United States
             Environmental Protection
             Agency
             Office of Pesticides
             and Toxic Substances
             Washington, D.C. 20460
EPA 560/13-80-039
September 1980
&EPA
             Pesticides and Toxic Substances
Identifying
Potential Asbestos Exposures
in Schools:

The
Montgomery County
Experience

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                                 DISCLAIMER

     This report was prepared under contract to an agency of the United
States Government.   Neither the United States Government nor any of its
employees, contractors, subcontractors, or their employees makes any war-
ranty, expressed or implied, nor assumes any legal liability or responsibil-
ity for any third party's use or the results of such use of any information,
apparatus, product, or process disclosed in this report, nor represents that
its use by such third party would not infringe privately-owned rights.
     Publication of the data in this document does not signify that the
contents necessarily reflect the joint or separate views and policies of
each sponsoring agency.  Mention of trade names or commercial  products  does
not constitute endorsement or recommendation for use.

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                           Identifying
  Potential Asbestos Exposures
                          in  Schools:

        The Montgomery  County
                           Experience
                                        by
                 T. L Wright* and E. E. Logue**

" Montgomery County Combined General Health District,
   Dayton, Ohio 45422. ** Research Triangle Institute,
        Research Triangle Park, North Carolina 27709

                       Contract No. 68-015848
                    Task Manager: Cindy Stroup
             Contract Project Officer: Joseph Carra
                 Design and Development Branch
                    Survey and Analysis Division
          Office of Pesticides and Toxic Substances
                 Environmental Protection Agency
                       Washington, D.C. 20460
                  EPA Report No. 560/13-80-039
                             September 1980
     111

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IV

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                           TABLE OF CONTENTS


                                                                      Page

Acknowledgments	    vi

List of Tables	   vii

Introduction 	     1

Chronology of Events 	     2

Inspection Activities  	     4

Sampling Activities	     4

Analysis of Bulk Samples	     5

Potential Exposure Assessments .  .  	     8

Recommendations	     9

References	    12

APPENDIX A:  Explanatory Letter and School Information Form	   A-l

APPENDIX B:  Asbestos Exposure Scoring Procedure 	   B-l

APPENDIX C:  Cover Letter Sent to Schools Without Asbestos
             Problems	C-l

APPENDIX 0:  Cover Letter and Supporting Documentation Sent
             to Schools with Asbestos Problems 	   D-l

APPENDIX E:  News Releases and an Editorial Concerning the
             Health District's Asbestos Program	E-l

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                               ACKNOWLEDGMENTS

     The authors greatly appreciate the cooperation of Mr. Larry Longanecker
and Ms.  Cindy Stroup of the U.S. Environmental Protection Agency, Washington,
D.C.,. for their comments on earlier drafts of this report, and Dr.  Tyler
Hartwell and Mr. Gene Brantly of the Research Triangle Institute for technical
consultation.
                                     VI

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                            LIST OF TABLES
Tables                                                           Page

  1       Comparison of Polarized Light Microscopic (PLM)
          Analysis and X-Ray Diffraction (XRD) Analysis
          of Split Bulk Samples for Asbestos 	     7
          Square Footage of Asbestos-Containing Material
          By School and Potential Exposure Scores	    10

          Estimated Abatement Costs by School and Abatement
          Procedure	    11

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            IDENTIFYING POTENTIAL ASBESTOS EXPOSURES IN SCHOOLS:
                      THE MONTGOMERY COUNTY EXPERIENCE
INTRODUCTION
     The Environmental Protection Agency (EPA) has established a guidance
program to help State and local officials identify and control potential
asbestos exposures in schools (1).  This guidance program was established
because of the increasing amount of data supporting the existence of a
causal relationship between asbestos exposure and asbestosis and cancers  of
the lung, chest, abdominal lining, and gastrointestinal tract (2).
     Officials of the Montgomery County (Dayton, Ohio) Combined General
Health District were informed about the potential health problem in their
schools, and they completed a survey of all schools within their jurisdic-
tion.   The survey provided estimates of the number of students potentially
exposed to airborne asbestos fibers and of the potential costs generated  by
different asbestos-abatement procedures.  The experience of the Montgomery
County Combined General Health District (MCCGHD) should be of interest to
other local health and school officials concerned about potential asbestos
exposures in schools.
     The Montgomery County Health District has a staff of over 300 persons,
and the Health Division's Bureau of General Services has a tradition of
conducting school inspections.  Thus, there were individuals within the
MCCGHD who were familiar with the schools' personnel and physical facilities.
The presence of a Bureau of Engineering, which could provide laboratory
support to an asbestos identification and control program, further increased
the probability of a satisfactory effort.  But the 2,000 hours eventually
spent by the MCCGHD in their school asbestos project strained the limits  of
an organization accustomed to spending 400 hours per year on school-related
activities.

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CHRONOLOGY OF EVENTS
     Montgomery County officials first became aware of a potential asbestos
exposure problem on March 15, 1979, at a meeting where a State asbestos
coordinator described the voluntary EPA guidance program.   Fifteen days
later, the Director of the Environmental Health Division of the MCCGHD met
with people from the General Services and Engineering Bureaus to set objec-
tives and allocate responsibility.
     The first order of business was to identify the target population of
schools.  Within the MCCGHD, there are approximately 200 public schools,
which are organized into 16 separate school districts, each managed by a
superintendent and a local board of education.  The existence of parochial
schools and special schools, which needed to be surveyed,  increased the size
of the task at hand.   It was decided that some basic descriptive information
about each school in the target population was needed.  This information
included the year of construction for each school, the dates of any major
repair work or remodeling, the existence of files containing school plans
and material specifications, and the possibility of future major repair work
or remodeling.
     On April 16, the District's Division of Environmental Health sent an
explanatory letter and a school information form to all school superinten-
dents.  The purpose of this communication was to minimize  possible over-
reaction to a scheduled public asbestos-in-schools meeting in nearby Columbus
and to collect the needed descriptive information.  The letter and school
information form are included in Appendix A.
     One month later the EPA sponsored a training meeting  concerning the
survey methodology and the EPA procedure for obtaining an  asbestos exposure
score.  The scoring procedure is described in detail in Appendix B.  The EPA
procedure requires raters to estimate (1) the asbestos-containing material's
general condition, (2) the extent of water damage, (3) the quantity of
material exposed, (4) the degree of accessibility, (5) the level of human
activity present, (6) the impact of moving air plenums, and (7) the material's
friability.   EPA's recommendation for estimating asbestos  exposure scores is
based upon the assumption that the percentage of asbestos  present in the
material and the seven factors listed above are predictive of cumulative

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asbestos air levels.   The EPA is reviewing available data to determine if
this assumption is reasonable.
     On May 21, the survey methodology and the scoring procedure were field
tested by supervisory personnel in several schools.   Three days later, the
experience of the field test was presented to the rest of the staff, and the
school superintendents were notified that the survey was about to begin.   By
June 5, the survey was underway.  Supervisors accompanied field staff during
the initial part of the survey to increase the reliability of the asbestos
exposure score data.
     In July, personnel from the Bureaus of Engineering and General Services
were sent to the McCrone Institute in Chicago for training in the analysis
of the bulk samples being collected by field personnel.  By July 31, a
survey of 195 schools was completed; over 600 bulk samples had been col-
lected.  On September 10, those schools determined to be "positive for
asbestos" were reevaluated by supervisors and staff.   On September 18, the
results of the entire survey were reported to the director of the Environ-
mental Health Division.
     On September 19, letters and supplementary materials were sent to the
school superintendents.  The superintendents of schools without asbestos
"problems" were sent a cover letter (see Appendix C) and a copy of the
Health District's report on all schools.  The superintendents of schools
with asbestos "problems" were sent a more detailed cover letter and support-
ing documentation describing the extent of the asbestos problem in their
schools (see Appendix D).  This supporting documentation included a table
identifying the problem areas within the affected schools; the square foot-
age of the material involved; ratings of material condition, water damage,
accessibility, and friability; total asbestos exposure scores; and a column
stating the recommended action.  A second table presented the square footage
of asbestos-containing materials in 23 schools by asbestos exposure scores.
A third table described the "cutpoints" that were used to classify asbestos
exposure scores.  Supporting documentation included copies of the rating
forms, from which asbestos exposure scores were calculated, and the labora-
tory reports, which indicated the presence of asbestos fibers in individual
bulk samples.

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     On October 29, representatives of Montgomery County Schools and the
Montgomery County Combined General Health District held a joint news con-
ference to present the findings of the asbestos-in-schools survey to the
public.  On November 1, an editorial praising the efforts of the Montgomery
County Schools and Health District was broadcast on a local television
station.   The news releases and the editorial are included in Appendix E.
On December 3, EPA Region V sent a letter to the Montgomery County Health
Commissioner suggesting that Montgomery County's efforts in identifying and
controlling potential asbestos exposure in schools might serve as an example
for other counties and cities.
INSPECTION ACTIVITIES
     The registered sanitarians* employed by the Health District for the
asbestos-in-schools survey had undergraduate degrees in a physical science
or environmental engineering; thus, they had some experience in collecting
data in a systematic manner.  Moreover, these sanitarians were familiar with
the school buildings from past inspections for other purposes.   Maintenance
personnel from each school accompanied the sanitarians, who were instructed
to examine all rooms, boilers, and pipe coverings.  After the survey was
underway, it was decided that too much effort was being spent on boilers and
pipe coverings, and the staff was told to concentrate upon suspicious spray
materials applied to vertical or horizontal surfaces in rooms or hallways.
     A draft of the EPA asbestos scoring system was modified and used to
characterize suspicious material in a given location (see Appendix B).   The
modifications of the EPA rating procedure consisted of slightly different
codes for some of the more extreme empirical situations.   Health District
personnel concluded that the coding scheme described in the initial  draft of
the asbestos-scoring algorithm was too "crude," in the sense that informa-
tion was being lost by grouping phenomena in broad categories.
SAMPLING ACTIVITIES
     The persons assigned to collect bulk samples of suspect friable materi-
als were familiar with existing EPA guidelines concerning friable material
     ^Sanitarians are a professionally registered class in the State of Ohio
as provided under Chapter 4736, Ohio Revised Code.

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sampling (1).  An effort was made to adhere to these guidelines.   Speci-
fically, "one bulk sample was taken for approximately every 5,000 square
feet of material having the same color and texture."  Additional  samples
were taken from suspect areas of less than 5,000 square feet if materials of
different color or texture were found, and this encouraged oversampling at
the start of the survey (samples of every pipe covering were being collected).
Supervisors recognized the implications of this enthusiastic initial sampling,
and they directed the inspectors to concentrate upon ceiling and wall cover-
ings, which were more likely to release asbestos fibers into the air.
Materials that were highly friable and already damaged were always sampled.
Undamaged materials of low friability were sampled less frequently.
     Plastic 35-mm film canisters were used to remove and contain bulk
samples taken from friable materials.  The open end of the canister was
twisted into the soft materials.  A knife was used to scrape or cut out a
small sample of hard materials, which were then deposited in canisters.
Each container was labeled with a numeric code that identified the school
and the area where the sample was collected.   The sample ID number,  the date
the sample was collected, the area sampled, and the school where the sample
was taken were recorded separately.
ANALYSIS OF BULK SAMPLES
     Personnel from the Montgomery County Bureaus of Engineering and General
Services,. who had received special training at the McCrone Institute in
Chicago, analyzed the bulk samples.  For the majority of samples, polarized
light microscopy with dispersion staining was the analytical technique used
to estimate the percentage of asbestos.  Thirty samples were also sent to a
laboratory run by the Ohio Department of Health for x-ray diffraction analysis.
X-ray diffraction analysis is recommended when a second analytical technique
is necessary to confirm an analysis by polarized light microscopy.  A colori-
metric (chemical) procedure [recently proposed by the National Institute for
Occupational Safety and Health (NIOSH)] for the preliminary identification
of asbestos in bulk samples was used to complement the internal quality
control efforts of the District laboratory.  This NIOSH procedure has an
estimated specificity (probability of detecting a truly negative observa-
tion) of 100 percent.

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     In general, the identification of asbestos by means of polarized light
microscopy with dispersion staining is based upon the difference between the
refractive index of the suspect fiber and the index of the liquid medium in
which the fiber is immersed.   When chrysotile asbestos is immersed in the
appropriate liquid, the fibers will transmit a blue color if they are perpen-
dicular to polarized light and a magenta color if they are parallel  to it.
Amosite asbestos immersed in 1.680 refractive index oil transmits magenta if
the fibers are perpendicular to polarized light; it transmits a golden
yellow color if the fibers are parallel.   The specific procedure used by
Montgomery County laboratory personnel is similar to that detailed in McCrone
et al., Polarized Light Microscopy (3).   A large portion of the bulk sample
was divided into three parts, and a subsample was selected from each.  The
three subsamples were then combined to form the main sample from which
material was mounted.
     Material  was immersed on a microscope slide in Cargille liquid of
refractive index 1.550 and covered with a cover slip.  Fibers present were
examined to determine birefringence, angle of extinction, fiber morphology,
and sign of elongation.   Identification of more than one asbestos type in a
bulk sample required the preparation of additional slides with the appro-
priate liquid.
     The quantity of asbestos present in a given sample was estimated by
comparing the appearance of the unknown sample, with the appearance of a
known "standard" sample of asbestos-containing material.   The appearance of
the unknown sample is first characterized by noting the quantity of asbestos
fibers showing the appropriate colors in relation to quantities of other
fibers and materials present.  The appearance of the standard sample with
its known percentage of asbestos is then compared with the initially charac-
terized unknown sample.   If the microscopist judges that there is a greater
(or lesser) percentage of asbestos in the unknown sample than in the stand-
ard sample, the initial  estimate of the percentage of asbestos present in
the unknown sample is revised upwards (or downwards).  The District labora-
tory in Montgomery County compared their unknown bulk samples against a
standard sample which contained 5 percent asbestos.   The standard sample was
analyzed by both PLM and x-ray diffraction procedures.   All  samples  estimated
as less than 10 percent asbestos were reanalyzed by Montgomery County personnel

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because the reliability of quantitative asbestos estimates is inversely
related to the amount truly present.
     Table 1 presents a comparison of polarized light microscopic (PLM)
analysis and x-ray diffraction (XRD)  analysis of split bulk samples for
asbestos.   The large range of values  associated with certain PLM obser-

     TABLE 1.   COMPARISON OF POLARIZED LIGHT MICROSCOPIC (PLM) ANALYSIS
   AND X-RAY DIFFRACTION (XRD) ANALYSIS OF SPLIT BULK SAMPLES FOR ASBESTOS
Sample
number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
PLM
analysis (%)a
5-20
10 - 25
10 - 30
10
=5
10 - 20
5
1 - 30
5 - 15
5 - 25
<5
<5
5 - 10
s5
35
5
10
25
<5
5 - 10
10
10 - 30
-
5-10
<5
20 - 40
50 - 75
5-20
<5
5 - 10
XRD .
analysis (%)D
4.5
8.9
N/D
N/D
4.7
N/D
6.2
N/D
N/D
N/D
N/D
4.0
5.9
8.6
N/D
2.5
5.6
8.4
N/D
8.6
4.9
4.9
6.6
4.7
3.8
4.1
4.1
2.6
8.4
3.6
N/D = not detectable (<1 percent asbestos).
aPolarized light microscopy with or without dispersion staining.   Health
 District laboratory.
 X-ray diffraction analysis.   Ohio Health Department laboratory.

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vations is partly a result of instructions to the microscopists to report
their results in ranges compatible with the EPA scoring procedure.  The EPA
scoring procedure necessitates the grouping of PLM results into three cate-
gories:  trace amounts to 1 percent asbestos, more than 1 percent up to
50 percent asbestos, and more than 50 percent asbestos.  Nine PLM observa-
tions, which were positive (greater than 1 percent) for the presence of
asbestos fibers, were subsequently reported to be negative when XRD analysis
was performed on the second half of the split bulk sample.  These data
suggest that either the bulk samples were not sufficiently "homogenized"
prior to the splitting or that one of the analysis techniques is not very
reliable.   Yet all PLM analyses were confirmed by other recognized labora-
tories.  These data suggest that the XRO protocol used in the above compari-
son yielded a number of false negatives.
     The EPA has established a program to identify commercial laboratories
experienced in the analysis of bulk samples.   The program is described in a
document entitled "Asbestos-Containing Materials in School Buildings:  Bulk
Sample Analysis Quality Assurance Program" (EPA Report No. 560/13-80-23,
August 1980).  The EPA has also supported the development of a PLM labora-
tory protocol with a more systematic procedure for estimating the asbestos
content of bulk samples.   This protocol is described in a report entitled
"Interim Method for the Determination of Asbestoform Minerals in Bulk Insula-
tion Samples" (Research Triangle Institute).
POTENTIAL EXPOSURE ASSESSMENTS
     The Health District collected over 600 bulk samples of suspect materials
in the course of surveying 195 schools.  Sprayed or trowelled-on, friable,
asbestos-containing materials were found in 23 schools, where 75 positive
(greater than 1 percent) bulk samples were collected.   The 23 schools con-
tained 14,883 students and approximately 488,000 square feet of asbestos-
containing material.   Five of the 23 schools  had at least one area with an
asbestos exposure score of "50" or greater.   These five potential problem
schools contained 5,319 students and approximately 33,000 square feet of
asbestos-containing materials.
     Asbestos exposure scores were calculated for each of the sampling areas
from which the 75 positive samples were selected.   To  obtain the scores, the

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ratings for material condition, water damage, exposed surfaces, accessibility,
activity, and the presence of air plenuns were summed, and the sum was
multiplied by the product of the friability rating and the coded asbestos
percentage level obtained from the bulk sample analysis.   The sampling areas
were divided into five groups based upon total asbestos exposure scores and
the values of certain components, which contribute to total asbestos exposure
scores.  Group 1 consisted of those areas with scores equalling less than
10.  Group 2 consisted of those areas with scores between 10 and 25, a
friability code equalling I, and repairable water damage or material condi-
tion.   Group 3 had scores between 10 and 50, friability codes equalling 2 or
3, a water damage code equalling 0, and an accessibility code equalling 1.
Group 4 consisted of those areas with total scores between 10 and 50 and an
accessibility code equalling 3 or water damage beyond repair.  Group 5
consisted of those areas with total scores greater than 50.
     Table 2 presents the square footage of asbestos-containing materials in
the 23 "positive" schools by asbestos exposure score categories.  Note that
several schools have asbestos areas with different asbestos exposure cate-
gories.  Table 3 presents estimated abatement costs by school and abatement
procedure.  These costs were estimated by multiplying the total square
footage of asbestos-containing materials in a given school by.two cost-per-
square-foot quotations obtained from contractors willing to build enclosures,
perform encapsulation, or engage in removal activities.  More realistic cost
estimates can be obtained by considering the possibility that a combination
of abatement procedures is more appropriate for those schools with a series
of asbestos areas with differing exposure potentials.  Also, it should be
noted that unit costs for asbestos abatement procedures should decrease as
contractors acquire more experience with a given procedure.
RECOMMENDATIONS
     Although 90 percent of the schools in the jurisdiction of the Montgomery
County Combined General Health District were built during the period when
asbestos was widely used, only 12 percent yielded samples that had a measur-
able level of asbestos.  But the presence of 12,000 students in schools with
nearly one-half million square feet of asbestos-containing materials presented
school and health officials with a problem, which was not easily solved.

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     TABLE 2.  SQUARE FOOTAGE OF ASBESTOS-CONTAINING MATERIAL BY SCHOOL
                        AND POTENTIAL EXPOSURE SCORES
Square footage of asbestos-containing material
School
A
B
C
D
E
F
G
H
I
J
K
L
M
N
0
P
Q
R
S
T
U
W


students <10
1,110
570
427
2,275
361
2,478
633
625
116
760
620
420
338
417
275
1,497
375
350
181
563
314
158
Totals 0
Potential exposure
10-253
71,395
-
6,373
49,574
-
-
507
4,778
3,267
13,514
6,576
-
-
-
11,760
-
-
-
-
-
-
-
184,028
10-50b
9,680
21,105
-
12,702
-
-
• -
-
-
-
-
3,808
29,000
19,630
1,580
64,456
22,823
25,458
1,328
19,465
12,389
6,408
249,832
scores
10-50C
3,501
-
1,204
2,827
946
-
-
-
6,954
-
-
-
-
-
-
1,868
-
1,697
-
-
-
2,643
21,640

>50
-
-
-
-
13,922
5,877
-
-
-
-
-
5,153
-
-
-
4,232
-
-
-
3,560
-
-
32,744
Totals
84,576
21,105
7,577
64,103
14,868
5,877
507
4,778
10,221
13,514
6,576
8,961
29,000
19,630
13,340
70,556
22,823
27,155
1,328
23,025
12,389
9,051
488,244
 Total potential exposure score between 10 and 25, low friability, and repair-
 able water damage or material condition.
 Total potential exposure scores between 10 and 50, moderate to high friability,
 but no water damage or high accessibility.
cTotal potential exposure scores between 10 and 50 and high accessibility or
 water damage.

     What is the relationship between EPA's asbestos exposure scores and
cumulative asbestos exposure in terms of the time-weighted mass concen-
tration (nanograms per cubic meter) of asbestos in the air inside a particular
room?  What is the increment in disease risk associated with a specified
cumulative asbestos exposure?  Since the data that could suggest answers to
these questions were not available to the Health District when the asbestos-
in-schools survey was completed, the Health District made its decisions
                                      10

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TABLE 3.
School
A
B
C
0
E
F
I
L
M
N
0
P
Q
R
S
T
U
W
Totals
ESTIMATED ABATEMENT COSTS BY SCHOOL AND ABATEMENT PROCEDURE
Enclosure
13,358
29,125

17,529



5,255
40,020
27,089
2,180
88,949
31,496
35,132
1,833
26,862
17,097
8,843
344,768
- 26,620
- 58,039

- 34,931



- 10,472
- 79,750
- 53,983
- 4,345
-177,254
- 62,763
- 70,010
- 3,652
- 53,529
- 34,070
- 17,622
-687,038
Encapsulation
22,651
49,386

29,723



8,911
67,860
45,934
3,697
150,827
53,406
59,572
3,108
45,548
28,990
14,995
584,607
- 35,429
- 77,244

- 46,489



- 13,937
-106,140
- 71,846
- 5,783
-235,909
- 83,532
- 93,176
- 4,860
- 71,242
- 45,344
- 23,453
-914,385
Removal
38,817

4,828
11,336
59,621
23,567
27,886
20,664



24,461

6,805

14,276

10,598
218,080
- 68,534

- 8,524
- 20,015
-105,265
- 41,609
- 49,234
- 36,483



- 43,188

- 12,015

- 25,205

- 18,712
-385,039
 Total costs are based upon cost-per-square-foot quotations obtained from
 two contractors.   "Enclosure" refers to the construction of a physical
 barrier.   "Encapsulation" refers to coating friable materials with a sealant.

about recommended abatement procedures by assuming that friability and the
condition of the suspect material were the most important factors determining
the release of asbestos fibers into the air.  Accessibility of materials was
given more weight in the decisionmaking process when there was visible
evidence of vandalism, which would probably increase true cumulative exposures.
     No abatement procedures were recommended for those areas with potential
exposure scores between 10 and 25, low friability, and good material condi-
tion.   If minor damage was present, repair was recommended.
     Although the survey located sprayed-on asbestos in only 12 percent of
the schools in the Health District's jurisdiction, asbestos materials in the
form of insulation wrap used to cover pipes and boilers were found in nearly
all schools.  It was assumed that these materials could present an occupa-
tional hazard to maintenance personnel.  It was recommended that asbestos
insulation wrap in student use areas should be replaced.   Asbestos ceiling
                                      11

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tile was only considered a problem when it was extensively damaged from
water or physically abused to the extent that the adhesive properties of the
tile were destroyed.
     The experience of the Montgomery County Combined General Health District
suggests that the identification of potential sources of asbestos exposure
in schools is feasible, but careful attention must be paid to the design of
the survey, the analysis of bulk samples, and the interpretation of the
survey results.  The reliability of the data collected during an inspection
should be systematically checked by having independent inspectors duplicate
part of the work of previous inspectors.  The results of this test-retest
should be reported.   A standard protocol should be followed by the labora-
tory analyzing the bulk samples.  Analyses of split bulk samples should be
duplicated to establish the reliability of the bulk-analysis procedures.
The results of these duplicate analyses should be reported.  A number of the
bulk samples should then be analyzed by a "criterion" procedure so that the
validity of the "standard" procedure is known.  Asbestos exposure scores
should be interpreted by examination of published data concerning the rela-
tionship between (potential) asbestos exposure scores and actual exposure
via increased air levels of asbestos.   Decisions concerning appropriate
abatement procedures should be made such that costs and asbestos (air level)
exposures are minimized.
     The EPA is preparing a guidance document to be used by school systems
in conducting surveys for asbestos-containing materials.   This document is
based on traditional statistical principles and has been field tested in
Montgomery County, Ohio.  The guidance document, entitled "Asbestos-Containing
Materials in School  Buildings:   A Guidance Document for Asbestos Analytical
Programs" (EPA Report No.  560/13-80-017), will be available in November 1980.
REFERENCES
1.    Asbestos-Containing Materials in School  Buildings:   A Guidance Document,
     Part I.   United States Environmental Protection Agency, Office of Toxic
     Substances, Washington, D.C., March 1979.
2.    Selikoff, I.  J., and E. C.  Hammond.  Health Hazards of Asbestos Exposure.
     Annals of the New York Academy of Sciences, 330:  December 14, 1979.
3.    McCrone, W. C. , McCrone, L.B., and J.  G. Delly.   Polarized Light Micro-
     scopy.   Ann Arbor Science:   Ann Arbor, Michigan, 1978.
                                      12

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                  Appendix A






Explanatory Letter and School Information Form
                      A-l

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A-2

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•.•?OBEHT A. VOGEL. M.D.
  HEALTH COMMISSIONER
                Appendix A
           MONTGOMERY  COUNTY
COMBINED GENERAL  HEALTH DISTRICT
                                 COUNTY GOVERNMENT PLAZA
                                  431 WEST THIRD STREET
                                   DAYTON. OHIO 43422
DIVISION OF ENVIRONMENTAL HEALTH
  DAVID B. PEDE.N, M.P.H.. DIRECTOR
   913 - 223-4382
  BOARD OF HEALTH
DAVID ULRICH. D.D.s. -
      PRESIDENT
MRS. MARTHA CARRICK .
      VICE.PRBSIOENT
HERMAN AbROMOWITZ. M.D.
MRS. MARIE DAUCMSRTY
JOHN DOAN
MRS. VCROREE HARRIS
ROBERT HOCK
W. J. LEWIS. M.D.
EDWARD RAUSCH
        TO:     ALL SCHOOL SUPERINTENDENTS OF.SCHOOL
                DISTRICTS WITHIN  MONTGOMERY COUNTY

        FROM:   DAVID B. PEDEN, M.P.H.
                DIRECTOR
                DIVISION OF ENVIRONMENTAL HEALTH

        DATE:   APRIL 16, 1979
        On or before April 29,  1979,  superintendents  of  all school
        districts  in Ohio will  be  receiving documents  from the United
        States  Environmental Protection Agency.

        These documents concern the potential health  risks to school
        children,  school staff,  and the general public from possible
        exposure  to asbestos in schools.

        Although  it is not our  intent to downplay  the  health hazard
        from exposure to asbestos,  it should be noted  that (1) asbestos
        has not been used in schools  as a building material since 1973
        and therefore exposure  risks  do not even exist in schools
        constructed after this  period,  (2) schools constructed prior
        to 1973 may or may not  have an exposure potential since asbes-
        tos may or may not have been  used in their construction, and
        (3) in  those schools where  asbestos was used,  the exposure
        potential  (and health risk) is directly dependent upon numerous
        additive  and multiplicative factors.

        Therefore, there is- no  real or immediate danger  in most cases.

        However,  in order to determine if this problem does exist in
        your schools, the Montgomery  County Health District staff will
        evaluate  the exposure potential, if any, of the  schools within
        your school district during May as we conduct  our usual semi-
        annual  inspection.  IT  IS  IMPORTANT TO NOTE THAT IF A PROBLEM
        DOES EXIST, IT CAN BE CORRECTED.

        Preliminary to our evaluation, we ask that the enclosed question-
        naire be  completed and  returned to our offices as soon as pos-
        sible.  The information provided is essential  and will enable us
        to expedite our evaluation.  Our evaluation cannot begin without
        this information.

        Should  you have any questions, or if we can be of other as'sis-
        tance,  please call Terry Wright at 225-4446.

        DBP/TLW/njr
        Enclosure
                                      A-3

-------
                                        PLEASE COMPLETE AND RETURN THIS INFORMATION TO:
                                                                                          Terry Wright
                                                                                          Montgomery County Health District
                                                                                          US>1 West Third Street
                                                                                          Dayton, Ohio
     SCHOOL DISTRICT:,
     SUPERINTENDENT:
NUMBER OP SCHOOLS
IN YOUR DISTRICT:
                                                           TELEPHONE
NAME
OF
SCHOOL










PRINCIPAL'S
NAME










rELEPHONE
NUMBER










YEAR
OF
CONSTRUCTION










DATES OF ANY
MAJOR REPAIR WORK
OR REMODELLING:



• • '






DO YOU HAVE THE
PLANS AND MATERIAL
SPECIFICATIONS ON FILE
FOR CONSTRUCTION?






,



IS THERE ANY REMODELLIKi
OR MAJOR REPAIR WORK
PLANNED FOR THIS SCHOOL
IN THE NEAR FUTURE?










 1.

 3.
 U.
 5.
 6.
 7.
 8.
 9.
10.

-------
            Appendix B






Asbestos Exposure Scoring Procedure
                 B-l

-------
B-2

-------
                              Appendix B



              Components of the Potential Exposure Score
Factor
Range or Extent
1.   Material Condition       None




     (Deterioration/Damage)




                              Moderate; small areas
                              Widespread; severe; pieces dislodged
2.   Water Damage
None
                              Minor
                              Moderate to major








3.   Exposed Surface Area     Not exposed.  Located above suspended




                              ceiling.  None visible without removing




                              panels or ceiling sections.








                              10% or less area exposed








                              10% to 100% area exposed
                                   B-3

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4.    Accessibility
Not accessible
                              Low:  Rarely accessible









                              Moderate to high:  Access may be frequent









5.   Activity and Movement    None or low:  Libraries, most classrooms









                              Moderate:  Some classrooms, corridors









                              High:  Some corridors and cafeterias,




                              all gymnasiums









6.   Air Plenum or Direct     None




     Air Stream




                              Present









7.   Asbestos Content         Trace to 1%




     (total % present)




                              1% to 5%









                              5% to 50%









                              50% to 100%
                                  B-4

-------
8.   Friability               Low friability.  Difficult but possible




                              to damage by hand.









                              Moderate friability.  Fairly easy to




                              dislodge and crush.









                              Highly friable.  Fluffy, spongy, flaking,




                              pieces hanging.
                 Potential Exposure Score Calculation
Factor                        Code
1.   Material Condition	   (0, 2, 5)
2.   Water Damage             	   (0, 1, 2, 3)
3.   Exposed Surface          	   (0, 1, 4)
4.   Accessibility            	   (0, 1, 3)
5.   Activity and Movement    	   (0, 1, 2)
6.   Air Plenum	    (0, 1, 2)
                                  B-5

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SUM  [1+2+3+4+5+6]
7.   % Content                	   (0, 2, 3, 4)
8.   Friability               	   (1, 2, 3)
PRODUCT [7x8]
EXPOSURE NUMBER = PRODUCT X SUM =
                                  B-6

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                                                       Hallway,Cafeteria,Classroom No., etc.
                                                                                                 Date
SCHOOL
                                                       Sample Material
PERSON CONTACTED
        FACTOR
                         Name                          Sample Number Assigned

                                         TABLE I,  FACTOR SCORES
                             RANGE OR EXTENT     SCORE           FACTOR
                  RANGE OR EXTENT   SCOI
E.   Material condition
    (adhesive,  cohesive}
    deterioration or
    damage)
I. i  Water damage
E.   Exposed surface area
    (from the floor
    looking up)
    Accessibility
                          None	 . .	'	0
                          Moderate;  small areas....2
                          Widespread, pieces dis-
                          lodged, evident flaking
                          and crumbling	5
Activity or
Movement
 None.;	 0       VI
 Minor	1
 Moderate to major..	2-3 \

 None-sealed by seldom           VII,
 violated suspended
 ceiling	0
 10% or less exposed	1
 10-100% exposed	4

. Not accessible	0     VIII,
 Low-mostly unusual
 maintenance	1
 Moderate to high-
 access may be frequent...3 I
                                                                Air plenum
                                                                or airstream
                                                                Asbestos
                                                                content
                                                                Friability
None or low
Libraries, non-student
use areas	0
Moderate-classrooms,
corridors...	1
High-some corridors
cafeterias,
gymnasiums	2

None	0
Present	1-2
              1%-30%	2
              30%-60%	3
              60%-100%	4
              Not friable to low
              friability-difficult
              to penetrate with
              pencil	
              Moderate friability-
              can push fingers into
              it	
                                                                              Highly friable-
                                                                              cottony, spongy, can
                                                                              easily push hand into
                                                                              it	

-------
B-8

-------
                      Appendix C
Cover Letter Sent to Schools Without Asbestos  Problems
                          C-l

-------
C-2

-------
                             Appendix C
                         MONTGOMERY  COUNTY
             COMBINED GENERAL  HEALTH  DISTRICT
yy .3	a  ix.
^ijnr
&
                                   COUNTY GOVERNMENT PI.AZA
                                    431 WEST THIRD STREET
                                     DAYTON. OHIO 4SAZ2
DfYISION OF ENVIRONMENTAL HEALTH
  DAVID 3. PCao*. M.P.H., Dm«cro>«
   513-225-1^^3
                                                              MWAH Ae»O..OW,TZ. M.D.
                                                              M«». MARIS DAUCHERTY
                                                              JOHN DOAH
                                                              MRS. VEHO>»«e HAB»I»
                                                              w. j. LEWIS. M.o.
                                                              EOWABO RAUSCH
                                                              CHABUSS F. WH.CHSO. JB.. D.O.
September 19,  1979
Bill M. Stephan, Superintendent
Brookville Schools
325 Simmons Street
Brookville, Ohio 45309

RE: Asbestos Survey

Dear Mr. Stephan:

The school asbestos survey of all school districts in Montgomery County
has been concluded.  As you know,  this survey was part of the United
States  Environmental Protection Agency (USEPA) nationwide voluntary
school asbestos program, and its purpose was to identify potential health
risks from sprayed-on asbestos containing material.

All schools within the Brookville School District were inspected for sprayed-
on asbestos materials, and USEPA assessment procedures were followed.
However, no  schools within your district have been identified as  having
sprayed-on asbestos materials used in their construction.

Sprayed-on asbestos materials were found in every school district within.
the jurisdiction of the Health District but four.

Although located in non-student use areas, other asbestos containing materials
were found in nearly all schools, however,  and if damaged may present an
occupational hazard to maintenance personnel and others who have access to
these areas.   These areas involve primarily boiler rooms where asbestos
insulation wrap was used on pipework and boiler jackets.  In addition,  heating
pipes with asbestos wrap in student use areas were found in schools, and this
material should be replaced with a non-asbestos insulating material.

Finally, many schools contained asbestos ceiling tile.  Asbestos  ceiling tiles
are considered a problem only when extensively damaged from water or
physically abused to the extent that the adhesive properties of the tile are
destroyed.  These conditions will not occur in schools with an adequate main-
tenance program of replacement of damaged tiles.
                                 C-3

-------
Mr.  Bill M.' Stephan, Superintendent
September 19,  1979
Pase 2
Should either of these conditions be found in any of your schools, adequate
maintenance procedures .should be followed.

A copy of the Health District's report on all schools within its jurisdiction is
enclosed for your information.

If you have any questions concerning  this report or should further assistance
be necessary, please call at 225-4446.
Sincerely,
Terry LV Wright, M P. H.
Supervisor
Bureau of General Services

TLW/dlg

Enclosures

cc: David B.  Peden, M. P. H.
    Director
    Division of Environmental Health
     Raymond Hopper
     Superintendent
     Montgomery County Schools
                                C-4

-------
               Appendix D

Cover Letter and Supporting Documentation
 Sent to Schools with Asbestos Problems
                   D-l

-------
D-2

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KOBE-rr' A. VOGEL. M.O.
             Appendix D

          MONTGOMERY  COUNTY
COMBINED  GENERAL  HEALTH  DISTRICT
                               COUNTY GOVERNMENT PLAZA

                                431 WEST THIHD STREET
                                 DAYTON. OHIO -iSAZZ
DIVISION OF ENVIRONMENTAL HEALTH

  DAVIO 8. pT.OfH, M.p. H.. DlHHCTOH

   313 - 7.23-1443
   BOARD OP HEALTH

OAVIO ULKICM. O.D.S. -
        PRESIDENT
MAS. MARTHA CARRICK .
        VICE.PRHIOSNT
HERMAN ABBOMOWirZ. M.D.
MRS. MARIS OAUCM&RTY
JOHN DOAN
MRS. VEPORF.E HARRI»
W. J. LEWIS. M.D.
EOWASO RAUSCH
CHAHLCS F. V/ILCHBR. Ja., D.O.
       September 19, 1979
       Lowell C. Draffen, Superintendent                           '  .:
       Valley View Schools
       64 Comstock Avenue              .
       Germantown, OH  45327

       RE:  Asbestos Survey

       Dear Dr.  Draffen:                                  -         •

       The school asbestos survey of  all  school  districts  in  Montgomery
       County has been concluded.  As  you  know,  this  survey was  part of
       the United States Environmental  Protection  Agency  (USEPA)  nation-
       wide voluntary school asbestos  program,  and its  purpose was to
       identify potential health risks  from  sprayed-on  asbestos  con-
       taining material.  The  survey  results  are summarized  as  follows."

       Within the total  jurisdiction  of the  Health District,,  twenty-
       three (23) schools or 11.8 percent  were  determined  to  have
       sprayed-on asbestos material  in  them,  and over twelve  thousand
       students may be exposed to the  airborne  release  of  asbestos
       fibers.  Nearly one half million square  feet of  sprayed-on
       asbestos material was used in  the  construction of  these .school s .- =
       All but four school districts  had  one  or more  schools  in  their
       system requiring  abatement action.  Although located  in  non-
       student use areas, asbestos  containing materials were  found in
       nearly all schools, hov/ever,  and if damaged may  present  an
       occupational hazard to  maintenance personnel and others  who
       have access to these  areas.   These  areas involve primarily
       boiler rooms where asbestos  insulation wrap was  used  on  pipework
       and boiler jackets.   In addition,  heating pipes  with  asbestos
       wrap in student  use areas were found  in  many schools,  and tnis
       material should  be substituted with a  non-asbestos  insulating
       materi al.

       Many schools contained  asbestos ceiling  tile.  -Asbestos  ceiling
       tiles are  considered  a  problem only when extensively  damaged
       from water or  physically abused to the extent that the adhssive
       properties of  the tile  are  destroyed.   These conditions  will not
       occur in schools  with  an adequate maintenance program of replace-
       ment of  damaged  tiles.
                                    D-3

-------
Lowell C. Draffen, Superintendent
September 19, 1979
Page 2


Fortunately, almost  all  (98 percent) of the sprayed-on asbestos
material was low  to  moderate  in  friability .(softness)', and-the
material condition relative to adhesive and cohesive properties
v;as inheren tly -better  in materials of lesser friability.  Con-
sequently,  it was possible to make recommendations requiring
abatement actions of lesser degree (and expense).

There is a  distinct  difference between exposure potential and.
exposure problem  as  viewed by the Health District.  Exposure
potential is distinguished from  exposure problem based on
degree of risk with  the  former meaning that existing conditions
or factors  would  not bs  facilitative to the release of fibers
although asbestos is present  in  the material and the latter
meaning  that factors are indeed  present for the release of
fibers and  consequential exposure, there is immediate cause
for concern, and  corrective action is necessary.

The USEPA shares  this  view, and  has determined that the presence
of sprayed  asbestos  containing material does not necessarily
constitute  a risk to the public  health;  only if the material is
flaking  or  damaged is  the asbestos material an immediate cause
for concern.

Accordingly, deferred  action  was  recommended to nine schools
having a combined total  of 184,028 square feet of material
based on exposure values.and  the  above factors, enclosure or
encapsulation was recommended as  a minimum abatement action
for thirteen schools having a combined total of 249,832 square
feet, and 54,384  square  feet  were recommended to be removed
from  twelve  schools.

All schools within the Valley  View School  District  were  inspected
for sprayed-on asbestos material, and  USEPA  assessment  procedures
were followed.

The Health District  has identified three  schools  within  the
Valley View School District to have  sprayed-on  asbestos  material
used in their const ruction:                                 *•*•
                                                            >-
                     1.   Germantown Elementary
                     2.   Germantown Middle
                     3.   Farmersville  Elementary

Asbestos was identified by polarized  light  microscopy  (.PLM)
using dispersion staining technique.   Additional  samples  were
taken and again confirmed as  containing  asbestos;  finally
positive identification was  made  using  x-ray  diffraction  (XRD)..
Use of asbestos was  extensive  in- all  three  schools  with  a
combined total  of 29,051 square  feet  for  these  schools.
                             D-4

-------
Lowell C. Draffen, Superintendent
September 19, 1979   -'
Page 3 •                            '                  •   • •


Exposure problems were only apparent in certain areas of'
Farmersville Elementary and will require abatement action
(Table I).  A combination of removal and encapsulation will  be
necessary for 8,961 square feet of asbestos material  in
Farmersville Elementary.

Five groups of exposure value ranges have been recognized by
the Health District and includes an additional category 10-25
(Table II).  This group acknowledges those areas where conditions
are not facilitative for the airborne release of asbestos fibers
and is based on the premise that if the material is not flaking
or damaged, then there is no exposure problem and threat to  the
public health.  Specifically, this group includes material.
where the exposure value is 10-25, the•friabi1ity of the material
is one or cementitious, and if damaged, it is repairable.

Additional qualification of this group is necessary.   Damage can
only be minor and any water damage must be minimal.  Contrary to
USEPA guidelines, accessible material has also been included in
this group when there is an apparent lack of vandalism.  It  is
absolutely essential that the integrity of the adhesive and
cohesive properties be maintained.  Upon consultation with the
school architect and asbestos contractor, it may very well be
that additional abatement activity is necessary and cost effective.
Therefore, it must be realized that figures in column 10-25   are
maximum figures only and are necessarily inflated while figures
in columns 10-50^ and 10-50C are only minimum.  Accordingly, all
Health District.recommendations are therefore minimum measures
that should require first priority for correction.

Recommended abatement actions are listed in Table III according--:-
to risk assessment.  It is essential to recognize that while
action may be deferred in certain areas of Germantown Elementary
and Middle Schools, a continuous monitoring program must be
established since conditions in these areas may change.

In summary, action may be deferred for 20,090 square feet of
asbestos material in Germantown Elementary and Middle Schools
under the restrictions as outlined in Table III.  Encapsulation
is the minimum recommendation for the classrooms in Farmerfville
Elementary, provided the affected damaged areas can be effectively
removed and repaired and the roof assured against leaking.  The
sprayed-on material in the hallway and cafeteria needs to be
removed.

All asbestos removal projects (demolition) are subject to Title
40, Part 61, U.S. Environmental Protection Agency Regulations
for Asbestos ;. Title 29, Part 1910, U.S. Department of Labor-
Occupational Safety and Health Administration (OSHA) Asbestos
Regulations; and Regulation 150, Hazardous Air Pollution Control
                            D-5

-------
Lowell C.
September
Page 4
Draffen ,
19,  1979
Superintendent
Regulation, Montgomery County Combined General  Health District
(copy enclosed).  Please refer to Appendices A  and C of the
EPA Guidance Document, Part I, for the OSHA and USEPA regulations.

It is imperative that any abatement action undertaken is performed
by qualified personnel.  Therefore , .Chapter 9,  Specifications  and
Requirements for Contractors Guidance Document  is appropriate
for your review.  Personnel unqualified or untrained in asbestos
abatement may create additional  exposure problems both to them-
selves and the public.                              .

Also enclosed are the factor sheets and laboratory documentation.

The Health District will provide additional consultative or
advisory assistance as needed.

If you have any questions concerning this report or should
further assistance be necessary, please call 225-4446.
Sincerely ,
Terry L./Wright, M.P.H.
Supervisor
Bureau of General Services

TLW/njr

Enclosures

cc:  David B. Peden, M.P.H.
     Di rector
     Division of Environmental Health

     Raymond  Hopper, Superintendent
     Montgomery  County  Schools
                            D-6

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                VALLEY.VIEW SCHOOLS
TABLE I.   Summary of areas with.selected factors
          where sprayed-on asbestos was found and
          recommended actions of abatement. •
SCHOOL
. Gcrmantown Elementary
a. hallway
b. classrooms
. German town Middle
_, a. hal Iway
^ b. cafeteri a
, Farmersvi 1 1 e Elementary
a. hallway
b. classroom
c. music room
d . cafeteria
SQUARE FEET MATERIAL WATER
BY AREA CONDITION DAMAGE ACCESSIBILITY F
=13,514
1,889.33
11,625
= 6,576
4,101
2,475
= 8,961
2,149.75
2,856
952
'3,003

0
0

0
0

5
2
2
2-5

0
0 .

0
0

2-3.
0-1
0-1
2-3

1
1

1
1

1
1
1
1

1
1

1
1

2
2
2
2
EXPOSURE RECOMMENDED
VALUE • ACTION

14
12

21
21

56-60
32-36
36-40
44-60

Defer
Defer

Defer
Defer

Remove
Repai r ,
* Repair,
Remove


V '*'





encapsul ate
encapsul ate


-------
                        TABLE  II.   Square feet of asbestos containing material
                                   by school according to risk assessment.
o
CO
SCHOOL


A
B
C
D
E
F
G
II
I
• J
K
L
M
N
0
P
Q
R
S
T
• •. u
V
V
1 1
TOTALS '
Exposure Values

s\
<10 10-25
71,395

6,373
48,574


507
4,778
3,267
. . . - 13,514
6,576



11,760






17,284

0 184,028

b
10-50
9,680
21,105

12,702







3,808
29,000
19,630
1,580
64,456
22,823
' 25,458
J.,328
-19,465
12 ,309

6,408
249,832

r*
10-50 >50
3,501

1,204
2,827
946 13,922
5,877


6,954


.. 5 ,153



1,868 4,232

1,697

3,560


2,643
. 21,640 32,744
TOTALS


84 ,576
21, 105
7,577
64,103
14, 863
5,877
507
4,788
10,221
13,514
6, 576
8,961
29,000
19 ,630
1 3 ; 3 <\ 0
70,556
22 , 023
27,155
1, 328
23,025
12 , 309
17,284
9,051
488,244
        10-25  and friability » one or cementitious ,  exposure  value  =  10-25,  good adhesive/
              cohesive properties and no water damage; or  if  .minor  water  damage  or other
              minor material damage, material is repairable and  necessary repairs are made..
       'lO-50  and friability >2, no water damage and/or no high  accessibility) or if minor
              water damage, affected areas are effectively removed. '  .
        10'-50  and either high accessibility or v/ate.r damaged  beyond repair.              .  •

-------
                      TABLE III.   Recommended abatement actions based
                                  on exposure values and other factors.
.10 or less	...deferred action

10-25  and  friability  =  one  or cementitious,
       good  adhesive  and cohesive  properties,
       non-vandalized/  and no  water damage;
       or  if water  damage  or other minor
       material  damage,  material  is repairable                                  ..
       and necessary  repairs are made	deferred action
10-50  and  friability  _>_  two, no water  damage
       and/or no high  accessibility; or if
       minor water  damage, affected areas  are
       effectively  removed	enclose  or encapsulate'

10-50  and either high accessibility or water                           .
       damaged beyond  repair	remove
greater than 50	remove
 deferred action          for this  area  no  action  is  needed at this time;  however, continuous
                          monitoring  for change  in conditions  is  necessary;  also asbestos
                          warning labels should  be posted

 enclosure                must be complete  with  no accessibility  or strictly regulated entry;
                          labels should  be  posted  warning of presence of asbestos hazard;
                          building  must  be  able  to support the additional  weight; also fire
                          rating, soundproofing  considerations

 encapsulation            material  must  have  good  adhesive and cohesive  strength; choose
                          bridging  or penetrating  sealant depending on friability; posting
         .   .              of asbestos hazard  signs applicable
 removal            *     only ultimate  solution;  material may have to be  substituted for
                          fireproofing/soundproofing  considerations

-------
 SCHOOL  DISTRICT  VALLEY VIEW


 SCHOOL   GERMANTOWN ELEMENTARY
                                HAJ.tr,,
                                                              M?I,T. v
PERSON  CONTACTED DAt* RUSSEL
i.
 G
 I
 M
 O
I.
                          Name
                                                                                 _
                                                    Hallway , Cafeteria, Cla-ssroom No.,  etc,

                                                      : CEILING  - A SPONGY MATERIAL   _
                                                    Sample Material

                                                       352-31-6  ' __ '_ _    .
                                                    Sample Number Assigned
                                                                         Ddt
        FACTOR
Material condition
(adhesive, cohesive;
deterioratio'n or
damage)
                                      TABLE I','.'FACTOR SCORES
                               •OR'EXTENT     SCORE           FACTOR.
None	,	ri . ; . . . {0,
Moderate; small areas....2
Widespread, pieces  dis-
lodged, evident flaking ••'•
and crumbling	:. . . 5
    Water damage
                      None ...... • ...... ........ .(OJ)
                      Minor. ........,,..,..,,. ,1
                      Moderate to maj or ....... 2-3
Exposed surface.area  None-sealed by  seldom
    (from the floor'
    looking up)
    Accessibility
                      violated suspended'
                      ceiling........ ...... ....0
                      lot or less exposed......!
                      10-100$ exposed ...... ..

                      Not accessible ........... 0
                      Lpv/-mostly unusual .,
                      maintenance ..... . ...... '£55
                      .Moderate to high—     •,
                      access may be frequent. ,', 3
                                                         V.  Activity  or
                                                             Movement
                                                       VII.
                                                         RANGE OR EXTENT
None or low
Libraries, non-student
use areas	
Moderate-classrooms,
corridors	
High-some corridors
cai'cteri as ,
gymnasiums. . .,	
                                  VI,   Air  plenum    None...
                                       or airstream  Present
                                      Asbestos
                                      content
                                                     30%-GOI;
                                                     60-1-100*
                               VIII,  Friability
                                                                           Not  friable  to  low.
                                                                           friability-'difficult
                                                                           to penetrate with
                                                                           pencil	'	
                                                                           Moderate friability-
                                                                           can push fingers into
                                                                           it,	,	
                                                                           jlighly friable-
                                                                                       ?n
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                     ASBESTOS ANALYSIS
DATS
          (P~/" "
               SAMPLE KO.
ANALYTICAL METHOD
flj
                                                            / 5
DESCRIPTION
TYPE OF ASBESTOS
                                              ( a
 OTHER MATERIAL
 ANALYST
 V73K/SC
 6-11-79
                           D-ll

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ICHOOL DISTRICT   VALLEY VIEW

iCHOOL
                                                   AREA  HALLWAY
        VALLEY  VIEW  MIDDLE  SCHOOL
'ERSON CONTACTED.
       FACTOR
                      CLENSY
                                                    Hallway,Cafeteria,Classroom  No.,  etc.

                                                     •' CEILING  (SPONGY MATERIAL)  PAINTED
                                                    Sample Material

                                                      352-31-5
                 -JZ/JU
                    Da
                         Name
                                                '      . Sample Number Assigned
                                                '                          *NOTE:  ALSO IN CENTRAL
                                         TABLE IV  'FACTOR SCORES                  HALLWAY 1H GERHAHT
                             RANGE "OR'EXTENT '    SCORE
                                                              FACTOR .
    ELEM. SCHOOL
     RANGE OR EXTENT
o
K>
Material condition
(adhesive, cohesive)
doterioratio'n or
damage)
   Water damage
                         None	(O)
                         Moderate;  small  areas....2
                         Widespread,  pieces  dis-
                         lodged,  evident  flaking . •
                         and  crumbling	.....5
                         None	 . ... . , . nDj
                         Minor.	 . i
                         Moderate to major....... 2-3
   v
    xposed surface area  None-sealed by seldom
   (from the floor
   looking up)
   7\ccccsibility
                         violated suspended
                         ceiling	 0
                         10* or less exposed.,.'...!
                         10-100% exposed	 . . . (Q

                         Not accessible.......... .0
                         Low-mostly unusual  •
                         mdfintenance	 . , . . , £l^
                         Moderate to.high- .    •
                         access may be frequent....1.3
                                                            V.  Activity or
                                                                •Movement
                                                          VII.
 None  or  low
 Libraries, non-studcn
 use areas	
 Moderate-classrooms,
 corridors	
 High-some  corridors
 cafeterias,
 gymnasiums	
                                                        VI,   Air plenum    None...
                                                            .or airstream  Present
                                                             Asbestos
                                                             content
                                                                              601;-100%
                                                     VIII.   Friability
Not friable to low
friability-difficult
to penetrate with
pencil	'	
Moderate friability-
can push fingers into
it	
Highly friable*-

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                     .ASBESTOS ANALYSIS
DATE '


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;HOOL  DISTRICT  VALLEY VIEW



'HOOL
iRSON  CONTACTED.
      FACTOR
                    ELEMENTARY
                                                  AREA   SOUTH' WALL
 . • Hallway Cafeteria, Classroom No., etc,

';     SPRAYED  ON  CEILING*  .
  • Sample. Material

    • 365-31-2  •  '    	
                   7/31/
                    Dati
                        Name         .  •               Sample Number  Assigned

                                   .     TABLE I','  FACTOR SCORES    .
                            RANGE "OR"EXTENT '    SCORE           FACTOR .'
                              RANGE OR EXTENT
  Material condition
  (adhesive/  cohesive;
  detorioratio'n or
  damage)
i
H1
js
  Water damage
  Exposed surface area
  (from the floor
  looking up)         •
  Accessibility
                         None	0
                         Moderate;  small areas...,2
                         Widespread/  pieces dis-
                         lodged,  evident flaking
                         and  crumbling	 ^j>
                        None		.0
                        Minor	 ...
                        Moderate  to  major

                        Nona-sealed  by  seldom
                        violated  suspended'      .
                        ceiling.....	,...0
                        10*1 or  less  exposed.......!
                        10-10CU' exposed.........{%)

                        Not accessible.......... .0
                        Lov/~rnostly unusual  •.. •
                        maintenance.	'. ,'	1.
                        Moderate  to  high-     ••
                        access may be frequent..^/
       V.  Activity or
           •Movement
 None or low
 Libraries,  non-student
 use areas	
 Moderate-classrooms,
 corridors	,
 High-some corridors
 cafeterias,
 gymnasiums ... ...	,
      VI,   Air plenum    ' None
           or airstream  Present
    , VII.   Asbestos
           content
                                                                             ecn-iocn
    VIII.  Friability
Not  friable  to  low
friability-difficult
to penetrate  with
pencil.,...\	
Moderate  friability-
can  push  fingers into
'it,	
Highly  friable-
                                                                                ;toi

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                     ASBESTOS ANALYSIS
DATE
          r>
          c ~/-
                                       SAI-IPLE KG.  7(1
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SCHOOL  DISTRICT.
VALLEY VIEW
        FARMERSVILLE ELEMENTARY
'ERSON  CONTACTED.
       FACTOR
                                                AREA  MAIN /HALL ABOVE PASS THRU DOOR	
                                                    Hallway/ Cafeteria, Classroom  No.,  ct.c,

                                                     , SPRAYED ON CEILING^MATERIAL

                                                    Sample.Material

                                                   •   365-31-3  •	' '
        Name                   ...  Sample Number Assigned

            '      . ;     TABLE I','' FACTOR SCORES
            RANGE "OR'EXTENT     SCORE   .        FACTOR .    .
                                7/3 3V
                                  Dat
                                                                               RANGE OR EXTENT
 o
   Material condition
   (adhesive, cohesive;
   detorioratio'n or
   damage)
   Water damage
Exposed surface area
(from the floor .
looking up)
   Acces sibility
         None	 0
         Moderate;  small areas.,..2
         Widespread/  pieces  dis-.
         lodged,  evident flaking  '
         and crumbling.	. . [5]
                                                         V.
None..................... 0
Minor.	
Moderate to major	

None-sealed by- seldom
violated suspended
ceiling.,..	0
101 or less exposed...'...!
10-100% exposed	
        Not accessible..........,0
        Low-mostly unusual   .•   .
        maintenance.,.,......... ,1
        Moderate to high- .   _
        access may be  frequent. .'
                                          VI.
                                                         VII.
Activity or
•Movement
                                                             Air plenum :
                                                             or airotream.
                                               Asbestos
                                               content
                                                      VIII.   Friability
                                                     None or low
                                                     Libraries,  non-student
                                                     use areas	
                                                     Moderate-classrooms,
                                                     corridors	
                                                     High-some corridors
                                                     cafeterias,
                                                     gymnasiums	
              None
              Present,
                                                                              301-60%
                                                                              60%-lOOt
              Not friable .to low
              friability-difficult
              to penetrate with
              pencil,.,..'	
              Moderate friability.-
              can push fingers into
              it,..,.,,,,,.,
              Highly friable^-

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                      ASBESTOS ANALYSIS
DATE    4^f~4^=sgs   '                SAMPLE. NO.
ANALYTICAL METHOD    /?£.-^n>-^,
-------
                     ASBESTOS ANALYSIS
DATE       T—'/  f i                    SAMPLE NO,
ANALYTICAL METHOD     /?*-**	X3 f^>.  f/*,^: - /• <;
DESCRIPTION

TYPE OF ASBESTOS

OTHER MATERIAL
ANALYST
WBK/sc
6-11-79
                             D-18

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                      ASBESTOS ANALYSIS
DATE       ^-//-"7f                   SAMPLE NO.
ANALYTICAL METHOD      ^-/^	&f/3. J7^/' ^ - /• T
DESCRIPTION
Z / /!>
                                              S
TYPE OF ASBESTOS
 OTHER MATERIAL
 ANALYST
 VJBK/sc
 6-11-79
                             D-19

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                     ASBESTOS ANALYSIS
DATE      V-//- XT                   SAMPLE NO.
ANALYTICAL METHOD
DESCRIPTION
TYPE OF ASBESTOS
OTHER MATERIAL
ANALYST
 WBK/sc
 6-11-79
                           D-20

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                     ASBESTOS ANALYSIS
DATE   . .  7-SS-S~7                   SAMPLE NO.
ANALYTICAL METHOD    /?£ S&\	^ jy?.  cPAi£— ^ 5TO
DESCRIPTION      """•   ~
TYPE  OF ASBESTOS
 OTHER 14ATERIAL
 ANALYST
 UBK/sc
 6-11-79
                             D-21

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                     ASBESTOS ANALYSIS
DATE       f"'' f<                    SAMPLE  NO.
ANALYTICAL METHOD    /^/v*	£>{„   o,^ - /•
DESCRIPTION
TYPE OF ASBESTOS
OTHER MATERIAL
ANALYST
 WBK/sc
 6-11-79

                             D-22

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                     .ASBESTOS  ANALYSIS
DATE       Y-'/~/^>r ct>
ANALYST
 WBK/sc
 6-11-79
                             D-23

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D-24

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               Appendix E

News Releases and an Editorial Concerning
 the Health District's Asbestos Program
                    E-l

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E-2

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Montgomery County Combined Genera I Health District
|51  West 3rd   Street, Dayton,Ohio 45422
Public Information Off ice, 225-4403

               David B.  Peden,  Director
       person:  Environmental Health Division
               225-4443
                                                October 29,  1979
                       FOR IMMEDIATE RELEASE



     The Montgomery County Health District recently surveyed all


area schools to assess the public health significance where


asbestos was used in building construction.  Findings indicate


that some problem areas need to be addressed, but based upon


United State Environmental Protection Agency assessment procedures,


there are no schools in the Montgomery County Health District


where the situation is considered immediately dangerous to the


health of the children.


     Where a problem with asbestos does exist there are several


corrective alternatives available.  The schools in Montgomery


County have been apprised of suggested corrective measures and


are working with the Health District to eliminate any potential


problem spots.


     Supervisor Terry Wright of the Health District, responsible


for school inspections, explained, "We've been working very


closely with the schools since we first started the surve3'.  Where
                              'more'

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                                                          2-2-2
problems have been found, the schools have been eager to take
appropriate corrective steps."
     Asbestos is a known carcinogen and 'with excessive exposure
can cause lung diseases and other problems.  Director of the
Environmental Health Division of the Health District, Dave Peden,
cautions however, "The asbestos danger in our schools is different
from that which occurs in many occupational environments.  Most
health problems have resulted from high and repeated exposure over
a long time period.  In the school we seldom see a high exposure
level.  We're trying to reduce any damage which might result from
low exposure levels over long periods of time."
     Asbestos is a component in many materials which the public
uses every day.  As long as the asbestos fibers are not airborne
where they can be inhaled into the body, they are not dangerous.
The bulk of the problem comes from asbestos-containing materials
being damaged, or being installed so that they release fibers into
the air.
     Survey results show twenty-three schools in the area have
sprayed-on asbestos material which could cause problems.  Each
affected school has been given recommendations by the Health
District on corrective steps necessary.  The Health District
anticipates these steps will be started in the summer of 1980.
All areas where asbestos needs to be removed as quickly as possi-
ble have been sealed off and restricted by the respective school
administrators.
                                    'more'
                               E-4

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                                                          3-3-3
     While asbestos was used extensively for fireproofing,  sound-

proofing, arid other purposes 'in school construction during  the
                                       »
post-WW II days, its use was finally banned in 1973 because of the

hazards involved.  Wright explained further, "One of our primary

concerns now is that when corrective steps are taken, they  must be

done in such a way that the workers' health won't be jeopardized

and it's essential that careless procedures don't result in more

contamination than before the treatment."

                                -30-



Number 15

October 1979
                               E-5

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                                                                  Sfiqftfvj &
                                                                  Jj3iUwJ.O
                              801 County Government Plaza
                              451 W. Third St.
                              Dayton, Ohio 45422
                              (513) 225-4598
  Dr. Raymond Hopper, Superintendent

For additional information contact:
Larry L. Oatman, public information officer
                                                                                    i,

                                                                                 J
                               October 29, 1979
 IMMEDIATE RELEASE
    "There is no immediate health danger from asbestos in the public school

buildings in the county, according to a recent extensive inspection by the

county health district," Dr. Raymond Hopper, Montgomery County Superintendent,
           I
said  today.

    The following information is based upon preliminary inspections made by

the Montgomery County Combined General Health District, Dr. Hopper said.

    The inspections revealed that sprayed-on asbestos X7as used in the constrtic-

tion  in 19 of the 170 public school buildings in the eight local and seven  city

school systems in the health district.

    Asbestos  is only a potential health problem when the fibers.become air-

borne.  It was used in school buildings constructed before 1973 when possible

dangers of deteriorated asbestos were unknown.

    In  three  of the 19 buildings where the material was found in potentially

hazardous,  condition,  the health department recommended immediate corrections

be made.   Those three school buildings were Daytons' Patterson Cooperative

High School,  Vandalia-Butler High School and Farmersville Elementary School

in  the Valley View local district.

    This past week those corrections were made, Dr. Hopper said.

    In  12 of  the buildings there is not an immediate health danger but the health

district has recommended that treatment of the material be started in the

summer of 1980.

    These buildings include Daycon City Schools' Horace Mann and Patterson

                                    (MORE)
                                     E-6

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/PAGE 2)

Kennedy elementaries, Jefferson Township Local Schools'  Radcllff  Elementary,

Kettering City Schools' Orchard Park Elementary,  Mad River Local  Schools'  Steb-

bins High School, New Lebanon Local Schools'  New  Lebanon Elementary, Northmont

Local Schools' Northmont High School and Union Elementary, Northridge Local

Schools' Tinberlane and Grafton Kennedy eleiaentaries, Vandalia-Butler City

Schools' Demmitt Elementary and Wayne Local Schools* Kitty Hawk Elementary,  Also

in this category, but previously mentioned, are Vandalia-Butler City Schools'

high school and Valley View Local-Schools' Farmersville  Elementary.

     The remaining four buildings will be only routinely monitored and  in-

spected by the health department to insure that any materials containing asbestos

does not deteriorate and create a potential health hazard.

     These buildings are Valley View Local Schools' Germantown Middle and Ger-

taantown Elementary and West.Carrollton City Schools' West Carrollton High School

and Russell Elementary.

     Several of the schools where some type of treatment is recommended also

have areas where only monitoring is necessary.

     A timetable for correction will be developed by each individual school

district.

     The major concern of the school officials, Dr. Hopper continued, has been

to eliminate any possible danger and to protect the health and safety of all

students and staff members.
           *
     "This community is most fortunate to have a  health  district  that initiated

an investigation and recommended corrections of this potential health hazard

for the welfare of its citizens," he said.

     Also Dr. Hopper praised the unique cooperation among area schools.  "The

area school officials have demonstrated an outstanding degree of  full cooper-

ation to share information and ideas to solve a potential problem. They are

taking every reasonable precaution to insure the  health'and safety of both

students and staff members," he said.

                                      -30-

                                     E-7

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                                      UUHIO television •am-fm
                                      1414 Wilmington Avenue Dayton, Ohio - 45401

                                AN OPINION OF THE MANAGEMENT
Requests In writing from qualified groups or Individuals to express opposing opinions on this station will be welcomed.
JACK HURLEY
EDITORIAL  DIRECTOR
WHIO-TV-AM-FM

NOVEMBER 1,  1979

Montgomery County residents this week  got  a  good look at how
public  agencies ought to work on their behalf.   The Montgomery
County  Combined General Health District and  area schools took
a positive and aggressive initiative in dealing with a potentially
serious  health hazard.
Working  quietly and.cooperatively the  schools  and the health dis-
trict  surveyed school buildings in  search  of  asbestos construction
materials  that might have deteriorated and might pose some prob-
lems.  They found, some potential problems  and  moved quickly to
.isolate  them.

In  short they  performed their public and personal duties in a manner
that could serve as a role model for all area  governmental agencies.
They were  effective/  aggressive and completely upfront.  Indications
are that many  of Ohio's health districts and  school districts are
way behind Montgomery County in dealing with  the asbestos problem...
if  indeed  they are dealing with it  at  all. County school Superin-
tendent/ Ray Hopper and Dayton school  Superintendent/ John Maxwell,
along  with their staffs and boards  took the potential problem and
their  obligations to students and parents  seriously.... as did other
Superintendents and the combined General Health District.

Problem  areas  and potential problem areas  have been identified and
are being  dealt with. .. .and being dealt', with  openly.   Based on their
attitudes  and  approaches... the public  has  every right to have as much
confidence in  the school officials  and health  district as we do.
                              Broadcasting
                                E-8

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L
       TECHNICAL REPORT DATA
(Please nad lnsx\ictions on the reverse before completing/
 1. REPORT NO.
    EPA 560/13-80-039
                                                             3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
 Identifying Potential  Asbestos Exposures  in Schools:
 The  Montgomery County  Experience
                                5. REPORT DATE
                                          September
1980
                                6. PERFORMING ORGANIZATION CODE
7. AUTHORisi  Terry L7 Wright (.Montgomery  County tomoinea
 General Health District,  Dayton, Ohio)
 Everett E. Logue  (Research Triangle  Institute)
                                8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
 Research Triangle  Institute
 P.  0.  Box 12194
 Research Triangle  Park,  NC  27709
                                |10. PROGRAM ELEMENT NO.
                                11. CONTRACT/GRANT NO.

                                    68-01-5848
 12. SPONSORING AGENCY NAME AND ADDRESS
 Design and Development Branch
 Survey and Analysis  Division
 Office of Pesticides and Toxic Substances
 EPA,  Washington, D.  C.  20460
                                13. TYPE OF REPORT AND PERIOD COVERED
                                14. SPONSORING AGENCY CODE
 IS. SUPPLEMENTARY NOTES
 16. ABSTRACT
          This report  summarizes the  experience of the Montgomery County  Combined
     General Health  District in their asbestos-in-schools  control program.   A
     survey of all schools within  the District's jurisdiction was completed.   Bulk
     samples of friable materials  were collected and analyzed for their asbestos
     content, and asbestos exposure scores were obtained  for those areas  where
     asbestos was present.  Recommendations for appropriate abatement procedures
     were made based upon exposure scores, and the values  of score components.
17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.IDENTIFIERS/OPEN ENDED TERMS
                                              c. COSATI l-'ield/Group
     Asbestos
     Asbestos  survey
     Asbestos  exposure
     Schools
is, DISTRIBUTION STATEMENT
     Release to Public
                                               | 19. SECURITY CLASS /This Repor:i

                                                       i f •! pH
                                              121. NO. OF PAGES
                                              !     69
                                               I 20. SECURITY CLASS :Thi
                                               \ Unclassified
                                             122. PRICE
                                             I
E.°A Form 2220-1 (Rev. 4-77)   previous EDITION is OBSOLETE

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