92-10-P
BQ-792-11A
BQ-792-13A
BQ-792-14A
BQ-792-15A
BQ-792-16OB
BQ-792-17OB
I
Sample Location
Previously abated area
Previously abated area
Previously ab'ated area
Previously abated area
Previously abated area
Outdoors
Duplicate analysis of A92-01-O
Outdoors
Outdoors |
Outdoors i
Outdoors
Replicate analysis of A92-05-O
Closed field blank
Perimeter area
Replicate analysis of A92-06-P
Perimeter area
Duplicate analysis of A92-07-P
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area 0.035
Outdoors j
Outdoors !
Outdoors
Outdoors
Outdoors ;
Open field blank
Open field blank
Closed field blank
Perimeter area
Perimeter are^
Perimeter area
Perimeter are|a
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Open field blank
Open field blank
Concentration Air
s/cm3 s/mm2 Volume, L
0.002
0
0.002
0
0.002
0.011
0.003
0
0.017
0.008
0.003
0
.
0
0
0
0
0.002
0
0
0.102
0.014
0.030
0.038
181
0
0
0
0.003
0
-
-
.
0.142
0.306
0.284
0.434
1.022
0.004
0
0
0
-
-
14
0
14
0
14
64
16
0
95
48
16
0
0
0
0
0
0
14
0
0
528
69
153
194
1995
0
0
0
14
0
0
0
0
736
1528
1403
2130
5148
16
0
0
0
13
0
2309
2204
2197
21 64
2244
2152
2152
2195
2216
2188
2146
2146
0
2297
2297
2346
2346
2195
2238
2364
1995
1976
1968
1995
1943
1909
1902
1909
1902
0
0
0
2000
1922
1903
1890
1939
1549
1435
1930
1787
0
0
(continued)
51
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APPENDIX A (continued)
Site
B
B
B
B
B
B
B
B
B
B
B
B
C
C
C
C
C
C
C
C
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
Date
Sampled
07/16/92
07/16/92
07/16/92
07/16/92
07/16/92
07/16/92
08/24/92
08/24/92
08/24/92
08/24/92
08/24/92
08/24/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
Sample
Number
BQ-792-18CB
BQ-792-06P
BQ-792-07P
BQ-792-08P
BQ-792-09P
BQ-792-10P
B892-16OB
B892-11A
B892-12A
B892-13A
B892-14A
B892-15A
C92-11-A
C92-12-A
C92-13-A
C92-14-A
C92-15-A
C92-01-O
C92-02-O
C92-03-O
C92-04-O
C92-05-O
C92-16-OB
C92-06-P
C92-07-P
C92-08-P
C92-09-P
C92-10-P
D92-11-A
D92-12-A
D92-13-A
D92-14-A
D92-15-A
D92-01-O
D92-01-OR
D92-02-O
D92-03-O
D92-04-O
D92-04-OR
D92-05-O
D92-16-OB
D92-17-OB
D92-18-CB
D92-06-P
D92-07-P
Sample Location
Closed field blank
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Open field blank
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
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Open field blank
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 analysis of D92-01-O
Outdoors
Outdoors
Outdoors
Replicate analysis of D92-04-O
Outdoors
Open field blank
Open field blank
Closed field blank
Perimeter area
Perimeter area
Concentration
s/cm3 s/mm2
0.021
0.004
0
0
0.003
.
0.008
0.004
0.004
0.018
0
0.008
0.021
0.010
0
0
0
0.006
0.007
0
0
.
0.005
0.003
0.003
0
0.005
0.050
0.008
0
0.006
0.059
0
0
0
0
0
0
0
.
-
.
0
0
0
94
16
0
0
16
0
32
16
16
63
0
42
111
56
0
0
0
32
32
0
0
0
28
14
14
0
28
222
42
0
28
278
0
0
0
0
0
0
0
0
0
0
0
0
Air
Volume, L
0
1698
1633
2520
1778
2115
0
1531
1579
1467
1356
1514
2056
2062
2124
1974
2140
1767
1887
1815
1851
1898
0
2218
2037
2115
2052
2011
1704
1988
1776
1933
1810
1805
1805
1830
1854
1817
1817
1867
0
0
0
2012
2083
(continued)
52
-------
APPENDIX A (continued)
Site
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
F
F
F
F
F
F
F
F
F
F
F
F
F
F
Date
Sampled
05/13/92
05/13/92
05/13/92
05/13/92
08/18/92
08/18/92
08/18/92
08/18/92
08/18/92
08/18/92
08/18/92
08/18/92
08/18/92
08/18/92
08/18/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
Sample
Number
D92-08-P
D92-08-PR
D92-09-P
D92-10-P
D892-16OB
D892-11A
D892-12A
D892-13A
D892-14A
D892-15A
D892-06P
D892-07P
D892-08P
D892-09P
D892-10P
E92-11-A
E92-11-AR
E92-12-A
E92-13-A
E92-14-A
E92-15-A
E92-01-O
E92-02-O
E92-03-O
E92-04-O
E92-05-O
E92-06-P
E92-07-P
E92-08-P
E92-09-P
E92-10-P
F92-11-A
F92-12-A
F92-13-A
F92-14-A
F92-15-A
F92-01-O
F92-02-O
F92-03-O
F92-04-O
F92-04-OR
F92-05-O
F92-16-OB
F92-17-OB
F92-18-CB
i
Sample Location
Perimeter area
Replicate analysis of D92-08-P
Perimeter area
Perimeter area
Open field blank
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Perimeter area
Perimeter area
Perimeter area
Perimeter are|a
Perimeter area
Previously abated area
Replicate analysis of E92-11-A
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors |
Outdoors
Outdoors
Outdoors
Perimeter areja
Perimeter area
Perimeter area
Perimeter are&
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors |
Outdoors
Outdoors
Outdoors
Replicate analysis of F92-04-O
Outdoors
Open field blank
Open field blank
Closed field blank
Concentration
s/cm3 s/mm2
0.003
0.009
0
0.003
_
0
0.016
0
0.021
0.004
0
0
0
0
0
0.008
0.008
0.008
0.007
0.010
0.011
0
0.010
0.003
0.007
0
0.011
0.005
0.003
0.008
0.005
0.034
0.042
0.038
0.025
0.040
0
0.002
0
0.003
0.003
0.007
.
_
-
14
42
0
14
0
0
56
0
62
14
0
0
0
0
0
42
42
42
42
56
56
0
48
16
32
0
56
28
14
42
28
208
250
222
153
236
0
14
0
14
14
42
0
0
0
Air
Volume, L
1796
1796
2122
1966
0
1001
1339
1360
1135
1510
1366
1295
1393
1558
1474
2016
2016
2127
2177
217'5
2019
1899
1893
1867
1860
1854
1948
1991
2040
1915
197'9
2331
2275
2258
2373
2287
2117
2183
2164
2115
2115
2146
0
0
0
(continued)
53
-------
APPEENDIX A (continued)
Site
F
F
F
F
F
F
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
H
H
H
H
H
H
Date
Sampled
05/12/92
05/12/92
05/12/92
05/12/92
05/12/92
09/01/92
09/01/92
09/01/92
09/01/92
09/01/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
08/27/92
08/27/92
08/27/92
08/27/92
08/27/92
08/27/92
08/27/92
OB/27/92
08/27/92
08/27/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
Sample
Number
F92-06-P
F92-07-P
F92-08-P
F92-09-P
F92-10-P
F892-170B
F892-06P
F892-07P
F892-08P
F892-10P
G92-11-A
G92-12-A
G92-13-A
G92-14-A
G92-15-A
G92-01-O
G92-02-O
G92-03-O
G92-04-O
G92-05-O
G92-16-OB
G92-16-OBR
G92-17-OB
G92-18-CB
G92-06-P
G92-07-P
G92-08-P
G92-09-P
G92-10-P
G892-11A
G892-12A
G892-13A
G892-14A
G892-15A
G892-06P
G892-07P
G892-08P
G892-09P
G892-10P
H92-11-A
H92-12-A
H92-13-A
H92-14-A
H92-15-A
H92-01-O
Sample Location
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Open field blank
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
Open field blank
Replicate analysis of G92-16-OB
Open field blank
Closed field blank
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
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
Concentration Air
s/cm3 s/mm2 Volume, L
0.039
0.061
0.017
0.005
0.062
-
0.098
0.121
0.032
0.028
0.146
0.136
0.236
0.111
0.108
0.003
0
0
0
0
-
-
-
-
0.033
0.005
0.013
0
0.005
0.012
0.004
0.008
0.003
0.004
0
0
0
0.004
0.004
0
0.003
0
0.009
0.018
0
222
347
79
28
349
0
306
417
111
97
764
708
1222
569
556
14
0
0
0
0
11
0
0
0
181
28
69
0
28
42
14
28
14
14
0
0
0
16
14
0
14
0
42
83
0
2177
2183
1838
2171
2186
0
1195
1325
1324
1333
2011
1999
1993
1967
1980
2048
2048
2056
2056
2030
0
0
0
0
2108
2073
2079
2091
2017
1333
1333
1308
1746
1375
1571
1314
1342
1589
1279
1814
1826
1911
1802
1777
1776
(continued)
54
-------
APPENDIX A (continued)
Site
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
J
J
Date
Sampled
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
05/13/92
08/25/92
08/25/92
08/25/92
08/25/92
08/25/92
08/25/92
08/25/92
08/25/92
08/25/92
08/25/92
08/25/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
•05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
Sample
Number
H92-02-O
H92-03-O
H92-04-O
H92-05-O
H92-16-OB
H92-17-OB
H92-18-CB
H92-06-P
H92-07-P
H92-08-P
H92-09-P
H92-10-P
H892-16OB
H892-11A
H892-12A
H892-13A
H892-14A
H892-15A
H892-06P
H892-07P
H892-08P
• H892-09P
H892-10P
192-11 -A
192-1 1-AR
192-1 2-A
192-1 3-A
192-1 4-A
192-1 5-A
192-01 -O
I92-02-O
I92-03-O
I92-04-O
I92-05-O
I92-05-OR
192-1 6-OB
192-1 7-OB
192-1 8-CB
I92-06-P
I92-07-P
I92-08-P
I92-09-P
192-1 0-P
J92-11-A
J92-12-A
|
Sample Location
Outdoors
Outdoors '
Outdoors
Outdoors :
Open field blank
Open field blank
Closed field blank
Perimeter area
Perimeter are;a
Perimeter area
Perimeter area
Perimeter area
Open field blank
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Perimeter areja
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Replicate analysis of 192-11 -A
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors !
Outdoors :
Outdoors j
Outdoors \
Replicate analysis of I92-05-O
Open field blank
Open field blank
Closed field blank
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Concentration
s/cm3 s/mm2
0.007
0
0
0
_
«
0.006
0.018
0.009
0.006
0.089
_
0.004
0.020
0.029
0.016
0.008
0.034
0.021
0.021
0.004
0.028
0
0.002
0.002
0
0
0
0.003
0
0.009
0
0
0.006
.
_
_
0
0.003
0
0
0
0.002
0
32
0
0
0
0
0
0
28
83
42
28
417
0
14
69
97
56
28
127
79
79
16
97
0
14
14
0
0
0
16
0
48
0
0
32
0
0
0
0
14
0
0
0
14
0
Air
Volume, L
1723
1759
1752
1717
0
0
0
1869
1820
1832
1826
1795
0
1332
1362
1290
1342
1380
1456
1457
1477
1408
1324
2171
2171
2198
2231
2213
2225
2058
2052
2058
2031
2009
2009
0
0
0
2092
2086
2094
2106
2117
2173
2216
(continued)
55
-------
APPENDIX A (continued)
Site
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
L
L
L
L
L
L
L
L
L
L
L
Date
Sampled
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/15/92
05/18/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
Sample
Number
J92-12-AD
J92-13-A
J92-14-A
J92-15-A
J92-01-O
J92-02-O
J92-03-O
J92-04-O
J92-05-O
J92-16-OB
J92-06-P
J92-07-P
J92-08-P
J92-09-P
J92-10-P
J92-01-OD
K92-11-A
K92-12-A
K92-13-A
K92-14-A
K92-15-A
KN92-01-O
KN92-02-O
KN92-03-O
KN92-04-O
KN92-05-O
K92-16-OB
KN92-17OB
KN92-18CB
K92-06-P
K92-07-P
K92-08-P
K92-09-P
K92-10-P
L92-11-A
L92-12-A
L92-13-A
L92-14-A
L92-15-A
L92-15-AR
L92-01-O
L92-02-O
L92-03-O
L92-04-O
L92-05-O
Sample Location
Duplicate analysis of J92-12-A
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Open field blank
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Duplicate analysis of J92-01-O
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Open field blank
Open field blank
Closed field blank
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 analysis of L92-15-A
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Concentration
s/cm3 s/mm2
0
0.002
0.005
0.005
0
0
0.003
0.003
0
.
0
0.002
0.055
0.002
0
0
0.017
0.011
0.004
0
0.003
0.012
0.006
0
0
0
.
.
.
0.004
0
0.005
0
0
0.002
0.005
0.002
0
0.007
0.005
0
0
0
0
0
0
14
28
28
0
0
16
16
0
0
0
14
292
14
0
0
97
42
14
0
14
64
32
0
0
0
0
0
11
28
0
28
0
0
14
28
14
0
42
28
0
0
0
0
0
Air
Volume, L
2216
2161
2182
2092
2101
2101
2163
2080
2142
0
2128
2142
2056
2163
2191
2101
2229
1505
1488
2124
2113
2088
2109
2109
2109
2103
0
0
0
2399
2343
2341
2500
2328
2290
2250
2154
2294
2297
2297
2241
2154
2213
2219
2213
(continued)
56
-------
j
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
N
N
N
N
N
N
N
N
N
N
N
N
O
O
O
0
O
O
O
O
O
0
0
0
Date
Sampled
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/11/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
05/20/92
Sample
Number
L92-16-OB
L92-17-OB
L92-18-CB
L92-06-P
L92-07-P
L92-08-P
L92-09-P
L92-10-P
M92-11-A
M92-12-A
M92-13-A
M92-14-A
M92-15-A
M92-15-AR
M92-16-OB
M92-17-OB
M92-18-CB
M92-06-P
M92-08-P
M92-09-P
M92-10-P
N92-11-A
N92-12-A
N92-13-A
N92-14-A
N92-14-AR
N92-15-A
N92-16-OB
N92-06-P
N92-07-P
N92-08-P
N92-09-P
N92-10-P
O92-11-A
O92-12-A
O92-13-A
O92-14-A
O92-15-A
O92-01-O
O92-02-O
O92-03-O
O92-04-O
O92-05-O
O92-06-P
O92-07-P
Sample Lopation
Open field blank
Open field blank
Closed field blank
Perimeter area
Perimeter area
Perimeter area
Perimeter are,a
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Replicate analysis of M92-15-A
Open field blank
Open field blank
Closed field blank
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Replicate analysis of N92-14-A
Previously abjated area
Open field blank
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 i
Perimeter area
Perimeter area
Concentration
s/cm3 s/mrn*
0
0
0
0.002 14
0.005 28
0 0
0.002 14
0 0
0.003 14
0.003 14
0 0
0.003 14
0.005 28
0 0
0
0
0
0 0
0.005 28
0 0
0.013 69
0.003 14
0.008 42
0.003 14
0.002 14
0.005 28
0.005 28
0
0.013 69
0.003 14
0.003 14
0.007 42
0.005 28
0.005 28
0.002 14
0.002 14
0 0
0 0
0.038 206
0.047 254
0.024 127
0.015 79
0.012 64
0 0
0 0
Air
Volume, L
0
0
0
2250
2272
2278
2216
2256
2005
1999
20(33
1810
1967
1967
0
0
0
1983
2128
2005
2113
2115
2074
2109
2332
2332
2299
0
2115
2086
2111
2199
2148
2139
2188
2167
2186
217'9
2066
2087
2066
2045
2066
2108
2217
(continued)
571
-------
APPENDIX A (continued)
Site
O
O
O
p
p
p
p
p
p
p
p
p
p
p
p
p
p
p
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
R
R
R
R
R
R
R
R
R
R
R
R
R
R
Date
Sampled
05/20/92
05/20/92
05/20/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/21/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
05/14/92
08/24/92
08/24/92
08/24/92
08/24/92
08/24/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
Sample
Number
O92-08-P
O92-09-P
O92-10-P
P92-11-A
P92-12-A
P92-13-A
P92-14-A
P92-15-A
P92-01-O
P92-02-O
P92-03-O
P92-04-O
P92-06-P
P92-07-P
P92-08-P
P92-08-PR
P92-09-P
P92-10-P
Q92-11-A
Q92-12-A
Q92-13-A
Q92-14-A
Q92-14-AD
Q92-15-A
Q92-15-AR
Q92-16-OB
Q892-11A
Q892-12A
Q892-13A
Q892-14A
Q892-15A
R92-11-A
R92-11-AR
R92-12-A
R92-13-A
R92-14-A
R92-15-A
R92-01-O
R92-02-O
R92-03-O
R92-04-O
R92-05-O
R92-16-OB
R92-17-OB
R92-18-CB
'.-. ' .• • •*••
Sample Location
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
Perimeter area
Perimeter area
Perimeter area
Replicate analysis of P92-08-P
Perimeter area
Perimeter area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Duplicate analysis of Q92-14-A
Previously abated area
Replicate analysis of Q92-15-A
Open field blank
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Replicate analysis of R92-11-A
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Outdoors
Open field blank
Open field blank
Closed field blank
Concentration
s/cm3 s/mm2
0.002
0.003
0
0.010
0
0.002
0.002
0
0.010
0.009
0
0.018
0
0.020
0
0
0
0.010
0.025
0.035
0.070
0.104
0.099
0.033
0.044
.
0
0.020
0.011
0.012
0.003
0.005
0.003
0
0
0
0
0.003
0
0.006
0.006
0.003
.
.
-
14
14
0
56
0
14
14
0
56
48
0
95
0
111
0
0
0
56
111
181
361
528
500
167
222
0
0
69
42
48
14
28
14
0
0
0
0
16
0
32
32
16
0
0
0
Air
Volume, L
2181
2066
2237
2155
2241
2192
2188
2164
2091
2091
2118
2091
2164
2149
2152
2152
2209
2051
1744
2004
1973
1949
1949
1943
1943
0
1259
1345
1528
1589
161
2089
2089
1882
1967
1967
1944
2077
2058
2019
2038
2127
0
0
0
(continued)
58
-------
APPENDIX A (continued)
Site
R
R
R
R
R
R
S
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
T
T
T
Date
Sampled
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/19/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
05/18/92
Sample
Number
R92-06-P
R92-07-P
R92-08-P
R92-09-P
R92-10-P
R92-10-PD
S92-11-A
S92-12-A
S92-13-A
S92-14-A
S92-15-A
S92-02-O
S92-03-O
S92-04-O
S92-05-O
S92-16-OB
S92-17-OB
S92-18-CB
S92-06-P
S92-07-P
S92-08-P
S92-09-P
S92-10-P
T92-11-A
T92-12-A
T92-13-A
T92-14-A
T92-15-A
T92-15-AR
T92-01-O
T92-02-O
T92-03-O
T92-04-O
T92-05-O
T92-16-OB
T92-17-OB
T92-18-CB
T92-06-P
T92-07-P
T92-07-PD
T92-08-P
T92-09-P
T92-10-P
Sample Location
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Duplicate analysis of R92-10-P
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Outdoors
Outdoors
Outdoors
Outdoors
Open field blank
Open field blank
Closed field blank
Perimeter area
Perimeter area
Perimeter area
Perimeter area
Perimeter areja
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Previously abated area
Replicate analysis of T92-15-A
Outdoors •
Outdoors
Outdoors
Outdoors '
Outdoors
Open field blank
Open field blank
Closed field blank
Perimeter area
Perimeter area
Duplicate analysis of T92-07-P
Perimeter area
Perimeter area
Perimeter area
Concentration
s/cm3 s/mm2
0
0.008
0
0.006
0.003
0.003
0
0
0
0
0
0
0.006
0.003
0.020
_
.
.
0
0.002
0.002
0.002
0
0
0
0
0
0
0
0.003
0
0.003
0
0
.
.
.
0
0
0
0
0.003
0
0
42
0
28
14
14
0
0
0
0
0
0
32
16
111
0
0
0
0
14
14
14
0
0
0
0
0
0
0
16
0
16
0
0
0
0
0
0
0
0
0
14
0
Air
Volume, L
2053
1955
1967
1770
1728
1728
2196
2133
2181
2134
2217
2164
2121
2164
2121
0
0
0
2155
2155
2205
2189
21 64
2057
2031
2011
2025
1991
1991
2012
2012
1987
2006
1967
0
0
0
2043
2050
2050
2068
2054
2074
59
-------
APPENDIX B
CASE HISTORIES
60
-------
SITE A
Background ;
Site Description
The abatement project at this single-story school building involved the removal
of approximately 19,100 rf2 of spray-applied asbestos-containing ceiling plaster. The
abatement area included corridors, classrooms, offices, and recreational rooms. The
project specifications indicated that the asbestos content of the ceiling plaster was
approximately 5 to 10 percent chrysotile. The information regarding the abated ACM
and associated asbestos content was obtained from the asbestos abatement
specifications for this site. ;
Air Monitoring Summary
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside of the abatement are£ but inside the building), and outdoors at
approximately the same time and location as the samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Final clearance of the
abatement site was based on the samples collected by the AST. In 1990, air samples
were collected at this school by use of a modified aggressive sampling technique to
simulate occupied conditions. The samples Were collected at approximately the same
locations as those collected in 1988. In 1991 and 1992, air samples were collected at
this school during actual occupied conditions'(i.e., during normal school operating
hours) at approximately the same locations as those collected in 1988 and 1990.
Summary of Air Monitoring Results
[
Table B-1 summarizes the results of the four sampling efforts. Figure B-1
illustrates the mean airborne asbestos concentrations at Site A. A single-factor
ANOVA was used to compare mean concentrations measured in each of the three
sampling locations. The results of the ANOVA analysis are presented in Table B-2.
The following subsections summarize the paih/vise comparisons of the mean
concentrations in the three sampling locations.
Postabatement -1988
AHERA Clearance Test \
i
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have passed the
AHERA initial screening test because the average filter concentration (22 s/mm2) was
i
61;
-------
TABLE B-1. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Aa
Abatement area
fefean
Win
Max
-Mean
Win
0.002
0.006
0.001
0.003
0.007
0.028
0.011
0.038
'Qcejapteti conrflf teRSn
tow' - -t
0.001
0.003
0.003
0.008
0.003
0.005
1882 /
0.001
0.002
0.001
0.002
0.008
0.017
a Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
TABLE B-2. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE A
ANOVA
p-vattte"
airborne
* s j.s Wff f
Slmulatect oceupa«cy»
' \ ^-•-•*">> sssff *
•> -
Occupied conditiorts-1992
0.0936
0.3160
0.1665
0.0186
A(0.002) P(0.001)
P(0.011) AfO.0071
P(0.003) O(0.003) AfO.001)
O(0.008) P(O.OOI) A(0.001)
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 sampling locations.
b A = 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
c Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
d Sampling locations (means) connected by a line are not significantly different.
62
-------
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o
0)
O)
oo
oo
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o
6
o
§
O
o
O
55
13
CD
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CD
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63;
-------
below 70 s/mm2. Furthermore, the site would have passed the AHERA Z-test
irregardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. These results are
consistent with AST sampling results.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.002 s/cm3) was not
significantly different from the average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.001 s/cm3) was not
significantly different from the average concentration measured outdoors (0 s/cm3).
Comparison of Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.002 s/cm3) was not
significantly different from the average concentration measured in the perimeter areas
(0.001 s/cm3).
Simulated Occupancy -1990
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.007 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 2
years after the 1988 abatement (0.011 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.007 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.011 s/cm3).
64
-------
Occupied Conditions -1991 ',
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.003 s/cm3).
Comparison of the Perimeter Area With Outdoors
i
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average concentration measured outdoors (0.003 s/cm3).
Comparison of Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured in the perinjieter areas (0.003 s/cm3).
Occupied Conditions -1992 \
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.008 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.008 s/cm3).
i
Comparison of Abatement Area With the Perimeter Area
\
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured in the perirrjeter areas (0.001 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
i
A single-factor ANOVA was used to compare mean concentrations measured in
1988,1990, 1991, and 1992. Each sampling location was evaluated separately. The
65
-------
result of the ANOVA analysis, along with the results of the Tukey multiple comparison
test, are presented in Table B-3. The following subsections summarize the pairwise
comparisons of mean concentrations measured in 1988, 1990, 1991, and 1992.
TABLE B-3. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE A
ANQVA
mail)
0.5855
0.2881
0.0015
1990(0.0007) 1988(0.002) 1991(0.001) 1992(0.001)
1990(0.011) 1991(0.003) 1988(0.001) 1992(0.001)
1992(0.008) 1991(0.003) 1990(0) 1988(0)
a Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b 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.
c Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring. '
d Years (means) connected by a line are not statistically significantly different.
1988 Abatement Area
Differences in average airborne asbestos concentrations measured in the
abatement area were not statistically significant. The highest average concentration
(0.007 s/cm3) and the highest individual concentration (0.028 s/cm3) were measured 2
years after the 1988 abatement.
Perimeter Area
Differences in average airborne asbestos concentrations measured in the
perimeter area were not statistically significant. The highest average concentration
(0.011 s/cm3) and the highest individual concentration (0.038 s/cm3) were measured 2
years after the 1988 abatement.
66
-------
Outdoors
The average airborne asbestos concentration measured in 1992 (0.008 s/cm3)
was significantly higher than the average concentrations measured in 1988 (0 s/cm3)
and 1990 (0 s/cm3). Average outdoor levels .measured in 1991 and 1992 were not
significantly different. The highest individual outdoor concentration (0.017 s/cm3) was
measured in 1992.
i
Structure Morphology and Size Distributions
Table B-4 presents the distribution of structure type and morphology at each
sampling location for each year of monitoring. The TEM analysis of 20 samples
collected in the abated area, 20 collected in the perimeter area, and 20 collected
outdoors yielded a total of 55 asbestos structures, of which 98.2 percent were
chrysotile asbestos and 1.8 percent were am^hibole. Overall, the asbestos structures
were primarily fibers (74.5 percent), and to a lesser extent, matrices (16.4 percent),
clusters (5.5 percent), and bundles (3.6 percent).
i
Table B-5 presents the cumulative size distribution of asbestos samples at each
sampling location for each year of monitoring. Overall, 94.5 percent of the observed
asbestos structures were less than 5 urn in length. Of the 41 asbestos fibers
observed, only 1 fiber (2.4 percent) was greater than 5 n-m in length.
NJDOH Visual Inspections j
1988 Inspection \
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site A as part of the State's traditional quality assurance program. This provides a
check and balance to asbestos abatement and ensures that high-quality abatement
and state-of-the art work practices are used. The onsite AST collected AHERA
clearance air samples only after the site had passed the NJDOH visual inspection.
Four visual inspections were required at this site. The site failed the first two
because live electrical outlets were present inside the containment and asbestos-
contaminated water was present in the toilets of the men's restroom and in the sink in
the janitor's closet. Workers were observed dumping the contaminated mop water into
drains, toilets, and sinks. The site failed the third visual inspection because of debris
found on several skylights, on horizontal surfaces, in wall penetrations, and at the top
of wooden and concrete walls. Pipe wrap was also left on pipes. The contractor was
again required to reclean these areas. When the areas were recleaned, NJDOH
conducted a fourth visual inspection and the site passed.
67
-------
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1991 Inspection f - ?
Although monitoring conducted in May 1991 indicated airborne asbestos levels
were within the AHERA criterion, NJDOH conducted another visual inspection at Site
A on November 7,1991, as a followup to the 1988 visual inspection. 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). In November 1991, the NJDOH
inspector examined only those areas indicated in the following subsections
1988 Abatement Areas
Corridors-Debris (4 to 6 percent chrysotile) from the thermal system insulation
was present on the upper surface of the suspended ceiling system (Table B-6).
Corrugated pipe insulation (21 percent chrysotile) penetrated concrete-masonry walls
at the radiators and other water-service locations (Table B-6). These materials were
not included in the Asbestos Management Plan.
L/6/ary--Damaged corrugated pipe insulation (37 percent chrysotile) was noted
in the Nesbitt heat exchanger units (Table B-6). These materials do not appear in the
Asbestos Management Plan.
Student Common /Area-Debris from damaged thermal system insulation was
noted in the vents above the telephone booth.
1988 Perimeter Areas
Music f?oon?"Corrugated pipe insulation penetrated the concrete-masonry walls
of the music room and other adjoining rooms from the corridors. These materials
were not included in the Asbestos Management Plan.
Office and Other .Areas-Offices and various other areas are served by the
Nesbitt heat exchanger units. The associated piping is insulated with corrugated
insulation. These materials were not included in the Asbestos Management Plan.
Conclusions
Asbestos-containing thermal system insulation was present in several areas
that were not noted in the Asbestos Management Plan. Asbestos-containing debris
was present on the upper surface of the suspended ceiling system in the corridors.
Disturbance of these materials during renovation or O&M activities could result in the
release of asbestos structures.
70
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TABLE B-6. SUMMARY OF BULK SAMPLE RESULTS - SITE A 1991 INSPECTION
1988 Abatement Area
Hall by radio room
Hall at faculty room
Hall between faculty and
radio rooms
Library
Library
Joint residue in pipe hanger
Corrugated pipe insulation
at radiator
Pipe joint material
Corrugated pipe insulation
at radiator
Felt motor pad,; radiator
6% chrysotile asbestos
21% chrysotile asbestos
Trace crocidolite asbestos
4% chrysotile asbestos
37% chrysotile asbestos
Negative
71
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SITEB
Background
Site Description
During the summer of 1988, two asbestos abatement projects were conducted
at this school (Sites B and Q). Spray-applied acoustical ceiling plaster was removed
from the second floor (Site B) and from the first floor (Site Q). The abatement area for
both sites 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 specifications for this school. There has been no additional abatement
activity since 1988.
Air Monitoring Summary
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside of the abatement area but inside the building), and outdoors at
approximately the same time and location as those samples collected by the Asbestos
Safely Technician (AST) for the AHERA clearance of the site. Preabatement samples
were also collected in the perimeter areas and outdoors before the 1988 abatement
activities. Final clearance of the abatement site was based on the samples collected
by the AST.
In 1990, air samples were collected at this school by a modified aggressive
sampling technique to simulate occupied conditions. The samples were collected at
approximately the same locations as those collected in 1988.
In 1991 and 1992, air samples were collected at this school during occupied
conditions (i.e., during normal school operating hours) at approximately the same
locations as those collected in 1988 and 1990.
Summary of Air Monitoring Results
Table B-7 summarizes the air monitoring results from 1988, 1990, 1991, and
1992, Figure B-2 illustrates the mean airborne asbestos concentrations at Site B. A
single-factor ANOVA was used to compare mean concentrations measured in each of
the three sampling locations. The results of the ANOVA analysis are presented in
Table B-8. The following subsections summarize the pairwise comparisons of the
mean concentrations in the three sampling locations.
72
-------
TABLE B-7. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Ba
v i
"
-SSfof
Max.
0.001
0.004
0.016
0.004
0.030
0.008
0.023
0.001
0.004
0.015
0.005
0.022
0.010
0.040
0.001
0.005
0.027
0.010
0.055
0.012
0.004
0.024
0.001
0.004
1992
0.044
0.014
0.102;
0.438
0.142
1.02
0.001
0.003
* Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b Abatement area was not accessible for preabatement sampling.
i
TABLE B-8. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE B
ffff
es in
Occupie cdncfftton&-1992
0.3466
0.0128
0.0299
0.0002
0.0001
P(0.001)O(0)
A(0.016) P(0.008) O(0.001)
A(0.015) PfO.010^ O(0.001)
A(0.027) P(0.012) O(0.001)
P(0.438) A(0.044) O(0.001)
* 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.
i
b A « 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
I
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location. ;
d Sampling locations (means) connected by a line are not significantly different.
73
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74
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Preabatement -1988
I
The average airborne asbestos concentration measured in the perimeter area
before the abatement (0.001 s/cm3) was not significantly different from the average
concentration measured outdoors (0 s/crn3). j
Postabatement - 1988
AHERA Clearance Test \
Airborne asbestos concentrations measured by EPA/NJDOH during the AHEERA
clearance phase of the 1988 abatement showed that this site would have failed the
AHERA initial screening test because the average filter concentration (109 s/mm2)
exceeded 70 s/mm2. Furthermore, the site would have failed the AHERA 2-test if the
abatement area concentrations were compared with the outdoor concentrations.
Although the site ultimately passed AHERA clearance by using the AST sampling
results, the EPA/NJDOH results clearly show that elevated levels of airborne asbestos
still existed in the school in 1988. [
i
Comparison of the Abatement Area With Outdoors
i
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.016 s/cm3) was
significantly greater than the average concentration measured outdoors (0.001 s/cm3).
This result is consistent with the AHERA Z-test comparison reported previously.
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.008 s/cm3) was not
significantly different from the average concentration measured outdoors (0.001
s/cm3). |
i .
Comparison of the Abatement Area With the}Perimeter Area
i
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.016 s/cm3) was not
significantly different from the average concentration measured in the perimeter areas
(0.008 s/cm3). !
75 i
-------
Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the previously
abated area 2 years after the 1988 abatement (0.015 s/cm3) was significantly greater
than the average concentration measured outdoors (0.001 s/cm3).
Comparison of the Perimeter Areas With Outdoors
The average airborne asbestos concentration measured in the perimeter area 2
years after the 1988 abatement (0.010 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.015 s/cm3) was not significantly different from the
average airborne asbestos concentration measured in the perimeter areas (0.010
s/cm111).
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.027 s/cm3) was significantly greater than the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Perimeter Areas With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.012 s/cm3) was significantly greater than the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.027 s/cm3) was not significantly different from the
average airborne asbestos concentration measured in the perimeter areas (0 012
s/cm3).
76
-------
Occupied Conditions - 1992 I
Comparison of the Previously Abated Area With Outdoors
i
I
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.044 s/cm3) was significantly greater than the
average concentration measured outdoors (0.001 s/cm3).
j
Comparison of the Perimeter Areas With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.438 s/cm3) was significantly greater than the
average outdoor concentration of airborne asbestos (0.001 s/cm3). The unusually high
average level in the perimeter areas is due primarily to one sample (1.02 s/cm3). The
other four samples ranged from 0.014 to 0.008 s/cm3.
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.044 s/cm3) was significantly less than the average
airborne asbestos concentration measured in the perimeter areas (0.438 s/cm3). The
unusually high average level in the perimeter areas is due primarily to one sample
(1.02 s/cm3). The other four samples ranged from 0.014 to 0.038 s/cm3.
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988, 1990, 1991, and 1992. Each sampling location was evaluated separately. The
result of the ANOVA analysis is presented m, Table B-9 along with the results of the
Tukey multiple comparison test. The following subsections summarize the pairwise
comparisons of mean concentrations measured in 1988, 1990,1991, and 1992.
i
1988 Abatement Area ;
f
Although average airborne asbestos cpncentrations measured in the abatement
area appeared to increase consistently in 1991 and 1992, the differences in the
average levels were not -statisticall;/ significant. The highest average concentration
(0.044 s/cm3) and the highest individual concentration (0.102 s/cm3) were measured 4
years after the 1988 abatement. |
77
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Perimeter Area
The average airborne asbestos concentrations measured in the perimeter area
4 years after the 1988 abatement (0.438 s/cm3) was significantly higher than the
average levels measured in 1988 (pre and postabatement), 1990, and 1991. The
differences between the average levels in 1988,1990, and 1991 were not statistically
significant. The highest average concentration (0.438 s/cm3) and the highest
individual concentration (1.02 s/cm3) were measured 4 years after the 1988
abatement.
Outdoors
Differences in average airborne asbestos concentrations measured outdoors in
each of the 4 years were not statistically significant. The highest individual
concentration (0.005 s/cm3) was measured in 1990, 2 years after abatement.
TABLE B-9. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990,1991, AND 1992 AT SITE B
"" "* ff -*:
•j: •,•,•>.% WbS '* ""•
Abatement area :
Peilme&a1 area % i
> *. ', < ' , i
Qut
-------
Structure Morphology and Size Distributions
Table B-10 presents the distribution erf structure type and morphology at each
sampling location for each year of monitoring. The TEM analysis of 20 samples
collected in the abated area, 20 collected in ithe perimeter area, and 20 collected
outdoors yielded a total of 716 asbestos structures, of which 99.3 percent were
chrysotile asbestos and 0.7 percent were amphibole. Overall, the asbestos structures
were primarily fibers (97.8 percent), and to a lesser extent, bundles (1.4 percent),
matrices (0.7 percent), and clusters (0.1 percent).
Table B-11 presents the cumulative size distribution of asbestos samples at
each sampling location for each year of monitoring. Overall, 99.2 percent of the
observed asbestos structures were less than 5 p.m in length. Of the 700 asbestos
fibers observed, only 5 fibers (0.7 percent) were greater than 5 ^.m in length.
Followup Air Monitoring - August 1991
Because the average airborne asbestos concentration in May 1991
(0.027 s/cm3) exceeded 0.02 s/cm3 in the previously abated area, EPA/NJDOH
conducted followup monitoring under simulated occupancy conditions on August 13,
1991, to determine whether airborne asbestds was still present at levels similar to
those measured in May 1991. The August 1|3 results revealed an average airborne
asbestos concentration in the previously abated area of less than 0.02 s/cm3 (0.018
s/cm3); therefore, no further monitoring activity was required at this school.
Intervention continued, however, to resolve the elevated asbestos concentrations at
this site. i
Followup Air Monitoring - August 1992 \
Because the average airborne asbestps concentration in the previously abated
area (0.044 s/cm3) and in the perimeter area; (0.438 s/cm3) exceeded 0.02 s/cm3,
EPA/NJDOH conducted followup monitoring |n July 1992 under simulated occupancy
conditions to determine whether airborne asbestos concentrations were still present at
the levels observed in May 1992. The average airborne asbestos concentration
measured in the perimeter area in July (0.00^ s/cm3) was below 0.02 s/cm3; therefore,
no further action was required in this area. The NJDOH did, however, require a
response action in the previously abated are£ at this school based on the May 1992
data. The school subsequently employed a licensed asbestos-abatement contractor to
clean the previously abated area. When the'cleaning action was complete, NJDOH
conducted followup air monitoring in August -J992 to determine the residual levels of
airborne asbestos. The average airborne asbestos concentration measured in August
1992 (0.007 s/cm3) was below 0.02 s/cm3; therefore, no further monitoring activity was
required at this school.
79!
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NJDOH Visual Inspections
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site B as part of the State's traditional quality assurance program. This provides a
check and balance to asbestos abatement and ensures that high-quality abatement
and state-of-the art work practices are used. The onsite AST collected AH ERA
clearance air samples only after the site had passed the NJDOH visual inspection.
Three visual inspections were required at this site. The site failed the first
visual inspection because of the presence of gross debris on the tops of closets, in the
corner window sills, at floor-wall and ceiling-wall junctions, in cracks and crevices, on
ceiling rafters and beams, on floors, and on auxiliary equipment. The contractor was
required to reclean these areas. After the areas were recleaned, NJDOH conducted a
second visual inspection. The site failed this visual inspection because of debris on
clocks, windows, ceiling beams, tops of blackboards, and horizontal surfaces in the
classrooms and closets. The contractor was again required to reclean the affected
areas. When the areas were recleaned, NJDOH conducted a third visual inspection.
The site passed the third visual inspection with the stipulation that overhead areas
would be sprayed with an encapsulant.
Background for 1991 and 1992 Inspections
On August 14, 1991, and July 16, 1992, NJDOH conducted a visual inspection
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 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 and July 1992.
1991 Inspection
1988 Abatement Areas
Second Floor C/assrooms-Two samples of overspray and debris were obtained
from the structural steel and closet overhead areas (Table B-12). These samples
tested positive for chrysotile asbestos. All areas examined showed signs of
inadequate encapsulation.
82
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1988 Perimeter Areas \
i
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
corridor, kitchen, and storage closet. This material appeared to be in generally good
condition. i
i
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. . ;
1992 Inspection
1988 Abatement Areas \
In 1991, the NJDOH inspectors found;residual spray-applied asbestos-
containing material on the black iron trusses ;above the ceilings and ventilation panels
in closets of the second floor classrooms. Samples of this material showed it to
contain asbestos (Table B-12). The black irpn trusses support the wire lathe, scratch
coat, and acoustical plaster layers that make up the ceiling system in each classroom.
The ceilings of the closets consist of wood paneling and a metal ventilation panel. It
appeared that the flakes of asbestos-containing acoustical plaster on the trusses were
the result of overspraying the scratch coat, which was done before the storage closets
were installed. Overspray material was also|observed on the trusses above the light
fixtures, where holes for electrical connections or for mounting the fixtures were open
during the spray application of the acoustical plaster.
The presence of oversprayed acoustical plaster on the trusses in the closets
could not be verified during the July 16, 1992, visual inspection because the ceiling in
the closets had been reinstalled and stored books and other materials in the closets
made the ventilation panels inaccessible. !
1988 Perimeter Area
i
Basement All-Purpose Room-In the sjoffit in the all-purpose room (which is
accessible through access panels in the ceiling), some Aircell pipe insulation and
cementitious elbows/fittings were noted. The fibrous-glass lines and cementitious
fittings appeared to be in good condition; however, the Aircell insulation had opened
(unsealed) seams and had delaminated in a couple of areas. These materials were
not identified in the Asbestos Management Pjlan.
83
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TABLE B-12. SUMMARY OF BULK SAMPLE RESULTS-SITE B
1991 INSPECTION
Analyses
1988 Abatement Area
2nd floor classroom, closet
overhead, truss
2nd floor classroom, top of
closet
1988 Perimeter Areas
Basement all-purpose room
Flakes of spray-on debris
Flakes of spray-on debris
Composite, ceiling sample
Positive8, chrysotile asbestos
Positive, chrysotile asbestos
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 judgment of the analyst, the sample is considered to contain greater than 1 percent
asbestos.
Kitchen-Along the base of the exterior wall below the radiators inside the
kitchen were extensive deposits of extremely friable, white, powdery material. These
deposits are believed to have been caused by efflorescence of the concrete-masonry
block and/or mortar. The white powdery material tested positive for asbestos (Table
B-13). The flooring in the kitchen was 9 in. by 9 in. asbestos-containing (15 percent
chrysotile) resilient floor tile (Table B-13). Two 15 in. by 15 in. transite hot plates were
present on the grill. These materials were not identified in the Asbestos Management
rian.
Boiler Room-In the boiler room, the following asbestos-containing materials
were noted (Table B-13): 1) mud used to seal the boiler segments; 2) a cementitious
pipe elbow debris behind the hot water tank; 3) spray-on ceiling debris noted in the
cavity of concrete-masonry wall at the make-up air feed for the boiler; 4) tan paint
from the boiler stack. These materials were not identified in the Asbestos
Management Plan.
Conclusions
A number of asbestos sources were identified that could have contributed to the
elevated asbestos levels measured in 1992 (and 1991). Elevated levels in the
classrooms and hallways could have been caused by disturbance of asbestos-
containing dust and/or friable asbestos-containing acoustical plaster overspray on the
84
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steel trusses above the ceilings and vents in the classroom storage closets. Wind
could cause air to flow from the roof vents through the ducts in this passive ventilation
system and into the classrooms and hallways.
i
The elevated asbestos levels in the kitchen could be due to the extensive
deposits of extremely friable, white, powdery; material caused by efflorescence of the
concrete-masonry block and/or mortar. Other possible contributory sources are the
transite plates and asbestos-containing resilient floor tile.
851
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TABLE B-13. SUMMARY OF BULK SAMPLE RESULTS - SITE B
1992 INSPECTION
1988 Perimeter Areas
Kitchen, floor at south wall
Kitchen, wood sink
Kitchen, south wall
Kitchen, south wall on floor
Kitchen, south wall surface
Kitchen, south wall
Kitchen, south wall
Kitchen by storage room
Kitchen by storage room
Bingo hall
Bingo hall, east wall
Bingo hall, NE comer
Bingo hall, girls' room
Bingo hall, girls' room
Boiler room
Boiler room
Boiler room, beam
Boiler room, ceiling pipe entry
Boiler room, air entry
Boiler room, chimney
Boiler room, beam
Boiler room, floor
Boiler room
White powder
White cement spray
Blue paint/white undercoat
White efflorescence
White efflorescence
Mortar, gray cement
Concrete-masonry block
Vinyl floor tile, grey 9" x 9"
Mortar from floor trap
Floor paint, grey
Glue paint with yellow and green
Concrete-masonry block
Paint
Soft debris in floor drain
Boiler segment mud
Boiler, fiber, rock wood
Plaster/granular cement
Overspray, soft granular
Spray on debris
Paint, tan
Paint and plaster
Elbow debris, hot water heater
Mortar debris on pipe
Positive9, chrysotile asbestos
Positive, chrysotile asbestos
Positive chrysotile asbestos
Positive, chrysotile asbestos
Positive, chrysotile, asbestos
Negative
2% chrysotile asbestos
15% chrysotile asbestos
Negative
Negative
1% chrysotile asbestos
Negative
Negative
Negative
30% chrysotile asbestos
Negative
Negative
Traceb, chrysotile asbestos
2% chrysotile asbestos
Positive, chrysotile asbestos
Trace, chrysotile asbestos
2% chrysotile asbestos
Negative
8 This classification was defined by the NJDOH laboratory to accommodate samples of which there is not adequate material
available to show 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 judgment of the analyst, the sample is considered to
contain greater than 1 percent asbestos.
b Trace = <1 percent asbestos.
86
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SITE C
i
Background i
Site Description \
During the summer of 1988, two asbestos abatement projects were conducted
at this school (Sites C and M). Asbestos-containing thermal system insulation (TSl)
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 (Site C),
and from pipes in the corridors, classrooms, 'offices, storage rooms, and gymnasium
located in the basement (Site M). The TSl contained approximately 40 to 60 percent
chrysotile asbestos. The information regarding the abated ACM and associated
asbestos content was obtained from the asbestos abatement specifications for this
site. No additional abatement activity has taken place since 1988.
i
Air Monitoring Summary \
i
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside of the abatement area, but inside the building) and outdoors at
approximately the same time and location asj- those samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Preabatement samples
were also collected in the perimeter areas arid outdoors before the 1988 abatement
activities. Final clearance of the abatement site was based on the samples collected
by the AST. In 1990, air samples were collected at this school by a modified
aggressive sampling technique to simulate obcupied conditions. The samples were
collected at approximately the same locations as those collected in 1988. In 1991 and
1992, air samples were collected during occupied conditions (i.e., during normal
school operating hours) at approximately the! same locations as those collected in
1988 and 1990. |
Summary of Air Monitoring Results
Table B-14 summarizes the results from the five sampling efforts. Figure B-3
illustrates the mean airborne asbestos concentrations at Site C. A single-factor
ANOVA was used to compare mean concentrations measured in each of the three
sampling locations. The' results of the ANOVA analysis are presented in Table B-15.
The following subsections summarize the pain/vise comparisons of the mean
concentrations in the three sampling locations.
87
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TABLE B-14. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Ca
•f •" VC"
-- --- iS?K«|>H«0jperio) 1
wiean
0.001
0.002
0.001
0.001
0.003
Wift
0
0
0
0
0
Max i
0.004
0.008
0.005
0.003
0.005
Outdoors
{«*§>
Mean
0.003
0.004
0
0.003
0.003
Mln
0
0
. 0
0
0
Max
0.011
0.016
0
0.007
0.007
a Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b Abatement area was not accessible for preabatement sampling.
TABLE B-15. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE C
Sampling perkwj
Statistically significant differences in
mean plrfcpme
Occupied
0.4466
0.0057
0.6186
0.2823
0.5566
O(0.003) P(0.001)
A(0.060) O(0.004) P(0.002)
A(0.001) P(0.001)
A(0.005) O(0.003) P(0.001)
A(0.008) P(0.003) O(0.003)
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 = 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
d Sampling locations (means) connected by a line are not significantly different.
88
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Preabatement -1988
The average airborne asbestos concentration measured in the perimeter area
before the abatement (0.001 s/cm3) was not significantly different from the average
concentration measured outdoors (0.003 s/cm3).
Postabatement • 1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have failed the
AHERA initial screening test because the average filter concentration (397 s/mm2)
exceeded 70 s/mm2. Furthermore, the site would have failed the AHERA Z-test
irregardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. Although the site
ultimately passed AHERA clearance by the use of the AST sampling results, the
EPA/NJDOH results clearly show that elevated levels of airborne asbestos still existed
in the school in 1988.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.060 s/cm3) was
significantly greater than the average concentration measured outdoors (0.004 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.002 s/cm3) was not
significantly different than the average concentration measured outdoors (0.004 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.060 s/cm3) was
significantly greater than the average concentration measured in the perimeter areas
(0.002 s/cm3).
90
-------
Simulated Occupancy -1990 I
i
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
i
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 2
years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
i
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average airborne asbestos concentration measured in the perimeter area
(0.001 s/cm3). i
Occupied Conditions -1991 ;
j
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.005 s/chn3) was not significantly different from the
average concentration measured outdoors (6.001 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.001 s/cm3|) was significantly greater than the
average concentration measured outdoors (0.003 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
i
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.005 s/cm3) was not significantly different from the
average airborne asbestos concentration measured in the perimeter areas (0.001
s/cm3). i
91
-------
Occupied Conditions -1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.008 s/cm3) was not significantly different from the
average concentration measured (0.003 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average outdoor concentration of airborne asbestos (0.003 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.008 s/cm3) was significantly less than the average
airborne asbestos concentration measured in the perimeter areas (0.003 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988, 1990, 1991, and 1992. Each sampling location was evaluated separately.
Table B-16 presents the result of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The following subsections summarize the pairwise
comparisons of mean concentrations measured in 1988, 1990, 1991, and 1992.
1988 Abatement Area
Although average airborne asbestos concentrations measured in the abatement
area appeared to increase consistently in 1991 and 1992, the differences in the
average levels were not statistically significant. The highest average concentration
(0.060 s/cm ) and the highest individual concentration (0.146 s/cm3) were measured
during the AHERA clearance phase of the 1988 abatement.
Perimeter Area
The differences between the average levels in 1988, 1990, 1991, and 1992
were not statistically significant. The highest average concentration (0.003 s/cm3) was
measured 4 years after the 1988 abatement. The highest individual concentration
(0.008 s/cm ) was measured during the AHERA clearance phase of the 1988
abatement.
92
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TABLE B-16. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990,1991, AND 1992 AT SITE C
Abatement
area '
area
* "i -
Outdoors
0.0079
0.3255
0.5835
1988(0.060) 1992(0.044) 1991(0.005) 1990(0.001)
1992(0.003) 1988(0.002) 1990(0.001) 1991(0.001) 1988P(0.001)
1988(0.004) 1991(0.003) 1992(0.003) 1988 PfO.003) 1990(0)
* Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
i
b If the ANOVA p-value was less than 0.05, then theTukey multiple comparison procedure was used
to distinguish pairwise differences between sampling locations.
!
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring. |
d Years (means) connected by a line are not significantly different.
• 1988P « Preabatement; 1988 = Postabatement. >
Outdoors i
t
Differences in average airborne asbestos concentrations measured outdoors in
1988, 1990, 1991, and 1992 were not statistically significant. The highest average
concentration (0.004 s/cm3) and the highest individual concentration (0.016 s/cm3)
were measured during the AHERA clearance phase of the 1988 abatement.
|
Structure Morphology and Size Distributions
Table B-17 presents the distribution of structure type and morphology at each
sampling location separately for each year of monitoring. The TEM analysis of 20
samples collected in the .abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 126 asbestos structures, all of which were
chrysotile asbestos. Overall, the asbestos structures were primarily fibers
(67.5 percent), and to a lesser extent, matrices (21.4 percent), bundles (5.6 percent),
and clusters (5.6 percent). i
93!
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Table B-18 presents the cumulative sike distribution of asbestos samples at
each sampling location separately for each y|ear of monitoring. Overall, 83.3 percent
of the observed asbestos structures were less than 5 |im in length. Of these 85
asbestos fibers, 13 (15.3 percent) were greajer than 5 ^m in length.
i
NJDOH Visual Inspections j
1988 Inspection \
\
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site C as part of the State's traditional quality assurance program. This provides a
check and balance to asbestos abatement and ensures that high-quality abatement
and state-of-the art work practices are used.! The onsite AST collected AHERA
clearance air samples only after the site had;passed the NJDOH visual inspection.
One visual inspection was required at this site. Some minor debris was found
on pipe elbows and joints and on some horizontal surfaces. These elbows, joints, and
horizontal surfaces were cleaned while the inspector was in the containment area, and
the site subsequently passed the first visual Inspection.
1991 Inspection
i
Although monitoring conducted in May! 1991 found airborne asbestos levels
within the AHERA criterion, on August 14,19^91, NJDOH conducted a visual inspection
at Sites C and M as a followup. 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 by the NJDOH inspector in August! 1991.
i
1988 Abatement Areas
Miscellaneous debris mixed in with th^ coal from the boiler room tested positive
for chrysotile (19 percent), amosite (3 percent), and crocidolite (trace) asbestos (Table
B-19). The TSI debris mixed in with the coal tested positive for chrysotile asbestos.
The TSI debris found under the boiler room stairway tested positive for asbestos
(67 percent chrysotile). ;
1988 Perimeter Area
Large Gymnasium-Plaster dust and debris
widespread along the north wall. No samples
from renovation work were
of the plaster dust were collected.
95
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TABLE B-19. SUMMARY OF BULK SAMPLE RESULTS-SITE C
1991 INSPECTION
,*•.•,••..
* Type of-iriaieriaJ
• Analyses'";""
1988 Abatement Area
Boiler room, coal area
Boiler room, coal area
Boiler room, under stairs
1988 Perimeter Area
Basement recreation
room/classroom
Basement hallway
Basement hallway
Debris mixed in coal
i
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TSI debris j
i
TSI debris |
i
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[
Plaster, top co^t
!
Plaster, top coat
[
Plaster, browncoat
3% chrysotile, 1 Q%
amosite, positive,
crocidolite asbestos
Positive, chrysotile
asbestos
Q7% chrysotile asbestos
Negative
Negative
Positive3, chrysotile
asbestos
a This classification was defined by the NJbOH laboratory to accommodate samples
for which inadequate material was available to allow a full quantitative evaluation,
but were of sufficient size to determine that asbestos was present and to
determine the specific type of asbestos. (Based on the professional judgment of
the analyst, the sample is considered to contain greater than 1 percent asbestos.
Classroom, Small Gymnasium, and Corridors-No TSI debris was found in
these perimeter areas. Plaster debris from trie 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 browncoajt underlay in the adjoining hallway
showed trace amounts of chrysotile asbestos (Table B-19). The storage and office
areas were locked and could not be accessed.
i
Other Considerations i
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 percent chrysotile asbestos or as negative for asbestos (Table B-19).
97
-------
Although none of these materials tested greater than 1 percent 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.
98
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SITE D
i
Background
Site Description \
I
During the summer of 1988, this schobl underwent the removal of sprayed-on
ceiling material and thermal system insulatiort (TSI) from the boiler room and adjoining
mechanical spaces. The ceiling plaster was |removed from the loading dock, book
storage areas, boiler room, mechanical equipment room, and the electrical equipment
room and its adjacent corridor. The TSI was; removed from a water tank and pipes in
the boiler room. The ceiling plaster and TSI contained approximately 20 to 35 percent
chrysotile 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 specifications for this site. No other asbestos-containing material has been
abated since 1988. I
Air Monitoring Summary \
In 1988, postabatement air samples were collected in the abatement area,
perimeter area and outdoors at approximately the same time and location as those
samples collected by the Asbestos Safety Technician (AST) for the AHERA clearance
of the site. Preabatement samples were also collected in the perimeter areas and
outdoors before the 1988 abatement activities. Final clearance of the abatement site
was based on the samples collected by the AST. In 1990, air samples were collected
at this school by a modified aggressive sampling technique to simulate occupied
conditions. The samples were collected at approximately the same locations as those
collected in 1988. In 1991 and 1992, air samples were collected during occupied
conditions (i.e., during normal school operating hours) at approximately the same
locations as those collected in 1988 and 1990.
Summary of Air Monitoring Results
Table B-20 summarizes the results of the five sampling efforts. Figure B-4
illustrates the mean airborne asbestos concentrations at Site D. A single-factor
ANOVA was used to corhpare mean concentrations measured in each of the three
sampling locations. The results of the ANOVA analysis are presented in Table B-21.
The following subsections following summarize the pairwise comparisons of the mean
concentrations in the three sampling locations.
99!
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TABLE B-20. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Da
Mean
fcutdoers •• ' . -"--
Mean
0.079
0.013
0.129
0.062
0.032
0.099
0.052
0.004
0.093
Sfrrialated occujsaijey- 4
'
0.001
0.005
0.001
0.005
0.020
0.003
0.059
0.004
0.009
0.014
0.012
1803K-
0.025
0.059
0.001
0.003
0.003
0.007
" Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b Abatement area was not accessible for preabatement sampling.
TABLE B-21. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE D
Sampling period
!*r
alifeorne I
Occupied condHlons-1S92
__*• . . ^ jffff'' f f
1.0
0.5619
0.6186
0.0899
0.0099
P(0) 0(0)
A(0.070) P(0.062) OfO.052)
AfO.001) R0.001) O(0^
A(0.020) P(0.004) O(0.004)
A(0.025) P(0.001)
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 = 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
c Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
d Sampling locations (means) connected by a line are not significantly different.
100
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Summary of Air Monitoring Results
Preabatemenl -1988
The average airborne asbestos concentration measured in the perimeter area
before the abatement (0 s/cm3) was not significantly different from the average
concentration measured outdoors (0 s/cm3).
Postabatement • 1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have failed the
AHERA initial screening test because the average filter concentration (516 s/mm2)
exceeded 70 s/mm2. The site would have passed the AHERA Z-test, however,
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. Although the site
ultimately passed AHERA clearance by using the AST sampling results and would
have passed the AHERA clearance test by using the EPA/NJDOH results, the
EPA/NJDOH results clearly show that elevated levels of airborne asbestos still existed
in the school in 1988.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the 1988 abatement (0.0.079 s/cm3) was not
significantly different from the average concentration measured outdoors (0.052
s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the 1988 abatement (0.062 s/cm3) was not
significantly different from the average concentration measured outdoors (0.052
s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the 1988 abatement (0.079 s/cm3) was not
significantly different from the average concentration measured in the perimeter areas
(0.062 s/cm3).
102
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Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
i
The average airborne asbestos concentration measured in the perimeter area 2
years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average outdoor concentration (0 s/cm3). j
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.001 s/cm3).
i
Occupied Conditions -1991 \
i
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.020 s/cm3) was not significantly different from the
average concentration measured outdoors (0.014 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.004 s/cm3) was not significantly different from the
average concentration measured outdoors (0.014 s/cm3).
Comparison of the Previously Abated Area \Mith the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.020 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.004 s/cm3).
103
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Occupied Conditions - 1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.025 s/cm3) was significantly greater than the
average concentration measured outdoors (0.003 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.003 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.025 s/cm3) was significantly greater than the
average concentration measured in the perimeter areas (0.001 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988, 1990,1991, and 1992. Each sampling location was evaluated separately.
Table B-22 presents the result of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The following subsections summarize the pairwise
comparisons of mean concentrations measured in 1988, 1990, 1991, and 1992.
1988 Abatement Area
The average airborne asbestos concentration measured in the abatement area
was significantly less in 1990 (0.003 s/cm3) than in 1988 (0.065 s/cm3). All other
differences in average airborne asbestos concentrations measured in the abatement
area were not statistically significant. The highest average concentration (0.065 s/cm3)
and the highest individual concentration (0.129 s/cm3) were measured during the
AHERA clearance phase of the 1988 abatement.
Perimeter Area
The average postabatement airborne asbestos concentration measured in the
perimeter area in 1988 was significantly greater than the average preabatement
concentration measured in 1988, 1990,1991, and 1992. The average concentration
in 1991 was also significantly greater than the preabatement concentration measured
in 1988. The highest average concentration (0.062 s/cm3) and the highest individual
104
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concentration (0.099 s/cm3) were measured during the AHERA clearance phase of the
1988 abatement.
TABLE B-22. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990,1991, AND 1992 AT SITE D
%*$&*'
Abatement area
Perimeter aria v
»>"*?' * % v ^
Outdoors '"'^-^
0.0012
0.0001
0.0001
1988(0.070) 1992(0.025) 1991(0.020) 1990(0.001)
I
1988(0.062) 1991(0.004) 1990(0.001) 1992(0.001) 1988P(0)
1988(0.052) 1991(0.004) 1990(0) 1992(0) 1988P(0)
• Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b 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.
i
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring. ;
d Years (means) connected by a line are not significantly different.
• 1988P » Preabatement; 1988 - Postabatement i
Outdoors \
The average airborne asbestos concentrations measured outdoors in 1990,
1991, and 1992 were not significantly different, but all were significantly less than the
average concentration measured in 1988. The highest average concentration (0.052
s/cm3) and the highest individual concentration (0.093 s/cm3) were measured during
the AHERA clearance phase of the 1988 abatement.
Structure Morphology and Size Distributions
Table B-23 presents the distribution of structure type and morphology at each
sampling location separately for each year of monitoring. The TEM analysis of 20
samples collected in the abated area, 20 samples collected in the perimeter area, and
20 samples collected outdoors yielded a total of 320 asbestos structures, of which
99.7 percent were chrysotile asbestos and Q'.3 percent were amphibole. Overall, the
asbestos structures were primarily fibers (83.4 percent), and to a lesser extent,
matrices (12.2 percent), clusters (2.8 percent), and bundles (1.6 percent).
105
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Table B-24 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. Overall, 96.6 percent
of the observed asbestos structures were les!s than 5 jim in length. Of the 267
asbestos fibers observed, only 4 (1.5 percent) were greater than 5 jim in length.
FoIIowUp Air Monitoring - August 1991 j
Because the April 1991 average airborne asbestos concentration in the
previously abated area was 0.02 s/cm3, EPA/NJDOH conducted followup 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. The
August 13 results revealed an average airborne asbestos concentration in the
previously abated area of less than 0.02 s/cm3 (0.018 s/cm3); therefore, no further
monitoring activity was required at this site, intervention continued, however, to
resolve the elevated asbestos concentrations at this site.
FoIIowUp Air Monitoring - August 1992 \
Because the May 1992 average airborne asbestos concentration in the
previously abated area (0.025 s/cm3) exceeded 0.02 s/cm3, NJDOH-EHS required
response action at this school. The school subsequently used in-house staff to clean
the previously abated and perimeter areas. When the cleaning action was complete,
EPA/NJDOH conducted followup air monitoring in August 1992 to determine the
residual levels of airborne asbestos. The average airborne asbestos concentrations in
the previously abated area (0.008 s/cm3) and perimeter area (0 s/cm3) were both
below 0.02 s/cm3; therefore, no further monitoring activity was required at this school.
NJDOH Visual Inspections j
i
1988 Inspection '
The NJDOH did not perform a visual inspection at this site. Upon completion of
the final cleaning, the abatement contractor requested that a visual inspection be
conducted by the onsite AST, who was the building owner's representative. The AST
conducted the visual inspection within 2 hours after notification and did not identify any
areas that required further cleaning. j
1991 Inspection \
On August 14,1991, NJDOH conducted a visual Inspection 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
107
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(i.e., materials not included in the Asbestos Management Plan). Only those areas
indicated in the following subsections were examined.
1988 Abatement Area I
Electrical Room-Celling debris (17 percent chiysotile asbestos) was present on
the top of ductwork, electrical boxes, and wiring and in wall penetrations (Table B-25).
Generator f?oom--Ceiling debris (8 to jl 5 percent chrysotile asbestos) was
present on the top of the ventilation ducts and the generator exhaust box and on the
floors (Table B-25). !
TABLE B-25. SUMMARY OF BULK SAMPLE RESULTS-SITE D
1991 INSPECTION
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
i
Corner ledge j
Top of generator exhaust
box |
i
Top of duct i
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
i
* This classification was defined by the NJDOH laboratory to accommodate samples
for which inadequate material was available to allow a full quantitative evaluation,
but were of sufficient size to determine that asbestos was present and to determine
the specific type of asbestos. Based on the professional judgment of the analyst,
the sample is considered to contain greater than 1 percent asbestos.
109
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Boiler Hoom-Ceiling debris (17 percent chrysotile asbestos) was present on the
lower window ledge areas. The ladders provided were too unstable for safe access to
such areas as the top of the air-handling unit and pipes (Table B-25).
Boiler Storage f?oo/77--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 f?oom--The top of the suspended ceiling system was
heavily contaminated with ceiling debris (18 percent chrysotile asbestos) (Table B-25).
The wires, pipes, and ductwork in this space were covered with loose spray-on ceiling
debris.
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 possibly have caused sufficient
air movement to 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 1991 inspection no abatement had occurred.
Conclusions
A likely source of the elevated airborne asbestos concentrations measured in
May 1991 was the widespread 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. The NJDOH recommended that all other areas of the school, such
as the loading dock, dumb-waiter, book storage, etc. be inspected for abatement
residue, dust, and debris.
110
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SITE E
Background ;
Site Description \
During the summer of 1988, approximately 15,000 ft2 of 2-ft by 4-ft lay-in ceiling
tiles and approximately 500 linear feet of thefmal system insulation (TSI) on pipes
were removed from this school. The ceiling tiles were removed from classrooms,
offices, and recreational areas; the TSI, from; corridors. The ceiling tiles and TSI
contained 2 to 8 percent amosite and 35 to 40 percent chrysotile asbestos,
respectively. The information regarding the Abated ACM and associated asbestos
content was obtained from the asbestos abatement specifications for this site. No
additional abatement activity took place between 1988 and 1992.
Air Monitoring Summary ;
t
In 1988, postabatement air samples were collected in the abatement area,
perimeter area, and outdoors at approximately the same time and location as those
collected by the Asbestos Safety Technician (AST) for the AHERA clearance of the
site. Preabatement samples were also collected in the perimeter areas and outdoors
before the 1988 abatement activities. Final Clearance of the abatement site was
based on samples collected by the AST. In 1990, air samples were collected at this
school by use of a modified aggressive sampling technique to simulate occupied
conditions. The samples were collected at approximately the same locations as those
collected in 1988. In 1991 and 1992, air samples were collected at this school during
occupied conditions (i.e., during normal school operating hours) at approximately the
same locations as those collected in 1988 and 1990.
Summary of Air Monitoring Results
i
Table B-26 summarizes the results froni the five sampling efforts. Figure B-5
illustrates the mean airborne asbestos concentrations at Site E. A single-factor
ANOVA was used to compare mean concentrations measured in each of the three
sampling locations. The results of the ANOVA analysis are presented in Table B-27.
The following subsections summarize the pairwise comparisons of the mean
concentrations in the three sampling locations.
111
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TABLE B-26. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(S/cm3) MEASURED AT SITE E8
•fiteart
Mn
0.001
0.005
•3980 ""^
0.004
0.011
0.006
0.016
0.037
0.011
0.069
0.010
0.029
0.003
0.007
QeeUipied concisions- "
"
0.009
0.007
0.011
0.007
0.003
0.011
0.004
0.010
Samples were collected in the 1988 abatement and perimeter areas and outdoors.
Abatement area was not accessible for preabatement sampling.
TABLE B-27. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE E
&N.QVA
£fet!'s$(3a% signlcant ciiferertees in sieSn a&bdrns
Oecujpied conditlops-1^92 "-»'-
0.3466
1.0
0.1048
0.0069
0.0787
PfO.OOD O(0)
P(0.006) A(0.004)
A(0.037) P(0.010)
A(0.009) P(O.OOT) O(0.004)
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 = 1988 Abatement area; P - 1988 Perimeter area; O = Outdoors
Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
Sampling locations (means) connected by a line are not significantly different.
112
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Summary of Air Monitoring Results
Preabatement -1988
The average airborne asbestos concentration measured in the perimeter area
before the abatement in 1988 was not significantly different from the average
concentration measured outdoors.
Posfabatement - 1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have passed the
AHERA initial screening test because the average filter concentration (0 s/mm2) was
below 70 s/mm2. Furthermore, the site would have passed the AHERA Z-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. These results are
consistent with AST sampling results.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0 s/cm3) was not
significantly different from the average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0 s/cm5) was not
significantly different from the average concentration measured outdoors (0 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0 s/cm3) was not
significantly different from the average concentration measured in the perimeter areas
(0 s/cm3).
114
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Simulated Occupancy -1990
\
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.004 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
i
Comparison of the Perimeter Area With Outdoors
i
The average airborne asbestos concentration measured in the perimeter area 2
years after the 1988 abatement (0.006 s/cm3) was not significantly different from the
average outdoor concentration (0 s/cm3). j
i
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.004 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.006 s/cm3).
Occupied Conditions -1991 \
i
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.037 s/cm3) was significantly greater than the
average concentration measured outdoors (0.003 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.010 s/cmf) was not significantly different from the
average concentration measured outdoors (0.003 s/cm3).
i
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.037 s/crti3) was significantly greater than the
average concentration measured in the perimeter areas (0.010 s/cm3).
-------
Occupied Conditions - 1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.009 s/cm3) was significantly greater from the
average concentration measured outdoors (0.004 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.007 s/cm3) was not significantly different from the
average concentration measured outdoors (0.004 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.009 s/cm3) was significantly greater than the
average concentration measured in the perimeter areas (0.007 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A Sin9|e'factor ANOVA was used to compare mean concentrations measured in
1988, 1990, 1991, and 1992. Each sampling location was evaluated separately
Table B-28 presents the result of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990, 1991, and
1992.
1988 Abatement Area
The average airborne asbestos concentration measured in 1991 during
occupied conditions (0.037 s/cm3) was significantly greater than the average
concentrations measured in 1988, 1990, and 1992. The average concentration
measured in 1992 (0.009 s/cm3) was significantly greater than the average
concentration measured in 1988 (0 s/cm3). Differences in average airborne asbestos
concentrations measured in 1988 and 1990 and those measured in 1990 and 1992
were not statistically significant. The highest average concentration and the highest
individual concentrations were measured during occupied conditions in 1991 3 vears
after the 1988 abatement.
116
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TABLE B-28. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990,1991, AND 1992 AT SITE E
#A*
Outdoor
0.0001
0.0181
0.0161
1991(0.037) 1992(0.009) 1990(0.004) 1988(0)
1991(0.010) 1992(0.007) 1990(0.006) 1988P(0.001) 1988(0)
1992(0.004) 1991(0.003) 1990(0) 1988(0) 1988P(0)
* Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
i
b 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.
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring. \
I
d Years (means) connected by a line are not significantly different statistically.
• 1988P «= Preabatement; 1988 = Postabatement ;
i
Perimeter
The average airborne asbestos concentrations measured in the perimeter area
in 1988, 1990, 1991, and 1992 were not significantly different. The highest average
concentration (0.01 s/cm3) and the highest individual concentration (0.029 s/cm3) were
measured during occupied conditions in 1991, 3 years after the 1988 abatement.
Outdoors \
i
The average airborne asbestos concentrations measured outdoors in 1988,
1990,1991, and 1992 were not significantly different. The highest average
concentration (0.004 s/cm3) and the highest individual concentration (0.01 s/cm3) were
measured during occupied conditions in 1992, 4 years after the 1988 abatement.
I
Structure Morphology and Size Distributions
Table B-29 presents the distribution of structure type and morphology at each
sampling location separately for each year o|f monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
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collected outdoors yielded a total of 118 asbestos structures, 99.2 percent of which
were chrysotile asbestos and 0.8 percent were amphibole. Overall, the asbestos
structures were primarily matrices (50.8 percent), and to a lesser extent, fibers (33.9
percent), clusters (13.6 percent), and bundles (1.7 percent).
Table B-30 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. Overall, 97.5 percent
of the observed asbestos structures were less than 5 urn in length. Of these 40
asbestos fibers, none was greater than 5 |im in length.
Followup Air Monitoring - August 1991
\
I
Because the average airborne asbestos concentration in the previously abated
area (0.037 s/cm3) exceeded 0.02 s/cm3 in May 1991, EPA/NJDOH conducted
followup 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. 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, however, to resolve the elevated airborne asbestos
concentrations at this site.
NJDOH Visual Inspections
1988 Inspection \
The NJDOH did not perform a visual inspection at this site. Upon completion of
the final cleaning, the abatement contractor requested that a visual inspection be
conducted by the onsite AST, who was the building owner's representative. The AST
conducted the visual inspection within 2 hours after notification and did not identify any
areas that required further cleaning. !
t
1991 Inspection
\
On August 13,1991, NJDOH conducted a visual inspection at Site E 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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1988 Abatement Area i
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i
Corridors-Jhe tops of the lockers contained small pieces of asbestos-
containing ceiling tiles (Table B-31). 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 foyef. The material in this barrier consisted of
asbestos-containing plaster (7 percent chrysotile) over construction wire.
Art Storage Room-~The TSI debris on top of the partition wall contained
5 percent chrysotile asbestos (Table B-31).
i
1988 Perimeter Area \
\
\-
Gy/77nas/t/m~Asbestos-containing resilient floor tiles were noted.
Boiler Hoom-The TSI debris on the surface of the concrete-masonry block wall
tested positive for asbestos (Table B-31). The TSI that remained on the interior
surfaces of the "pork-chop" type boilers after abatement contained 2 to 5 percent
chrysotile asbestos (Table B-31). j
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 j interior of the boiler.
i
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 asbestos-
containing insulating barrier above the entry Idoors.
121
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TABLE B-31. SUMMARY OF BULK SAMPLE RESULTS
SITE E 1991 INSPECTION
Location
Type of Material
Analysis
1988 Abatement Area
Top of lockers at Room 109
Top of lockers at Room 108
At exit by Room 108
Top of locker #403
Top of lockers at Room 111
Top of locker at boiler room
Art storage room
1988 Perimeter Areas
Boiler room
Boiler room
Boiler room
Ceiling tile
Ceiling tile
Above drop ceiling
Ceiling tile
Ceiling tile
Ceiling tile
Partition wall
Lagging inside boiler
Lagging inside boiler
TSI debris on wall
<1 % amosite
Trace3 amosite
7% chrysotile
1 % amosite
1 % amosite
1 % amosite
5% chrysotile
5% chrysotile
2% chrysotile
Trace chrysotile
Trace = <1 percent asbestos.
122
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SITEF
Background j
Site Description \
During the summer of 1988, approximately 2200 ft2 of thermal system insulation
(TSI) on the boiler, boiler breeching, and pipes was removed from the boiler room in
the 1955 wing at this school. The TSI contained approximately 30 to 40 percent
chrysotile asbestos. The information regarding the abated ACM and associated
asbestos content was obtained from the asbestos abatement specifications for this
site. There has been no additional abatement activity took place between 1988 and
1991. In April 1992, thermal system insulation and asbestos-containing resilient floor
tile (and mastic) were removed from the cafeteria and music room of the 1923 Wing.
In July 1992, asbestos-containing resilient floor tile (and mastic) were removed from
hallways of the 1955 Wing. Ceiling tiles also may have been removed in three
classrooms (Rooms 20, 22, and 23) in July ^992. The 1923 Wing underwent a major
renovation of the cafeteria, including installation of an elevator system.
Air Monitoring Summary \
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside the abatement area but inside the building), and outdoors at
approximately the same time and location as those collected by the Asbestos Safety
Technician (AST) for the AHERA clearance of the site. Preabatement samples were
also collected in the perimeter areas and outdoors before the 1988 abatement
activities. Final clearance of the abatement site was based on the samples collected
by the AST. In 1990, air samples were collected at this school by use of a modified
aggressive sampling technique to simulate occupied conditions. The samples were
collected at approximately the same locations as those collected in 1988. In 1991 and
1992, air samples were collected at this school during occupied conditions (i.e., during
normal school operating hours) at approximately the same locations as those collected
in 1988 and 1990.
i
Summary of Air Monitoring Results ;
Table B-32 summarizes the results from the four sampling efforts. Figure B-6
shows the mean airborne asbestos concentrations at Site F. A single-factor ANOVA
was used to compare mean concentrations measured in each of the three sampling
locations. Table B-33 presents the results of the ANOVA analysis. The following
subsections summarize the pairwise comparisons of the mean concentrations in the
three sampling locations.
123
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TABLE B-32. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Fa
Mean.
Max
***'
0.003
0.008
0.024
0.009
0.052
0.002
0.009
0.001
0.003
0.001
0.005
0.005
0.024
0.043
0.032
0.066
0.036
0.010
0.058
0.001
0.002
0.036 0.025 0.042 0.037 0.005 0.062
0.002
0.008
Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
Abatement area was not accessible for preabatement sampling.
TABLE B-33. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE F
0.1456
0.0003
0.5616
0.0001
0.0002
P(0.003) O(0)
A(0.024) P(0.002) O(0.001)
P(0.005) AfO.OOD CKO)
A(0.043) P(0.036) 0(0.001)
P(0.037) A(0.036> O(0.002)
If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used to
distinguish pairwise differences between sampling locations.
b A = 1988 Abatement area; P = 1988 Perimeter area; Os Outdoors
Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that sampling location.
Sampling locations (means) connected by a line are not significantly different.
124
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Preabatement -1988
The average airborne asbestos concentration measured in the perimeter area
before the abatement (0.003 s/cnf) was not significantly different from the average
concentration measured outdoors (0 s/cm3).
Posiabatement -1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have failed the
AHERA initial screening test because the average filter concentration (215 s/mm2)
exceeded 70 s/mm2. Furthermore, the site would have failed the AHERA 2-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. Although the site
ultimately passed AHERA clearance by use of the AST sampling results, the
EPA/NJDOH results clearly show that elevated levels of airborne asbestos still existed
in the school in 1988.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.024 s/cm3) was
significantly greater than the average concentration measured outdoors (0.001 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.002 s/cm3) was not
significantly different from the average concentration measured outdoors
(0.001 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.024 s/cm3) was
significantly greater than the average concentration measured in the perimeter areas
(0.001 s/cm3).
126
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Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
i
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/c|n3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 2
years after the 1988 abatement (0.005 s/cm3) was not significantly different from the
average outdoor concentration (0 s/cm3). |
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/cin3) was not significantly different from the
average concentration measured in the perirjneter areas (0.005 s/cm3).
Occupied Conditions -1991 \
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.043 s/chf) was significantly greater than the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Perimeter Area With Outdoors
\
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.036 s/cm3) was significantly greater than the
average concentration measured outdoors (6.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
i
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.043 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.036 s/cm3).
127
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Occupied Conditions -1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.036 s/cm3) was significantly greater than the
average concentration measured outdoors (0.002 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.037 s/cm3) was significantly greater than the
average concentration measured outdoors (0.002 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.036 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.037 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988,1990, 1991, and 1992. Each sampling location was evaluated separately.
Table B-34 presents the result of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990, 1991, and
1992,.
1988 Abatement Area
The differences between average airborne asbestos concentrations measured
in 1988,1991, and 1992 were not statistically significant. The average airborne
asbestos concentration measured in 1990 (0.001 s/cm3) was, however, significantly
less than average concentrations measured in 1988,1991, and 1992. The highest
average airborne asbestos concentration (0.043 s/cm3) and highest individual
concentration (0.066 s/cm3) were measured during occupied conditions in 1992, four
years after the 1988 abatement.
1988 Perimeter Area
The average airborne asbestos concentrations measured during occupied
conditions in 1991 (0.036 s/cm3) and 1992 (0.037 s/cm3) were not significantly
different; however, they were significantly greater than the average concentrations
128
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measured in 1988 and 1990. The average preabatement concentration (0.003 s/cm3)
and postabatement concentration (0.002 s/cfn3) in 1988 were not significantly different
from the concentration measured in 1990 (01005 s/cm3). The highest average airborne
asbestos concentration (0.037 s/cm3) and individual concentration (0.062 s/cm3) were
measured during occupied conditions in 19S2, four years after the 1988 abatement.
TABLE B-34. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990,1991, AND 1992 AT SITE F
mm slrteorn* asfeestos ",
' '
Outdoors 4-'^ >
0.0001
0.0001
0.0816
1991(0.043) 1992(0.036) 1988(0.024) 1990(0.001)
1992(0.037) 1991(0.036) 1990(0.005) 1988P(0.003) 1988(0.002)
1992(0.002) 1988(0.001) 1991(0.001) 1990(0) 1988P(0)
• Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used to
distinguish pairwise differences between sampling locations.
c Parenthetical entries are mean airborne asbestos concejntrations (s/cm3) associated with that year's monitoring.
d Years (means) connected by a line are not significantly different.
* 1988P m Preabatement; 1988 = Postabatement. !
Outdoors \
i
The average airborne asbestos concentrations measured outdoors in 1988,
1990,1991, and 1992 were not significantly different. The highest average
concentration (0.002 s/cm3) and the highest individual concentration (0.008 s/cm3)
were measured during occupied conditions \i\ 1992, four years after the 1988
abatement.
i
Structure Morphology and Size Distributions
Table B-35 presents the distribution of structure type and morphology at each
sampling location separately for each year of monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 318 asbestos structures, of which 99.1 percent
were chrysotile asbestos and 0.9 percent were amphibole. Overall, the asbestos
129
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structures were primarily fibers (44.7 percent) and matrices (40.9 percent), and to a
lesser extent, bundles (10.4 percent) and clusters (4.1 percent).
i
Table B-36 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. Overall, 96.2 percent
of the observed asbestos structures were less than 5 u.m in length. Of the 142
asbestos fibers, only 4 (2.8 percent) were greater than 5 u.m in length.
i
Followup Air Monitoring - August 1991 I
Because 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 in
May 1991, EPA/NJDOH conducted followup imonitoring under simulated occupancy
conditions on August 12, 1991, to determine I whether airborne asbestos was still
present at levels similar to those measured ih May 1991. 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. When the cleaning action was complete, EPA/NJDOH conducted
followup air monitoring on August 28,1991. 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, however, to resolve the elevated asbestos concentrations at
this site. ;
Followup Air Monitoring - August 1992 i
Because the average airborne asbestos concentration in the previously abated
area (0.036 s/cm3) and in the perimeter area; (0.037 s/cm3) in May 1992 exceeded
0.02 s/cm3, NJDOH-EHS required response action at this school. The school
subsequently employed a licensed asbestos-abatement contractor to clean the
previously abated and perimeter areas. When the cleaning action was complete,
NJDOH conducted followup air monitoring in September 1992 to determine the
residual levels of airborne asbestos in the perimeter area. The average airborne
asbestos concentration in the perimeter area1 (0.07 s/cm3) still exceeded 0.02 s/cm3;
therefore, further cleaning was required. After the additional cleaning was complete,
the school's consultant conducted followup air monitoring in the previously abated area
and the perimeter area. The average airborne asbestos concentration in both areas
(0.004 s/cm3) was below 0.02 s/cm3; therefore, no further monitoring activity was
required. i
131
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NJDOH Visual Inspections :
i
1988 Inspection \
\
The NJDOH did not perform a visual inspection at this site. Upon completion of
the final cleaning, the abatement contractor requested that a visual inspection be
conducted by the onsite AST, who was the Building owner's representative. The AST
conducted the visual inspection within 2 hou^s after notification, and did not identify
any areas that required further cleaning. i
i
Background for 1991 and 1992 Inspections
On August 13,1991, and July 15,1992, NJDOH conducted a visual inspection
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.
t
1991 Inspection j
1988 Abatement Area •
\
In the boiler room, asbestos-containing TSI (29 percent chrysotile asbestos)
was found on the interior of the boiler. The asbestos-containing TSI on the exterior of
the boiler had been removed, and the boiler |had been reinsulated.
1988 Perimeter Areas
i
Hallway at the Boiler Room Entry-The school's Asbestos Management Plan
indicated the presence of sprayed-on asbestbs 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 Rooms in Gymnasium-Thermal system insulation was removed
from these areas. A thick accumulation of dust mixed with flakes of elbow debris
133
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(positive, chrysotile asbestos) was present on the air-handling unit (Table B-37). The
duct sealant contained 49 percent chrysotile asbestos. The duct sealant had been
abated in the north air-handling room, but was only partly abated in the south air-
handJing 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 percent chrysotile and trace to 4 percent
amosite) was recovered from the base of the units (Table B-37).
Conclusions
The school's Asbestos Management Plan did not reflect the residual asbestos
in the boilers. This material probably 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 and the installation of electrical cable in the plenum above
the hiallway 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.
Operations and maintenance activities on floor tiles located in the perimeter areas may
have also contributed to the elevated airborne asbestos levels.
1992 Inspection
1988 Abatement Area
Boiler Room-The friable thermal system insulation sampled during the August
1991 visual inspection was still present in the interior of the boiler. The cementitious
ceiling material in the boiler room did not contain asbestos (Table B-38).
1988 Perimeter Area
Stage (1955 Wing)--Scraps of asbestos-containing floor tile was used to shim
the lath of the suspended ceiling systems.
134
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TABLE B-37. SUMMARY OF BULK SAMPLE RESULTS-SITE F
1991 INSPECTION
*V £ rt*wattA.?i ' ^ % %^
tl> v° •
T " Type of material
1988 Abatement Area
Boiler room
1988 Perimeter Areas
SE air handling room,
gymnasium
SE 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
Traceb, amosite
asbestos
This classification was defined by the NJDOH laboratory to accommodate samples
for which inadequate material was available to allow a full quantitative evaluation,
but were of sufficient size to determine that asbestos was present and to determine
the specific type of asbestos. Based on the professional judgment of the analyst,
the sample is considered to contain greater than 1 percent asbestos.
I
Trace = <1 percent asbestos. i
135
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Corridors (1955 Building W/'np>-Damaged asbestos-containing thermal system
insulation was present in the air plenum above the dropped ceiling in the hallways of
the 1955 wing (Table B-38). The debris noted during the 1991 NJDOH inspection had
only been partially abated. This debris tested positive for asbestos as did the other
homogeneous thermal system insulation of pipes. These insulating materials were not
listed in the Asbestos Management Plan prepared in 1988. The Management Plan
inaccurately identified sprayed-on material in this area.
Utility Chase (1955 Building W//7g>-Asbestos-containing TSI debris was noted
on the dirt floor in the utility chase (accessible through the floor hatch in the janitor's
closet) that runs under the floor of the 1955 Wing (Table B-38).
Stairwell by Gym (1923 Building Wing)~No positive materials were recovered
from the immediate area, however, the plaster of the ceiling system had been severely
damaged by water leaving a hole of approximately ten square feet. The area above
this, an attic plenum, had been constructed of nonfriable transite type asbestos
sheeting. Several linear feet of friable and damaged trowel-applied asbestos-
containing material was observed in this plenum where metal conduits bend downward
and penetrate through the floor (Table B-38). The corner joints of the transite plenum
had also been spackled with a trowel-applied asbestos-containing mud (Table B-38).
These materials were not noted in the Asbestos Management Plan or in the 3-year
reinspection report.
Lavatories (1960 Addition-adjacent to 1923 W/ngr>-Thermal system
insulation was observed on the elbows of the fan/duct system in each lavatory.
Generally the material appeared to be in good condition. The 1960 addition and the
thermal system insulation materials did not appear in the Management Plan or the
three year reinspection. Some abatement may have taken place in this area in 1988.
The addition utilized materials that "matched" the materials of the 1923 wing, however
this area was not listed in the Management Plan.
Gymnasium Air-Handling Room (1955 Building Wing)~Fr\ab\e asbestos-
containing duct sealant (paper type) and associated sealant debris were noted in the
air-handling rooms (Table B-38). These partially abated materials were also noted
during the August 1991 visual inspection. Sealant debris was also present in the
cavities of the concrete-masonry blocks.
Janitor's Office/Old Boiler floom-Asbestos-containing debris was noted in a
wall penetration from the hallway (Table B-38).
North-East Stairwell (1923 Wing)-Jh\s area had corrugated pipe insulation,
sealed in part by a metal jacket and several old layers of paint. This material did not
appear in the Management Plan or in the three year re-inspection report.
136
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TABLE B-38. SUMMARY OF BULK SAMPLE RESULTS • SITE F
1992 INSPECTION
Analyses
1988 Abatement Area
Boiler room
1988 Perimeter Areas
1923 Stairwell by gym
1923 Stairwell by gym
Stage overhead
1955 Hallway plenum at boiler room
1955 Hallway plenum at boiler room
1955 Hallway plenum at boiler room
1955 Hallway plenum at boiler room
1955 Hallway plenum at boiler room
1955 Hallway plenum, west hall
Stage air-handling room SE
Stage air-handling room NW
1923 Attic plenum
1923 Attic plenum
1923 Attic plenum
1923 Attic plenum
1955 Classroom #33. closet
1955 Classroom #32, closet
1955 Classroom #30, closet
1955 Custodian room, below grade
1623 Wing old boiler room
Cement ceiling
Plaster, top coat, ceiling
Plaster, browncoat, ceiling
VAT chips to phim lath
Pipe debris - outer layer
Pipe debris - mid layer
Pipe debris - bottom layer
8" Line, block insulation
3" Line, corrugated
"Balsam-wood" pillow
Duct debris in block
Duct, residual!
Pipe bedding '
Mud caulk to seal transite
Transite type sheeting
Soft sheeting
Debris at heater/pipe entry
(
Debris at heater/pipe entry
Debris at heater/pipe entry
Debris, corrugated insulation
Debris, block insulation in
penetration ;
Negative
Negative
Negative
17% Chrysotile asbestos
17% Chrysotile asbestos
1% Chrysotile asbestos
Negative
8% Amosite asbestos
33% Chrysotile asbestos
Negative
42% Chrysotile asbestos
41% Chrysotile asbestos
20% Chrysotile asbestos
16% Chrysotile asbestos
8% Chrysotile asbestos
21% Chrysotile asbestos
23% Chrysotile asbestos
Trace, amosite
7% Chrysotile asbestos
Trace9, amosite asbestos
Positive"
Chrysotile asbestos
25% Chrysotile asbestos
1% Chrysotile asbestos
7% Amosite asbestos
• Trace « <1 percent asbestos
* This classification was defined by the NJDOH laboratory to accommodate samples for which inadequate material was
available to allow a full quantitative evaluation, but were of sufficient size to determine that asbestos was present and to
determine the specific type of asbestos. Based on the professional judgment of the analyst, the sample is considered to
contain greater than 1 percent asbestos. ;
137
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Conclusions
A number of asbestos sources were identified in various areas of the building
that could have contributed to the elevated asbestos levels measured in May 1992.
The school's Asbestos Management Plan must be revised to reflect the presence of
these materials.
Elevated air levels in the first-floor hallway (1955 wing) could have been caused
by damaged friable asbestos-containing material in the air plenum above the dropped
ceiling. Under certain environmental conditions of wind direction and velocity, air
could flow from the plenum through the louvered ceiling vents into the hallway.
Workers who installed the smoke detectors and connecting cable in the hallway ceiling
or who periodically service the system could have disturbed the asbestos-containing
material and caused a fiber-release episode. Air from the third-floor plenum, where
several types of asbestos-containing materials were identified, could flow into occupied
areas and the nearby stairwell under certain environmental conditions.
The elevated levels in the boiler room could be attributed to resuspended
residual debris that was not completely removed during abatement. The elevated
levels also could be from air infiltration from the first-floor ceiling plenum or
classrooms.
138
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SITEG
Background
i
Site Description !
The abatement project at this two-story school building involved the removal of
asbestos-containing thermal insulation materials (i.e., boiler lagging, boiler breeching,
and boiler gaskets) on the boiler and mechanical equipment. The project
specifications indicated that the asbestos content of the boiler lagging was 10 to 15
percent chrysotile and 35 to 40 percent amosite; the asbestos content of the boiler
breeching was 25 to 30 percent chrysotile and 30 to 35 percent amosite; and the
asbestos content of the boiler gasket was 70 to 75 percent chrysotile. The information
regarding the abated ACM and associated asbestos content was obtained from the
asbestos abatement specifications for this site. The project specifications did not
quantify the amount of asbestos-containing material in each location.
Air Monitoring Summary
i
In 1988, post-abatement air samples were collected in the abatement area, the
perimeter area, and outdoors at approximately the same time and location as those
collected by the Asbestos Safety Technician;(AST) for the AHERA clearance of the
site. Preabatement samples were also collected in the perimeter area and outdoors
before the 1988 abatement activities. Final clearance of the abatement site was
based on the samples collected by the AST.: In 1990, air samples were collected at
this school by use of a modified aggressive sampling technique to simulate occupied
conditions. The samples were collected at approximately the same locations as those
collected in 1988. In 1991 and 1992, air samples were collected during occupied
conditions (i.e., during normal school operating hours) at approximately the same
locations as those collected in 1988 and 1990.
Summary of Air Monitoring Results
Rgure B-7 shows the mean airborne asbestos concentrations at Site G. Table
B-39 summarizes the results from the five sampling efforts. A single-factor ANOVA
was used to compare mean concentrations rheasured in each of the three sampling
locations. The results of the ANOVA analysis are presented in Table B-40. The
following subsections summarize the pairwise comparisons of the mean concentrations
In the three sampling locations.
139
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TABLE B-39. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE G
Max
Wesu
Min
0.007
0.022
0.010
0.026
0.001
0.005
0.001
0.005
0.001
0.005
0.027
0.011
0.037
0.005
0.011
0.001
0.004
0.148 0.108 0.236 0.011
0.033 0.001
0.003
* Samples were collected each year in the 1988 abatement and perimeter areas, and outdoors.
I
b Abatement area was not accessible for preabatement sampling.
TABLE B-40. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE G
.ANQVA
Statistical ly slgnificani differences in; ••
,,,
Simulated
V
,
""
1.0
0.1003
1.0
0.0005
0.0001
P(0) O(0)
P(0.010) A(0.007) O(0)
A(O.OOI) P(0.001) O(0.001)
A(0.027) PfO.005) O(0.001)
A(0.148) P(0.011) O(0.001)
" If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pain/vise differences between sampling locations.
b A = 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
d Sampling locations (means) connected by a line are not significantly different.
14-1
-------
Preabatement - 1988
The average airborne asbestos concentration measured in the perimeter area
before the abatement (0 s/cm3) was not significantly different from the average
concentration measured outdoors (0 s/cm3).
Postabatement - 1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have passed the
AHERA initial screening test because the average filter concentration (51 s/mm2) was
below 70 s/mm2. Furthermore, the site would have passed the AHERA Z-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. These results are
consistent with AST sampling results.
Comparison of the Abatement Area With Outdoors
X.
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.007 s/cm3) was not
significantly different from the average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.010 s/cm3) was not
significantly different from the average concentration measured outdoors (0 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.007 s/cm3) was not
significantly different from the average concentration measured in the perimeter area
(0.010 s/cm3).
Simulated Occupancy - 1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
142
-------
Comparison of the Perimeter Area With Outdoors
I
The average airborne asbestos concentration measured in the perimeter area in
1990 (0.001 s/cm3) was not significantly different from the average outdoor
concentration (0.001 s/cm3). \
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/crn3) was not significantly different from the
average concentration measured in the perimeter area (0.001 s/cm3).
Occupied Conditions -1991 \
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.027 s/cm3) was significantly greater than the
average concentration measured outdoors (0,001 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.005 s/cm3) was not significantly different from the
average concentration measured outdoors (01.001 s/cm3).
i
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.027 s/crp3) was significantly greater than the
average concentration measured in the perimeter areas (0.005 s/cm3).
i-
i
Occupied Conditions -1992 I
Comparison of the Previously Abated Area with Outdoors
The average airbdrne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.148 s/cm3) was significantly greater than the
average concentration measured outdoors (0,001 s/cm3).
143
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.011 s/cm3) was significantly greater than the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.148 s/cm3) was significantly greater than the
average concentration measured in the perimeter area (0.011 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988, 1990, 1991, and 1992. Each sampling location was evaluated separately.
Table B-41 presents the result of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The following subsections summarize the pairwise
comparisons of mean concentrations measured in 1988, 1990, 1991, and 1992.
TABLE B-41. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE G
location*
-AHOVA
0.0001
0.2346
0.5623
1992(0.148) 1991(0.027) 1988(0.007) 1990(0.001)
1992(0.011) 1988(0.010) 1991(0.005) 1990(0.001) 1988P(0)
1991(0.001) 1990(0.001) 1992(0.001) 1988(0) 1988P(0)
Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used to
distinguish pairwise differences between sampling locations.
Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's monitoring.
d Years (means) connected by a line are not significantly different.
' 1988P = Preabatement; 1988 = Postabatement
144
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1988 Abatement Area
The average airborne asbestos concentrations measured in 1988 and 1990
were not significantly different. The average
concentration measured during occupied
conditions in 1991 (0.027 s/cm3) was significantly greater than the average
concentrations measured in 1988 (0.007 s/cm3) and 1990 (0.001 s/cm3). The average
concentration measured in 1992 (0.148 s/cm®) was significantly greater than average
concentrations measured in 1988,1990, and 1991. The highest average
concentration (0.148 s/cm3) and the highest individual concentration (0.236 s/cm3)
were measured during occupied conditions in 1992, four years after abatement.
1988 Perimeter Area \
The average airborne asbestos concentrations measured in the perimeter area
in 1988,1990, 1991, and 1992 were not significantly different. The highest average
concentration (0.011 s/cm3) and the highest individual concentration (0.033 s/cm3)
were measured during occupied conditions iri 1992, four years after the 1988
abatement. |
i
Outdoors
The average airborne asbestos concentrations measured outdoors in 1988,
1990,1991, and 1992 were not significantly different. The highest average
concentration (0.001 s/cm3) and the highest individual concentration (0.005 s/cm3)
were measured during simulated occupancy ;in 1990, two years after the 1988
abatement.
Structure Morphology and Size Distributions
Table B-42 presents the distribution of structure type and morphology at each
sampling location separately for each year of monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 382 asbestos structures, of which 96.6 percent
were chrysotile asbestos and 3.4 percent were amphibole. Overall, the asbestos
structures were primarily fibers (90.1 percent), and to a lesser extent, matrices (7.1
percent), bundles (2.4 percent), and clusters (0.5 percent).
Table B-43 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. Overall, 96.1 percent
of the observed asbestos structures were less than 5 jj.m in length. Of the 344
asbestos fibers observed, only 12 (3.5 percent) were greater than 5 ^im in length.
145
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Followup Air Monitoring - August 1991
Because the average airborne asbestos concentration in the previously abated
area (0.027 s/cm3) exceeded 0.02 s/cm3 in May 1991, 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. 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 used
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.
The average airborne asbestos concentrations in the previously abated and perimeter
areas were below 0.02 s/cm3; therefore, no further monitoring activity was required at
this school. Intervention continued, however, to resolve the elevated asbestos
concentrations at this site.
Followup Air Monitoring - August 1992
Because the average airborne asbestos concentration in the previously abated
area (0.148 s/cm3) in May 1992 exceeded 0.02 s/cm3, NJDOH-EHS required response
action at this school. The school subsequently used in-house staff to clean the
previously abated and perimeter areas. When the cleaning action was complete,
EPA/NJDOH conducted followup air monitoring in August 1992 to determine the
residual levels of airborne asbestos. The average airborne asbestos concentrations in
the previously abated area (0.006 s/cm3) and perimeter area (0.002 s/cm3) were both
below 0.02 s/cm3; therefore, no further monitoring activity was required at this school.
NJDOH Visual Inspections
1988 Inspection
The NJDOH did not perform a visual inspection at this site. Upon completion of
the final cleaning, the abatement contractor requested that a visual inspection be
conducted by the onsite AST, who was the building owner's representative. The AST
conducted the visual inspection within 2 hours after notification and did not identify any
areas that required further cleaning.
Background for 1991 and 1992 Inspections
On August 15, 1991, and July 17,1992, a NJDOH visual inspection was
conducted at Site G to determine potential sources of airborne asbestos
148
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concentrations measured by EPA/NJDOH in | May 1991 and May 1992, respectively.
The visual inspection strategy considered the asbestos-abatement history of the site,
the O&M activities, and other sources of pos'sible 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
and July 1992. \
i
1991 Inspection \
1988 Abatement Area \
I
All areas examined revealed contamination from abatement activities. Wall
penetrations, pipe hangers, tops of tanks, wifing, and electrical panels were all
contaminated with residual material and debris (Table B-44).
t
1988 Perimeter Area \
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 percent) for asbestos. Several
samples collected during the inspection, hoWever, showed no detectable levels of
asbestos in either the top-coat or browncoatj layer (Table B-44).
Conclusions
The elevated airborne asbestos concentrations measured in May 1991 may be
due to the residual asbestos-containing material and debris on surfaces in the boiler
room remaining from the 1988 abatement. The perimeter air samples contained
chrysotile asbestos. It was originally thought that the wall demolition (as specified by
the Management Plan) was the primary contributor to the elevated air levels. This,
however, was not supported by the analysis of bulk samples.
1992 Inspection i
1988 Abatement Area \
As noted during the 1991 visual inspection, all areas examined in the boiler
room revealed contamination from the 1988 abatement activities. Wall penetrations,
holes, pipe hangers, top of tanks, wiring, and electrical panels were all contaminated
with residual asbestos-containing material apd debris (Table B-45). The residual
asbestos-containing spray-on ceiling material was encapsulated with a thin coat of
149
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TABLE B-44. SUMMARY OF BULK SAMPLE RESULTS - SITE G
1991 INSPECTION
, Location
1988 Abatement Areas
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
Boiler room
3oiler 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
nsulation, 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
Positive3, amosite asbestos
Negative
Negative
Negative
Negative
Negative
Negative
This classification was defined by the NJDOH laboratory to accommodate samples for which
inadequate material was available to allow a full quantitative evaluation, but were of sufficient size to
determine that asbestos was present and to determine the specific type of asbestos. Based on the
professional judgment of the analyst, the sample is considered to contain greater than 1 percent
asbestos.
150
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TABLE B-45. SUMMARY OF BULK SAMPLE RESULTS • SITE G
1992 INSPECTION
1988 Abatement Area
Under Baldor pump behind
boilers
Under Baldor pump behind
boilers
Above Domestic Vac unit behind
tank
Above Domestic Vac unit behind
tank
Brace of small expansion tank
Floor trap by janitors office, left
side
Floor trap by janitors office, right
side
Small expansion tank brace
Boiler 1 caulk, front of unit
Boiler 1, rear of unit
Boiler 1, delaminated seam
Boiler 2, rear of unit
Boiler 2, rear of unit
Boiler 1, front of unit
Beam at Taco unit
Electrical box by Taco unit
Electrical box by Taco unit
Pipe brace above Taco unit
Beam by boilers
Thermal debris
Thermal debris
I
Thermal debris
Thermal debris i
I
Thermal debris j
Dirt and spray-on debris
Dirt and spray-on debris
Debris
t
I
Grey, nonfriable
Pink refractory cement
Dirt and scale
Refractory debris
Soot and refractory
Soot from combustion tubes
Spray-on residue
Spray-on residue
Spray-on residue j
Spray-on residue j
I
Spray-on residue ;
2% chrysotile asbestos
5% amosite asbestos
3% chrysotile asbestos
3% amosite asbestos
19% chrysotile asbestos
40% chrysotile asbestos
40% chrysotile asbestos
9% amosite asbestos
<3% (0.9%) chrysotile asbestos
21% amosite asbestos
Positive3 chrysotile asbestos
Positive amosite asbestos
4% chrysotile asbestos
Negative
Negative
Negative
Negative
Negative
Positive, amosite asbestos
1% chrysotile asbestos
20% amosite asbestos
1% chrysotile asbestos
15% amosite asbestos
1% chrysotile asbestos
6% amosite asbestos
0.9% chrysotile asbestos
8% amosite asbestos
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 determinfe the specific type of asbestos. Based on the
professional judgement of the analyst, the sample is considered to contain greater than 1 percent
asbestos. ;
151
-------
paint, which was peeling (Table B-45). The boiler soot, refractory debris, or
delarninating insulation seam did not contain detectable levels of asbestos (Table
B-45).
Conclusions
As noted during the 1991 visual inspection, the primary source of the elevated
airborne asbestos concentrations measured in May 1991 was from the residual
asbestos-containing material and debris on surfaces in the boiler room remaining from
the 1988 abatement. Remedial actions in 1991 relied on encapsulating the residual
spray-on material with paint, which failed to correct the conditions adequately in the
boiler room. Conditions still exist that could cause periodic fiber-release episodes
during routine O&M activities in the boiler room.
152
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SITE H
Background
i
Site Description ;
During the summer of 1988, asbestos-containing acoustical ceiling plaster,
spray-applied fireproofing, and thermal system insulation (TSI) were removed from
Site H. The abatement area included corridqrs 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 specifications for this
site. No additional abatement activity occurred between 1988 and 1992.
Air Monitoring Summary
In 1988, postabatement air samples wjere collected in the abatement area,
perimeter area (outside the abatement area but inside the building), and outdoors at
approximately the same time and location as the samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Final clearance of the
abatement site was based on the samples collected by the AST. In 1990, air samples
were collected at this school by use of a modified aggressive sampling technique to
simulate occupied conditions. The samples Were collected at approximately the same
locations as those collected in 1988. In 1991 and 1992, air samples were collected at
this school during occupied conditions (i.e., during normal school operating hours) at
approximately the same locations as those collected in 1988 and 1990.
Summary of Air Monitoring Results
Table B-46 summarizes the results of the four sampling efforts. Figure B-8
shows the mean airborne asbestos concentrations at Site H. A single-factor ANOVA
was used to compare mean concentrations measured in each of the three sampling
locations. Table B-47 presents the results of
subsections summarize the pairwise comparisons of the mean concentrations in the
three sampling locations.
153
the ANOVA analysis. The following
-------
TABLE B-46. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Ha
Abatement area -
Ital
Perimeter area - •• ••
Win
0.016
0.008
0.045
0.062
0.012
0.206
0.003
0.012
0.030
0.102
0.005
0.011
0.003
0.006
0.007
0 0.018 0.025 0.006 0.089 0.001
0.007
Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
TABLE B-47. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE Ha
siBsiu&e** «K£«paaej£t990
sv ff -^ w,*s ••••••• -f-f-f-ff-ff ffff ^
0.0069
1.0
0.1078
0.0203
P(0.062) A(0.016) O(O.OQ3)
A(0) P(0) 0(0^
A(0.030) PfO.005) O(0.003^
P(0.025> AfO.007) 0(0.001)
If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
b A = 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
Sampling locations (means) connected by a line are not significantly different.
154
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Summary of Air Monitoring Results
Postabatement - 1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have failed the
AHERA initial screening test because the average filter concentration (106 s/mm2)
exceeded 70 s/mm2. The site would have passed the AHERA Z-test, however,
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. Although the site
ultimately passed AHERA clearance by using the AST sampling results and would
have passed the AHERA clearance test by using the EPA/NJDOH results, the
EPA/NJDOH results clearly show that elevated levels of airborne asbestos still existed
in the school in 1988.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the 1988 abatement (0.016 s/cm3) was not
significantly different from the average concentration measured outdoors (0.003
s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.062 s/cm3) was
significantly greater than the average concentration measured outdoors (0.003 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.016 s/cm3) was not
significantly different from the average concentration measured in the perimeter areas
(0.062 s/cm3).
Simulated Occupancy - 1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
156
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area in
1990 (0 s/cm3) was not significantly different ;from the average outdoor concentration
(0 s/cm3). !
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0 s/cm3).
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.030 s/cm3) was not significantly different from the
average concentration measured outdoors (Or003 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.005 s/cm3) was not significantly different from the
average concentration measured outdoors (0^003 s/cm3).
I
Comparison of the Previously Abated Area With the Perimeter Area
\
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.030 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.005 s/cm3).
I
Occupied Conditions - 1992
Comparison of the Previously Abated Area With Outdoors
i
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.007 s/cm3) was not significantly different from the
average concentration measured outdoors (0;003 s/cm3).
157
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.025 s/cm3) was significantly greater than the
average concentration measured outdoors (0.003 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.007 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.025 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988, 1990, 1991, and 1992. Each sampling location was evaluated separately.
Table B-48 presents the result of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. Subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990, 1991, and
1992.
TABLE B-48. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE H
-statistically slgftitfcani
-------
1988 Abatement Area \
i
The average airborne asbestos concentration measured in 1988 (0.016 s/cm3)
was significantly greater than the average concentration measured in 1990 (0 s/cm3).
Differences between average levels measured in 1990,1991, and 1992 were not
statistically significant. Similarly, differences; between average levels measured in
1988,1991, and 1992 were not statistically Significant. The highest average
concentration (0.016 s/cm3) and the highest Individual concentration (0.045 s/cm3)
were measured during the AHERA clearance phase of the 1988 abatement.
i
Perimeter
The average airborne asbestos concentration measured during the AHERA
clearance phase of the 1988 abatement (0.062 s/cm3) was significantly greater than
the average levels measured in 1990 (0 s/cm3), 1991 (0.005 s/cm3), and 1992 (0.025
s/cm3). Differences between average levels;measured in 1990, 1991, and 1992 were
not statistically significant. The highest average (0.062 s/cm3) and highest individual
(0.206 s/cm3) concentrations were measured during the AHERA clearance phase of
the 1988 abatement. ;
Outdoors i
i
i
The average airborne asbestos concentrations measured outdoors in 1988,
1990,1991, and 1992 were not significantly idifferent. The highest average
concentration (0.003 s/cm3) and the highest individual concentration (0.012 s/cm3)
were measured during the AHERA clearance phase of the 1988 abatement.
Structure Morphology and Size Distributions
Table B-49 presents the distribution of structure type and morphology at each
sampling location separately for each year o!f monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 181 asbestos structures, all of which were
chrysotile asbestos. Overall, the asbestos structures were primarily fibers (70.2
percent), and to a lesser extent, matrices (22.1 percent), bundles (6.1 percent), and
clusters (1.7 percent). j
Table B-50 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. Overall, 97.2 percent
of the observed asbestos structures were less than 5 \im in length. Of the 127
asbestos fibers observed, none were greater than 5 |im in length.
159
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FoIIowup Air Monitoring - August 1991
.*t
The average airborne asbestos concentrations in the previously abated area
and the perimeter area in May 1991 exceeded 0.02 s/cm3. Therefore, EPA/NJDOH
conducted followup monitoring under simulated occupancy conditions on August 15,
1991, The average airborne asbestos concentration 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 followup air monitoring on August 29,1991, to determine the
residual levels of airborne asbestos. 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, however, to resolve the elevated asbestos concentrations at this site.
Followup Air Monitoring • August 1992
Because the average airborne asbestos concentration in the perimeter area
(0.025 s/cm3) in May 1992 exceeded 0.02 s/cm3, NJDOH-EHS required a response
action at this school. The school subsequently used in-house staff to clean the
previously abated and perimeter areas. When the cleaning action was complete,
EPA/NJDOH conducted followup air monitoring in August 1992 to determine the
residual levels of airborne asbestos. The average airborne asbestos concentration in
the previously abated area (0.02 s/cm3) and perimeter area (0.015 s/cm3) did not
exceed 0.02 s/cm3; therefore, no further monitoring activity was required at this school.
NJDOH Visual Inspections
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site H as part of the State's traditional quality assurance program which provides a
check and balance to asbestos abatement to ensure that high-quality abatement and
state-of-the art work practices are used. The onsite AST collected the AHERA
clearance air samples only after the site had passed the NJDOH visual inspection.
Two visual inspections were required at this site. The site failed the first visual
inspection because of the presence of debris on heating units, on pipes in the
hallways and classrooms, on electrical wires and outlet boxes, at floor-wall corners,
and around air vents. The contractor was required to reclean these areas. After the
areas were recleaned, NJDOH conducted a second visual inspection, which the site
passed.
162
-------
1991 Inspection
On August 16,1991, NJDOH conducted a visual inspection 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 ,-4reas~Spray-applied ceiling debris collected from the top
surface of the ceiling access panels contained 7 percent chrysotile asbestos (Table
B-51). As indicated in the table, an accumulation of dust found on the baseboard
heating pipes tested positive for asbestos, and the TSI on pipes above the ceiling did
not contain asbestos. i
Corridor to the Gymnasium-The TSI on pipes above the ceiling did not contain
asbestos (Table B-51). j
i
i
Mechanical Arts Shops-Metal partition walls along the windows contained
ceiling debris (8 percent chrysotile) and dust'that tested positive for asbestos (Table
B-51). Radiators were also found to contain !debris and dust that tested positive for
chrysotile asbestos. '
1988 Perimeter Areas ;
Hallway by the Custodian's Locker Room-Dud insulation above the ceiling in
the hallway outside the men's custodian locker room was friable and contained
1 percent chrysotile and 6 percent amosite asbestos (Table B-51). The duct insulation
was not included in the Asbestos Management Plan.
Auditorium-^ fireproofing type of material adhered to several areas of the stage
wall. Two samples of this material contained 27 and 35 percent chrysotile asbestos
(Table B-51). , ;
i
Conclusions ' • '.
I
The asbestos-containing debris and dust on ceiling panels and behind partition
walls were a potential source of airborne asbestos fibers measured in May 1991. This
debris was from improper O&M activities or fj-om uninventoried or residual ACM from
the 1988 abatement. No asbestos-containing duct insulation was identified in the
Asbestos Management Plan. The Asbestos Management Plan also erroneously
identified the TSI on pipes above the corridor ceilings as asbestos-containing material.
i
163
-------
Because the Asbestos Management Plan was in error, the potential exists for the
disturbance of unidentified ACM.
164
-------
TABLE B-51. SUMMARY OF BULK SAMPLE RESULTS-SITE H
1991 INSPECTION
1988 Abatement Area
Drafting storage
Halt at shops
Hall at shops
Hall at shops
Hall to gymnasium
Half 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
i
Above suspended ceiling, 4-in. block
pipe insulation |
i
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 materia
Dust and debris
Ceiling debris
Radiator dust
Duct insulation
Debris
Debris
Negative
Negative
Negative
Negative
Negative
Negative
Positive8, 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
This classification was defined by the NJDOH laboratory
material was available to allow a full quantitative evaluation,
asbestos was present and to determine the specific type
the analyst, the sample is considered to contain greater than
to accommodate samples for which inadequate
i, but were of sufficient size to determine that
of asbestos. Based on the professional judgment of
1 percent asbestos.
165
-------
SITE I
Background
Site Description
The abatement project at this single-story school building involved the removal
of approximately 5100 ft2 of spray-applied, asbestos-containing, acoustical ceiling
plaster. The abatement area included an office, a lobby, and an auditorium. The
project specifications indicated that the asbestos content of the ceiling plaster was
approximately 5 to 25 percent chrysotile. The information regarding the abated ACM
and associated asbestos content was obtained from the asbestos abatement
specifications for this site.
Air Monitoring Summary
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside the abatement area but inside the building), and outdoors at
approximately the same time and location as those samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Final clearance of the
abatement site was based on the samples collected by the AST. In 1990, air samples
were collected at this school by use of a modified aggressive sampling technique to
simulate occupied conditions. The samples were collected at approximately the same
locations as those collected in 1988. In 1991 and 1992, air samples were collected at
this school during occupied conditions (i.e., during normal school operating hours) at
approximately the same locations as those collected in 1988 and 1990.
Summary of Air Monitoring Results
Table B-52 summarizes the results from the four sampling efforts. Figure B-9
shows the mean airborne asbestos concentrations at Site I. A single-factor ANOVA
was used to compare mean concentrations measured in each of the three sampling
locations. Table B-53 presents the results of the ANOVA analysis. The following
subsections summarize the pairwise comparisons of the mean concentrations in the
three sampling locations.
166
-------
TABLE B-52. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3)MEASURED AT SITE la
MJtt
Win
Mean
Mlrt
Max
0.005
0.020
0.001
o.oosi
0.011
0.056
0.001
0.005
0.003
0.007|
0.005
0.011
0.005
0.020
0.001
0.002 i 0.001
0.003 0.002
0.009
Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
TABLE B-53. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE I
Saiaj&tig peHmi: s s
Statistically signiricanr ddffofen^es
mean
0.0389
0.7400
0.6961
0.4809
0(0.005)
P(0.011) AfO.OOD 0(0.001)
PfO.OOS) 0(0.005) AfO.003)
O(0.002) AfO.OOD P(0.001 )
' If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
[
b A » 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location. '
d Sampling locations (means) connected by a line ar|e not significantly different.
167
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Summary of Air Monitoring Results
Postabatement -1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have passed the
AHERA initial screening test because the average filter concentration (0 s/mm2) was
below 70 s/mm2. Furthermore, the site would have passed the AHERA Z-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. These results are
consistent with AST sampling results.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0 s/cm3) was not
significantly different from the average concentration measured outdoors
(0.005 s/cm3). I
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0 s/cm3) was not
significantly different from the average concentration measured outdoors
(0.005 s/cm3). :
i
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0 s/cm3) was not
significantly different from the average concentration measured in the perimeter areas
(0 s/cm3).
Simulated Occupancy -1990 \
i
Comparison of the Previously Abated Area With Outdoors
i
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (O.Q01 s/cm3).
169
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area in
1990 (0.011 s/cm3) was not significantly different from the average outdoor
concentration (0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.011 s/cm3).
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average concentration measured outdoors (0.005 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.005 s/cm3) was not significantly different from the
average concentration measured outdoors (0.005 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.005 s/cm3).
Occupied Conditions -1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.002 s/cm3).
170
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.001 s/cnf?) was not significantly different from the
average concentration measured outdoors (0.002 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.001 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to cbmpare mean concentrations measured in
1988,1990,1991, and 1992. Each sampling location was evaluated separately.
Table B-54 presents the result of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990, 1991, and
1992.
TABLE B-54. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE I
Statistically significant differences in mean airborne
' " ' '*
„.„,...„.„•> ' A,
area ,
Perimeter area M "
0.1141
0.2019
0.6690
1991(0.003) 1992(0.001) 1990(0.001) 1988(0)
1990(0.011) 1991(0.005) 1992(0.001) 1988(0)
1988(0.005) 1991(0.005) 1992(0.002) 1990(0.001)
* Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring.
d Years (means) connected by a line are not significantly different.
171
-------
1988 Abatement Area
Differences between average levels measured in 1988,1990, 1991, and 1992
were not statistically significant. The highest average concentration (0.003 s/cm3) and
the highest individual concentration (0.007 s/cm3) were measured during occupied
conditions in 1991, 3 years after the 1988 abatement.
Perimeter
Differences between average levels measured in 1988, 1990, 1991, and 1992
were not statistically significant. The highest average (0.011 s/cm3) and highest
individual (0.056 s/cm3) concentrations were measured during simulated occupancy, 2
years after the 1988 abatement.
Outdoors
The average airborne asbestos concentrations measured outdoors in 1988,
1990, 1991, and 1992 were not significantly different. The highest average
concentration (0.005 s/cm3) and the highest individual concentration (0.020 s/cm3)
were measured during the AHERA clearance phase of the 1988 abatement and during
occupied conditions in 1991, 3 years after the 1988 abatement.
Structure Morphology and Size Distributions
Table B-55 presents the distribution of structure type and morphology at each
sampling location separately for each year of monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 43 asbestos structures, all of which were
chrysotile asbestos. Overall, the asbestos structures were primarily fibers
(88.4 percent), and to a lesser extent, matrices (11.6 percent). Table B-56 presents
the cumulative size distribution of asbestos samples at each sampling location
separately for each year of monitoring. All of the observed asbestos structures were
less than 5 jim in length.
NJDOH Visual Inspection
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site I as part of the State's traditional quality assurance program which provides a
check and balance to asbestos abatement to ensure that high-quality abatement and
state-of-the art work practices are used. The onsite AST collected AHERA clearance
air samples only after the site had passed the NJDOH visual inspection.
172
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Four visual inspections were required at this site. The site failed the first visual
inspection because of the presence of residual materials or loose granular debris on
corkboards and walls, on tops of wood partitions under the stage, on light fixtures and
electrical cords, at ceiling-wall junctions, and on the carpeted area around the stage.
The contractor was required to reclean these areas. After the affected areas were
recleaned, NJDOH conducted a second visual inspection. The site failed the second
visual inspection because of debris at ceiling-wall junctions, above the entry doorway,
on electrical wires, and on corkboards. The Contractor was again required to reclean
the affected areas. After the areas were recleaned, NJDOH conducted a third visual
inspection. The site failed the third visual inspection because of the presence of
debris at ceiling-wall junctions and on the floor. After these areas were recleaned,
NJDOH conducted a fourth visual inspection, which the site passed.
1991 Inspection
Although monitoring conducted in May 1991 found airborne asbestos levels
within the AHERA criterion, on October 30, 1(991, NJDOH conducted a visual
inspection at Site I as a followup. 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 by the NJDOH inspector in October 1991.
1988 Abatement Areas \
i
Entry Lobby and Athletic Office-Dust from one sample on top of the trophy
cabinet and inside the radiator at the east window wall tested positive for chrysotile
asbestos (Table B-57).
/Aad/tor/i/m-Unsecured scaffolding limited the inspection, and extension ladders
were not available. No debris was noted.
1988 Perimeter Areas \
i
Cor/7'c/brs-Thermal system insulation was noted above the suspended ceilings
of the corridors. It appeared to be in generally good condition.
Library Office-Residue from the ceiling abatement was found on the window
soffit. This material tested positive for chrysotile asbestos (Table B-57).
i
Library Air-Handling Room-Thermal system insulation debris (2 to 5 percent
chrysotile asbestos) was found on the floors and the upper surfaces of the air-handiinq
units (Table B-57). j
175
-------
CO/7C/17S/0/7S
Residual asbestos-containing dust was noted on horizontal surfaces in several
areas of the 1988 abatement area and perimeter areas.
TABLE B-57. SUMMARY OF BULK SAMPLE RESULTS - SITE I
1991 INSPECTION
Location
Analyses
1988 Abatement Area
Entry lobby
Entry lobby
Entry lobby
1988 Perimeter Areas
Library, office
Library, air-handling
room
Library, air-handling
room
Library, air-handling
room
Dust, top of trophy cabinet,
east side (wipe sample)
Dust, top of trophy cabinet,
east side (wipe sample)
Dust inside east radiator
(wipe sample)
Residue, window soffit
Elbow debris on floor
Top air unit, elbow debris
Debris, top of east unit
Negative
Positive3, chrysotile asbestos
Positive, chrysotile asbestos
Positive, chrysotile asbestos
Positive, chrysotile asbestos
2% Chrysotile asbestos
5% Chrysotile asbestos
This classification was defined by the NJDOH laboratory to accommodate samples
for which inadequate material was available to allow a full quantitative evaluation,
but were of sufficient size to determine that asbestos was present and to determine
the specific type of asbestos. Based on the professional judgment of the analyst,
the sample is considered to contain greater than 1 percent asbestos.
176
-------
SITE J
Background
Site Description
The abatement project at this two-story school building involved the removal of
approximately 5300 ft2 of spray-applied asbestos-containing fireproofing from structural
steel and metal ceiling decks. The abatement area included two electrical transformer
vaults and two mechanical equipment rooms. The project specifications indicated that
the asbestos content of the cementitious fireproofing was approximately 10 to 25
percent chrysotile. The information .regarding the abated ACM and associated
asbestos content was obtained from the asbestos abatement specifications for this
site. i
Air Monitoring Summary
i
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside the abatement area but inside the building), and outdoors at
approximately the same time and location as^those samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Final clearance of the
abatement site was based on the samples collected by the AST. In 1990, air samples
were collected at this school by use of a modified aggressive sampling technique to
simulate occupied conditions. The samples vyere collected at approximately the same
locations as those collected in 1988. In 1991! and 1992, air samples were collected at
this school during occupied conditions (i.e., during normal school operating hours) at
approximately the same locations as those collected in 1988 and 1990.
i
Summary of Air Monitoring Results
i
Table B-58 summarizes the results frorn the four sampling efforts. Figure B-10
shows the mean airborne asbestos concentrations at Site J. A single-factor ANOVA
was used to compare mean concentrations measured in each of the three sampling
locations. Table B-59 presents the results of the ANOVA analysis. The following
subsections summarize the pairwise comparisons of the mean concentrations in the
three sampling locations.
177
-------
TABLE B-58. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Ja
,
" sawing $88rfod
Wn'-
Mean
Win
Max
Mln
-
tee
0.004
0.004
0.004
0.001
0.004
0.001
0.004
0.003
0.005
0.003
0.011
0.001
0.004
0.003
0.005 0.012
0.055 0.001
0.003
" Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
TABLE B-59. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE J
Posl:abat erne nt-1988 -
- -
0.0086
0.0156
0.2878
0.5921
A(0.004) P(O.OOI) O(0.001)
P(0.003) A(0) 0(0)
A(0.003) O(0.001)
P(0.012) A(0.003) 0(0.001)
8 If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pain/vise differences between sampling locations.
b A = 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
d Sampling locations (means) connected by a line are not significantly different.
178
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Summary of Air Monitoring Results
Postabatement • 1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have passed the
AHERA initial screening test because the average filter concentration (27 s/mm2) was
below 70 s/mm2. Furthermore, the site would have passed the AHERA Z-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. These results are
consistent with AST sampling results.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.004 s/cm3) was
significantly greater than the average concentration measured outdoors (0.001 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.001 s/cm3) was not
significantly different from the average concentration measured outdoors
(0.001 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.004 s/cm3) was
significantly greater than the average concentration measured in the perimeter areas
(0.0011 s/cm3).
Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
180
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area in
1990 (0.003 s/cm3) was significantly greater than the average outdoor concentration
(0 s/cm3).
i
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0 s/cm3) was significantly less than the average
concentration measured in the perimeter areas (0.003 s/cm3).
Occupied Conditions • 1991 i
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average concentration measured outdoors (p.001 s/cm3).
Comparison of the Perimeter Area With Outdoors
i
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average concentration measured in the perirrieter area (0 s/cm3).
Occupied Conditions -1992 \
.
Comparison of the Previously Abated Area With Outdoors
i
The average airbdrne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.003 s/crn3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
181
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.012 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.012 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988, 1990, 1991, and 1992. Each sampling location was evaluated separately.
Table B-60 presents the results of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990,1991, and
1992.
TABLE B-60. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE J
„ ' MocaHfjtf^ " ™-
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Statistically significant differences in mean airborne
' '
0.0219
0.2544
0.6112
1988(0.004) 1991(0.003) 1992(0.003) 1990(0)
1992(0.012) 1990(0.003) 1988(0.001) 1991(0)
1988(0.001) 1991(0.001) 1992(0.001) 1990(0)
a Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
c Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring.
d Years (means) connected by a line are not significantly different.
182
-------
1988 Abatement Area \
Differences between average levels measured in 1988, 1990, 1991, and 1992
were not statistically significant except that the average concentration measured
during simulated occupancy in 1990 was significantly less than that measured during
the AHERA clearance phase of the 1988 abatement. The highest average
concentration (0.004 s/cm3) was measured during the AHERA clearance phase of the
1988 abatement, and the highest individual concentration (0.011 s/cm3) was measured
during occupied conditions in 1991, three years after the 1988 abatement.
Perimeter
Differences between average levels measured in 1988,1990,1991, and 1992
were not statistically significant. The highest average (0.012 s/cm3) and highest
individual (0.055 s/cm3) concentrations were measured during occupied conditions, 4
years after the 1988 abatement.
Outdoors
The average airborne asbestos concentrations measured outdoors in 1988,
1990,1991, and 1992 were not significantly different. The highest average
concentrations (0.001 s/cm3) were measured! in 1988,1991, and 1992 and the highest
individual concentrations (0.004 s/cm3) were measured during the AHERA clearance
phase of the 1988 abatement and during occupied conditions in 1991, three years
after the 1988 abatement. |
Structure Morphology and Size Distributions
Table B-61 presents the distribution of structure type and morphology at each
sampling location separately for each year of monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 46 asbestos structures, all of which were
chrysotile asbestos. Overall, the asbestos structures were primarily fibers (78.3
percent), and to a lesser extent, clusters (10.9 percent), matrices (11.6 percent), and
bundles (4.3 percent).
Table B-62 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. Overall, 97.8 percent
of the observed asbestos structures were less than 5 n.m in length. Of the 36
asbestos fibers observed, none was greater than 5 |im in length.
183
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NJDOH Visual Inspection
1988 Inspection
The NJDOH did not perform a visual inspection at this site. Upon completion of
the final cleaning, the abatement contractor requested that a visual inspection be
conducted by the onsite AST, who was the building owner's representative. The AST
conducted the visual inspection within 2 hours after notification and did not identify any
areas that required further cleaning.
1991 Inspection
Although monitoring conducted in May 1991 found airborne asbestos levels
within the AHERA criterion, on November 8,1991, a NJDOH Visual Inspection was
conducted at Site J as a follow-up. This facility did not have an AHERA Management
Plan and being a college is not required to do so. 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.
Only those areas indicated in the following subsections were examined by the NJDOH
inspector in November 1991.
1988 Abatement Areas
Mechanical Hoom-This area contains the air-handling and electrical equipment
for the building. The main room is dominated by the ductwork and blower units of the
HVAC system. Non-asbestos spray-on replacement material had been applied to the
abated surfaces. The replacement materials and the accompanying debris from their
application made it difficult to detect debris or residual material from the original
asbestos application.
It appears that the fiberglass pipe insulation with cementitious joint and elbow
compounds were not removed during the 1988 abatement. Debris was noted in all
areas examined. Also, the repairs made to the materials have rendered a high
number of homogeneous "types." These materials were not sampled because the
facility assumes they are asbestos.
The top of the ducts, wall and ceiling surfaces, mechanical support stands and
brackets, floor drains, and the electrical equipment all showed contamination [5 to 19
percent chrysotile asbestos (Table B-63)]. The areas from which bulk samples were
collected were probably covered with polyethylene sheeting during the 1988
abatement, and were not accessible for a visual inspection prior to air sampling.
186
-------
TABLE B-63. SUMMARY OF BULK SAMPLE RESULTS -- SITE J
1991 INSPECTION
Type of Material
1988 Abatement Area
Mechanical room
Mechanical room
Mechanical room
Mechanical room
Mechanical room
Mechanical room
Mechanical room
Mechanical room
Mechanical room
Mechanical room
Mechanical room
1988 Perimeter Area
Hallway at mechanical
room entry
Hallway at elevator
Hallway at slate foyer
Hallway at school store
Residue behind ducting
Spray-on debris on wall at
"Dover box \
Spray-on debris top of duct,
filter entry ;
Floor drain, spray-on debris
Spray-on debris, "Alpha"
tank supports
Spray-on debris under main
filter duct
Spray-on debris in floor trap
Southwest corner, spray-on
debris on floor !
Debris in hangers
Wall at entry door, smudge
of spray-on, on Wall
New sealant at duct
Spray-on debris above drop
ceiling j
Spray-on debris above drop
ceiling
\
Overspray above drop
ceiling \
Spray-on debris above
ceiling tile \
9% chrysotile asbestos
Positive8, chrysotile
asbestos
5% chrysotile asbestos
Positive, chrysotile asbestos
Positive, chrysotile asbestos
19% chrysotile asbestos
Negative
Positive, chrysotile asbestos
Negative
Positive, chrysotile asbestos
Negative
13% chrysotile asbestos
7% chrysotile asbestos
16% chrysotile asbestos
7% chrysotile asbestos
This classification was defined by the NJDOH laboratory to accommodate samples
for which inadequate material was available to allow a full quantitative evaluation,
but were of sufficient size to determine that asbestos was present and to determine
the specific type of asbestos. Based on the professional judgment of the analyst,
the sample is considered to contain greater than 1 percent asbestos.
187
-------
1988 Perimeter Areas
Hallway at Mechanical Room Entrance-Ths cementitious joints and elbows
associated with the fiberglass pipe insulation were noted in the area above the
dropped ceiling. All of these materials appeared to be in good condition.
The areas below several pipe and duct penetrations in the wall have become
contaminated during abatement or repair actions (7 to 16 percent chrysotile asbestos).
Thick slabs and pieces of spray-on debris from the mechanical room are lying on the
upper surface of the dropped ceiling system by the elevator, by the mechanical room
entrance, and in the area by the slate foyer. The game room and other areas were
not accessed for inspection because of student occupancy and equipment storage.
Overspray was also noted in these perimeter areas on the beams, block walls, and
ductwork.
Conclusions
As noted earlier, debris was found in areas that may have been covered by
polyethylene sheeting during clearance air sampling or in areas that were outside the
abatement zone (above dropped ceilings). Clearance and followup testing would not
have disturbed such material. Also, much of the asbestos residue and debris has
been covered by replacement material.
Most debris was located on top of and under ducts or in other inaccessible
areas. This material might not be disturbed by floor-level aggressive sampling or daily
operations. Free fibers may have been scavenged from remaining material over time
and exhausted by the ventilation system in these areas.
188
-------
SITEK
Background
Site Description
During the summer of 1988, asbestos-containing acoustical ceiling plaster was
removed from Sites K and N. Site K involved removal of approximately 8200 ft2 of
spray-applied acoustical plaster from an "egg crate design" concrete ceiling. The
abatement area included the carpentry shop, mechanical arts classrooms, and offices.
The acoustical plaster contained 10 to 25 percent chrysotile asbestos. The
information regarding the abated AGM and associated asbestos content was obtained
from the asbestos abatement specifications for this site.
During the summer of 1991, 75,600 square feet of asbestos-containing ceiling
plaster was abated. No other abatement activity occurred between 1988 and 1992.
Air Monitoring Summary
In 1988, postabatement air samples were collected in the abatement area,
perimeter area, and outdoors at approximately the same time and location as those
samples collected by the Asbestos Safety Technician (AST) for the AHERA clearance
of the site. Final clearance of the abatement site was based on the samples collected
by the AST. In 1990, air samples were collected at this school by use of a modified
aggressive sampling technique to simulate occupied conditions. The samples were
collected at approximately the same locations as those collected in 1988. In 1991 and
1992, air samples were collected at this school during occupied conditions (i.e., during
normal school operating hours) at approximately the same locations as those collected
in 1988 and 1990. I
Summary of Air Monitoring Results
Table B-64 summarizes the results from the four sampling efforts. Figure B-11
shows the mean airborne asbestos concentrations at Site K. A single-factor ANOVA
was used to compare mean concentrations rpeasured in each of the three sampling
locations. Table B-65 presents the results of! the ANOVA analysis. The subsections
following the tables summarize the pairwise comparisons of the mean concentrations
in the three sampling locations.
189
-------
TABLE B-64. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Ka
Sarapiiftg period
-sain
Max
Mean
Iffis'
Max
Win
.Poslafoatemenirisaa
0.063
0.035
0.103
0.008
0.015
0.007
0.005
0.010
0.001
0.005
0.041
0.014
0.097
0.003
0.007
,, 0.007
0.017 0.002
0.005
0.004
0.012
Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
TABLE B-65. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE K
0.0001
0.0059
0.0001
0.3567
A(0.063) P(0.008) O(0)
P(0.007) O(0.001)
A(0.041) P(0.003)
A(0.007) O(0.004) PfO.002)
a If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
b A = 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
Sampling locations (means) connected by a line are not significantly different.
190
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Postabatement -1988
AHERA Clearance Test
Airborne asbestos concentrations measured during the AHERA clearance
phase of the 1988 abatement by EPA/NJDOH showed that this site would have failed
the AHERA initial screening test because the average filter concentration (431 s/mm2)
exceeded 70 s/mm2. Furthermore, the site would have failed the AHERA Z-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. Although the site
ultimately passed AHERA clearance by using the AST sampling results, the
EPA/NJDOH results clearly show that elevated levels of airborne asbestos still existed
in the school in 1988.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.063 s/cm3) was
significantly greater than the average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.008 s/cm3) was
significantly greater than the average concentration measured outdoors (0 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.063 s/cm3) was
significantly greater than the average concentration measured in the perimeter area
(0.008 s/cm3).
Simulated Occupancy - 1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
192
-------
Comparison of the Perimeter Area With Outdoors
i
The average airborne asbestos concentration measured in the perimeter area in
1990 (0.007 s/cm3) was significantly greater than the average outdoor concentration
(0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0 s/cm3) was significantly less than the average
concentration measured in the perimeter area (0.007 s/cm3).
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.041 s/cm3) was significantly less than the average
concentration measured outdoors (0 s/cm3). :
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.003 s/cm3;) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.041 s/cm3) was significantly greater than the
average concentration measured in the perimeter areas (0.003 s/cm3).
Occupied Conditions -1992 !
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.007 s/crfn3) was not significantly different from the
average concentration measured outdoors (0.004 s/cm3).
193
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.002 s/cm3) was not significantly different from the
average concentration measured outdoors (0.004 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.007 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.002 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988, 1990, 1991, and 1992. Each sampling location was evaluated separately.
Table B-66 presents the results of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990, 1991, and
1992.
TABLE B-66. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE K
.
location*
... ANQVA
Statistically significant differences ia mean airborne
area,.
perimeter arsa ,,,,
0.0001
0.3674
0.2137
1988(0.063) 1991(0.041) 1992(0.007) 1990(0)
1988(0.008) 1990(0.007) 1991(0.003) 1992(0.002)
1992(0.004) 1990(0.001) 1988(0) 1991(0)
a Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
c Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring.
d Years (means) connected by a line are not significantly different.
194
-------
1988 Abatement Area
The average airborne asbestos concentrations measure during the AHERA
clearance phase of the 1988 abatement (0.063 s/cm3) and during occupied conditions
in 1991 (0.041 s/cm3) were not significantly different, but they were significantly
greater than the average concentrations measured during simulated occupancy in
1990 (0 s/cm3) and during occupied conditions in 1992 (0.007 s/cm3). Furthermore,
the average concentration measured in 1992 was significantly greater than the
average concentration measured in 1990. The highest average concentration and the
highest individual concentration were measured during the AHERA clearance phase of
the 1988 abatement.
i
Perimeter
Differences between average levels measured in 1988, 1990, 1991, and 1992
were not statistically significant. The highest1 average (0.008 s/cm3) and highest
individual (0.015 s/cm3) concentrations were 'measured during the AHERA clearance
phase of the 1988 abatement.
i
Outdoors '
,
The average airborne asbestos concentrations measured outdoors in 1988,
1990,1991, and 1992 were not significantly different. The highest average
concentration (0.004 s/cm3) and the highest individual concentration (0.012 s/cm3)
were measured during occupied conditions in 1992, four years after the 1988
abatement.
Structure Morphology and Size Distributions
Table B-67 presents the distribution ofi structure type and morphology at each
sampling location separately for each year of| monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 169 asbestos structures, all of which were
chrysotile asbestos. Overall, the asbestos structures were primarily fibers (84.6
percent), and to a lesser extent, matrices (107 percent), clusters (3.0 percent), and
bundles (1.8 percent). i
Table B-68 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each y6ar of monitoring. Overall, 97.6 percent
of the observed asbestos structures were less than 5 urn in length. Of the 143
asbestos fibers observed, only 1 (0.7 percent} was greater than 5 |im in length.
195
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Followup Air Monitoring - August 1991
Because the average airborne asbestos concentration in the previously abated
area (0.041 s/cm3) exceeded 0.02 s/cm3 in April 1991, 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. 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, however, to resolve the elevated asbestos concentrations at
this site.
NJDOH Visual Inspections
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site K as part of the State's traditional quality assurance program which provides a
check and balance to asbestos abatement to ensure that high-quality abatement and
state-of-the art work practices are used. The onsite AST collected the AHERA
clearance air samples only after the site had passed the NJDOH visual inspection.
Four visual inspections were required at this site. The site failed the first visual
inspection because of the presence of gross debris on the concrete substrate
surfaces, under pipe hangers, on vertical and horizontal surfaces, and on the
scaffolding equipment. The contractor was then required to reclean the affected
areas. After the areas were recleaned, NJDOH conducted a second visual inspection.
The site failed the second visual inspection because of gross debris found behind
immovable wooden shelves, at floor-wall junctions, behind student lockers, on
horizontal surfaces, and on other immovable objects. The contractor was again
required to reclean the affected areas. After the areas were recleaned, NJDOH
conducted a third visual inspection. The site failed the third visual inspection because
of gross debris on horizontal surfaces, behind immovable objects, and at floor-wall .
junctions. After the affected areas were recleaned, NJDOH conducted a fourth visual
inspection, which the site passed.
1991 Inspection
On August 15, 1991, an NJDOH visual inspection was conducted at Sites K
and M as a followup. 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.
198
-------
1988 Abatement Areas
Carpentry Shop and C/assroom--The surface dust found on building and
equipment surfaces tested positive for asbestos (Table B-69). Floor tile from the
carpentry classroom contained 7 percent chrysotile. The floor tile was not identified as
ACM in the Asbestos Management Plan. |
1988 Perimeter Areas ',
Hallway and Miscellaneous Classrooms-Samples of building materials found in
these areas did not show detectable levels of asbestos.
Conclusions
Asbestos-containing dust was present; on surfaces in the carpentry shop.
Asbestos materials in the brake and clutch assemblies in various high speed
equipment could be a possible source of the elevated asbestos levels in the 1988
abatement area. The misidentification of vinyl asbestos-containing floor tile (VAT) in
the Asbestos Management Plan could also lead to uncontained VAT removals,
improper O&M, and possible contamination.
199
-------
TABLE B-69. SUMMARY OF BULK SAMPLE RESULTS
SITE K 1991 INSPECTION
Tyjteof material
Analyses
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 F'erimeter 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 stand
Negative
Positive0, amosite asbestos
Positive, chrysotile 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 for which inadequate material
was sivailable to allow a full quantitative evaluation, but were of sufficient size to determine that asbestos was
present and to determine the specific type of asbestos. Based on the professional judgment of the analyst, the
sample is considered to contain greater than 1 percent asbestos.
b Trace = <1 percent asbestos.
200
-------
SITEL
Background
Site Description
i
The abatement project at this single-sjtory school building involved the removal
of approximately 1600 ft2 of trowel-applied, asbestos-containing, acoustical ceiling
plaster. The abatement area was an auditorium. The project specifications indicated
that the asbestos content of the ceiling plaster was approximately 15 to 25 percent.
The information regarding the abated ACM and associated asbestos content was
obtained from the asbestos abatement specifications for this site.
Air Monitoring Summary
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside the abatement area, but inside the building), and outdoors at
approximately the same time and location as those samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Final clearance of the
abatement site was based on the samples collected by the AST. In 1990, air samples
were collected at this school by use of a modified aggressive sampling technique to
simulate occupied conditions. The samples were collected at approximately the same
locations as those collected in 1988. In 199]l and 1992, air samples were collected at
this school during occupied conditions (i.e., during normal school operating hours) at
approximately the same locations as those collected in 1988 and 1990.
i
Summary of Air Monitoring Results
Table B-70 summarizes the results frdm the four sampling efforts. Figure B-12
shows the mean airborne asbestos concentrations at Site L. A single-factor ANOVA
was used to compare mean concentrations measured in each of the three sampling
locations. Table B-71 presents the results of the ANOVA analysis. The subsections
following the tables summarize the pain/vise comparisons of the mean concentrations
in the three sampling locations. I
Postabatement -1988 \
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have failed the
AHERA initial screening test because the average filter concentration (768 s/mm2)
exceeded 70 s/mm2. Furthermore, the site would have failed the AHERA Z-test
201
-------
TABLE B-70. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(S/cm3) MEASURED AT SITE La
Sampling period
Mean
Mirt
Max
Max
Mean
0.118
0.093
0.156
0.060
0.026
0.181
0.004
0.015
0.002
0.010
0.001
0.005
0.006
0.016
0.003
0.006
0.003
0.007 0.002
0.005
• Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
TABLE B-71. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE L
"'
Statistically sjgnifieanl deferences in mean
0.0001
0.6016
0.0752
0.0408
A(0.118) R0.0601 O(0.004)
A(0.002) PfO.OOD O(0)
A(0.006) P(0.003) O(01
A(0.003) P(0.002) O(0)
If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
A = 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
Sampling locations (means) connected by a line are not significantly different.
202
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regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the^perimeter concentrations. Although the site
ultimately passed AHERA clearance by using the AST sampling results, the
EPA/IMJDOH results clearly show that elevated levels of airborne asbestos still existed
in the school in 1988.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.118 s/cm3) was
significantly greater than the average concentration measured outdoors (0.004 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.060 s/cm3) was
significantly greater than the average concentration measured outdoors (0.004 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.118 s/cm3) was not
significantly different from the average concentration measured in the perimeter areas
(0.060 s/cm3).
Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.002 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area in
1990 (0.001 s/cm3) was not significantly different from the average outdoor
concentration (0 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.002 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.001 s/cm3).
204
-------
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
I
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.006 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.003 s/cm3|) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.006 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.003 s/cm3).
i
Occupied Conditions -1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.003 s/crn3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.002 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
i
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.003 s/cnS3) was not significantly different from the
average concentration measured in the perimeter area (0.002 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
i
A single-factor ANOVA was used to compare mean concentrations measured in
1988,1990, 1991, and 1992. Each sampling location was evaluated separately.
i
205
-------
Table B-72 presents the results of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990, 1991, and
1992.
TABLE B-72. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE L
j?-vatueh
Fn rae&n airftorae
area
0.0001
0.0001
0.1191
1988(0.118) 1991(0.006) 1992(0.003) 1990(0.002)
1988(0.060) 1991(0.003) 1992(0.002) 1990(0.001)
1988(0.004) 1990(0) 1991(0) 1992(0)
a Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring.
d Years (means) connected by a line are not significantly different.
1988 Abatement Area
The average airborne asbestos concentrations measure during the AHERA
clearance phase of the 1988 abatement (0.118 s/cm3) was significantly greater than
the average concentration measured during simulated occupancy in 1990 (0.002
s/cm3) and during occupied conditions in 1991 (0.006 s/cm3) and 1992 (0.003 s/cm3).
Differences between average airborne asbestos concentrations measured in 1990,
1991, and 1992 were not statistically significant. The highest average concentration
(0.118 s/cm3) and the highest individual concentration (0.156 s/cm3) were measured
during the AHERA clearance phase of the 1988-abatement.
206
-------
Perimeter
The average airborne asbestos concentration measured during the AHERA
clearance phase of the 1988 abatement (0.060 s/cm3) was significantly greater than
the average concentrations measured during simulated occupancy in 1990
(0.001 s/crn3) and during occupied conditions in 1991 (0.003 s/cm3) and 1992 (0.002
s/cm3). Differences between average airborne asbestos concentrations measured in
1990,1991, and 1992 were not statistically significant. The highest average
concentration (0.060 s/cm3) and the highest individual concentration (0.181 s/cm3)
were measured during the AHERA clearance phase of the 1988 abatement.
i
Outdoors
The average airborne asbestos concentrations measured outdoors in 1988,
1990,1991, and 1992 were not significantly different. The highest average
concentration (0.004 s/cm3) and the highest individual concentration (0.015 s/cm3)
were measured during the AHERA clearance phase of the 1988 abatement.
Structure Morphology and Size Distributions
Table B-73 presents the distribution of structure type and morphology at each
sampling location separately for each year of monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 273 asbestos structures, of which 99.6 percent
were chrysotiie asbestos and 0.4 percent were amphibole asbestos. Overall, the
asbestos structures were primarily fibers (61J9 percent), and to a lesser extent,
clusters (18.3 percent), matrices (14.3 percent), and bundles (5.5 percent).
Table B-74 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each yjear of monitoring. Overall, 93.0 percent
of the observed asbestos structures were less than 5 jim in length. Of the 169
asbestos fibers observed, only 9 (5.4 percent) were greater than 5 ^m in length.
NJDOH Visual Inspections
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site L as part of the State's traditional quality assurance program which provides a
check and balance to asbestos abatement to! ensure that high-quality abatement and
state-of-the art work practices are used. The onsite AST collected the AHERA
clearance air samples only after the site had passed the NJDOH visual inspection.
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Two visual inspections were, required at this site. The site failed the first visual
inspection because of the presence of debris on thes upper ledge of the auditorium
ceiling and on the wooden blocks used to support th*e polyethylene containment
barriers. The contractor was then required to reclean these areas. After the areas
were recleaned, NJDOH conducted a second visual inspection, which the site passed.
1991 Inspection
Although asbestos monitoring conducted in May 1991 found airborne levels of
asbestos within the AHERA criteria, NJDOH conducted a visual inspection at Site L on
October 24, 1991, as a followup. 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 the following subsections were
examined by the NJDOH inspector in October 1991.
1988 Abatement Areas
Auditorium-DufmQ the abatement of acoustical ceiling materials in the
auditorium in 1988, scaffolding was used to access the materials, which were
approximately 35 feet above the floor. The sloping floor prevented the use of
conventional extension ladders to access the abatement zone. An attempt was made
to access the overhead areas via an opening in the wall above the projection booth
area; however, it was questionable whether the 1 ft-by-6 in. ductwork in this area or
the plaster ceiling would support any weight. No catwalks were available to gain
access to the truss/black-iron system to conduct an inspection for debris or overspray
materials. Either some white "splotches" remained after abatement or they were
splashes of encapsulant.
1988 Perimeter Areas
Stage-The Asbestos Management Plan does not list thermal system insulation
in the stage area; however, the roof drain appears to be cementitious material that has
sustained some minor damage from stored lumber (Table B-75).
Comctors-Thermal system insulation is present on pipe joints and elbows in the
plenum above the corridor drop ceiling. The materials appear to have been disturbed.
The Management Plan does not reflect this activity.
COA7C/L/S/O/7S
Inaccessibility to the abated areas prevented a definitive reinspection of the
site.
210
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TABLE B-75. SUMMARY OF BULK SAMPLE RESULTS - SITE L
1991 INSPECTION
•'"type of teertal
Air handling loft, stage
Air handling loft, stage
Elbow, air unit
Elbow, air unit
Negative
Trace3, chrysotile asbestos
Trace ~ <1 percent asbestos.
211
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SITEM
Background
Site Description
During the summer of 1988, two asbestos abatement projects were conducted
at this school. 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 (Site C). TSI was removed
from pipes in the corridors, classrooms, offices, storage rooms, and gymnasium
located in the basement (Site M). 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 specifications for this
site. There has been no additional abatement activity since 1988.
Air Monitoring Summary
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside the abatement area but inside the building), and outdoors at
approximately the same time and location as the samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Preabatement samples
were also collected in the abatement area and outdoors before the 1988 abatement
activities. Final clearance of the abatement site was based on the samples collected
by the AST.
In 1990, air samples were collected at this school by use of a modified
aggressive sampling technique to simulate occupied conditions. The samples were
collected at approximately the same locations as those collected in 1988.
In 1991 and 1992, air samples were collected at this school during actual
occupied conditions (i.e., during normal school operating hours) at approximately the
same locations as those collected in 1988 and 1990.
Summary of Air Monitoring Results
Table B-76 summarizes the results of the five sampling efforts. Figure B-13
illustrates the mean airborne asbestos concentrations at Site M. A single-factor
ANOVA was used to compare mean concentrations measured in each of the three
sampling locations. The results of the ANOVA analysis are presented in Table B-77.
The following subsections summarize the pairwise comparisons of the mean
concentrations in the three sampling locations.
212
-------
TABLE B-76. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Ma
Mean
Mean
Max
Mean
Win
0.001
0.004
0.003
0.011
0.322
0.054
0.530
0.002
0.008
0.002
0.004
1990
1991
0.023
0.056
0.004"
0.007
0.003
CXasup&rf condhfc&s^
199? *
0.003
0.005
0.005"
0.013
0.003
0.007
* Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b Outdoor samples are the same as those collected at Site C in 1990. 1991, and 1992 (Site M was the second
abatement project at this school in 1988).
0 Preabatement samples were not collected in the perimeter areas.
* N-4.
TABLE B-77. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE M
0.4466
0.0001
1.0
0.1924
0.8649
O(0.003) A(0.0011
A(0.322) P(0.002) O(0.002)
A(0) P(0) 0(0)
A(0.023) P(0.004) O(0.003)
P(0.005) A(0.003) O(0.003)
* If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
b As 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location. :
d Sampling locations (means) connected by a line are not significantly different.
213
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Preabatement -1988
The average airborne asbestos concentration measured in the abatement area
before the abatement (0.001 s/cm3) was not significantly different from the average
concentrations measured outdoors (0.003 s/cm3).
Postabatement -1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement by EPA/NJDOH showed that this site would
have failed the AHERA initial screening test because the average filter concentration
(2146 s/mm2) exceeded 70 s/mm2. Furthermore, the site would have failed the
AHERA Z-test regardless of whether the abatement area concentrations were
compared with the outdoor concentrations or| with the perimeter concentrations.
Although the site ultimately passed AHERA clearance by using the AST sampling
results, the EPA/NJDOH results clearly show that elevated levels of airborne asbestos
still existed in the school in 1988.
r
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.322 s/cm3) was
significantly greater than the average concentration measured outdoors (0.002 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.002 s/cm3) was not
significantly different from the average concentration measured outdoors (0.002
s/cm3).
Comparison of the Abatement Area With the Perimeter Area
i
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.322 s/cm3) was
significantly greater than the average concentration measured in the perimeter areas
(0.002 s/cm3).
215
-------
Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area in
1990 (0 s/cm3) was not significantly different from the average outdoor concentration
(0 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0 s/cm3).
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.023 s/cm3) was not significantly different from the
average concentration measured outdoors (0.003 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.004 s/cm3) was not significantly different from the
average concentration measured outdoors (0.003 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.023 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.004 s/cm3).
216
-------
Occupied Conditions -1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.003 s/crp3) was not significantly different from the
average concentration measured outdoors (0.003 s/cm3).
Comparison of the Perimeter Area With Outdoors
i
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.005 s/cm3) was not significantly different from the
average concentration measured outdoors (0.003 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.005 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988,1990,1991, and 1992. Each sampling location was evaluated separately.
Table B-78 presents the results of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990, 1991, and
1992.
1988 Abatement Area
i
The average airborne asbestos concentrations measure during the AHERA
clearance phase of the 1988 abatement (0.322 s/cm3) was significantly greater than
the average concentrations measured during simulated occupancy in 1990 (0 s/cm3)
and during occupied conditions in 1991 (0.023 s/cm3) and in 1992 (0.003 s/cm3).
Differences between average airborne asbestos concentrations measured during
occupied conditions in 1991 and 1992 were not statistically significant. Nor were the
average concentrations measured in 1990 and 1992 statistically significant. The
average concentration measured during occupied conditions in 1991 was, however,
significantly greater than the average concentration measured during simulated
occupancy in 1990. The highest average concentration (0.322 s/cm3) and the highest
individual concentration (0.530 s/cm3) were measured during the AHERA clearance
phase of the 1988 abatement.
217
-------
TABLE B-78. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990,1991, AND 1992 AT SITE M
.;- Samptteg
AMOVA
Sfatl^tlcaJly ^igftiilcaRi Differences tti wiean a!rt?orne
, "\ „, asbestos
Abatement area
Perimeter area
0.0001
0.1487
0.2707
1988(0.322) 1991(0.023) 1992(0.003) 1990(0)
1991(0.005) 1992(0.005) 1988(0.002) 1990(0)
1991(0.003) 1992(0.003) 1988(0.002) 1990(0)
8 Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring.
d Years (means) connected by a line are not significantly different.
Perimeter
The average airborne asbestos concentrations measured in the perimeter area
in 1988, 1990, 1991, and 1992 were not significantly different. The highest average
concentrations (0.005 s/cm3) was measured during occupied conditions in 1992 and
the highest individual concentrations (0.013 s/cm3) were measured during occupied
conditions in 1992, 4 years after the 1988 abatement.
Outdoors
The average airborne asbestos concentrations measured outdoors in 1988,
1990, 1991, and 1992 were not significantly different. The highest average
concentration (0.003 s/cm3) and the highest individual concentrations (0.011 s/cm3)
were measured during the AHERA clearance phase of the 1988 abatement.
Structure Morphology and Size Distributions
Table B-79 presents the distribution of structure type and morphology at each
sampling location for each year of monitoring. The TEM analysis of 20 samples
collected in the abated area, 20 collected in the perimeter area, and 20 collected
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outdoors yielded a total of 317 asbestos structures, of which 99.7 percent were
chrysotile asbestos and 0.3 percent were amphibole asbestos. Overall, the asbestos
structures were primarily fibers (68.1 percent), and to a lesser extent, matrices
(22.4 percent), clusters (7.3 percent), and bundles (2.2 percent).
Table B-80 presents the cumulative size distribution of asbestos samples at
each sampling location for each year of monitoring. Overall, 94.6 percent of the
obseived asbestos structures were less than 5 ^.m in length. Of the 216 asbestos
fibers observed, only 7 (3.3 percent) was greater than 5 jim in length.
Followup Air Monitoring - August 1991
Because the May 1991 average airborne asbestos concentration in the
previously abated area (0.023 s/cm3) exceeded 0.02 s/cm3, EPA/NJDOH conducted
followup monitoring on August 13, 1991, under simulated occupancy conditions, to
determine whether the airborne asbestos was still present at levels similar to those
measured in May. 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.
i
When the response action was complete, EPA/NJDOH conducted followup air
monitoring on August 29, 1991, to determine the residual levels of airborne asbestos.
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, however, to resolve the
elevated asbestos concentrations at this site.
NJDOH Visual Inspections
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site M as part of the State's traditional quality assurance program. This provides a
check and balance to asbestos abatement and ensures that high-quality abatement
and state-of-the art work practices are used. The onsite AST collected AHERA
clearance air samples only after the site had passed the NJDOH visual inspection.
220
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Three visual inspections w^re required at thislsite. The site failed the first
because debris was present on the floors and on pipe joints and elbows. The
contractor was then required to reclean these areas^ After the areas were recleaned,
NJDOH conducted a second visual inspection. The site failed the second visual
inspection because debris was found on pipes, on the floors and in wall penetrations.
When these areas were recleaned, NJDOH conducted a third visual inspection and
the site passed.
1991 Inspection
NJDOH conducted another visual inspection at Site M on August 14, 1991 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). In August 1991, the
NJDOH inspector examined only those areas indicated in the following subsections.
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
B-81). The storage and office areas were locked and could not be accessed.
1988 Perimeter Area
Boiler Room-Miscellaneous debris mixed in with the coal tested positive for
chrysotile (19 percent), amosite (3 percent), and crocidolite (trace) asbestos (Table B-
81). The TSI debris mixed in with the coal tested positive for chrysotile asbestos.
The TSI debris found under the boiler room stairway tested positive for chrysotile
asbesitos (67 percent).
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-
cpntafning building material (ACBM). Samples taken by the NJDOH were reported as
either 1 percent chrysotile asbestos, <1 percent chrysotile asbestos, or as negative for
asbestos (Table B-81). Although none of these materials tested greater than 1
222
-------
percent 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.
TABLE B-81. SUMMARY OF BULK SAMPLE RESULTS-SITE M
1991 INSPECTION
material
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, browncpat
Debris mixed in coal
j
TSI debris >
i
TSI debris
Negative
Negative
Positive3, chrysotile asbestos
3% chrysotile,
19% amosite, positive,
crocidolite asbestos
Positive, chrysotile asbestos
67% chrysotile asbestos
" This classification was defined by the NJDOH laboratory to accommodate samples for which
inadequate material was available to allow a full quantitative evaluation, but were of sufficient size to
determine that asbestos was present and to determine the specific type of asbestos. Based on the
professional judgment of the analyst, the sample is considered to contain greater than 1 percent
asbestos. '
223
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SITEN
Background
Site Description
During the summer of 1988, asbestos-containing acoustical ceiling plaster was
removed from Site N. The Site N abatement involved the removal of approximately
11,000 ft2 of ceiling plaster from an "egg crate" design concrete ceiling. The
abatement area included corridors, mechanical arts classrooms, and offices. The
acoustical plaster contained 10 to 25 percent chrysotile asbestos. The information
regarding the abated ACM and associated asbestos content was obtained from the
asbesitos abatement specifications for this site.
During the summer of 1991, 75,600 square feet of asbestos-containing ceiling
plaster was abated. There has been no other abatement activity between 1988 and
1992.
Air Monitoring Summary
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside of the abatement area but inside the building), and outdoors at
approximately the same time and location as those samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Final clearance of the
abatement site was based on the samples collected by the AST.
In 1990, air samples were collected at this school by a modified aggressive
sampling technique to simulate occupied conditions. The samples were collected at
approximately the same locations as those collected in 1988.
In 1991 and 1992, air samples were collected at this school during occupied
conditions (i.e., during normal school operating hours) at approximately the same
locations as those collected in 1988 and 1990.
Summary of Air Monitoring Results
Table B-82 summarizes the air monitoring results from the four sampling efforts.
Figure B-14 illustrates the mean airborne asbestos concentrations at Site N. A single-
factor ANOVA was used to compare mean concentrations measured in each of the
three sampling locations. The results of the ANOVA analysis are presented in Table
B-83. The following subsections summarize the pairwise comparisons of the mean
concentrations in the three sampling locations.
224
-------
TABLE B-82. SUMMARY OF AIRBORNE
(s/cm3) MEASURED
ASBESTOS CONCENTRATIONS
AT SITE Na
Mifl
Max
Ouldaoisi*
*
0.100
0.076
0.129
0.003
0.016
0.004
0.004
0.004
\'s'v *" 3 ""> ^ -A ww* •«
<«cupaH; -
0.007
0.031 !
0.004
0.011
0.001
0.005
0.004
0.003
0.009
0.015
0.046
0.004 0.002 0.008
0.006 0.003 0.013 0.004
0.012
* Samples were collected each year in the 1988 abatement
b Outdoor samples are the same as those collected
second abatement project at this school in 1988).
and perimeter areas and outdoors.
at Site K in 1990,1991, and 1992 (Site N was the
TABLE B-83. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE N
iiiiffer^nceis lii.
0.0001
0.6268
0.0125
0.2949
A(0.100) O(0.004) P(0.003)
A(0.007) P(0.004) O(0.001)
P(0.015) A(0.004) O(0)
P(0.006) A(0.004) O(0.004)
" If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pain/vise differences between sampling locations.
b A = 1988 Abatement area;. P = 1988 Perimeter area; O = Outdoors
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location. i
d Sampling locations (means) connected by a line are not significantly different.
225
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Postabatement - 1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have failed the
AHERA initial screening test because the average filter concentration (663 s/mm2)
exceeded 70 s/mm2. Furthermore, the site would have failed the AHERA Z-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. Although the site
ultimately passed AHERA clearance by using the AST sampling results, the
EPA/NJDOH results clearly show that elevated levels of airborne asbestos still existed
in the school in 1988.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.100 s/cm3) was
significantly greater than the average concentration measured outdoors (0.004 s/cm3).
i
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.003 s/cm3) was not
significantly different from the average concentration measured outdoors
(0.004 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos
during the AHERA clearance phase of the
significantly greater than the average
(0.003 s/cm3).
Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.007 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
concentration measured in the abatement area
abatement in 1988 (0.100 s/cm3) was
concentration measured in the perimeter areas
227
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area in
1990 (0.004 s/cm3) was not significantly different from the average outdoor
concentration (0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.007 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.004 s/cm3).
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.004 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.015 s/cm3) was significantly greater than the
average concentration measured outdoors (0 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.004 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.015 s/cm3).
Occupied Conditions -1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.004 s/cm3) was not significantly different from the
average concentration measured outdoors (0.004 s/cm3).
228
-------
Comparison of the Perimeter Area With Outdoors
\
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.006 s/cm3) was not significantly different from the
average concentration measured outdoors (0.004 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
\
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.004 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.006 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988,1990, 1991, and 1992. Each sampling location was evaluated separately. The
result of the ANOVA analysis is presented in Table B-84, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990,1991, and
1992.
TABLE B-84. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE N
Sta|i$llcaffy signiljcant <3i«emnces in mean airborn
"'*-"' " '
Abatement
•f "*^
, ,S V *'
Perimeter ar&a
\
""•^ •" ^ -,-i
Outdoors /^s
0.0001
0.2248
0.0282
1988(0.100) 1990(0.007) 1991(0.004) 1992(0.004)
1991(0.015) 1992(0.006) 1990(0.004) 1988(0.003)
1988(0.004) 1992(0.004) 1990(0.001) 1991(0)
* Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring. ;
d Years (means) connected by a line are not significantly different.
229
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1988 Abatement Area -6. » '
The average airborne asbestos concentrations measure during the AHERA
clearance phase of the 1988 abatement (0.100 s/cm3) was significantly greater than
the average concentrations measured during simulated occupancy in 1990
(0.007 s/cm3) and during occupied conditions in 1991 (0.004 s/cm3) and in 1992
(0.004 s/cm3). Differences between average airborne asbestos concentrations
measured during occupied conditions in 1990,1991 and 1992 were not statistically
significant. The highest average concentration (0.100 s/cm3) and the highest
individual concentration (0.129 s/cm3) were measured during the AHERA clearance
phase of the 1988 abatement.
1988 Perimeter Area
The average airborne asbestos concentrations measured in the perimeter area
in 1988, 1990, 1991, and 1992 were not significantly different. The highest average
concentrations (0.015 s/cm3) were measured during occupied conditions in 1991 and
1992 and the highest individual concentrations (0.006 s/cm3) were measured during
occupied conditions in 1991, 3 years after the 1988 abatement.
Outdoors
The average airborne asbestos concentrations measured outdoors in 1988 was
significantly greater than the average concentration measured in 1991. Other
differences in the average concentrations measured in 1988, 1990, 1991, and 1992
were not statistically significant. The highest average concentrations (0.004 s/cm3)
were measured in 1988 and in 1992 and the highest individual concentration (0.012
s/cm3) was measured in 1992.
Structure Morphology and Size Distributions
Table B-85 presents the distribution of structure type and morphology at each
sampling location for each year of monitoring. The TEM analysis of 20 samples
collected in the abated area, 20 collected in the perimeter area, and 20 collected
outdoors yielded a total of 203 asbestos structures, all of which were chrysotile
asbestos. Overall, the asbestos structures were primarily fibers (72.9 percent), and to
a lesser extent, matrices (19.2 percent), clusters (4.9 percent), and bundles (3.0
percent).
Table B-86 presents the cumulative size distribution of asbestos samples at
each sampling location for each year of monitoring. Overall, 96.6 percent of the
observed asbestos structures were less than 5 jam in length. Of the 148 asbestos
fibers observed, only 2 (1.4 percent) were greater than 5 |im in length.
230
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Followup Air Monitoring - August 1991
Although the average airborne asbestps concentrations in the previously abated
area and in the perimeter area did not exceed 0.02 s/cm3 in May 1991, EPA/NJDOH
conducted followup monitoring under simulated occupancy conditions on August 14,
1991, because the average airborne asbestos concentration in the previously abated
area from another abatement project at this school (Site K) did exceed 0.02 s/cm3.
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 Inspections
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site N as part of the State's traditional quality assurance program. This provides a
check and balance to asbestos abatement and ensures that high-quality abatement
and state-of-the art work practices are used. The onsite AST collected AHERA
clearance air samples only after the site had passed the NJDOH visual inspection.
Two visual inspections were required at this site. The site failed the first visual
inspection because debris was present on light fixtures, on the tops of heating
elements, on conduit pipe, on the walls behind ventilation ducts, and on the floors.
The contractor was then required to reclean these areas. When the areas were
recleaned, NJDOH conducted a second visual inspection, which the site passed.
1991 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
Refrigeration/AC Room, Mechanical (Engine) Room-Surface dust was noted
but not sampled.
233
-------
1988 Perimeter Areas
Classrooms, Mechanical Arts Room-Surface dust was noted but not sampled.
The floor tile in classrooms was not identified as ACM in the Asbestos Management
Plan.
Conclusions
Asbestos materials in the brake and clutch assemblies in various high speed
equipment could be a possible source of airborne asbestos. The misidentification of
VAT in the Asbestos Management Plan could also lead to uncontained VAT removals,
improper O&M and possible contamination.
234
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SITED
Background
Site Description
The abatement project at this two-story school involved the removal of
approximately 2,100 ft2 of 2-ft by 4-ft lay-in, asbestos-containing, acoustical ceiling
tiles. The abatement area included corridors, classrooms, and offices. The project
specifications indicated that the asbestos content of the ceiling plaster was
approximately 5 to 10 percent amosite. The information regarding the abated ACM
and associated asbestos content was obtained from the asbestos abatement
specifications for this site. ,
Air Monitoring Summary
i
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside the abatement area but inside the building), and outdoors at
approximately the same time and location as those samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Final clearance of the
abatement site was based on the samples collected by the AST. In 1990, air samples
were collected at this school by a modified aggressive sampling technique to simulate
occupied conditions. The samples were collected at approximately the same locations
as those collected in 1988. In 1991 and 1992, air samples were collected during
occupied conditions (i.e., during normal school operating hours) at approximately the
same locations as those collected in 1988 and 1990.
i
Summary of Air Monitoring Results ;
I
Table B-87 summarizes the results from the four sampling efforts. Figure B-15
illustrates the mean airborne asbestos concentrations at Site O. A single-factor
ANOVA was used to compare mean concentrations measured in each of the three
sampling locations. The results of the ANOVA analysis are presented in Table B-88.
The following subsections summarize the pairwise comparisons of the mean
concentrations in the three sampling locations.
Postabatement -1988
AHERA Clearance Test
Airborne asbestos concentrations measured
clearance phase of the 1988 abatement showed
AHERA initial screening test because the
average
235
by EPA/NJDOH during the AHERA
that this site would have passed the
filter concentration (31 s/mm2) was
-------
TABLE B-87. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Oa
Mean
f-f'- _ _ ''S-fffff f
I/lax ;
Mean
Win
. .Mean '•
Mast
0.004
0.003
0.007
0.003
0.010
0.001
0.004
occupancy- tSS&
0.001
0.005
0.018
0.086
0.001
0.005
Occuipjad conditions- 1391
0.005
0.022
0.001
0.003
Oecuipleci conditions- 1S92
0.002
0.005 0.001
0.003
0.027
0.012
0.047
Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
TABLE B-88. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE O
Sampling period
Statistically significant differences In"
t&¥i afthftrttfi ftfthoclAfe /*rin**ant^ttt}rtWW^
0.1084
0.4478
0.3298
0.0001
A(0.004) P(0.003) 0(0.001)
P(0.018) A(0.001) O(0.001)
AfO.OOS) O(0.001) P(0)
O(0.027) A(0.002) PfO.OOD
a If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
b A = 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
d Sampling locations (means) connected by a line are not significantly different.
236
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-------
below 70 s/mm2. Furthermore, the site would have passed the AHERA Z-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. These results are
consistent with AST sampling results.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.004 s/cm3) was not
significantly different from the average concentration measured outdoors (0.001
s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.003 s/cm3) was not
significantly different from the average concentration measured outdoors (0.001
s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.004 s/cm3) was not
significantly different from the average concentration measured in the perimeter areas
(0.003 s/cm3).
Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area in
1990 (0.018 s/cm3) was not significantly different from the average outdoor
concentration (0.001 s/cm3).
238
-------
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/crn3) was not significantly different from the
average concentration measured in the perimeter areas (0.018 s/cm3).
i
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.005 s/cbi3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
i
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0 s/cm3) was not significantly different from the
average concentration measured outdoors (6.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.005 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0 s/cm3).
Occupied Conditions - 1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.002 s/crn3) was significantly less than the average
concentration measured outdoors (0.027 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.001 s/cm3) was significantly less than the average
concentration measured outdoors (0.027 s/cm3).
239
-------
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.002 s/cm3) was not significantly different from the
average concentration measured in the perimeter areas (0.001 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988, 1990, 1991, and 1992. Each sampling location was evaluated separately.
Table B-89 presents the result of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990, 1991, and
1992.
TABLE B-89. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE O
-------
individual concentration (0.022 s/cm3) were measured during occupied conditions in
1991, 3 years after abatement.
Perimeter \
The average airborne asbestos concentrations measured in the perimeter area
in 1988,1990, 1991, and 1992 were not significantly different. The highest average
concentrations (0.018 s/cm3) and the highest individual concentrations (0.086 s/cm3)
were measured during simulated occupancy, conditions in 1990, 2 years after the 1988
abatement.
Outdoors
The average airborne asbestos concentrations measured outdoors in 1992 was
significantly greater than the average concentration measured in 1988, 1990, and
1991. Differences in the average concentrations measured in 1988, 1990, 1991 were
not statistically significant. The highest average concentrations (0.027 s/cm3) and the
highest individual concentration (0.047 s/cm3) was measured in 1992.
Structure Morphology and Size Distributions
Table B-90 presents the distribution of structure type and morphology at each
sampling location separately for each year of monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 95 asbestos structures, of which 97.9 percent
were chrysotile asbestos and 2.1 percent of which were amphibole asbestos. Overall,
the asbestos structures were primarily fibers (80 percent), and to a lesser extent,
matrices (10.5 percent), clusters (5.3 percent), and bundles (4.2 percent).
Table B-91 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. All of the observed
asbestos structures were less than 5 |im in length.
NJDOH Visual inspections
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site O as part of the State's traditional quality assurance program. This provides a
check and balance to asbestos abatement apd ensures that high-quality abatement
and state-of-the art work practices are used.: The onsite AST collected AHERA
clearance air samples only after the site had| passed the NJDOH visual inspection.
241
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•!=•• r; -|
Two visual inspections were required at this site. The site failed the first visual
inspection because debris was present on overhead pipes, on the grid system
framework for suspended ceiling panels, and in corners of floor-wall intersections.
The contractor was then required to reclean these areas. Once the areas were
recleaned, NJDOH conducted a second visual inspection. The site passed the second
visual inspection.
1991 Visual Inspection
Although asbestos monitoring conducted in May 1991 found airborne levels of
asbestos within the AHERA criteria, on October 29, 1991, NJDOH conducted a visual
inspection at Site O as a followup. 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 by the NJDOH inspector in October 1991.
1988 Abatement Areas
First Floor Corridor and Stairwell-Minor debris (flakes that tested positive for
chrysotile asbestos) was obtained from the lip of a suspended Nesbitt heater unit
(Table B-92) Other flakes of debris found on a wall tested negative for asbestos.
Fiberglass pipe insulation with cementitious elbows and joints was noted above the
drop ceiling. Debris recovered near an elbow above the drop ceiling at a water
fountain tested positive (6 percent chrysotile, 21 percent amosite asbestos). Another
sample, taken from an elbow, tested negative for asbestos. These materials are not
listed in the Asbestos Management Plan.
Second Floor Corr/cfor-This inspection was limited by heavy fiberglass batting
applied atop the drop ceilings. No debris was found in this area.
1988 Perimeter Areas
Hallway at Gym and Boiler Room-No suspect asbestos-containing thermal
system insulation was found.
Boiler f?oom--Approximately 5 linear feet of corrugated pipe insulation
(22 percent chrysotile asbestos) with damaged friable elbow insulation (4 percent
chrysotile, 4 percent amosite asbestos) was found (Table B-92). This material was
apparently overlooked during abatement.
Pipe Tunnel-Thermal debris (1 percent chrysotile, 4 percent amosite asbestos)
was found at the entry to the tunnel (Table B-92).
244
-------
TABLE B-92. SUMMARY OF BULK SAMPLE RESULTS
1991 INSPECTION
SITEO
Type of
Analyses
1988 Abatement Areas
North stairwell
South stairwell
Corridor 1st level
Corridor 1st level
1988 Perimeter Areas
Boiler room
Boiler room
Pipe tunnel entry
Encapsulated flakes on wall
Residue on Nesbitt heater
Elbow with fiberglass
insulation
Elbow debris at water
fountain
NE corner - corrugated pipe
insulation
N/E corner - elbow
Thermal debris
Negative
Positive3, chrysotile asbestos
Negative
6% chrysotile asbestos
21% amosite asbestos
22% chrysotile asbestos
4% chrysotile asbestos
<1 % amosite asbestos
1% chrysotile asbestos
4% amosite asbestos
a This classification was defined by the NJDOH laboratory to accommodate samples
for which inadequate material was available to allow a full quantitative evaluation,
but were of sufficient size to determine that asbestos was present and to determine
the specific type of asbestos. Based on the professional judgment of the analyst,
the sample is considered to contain greater than 1 percent asbestos.
Basement of New Wing-Room 114 and Science Storage have cementitious
elbows associated with fiberglass pipe insulation. These materials do not appear in
the Asbestos Management Plan.
Conclusions
[
A number of asbestos sources were identified in the various areas of the
building. The school's Asbestos Management Plan must be revised to reflect the
presence of these materials.
245
-------
SITEP
Background
Site Description
The abatement project at this three-story school building involved the removal
of trowel-applied, asbestos-containing, acoustical ceiling plaster and mixed-diameter
pipe insulation. The abatement area included corridors, classrooms, and offices. The
project specifications indicated that the abatement involved the removal of
approximately 8500 ft2 of acoustical ceiling plaster containing 91 to 93 percent
chrysotile and approximately 1600 linear feet of mixed-diameter pipe insulation. The
latter included hard-packed pipe insulation (24 percent chrysotile), air-cell-paper pipe
insulation (4 to 10 percent chrysotile), and hard-packed joint insulation (60 percent
chrysotile). The information regarding the abated ACM and associated asbestos
content was obtained from the asbestos abatement specifications for this site.
Air Monitoring Summary
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside the abatement area but inside the building), and outdoors at
approximately the same time and location as those samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Preabatement samples
were also collected in the perimeter areas and outdoors before the 1988 abatement
activities. Final clearance of the abatement site was based on samples collected by
the AST. In 1990, air samples were collected at this school by use of a modified
aggressive sampling technique to simulate occupied conditions. The samples were
collected at approximately the same locations as those collected in 1988. In 1991 and
1992, air samples were collected at this school during occupied conditions (i.e., during
normal school operating hours) at approximately the same locations as those collected
in 1988 and 1990.
Summary of Air Monitoring Results
Table B-93 summarizes the results of the five sampling efforts. Figure B-16
shows the mean airborne asbestos concentrations at Site P. A single-factor ANOVA
was used to compare mean concentrations measured in each of the three sampling
locations. Table B-94 presents the results of the ANOVA analysis. The following
subsections summarize the pairwise comparisons of the mean concentrations in the
three sampling locations.
246
-------
TABLE B-93. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Pa
< Sean '"
j' .%!'',-?: '..'•'.
Max
Mean
Win
Max
Outsets,
Mean
0.001
0.005
0.005
0.011
0.007
0.018
0.003
0.016
- tsso
0.005
0.025
0.004
0.011
0.001
0.004
Occulted condi«ofls.-t992
0.003
0.010
0.006
0.020
0.009°
0.018
* Samples ware collected each year in the 1988 abatement and perimeter areas and outdoors.
b Abatement area was not accessible for preabatemant sampling.
c N-4.
TABLE B-94. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATlbNS MEASURED AT SITE P
Statlstlcafly sighificanl differences m im&
«lrl>ome
0.3466
0.4285
0.3966
0.0891
0.4714
P(0.001) OKH
P(0.007) A(O.OOS) O(0.003)
AfO.OOS)
O(0)
A(0.004) P(0.001)
O(Q.OQ9) P(0.006)
" If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
b A « 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
d Sampling locations (means) connected by a line ar|e not significantly different.
247
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Preabatement -1988
The average airborne asbestos concentration measured in the perimeter area
before the abatement in 1988 (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (p s/cm3).
Postabatement -1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have passed the
AHERA initial screening test because the average filter concentration (30 s/mm2) was
below 70 s/mm2. Furthermore, the site would have passed the AHERA Z-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. These results are
consistent with AST sampling results. :
Comparison of the Abatement Area With Outdoors
\
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.005 s/cm3) was not
significantly different from the average concentration measured outdoors (0.003
s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.007 s/cm3) was not
significantly different from the average concentration measured outdoors (0.003
s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.005 s/cm3) was not
significantly different from the average concentration measured in the perimeter area
(0.007 s/cm3).
249
-------
Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.005 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area in
1990 (0 s/cm3) was not significantly different from the average outdoor concentration
(0 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.005 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0 s/cm3).
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.004 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.004 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.001 s/cm3).
250
-------
Occupied Conditions -1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.003 s/cpi3) was not significantly different from the
average concentration measured outdoors (0.009 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.006 s/cm3) was not significantly different from the
average concentration measured outdoors (0.009 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.003 s/cfn3) was not significantly different from the
average concentration measured in the perimeter area (0.006 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
i
A single-factor ANOVA was used to compare mean concentrations measured in
1988, 1990,1991, and 1992. Each sampling location was evaluated separately.
Table B-95 presents the results of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subseptions following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990, 1991, and
1992. ;
1988 Abatement Area
Differences between average airborne asbestos concentrations measured
during occupied conditions in 1988, 1990, 1991, and 1992 were not statistically
significant. The highest average concentrations (0.005 s/cm3) were measured in 1988
and 1990, and the highest individual concentration (0.025 s/cm3) was measured during
simulated occupancy in 1990, 2 years after abatement.
i
Perimeter
i
The average airborne asbestos concentrations measured in the perimeter area
in 1988,1990, 1991, and 1992 were not significantly different. The highest average
concentration (0.007 s/cm3) was measured during the AHERA clearance phase of the
1988 abatement, and the highest individual concentration (0.020 s/cm3) was measured
during occupied conditions in 1992, four years after the 1988 abatement.
251
-------
TABLE B-95. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990,1991, AND 1992 AT SITE P
\ ,r$ar8:piing
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0.9024
0.0856
0.0088
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253
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Table B-97 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. Overall, 98.4 percent
of the observed asbestos structures were less than 5 |im in length. Of the 45
asbestos fibers observed, only 1 (2.2 percent) was greater than 5 ^m in length.
NJDOH Visual Inspections
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site P as part of the State's traditional quality assurance program, which provides a
check and balance to asbestos abatement to ensure that high-quality abatement and
state»of-the art work practices are used. The onsite AST collected the AHERA
clearance air samples only after the site had passed the NJDOH visual inspection.
Three visual inspections were required at this site. The site failed the first
visual inspection because of the presence of debris on pipes, in openings where the
pipes penetrated the walls, on electrical fixtures and wires, in door jambs, at ceiling-
wall junctions, on walls, inside a fireplace and chimney, and in a sink used for disposal
of asbestos-contaminated wastewater. The contractor was then required to reclean
these areas. After the areas were recleaned, NJDOH conducted a second visual
inspection. The site failed the second visual inspection because of debris found
behind the fireplace, at ceiling-wall junctions, and on floors and residual slurry found
on walls and underneath stairs. After these areas were recleaned, NJDOH conducted
a third visual inspection which the site passed.
1991 Inspection
Although asbestos monitoring conducted in May 1991 found airborne levels of
asbestos within the AHERA criteria, NJDOH conducted a visual inspection at Site P on
November 5, 1991 as a followup. 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 by the NJDOH inspector in November 1991.
1988 Abatement Areas
Kindergarten ffoom-Unencapsulated residual ceiling material was noted on the
top of the windows and exterior aluminum wall columns (Table B-98). Encapsulated
and painted material was noted at the ceiling and wall junctions. Approximately
35 linear feet of corrugated pipe insulation was found in the space above the lavatory
and the closet storage area. These pipes do not appear in the Asbestos Management
Plan.
254
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TABLE B-98. SUMMARY OF BULK SAMPLE RESULTS - SITE P
,1991 INSPECTOR
Lotion
Type of Material
1988 Abatement Area
Kindergarten (KDGA)
KDGA
KDGA
SW Stairwell
1988 Perimeter Areas
2nd Floor classroom
Spray-on residue at top of
windows
Dust inside radiator
Painted over residue on wall
at ceiling and wall junctions
Floor tile debris under
radiator
Dust inside radiator
Positive3 for chrysotile
asbestos
Negative
Positive for chrysotile
asbestos
8% Chrysotile asbestos
Negative
This classification was defined by the NJDOH laboratory to accommodate samples
for which inadequate material was available to allow a full quantitative evaluation,
but were of sufficient size to determine that asbestos was present and to determine
the specific type of asbestos. Based on the professional judgment of the analyst,
the sample is considered to contain greater than 1 percent asbestos.
First Floor Corridor, 1965 Wing-Pipe insulation was observed in the plenum
above the hallway through a new penetration. Intercom-type wire had recently been
run on top of this insulation. This material does not appear in the Asbestos
Management Plan.
Classroom No. 2~From a closet overhead area, pipe insulation was noted to be
running through vertical shafts along the exterior wall. Pipe insulation was also visible
above the corridor ceilings. These materials do not appear in the Asbestos
Management Plan.
1988 Perimeter Areas
1st Floor Corridor, Old W/?g~Thermal system insulation was noted in the
plenum above the hallway. This material is listed in the Asbestos Management Plan.
Foyer Chase-Jhe floor under the entry foyer contains thermal system insulation
that is not listed in the Asbestos Management Plan.
256
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Girls Lavatory, 1st F/oor-lnaccessible thermal systems insulation was
observed. The Asbestos Management Plan does not list these remaining materials.
Boiler floom-Packing and lag were noted around the caps on top of the boilers
and are not included in the Asbestos Management Plan.
Pump Room-Debris was noted at the entrance to the pipe tunnels.
Conclusions
TSI was present in the 1988 abatement and perimeter areas, but not listed in
the Management Plan and the potential for disturbance exists. Residual materials are
located above the suspended ceiling and as such, would not be disturbed during
subsequent air sampling.
257
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SITE Q
Background
Site Description
During the summer of 1988, two asbestos abatement projects were conducted
at this school (Sites B and Q). Spray-applied acoustical ceiling plaster was removed
from the second floor (Site B) and from the first floor (Site Q). The abatement areas
at both sites 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 specifications for this site. No additional abatement activity has occurred
since 1988.
Air Monitoring Summary
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside the abatement area, but inside the building), and outdoors at
approximately the same time and location as those samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Preabatement samples
were also collected in the perimeter area and outdoors before the 1988 abatement
activities. Final clearance of the abatement site was based on the samples collected
by the AST. In 1990, air samples were collected at this school by use of a modified
aggressive sampling technique to simulate occupied conditions. The samples were
collected at approximately the same locations as those collected in 1988. In 1991 and
1992, air samples were collected at this school during occupied conditions (i.e., during
normal school operating hours) at approximately the same locations as those collected
in 1988 and 1990.
Summary of Air Monitoring Results
Table B-99 summarizes the results from 1988, 1990, 1991, and 1992. Figure
B-17 shows the mean airborne asbestos concentrations at Site Q. A single-factor
ANOVA was used to compare mean concentrations measured in each of the three
sampling locations. The results of the ANOVA analysis are presented in Table B-100.
The following subsections summarize the pairwise comparisons of the mean
concentrations in the three sampling locations.
258
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TABLE B-99. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Qa
Max
"Jala*
0.001
0.004
0.099
0.029
0.157
0.055
0.115
0.007
0.021
0.019
0.040
0.010
0.040
0.001
0.005
0.009
0.018
0.012
0.004
0.024
0.001
0.004
0.053 0.025 0.104 0.438 0.142 1.02
0.001
0.003
* Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b Perimeter and Outdoor samples are the same as those collected at Site B in 1990, 1991, and 1992 (Site Q was
the second abatement project at this school in 1988).
c Abatement area was not accessible for preabatement sampling.
TABLE B-100. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE Q
•. atrbome asbestos ^6ncen|ralion
v ,
pccupfed conditIoosrif92: v;
0.3466
0.0095
0.0907
0.0059
0.0001
P(0.001) CXO)
P(0.055) O(0.007)
A(0.019) P(0.010) O(0.001)
P(0.012) A(0.009) O(0.001)
P(0.438) A(0.053) O(0.001)
* If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
b A s 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors.
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location. l
d Sampling locations (means) connected by a line are not significantly different.
259
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260
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Preabatement - 1988
The average airborne asbestos concentration measured in the perimeter area
before the abatement (0.001 s/cm3) was not significantly different from the average
concentration measured outdoors (0 s/cm3).
Postabatement -1988
\
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have failed the
AHERA initial screening test because the average filter concentration (648 s/mm2)
exceeded 70 s/mm2. Furthermore, the site would have failed the AHERA 2-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. Although the site
ultimately passed AHERA clearance by using the AST sampling results, the
EPA/NJDOH results clearly show that elevated levels of airborne asbestos still existed
in the school in 1988.
Comparison of the Abatement Area With Outdoors
. i
The average airborne asbestos concentration measured in the abatement area •
during the AHERA clearance phase of the abatement in 1988 (0.099 s/cm3) was
significantly greater than the average concentration measured outdoors (0.007 s/crn3).
This result is consistent with the AHERA Z-test comparison reported previously.
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0.055 s/cm3) was not
significantly different from the average concentration measured outdoors
(0.007 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.099 s/cm3) was not
significantly different from the average concentration measured in the perimeter area
(0.055 s/cm3).
261
-------
Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the previously
abated area 2 years after the 1988 abatement (0.019 s/cm3) was not significantly
different from the average concentration measured outdoors (0.001 s/cm3).
Comparison of the Perimeter Areas With Outdoors
The average airborne asbestos concentration measured in the perimeter area 2
years after the 1988 abatement (0.010 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area ,
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.019 s/cm3) was not significantly different from the
average airborne asbestos concentration measured in the perimeter area
(0.010 s/cm3).
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.009 s/cm3) was significantly greater than the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Perimeter Areas With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.012 s/cm3) was significantly greater than the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.009 s/cm3) was not significantly different from the
average airborne asbestos concentration measured in the perimeter area
(0.012 s/cm3).
262
-------
Occupied Conditions - 1992
Comparison of the Previously Abated Area With Outdoors
i
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.053 s/cm3) was significantly greater than the
average concentration measured outdoors (6.001 s/cm3).
Comparison of the Perimeter Areas With Outdoors
f
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.438 s/cm3) was significantly greater than the
average outdoor concentration of airborne asbestos (0.001 s/cm3). The unusually high
average level in the perimeter areas is due primarily to one sample (1.02 s/cm3); the
other four samples ranged from 0.014 to 0.038 s/cm3.
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.053 s/cm3) was significantly less than the average
airborne asbestos concentration measured in the perimeter area (0.438 s/cm3). The
unusually high average level in the perimeter area is due primarily to one sample
(1.02 s/cm3); the other four samples ranged [from 0.014 to 0.038 s/cm3.
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988,1990, 1991, and 1992. Each sampling location was evaluated separately.
Table B-101 presents the results of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990, 1991, and
1992.
1988 Abatement Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the 1988 abatement (0.099 s/cm3) was
significantly greater than the average concentrations measured during simulated
occupancy in 1990 (0.019 s/cm3) and during occupied conditions in 1991
(0.009 s/cm3), but not significantly different from the average concentration measured
during occupied conditions in 1992 (0.053 s/cm3). Furthermore, the average
concentration measured during occupied conditions in 1992 was significantly higher
than the average concentration measured in 1991. Other differences between
average concentrations were not statistically, significant. The highest average
263
-------
concentration (0.099 s/cm3) and the highest individual concentration (0.157 s/cm3)
were measured during the AHERA clearance phase of the 1988 abatement.
TABLE B-101. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE Q
Statisiicaiiy significam differences IB mean airborne
— —^ asbestos coneealraflon^ -- "-* - ,t"•
area
0.0019
0.0002
0.1871
1988(0.099) 1992(0.053) 1990(0.019) 1991(0.009)
1992(0.438) 1988(0.055) 1991(0.012) 1990(0.010)
1988(0.007) 1990(0.001) 1991(0.001) 1992(0.001)
a Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pain/vise differences between sampling locations.
c Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring.
d Years (means) connected by a line are not significantly different.
Perimeter Area
The average airborne asbestos concentrations measured in the perimeter area
in 1992, 4 years after the 1988 abatement (0.438 s/cm3), was significantly higher than
the average levels measured in 1988,1990, and 1991. The differences between the
average levels in 1988, 1990, and 1991 were not statistically significant. The highest
average concentration (0.438 s/cm3) and the highest individual concentration (1.02
s/cm3) were measured in 1992 4 years after the 1988 abatement.
Outdoors
Differences in average airborne asbestos concentration measured outdoors in
each of the 4 years were not statistically significant. The highest individual
concentration (0.021 s/cm3) was measured in 1988 during the AHERA clearance
phase of the abatement.
264
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Structure Morphology and Size Distributions
Table B-102 presents the distribution of structure type and morphology at each
sampling location separately for each year of monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 889 asbestos structures, of which 99.7 percent
were chrysotile asbestos and 0.3 percent were amphibole. Overall, the asbestos
structures were primarily fibers (92.2 percent), and to a lesser extent, matrices (5.4
percent), clusters (1.5 percent), and bundles (0.9 percent).
!
Table B-103 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. Overall, 98.7 percent
of the observed asbestos structures were less than 5 jim in length. Of the 820
asbestos fibers observed, only 4 fibers (0.5 percent) were greater than 5 urn in length.
Followup Air Monitoring - August 1991
Although the average airborne asbestos concentration in the previously abated
area and the perimeter area in May 1991 did not exceed 0.02 s/cm3, EPA/NJDOH
conducted followup monitoring on August 13,1991, under simulated occupancy
conditions because the average airborne asbestos concentration in the previously
abated area from another abatement project at this school (Site B) did exceed
0.02 s/cm3. The August 13 results showed that the average airborne asbestos
concentration in the previously abated area and perimeter area of Site Q were below
0.02 s/cm3; therefore, no further monitoring activity was required.
Followup Air Monitoring - August 1992
Because the average airborne asbestos concentrations in the previously abated
area (0.053 s/cm3) and the perimeter area (0.438 s/cm3), EPA/NJDOH conducted
followup monitoring in July 1992 under simulated occupancy conditions to determine
whether airborne asbestos concentration were still present at the levels observed in
May 1992. The average airborne asbestos concentration measured in the perimeter
area in July (0.006 s/cm3) was below 0.02 s/cm3; therefore, no further action was
required in this area. The NJDOH did, however, require a response action in the
previously abated area at this school, based on the May 1992 data. The school
subsequently employed a licensed asbestosrabatement contractor to clean the
previously abated area. When the cleaning fiction was complete, NJDOH conducted
followup air monitoring in August 1992 to determine the residual levels of airborne
asbestos. The average airborne asbestos concentration measured in August
(0.009 s/cm3) was below 0.02 s/cm3; therefore, no further monitoring activity was
required at this school.
265
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267
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NJDOH Visual Inspections
1
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site Q as part of the State's traditional quality assurance program, which provides a
check and balance to asbestos abatement to ensure that high-quality abatement and
state-of-the art work practices are used. The onsite AST collected the AHERA
clearance air samples only after the site had passed the NJDOH visual inspection.
Four visual inspections were required at this site. The site failed the first visual
inspection because of the presence of debris on the tops of storage closets and on
structural beams. The contractor was then required to reclean these areas. After the
areas were recleaned, NJDOH conducted a second visual inspection. The site failed
the second visual inspection because of debris in openings at wall penetrations and on
several light fixtures. The contractor was again required to reclean the affected areas.
After the areas were recleaned, NJDOH conducted a third visual inspection. The site
failed the third visual inspection because of debris at wall-ceiling junctions, in door
jambs, and in corners of window sills. After these areas were recleaned, NJDOH
conducted a fourth visual inspection. The site passed the fourth visual inspection with
the stipulation that the overhead area be sprayed with encapsulant.
Background for 1991 and 1992 Inspections
On August 14,1991, and July 16,1992, NJDOH conducted a visual inspection
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 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 and July 1992.
1991 Inspection
1988 Abatement Areas
Two samples of overspray and debris were collected from the structural steel
and closet overhead areas in the first-floor classrooms (Table B-104); one sample of
spray-on debris tested positive for chrysotile asbestos, and a sample of sandy debris
from an air shaft tested negative for asbestos.
268
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TABLE B-104. SUMMARY OF BULK SAMPLE RESULTS-SITE Q
1991 INSPECTION
Type of material
Analyses
1988 Abatement Area
1st floor classroom
1st floor classroom, air
shaft ledge
1988 Perimeter Areas
Basement all-purpose
room
Flakes of spray-on debris
Flakes of spray-on debris
Positive, chrysotile
asbestos
Negative
Composite, ceiling sample
Negative
This classification was defined by the NJDOH laboratory to accommodate samples
for which inadequate material was available to allow a full quantitative evaluation,
but were of sufficient size to determine that asbestos was present and to determine
the specific type of asbestos. Based on the professional judgment of the analyst,
the sample is considered to contain greater than 1 percent 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
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.
269
-------
1992 Inspection
v*- .,-
1988 Abatement Area f
First-Floor Classrooms-\n 1991, the NJDOH inspectors found residual spray-
applied asbestos-containing material on the black iron trusses above the ceilings and
ventilation panels in closets of the classrooms. Samples of this material showed it to
contain asbestos (Table B-105). The black iron trusses support the wire lathe, scratch
coat, and acoustical plaster layers that make up the ceiling system in each classroom.
The ceilings of the closets consist of wood paneling and a metal ventilation panel.
The flakes of asbestos-containing acoustical plaster on the trusses appeared to be the
result of overspraying the scratch coat, which took place before the storage closets
were installed. Overspray material was also observed on the trusses above the light
fixtures, where holes for electrical connections or for mounting the fixtures were open
during the spray application of the acoustical plaster.
The presence of oversprayed acoustical plaster on the trusses in the closets
could not be verified during the July 16, 1992, visual inspection because the ceiling in
the closets had been reinstalled and the ventilation panels were inaccessible because
of stored books and other materials in the closets.
1988 Perimeter Areas
Basement All-Purpose Room-lr\ the soffit in the all-purpose room (which is
accessible through access panels in the ceiling), some air-cell-paper pipe insulation
and cementitious elbows/fittings were noted. The fibrous-glass lines and cementitious
fittings appeared to be in good condition; however, the air-cell-paper insulation had
opened (unsealed) seams and had delaminated in a couple of areas. These materials
were not identified in the Asbestos Management Plan.
Kftc/)e/7--Extensive deposits of extremely friable, white, powdery material were
found inside the kitchen along the base of the exterior wall below the radiators. These
deposits are believed to be caused by efflorescence of the concrete-masonry block
and/or mortar. The white powdery material tested positive for asbestos (Table B-105).
The flooring in the kitchen was 9 in. x 9 in. asbestos-containing (15 percent chrysotile)
resilient floor tile (Table B-105). Two 15 in. by 15 in. transite hot plates were present
on the grill.
Boiler Room-As shown in Table B-105, the following asbestos-containing
materials were noted in the kitchen: 1) mud used to seal the boiler segments, 2) a
cementitious pipe elbow debris behind the hot water tank, 3) spray-on ceiling debris in
the cavity of concrete-masonry wall at the make-up air feed for the boiler, and 4) tan
paint from the boiler stack. These materials were not identified in the Asbestos
Management Plan.
270
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TABLE B-105. SUMMARY OF BULK SAMPLE RESULTS - SITE Q
1992 INSPECTION
1988 Abatement Area
1st Floor S/E classroom above closet
1st Floor S/E classroom above closet
1988 Perimeter Areas
Kitchen, floor at South wall
Kitchen, wood sink
Kitchen, south wall
Kitchen, South wall on floor
Kitchen, South wall surface
Kitchen, South wall
Kitchen, South wall
Kitchen by storage room
Kitchen by storage room
Bingo hall
Bingo haS, East wall
Bingo hail, N/E comer
Bingo hall, girls room
Bingo hall, girls room
Boiler room
Boiler room
Boiler room, beam
Boiler room, ceiling pipe entry
Boiler room, air entry
Boiler room, chimney
Boiler room, beam
Boiler room, floor
Boiler room
Construction block
t
Mortar
I
White powder
White cement spray
Blue paint/white undercoat
White efflorescence
White efflorescence
Mortar, gray cement
Concrete-masonry block
Vinyl floor tile, grey 9" x 9"
Mortar from floor trap
Floor paint, grey
Glue paint with yellow and green
Concrete-masonry block
Paint
Soft debris in floor drain
Boiler segment mud
Boiler, fiber, rock wood
Plaster/granular cement
Overspray, soft granular
--
Spray-on debris
Paint, tan
Paint and plaster
Elbow debris, hot-water heater
Mortar debris on pipe
Negative
Negative
Positive8, chrysotile asbestos
Positive, chrysotile asbestos
Positive chrysotile asbestos
Positive, chrysotile asbestos
Positive, chrysotile, asbestos
Negative
2% chrysotile asbestos
15% chrysotile asbestos
Negative
Negative
1% chrysotile asbestos
Negative
Negative
Negative
30% chrysotile asbestos
Negative
Negative
Trace", chrysotile asbestos
2% chrysotile asbestos
Positive, chrysotile asbestos
Trace, chrysotile asbestos
2% chrysotile asbestos
Negative
This classification was defined by the NJDOH laboratory to accommodate samples for which inadequate material was
available to allow a full quantitative evaluation, but were of sufficient size to determine that asbestos was present and to
determine tha specific type of asbestos. Based on the professional judgment of the analyst, the sample is considered to
contain greater than 1% asbestos.
Trace = <1 percent asbestos. i
271
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Conclusions
Several asbestos sources were identified that could have contributed to the
elevated asbestos levels measured in 1992 (and 1991). Elevated levels in the
classrooms and hallways could have been caused by disturbance of asbestos-
containing dust and/or friable asbestos-containing acoustical plaster overspray on the
steel trusses above the ceilings and vents in the classroom storage closets. Wind
could caused air to flow from the roof vents through the ducts in this passive
ventilation system and into the classrooms and hallways.
The elevated asbestos levels in the kitchen may be due to the extensive
deposits of extremely friable, white, powdery material caused by efflorescence of the
concrete-masonry block and/or mortar. Other possible contributory sources are the
transite plates and asbestos-containing resilient floor tile.
272
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SITER
Background
Site Description
The abatement project at this four-story school building involved the removal of
approximately 2900 linear feet of asbestos-containing thermal insulation, including
mixed-diameter air-cell-paper pipe insulation and hard-packed fitting insulation. The
abatement area included corridors, classrooms, offices, storage rooms, stairwells, and
recreational rooms. The project specifications indicated that the asbestos content of
the thermal surface insulation was approximately 10 to 25 percent chrysotile. The
information regarding the abated ACM and associated asbestos content was obtained
from the asbestos abatement specifications for this site.
Air Monitoring Summary
In 1988, postabatement air samples Were collected in the abatement area,
perimeter area (outside the abatement area, but inside the building), and outdoors at
approximately the same time and location as those samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Final clearance of the
abatement site was based on the samples collected by the AST. In 1990, air samples
were collected at this school by use of a modified aggressive sampling technique to
simulate occupied conditions. The samples were collected at approximately the same
locations as those collected in 1988. In 1991 and 1992, air samples were collected at
this school during occupied conditions (i.e., during normal school operating hours) at
approximately the same locations as those collected in 1988 and 1990.
Summary of Air Monitoring Results
Table B-106 summarizes the results from the four sampling efforts. Figure
B-18 shows the mean airborne asbestos concentrations at Site R. A single-factor
ANOVA was used to compare mean concentrations measured in each of the three
sampling locations. The results of the ANOVA analysis are presented in Table B-107.
The following subsections summarize the pairwise comparisons of the mean
concentrations in the three sampling locations.
Postabatement-1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have passed the
273
-------
TABLE B-106. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(S/cm3) MEASURED AT SITE R
Win
Otrtstows
Mean
""IX
Max
0.002
0.008
0.011
0.027
0.013
0.038
0.005
0.010
0.001
0.004
0.004
0.012
J 0.001 0 0.005 0.003
0.008 0.004
0.006
Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
TABLE B-107. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE R
Statistically significant differences in mean
0.3966
0.0237
0.3899
0.2505
A(0.002) P(0) OfO)
A(0)
O(0.013) PI 0.011)
A(0.005) O(0.004)
OfO.004) P(0.003) A(0.001)
a If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
b A = 1988 Abatement area; P = 1988 Perimeter area; O = Outdoors
Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
d Sampling locations (means) connected by a line are not significantly different.
274
-------
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AHERA initial screening test because the average filter concentration (11 s/mm2) was
below 70 s/mm2. Furthermore, the site would have passed the AHERA Z-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. These results are
consistent with AST sampling results.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.002 s/cm3) was not
significantly different from the average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the abatement in 1988 (0 s/cm3) was not
significantly different from the average concentration measured outdoors (0 s/cm3).
i
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.002 s/cm3) was not
significantly different from the average concentration measured in the perimeter area
(0 s/cm3).
Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0 s/cm3) was significantly less than the average
concentration measured outdoors (0.013 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area in
1990 (0.011 s/cm3) was not significantly different from the average outdoor
concentration (0.013 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0 s/cm3) was significantly less than the average
concentration measured in the perimeter area (0.011 s/cm3).
276
-------
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.005 s/cm3) was not significantly different from the
average concentration measured outdoors (0.004 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.004 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.005 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.001 s/cm3).
Occupied Conditions -1992
Comparison of the Previously Abated Area With Outdoors
i
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.004 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average concentration measured outdoors (0.004 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.003 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988,1990,1991, and 1992. Each sampling location was evaluated separately.
277
-------
Table B-108 presents the results of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990, 1991, and
1992.
TABLE B-108. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE R
'-* - location!
ITJT-.--TM. .-•". y -.-.-..- •_-[.-_-, .- •-_-_-.----•-
Statistically significant differences in mean airborne
Afe?tteH»ent area
putdbora -f
\-.-.-" "•
•f "• s AffffSp. •y.'.v. j
0.0636
0.0173
0.0391
1991(0.005) 1988(0.002) 1992(0.001) 1990(0)
1990(0.011) 1992(0.003) 1991(0.001) 1988(0)
1990(0.013) 1991(0.004) 1992(0.004) 1988(0)
a Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
0 Parenthetical entries are mean airborne asbestos concentrations (s/cnf) associated with that year's
monitoring.
d Years (means) connected by a line are not significantly different.
1.988 Abatement Area
Differences between average airborne asbestos concentrations measured
during occupied conditions in 1988, 1990, 1991, and 1992 were not statistically
significant. The highest average concentration (0.005 s/cm3) and the highest
individual concentration (0.010 s/cm3) were measured during occupied conditions in
1991,, 3 years after abatement.
Perimeter
The average airborne asbestos concentrations measured in the perimeter area
during simulated occupancy in 1990 was significantly greater than the average
concentration measured during the AHERA clearance phase of the 1988 abatement.
Other differences between average concentrations measured in 1988, 1990,1991,
and 1992 were not statistically significant. The highest average concentrations
278
-------
(0.011 s/cm3) and the highest individual concentration (0.027 s/cm3) were measured
during simulated occupancy in 1990, 2 years after the 1988 abatement.
Outdoors
The average airborne asbestos concentrations measured outdoors in 1990 was
significantly greater than the average concentration measured during the AHERA
clearance phase of the 1988 abatement. Other differences between average
concentrations measured in 1988,1990,1991, and 1992 were not statistically
significant. The highest average concentration (0.013 s/cm3) and the highest
individual concentration (0.038 s/cm3) were measured in 1990, two years after the
1988 abatement.
Structure Morphology and Size Distributions
Table B-109 presents the distribution of structure type and morphology at each
sampling location for each year of monitoring. The TEM analysis of 20 samples
collected in the abated area, 20 collected in the perimeter area, and 20 collected
outdoors yielded a total of 54 asbestos structures, all of which were chrysotile
asbestos. Overall, the asbestos structures were primarily fibers (75.9 percent), and to
a lesser extent, matrices (16.7 percent), clusters (3.7 percent), and bundles (3.7
percent).
Table B-110 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. Overall, 96.3 percent
of the observed asbestos structures were less than 5 urn in length. Of the 41
asbestos fibers observed, only 2 (4.9 percent) were greater than 5 urn in length.
NJDOH Visual Inspections
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site R as part of the State's traditional quality assurance program, which provides a
check and balance to asbestos abatement to ensure that high-quality abatement and
state-of-the art work practices are used. The onsite AST collected the AHERA
clearance air samples only after the site had passed the NJDOH visual inspection.
i
Seven visual inspections were required at this site. The site failed the first
visual inspection because of the presence of debris on top of ventilation ducts, in wall
penetrations, on horizontal surfaces, and on pipes, pipe fittings, elbows, and joints
throughout the entire containment area. Pipe insulation was also present on counters
and floor coverings. The contractor was required to reclean these areas.
279
-------
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After these areas were recleaned, NJDOH conducted a second visual
inspection. The site failed the second visual inspection because of gross debris on
ventilation ducts, pipes, pipe hangers, elbows, joints, conduit, and other horizontal
surfaces. Residual debris was also found in wall penetrations throughout the
containment area. After these areas were recleaned by the contractor, NJDOH
conducted a third visual inspection. The site failed the third visual inspection because
of debris in wall penetrations and on horizontal surfaces throughout the entire
containment area. After these areas were recleaned, NJDOH conducted a fourth
visual inspection. The site failed the fourth visual inspection because of debris behind
lockers, on pipes, on pipe joints and elbows, on tops of ventilation ducts, and on other
horizontal surfaces throughout the entire containment area. After these areas were
recleaned, NJDOH conducted a fifth visual inspection. The site failed the fifth visual
inspection because of debris on pipes, pipe elbows, and joints; on student lockers;
behind counters; and on the floor. After these areas were .recleaned by the contractor,
NJDOH conducted a sixth visual inspection. The site failed the sixth visual inspection
because of debris on ventilation ducts and fans, on floors, on pipe elbows, and on
other horizontal surfaces. After these areas were recleaned by the contractor, NJDOH
conducted a seventh visual inspection, which the site passed.
1991 Inspection
Although asbestos monitoring conducted in May 1991 found airborne levels of
asbestos within the AHERA criteria, on November 7, 1991, a NJDOH Visual Inspection
was conducted at Site R as a follow-up. 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 by the NJDOH inspector in November 1991.
1988 Abatement Areas
Corridors and Classrooms--JS\ residue (positive for chrysotile asbestos) was
collected in the Home Economics Room (Table B-111). Other such residue were
noted in the basement corridors. All abatement areas could not be assessed because
of the extensive construction activity in the abatement area classrooms. All of the
areas examined were coated with an encapsulant.
1988 Perimeter Areas
Central Basement S/70ps-No debris or material was identified.
Ramp to the Kitchen-Damaged thermal system insulation was found behind a
large grille in a wall recession that opens to the abatement area corridor. These
materials do not appear in the Asbestos Management Plan.
282
-------
TABLE B-111. SUMMARY OF BULK RESULTS - SITE R 1991 INSPECTION
I v- to^tloh^^
| Home Economics Room
£ ~$W&<& ftfatariat - -
Debris on pipe riser
""*''- Analyses , , , ' ,
Positive3, chrysotile asbestos
This classification was defined by the NJDOH laboratory to accommodate samples
for which inadequate material was available to allow a full quantitative evaluation,
but were of sufficient size to determine that asbestos was present and to determine
the specific type of asbestos. Based on the professional judgment of the analyst,
the sample is considered to contain greater than 1 percent asbestos.
Kitchen ^Areas-Thermal system insulation was noted above the suspended
ceiling system.
Conclusions
TSI debris was present on a pipe riser in the 1988 abatement area. Damaged
TSI was present in the 1988 perimeter areas. This TSI did not appear in the
Management Plan and were minor in nature.
have contributed to the acceptable air levels
The heavy use of encapsulants may
of asbestos.
283
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SITES
Background
Site Description
The abatement project at this two-story school building involved the removal of
approximately 7200 ft2 of trowel-applied, asbestos-containing acoustical ceiling plaster.
The abatement area included a gymnasium and stage, corridors, and storage areas.
The project specifications indicated that the asbestos content of the acoustical ceiling
plaster was approximately 10 to 20 percent chrysotile. The information regarding the
abated ACM and associated asbestos content was obtained from the asbestos
abatement specifications for this site.
Air Monitoring Summary
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside the abatement area, but inside the building), and outdoors at
approximately the same time and location as those samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Preabatement samples
were also collected in the perimeter area and outdoors before the 1988 abatement
activities. Final clearance of the abatement site was based on samples collected by
the AST. In 1990, air samples were collected at this school by use of a modified
aggressive sampling technique to simulate occupied conditions. The samples were
collected at approximately the same locations as those collected in 1988. In 1991 and
1992, air samples were collected during occupied conditions (i.e., during normal
school operating hours) at approximately the same locations as those collected in
1988 and 1990.
Summary of Air Monitoring Results
Table B-112 summarizes the results of the five sampling efforts. Figure B-19
shows the mean airborne asbestos concentrations at Site S. A single-factor ANOVA
was used to compare mean concentrations measured in each of the three sampling
locations. Table B-113 presents the results of the ANOVA analysis. The following
subsections summarize the pairwise comparisons of the mean concentrations in the
three sampling locations.
Preabatement -1988
The average airborne asbestos concentration measured in the perimeter area
before the abatement in 1988 (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
284
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TABLE B-112. SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE Sa
Sampling
Wit
IfoK
MB**
Owttioors- ' " ' ';' "'
Min
0.001
0.005
0.001
0.005
0.012
0.028
0.003
0.008
, •, ss
Slmtfteted wcopunpy.-
0.003
0.014
0.001
0.005
0.001
0.004
0.003
0.011
0.001
0.004
1982
0.001
0.003
0.007°
0.020
* Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
I
b Abatement area was not accessible for preabatement sampling.
c N-4.
TABLE B-113. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE S
ANOVA
Statistically significant differences In mean
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Postabatement -1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have failed the
AHERA initial screening test because the average filter concentration (82 s/mm2)
exceeded 70 s/mm2. Furthermore, the site would have failed the AHERA Z-test if the
abatement area concentrations were compared with the outdoor concentrations.
Although the site ultimately passed AHERA clearance by using the AST sampling
results, the EPA/NJDOH results clearly show that elevated levels of airborne asbestos
still existed in the school in 1988.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the abatement in 1988 (0.012 s/cm3) was not
significantly different from the average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the 1988 abatement (0.003 s/cm3) was not
significantly different from the average concentration measured outdoors (0 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the 1988 abatement (0.012 s/cm3) was not
significantly different from the average concentration measured in the perimeter areas
(0.003 s/cm3).
Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
287
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area in
1990 (0.001 s/cm3) was not significantly different from the average outdoor
concentration (0 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.001 s/cm3).
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.003 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.003 s/cm3).
Occupied Conditions -1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0 s/cm3) was significantly less than the average
concentration measured outdoors (0.007 s/cm3).
288
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.007 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.001 s/cm3).
Comparison of 1988,1990,1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988,1990,1991, and 1992. Each sampling location was evaluated separately.
Table B-114 presents the results of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988,1990,1991, and
1992.
i
TABLE B-114. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE S
Saflipfing 5"
location*
Abatement y -
area , ,
perimeter (_?
area " - *
Outdoors
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0.0779
0.6448
0.0129
_. '< •. ^ ,, •" • f :>f f,j, ^ f f f f f
Statistically significant differences In linean airborne asbestos
' -', " ~ {fcncentratoW4* * , ^ ' V
1988(0.012) 1990(0.003) 1991(0.001) 1992(0)
1988(0.003) 1991(0.003) 1990(0.001) 1992(0.001) 1988P(0.001)
1992(0.007) 1991(0.001) 1988P(0.001) 1988(0) 1990(0)
* Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b If the ANOVA p-value was-less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring.
d Years (means) connected by a line are not significantly different.
• 1988P » Preabatement; 1988 = Postabatement
289
-------
1988 Abatement Area
Differences between average airborne asbestos concentrations in the
abatement area in 1988, 1990, 1991, and 1992 were not statistically significant. The
highest average concentration (0.012 s/cm3) and the highest individual concentration
(0.028 s/cm ) were measured during the AHERA clearance phase of the 1988
abatement.
Perimeter
Differences between average airborne asbestos concentrations measured in the
perimeter area in 1988,1990,1991, and 1992 were not statistically significant. The
highest average concentration (0.003 s/cm3) and the highest individual concentration
(0.011 s/cm ) were measured during occupied conditions in 1991, 3 years after the
1988 abatement.
Outdoors
The average airborne asbestos concentration measured outdoors in 1992 was
significantly greater than the average concentration measured postabatement in 1988
and in 1990. Differences between average concentrations measured in 1988, 1990,
and 1991 were not statistically significant. The highest average concentrations
(0.007 s/cm3) and the highest individual concentration (0.020 s/cm3) were measured in
1992, four years after the 1988 abatement.
Structure Morphology and Size Distributions
Table B-115 presents the distribution of structure type and morphology at each
sampling location separately for each year of monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 42 asbestos structures, all of which were
chrysotile asbestos. Overall, the asbestos structures were primarily fibers
(71.4 percent), and to a lesser extent, clusters (16.7 percent), matrices (7.1 percent)
and bundles (4.8 percent).
Table B-116 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. Overall, 95.2 percent
of the observed asbestos structures were less than 5 jim in length. Of the 30
asbesitos fibers observed, only 1 (3.3 percent) was greater than 5 ^im in length.
290
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NJDOH Visual Inspections
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site S as part of the State's traditional quality assurance program, which provides a
check and balance to asbestos abatement to ensure that high-quality abatement and
state-of-the art work practices are used. The onsite AST collected the AHERA
clearance air samples only after the site had passed the NJDOH visual inspection.
Three visual inspections were required at this site. The site failed the first
visual inspection because of the presence of debris on floors, on electrical wires and
fixtures, behind floor moldings, behind shelving units, and behind balcony seats. After
these areas were recleaned by the abatement contractor, NJDOH conducted a second
visual inspection. The site failed the second visual inspection because of the presence
of minor debris on the tops of exits signs, skylights, and stage fixtures and dust on the
balcony floor and shelving units. After these areas were recleaned by the abatement
contractor, NJDOH conducted a third visual inspection, which the site passed.
1991 Inspection
Although asbestos monitoring conducted in May 1991 found airborne levels of
asbestos within the AHERA criteria, NJDOH conducted a visual inspection at Site S on
November 6,1991, as a followup. 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 by the NJDOH inspector in November 1991.
1988 Abatement Area
Gymnasium-The asbestos-containing ceiling plaster was removed by scraping
the material from the browncoat and then hammering the browncoat to break it loose
from the supporting wire mesh. This resulted in loose, crumbled browncoat being
trapped above the mesh. Such an approach posed a problem of how to remove the
material above the supporting wire mesh. This area was not accessible to the
workers, but it was now part of the abatement zone. The abatement contractor was
allowed to encapsulate the remaining browncoat by spraying through the mesh. In a
more conventional approach, the asbestos browncoat and wire mesh would have been
removed, which would have allowed the workers to access the upper areas to remove
all of the debris. Residue from the asbestos-containing ceiling plaster was noted on
several duct inlets (Table B-117). Crumbled browncoat plaster was noted above the
supporting wire mesh.
293
-------
Corridors--As noted for the gymnasium, browncoat plaster was noted above the
supporting wire mesh.
1988 Perimeter Areas
C/assrooms-Asbestos-containing block pipe insulation (24 percent chrysotile
asbestos) was noted in the closet overhead areas (Table B-117). This material was
not identified in the Asbestos Management Plan.
/./dra/y-Damaged thermal system insulation (elbows) was noted. This material
is not identified in the Asbestos Management Plan.
Crawl Space-Damaged cementitious elbows and joints of various
homogeneous types (4 to 19 percent chrysotile asbestos) associated with wrapped
fiberglass insulation were noted. Air-cell paper insulation matching the description of
materials located on the second floor was also noted. The crawl space and these
materials do not appear in the Asbestos Management Plan.
Boiler Room by the Gym-Large pieces of elbow debris (22 percent chrysotile
asbestos) were found behind the incinerator (Table B-117).
Conclusions
Debris from the ceiling plaster abated in 1988 was present on surfaces in the
1988 abatement area. TSI was present in the 1988 perimeter areas. This TSI did not
appear in the Management Plan.
294
-------
TABLE B-117. SUMMARY OF BULK SAMPLE RESULTS - SITE S
1991 INSPECTION
Type of Material
Analyses ,,
1988 Abatement Areas
Gym balcony
Gym SW wall
1988 Perimeter Areas
Library
Library
Classroom, middle, east
wing
Boiler room by gym
Crawl space
Crawl space
Crawl space
Crawl space
Residue on vent
Residue at ceiling wall
junction
Old ceiling tile at pipe entry
Broken joint in corner
Pipe in closet
Elbow debris
Elbow associated with
fiberglass, cloth outer wrap
Joint associated with
fiberglass, cloth outer wrap
2-in. Elbow associated with
fiberglass, paper outer wrap
2-in. Joint associated with
fiberglass, paper outer wrap
Positive81, chrysotile asbestos
Positive, chrysotile asbestos
Positive, chrysotile asbestos
Negative
24% amosite asbestos
22% chrysotile
<1% chrysotile asbestos
4% chrysotile asbestos
19% chrysotile asbestos
<1% chrysotile asbestos
a This classification was defined by the NJDOH laboratory to accommodate samples
for which inadequate material was available to allow a full quantitative evaluation,
but were of sufficient size to determine that asbestos was present and to determine
the specific type of asbestos. Based on the professional judgment of the analyst,
the sample is considered to contain greater than 1 percent asbestos.
295
-------
SITET
Background
Site Description
The abatement project at this three-story school building involved the removal
of approximately 4100 ft2 of spray-applied, asbestos-containing, acoustical ceiling
plaster. The abatement area included a cafeteria and stairwell. The project
specifications indicated that the asbestos content of the acoustical ceiling plaster was
approximately 10 to 25 percent chrysotile. The information regarding the abated ACM
and associated asbestos content was obtained from the asbestos abatement
specifications for this site.
Air Monitoring Summary
In 1988, postabatement air samples were collected in the abatement area,
perimeter area (outside the abatement area, but inside the building), and outdoors at
approximately the same time and location as those samples collected by the Asbestos
Safety Technician (AST) for the AHERA clearance of the site. Preabatement samples
were also collected in the perimeter areas and outdoors before the 1988 abatement
activities. Final clearance of the abatement site was based on the samples collected
by the AST. In 1990, air samples were collected at this school by use of a modified
aggressive sampling technique to simulate occupied conditions. The samples were
collected at approximately the same locations as those collected in 1988. In 1991 and
1992, air samples were collected at this school during occupied conditions (i.e., during
normal school operating hours) at approximately the same locations as those collected
in 1988 and 1990.
Summary of Air Monitoring Results
Table B-118 summarizes the results of the five sampling efforts. Figure B-20
shows illustrates the mean airborne asbestos concentrations at Site T. A single-factor
ANOVA was used to compare mean concentrations measured in each of the three
sampling locations. Table B-119 presents the results of the ANOVA analysis. The
following subsections summarize the pairwise comparisons of the mean concentrations
in the three sampling locations.
Preabatement -1988
The average airborne asbestos concentration measured in the perimeter area
before the 1988 abatement (0 s/cm3) was significantly less than the average
concentration measured outdoors (0.003 s/cm3).
296
-------
TABLE B-118 SUMMARY OF AIRBORNE ASBESTOS CONCENTRATIONS
(s/cm3) MEASURED AT SITE T
•l&ix
MJn
Max
0.003
0.005
0.049
0.037
0.061
0.030
0.070
0.015
0.050
0.001
0.005
0.001
0.005
0.005
0.015
0.001
0.007
0.001
0.004
0.001
0.003 0.001
0.003
* Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b Abatement area was not accessible for preabatement sampling.
TABLE B-119. SUMMARY OF ANOVA RESULTS FOR AIRBORNE
ASBESTOS CONCENTRATIONS MEASURED AT SITE T
cJlfferences in......
Simulated
Occtiptetf co
0.04
0.0720
0.2504
0.4214
0.3349
O(0.003) P(0)
A(0.049) P(0.030) O(0.015)
O(0.005) AfO.OOD P(0.001)
A(O.OOI) PfO.OOD O(0)
A(0)
O(0.001)
* If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pain/vise differences between sampling locations.
b A s 1988 Abatement area;" P = 1988 Perimeter area; O = Outdoors
0 Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that
sampling location.
d Sampling locations (means) connected by a line are not significantly different.
297
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Postabatement -1988
AHERA Clearance Test
Airborne asbestos concentrations measured by EPA/NJDOH during the AHERA
clearance phase of the 1988 abatement showed that this site would have failed the
AHERA initial screening test because the average filter concentration (321 s/mm2)
exceeded 70 s/mm2. Furthermore, the site would have failed the AHERA Z-test
regardless of whether the abatement area concentrations were compared with the
outdoor concentrations or with the perimeter concentrations. Although the site
ultimately passed AHERA clearance by using the AST sampling results, the
EPA/NJDOH results clearly show that elevated levels of airborne asbestos still existed
in the school in 1988.
Comparison of the Abatement Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the 1988 abatement (0.049 s/cm3) was not
significantly different from the average concentration measured outdoors
(0.015 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the 1988 abatement (0.030 s/cm3) was not
significantly different from the average concentration measured outdoors
(0.015 s/cm3).
Comparison of the Abatement Area With the Perimeter Area
i
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the 1988 abatement (0.049 s/cm3) was not
significantly different from the average concentration measured in the perimeter areas
(0.030 s/cm3).
Simulated Occupancy -1990
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.005 s/cm3).
299
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area in
1990 (0.001 s/cm3) was not significantly different from the average outdoor
concentration (0.005 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
2 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.001 s/cm3).
Occupied Conditions -1991
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 3
years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
3 years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.001 s/cm3).
Occupied Conditions -1992
Comparison of the Previously Abated Area With Outdoors
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
300
-------
Comparison of the Perimeter Area With Outdoors
The average airborne asbestos concentration measured in the perimeter area 4
years after the 1988 abatement (0.001 s/cm3) was not significantly different from the
average concentration measured outdoors (0.001 s/cm3).
Comparison of the Previously Abated Area With the Perimeter Area
The average airborne asbestos concentration measured in the abatement area
4 years after the 1988 abatement (0 s/cm3) was not significantly different from the
average concentration measured in the perimeter area (0.001 s/cm3).
Comparison of 1988, 1990, 1991, and 1992 Results
A single-factor ANOVA was used to compare mean concentrations measured in
1988,1990,1991, and 1992. Each sampling location was evaluated separately.
Table B-120 presents the results of the ANOVA analysis, along with the results of the
Tukey multiple comparison test. The subsections following the table summarize the
pairwise comparisons of mean concentrations measured in 1988, 1990, 1991, and
1992.
TABLE B-120. SUMMARY OF ANOVA RESULTS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED IN 1988, 1990, 1991, AND 1992 AT SITE T
locaBorf
Statistically stpfibartt differences in mean£fr£orne asbestos.
' '• * ' 1** ' '
Abatement
Perimeter
area
Outdoors
0.0001
0.0011
0.3082
1988(0.049) 1990(0.001) 1991(0.001) 1992(0)
1988(0.030) 1990(0.001) 1991(0.001) 1992(0.001) 1988P(0)
1988(0.015) 1990(0.005) 1988P(0.003) 1992(0.001) 1991(0)
* Samples were collected each year in the 1988 abatement and perimeter areas and outdoors.
b If the ANOVA p-value was less than 0.05, the Tukey multiple comparison procedure was then used
to distinguish pairwise differences between sampling locations.
c Parenthetical entries are mean airborne asbestos concentrations (s/cm3) associated with that year's
monitoring.
d Years (means) connected by a line are not significantly different.
• 1988P = Preabatement; 1988 = Postabatement.
301
-------
1988 Abatement Area
The average airborne asbestos concentration measured in the abatement area
during the AHERA clearance phase of the 1988 abatement (0.049 s/cm3) was
significantly greater than the average concentrations measured in 1990 (0.001 s/cm3),
1991 (0.001 s/cm3) , and 1992 (0 s/cm3). Differences between average airborne
asbestos concentrations measured in the abatement area in 1990,1991 and 1992
were not statistically significant. The highest average concentration (0.049 s/cm3) and
the highest individual concentration (0.061 s/cm3) were measured during the AHERA
clearance phase of the 1988 abatement.
Perimeter Area
The average airborne asbestos concentration measured in the perimeter area
during the AHERA clearance phase of the 1988 abatement (0.030 s/cm3) was
significantly greater than the average concentrations measured preabatement in 1988
(0 s/cm3), in 1990 (0.001 s/cm3), in 1991 (0.001 s/cm3), and in 1992 (0.001 s/cm3).
Differences between average airborne asbestos concentrations measured in the
abatement area preabatement in 1988, and those measured in 1990, 1991 and 1992
were not statistically significant. The highest average concentration (0.030 s/cm3) and
the highest individual concentration (0.070 s/cm3) were measured during the AHERA
clearance phase of the 1988 abatement.
Outdoors
Differences between average concentrations measured in 1988, 1990,1991,
and 1992 were not statistically significant. The highest average concentration
(0.015 s/cm3) and the highest individual concentration (0.050 s/cm3) were measured
during the AHERA clearance phase of the 1988 abatement.
Structure Morphology and Size Distributions
Table B-121 presents the distribution of structure type and morphology at each
sampling location separately for each year of monitoring. The TEM analysis of 20
samples collected in the abated area, 20 collected in the perimeter area, and 20
collected outdoors yielded a total of 127 asbestos structures, of which 99.2 percent
were chrysotile asbestos and 0.8 percent were amphibole asbestos. Overall, the
asbestos structures were primarily fibers (88.2 percent), and to a lesser extent,
matrices (11 percent), and bundles (0.8 percent).
Table B-122 presents the cumulative size distribution of asbestos samples at
each sampling location separately for each year of monitoring. All of the observed
asbestos structures were less than 5 urn in length.
302
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NJDOH Visual Inspections
1988 Inspection
The NJDOH's Environmental Health Service conducted a final visual inspection
at Site S as part of the State's traditional quality assurance program, which provides a
check and balance to asbestos abatement to ensure that high-quality abatement and
state-of-the art work practices are used. The onsite AST collected the AH ERA
clearance air samples only after the site had passed the NJDOH visual inspection.
Two visual inspections were required at this site. The site failed the first visual
inspection because of the presence of debris on floors, walls, pipes, light fixtures, wall-
ceiling junctions, and wall penetrations. After these areas were recleaned by the
abatement contractor, NJDOH conducted a second visual inspection, which the site
passed.
1991 Inspection
Although asbestos monitoring conducted in May 1991 found airborne levels of
asbestos within the AHERA criteria, NJDOH conducted a visual inspection at Site T on
October 22,1991, as a followup. 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 by the NJDOH inspector in October 1991.
1988 Abatement Areas
Cafeteria-The residual spray-on materials (positive for chrysotile asbestos)
were obtained from the ceiling and wall junction as encapsulated "bumps" along the
border of the original ceiling application (Table B-123), Loose ceiling debris was also
recovered from one pipe hanger. All the pipes in the abatement area have been
reinstated with fiberglass. This negated a thorough inspection of pipe surfaces
without removing the fiberglass. All pipe penetrations (wall and ceiling) were foamed
or caulked.
The area also has a new suspended ceiling system that isolates the original
abatement zone from the occupied space below. Numerous penetrations of the
browncoat occurred during the ceiling abatement. Air is moved through the lower,
occupied space and into the zone above the suspended ceiling via vents in the wall.
The vents lead to ducts that run throughout the facility.
305
-------
TABLE B-123. SUMMARY OF BULK SAMPLE RESULTS - SITE T
1991 INSPECTION
Type at Material
Analyses
1988 Abatement Areas
Cafeteria, west wall
Cafeteria, SE wall
Cafeteria, NW wall
1988 Perimeter Areas
Basement hall at
custodial office
Basement hall at
custodial office
2nd-Floor hall
3rd-Floor hall
3rd-Floor hall
Debris in hanger
Encapsulated residue
Encapsulated residue
Encapsulated debris at
duct
Encapsulated debris at
duct
1-ft by 1-ft Ceiling tile
1-ftby 1-ft Ceiling tile
Sheetrock above ceiling
tile
Positive3, chrysptile
asbestos
4% chrysotile asbestos
Positive, chrysotile asbestos
39% chrysotile asbestos
Positive, chrysotile asbestos
Negative
Negative
Positive, chrysotile asbestos
This classification was defined by the NJDOH laboratory to accommodate samples
for which inadequate material was available to allow a full quantitative evaluation,
but were of sufficient size to determine that asbestos was present and to determine
the specific type of asbestos. Based on the professional judgment of the analyst,
the sample is considered to contain greater than 1 percent asbestos. ,
1988 Perimeter Areas
Basement Hallway --In 1989, thermal system insulation was removed from the
pipes and ductwork in this (and other) basement areas. Encapsulated "lumps"
(positive for chrysotile asbestos) were recovered from the wall below the ductwork in
this area. The tops of the ducts and the pipe penetrations had been heavily sealed
with expanding foam and caulk. Although the use of foam and caulk-type sealants is
not a preferred practice, this practice does require that the resilient ACM be managed
under an O&M Plan. Pipes had been reinsulated with fiberglass and could not be
inspected without the removal of these materials.
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Perimeter Comcfo/s~The first and second-floor corridors have asbestos-
containing resilient floor tile and 1-ft by 1-ft interlock ceiling tiles that are assumed to
be asbestos. According to the Asbestos Management Plan, these are nonfriable
miscellaneous materials, in some areas, the ceiling tiles are bowed from water or
other damage and are friable. The plenum area above the 1-ft by 1-ft suspended
ceiling system is not accounted for in the Management Plan. Visual access to the
plenum is limited to holes (damaged areas) in the ceiling system. Ductwork (white-
grey fiber type) and corrugated pipe insulation with solid joints and elbows were
observed. These materials are not identified in the Asbestos Management Plan.
Boiler Room Vertical Shafts-Pipe insulation was in the shafts that rise from the
boiler area. These materials are not mentioned in the Asbestos Management Plan.
Gymnasium-Pipe insulation was noted above the suspended ceiling system in
the gym. It could be seen from a hole in the wall of the basement corridor. This
material is not mentioned in the Asbestos Management Plan.
Third Floor Comcfor-Sheetrock above the suspended ceiling system tested
positive for chrysotile asbestos. This material does not appear in the Asbestos
Management Plan.
Conclusions
The Asbestos Management Plan was not updated regarding the 1989
abatement.
The Asbestos Management Plan noted nine rooms that had not been inspected
during the original AHERA inspection. The Plan does not state whether these areas
were ever inspected in accordance with the AHERA requirements.
Although debris and residual materials were recovered from the areas
inspected, the use of suspended ceilings isolating the abatement zone, the heavy use
of encapsulants, foam and sealant, and the use of fiberglass retrofit materials, have
resulted in acceptable levels. This, however, does not eliminate the potential for
future disturbances through operations and maintenance activities.
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