United States
Environmental Protection
Agency
Risk Reduction
Engineering Laboratory
Cincinnati, OH 45268
Research and Development
EPA/600/SR-94/084 August 1994
^ EPA Project Summary
An Evaluation of Asbestos
Management Programs in 17
New Jersey Schools: A Case
Studies Report
John R. Kominsky, Ronald W. Freyberg, C. S. Hubert, James A. Brownlee,
Donald R. Gerber, Gary J. Centifonti, and Richard M. Ritota
From 1988 through 1992, the U.S.
Environmental Protection Agency's
Risk Reduction Engineering Laboratory
(EPA-RREL) and the New Jersey De-
partment of Health's Environmental
Health Service (NJDOH-EHS) conducted
air monitoring in 17 schools in New
Jersey to evaluate their asbestos man-
agement programs.
Findings of a study conducted in
1988, to document Asbestos Hazard
Emergency Response Act (AHERA) fi-
nal clearance levels of asbestos at
these 17 schools, prompted a followup
study in 1990 to determine the airborne
asbestos levels 2 yr after the abate-
ments. Although the 1990 study pro-
vided data regarding airborne asbestos
levels during simulated occupancy con-
ditions 2 yr after abatements, whether
these data were representative of lev-
els during actual occupancy was un-
certain.
Another followup study conducted in
May 1991 during actual occupied con-
ditions showed airborne asbestos lev-
els to be above the AHERA criterion of
70 structures per square millimeter
(s/mm2) at 8 of the 17 schools.
Reentrainment of residual asbestos-
containing debris from the 1988 abate-
ment activities or from operations and
maintenance activities may have con-
tributed to these elevated airborne as-
bestos levels.
In 1992, EPA/NJDOH conducted a fi-
nal study at the 17 schools to measure
airborne asbestos levels during actual
occupied conditions 4 yr after abate-
ment activities were completed. The full
report presents the results of the 1992
study and integrates the results of the
previous studies to evaluate the as-
bestos 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.
This Project Summary was developed
by EPA's Risk Reduction Engineering
Laboratory, Cincinnati, OH, to announce
key findings of the research project
that is fully documented in a separate
report of the same title (see Project
Report ordering information at back).
Introduction
The EPA recommends a proactive, in-
place management program whenever
asbestos-containing material (ACM) is
present in buildings. Asbestos removal is
required only when necessary to prevent
significant public exposure to airborne as-
bestos during building demolition or reno-
vation activities. The ultimate goal of every
asbestos abatement project is to elimi-
nate, or reduce to the extent possible, the
actual or potential hazard airborne asbes-
tos may present to building occupants. If
all safeguards are not properly applied,
asbestos removals may actually elevate
airborne levels of asbestos in a building.
EPA-RREL and NJDOH-EHS conducted
a series of studies to measure airborne
asbestos levels immediately after and 2 to
4 yr after abatements in 17 New Jersey
schools. The primary purpose of these
studies was to evaluate the schools' as-
bestos management programs.
Printed on Recycled Paper
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In 1988, EPA-RREL and NJDOH-EHS
conducted a study to document AHERA
air-sampling practices during final clear-
ance and to measure final clearance lev-
els of airborne asbestos at 20 projects (20
sites at 17 schools) involving removal of
ACM in 17 New Jersey schools. In 1990,
EPA/NJDOH conducted a study at the
same 17 schools to measure airborne as-
bestos levels 2 yr after the abatements in
1988. Although the 1990 study provided
data regarding the residual levels of as-
bestos 2 yr after abatements, the extent
to which these data represented condi-
tions of actual occupancy remained un-
certain. In 1991, EPA/NJDOH measured
airborne asbestos levels under occupied
conditions at the 17 schools 3 yr after
abatements. In 1992, EPA/NJDOH con-
ducted a final study at the 17 schools to
measure airborne asbestos levels under
actual occupied conditions 4 yr after abate-
ments.
Objectives
The objectives of the 1992 study were
to (1) determine the airborne asbestos
levels measured during occupied condi-
tions in 17 schools that underwent abate-
ments in 1988; (2) evaluate the airborne
asbestos levels measured in the 17
schools over the 4-yr period (1988, 1990,
1991, and 1992); (3) determine the accu-
racy of each school's Asbestos Manage-
ment Plan (AMP) for the areas monitored;
and (4) determine the possible sources of
airborne asbestos in schools with elevated
levels.
Study Design
The 1992 study was conducted at the
same 17 schools involved in the 1988,
1990, and 1991 EPA/NJDOH studies. Area
airborne asbestos levels were measured
at each site in the same three areas as in
the previous studies: the previously abated
area, the perimeter area (outside the
abated area but inside the building), and
outdoors. The actual abatement areas and
perimeter areas could not be separated
because the containment barriers present
during the 1988 abatements had been
removed.
Air Sampling Strategy
The air sampling strategy for this study
consisted of monitoring during periods of
occupancy at the 17 schools (i.e., during
school hours, 8:00 a.m. to 3:00 p.m.).
Response actions were conducted at sites
with average airborne asbestos levels
above 0.02 s/cm3. The 0.02 s/cm3 crite-
rion was derived from the AHERA initial
screening criterion of 70 s/mm2 (40 CFR
763 (Code of Federal Regulations)) 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 level 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 sam-
pling strategy for this study and those for
the three preceding studies in 1988,1990,
and 1991.
At each site in May 1992, five area air
samples were collected in each of three
areas at approximately the same loca-
tions as those collected during the 1988,
1990, and 1991 studies.
July through August 1992
Based on the May 1992 sampling, five
schools representing six sites were re-
quired to conduct a response action in the
1988 abatement areas and/or perimeter
areas to reduce the risk of exposure to
airborne asbestos in these school build-
ings. The response action taken at each
of the schools primarily involved cleaning
the areas to remove all visible dust and
debris. After 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 num-
ber and locations of the samples were the
same as those collected in May 1992.
NJDOH Inspections
In 1991, a certified AHERA building in-
spector from NJDOH-EHS conducted an
Table 1. Summary of Air Sampling Strategies
inspection at each of these schools. The
inspection included a review of the school's
AMP relating to the 1988 abatement ar-
eas and perimeter areas and a visual in-
spection of these areas. In July through
August 1992, a followup visual inspection
was conducted at four schools with el-
evated airborne asbestos levels (i.e., >0.02
s/cm3) based on monitoring conducted in
May 1992.
Management Plan Review
Before conducting the visual inspection,
each school's AMP was reviewed. The
review included (1) recording the material
category, material type, amount of mate-
rial, and condition of material remaining in
the 1988 abatement areas and perimeter
areas; (2) recording response actions; and
(3) recording renovations or asbestos
abatements that occurred after the 1988
abatements. This information was then
compared with that obtained during the
visual inspection of the 1988 abatement
areas and perimeter areas to determine
the accuracy of the original AHERA in-
spection regarding the identification, as-
sessment, 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 measured in May
Period of Study
No. of Sites Conditions of Sampling
Monitoring Criteria
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
11
16
20
20
20
10
4
1
20
6
Passive*
Abatement conditions
Aggressive?/ passive
Modified aggressive*
Occupied
Modified aggressive
Modified aggressive
Modified aggressive
Occupied
Modified aggressive
Determine preabatement levels
Determine pre-final cleanup
levels
AHERA final clearance
2-yr followup
3-yr followup
Confirm if levels exceeded
0.02 s/cm3
Verify completion of followup
response action
Verify completion of followup
response action
4-yr followup
Verify completion of response
action
* Minimal occupant activity in the area.
* Aggressive sampling protocol in accordance with AHERA - 40 CFR 763.
* Sampling protocol to simulate normal occupant activity, including air sweeping of floors with
exhaust of 1-hp leaf blower and positioning of 1 stationary fan/10,000 ft3.
-------
1991 and 1992. The visual inspection in-
cluded (1) identification and condition of
the ACM recorded as well as not recorded
in the AMP and (2) documentation of the
presence of asbestos-containing debris in
the 1988 abatement areas and perimeter
areas. These areas were inspected for
the presence of debris, as well as residual
ACM on the substrate-surface using pro-
cedures in accordance with those speci-
fied in ASTM Standard E1368-90.
Sampling Methods
Fixed-Station Area Air Samples
Air samples were collected on open-
face, 25-mm-diameter, 0.45-n.m-pore-size,
mixed cellulose ester (MCE) membrane
filters with a 5-nm-pore-size, MCE, backup
diffusing filter and cellulose support pad
contained in a three-piece cassette. The
filter cassettes were positioned approxi-
mately 5 ft above the floor on tripods, with
the filter face at approximately a 45° 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
Bulk Samples
Bulk samples were collected of suspect
ACM or suspect asbestos-containing de-
bris for laboratory analysis to determine
the asbestos content. 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.
Analytical Methods
Air Samples
The MCE filters were prepared by the
direct transfer technique and were ana-
lyzed in accordance with the nonmandatory
transmission electron microscopy (TEM)
method, as described in the AHERA Final
Rule. A sufficient number of grid openings
were analyzed for each sample to ensure
an analytical sensitivity of no greater than
0.005 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 re-
corded.
Bulk Samples
The type and percentage of asbestos in
the bulk samples were determined by po-
larized light microscopy (PLM) and X-ray
diffraction (XRD). The samples were pre-
pared and analyzed in accordance with
the "Interim Method for Determination of
Asbestos in Bulk Insulation Samples" (EPA
600/M4-82-020).
Statistical Methods
Although the 17 schools did not repre-
sent a statistical random sample and were
likely to differ in abatement history and
current status with respect to the pres-
ence of ACM, the 1992 data were com-
bined across all sites to examine overall
trends in airborne asbestos levels at these
schools. Analysis of variance (ANOVA)
techniques were used to compare airborne
asbestos levels measured in 1992. ANOVA
techniques were also used to compare
the airborne asbestos levels measured in
1988,1990,1991, and 1992. If the ANOVA
p-value was less than 0.05, the Tukey
multiple comparison procedure was used
to evaluate pairwise differences. All statis-
tical comparisons were performed at the
0.05 level of significance.
Qual ity Assu ran ce
Specific quality assurance procedures
specified in AHERA were used to ensure
the precision of the collection and analy-
sis of air samples, including filter lot blanks,
open and closed field blanks, and repeated
sample analyses.
Results and Discussion
Airborne Asbestos Levels
During Occupied Conditions in
May 1992
Six of the 20 sites showed levels above
the AHERA initial screening criterion of 70
s/mm2 and above the NJDOH-EHS re-
sponse action criterion of 0.02 s/cm3. A
two-factor ANOVA was used to examine
overall differences in airborne asbestos
levels measured at the 20 sites in 1992.
When averaged across all sites, the air-
borne asbestos levels measured in the
1988 abatement areas and the 1988 pe-
rimeter areas were numerically greater
than the levels measured outdoors, but
the difference was not statistically signifi-
cant (p = 0.1161). The overall average
levels measured in the 1988 abatement
areas, the 1988 perimeter areas, and out-
doors we»e 0.008 s/cm3, 0.007 s/cm3,
and 0.003 s/cm3, respectively. Although
individually the overall airborne asbestos
levels measured in the abatement areas
and perimeter areas were not significantly
different from levels measured outdoors,
when combined, the indoor airborne as-
bestos levels at these 20 sites (overall
average = 0.008 s/cm3) were significantly
greater (p = 0.0408) than levels measured
outdoors (overall average = 0.003 s/cm3).
Overall Structure Morphology
and Length Distributions
The TEM analysis of the samples col-
lected in May 1992 yielded a total of 1552
asbestos structures, of which 99.7% were
chrysotile asbestos and 0.3% were am-
phibole. Overall, the asbestos structures
were primarily fibers (87%), and to a lesser
extent, matrices, bundles, and clusters.
Overall, 99% of the measured asbestos
structures were less than 5 jim in length;
most of the structures (97%) were less
than 2 |o.m in length.
NJDOH Inspections
In 1991, NJDOH-EHS conducted an in-
spection at each of the 17 schools. In July
through August 1992, a followup visual
inspection was conducted at three schools
with elevated airborne asbestos levels
based on monitoring conducted in May
1992. (The information from the 1991 and
1992 inspections was provided to the re-
spective school officials.)
Management Plan Review
At 16 of the 20 sites, the schools' AMP
contained at least one error relating to the
areas of the schools inspected by the
NJDOH-EHS. The errors related to mate-
rial identification or material location.
Fourteen of the sites contained at least
one ACM not identified in the original
AHERA inspection conducted by the
school. The most consistently unidentified
material was thermal system insulation
(TSI), which was not identified at 14 of the
20 sites inspected.
At five sites, the AMP misidentified ma-
terials. At three of the sites the materials
did not contain >1% asbestos based on
bulk sample analysis by the NJDOH-EHS.
At one of the sites, the ACM identified in
the AMP was spray-on surfacing material,
but inspections by NJDOH-EHS showed it
to be TSI. At the same site, the AMP did
not identify the presence of asbestos-con-
taining TSI in the boiler. At one of the
sites, the school's AMP did not identify
the resilient floor tile as asbestos-contain-
ing.
At one site, the AMP was in error re-
garding both the identification and loca-
tion of an ACM. The AMP indicated the
presence of spray-on materials in an area
where no spray-on materials were present.
Nine of the 16 sites with AMP errors
had elevated airborne asbestos levels in
either May 1991 or May 1992. At two of
these sites, Operations and Maintenance
(O&M) activities involving ACM that was
not identified in the AMP may have con-
tributed to the elevated airborne asbestos
levels.
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Residual Asbestos-Containing
Debris
Each site was inspected to determine
the presence of asbestos-containing de-
bris from the 1988 abatement activities
and/or asbestos-containing debris from
other activities. The visual inspections re-
vealed the presence of asbestos-contain-
ing debris at 18 sites. At 14 sites, the
debris was present in the 1988 abatement
areas. Eight of these 14 sites also failed
the AHERA initial screening criterion of 70
s/mm2 during the 1988 clearance test
(based on the EPA/NJDOH monitoring
data), which indicated that asbestos-con-
taining debris remained in the abatement
areas. The debris was believed to be from
the 1988 abatements based on bulk
sample analysis, location of the material,
and residual debris on the original sub-
strates abated. Other asbestos-containing
debris present at 12 of the sites generally
resulted from damaged TSI, fireproofing,
and acoustical plaster. At one site, the
debris resulted from efflorescence of con-
crete-masonry block and/or mortar result-
ing in a white powdery material (containing
chrysotile asbestos) along the base of the
wall.
In May 1991, elevated airborne asbes-
tos levels were measured at eight of the
sites measured by EPA/NJDOH in the
1988 abatement areas and/or perimeter
areas; in 1992, six sites measured had
elevated levels. The potential sources of
the elevated levels were believed to be
primarily the debris identified during the
visual inspections conducted in 1991 and/
or 1992. In addition, other sources such
as floor care maintenance activities could
also contribute to the airborne asbestos
levels present in these school buildings.
Response Action Evaluation
1991 Response Action
In May 1991, 8 of the 20 sites had
average airborne asbestos levels above
0.02 s/cm3. In August 1991, EPA/NJDOH
conducted followup monitoring at these
sites to determine if the elevated levels
still existed. Results of the followup moni-
toring indicated that four sites showed av-
erage 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 re-
sponse action was determined by each
school's AMP and/or its consultant and
included dry-vacuuming of horizontal sur-
faces with a HEPA-filtered vacuum cleaner,
wet-wiping of horizontal surfaces, or en-
capsulation. After the response actions by
the schools, monitoring conducted by EPA/
NJDOH showed that one of the four sites
had an average airborne asbestos level
above 0.02 s/cm3. Further response ac-
tions were required at this site, and the
airborne asbestos levels were reduced to
below 0.02 s/cm3.
1992 Response Action
In May 1992, 6 of the 20 sites had
average airborne asbestos levels above
.0.02 s/cm3. The NJDOH-EHS required
each of the five schools (representing the
six sites) to conduct response actions to
reduce the airborne asbestos levels be-
low the 0.02 s/cm3 criterion. After the re-
sponse actions at these five schools, air
monitoring conducted by EPA/NJDOH
showed that the asbestos levels were be-
low the 0.02 s/cm3 criterion, and no fur-
ther response action was required at four
of the schools. One school required addi-
tional cleaning to bring asbestos levels
below the 0.02 s/cm3 criterion.
Comparison of 1988, 1990,
1991, and 1992 Airborne
Asbestos Levels
A two-factor ANOVA was used to ex-
amine overall differences between the
three sampling locations. Each year was
analyzed separately. The results of the
ANOVAs are summarized in Table 2.
A two-factor ANOVA was used to ex-
amine overall differences between the 4
yr of sampling results. Each sampling lo-
cation was analyzed separately. The re-
sults of the ANOVAs are summarized in
Table 3.
General Observations from the
1988, 1990, 1991, and 1992
Studies
Table 4 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 in-
spections conducted at these sites.
Conclusions
1. Overall, when all of the 20 sites
were considered collectively, there
was no apparent trend toward pro-
gressively increasing airborne as-
bestos concentrations 2 to 4 yr after
the 1988 abatements. At a number
of sites, however, airborne asbes-
tos concentrations were elevated
immediately after and 2 to 4 yr af-
ter the 1988 abatements.
2. Response actions conducted by the
schools in 1991 and 1992 demon-
strated that elevated airborne as-
bestos levels can be reduced to
acceptable levels (i.e., <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 activities and from
postabatement O&M activities may
have contributed to the elevated
airborne asbestos levels (>0.02
s/cm3) present in 1991 or 1992, or
both at nine sites.
4. Errors in the AMPs relating to ma-
terial identification or material loca-
tion were documented at 13 of the
17 schools. The errors at three
schools may have resulted in the
accidental disturbance of ACM.
5. A standardized visual inspection is
an effective tool to determine the
presence of residual asbestos-con-
taining 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 use
the outdoor samples as the refer-
ence point rather than the.perim-
eter samples collected inside the
building. At nine schools, airborne
asbestos levels in the perimeter ar-
eas after the 1988 abatements were
significantly higher than those mea-
sured before the abatements. (Re-
sults of preabatement samples
collected in the perimeter areas and
outdoors did not differ significantly).
7. Consultants who conducted the
schools' clearance air monitoring in
1988 often did not completely un-
derstand and follow the AHERA
sampling and analytical require-
ments and recommendations. Prac-
tices observed during clearance
monitoring included inadequate dry-
ing of the abatement areas before
sampling, use of improper sampling
medium and flow rates, inadequate
aggressive air sweeping of sur-
faces, and insufficient use of circu-
lating fans to maintain air movement
during sampling.
Recommendations
1. A study should be conducted to
evaluate the long-term effectiveness
of asbestos response actions in
schools. This information would as-
sist EPA in evaluating the need for
issuance of guidance on response
actions.
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Table 2. Comparison of Sampling Locations for Airborne Asbestos Levels Measured in 1988,
1990, 1991, and 1992
Statistically Significant Differences in Airborne
Year
1988
1990
1991
1992
ANOVA p-value
0.0001
0.0030
0.0001
0. 1 161
Asbestos Concentrations*'*
A(0.020) P(0.006) O(0.002)
P(0.003) A(0.002) O(0.001)
A(0.008) P(0.004) O(0.001)
P(0.008) A(0.007) O(0.003)
* A = 1988 abatement area; P = 1988 perimeter area; O = Outdoors. 3
Parenthetical entries are average airborne asbestos concentrations (s/cm jassociated with that
sampling location. Sampling locations (averages) connected by a line are not significantly
different.
Table 3. Comparison of Yearly Levels of Airborne Asbestos
Sampling Location
1988 Abatement area
1988 Perimeter area
Outdoors
ANOVA
p-value
0.0001
0.2725
0.0369
Statistically Significant Differences in Airborne
Asbestos Concentrations*
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)
Parenthetical entries are average airborne asbestos concentrations (s/cm) associated with that
year. Years (averages) connected by a line are not significantly different.
2. Although not specifically required 3.
by AH ERA, schools should evalu-
ate the effectiveness of their O&M
program and periodic surveillance.
Areas of the buildings that have
undergone asbestos-removal or
O&M activity (involving ACM)
should be thoroughly reinspected
for the presence of residual asbes-
tos-containing debris. If asbestos- 4.
containing debris are observed,
thorough cleaning and followup air
monitoring should be conducted.
education agencies, AH ERA desig-
nated 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 standard-
ized visual inspection procedure (or
a variation thereof) should be in-
corporated into the 3-yr AHERA
AMP reinspections.
7. A comprehensive guidance docu-
ment should be developed that ad-
dresses the procedures and
protocols for conducting a standard-
ized visual inspection and AHERA
clearance air sampling.
The full report was submitted in partial
fulfillment of Contract No. 68-D2-0058,
Work Assignment No. 1-18, by Environ-
mental Quality Management, Inc., under
subcontract to Pacific Environmental Ser-
vices, Herndon, VA 22070. This work was
conducted under the sponsorship of the
U.S. Environmental Protection Agency.
Each school should maintain and
update its AMP to keep it current
with ongoing O&M, periodic sur-
veillance, inspection, reinspection,
response actions, and post-re-
sponse action activities. The school
should ensure that workers who
may disturb ACM are aware of
changes in the AMP.
EPA, cooperatively with state agen-
cies, need to provide further out-
reach and education to all
responsible parties such as local
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