EPA/60Q/R-97/063
October1997
EVALUATION OF THE IMPLEMENTATION OF OPERATIONS AND
MAINTENANCE PROGRAMS IN NEW JERSEY SCHOOLS
by
John R. Kominsky, Ronald W. Freyberg
Environmental Quality Management, Inc.
Cincinnati, Ohio 45240
EPA Contract No. 68-D2-0058
and
Donald R. Gerber, Gary J. Centifonti
Environmental Health Services
New Jersey Department of Health
Trenton, New Jersey 08625
EPA Cooperative Agreement No. CR-821955-01
Project Officer
Aaron R. Martin
Stationary Source Compliance Division
U.S. Environmental Protection Agency
Washington, D.C. 20460
Technical Project Officer
Alva Edwards
Sustainable Technologies Division
National Risk Management Research Laboratory
Cincinnati, Ohio 45268
NATIONAL RISK MANAGEMENT RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
Printed on Recycled Paper
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DISCLAIMER
The U.S. Environmental Protection Agency through its Office of Research and
Development partially funded and collaborated in the research described here under
Contract 68-D2-0058 to Pacific Environmental Services, Inc. (under Subcontract No.
SSCD-92-01 to Environmental Quality Management, Inc.) and under Cooperative
Agreement No. CR-821955-01 to the New Jersey Department of Health-Environmental
Health Services. It has been subjected to the Agency's peer and administrative review
and 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
The U.S. Environmental Protection Agency 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 compatiable
balance between human activities and the ability of natural systems to support and
nuture life. To meet this mandate, EPA's research program is providing data and
technical support for solving environmental problems today and building a science
knowledge base necessary to manage our ecological resources wisely, understand
how polluntants affect our health, and prevent or reduce environmental risks in the
future.
The National Risk Management Research Laboratory is the Agency's center for
investigation of technilogical and management approaches for reducing risks from
threats to human health and the environment. The focus of the Laboratory's research
program is on the methods for the prevention and control of pollution to air, land, water,
and subsurface resources; protection of water quality in public water systems;
remediation of contaminated sites and ground water; and prevention and control of
indoor air pollution. The goal of this research effort is to catalyze development and
implementation of innovative, cost-effective environmental technologies; develop
scientific and engineering information needed by EPA to support regulatory and policy
decisions; and provide technical support and information transfer to ensure effective
implementation of environmental regulations and strategies.
This publication has been produced as part of the Laboratory's strategic long-term
research plan. It is published and made available by EPA's Office of Research and
Development to assist the user community and link researchers with their clients.
E. Timothy Oppelt, Director
National Risk Management Research Laboratory
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ABSTRACT
The Asbestos Hazard Emergency Response Act (AHERA) requires all schools to develop
and implement an Asbestos Management Plan (AMP). The U.S. Environmental Protection
Agency (EPA) has also published guidance regarding the in-place management of asbestos-
containing materials (ACM). The key component of the AMP is the operations and maintenance
(O&M) program. An O&M program is an administrative framework that prescribes specific
activities and work procedures to control activities that may disturb AGM and respond to any
uncontrolled release of asbestos fibers. A well-developed O&M program is ineffective unless it is
implemented properly. The O&M program's success is contingent upon the commitment of all
personnel involved in conscientiously implementing O&M program elements and conducting
O&M activities.
A study was conducted to evaluate the implementation of asbestos O&M programs at 10
sites representing 8 New Jersey schools. The evaluation included aspects required by AHERA
as well as those recommended in EPA guidance. Each school's O&M program and compliance
with their program during past O&M activities were documented. In addition, 10 ongoing O&M
activities were documented to determine the impact of the activities on airborne asbestos levels
and to determine compliance with the O&M program during these activities. Airborne asbestos
levels were measured by using transmission electron microscopy (TEM) before and during each
activity. Personal breathing zone exposures to total fibers were measured by using phase
contrast microscopy (PCM) during each activity for comparison with the Occupational Safety and
Health Administration (OSHA) Permissible Exposure Limit (PEL) of 0.1 f/cm3, 8-hour time-
weighted average.
Overall, the schools were not completely implementing all the elements of the asbestos
O&M program as outlined in AHERA or in EPA guidance. Schools performed more O&M
program elements required by AHERA than those recommended in EPA guidance. The
percentage of performance responses given by the schools indicating that the elements of the
O&M program were performed (52.5%) was higher than those provided by the worker or
contractor performing the activity (35% and 22.5%, respectively). Elements of the O&M program
were not performed or they were not communicated to the worker or contractor. Significant
increases in area airborne asbestos levels (determined by TEM) were observed during 5 of the
10 activities. None of the total fiber levels measured using PCM, however, exceeded the OSHA
PEL. This study underscores the importance of a thorough O&M program and the effective
communication and implementation of all program elements.
Environmental Quality Management, Inc., and the New Jersey Department of Health
submitted this document to the U.S. Environmental Protection Agency's Office of Research and
Development, National Risk Management Research Laboratory, in partial fulfillment of Contract
No. 68-D2-0058 and Cooperative Agreement No. CR-821955-01, respectively. The report covers
the period of April 30, 1995 through November 27, 1995 and work was completed as of
November 27,1995.
IV
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CONTENTS
Disclaimer
Foreword
Abstract
Figures
Tables
Acknowledgments
1. Introduction
Background
Objectives
2. Conclusions and Recommendations
Conclusions
Recommendations
3. Study Design and Methods
Site Selection
Evaluation of O&M Programs
Impact of O&M Activities on Airborne Asbestos Levels
Sampling Methods
Analytical Methods
Statistical Methods
4. Quality Assurance
Sample Chain of Custody
Sample Analysis
5. Results and Discussion
Site Descriptions
Assessment of O&M Programs
Impact of O&M Activities on Airborne Asbestos Levels
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iii
iv
vii
viii
ix
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29
References
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CONTENTS (continued)
Appendices
A NJDOH-EHS Site Evaluation/Assessment Documentation Form
B
Individual Estimates of Airborne Asbestos Concentrations
Measured Before and During O&M Activities
VI
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FIGURES
Number
1
3
4
5
6
7
8
9
10
11
12
Title
Percent total performance of program elements required
byAHERA
Percent total performance of program elements recommended
in EPA guidance
Percent total performance of all program elements
Average percentage of performance response for all sites by
category and parts for the O&M program elements
Average percentage of performance response for all sites by
parts and category for the O&M program elements
Average percentage of performance response for all sites by
category and Part 3 individual school, worker, and
contractor response to O&M program elements
Average percentage of performance response for all sites by
element and part for all O&M program elements
Average airborne asbestos concentrations before and during
wet-stripping of resilient floor tile at Site A
Average airborne asbestos concentrations before and during
renovation at Site C
Average airborne asbestos concentrations before and during
changing filters and vacuuming air handling unit at Site F.,
Average airborne asbestos concentrations before and during
installation of smoke detector wiring at Site F2
Average airborne asbestos concentrations before and during
installation of a fire alarm system at Site H
21
22
23
24
26
28
31
35
36
37
38
39
VII
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TABLES
Number Title
1 Data summary for replicate analyses
2 Data summary for duplicate analyses
3 Characteristics of study sites and O&M activities evaluated
4 Percentage of performance responses for program elements
5 Percentage of performance responses for Part 3 with
individual school, worker, and contractor responses
6 Average performance responses for all sites by element
and part (all elements category)
7 Summary statistics for airborne asbestos concentrations
measured by TEM before and during each O&M activity
8 Summary of ANOVA comparisons
9 Distribution of asbestos structure type and morphology
before and during O&M activities
10 Cumulative size distribution of asbestos structures measured
before and during O&M activities
11 8-hour TWA total fiber concentrations (as determined by PCM)
during O&M activities
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20
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45
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VIII
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ACKNOWLEDGMENTS
This document was prepared for EPA's Office of Research and Development.
Aaron R. Martin served as the EPA Project Officer, and Alva Edwards served as the
EPA Work Assignment Manager. Also acknowledged are Patrick J. CJark of EPA's
National Risk Management Research Laboratory (NRMRL) Transmission Electron
Microscopy (TEM) Laboratory, and Kim Brackett, Ph.D., Cory Demaris, and Eugenia S.
Shtrom of IT Corporation contractor staff of NRMRL's TEM Laboratory for conducting
the analyses of the air and bulk samples. The technical guidance and administrative
efforts of Bruce A. Hollett and Roger C. Wilmoth of EPA's NRMRL are also greatly
appreciated. The field portion of this study was conducted by Chad Replogle, Gavin
Smith, and John R. Kominsky of Environmental Quality Management, Inc., and Edward
Millerick, Gary J. Centifonti, and Donald R. Gerber of the Environmental Health
Services of the New Jersey Department of Health (EHS-NJDOH). The authors
acknowledge Cynthia Mitchell of the EHS-NJDOH for providing technical assistance in
finalizing the Site Evaluation and Documentation Form. The authors acknowledge Kim
A. McClellan of EPA's NRMRL for conducting the Quality Assurance review of the
report. The authors also acknowledge George T. Moore, Ph.D. and Robert Jordan,
Ph.D. of EPA, and James A. Brownlee and Richard M. Ritota of the EHS-NJDOH for
conducting a technical review of this study report, and Barbara Ore, Environmental
Quality Management, Inc., for typing this report.
This document was written by John R. Kominsky and Ronald W. Freyberg of
Environmental Quality Management, Inc., and Donald R. Gerber and Gary J. Centifonti
of the Environmental Health Services, New Jersey Department of Health.
IX
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SECTION 1
INTRODUCTION
Background
The concern about asbestos-containing materials (ACM) in buildings started in
the late 1970s in the United States. In 1978 the U.S. Environmental Protection Agency
(EPA) issued a two-volume guidance document to schools for identification and
evaluation of in-place asbestos.1 Subsequently, three additional guidance documents
were issued by the EPA in 1983, 1985, and 1990.2'3'4
Although removal was encouraged over alternative approaches of asbestos
management in the past, in-place management and operations and maintenance
(O&M) programs are currently viewed by the EPA as the most appropriate overall
strategy for management of asbestos in buildings.4 In-place management involves the
use of building O&M work practices and control measures that minimize the release of
airborne fibers from ACM, thereby reducing exposures and associated risks to workers
and other building occupants.
Operations and maintenance programs must be prepared and implemented
whenever friable ACM is present or assumed to be present in school buildings.5 An
O&M program is a program of work practices and training to maintain friable ACM in
good condition, ensure cleanup of asbestos fibers previously released, and prevent
future release by minimizing and controlling friable ACM disturbance during installation,
repair, maintenance, and cleaning activities. A well-developed O&M program is
ineffective unless it is implemented properly. The O&M program's success is
contingent upon the commitment of all personnel involved in developing,
conscientiously implementing, and conducting O&M activities.
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Although these O&M programs have been prepared for schools, no
representative field studies have been conducted to evaluate the implementation and
effectiveness of these programs in controlling the release of asbestos fibers into a
building. The purpose of this study was to evaluate the implementation of O&M
programs in selected schools in New Jersey.
Objectives
The objectives of this study were as follows:
1) Document and assess each school's O&M program and other related
components in the Asbestos Management Plan.
2) Document and assess each school's compliance with their O&M program
during previously conducted O&M activities.
3) Observe and document the conduct of selected O&M activities involving
ACM or in the vicinity of ACM.
4) Determine the impact of selected O&M activities on airborne asbestos
levels.
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SECTION 2
CONCLUSIONS AND RECOMMENDATIONS
Conclusions
The following are the principal conclusions reached during this study:
1. Overall, schools were not completely implementing all the elements of the
O&M program within the Asbestos Management Plan as outlined in
' AH ERA or in EPA guidance documents. The O&M programs ranged in
overall comprehensiveness from 45.9 percent to 83.8 percent with an
average of 70.6 percent.
2. School Designated Persons may not be aware of all program elements in
the Asbestos Management Plan. The overall percentage of performance
responses given by the school officials during the observed O&M activities
was 52.5 percent. The school maintenance worker indicated a
performance response of only 35 percent, while the outside contractor
indicated an even lower performance of 22.5 percent. All elements were
not implemented and/or communicated by the school's designated
person. Additionally, all program elements were not performed by the
workers/contractors conducting the O&M activity.
3. Schools implemented more required items in accordance with AHERA
than those additional program elements outlined in EPA guidance
documents. The percentage of performance responses was highest in
the management elements of AHERA and EPA guidance. The elements
indicating implementation items such as notification to workers/
contractors, work permit system, and work practices for the O&M activities
had the least percentage of performance responses.
4. O&M activities were performed in the vicinity of ACM without causing
elevated airborne asbestos levels. When O&M activities disturbed or
were conducted on ACM, however, airborne asbestos levels were
significantly elevated and exceeded 0.02 asbestos structure/cm3 (School
Sites A, C, and H).
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5. The estimated 8-hour TWA of total fiber concentrations (0.005 f/cm3
maximum) in the breathing zone of the individual performing the O&M
activities (as determined by phase contrast microscopy) did not exceed
the OSHA Permissible Exposure Limit of 0.1 f/cm3, 8-hour TWA.
Recommendations
1. EPA cooperatively with State Agencies need to provide further outreach
and education to all responsible parties such as Local Education
Agencies, and AHERA Designated Persons as well as the schools' O&M
staff, consultants, and contractors to enhance their understanding of the
intent and requirements of the O&M aspects of AHERA. Thorough
regulatory oversight is necessary to ensure compliance within the
requirements of AHERA.
2. A training program for designated persons should be developed that
provides an understanding and working knowledge of AHERA, O&M
program elements, the Asbestos Management Plan information, and
effective implementation of an O&M program.
3. Schools should implement controls to ensure that workers (school
employees and outside contractors) who may disturb ACM or perform an
activity in the vicinity of ACM are notified as to its location and are aware
of the potential for disturbance of ACM. Additionally, each school must
enhance programs to ensure that O&M staff receive and are properly
trained in handling ACM.
4. Areas of the building that have undergone an 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.
5. Further research is recommended to evaluate the long-term impact of
O&M activities on the release of asbestos structures in the building
environment. This information would assist EPA in defining the need for
and nature of guidance on asbestos O&M activities.
6. Schools should ensure that workers performing maintenance procedures
on asbestos-containing resilient floor tile are informed of the potential for
elevated airborne asbestos levels as measured during this and four other
EPA studies.
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SECTION 3
STUDY DESIGN AND METHODS
Site Selection
The Environmental Health Services - New Jersey Department of Health (EHS-
NJDOH) distributed an "O&M Activities Survey Form" to 26 candidate schools
representing 14 different school districts that planned to perform O&M activities
involving asbestos-containing materials (ACM) or activities in the vicinity of ACM during
the summer of 1994. This form solicited information regarding three types of O&M
activities: (1) Operations (custodial/service); (2) Maintenance (heating, ventilation, and
air-conditioning, plumbing, electrical/communications, fire protection, and other building
systems or components); (3) and Renovation (general space modifications, ceiling tile
replacement, carpet removal, and roofing repair).
Eight schools, representing 10 distinct O&M activities, were selected based on
the type of planned activity and the schedule for conducting the planned activity. The
number of schools and activities selected for this study do not represent a statistical
sample. The results obtained from the different schools studied were used to
document the implementation of the O&M programs at these schools and to identify
common factors that may influence airborne asbestos levels during O&M activities on or
near ACM.
Evaluation of O&M Programs
A "Site Evaluation/Assessment Documentation Form" was used to standardize
the evaluation of each school's O&M Program (Appendix A). To prevent any ambiguity
regarding the questions or recording of the responses, the form was administered by
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EHS-NJDOH representative who were thoroughly instructed on the basis of each
question, as well as its application to the various parts of the evaluation (i.e., Parts 1, 2,
and 3 as described below). To ensure data consistency the same persons completed
the Site Evaluation/Assessment Documentation Form.
Each school's O&M program evaluation included three primary parts. Part 1
involved a review of each school's O&M program and other related components in the
Asbestos Management Plan (AMP) on file with the New Jersey Department of Health
(NJDOH) to determine the overall comprehensiveness of the O&M program.* Part 2
involved an on-site interview with the school's AH ERA Designated Person to assess
each school's compliance with their O&M program during previously conducted O&M
activities.** Part 3 involved interviewing the school's AHERA Designated Person and
observing and interviewing the worker (school employee or contractor) performing an
O&M actual activity.
Part 1 - Each school's Asbestos Management Plan, which was on file with the
EHS-NJDOH, was evaluated by an EPA-accredited Inspector/Management Planner
prior to initiating the planned activity. The Inspector/Management Planner completed
the Site Assessment/Documentation Form during the review of the school's O&M
program.
The evaluation included the program elements required by AHERA as well as
those elements recommended by EPA in issued guidance.1"4 Hence, the evaluation
was based on three categories of program elements: those program elements required
by AHERA; those program elements recommended in EPA guidance documents; and
An Asbestos Management Plan is a document that each Local Education Agency (LEA) "School"
is required to prepare under the AHERA. It describes all activities planned and undertaken by a
school to comply with AHERA regulations, such as building inspections to identify asbestos-
containing materials, response actions, and operations and maintenance programs to minimize
the risk of exposure to asbestos in school buildings.
A designated person is the person designated by the LEA to ensure that the AHERA requirements
are properly implemented. AHERA established the framework for a regulation which requires,
among other things, that elementary and secondary schools identify asbestos-containing
materials in school buildings, institute programs aimed at minimizing the risk of asbestos
exposure in those buildings, and reinspect those materials at least every three years.
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all of the program elements (i.e., those required by AHERA and those recommended in
EPA-issued guidance). A "Site Evaluation/Assessment Documentation Form" was
used to standardize the evaluation of the respective O&M programs (Appendix A).
Each school's O&M Program was evaluated regarding the following elements:
Comprehensiveness: The program should be developed by a qualified
Asbestos Management Planner and implemented by a qualified Asbestos
Program Manager/Designated Person following a comprehensive building
inspection to identify and assess the condition of all ACM in the building.
The written O&M Program should be site-specific and take into account
function and building design. The program should address specific
activities and procedures related to use, cleaning, maintenance, repairs,
equipment service, and fiber release episodes.
• Administration/Awareness: The written Asbestos Management Plan
should be available at the school and updated to keep it current with
ongoing O&M, periodic surveillance, inspection, reinspection, and
response action activities. Additionally, maintenance and custodial
personnel must be made aware and have reviewed the Asbestos
Management Plan and O&M Program prior to conducting activities.
• Notification: AHERA requires that workers (school employees and
contract workers), tenants, and building occupants be notified where ACM
is located, and how and why to avoid disturbing the ACM. All persons
affected should be properly informed.
• Surveillance: AHERA requires regular 6-month ACM surveillance and 3-
year reinspections to note, assess, and document any changes in the
condition of the ACM.
• Controls: The program should include a work control/permit system to
control activities that might disturb ACM.
Work Practices: The program should describe O&M work practices to
avoid or minimize fiber release during activities affecting ACM.
• Recordkeeping: AHERA requires specific documentation of O&M
activities.
• Worker Protection: AHERA requires medical and respiratory protection
programs, as applicable.
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Training: AHERA requires proper training of custodial and maintenance
staff who may deal with activities involving ACM.
Part 2 - Information regarding previously conducted O&M activities at the school
was obtained by interviewing each school's designated person using the "Site
Evaluation/Assessment Documentation Form" (Appendix A). This information included
the type and location of the O&M activity, the date of the activity, whether key elements
of the O&M program were followed, etc. This information was used to assess the
school's perception of compliance with their O&M program during previously conducted
O&M activities.
Part 3 - Selected O&M activities involving ACM, or in the vicinity of ACM, were
observed and documented at each school by using the Site Evaluation/Assessment
Documentation Form (Appendix A). The school's AHERA Designated Person was
observed and interviewed. In addition, the school employee or contract worker
performing the O&M activity was also interviewed regarding use of the elements (e.g.,
work practices and procedures) specified in the school's O&M program. This
information was used to determine the extent of actual compliance with their O&M
program during the activity.
impact of O&M Activities on Airborne Asbestos Levels
The impact of the selected O&M activities on the exposure of custodial workers,
maintenance workers, and/or building occupants was evaluated by air monitoring for
asbestos structures and total fibers. Characterization of the ACM or source of asbestos
structures potentially involved in the O&M activity or near the O&M activity was
determined by collecting bulk samples of the material(s).
Air Samples
Five fixed-station area air samples were collected in the immediate area of the
O&M activity both before and during the activity. These samples were collected under
static conditions (i.e., without intentional disturbance of the air beyond that attributable
to general occupant activity or the O&M activity itself). Two field blanks (one open and
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one closed) were also collected during each sampling period for each O&M activity as a
quality assurance check for filter contamination.
In addition to the fixed-station area air samples, three personal breathing zone
samples (i.e., the sampling cassette was placed in the breathing zone of the worker
performing the O&M activity) were also collected, when feasible. Two of the three
samples were collected for analysis by TEM. The third personal breathing zone sample
was collected for analysis by PCM to compare the results to the Occupational Safety
and Health Administration (OSHA) PEL of 0.1 f/cm3, 8-hour time-weighted average.
One open field blank was collected as a quality assurance check for each O&M activity
for filter contamination.
Bulk Samples
Bulk samples of in-place material were collected to characterize the asbestos
content of the ACM (e.g., fireproofing, thermal system insulation, resilient floor tile,
plaster) or other sources of asbestos fibers (e.g., debris) potentially involved in the O&M
activity.
Sampling Methods
Fixed-Station Area Air Samples
The fixed-station area air samples were collected on open-face,
25-mm-diameter, 0.45-um poresize, mixed cellulose ester (MCE) filters with a 5-urn
poresize MCE diffusing filter and cellulose support pad contained in a three-piece
cassette. The labeled filter cassettes were positioned on tripods approximately 5 feet
above the floor with the filter face at a 45-degree angle toward the floor. The filter
assembly was attached to an electric-powered (1-10 VAC) 1/6-horsepower vacuum
pump operating at a flowrate of approximately 9 liters per minute. At the end of the
sampling period, the filters were turned upright before being disconnected from the
vacuum pump and then were stored in this position until they were analyzed by the
laboratory.
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The sampling pumps were calibrated with a precision rotameter (Manostat Model
36-546-215) both before and after sampling. The precision rotameter is a secondary
standard; hence, it was calibrated with a primary airflow standard (i.e., a Gilian
Gilibrator) both immediately before and after the study.
Personal Breathing Zone Samples
One personal breathing zone air sample was collected on an open-face,
25-mm-diameter, 0.8-um poresize MCE membrane filter and cellulose support pad
contained in a three-piece cassette with a 50-mm conductive extension cowl. This
sample was collected in accordance with NIOSH Method 7400 for analysis by PCM for
comparison to the OSHA PEL. Two additional personal breathing zone air samples
were collected on open-faced, 25-mm-diameter, 0.45-um poresize MCE filters with a 5-
um poresize MCE diffusing filter and a cellulose support pad contained in a three-piece
cassette. These two samples were collected for analysis by TEM.
The three labeled filter cassettes were positioned in the breathing zone of the
individual performing the O&M activity. Each filter was attached to approximately 50
feet of Tygon tubing that was attached to an electric-powered (110 VAC) 1/6-
horsepower vacuum pump operating at a flowrate of approximately 9 L/min. Traditional
battery-powered, personal sampling pumps could not be used because of their limited
airflow rates (approximately 2 L/min with the 0.45-um poresize MCE filter with a 5-um
poresize MCE diffusing filter and a cellulose support pad contained in a three-piece
cassette).
The sampling pumps were calibrated with a precision rotameter (Manostat Model
36-546-215) both before and after sampling. The precision rotameter is a secondary
standard; hence, it was calibrated with a primary airflow standard (i.e., a Gilian
Gilibrator) both immediately before and after the study.
Bulk Samples
The bulk samples of in-place material (e.g., fireproofing, thermal system
insulation, plaster, and resilient floor tile) were collected by using a standard coring tool
or chipping tool. Other sources of asbestos fibers (e.g., debris) were either collected by
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hand or collected using a spatula and brush. All samples were then placed in a labeled
sample storage container; The exact location of the sample was recorded on a plan
drawing of the building.
Analytical Methods
Area Air Samples
The 0.45-um poresize MCE filters were prepared and analyzed in accordance
with the nonmandatory TEM method specified in the AHERA Final Rule (October 30,
1987; 52 CFR 4826). In addition to the requirements of the AHERA nonmandatory
TEM method, the specific length and width of each structure were measured and
recorded. A sufficient number of grid openings were analyzed to ensure a sensitivity
(the concentration represented by the finding of a single structure) of no greater than
0.005 asbestos structure per cubic centimeter of air sampled, unless the degree of
loading made this impractical. On heavily loaded samples, counting stopped after
completion of the grid square in which the 100th asbestos structure was found.
Personal Breathing Zone Samples
Each of the 0.8-um poresize MCE membrane filters used to collect the personal
breathing zone samples were analyzed by PCM. These samples were prepared and
analyzed according to the NIOSH 7400 protocol (Revision 3, June 5, 1989, National
Institute for Occupational Safety and Health Manual of Analytical Methods). All fibers >
5 /u.m in length and with an aspect ratio of > 3:1 were counted using the "A" counting
rules. The analytical sensitivity was approximately 0.01 fiber per cubic centimeter of air
sampled.
Bulk Samples
The type and percentage of asbestos in bulk samples was determined by
polarized light microscopy (PLM) and X-ray diffraction (XRD) in accordance with the
"Interim Method for Determination of Asbestos in Bulk Samples" (EPA-600/M4-82-020).
Statistical Methods
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Airborne asbestos concentrations measured before and during each O&M
activity 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. A one-factor analysis of variance (ANOVA) was used
to examine overall differences between baseline concentrations, area air
concentrations measured during the O&M activity, and personal breathing zone
concentrations measured during the activity. 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. The Tukey multiple comparison procedure was used to distinguish pain/vise
differences between mean concentrations. All statistical comparisons were conducted
at the 0.05 level of significance.
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SECTION 4
QUALITY ASSURANCE
Sample Chain of Custody
During the study, sample chain-of-custody procedures were an integral part of
both the sampling and analytical activities and were followed for all air and bulk
samples collected. The field custody procedures documented each sample from the
time of its collection until its receipt by the analytical laboratory. Internal laboratory
records then documented the custody of the sample through its final disposition.
Standard sample chain-of-custody procedures were used. Each air and bulk
sample was labeled with a unique project identification number, which was recorded on
a sample data sheet along with other information (as appropriate), such as sampling
date, location of the sample, 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, NRMRL 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
13
-------
100 MCE filters showed a background contamination level of 0 asbestos structure 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. Ten
grid openings were examined on each filter.
A total of 19 0.45-um open field blanks and 18 0.45-um closed field blanks were
collected and analyzed by TEM; no asbestos structures were detected on any of the
field blanks. A total of nine 0.8-um open field blanks were collected and analyzed by
PCM; no fibers were observed on any of the nine open field blanks.
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 nine 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 did 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 1.
A duplicate sample analysis of four 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 2.
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 CVs associated with the replicate
14
-------
and duplicate analyses were 20 and 28 percent, respectively. These CVs are
consistent with the range of CVs observed in past EPA asbestos research studies.
TABLE 1. DATA SUMMARY FOR REPLICATE ANALYSES3
Sample number
A-01-D1-P-02
D-01-D1-P-01
E-01-B-05
F-01-B-02
F-02-B-04
G-01-B-01
G-02-B-01
H-01-B-05
H-01-F1-05
Original analysis
N"
107
1
0
0
0
0
0
0
0
s/cm3
3.579
0.004
<0.005
O.004
O.005
<0.004
<0.004
O.004
O.004
Replicate analysis
Nb
115
1
1
0
0
1
0
0
0
s/cm3
3.846
0.004
0.004
O.004
<0.005
0.004
<0.004
<0.004
<0.004
a A second analysis of the same grid performed by the same microscopist as the original analysis.
b Number of asbestos structures.
TABLE 2. DATA SUMMARY FOR DUPLICATE ANALYSES8
Sample number
D-01-D1-01
F-02-D1-P-02
G-02-D1-01
H-01-F1-04
Original analysis
Nb
0
2
2
0
s/cm3
O.004
0.010
0.008
<0.004
Duplicate analysis
Nb
0
1
3
0
s/cm3
<0.004
0.005
0.012
<0.004
8 A second TEM grid preparation was analyzed by the same microscopist.
b Number of asbestos structures.
15
-------
SECTION 5
RESULTS AND DISCUSSION
Site Descriptions
Eight schools representing seven school districts were surveyed during this
study. All eight of these schools have participated in past asbestos-related studies
conducted cooperatively by EPA and EHS-NJDOH. A total of 10 O&M activities were
evaluated at these 8 schools; 2 activities were evaluated at 2 of the schools (Sites F
and G) and 1 activity was evaluated at each of the other 6 schools. A summary matrix
of each study site and the O&M activity evaluated is presented in Table 3.
Assessment of O&M Programs
. The evaluation of the data for each school's O&M program was grouped into
three categories: AHERA Elements, including those program elements required by
AH ERA; Guidance Elements, including those program elements recommended in EPA-
issued guidance; and All Elements, including all of the program elements (i.e., the first
two categories combined). Each school's O&M program evaluation was also divided
into three primary parts: Part 1 (AMP) which included the information contained in the
school's AHERA AMP filed with the EHS-NJDOH; Part 2 (previous O&M activities),
which included the previously conducted O&M activities information obtained by
interviewing each school's AHERA Designated Person; and Part 3 (observed O&M
activities), which included the information obtained by direct observation of O&M
activities.
16
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Comparisons By Category
Table 4 and Figures 1 through 3 summarize the individual performance
responses for each site by part and category. Figure 4 presents the average
percentage of performance response for all sites by part and category. The responses
to questions on the Site Assessment/Documentation Form are termed "performance
responses" in this report. A "yes" indicates an affirmative response to the respective
question, as well as indicates that the particular activity or function had been
accomplished. For example, a "yes" response to Question C.1 "Surveillance" would
indicate that the 6-month periodic surveillance had been conducted.
AHERA Elements - Overall, the performance responses were highest for
elements required by AHERA. The AMP performance responses ranged from 69.6 to
95.7 percent with an average of 88.3 percent. At 7 of 10 sites, the AMP indicated
greater than 90 percent performance response. Only one site's AMP had less than 70
percent performance response. It should be noted that for the evaluation of the
information required by AHERA in the AMP, it is possible to have less than 100 percent
performance for the purpose of this study. Some O&M program elements could not be
verified because they would not be performed until a future date, i.e., a date beyond the
time when the AMP was reviewed by the EHS-NJDOH inspector. In previous O&M
activities, performance responses in 8 of 10 sites were less than noted in the AMP. In
the observed O&M activities, performance responses in all sites were less than those
documented in the AMP and averaged 58.9 percent.
Guidance Elements - Overall, in all three parts, the performance responses
noted in this category were the lowest. The AMP performance responses ranged from
7.1 to 71.4 percent with an average of 41.4 percent. At 8 of 10 sites, the AMP indicated
less than 70 percent performance response. The lower responses could be attributed
to some of the guidance information (particularly the "Green Book"4) not being available
when the AMPs were prepared in 1987 to 1989. The performance responses averaged
only slightly higher in previous O&M activities (54.1 percent) and during the observed
O&M activities (44.0 percent). Although all of the guidance was
19
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available for approximately five years prior to this evaluation, the most recent EPA
guidance (the "Green Book") is not geared specifically toward schools, but for buildings
in general. Hence, the schools may not be aware of the guidance or may choose not to
implement the guidance recommendations since it's not a regulatory requirement.
All Elements - A comparison of the data contained in the AMP, with the
performance responses from previous O&M activities and a comparison with the
observed O&M activities suggest a trend in decreasing percentage of performance
responses. The AMP documented an average performance response of 70.6 percent,
whereas the school stated that it performed 57.6 percent of the O&M elements during
previous O&M activities, and performed 49.2 percent of the elements during the
observed O&M activity. In the observed O&M activities, performance responses in 8 of
10 sites were less than those noted in the asbestos management plan.
Comparisons by Part
Table 4 summarizes the individual performance responses for each site by part
and category. Figure 5 presents the average percentage of performance response for
all sites by part and category.
Part 1 - At all sites, the individual percentage of AHERA element performance
responses was higher than those recommended in EPA Guidance elements. The
number of sites with performance responses less than 70 percent was only 1 of 10 for
AHERA elements and 8 of 10 for Guidance elements. The average performance
response for AHERA elements (88.3 percent) was 53.1 percent higher than the average
performance response for Guidance elements (41.4 percent).
Part 2 - The average performance response for Guidance elements (54.1
percent) was 9.8 percent lower than the average performance response for AHERA
elements (60.0 percent). All three categories had 6 of 10 sites with performance
responses less than 70 percent.
Part 3 - The average performance response for Guidance elements (44.0
percent) was 25.3 percent lower than the average performance response for AHERA
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elements (60.0 percent). All three categories had 6 of 10 sites with performance
responses less than 70 percent.
Part 3 - The average performance response for Guidance elements (44.0
percent) was 25.3 percent lower than the average performance response for
AHERA elements (58.9 percent). Both the AHERA elements and Guidance
elements categories had 7 of 10 sites with performance responses less than 70
percent.
Comparisons of School, Worker, and Contractor Performance Responses
Further evaluation was made to compare the performance responses of the
school officials to those of the persons actually performing the observed O&M
activity. Both the school Designated Person and the school maintenance worker or
the outside contractor performing the activity where asked specific questions
regarding the observed O&M activities. Table 5 summarizes the responses for
these specific questions for the "All Elements" and "AHERA Elements" categories.
The performance response for "All Elements" indicated by the school Designated
Person was 52.5 percent, whereas the performance response indicated by the
school maintenance worker was 35 percent. The outside contractor indicated that
22.5 percent of the O&M elements were performed. Figure 6 shows approximately
a 33.3 percent decrease in the performance response from the school Designated
Person to the school maintenance worker. Similarly, a 57.1 percent decrease in the
performance response from the school Designated Person to the outside contractor
was observed. This also reflects a 35.7 percent decrease in performance response
from the school maintenance worker to the outside contractor. The performance
responses for "AHERA Elements" were very similar as was the trend of decreasing
performance responses from the school Designated Person to the school
maintenance worker and the outside contractor.
27
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TABLE 5. PERCENTAGE OF PERFORMANCE RESPONSES FOR PART 3
FROM INDIVIDUAL SCHOOL, WORKER, AND CONTRACTOR RESPONSES
Elements
All Elements
AH ERA Elements
Percentage of Performance Res
School Designated
Person
52.5
60.0
School Worker
35.0
37.5
ponses
Contractor
22.5
25.0
Comparisons by Program Elements
Table 6 and Figure 7 present the performance responses to the individual
program elements for both the AHERA-required and EPA-recommended elements
by Parts 1, 2, and 3. Generally, decreases in performance responses for each
element are noted from the elements documented in the AMP (Part 1), to previous
O&M activities (Part 2), and to what was actually observed during the O&M activity
(Part 3). An overall average was calculated across all sites for each program
element. When the AMP is evaluated according to the "All Elements" category,
surveillance, recordkeeping, and training had the highest percentage of
performance responses. Other program elements scored less, with all being less
than 80 percent. Work practices and work permit system program elements scored
the lowest, with 57.5 percent and 38.9 percent, respectively.
28
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Impact of O&M Activities on Airborne Asbestos Levels
JEM Air Monitoring Results
Table 7 presents the summary statistics for the airborne asbestos
concentrations measured before and during each O&M activity at each site.
Individual sample results of airborne asbestos concentrations are presented in
Appendix B. A one-way ANOVA was used to compare airborne asbestos
concentrations measured before each activity to area and personal breathing zone
concentrations measured during the activity at each site. Table 8 summarizes the
results of these comparisons for each O&M activity. Some O&M activities were
performed in the vicinity of ACM without causing elevated airborne asbestos levels.
Five of 10 activities (Sites A, C, F.,, F2, and H) showed significant increases in
airborne asbestos concentrations during the associated O&M activity when
compared to baseline measurements (Figures 8-12). Another study, conducted
over a 4 year period, concluded that O&M activities that disturbed ACM (including
thermal system insulation and plaster, and resilient floor tile) may have contributed
to elevated airborne asbestos levels at several of the sites.6
Additionally, when O&M activities disturbed ACM in the vicinity or were
conducted on ACM, airborne asbestos levels were elevated at or above 0.02 s/cm3
in 4 of 10 sites (A, C, F1( and H). The 0.02 s/cm3 criterion was derived from the
AHERA clearance criterion of 70 s/mm2 (CFR 763). In schools with mean airborne
asbestos concentrations greater or equal to 0.02 s/cm2 the NJDOH required that a
response action to be taken by the school to lower the asbestos levels below 0.02
s/cm2. An EPA-certified Building Inspector/Management Planner from the EHS-
NJDOH performed a visual inspection of the affected areas to assist the school in
locating any potential sources of asbestos contamination. These areas were then
cleaned by the school and air monitoring was conducted to demonstrate that the
airborne asbestos concentrations were below 0.02 s/cm2. The follow-up air samples
were analyzed by EPA.
30
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TABLE 6. AVERAGE PERFORMANCE RESPONSES FOR ALL SITES BY
ELEMENT AND PART (ALL ELEMENTS CATEGORY)
Program Elements
Administration
Notification
Surveillance
Work Control/Permit System
Work Practices
Recordkeeping
Personal Protective Equipment
Training
Totals
Parts
r
72.3
76.7
100
38.9
57.5
97.5
70.0
90.0
70.6
2b
66.4
30.0
75.0
45.6
44.0
70.0
50.0
65.0
57.6
3C
68.0
35.0
38.9
33.3
75.0
80.0
45.0
492
Part 1 involved a review of each school's Asbestos Management Plan.
Part 2 involved an interview with the school's AHERA Designated Person
regarding previous O&M activities.
Part 3 involved information from the school's AHERA Designated Person and
the individual performing the observed O&M activity.
31
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TABLE 7. SUMMARY STATISTICS FOR AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED BY TEM BEFORE AND
DURING EACH O&M ACTIVITY
Sample Type
N
Airborne Asbestos Concentration, s/cm3
Arithmetic
Mean
Geometric
Mean
Minimum
Maximum
Site A - Wet-Stripping of Resilient Floor Tile
Baseline
During (Area)
During (Personal)
5
5
2
0.003
3.948
3.305
0.002
3.91
3.29
<0.004
3.30
3.03
O.004
4.84
3.58
Site B - Vacuuming Interior of Boilers
Baseline
During (Area)
During (Personal)
5
5
1
0.004
0.008
0.002
0.003
0.006
0.002
<0.004
<0.005
O.004
0.009
0.021
<0.004
Site C - Space Modification
Baseline
During (Area)
5
8
0.004
0.026
0.003
0.020
O.003
<0.004
0.008 .
0.050
Site D - Vacuuming Air Handling Unit
Baseline
During (Area)
During (Personal)
5
5
3
0.002
0.003
0.003
0.002
0.003
0.003
<0.004
<0.004
<0.004
0.004
0.004
0.004
Site E - Carpet Removal
Baseline
During (Area)3
5
5
0.003
-
0.001
-
<0.005
-
0.005
-
Site F1 - Changing Filters & Vacuuming Air Handling Unit
Baseline
During (Area)
During (Personal)
5
5
2
0.005
0.011
0.042
0.003
0.007
0.042
<0.004
<0.005
0.038
0.013
0.024
0.046
(continued)
33
-------
TABLET (continued)
Sample Type
N
Airborne Asbestos Concentration, s/cm3
Arithmetic
Mean
Geometric
Mean
Minimum
Maximum
Site F2 - Installation of Smoke Detector Wiring
Baseline
During (Area)
During (Personal)
5
5
2
0.002
0.003
0.008
0.003
0.003
0.009
. <0.004
O.005
0.005
0.005 -
<0.005
0.010
Site G1 - Ceiling Tile Removal\Replacement
Baseline
During (Area)
During (Personal)
5
5
2
0.012
0.004
0.006
0.007
0.004
0.006
<0.004
0.004
0.004
0.039
0.008
0.008
Site G2 - Installation of Flexible Conduit Above Suspended Ceiling
Baseline
During (Area)
During (Personal)
5
5
2
0.006
0.011
0.014
0.004
0.009
0.008
O.004
<0.004
<0.005
0.013
0.023
0.026
Site H - Installation of Fire Alarm System
Baseline
During (Area)
During (Personal)
5
5
2
0.003
0.056
0.145
0.003
0.053
0.120
<0.004
0.030
0.064
0.004
0.076
0.226
Samples collected during the O&M activity at Site E were too heavily loaded to
count.
(continued)
34
-------
TABLE 8. SUMMARY OF ANOVA COMPARISONS
Site - Activity
Site A -
Site 6 -
Site C -
Site D -
Site F! -
Site F2 -
Site G1 -
Site G2 -
Site H -
Wet-stripping of resilient floor tile
Vacuuming interior of boilers
Space modification
Vacuuming air handling unit
Changing filter and vacuuming air
handling unit
Installation of smoke detector wiring
Ceiling tile removal replacement
Installation of flexible electrical
conduit above suspended ceiling
Installation of fire alarm system
ANOVA
p-value
0.0001
0.3627
0.0102
0.4889
0.0254
0.0059
0.5192
0.5650
0.0001
Tukey pairwise comparisons3'"'0
6(0.002) DP(3.29} DA(3.91}
DP(0.002} 8(0.003} DA(nnflfi)
6(0.003) DA(0.020)
8(0.002} DA(o.oos) npfn ma)
8(0.003} DA(0.007} DP(0.042)
DA(0.003} 8(0.003} DP(0.009)
DA(0.004} DP(0.006} B(f) nf)7)
8(0.004} DAC0.009) DP(0.008}
6(0.003) DA(0.053} DPfQ.12D)
8 = 8aseline; DA = Area samples during the activity; DP = Personal samples during the
activity.
Parenthetical entries are geometric average airborne asbestos concentrations (s/cm3).
Geometric average concentrations connected by a line are not significantly different.
35
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The airborne asbestos levels measured during wet-stripping of the resilient
floor tile were three orders of magnitude higher than the levels measured during the
other O&M activities. These elevated levels during wet-stripping of resilient floor tile
are consistent with those levels measured during other studies involving the same
floor care maintenance practice.7-8 Additionally, a study previously conducted on the
spray-buffing of resilient floor tile demonstrated that this common maintenance
procedure increased airborne asbestos concentrations at the majority of the study
sites.9
In general, persona! breathing zone concentrations tended to be slightly
higher than area concentrations during the activities. This difference, however, was
statistically significant during only one activity. The higher concentrations of
asbestos measured by the personal breathing zone samples than the
concentrations measured by the fixed-station area samples at Site F2 are most likely
attributable to differences in the proximity of the sampling cassettes to the source of
the asbestos release; i.e.. the O&M activity.
Asbestos Structure Size and Morphology Distributions
Table 9 summarizes the asbestos structure type and morphology
distributions for samples collected before and during each O&M activity. All of the
asbestos structures observed were chrysotile asbestos. Overall, the asbestos
structures were primarily fibers (63.0 percent) and, to a lesser extent, bundles (19.5
percent), matrices.
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(15.8 percent), and clusters (1.7 percent). The highest percentage of fibers was
noted during wet-stripping of resilient floor tile (70.9 percent).
Table 10 presents the cumulative size distribution for the asbestos structures
observed on samples collected before and during each O&M activity.
Approximately 94 percent of the asbestos structures observed were less than or
equal to 5 urn in length; approximately 45 percent were less than 1 urn in length.
PCM Air Monitoring Results
Table 11 presents the individual total fiber concentrations, along with the 8-
hour TWA concentrations for the personal breathing zone samples collected during
each O&M activity. The 8-hour TWA concentrations were calculated by assuming
zero exposure beyond that which was measured during the activity. That is, the 8-
hour TWA concentration was calculated by multiplying the sample duration
(minutes) by the measured concentration (f/cm3) and dividing the result by 480
minutes. None of the calculated 8-hour TWA concentrations exceeded the OSHA
PEL of 0.1 f/cm3, 8-hour TWA.
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49
-------
I
REFERENCES
1. U.S. Environmental Protection Agency. Sprayed Asbestos-Containing
Materials in Buildings: A Guidance Document, Part 1. EPA-450/2-78-014.
1978. ("Orange Book")
2. U.S. Environmental Protection Agency. Guidance for Controlling Friable
Asbestos-Containing Materials in Buildings. EPA 560/5-83-002. 1983.
("Blue Book")
3. U.S. Environmental Protection Agency. Guidance for Controlling Asbestos-
Containing Materials in Buildings. EPA 560/5-85-024. 1985. ("Purple
Book")
4. U.S. Environmental Protection Agency. Managing Asbestos in Place: A
Building Owner's Guide to Operations and Maintenance Programs for
Asbestos-Containing Materials. EPA 20T 2003. 1990. ("Green Book")
5. U.S. Environmental Protection Agency. Asbestos-Containing Materials in
Schools; Final Rule and Notice. 40 CFR Part 763. Federal Register,
October 30, 1987.
6. Kominsky, J. R., R. W. Freyberg, C. S. Hubert, J. A. Brownlee, D. R. Gerber,
G. J. Centifonti, and R. W. Ritota. An Evaluation of Asbestos Management
Programs in 17 New Jersey Schools: A Case Studies Report. U.S.
Environmental Protection Agency, EPA/600/SR-94/084, August 1994.
7. Kominsky, J. R., R. W. Freyberg, and J. M. Boiano. Airborne Asbestos
Concentrations During Buffing, Burnishing, and Stripping of Resilient Floor
Tile. U.S. Environmental Protection Agency, EPA/600/SR-95/121, August
1995.
8. U.S. Environmental Protection Agency. Evaluation of Asbestos Fiber
Release During Maintenance of Asbestos-Containing Floor Tile. EPA 747-R-
93-005. Office of Pollution Prevention and Toxics, Washington, D.C. March
1993.
50
-------
9. Kominsky, J. R., R. W. Freyberg, J. A. Brownlee, D. R. Gerber, and G. J.
Centifonti. Airborne Asbestos Concentrations During Spray-Buffing of
Resilient Floor Tile in New Jersey Schools. U.S. Environmental Protection
Agency. EPA/600/SR-93/159. October 1993.
51
-------
r
APPENDIX A
NJDOH-EHS SITE EVALUATION/ASSESSMENT
DOCUMENTATION FORM
52
-------
NJDOH/EPA SITE EVALUATION/ASSESSMENT DOCUMENTATION FORM
Implementation of O&M Programs in NJ Schools
I. GENERAL INFORMATION
A. Building Data
1. Location Number:
2. Facility/Location:
Building:
Case Number:
Building ID No.
3. Building Information
Address:
City:
State:
Zip:
County:
County Code:
Contact 1:
Contact 2:
Title 1:
Phone 1:
Title 2:
Phone 2:
4. Asbestos Program Manager ( ) / Designated Person ( )
Name: Affiliation:
Address:
City:
State:
Zip:
Phone:
5. Building Owner
Name:
Address:
City:
State:
Zip:
County:
County Code:
Contact 1:
Contact 2:
Title 1:
Phone 1:
Title 2:
Phone 2:
53
-------
A. Building Data (continued)
6. Management Planner (MP)/lnspector
Original MP-Firm:
3-Year Reinspection-Firm:
Current Consultant-Firm:
7. Comments:
Date:
_ Date:
Date:
8. Hours of Normal Building Occupancy:
9. Directions: .
B. Documentation Data
Date(s) Performed:
Performed By:
Building:
NJDOH/EP
A
Form Completed
By:
Parti
NA
Part 2
PartS
Note: Part 1 - Document and assess school's O&M program and other related components in the Asbestos
Management Plan (NJDOH: In-house).
Part 2: - Document and assess school's compliance with their O&M program during previously conducted
O&M activities (on-site).
Part 3 - Observe and document the conduct of selected O&M activities covered under their O&M program
(on-site).
54
-------
II. BUILDING DESCRIPTION INFORMATION
1. Building Use(s):
2. Year Constructed:
3. Occupancy - Limit:
4. Total Square Feet:
5. Comments:
III. SITE INFORMATION
1. Location(s) of Building:
2. Use of Area(s):
A. In-house Review - O&M /M.P.
1. Abatement (Y/N):
a. Type of ACM1:
b. Approx. Amt. (s.f./l.f.):
c. Location of ACM (pipes,
walls, etc.):
d. Abatement Type2:.
e. Date(s) for Completion:
2. ACM in Area(s)
a. Type of ACM1:
b. Approx. Amt. (s.f./l.f.):
c. Location of ACM (pipes,
walls, etc.):
d. Condition of ACM3:
3. Comments:
Date(s) of Addition/Major Renovations:
Normal Use: Special Use:
No. of Floors: No. of Rooms:
Area A
AreaB
55
-------
Area A
AreaB
B. On-Site Eval./Assess.
1. Previous Abatement (Y/N)
a. Type of ACM1:
b. Approx. Amt. (s.f./l.f.):
c. Location of ACM (pipes,
walls, etc.):
d. Abatement Type2:
e. Date(s) Completed:
f. NJDOH Visual Inspection
(Y/N):
2. ACMinArea(s)
a. Type of ACM1:
b. Approx. Amt. (s.f./l.f.):
c. Location of ACM (pipes,
walls, etc.):
d. Condition of ACM3:
3. Comments:
IV. SITE O&M ACTIVITY INFORMATION
1. Location(s) in Building:
2. Use of Area(s):
A. Past O&M Activities
1. Activity4:
2. Activity-
a. On ACM (O):
b. In Vicinity of ACM (V):
3. Location(s) in Area:
4. Date(s) Performed:
Area A
Area B
56
-------
Area A
AreaB
5. Performed By—
a. Employee (E):
b. Contractor (C):
Name:
Contact:
Phone:
B. Current O&M Activities
1. Activity4:
2. Activity—
a. On ACM (O):
b. In Vicinity of ACM (V):
3. Date(s) - Start:
Finish:
4. Performed By—
a. Employee(s):
b. Contractor(s):
Name:
Contact:
Phone:
Employee:
5. Time of Activity
a. Day (D)/ Evening (E):
b. Time(s):
6. Length of Activity Per
Day (hrs):
C. Miscellaneous Notes:
57
-------
r
V. Asbestos Operations & Maintenance Program
Program Elements
A. Administration/Awareness
1, Designated Person (DP) / Asbestos Program
Manager (APM)
a. Is a DP or APM listed and actively
employed?
b. Has the DP/APM received training?
c, Is the plan referenced by the DP/APM
before any O&M work is performed?
2, Is the Plan available at the school for review
and access? (V)
3: Is the Plan updated periodically to reflect O&M
activities or abatements? (V)
4 Is the Plan referenced by workers before
performing an O&M activity?
5 Do workers know the locations and availability
of the Plan?
6, Has an O&M Program been implemented?
7, Is the O&M Program followed?
8 Are O&M staff and building occupants aware of
who is the DP/APM? (V)
9 Are response actions carried out and
documented within the time frame outlined in
the MP?
B. Notification
1, Has written notification of the availability of the
MP been provided to affected parties on a
yearly basis?
2. Is written notification provided to outside
contractors performing work at the school? (V)
3. Are warning labels posted in routine
maintenance areas? (V)
C. Surveillance
1, Have 6-month periodic surveillances been
conducted?
Parti
School's O&M /
Management Plan
(In-house Review)
Part 2
School's Compliance
with Plan
(On-site)
Parts
Document O&M Activity
(On-site)
N/A
X
58
-------
Program Elements
2. Has the MP been updated with the 6-month
surveillance information? (V)
3. Have 3-year reinspections been conducted? (V)
4. Has the information from the 3-yr reinspection
been incorporated into the MP? (V)
5. Does the MP identify or assume ACM to be
present in the vicinity of the selected activity?
6. For reinspections, did the reinspector: visually
reinspect and reassess the condition of all
friable known or assumed ACM?
D. WORK CONTROLS/PERMIT SYSTEM
1 . Does the O&M Program contain a work
control/permit system? (V)
2. Is the work control/permit system documented
in the O&M Program?
3. Does the DP/APM physically inspect the area in
which work is to be performed to ensure
records reflect actual conditions?
4. Is the work performed by outside contractors
reviewed by the DP/APM to determine the
presence of ACM where the work is to be
performed?
5. Is the "person requesting the work required to
submit a Work Request to the DP/APM? (V)
6. Upon receiving the Work Request, does the
DP/APM do the following:
a. Determine whether 'ACM is present in
the area where work will occur?
b. If ACM is present and will likely be
disturbed, does the DP/APM visit the
site to determine what work practices
should be initiated to minimize the
release of asbestos fibers during the
maintenance activity?
c. If the task is not covered by previously
approved standard work practices, does
the DP/APM make sure that the
appropriate work practices and
protective measures are used for the
job?
d. Does the DP/APM inspect the site after
work is performed?
Parti
School's O&M /
Management Plan
(In-house Review)
Yes
•
•
No
•
•
N/A
X
•
•
Part 2
School's Compliance
with Plan
(On-site)
Yes
No
N/A
Parts
Document O&M Activity
(On-site)
Yes
No
-
-
-
-
-
iiy.
HP
•i™*Ti i
HHBalS ,, '
ffe*^-
i*si»i*tsia*
;„,.,.-.,, ..,-
N/A
X
*
X
X
X
1
• -*
(V) On-Site Verification denotes that responses to the questions followed by a "V" are to be verified on-site by the interviewer.
oy
-------
Program Elements
E. WORK PRACTICES
1, Have specific work practices been developed
and utilized for activities (See Code 4)? (V)
2; Do specific work practices contain step-by-step
procedures for conducting the activity?
3, Has cleaning been performed prior to all
response actions conducted?
4, Were the specific procedures in the O&M
Program followed?
5, Have specific work practices been developed
for fiber release episodes?
F. RECORDKEEPING
1 Are records maintained in a centralized location
at the school? (V)
2, Was each custodial/maintenance person
required to receive training, trained? (V)
3, Is each periodic surveillance documented? (V)
4. Is each O&M activity documented?
G. WORKER PROTECTION
1 Is a written worker protection program outlined
as part of the O&M Program? (V)
2. For the activities monitored (Code 4), were the
proper worker protection items used?
H. TRAINING
1. Was awareness training provided for
custodians involved in cleaning and simple
maintenance tasks where ACM may accidently
be disturbed? (V)
2, Was special O&M training provided for
maintenance workers involved in general
maintenance and incidental ACM repair tasks?
(V)
Parti
School's O&M /
Management Plan
(In-house Review)
Part 2
School's Compliance
with Plan
(On-site)
Parts
Document O&M Activity
(On-site)
X
X
(V) On-Site Verification denotes that responses to the questions followed by a 'V are to be verified on-site by the interviewer.
-------
CODES
1 ACM Types
PB = Preformed block (thermal system insulation)
AC = Air cell (thermal system insulation)
LP = Layered paper (thermal system insulation)
CEM = cementitious insulation (thermal system insulation)
BD = Asbestos board (thermal system insulation)
AP = Acoustical plaster (surfacing material)
FP = Fireproofing (surfacing material)
CT = Ceiling Tile (miscellaneous material)
FT = Floor tile (miscellaneous material)
TR = Transite (miscellaneous material)
PAP = Paper-like material (miscellaneous material)
Other (describe)
2 Abatement Type
REM = Removal
REP = Repair
ENCP = Encapsulation
ENCL = Enclosure
3 Condition of ACM
P = Poor
F = Fair
G = Good
E = Excellent
61
-------
* Activities
I. OPERATIONS (CUSTODIAL/SERVICE) ACTIVITIES
1. Dry-dusting/sweeping/mopping of asbestos-containing floor tile.
2. Spray-buffing asbestos-containing floor tile.
3. Stripping/refinishing asbestos-containing floor tile.
4. Dry burnishing asbestos-containing floor tile.
5. Carpet vacuuming.
6. Carpet cleaning (wet-vacuuming).
7. Dry-dusting/sweeping/mopping of surfaces and floors.
8. Maintenance/installation/cleaning of draperies, shades, or other window treatments.
9. Other
II. MAINTENANCE ACTIVITIES
A. HVAC
1.
3.
4.
5.
6.
Repair/maintenance of mechanical equipment (e.g., boilers, air-handling units, heat exchangers, tanks)
in utility spaces.
Adjustment/repair/maintenance of HVAC systems (e.g., ductwork, variable air volume boxes, mixing
boxes, dampers, pneumatic controls).
Air filter replacement/cleaning of grills, diffusers, or registers.
Repair/replacement of pipe or duct insulation.
Valve or gasket replacement.
Other.
B. PLUMBING
1.
2.
3.
4.
Installation/removal/modification of piping or equipment (e.g., domestic hot and cold water lines, roof
drains, storage tanks, water pumps).
Repair/replacement of plumbing system components.
Repair/replacement of pipe insulation.
Other.
62
-------
C. ELECTRICAL/COMMUNICATIONS
1. Connections and/or extensions for electrical systems (e.g., installing conduit, electrical boxes).
2. Repair/replacement of lighting/electrical fixtures.
3. Installation/modification of telecommunications or computer network (e.g., pulling cable).
4. Other.
D. FIRE PROTECTION
1. Installation/repair of sprinkler system components.
2. Installation of smoke or heat detection equipment.
3. Testing/cleaning/repair/replacement of smoke or heat detection equipment.
4. Other.
E. OTHER BUILDING SYSTEMS
1. Repair/replacement of asbestos-containing floor tile.
2. Other.
III. RENOVATION ACTIVITIES
1. Carpet removal.
2. Ceiling tile installation/repair/replacement.
3. General space modification-repair/replacement of walls, ceilings, and plaster (e.g., installing
demolishing partitions).
4. Repair/replacement of roofing materials.
5. Other.
63
-------
APPENDIX B
INDIVIDUAL ESTIMATES OF AIRBORNE ASBESTOS
CONCENTRATIONS MEASURED BEFORE AND
DURING OPERATION AND MAINTENANCE ACTIVITIES
64
-------
APPENDIX B. INDIVIDUAL ESTIMATES OF AIRBORNE ASBESTOS CONCENTRATIONS
MEASURED BEFORE AND DURING OPERATION AND MAINTENANCE ACTIVITIES
Site
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
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
Date
Sampled
08/01/94
08/01/94
08/01/94
08/01/94
08/01/94
08/01/94
08/01/94
08/02/94
08/02/94
08/02/94
08/02/94
08/02/94
08/02/94
08/02/94
08/02/94
08/02/94
08/02/94
08/15/94
08/15/94
08/15/94
08/15/94
08/15/94
08/15/94
08/15/94
08/15/94
08/15/94
08/25/94
08/25/94
08/25/94
08/25/94
08/25/94
08/25/94
08/25/94
08/25/94
08/25/94
08/02/94
08/02/94
08/02/94
08/02/94
08/02/94
08/02/94
08/02/94
08/03/94
08/03/94
08/03/94
08/03/94
Sample Number
A-01-B-01
A-01-B-02
A-01-B-03
A-01-B-04
A-01-B-05
A-01-B-OB1
A-01-B-CB1
A-01-D1-01
A-01-D1-02
A-01-D1-03
A-01-D1-04
A-01-D1-05
A-01-D1-P-01
A-01-D1-P-02
A-01-D1-P-02R3
A-01-D1-OB1
A-01-D1-CB1
HUNJ01
HUNJ02
.HUNJ03
HUNJ04
HUNJ05
HUNJ06
HUNJ07
HUNJ08
HUNJ09
RHUNJ01
RHUNJ02
RHUNJ03
RHUNJ04
RHUNJ05
RHUNJ09
RHUNJ06
RHUNJ07
RHUNJ08
B-01-B-01
B-01-B-02
B-01-B-03
B-01-B-04
B-01-B-05
B-01-B-OB1
B-01-B-CB1
B-01-D1-01
B-01-D1-02
B-01-D1-03
B-01-D1-04
Sample Type
Baseline
Baseline
Baseline
Baseline
Baseline
Open Field Blank
Closed Field Blank
During - Area
During - Area
During - Area
During - Area
During - Area
During - Personal
During - Personal
During - Personal
Open Field Blank
Closed Field Blank
Followup
Followup
Followup
Followup
Followup
Closed Field Blank
Open Field Blank
Open Field Blank
Followup
Followup
Followup
Followup
Followup
Followup
Followup
Open Field Blank
Closed Field Blank
Closed Field Blank
Baseline
Baseline
Baseline
Baseline
Baseline
Open Field Blank
Closed Field Blank
During - Area
During - Area
During - Area
During - Area
Air
Volume, L
1350
1407
1365
1375
1385
0
0
1321
1385
1439
1403
1431
1348
1279
1279
0
0
1203
1131
1203
1131
1218
0
0
0
1160
1247
1164
1140
1176
1247
1140
0
0
0
1224
1143
1160
1144
1218
0
0
420
358
368
363
Concentration
s/cm3 s/mm2
0.004 <13.9
O.004 <13.9
<0.004 <13.9
<0.004 <13.9
<0.004 <13.9
<13.9
<13.9
3.562 12222
3.768 13556
3.300 12333
4.269 15556
4.843 18000
3.031 10611
3.579 11889
3.846 12778
<11.1
<13.9
0.053 166.7
0.059 172.8
0.071 222.2
0.059 172.8
0.044 138.9
<13.9
<13.9
<13.9
0.229 691.4
<0.004 <13.9
<0.004 <12.3
O.004 <12.3
O.004 <12.3
O.004 <13.9
<0.005 <13.9
<13.9
<13.9
<13.9
<0.004 <13.9
0.004 <12.3
O.004 <12.3
0.009 27.8
0.004 13.9
<11.1
<11.1
0.010 11.1
O.005 <4.6
0.005 4.6
O.005 <4.6
(continued)
65
-------
APPENDIX B (continued)
B
B
B
B
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
D
D
D
E
E
E
E
E
E
E
E
Date
Site Sampled Sample Number Sample Type
08/03/94
08/03/94
08/03/94
08/03/94
05/15/92°
05/15/92°
05/15/92°
05/15/92"
05/15/92°
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/04/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
08/05/94
B-01-D1-05
B-01-D1-P-02
B-01-D1-OB1
B-01-D1-CB1
C-01-B-01
C-01-B-02
C-01-B-03
C-01-B-04
C-01-B-05
C-01-D1-01
C-01-D1-02
C-01-D1-03
C-01-D1-04
C-01-D1-05
C-01-D1-06
C-01-D1-07
C-01-D1-08
C-01-D1-OB1
C-01-D1-CB1
D-01-B-01
D-01-B-02
D-01-B-03
D-01-B-06
D-01-B-07
D-01-B-OB1
D-01-B-CB1
D-01-D1-01
D-01-D1-01D"
D-01-D1-02
D-01-D1-03
D-01-D1-04
D-01-D1-05
D-01-D1-P-01
D-01-D1-P-01R
D-01-D1-P-02
D-01-D1-P-03
D-01-D1-OB1
D-01-D1-OB2
D-01-D1-CB1
E-01-B-01
E-01-B-02
E-01-B-03
E-01-B-04
E-01-B-05
E-01-B-05R
E-01-B-OB1
E-01-B-CB1
During - Area
During - Personal
Open Field Blank
Closed Field Blank
Baseline
Baseline
Baseline
Baseline
Baseline
During - Area
During - Area
During - Area
During - Area
During - Area
During - Area
During - Area
During - Area
Open Field Blank
Closed Field Blank
Baseline
Baseline
Baseline
Baseline
Baseline
Open Field Blank
Closed Field Blank
During - Area
During - Area
During - Area
During - Area
During - Area
During - Area
During - Personal
During - Personal
During - Personal
During - Personal
Open Field Blank
Open Field Blank
Closed Field Blank
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
Open Field Blank
Closed Field Blank
Air Concentration
Volume, L s/cm3 s/mm2
343
284
0
0
-
-
-
-
-
934
932
911
911
945
896
938
923
0
0
1226
1241
1314
1213
1213
0
0
1267
1267
1263
1184
1198
1232
1222
1222
750
496
0
0
0
1330
1311
1269
1218
1293
1293
0
0
0.021 18.5
<0.004 <3.1
<13.9
<13.9
O.003 -
0.008 -
O.003 -
0.006 -
0.003 -
0.014 33.3
0.041 100.0
0.038 90.9
0.017 40.4
0.050 122.2
0.009 20.2
<0.004 <10.1
0.034 80.8
<11.1
<11.1
0.004 13.9
O.004 <13.9
<0.004 <13.9
O.004 <13.9
O.004 <13.9
<13.9
<13.9
<0.004 <13.9
<0.004 <13.9
<0.004 <13.9
0.004 12.3
<0.004 <12.3
0.004 13.9
0.004 13.9
0.004 13.9
0.004 7.9
<0.004 <5.6
<13.9
<13.9
<13.9
<0.005 <15.9
O.005 <15.9
0.005 15.9
O.005 <15.9
O.005 <15.9
0.004 13.9
<13.9
<13.9
(continued)
66
-------
APPENDIX B (continued)
Date Air Concentration
Site Sampled Sample Number Sample Type Volume L s/cm3 s/mm2
E
E
E
E
E
E
E
FI
FI
F,
F,
FI
F1
FI
FI
F1
F,
FI
F!
F,
F1
F,
FI
F,
F2
F2
F2
F2
F2
F2
F2
F2
F2
F2
F2
F2
F2
F2
F2
F2
F2
F2
GI
G,
G,
G,
G,
08/08/94
08/08/94
08/08/94
08/08/94
08/08/94
08/08/94
08/08/94
08/08/94
08/08/94
08/08/94
08/08/94
08/08/94
08/08/94
08/08/94
08/08/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
08/09/94
E-01-D1-01
E-01-D1-02
E-01-D1-03
E-01-D1-04
E-01-D1-05
E-01-D1-OB1
E-01-D1-CB1
F-01-B-01
F-01-B-02
F-01-B-02R
F-01-B-03
F-01-B-04
F-01-B-05
F-01-B-OB1
F-01-B-CB1
F-01-D1-01
F-01-D1-02
F-01-D1-03
F-01-D1-04
F-01-D1-05
F-01-D1-P-01
F-01-D1-P-02
F-01-D1-OB1
F-01-D1-CB1
F-02-B-01
F-02-B-02
F-02-B-03
F-02-B-04
F-02-B-04R
F-02-B-05
F-02-B-OB1
F-02-B-CB1
F-02-D1-01
F-02-D1-02
F-02-D1-03
F-02-D1-04
F-02-D1-05
F-02-D1-P-01
F-02-D1-P-02
F-02-D1-P-02D
F-02-D1-OB1
F-02-D1-CB1
G-01-B-01
G-01-B-01R
G-01-B-02
G-01-B-03
G-01-B-04
During - Area
During - Area
During - Area
During - Area
During - Area
Open Field Blank
Closed Field Blank
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
Open Field Blank
Closed Field Blank
During - Area
During - Area
During - Area
During - Area
During - Area
During - Personal
During - Personal
Open Field Blank
Closed Field Blank
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
Open Field Blank
Closed Field Blank
During - Area
During - Area
During - Area
During - Area
During - Area
During - Personal
During - Personal
During - Personal
Open Field Blank
Closed Field Blank
Baseline
Baseline
Baseline
Baseline
Baseline
880
809
810
781
762
0
0
1243
1228
1228
1253
1276 .
1236
0
0
934
987
1033
1025
955
829
825
0
0
914
919
881
908
908
811
0
0
740
758
699
697
716
656
664
664
0
0
1369
1369
1194
1336
1410
<13.9
<13.9
0.013 41.7
O.004 <13.9
<0.004 <13.9
0.004 13.9
O.004 <13.9
<0.004 <13.9
<13.9
<13.9
O.005 <12.3
0.024 61.7
0.018 49.4
0.009 24.7
<0.005 <12.3
0.046 98.8
0.038 80.8
<13.9
<13.9
<0.004 <10.1
O.005 <11.1
O.004 <10.1
O.005 <11.1
<0.005 <11.1
0.005 10.1
<13.9
<13.9
O.005 <9.3
<0.005 <9.3
O.005 <8.5
O.005 <8.5
O.005 <8.5
0.005 8.5
0.010 17.1
0.005 8.5
<13.9
<13.9
<0.004 <13.9
0.004 13.9
0.004 12.3
0.008 27.8
0.009 31.7
(continued)
67
-------
APPENDIX B (continued)
Date
Site Sampled Sample Number Sample Type
G,
1
G,
1
G,
v^1
G,
i
G,
1
G,
1
G,
V1
G,
1
G,
^1
G,
•W]
G,
i
G,
i
G,
i
G,
^2
G2
^2
G,
>^2
G2
£
G,
*
G,
*
G,
«
G,
«
G,
Z
G,
<
G,
VJ2
G,
^2
G,
*
G,
^2
G,
2
G,
^2
G,
*
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
H
08/09/94
08/09/94
08/09/94
08/10/94
08/10/94
08/10/94
08/10/94
08/10/94
08/10/94
08/10/94
08/10/94
08/10/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/10/94
08/10/94
08/10/94
08/10/94
08/10/94
08/10/94
08/10/94
08/10/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/11/94
08/31/94
G-01-B-05'
G-01-B-CB1
G-01-B-OB1
G-01-D1-01
G-01-D1-02
G-01-D1-03
G-01-D1-04
G-01-D1-05
G-01-D1-P-01
G-01-D1-P-02
G-01-D1-OB1
G-01-D1-CB1
G-02-D1-01
G-02-D1-01D
G-02-D1-02
G-02-D1-03
G-02-D1-04
G-02-D1-05
G-02-D1-P-01
G-02-D1-P-02
G-02-B-OB1
G-02-D1-OB1
G-02-B-CB1
G-02-D1-CB1
G-02-B-01
G-02-B-01R
G-02-B-02
G-02-B-03
G-02-B-04
G-02-B-05
H-01-B-01
H-01-B-02
H-01-B-03
H-01-B-04
H-01-B-05
H-01-B-05R
H-01-B-OB1
H-01-B-CB1
H-01-D1-01
H-01-D1-02
H-01-D1-03
H-01-D1-04
H-01-D1-05
H-01-D1-P-01
H-01-D1-P-02
H-01-D1-CB1
H-01-F1-01
Baseline
Closed Field Blank
Open Field Blank
During - Area
During - Area
During - Area
During - Area
During - Area
During - Personal
During - Personal
Open Field Blank
Closed Field Blank
During - Area
During - Area
During - Area
During - Area
During - Area
During - Area
During - Personal
During - Personal
Open Field Blank
Open Field Blank
Closed Field Blank
Closed Field Blank
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
Open Field Blank
Closed Field Blank
During - Area
During - Area
During - Area
During - Area
During - Area
During - Personal
During - Personal
Closed Field Blank
Followup
Air Concentration
Volume, L s/cm3 s/mm2
1420
0
0
810
815
742
790
790
635
635
0
0
739
739
693
679
744
655
552
572
0
0
0
0
1181
1181
1200
1129
1150
1252
1296
1203
1302
1281
1307
1307
0
0
1107
1122
1181
1123
1171
867
764
0
1241
0.039 142.9
<13.9
<13.9
<0.004 <9.3
0.004 9.3
0.004 7.9
0.004 8.5
0.008 17.1
0.004 6.9
0.008 13.9
<13.9
<13.9
0.008 15.9
0.012 23.8
0.009 15.9
0.023 39.7
<0.004 <7.9
0.014 23.8
<0.005 <6.5
0.026 39.2
<13.9
<13.9
<13.9
<13.9
O.004 <12.3
O.004 <12.3
0.013 41.7
0.013 37.0
O.004 <12.3
O.004 <13.9
0.004 13.9
0.004 13.9
O.004 <13.9
<0.004 <13.9
O.004 <13.9
O.004 <13.9
<13.9
<13.9
0.047 135.8
0.076 222.2
0.056 172.8
0.030 86.4
0.073 222.2
0.064 144.8
0.226 448.9
<13.9
<0.004 <13.9
(continued)
68
-------
APPENDIX B (continued)
Date
Site Sampled Sample
H
H
H
H
H
H
H
08/31/94
08/31/94
08/31/94
08/31/94
08/31/94
08/31/94
08/31/94
H-01-F1-02
H-01-F1-03
H-01-F1-04
H-01-F1-04D
H-01-F1-05
H-01-F1-05R
H-01-F1-OB1
Number Sample Type
Followup
Followup
Followup
Followup
Followup
Followup
Open Field Blank
Air Concentration
Volume, L s/cm3 s/mm2
1249
1330
1360
1360
1280
1280
0
O.004 <13.9
<0.004 <13.9
<0.004 <15.9
<0.004 <15.9
O.004 <13.9
<0.004 <13.9
<13.9
a Samples ending with 'R' represent a replicate laboratory analysis of that sample.
b Samples ending with 'D1 represent a duplicate laboratory analysis of that sample.
0 Historical data based on sampling conducted in this school by U.S. EPA in May 1992. It was not possible to obtain
baseline data at this site in 1994. <
69
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