United States
Environmental Protection
Agency
National Risk Management
Research Laboratory
Cincinnati, OH 45268
Research and Development
EPA/600/SR-97/063 July 1997
&EPA Project Summary
Evaluation of the Implementation of
Operations and Maintenance
Programs in New Jersey Schools
John R. Kominsky, Ronald W. Freyberg Donald R. Gerber, Gary J. Centifonti
Abstract
The Asbestos Hazard Emergency Re-
sponse Act (AHERA) required all
schools to develop and implement an
asbestos management plan (AMP). The
key component of the AMP is the op-
erations and maintenance (O&M) pro-
gram. A study was conducted to evalu-
ate the implementation of O&M pro-
grams at ten sites representing eight
New Jersey schools. The evaluation in-
cluded aspects required by AHERA as
well as those recommended in the En-
vironmental Protection Agency's (EPA)
guidance. Each school's O&M program
and compliance with their program dur-
ing past O&M activities were docu-
mented. In addition, ten ongoing O&M
activities were documented to deter-
mine the impact of the activities on
airborne asbestos levels and to deter-
mine compliance with the O&M pro-
gram during these activities. Overall,
schools were not implementing all the
elements of the O&M program. Schools
performed more O&M program ele-
ments 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 programs were
performed (52%) was higher than those
provided by the worker or contractor
performing the activity (35% and 22%
respectively). Increases in area asbes-
tos levels (by transmission electron
microscopy [TEM]) were observed dur-
ing five of the ten O&M activities evalu-
ated, however, none of the total fiber
levels (by phase contrast microscopy
[PCM]) exceeded the Occupational
Safety and Health Administration
(OSHA) Permissible Exposure Limit
(PEL). This study underscores the im-
portance of a thorough O&M program
and the effective communication and
implementation of all program ele-
ments.
This Project Summary was developed
by the National Risk Management Re-
search Laboratory's Sustainable Tech-
nologies Division, 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 infomration at
back).
Introduction
The concern for asbestos-containing ma-
terials (ACM) in buildings started in the late
1970s in the U.S. In 1978 the EPA issued
a two-volume guidance document to schools
for identification and evaluation of in-place
asbestos. Subsequently, three additional
guidance documents were issued by the
EPA in 1983,1985, and 1990.
Although removal was encouraged over
alternative approaches of asbestos man-
agement in the past, in-place manage-
ment and O&M programs are currently
viewed by the EPA as the most appropri-
ate overall strategy for management of
asbestos in buildings. In-place manage-
ment 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 when-
Printedon Recycled Paper
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evef friable ACM is present or assumed
to be present in school buildings. An O&M
program is an administrative framework
that prescribes specific work practices and
training to maintain friable ACM in good
condition, ensure cleanup of asbestos fi-
bers previously released, and prevent fu-
ture release by minimizing and controlling
friable ACM disturbance during installa-
tion, repair, maintenance, and cleaning
activities. A well-developed O&M program
Is ineffective unless it is implemented prop-
erly. The O&M program's success is con-
tingent upon the commitment of all per-
sonnel involved in developing, conscien-
tiously implementing, and conducting O&M
activities.
Although these O&M programs have
been prepared for schools, no represen-
tative field studies have been conducted
to evaluate the implementation and effec-
tiveness of these programs in controlling
the release of asbestos fibers into a build-
ing. The purpose of this study was to
evaluate the implementation of O&M pro-
grams in selected schools in New Jersey.
Objectives
The objectives of this study were to (1)
document and assess each school's O&M
program and other related components in
the AMP; (2) document and assess each
school's compliance with their O&M pro-
gram during previously conducted O&M
activities; (3) observe and document the
conduct of selected O&M activities involv-
ing ACM or in the vicinity of ACM; and (4)
determine the impact of selected O&M
activities on airborne asbestos levels.
Site Selection
An "O&M Activities Survey Form" was
distributed to 26 candidate schools repre-
senting 14 different school districts that
planned to perform O&M activities involv-
ing 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 (heat-
ing, ventilation, and air-conditioning, plumb-
ing, electrical/communications, fire protec-
tion, and other building systems or com-
ponents); (3) and Renovation (general
space modifications, ceiling tile replace-
ment, carpet removal, and roofing repair).
Eight schools, representing ten distinct
O&M activities, were selected based on
the type of planned activity and the sched-
ule for conducting the planned activity.
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 asbes-
tos levels during O&M activities on or near
ACM.
Evaluation of O&M Programs
A "Site Evaluation/Assessment Docu-
mentation Form" was used to standardize
the evaluation of each school's O&M Pro-
gram. To prevent any ambiguity regarding
the questions or recording of the re-
sponses, the form was administered by
an Environmental Health Services-New
Jersey Department of Health (EHS-
NJDOH) representative who was thor-
oughly 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 en-
sure 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 in-
volved a review of each school's O&M
program and other related components in
the AMP on file with the NJDOH to deter-
mine the overall comprehensiveness of
the O&M program. Part 2 involved an on-
site interview with the school's AHERA
Designated Person to assess each
school's compliance with their O&M pro-
gram 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) perform-
ing an actual O&M activity.
Part 1 - Each school's AMP, which was
on file with the EHS-NJDOH, was evalu-
ated by an EPA-accredited Inspector and
Management Planner prior to initiating the
planned activity. The Inspector/Manage-
ment Planner completed the Site Assess-
ment/Documentation Form during the re-
view of the school's O&M program. The
evaluation included the program elements
required by AHERA as well as those ele-
ments recommended by EPA in issued
guidance. Therefore, the evaluation was
based on three categories of program ele-
ments: those program elements required
by AHERA; those program elements rec-
ommended in EPA guidance documents;
and all of the program elements (i.e., those
required by AHERA and those recom-
mended in EPA-issued guidance). A "Site
Evaluation/Assessment Documentation
Form" was used to standardize the evalu-
ation of the respective O&M programs.
Each school's O&M Program was evalu-
ated 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 pro-
gram should address specific activi-
ties and procedures related to use,
cleaning, maintenance, repairs, equip-
ment service, and fiber release epi-
sodes.
• Administration/Awareness: The writ-
ten AMP should be available at the
school and updated to keep it current
with ongoing O&M, periodic surveil-
lance, inspection, reinspection, and
response action activities. Addition-
ally, maintenance and custodial per-
sonnel must be made aware and have
reviewed the AMP and O&M Program
prior to conducting activities.
• Notification: AHERA requires that
workers (school employees and con-
tract workers), tenants, and building
occupants be notified where ACM is
located, and how and why to avoid
disturbing the ACM. All persons af-
fected should be properly informed.
• Surveillance: AHERA requires regu-
lar 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 con-
trol activities that might disturb ACM.
• Work Practices: The program should
describe O&M work practices to avoid
or minimize fiber release during ac-
tivities affecting ACM.
• Recordkeeping: AHERA requires spe-
cific documentation of O&M activities.
• Worker Protection: AHERA requires
medical and respiratory protection pro-
grams, as applicable.
• Training: AHERA requires proper
training of custodial and maintenance
staff who may deal with activities in-
volving ACM.
Part 2 - Information regarding previ-
ously conducted O&M activities at the
school was obtained by interviewing each
school's designated person using the "Site
Evaluation/Assessment Documentation
Form." 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 con-
ducted O&M activities.
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Part 3 - Selected O&M activities involv-
ing ACM, or in the vicinity of ACM, were
observed and documented at each school
by using the Site Evaluation/Assessment
Documentation Form. 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 re-
garding 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 ac-
tual 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 activi-
ties on the exposure of custodial workers,
maintenance workers, and/or building oc-
cupants 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).
Sampling Methods
Fixed-Station Area Air Samples
The fixed-station area air samples were
collected on open-face, 25-mm diameter,
0.45-n.m poresize, mixed cellulose ester
(MCE) filters with a 5-(im 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° angle
toward the floor. The filter assembly was
attached to an electric-powered (110 VAC)
1/6-horsepower vacuum pump operating
at a flowrate of approximately 9 liters per
minute (L/min).
Personal Breathing Zone
Samples
One personal breathing zone air sample
was collected on an open-face, 25-mm
diameter, 0.8-p.m poresize MCE 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-ja.m
poresize MCE filters with a 5-jim poresize
MCE diffusing filter and a cellulose sup-
port pad contained in a three-piece cas-
sette. These two samples were collected
for analysis by TEM. The three labeled
filter cassettes were positioned in the
breathing zone of the individual perform-
ing the O&M activity. Each filter was at-
tached 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 air-
flow rates (approximately 2 L/min with the
0.45-jim poresize MCE filter with a 5-|im
poresize MCE diffusing filter and a cellu-
lose support pad contained in a three-
piece cassette).
Analytical Methods
Area Air Samples
The MCE filters were prepared and ana-
lyzed in accordance with the nonmandatory
TEM method specified in the AHERA Fi-
nal 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 rep-
resented by the finding of a single struc-
ture) of no greater than 0.005 asbestos
structures per cubic centimeter of air
sampled, unless the degree of loading
made this impractical. On heavily loaded
samples, counting stopped after comple-
tion of the grid square in which the 100th
asbestos structure was found.
Personal Breathing Zone
Samples
The 0.8-jim poresize MCE filters were
analyzed by PCM. These samples were
prepared and analyzed according to the
NIOSH 7400 protocol (Revision 3, June 5,
1989, NIOSH Manual of Analytical Meth-
ods). All fibers > 5 )im in length and with
an aspect ratio of > 3:1 were counted
using the "A" counting rules. The analyti-
cal sensitivity was approximately 0.01 fi-
ber per cubic centimeter of air sampled.
Bulk Samples
The type and percentage of asbestos in
bulk samples was determined by polar-
ized light microscopy (PLM) and X-ray
diffraction (XRD) in accordance with the
"Interim Method for Determination of As-
bestos in Bulk Samples" (EPA-600/M4-
82-020).
Statistical Methods
Airborne asbestos levels measured be-
fore and during each O&M activity were
characterized for each site by the use of
descriptive statistics. The descriptive sta-
tistics included the arithmetic mean, mini-
mum and maximum concentrations, and
sample size. A one-factor analysis of vari-
ance (ANOVA) was used to examine over-
all differences between baseline concen-
trations, 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 con-
centration, was applied to each measure-
ment before the ANOVA was performed.
The transformation was used to make vari-
ances 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 natu-
ral 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 distin-
guish pairwise differences between mean
concentrations. All statistical comparisons
were conducted at the 0.05 level of sig-
nificance.
Quality Assurance
During the study, sample chain-of-cus-
tody 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 pro-
cedures documented each sample from
the time of its collection until its receipt by
the analytical laboratory. Internal labora-
tory records then documented the cus-
tody of the sample through its final dispo-
sition. Specific quality assurance proce-
dures outlined in the AHERA rule were
used to ensure the precision of the collec-
tion and analysis of air samples, including
filter lot blanks, open and closed field
blanks, and repeated sample analyses.
Results and Discussion
Site Descriptions
Eight schools representing seven school
districts were surveyed during this study.
All eight of these schools have partici-
pated in past asbestos-related studies con-
ducted cooperatively by EPA and EHS-
NJDOH. A total of ten O&M activities were
evaluated at these eight schools; two ac-
tivities were evaluated at two of the schools
(Sites F and G) and one activity was evalu-
ated at each of the other six schools. A
summary matrix of each study site and
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the O&M activity evaluated is presented
in Table 1.
Assessment of O&M Programs
The evaluation of the data for each
school's O&M program was grouped into
three categories: AHERA Elements, in-
cluding those program elements required
by AHERA; 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 con-
tained in the school's AHERA AMP filed
with the EHS-NJDOH; Part 2 (previous
O&M activities), which included the previ-
ously conducted O&M activities informa-
tion obtained by interviewing each school's
AHERA Designated Person; and Part 3
(observed O&M activities), which included
the information obtained by direct obser-
vation of O&M activities.
Comparison By Category
Table 2 summarizes the individual per-
formance responses for each site by part
and category. It also presents the overall
average percentage of performance re-
sponse 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 re-
sponse to the respective question, as well
as indicates that the particular activity or
function had been accomplished.
AHERA Elements - Overall, the perfor-
mance responses were highest for ele-
ments required by AHERA. The AMP per-
formance responses ranged from 69.6%
to 95.7% with an average of 88.3%. At
seven of ten sites, the AMP's indicated
greater than 90% performance response.
Only one site's AMP had less than 70%
performance response. It should be noted
that for the evaluation of the information
required by AHERA in the AMP, it is pos-
sible to have less than 100% performance
for the purpose of this study. Some O&M
program elements could not be verified
because they would not be performed un-
til 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 eight
of ten sites were less than those 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%.
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% with an average of 41.4%. At
eight of ten sites, the AMP indicated less
than 70% performance response. The
lower responses could be attributed to
some of the guidance information (par-
ticularly the "Green Book") not being avail-
able when the AMP's were prepared in
1987 to 1989. The performance responses
averaged only slightly higher in previous
O&M activities (54.1%) and during the ob-
served O&M activities (44.0%).
Although all of the guidance was avail-
able for approximately five years prior to
this evaluation, the most recent EPA guid-
ance (the "Green Book") is not geared
Table 1. Summary of O&M Activities Evaluated by SITE
Site
A
B
C
0
E
F,
FS
G,
G*
H
O&M Category
Operations'
Maintenance"
Renovation
Maintenance'
Renovation
Maintenance"
Maintenance
Renovation'
Maintenance
Maintenance
Description of O&M Activity
Wet-stripping of resilient floor tile.
HEPA-vacuuming of boiler interior.
Spacemodification (demolition of plasterwalls/ceilings; pipes).
HEPA-vacuuming of HVAC unit in classrooms.
Removal of carpet over resilient floor tile.
HEPA-vacuuming of interior air handling unit.
Wiring pulled above suspended ceiling for smoke detectors.
Removal/replacement of suspended ceiling panels.
Romex cable pulled above suspended ceiling.
Holes drilled in acoustical plaster to install smoke detectors.
•Denotes that the work was performed by an employee of the school.
specifically toward schools, but for build-
ings in general. Therefore, the schools
may not be aware of the guidance or may
choose not to implement the guidance
recommendations since it's not a regula-
tory requirement. A comparison of the data
contained in the AMP, with the perfor-
mance responses from previous O&M ac-
tivities and a comparison with the observed
O&M activities and a comparison suggest
a trend in decreasing percentage of per-
formance responses. The AMP's docu-
mented an average performance response
of 70.6%, whereas the school stated that
it performed 57.6% of the O&M elements
during previous O&M activities, and per-
formed 49.2% of the elements during the
observed O&M activity. In the observed
O&M activities, performance responses in
eight of ten sites were less than those
noted in the AMP.
Comparisons by Part
Table 2 summarizes the individual per-
formance responses for each site by part
and category. It also presents the aver-
age percentage of performance response
for all sites by part and category.
Part 1 - At all sites, the individual per-
centage of AHERA element performance
responses was higher than those recom-
mended in EPA Guidance elements. The
number of sites with performance re-
sponses less than 70% was only one of
ten for AHERA elements and eight of ten
for Guidance elements. The average per-
formance response for AHERA elements
(88.3%) was 53.1% higher than the aver-
age performance response for Guidance
elements (41.4%).
Part 2 - The average performance re-
sponse for Guidance elements (54.1%)
was 9.8% lower than the average perfor-
mance response for AHERA elements
(60.0%). All three categories had six of
ten sites with performance responses less
than 70%.
Part 3 - The average performance re-
sponse for Guidance elements (44.0%)
was 25.3% lower than the average perfor-
mance response for AHERA elements
(58.9%). Both the AHERA elements and
Guidance elements categories had seven
of ten sites with performance responses
less than 70%.
Comparisons of School, Worker,
and Contractor Performance
Responses
Further evaluation was made to com-
pare the performance responses of the
school officials to those of the persons
actually performing the observed O&M
activity. Both the school Designated Per-
son and the school maintenance worker
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Table 2. Percentage of Performance Responses for Program Elements
Study Site
A
B
C
D
E
F,
P2
G,
G2
H
Average
Rec
Parti"
95.7
. 91.3
78.3
91.3
69.6
95.7
95.7
91.3
91.3
82.6
88.3
luired by AHER
Part2b
58.3
50.0
95.8
54.2
95.8
12.5
16.7
75.0
75.0
66.7
60.0
A
Part3c
66.7
22.2
77.8
77.8
66.7
44.4
44.4
55.6
55.6
' 77.8
58.9
Parti
50.0
35.7
50.0
71.4
7.1
14.3
14.3
50.0
50.0
71.4
41.4
EPA Guidance
Part 2
47.1
41.2
100
23.5
" 76.5
23.5
23.5
8.2
88.2
29.4
54.1
PartS
46.7
6.7
80.0
20.0
66.7
13.3
13.3
80.0
73.3
40.0
44.0
Parti
78.4
70.3
67.6
83.8
45.9
64.9
64.9
75.7
75.7
78.4
70.6
Ail Elements"
Part 2
53.7
46.3
97.6
41.5
87.8
12.5
19.5
80.5
80.5
51.2
57.6
PartS
54.2
12.5
83.3
33.3
66.7
25.0
25.0
70.8
66.7
54.2
49.2
"Part 1 involved a review of each school's Asbestos Management Plan.
bPart 2 involved an interview with the school's AHERA Designated Person regarding previous O&M activities.
cPart 3 involved information from the school's AHERA Designated Person and the individual performing the observed O&M activity.
"Includes the O&M program elements required by AHERA and those recommended in EPA-issued guidance.
or the outside contractor performing the
activity where asked specific questions re-
garding the observed O&M activities. Table
3 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 Per-
son was 52.5%, whereas the performance
response indicated by the school mainte-
nance worker was 35%. The outside con-
tractor indicated that 22.5% of the O&M
elements were performed. Approximately
a 33.3% decrease in the performance re-
sponse from the school Designated Per-
son to the school maintenance worker was
also observed. Similarly, a 57.1 % decrease
in the performance response from the
school Designated Person to the outside
contractor was observed. This also re-
flects a 35.7% decrease in performance
response from the school maintenance
worker to the outside contractor. The per-
formance responses for "AHERA Ele-
ments" were very similar as was the trend
of decreasing performance responses from
the school Designated Person to the
school maintenance worker and the out-
side contractor.
Comparisons by Program
Elements
Table 4 presents the performance re-
sponses to the individual program ele-
ments for both the AHERA-required and
EPA-recommended elements by Parts 1,
2, and 3. Generally, decreases in perfor-
mance responses for each element is
noted from the elements documented in
the AMP (Part 1), to previous O&M activi-
ties (Part 2), and to what was actually
observed during the O&M activity (Part 3).
Across all sites for each program ele-
ment, an overall average was calculated.
When the AMP is evaluated according to
the "All Elements" category; surveillance,
recordkeeping, and training had the high-
est percentage of performance responses.
Other program elements scored less, with
all being less than 80%. Work practices
and work permit system program elements
scored the lowest with 57.5% and 38.9%,
respectively.
Impact of O&M Activities on
Airborne Asbestos Levels
TEM Air Monitoring Results
Airborne asbestos levels were measured
before and during each O&M activity at
each site. A one-way ANOVA was used
to compare airborne asbestos levels mea-
sured before each activity to area and
personal breathing zone levels measured
during the activity at each site. Table 5
summarizes the results of these compari-
sons for each O&M activity. Some O&M
activities were performed in the vicinity of
ACM without causing elevated airborne
asbestos levels. Five of ten activities (Sites
A, C, F,, F2, and H) showed significant
increases in airborne asbestos levels dur-
ing the associated O&M activity when com-
pared to baseline measurements. Addi-
tionally, when O&M activities disturbed
ACM in the vicinity or were conducted on
ACM, airborne asbestos levels were el-
evated at or above 0.02 s/cm3 in four of
ten sites (A, C, F,, and H). The 0.02 s/cm3
criterion was derived from the AHERA
clearance criterion of 70 s/mm2 (40 CFR
763). Another study, conducted over a 4
year period, concluded that O&M activi-
ties that disturbed ACM (including thermal
system insulation and plaster, and resil-
ient floor tile) may have contributed to
elevated airborne asbestos levels at sev-
eral of the sites.
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 dur-
ing wet-stripping of resilient floor tile are
consistent with those levels measured dur-
ing other studies involving the same floor
care maintenance practice.
Additionally, a study previously con-
ducted on the spray-buffing of resilient
floor tile demonstrated that this common
maintenance procedure increased airborne
asbestos levels at the majority of the study
sites.
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TabloS. Percentage of Performance Responses for Parts with Individual School Designated Person,
Worker, and Contractor Responses
Percentage of Performance Responses
Elements
School
Designated Person
School Worker
Contractor
AH Elements
AHERA Elements
52.5
60.0
35.0
37.5
22.5
25.0
Table 4. Average Performance Responses for all SITES by Element and Part - All Elements Category
Parts
Program Elements
1°
2"
Administration 72.3
Notification 76.7
Surveillance 100
Work Control/Permit System 38.9
Work Practices 57.5
Recordkeeping 97.5
Personal Protective Equipment 70.0
Training 90.0
Totals 70.6
66.4
30.0
75.0
45.6
44.0
70.0
50.0
65.0
57.6
68.0
35.0
38.9
33.3
75.0
80.0
45.0
49.2
•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.
«Part3 involved information from the school's AHERA Designated Person and the individual performing
the observed O&M activity.
Table 5. Summary of ANOVA Comparisons
Site-Activity
ANOVA
p-value
Tukey pairwise comparisons111'-0
Site A - Perform wet-stripping of resilient floor tile 0.0001
Site B - Vacuum interior of boilers 0.3627
Site C - Contact space modification 0.0102
Site D - Vacuum air-handling unit 0.4889
Site F, - Changer filter and vacuum air-handling unit 0.0254
Site Fa - Install smoke detector wing 0.0059
Site G, - Remove/replace ceiling tile 0.5192
Site Gj - Install flexible electrical conduit above 0.5650
suspended ceiling
Site H- Install fire alarm system 0.0001
B(0.002) DP(3.29T
DP(0.002) BKX003) DA(0.006)
B(0.003) DA(0.020)
BfO.002^ DAfO.003^ DPKX003T
BfO.003) DAfO.007^ DP(0.042)
DA(0.003^ BfO.003^ DP(0.009)
DAfO.004) DPm.006^ BfO.007^
8(0.004) DAfO.009) DPfO.008^
B(0.003) DAfO.053^ DP(0.120^
•8 m Baseline; DA • Area samples taken during the activity; DP = Personal samples taken during the
activity
'Parenthetical entries are geometric average airborne asbestos concentrations (s/cm3).
•Average concentrations connected by a line are not significantly different.
In general, personal breathing zone lev-
els tended to be slightly higher than area
levels during the activities. This difference,
however, was statistically significant dur-
ing only one activity. The higher concen-
trations of asbestos measured by the per-
sonal breathing zone samples than the
concentrations measured by the fixed-sta-
tion area samples at Site F2 are most
likely attributable to differences in the prox-
imity of the sampling cassettes to the
source of the asbestos release; i.e., the
O&M activity.
PCM Air Monitoring Results
None of the personal breathing zone
levels exceeded the OSHA PEL of 0.1 f/
cm3,8-hour time weighted average (TWA).
The 8-hour TWA concentrations were cal-
culated by assuming zero exposure both
before and beyond that which was mea-
sured during the activity.
Conclusions
The following are the principal conclu-
sions reached during this study:
1. Overall, schools were not completely
implementing all the elements of the
O&M program within the AMP as
outlined in AHERA or in EPA guid-
ance documents. The O&M pro-
grams ranged in overall comprehen-
siveness from 45.9% to 83.8% with
an average of 70.6%.
2. School Designated Persons may not
be aware of all program elements in
the AMP. The overall percentage of
performance responses given by the
school officials during the observed
O&M activities was 52.5%. The
school maintenance worker indicated
a performance response of only 35%,
while the outside contractor indicated
an even lower performance of 22.5%.
All elements were not implemented
and/or communicated by the school's
designated person. Additionally, all
program elements were not per-
formed by the workers/contractors
conducting the O&M activity.
3. Schools implemented more required
items in accordance with AHERA
than those additional program ele-
ments outlined in EPA guidance
documents. The percentage of per-
formance responses was highest in
the management elements of
AHERA and EPA guidance. The el-
ements indicating implementation
items such as notification to work-
ers/contractors, work permit system,
and work practices for the O&M ac-
tivities had the least percentage of
performance responses.
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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 sig-
nificantly elevated and exceeded
0.02 asbestos structure/cm3 (School
Sites A, C, and H).
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.
The full report was submitted in partial
fulfillment of Contract No. 68-D2-0058 by
Environmental Quality Management, Inc.,
under subcontract to Pacific Environmen-
tal Services, Inc., under the sponsorship
of the U.S. Environmental Protection
Agency.
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J.R. Komlnsky and R.W. Freybergare with Environmental Quality Management,
Inc., Cincinnati, OH45240;D.R. GerberandG.J. Centifontiare with the Environ-
mental Health Services - New Jersey Department of Health, Trenton, NJ 08625.
Aaron R. Martin Is the EPA Project Officer and Alva Edwards is the EPA Technical
Project Officer (see below).
The complete report, entitled "Evaluation of the Implementation of Operations and
Maintenance Programs in New Jersey Schools," (Order No. PB97-181424; Cost:
§25.00, subject to change) will be available only from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: 703-487-4650
The EPA Technical Project Officer can be contacted at:
Sustainable Technology Division
National Risk Management Research Laboratory
U.S. Environmental Protection Agency
Cincinnati, OH 45268
United States
Environmental Protection Agency
Center for Environmental Research Information
Cincinnati, OH 45268
Official Business
Penalty for Private Use $300
BULK RATE
POSTAGE & FEES PAID
EPA
PERMIT No. G-35
EPA/600/SR-97/063
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