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QUALITY ASSURANCE PROJECT PLAN:
EVAL UATION OF AN
ALTERNATIVE ASBESTOS CONTROL METHOD
FOR BUILDING DEMOLITION
Prepared for:
Mr. Glenn M. Shaul
Task Order Manager
U.S. EPA, Office of Research & Development
National Risk Management Research Laboratory
26 West Martin Luther King Drive
Cincinnati, OH 45268
Prepared by:
Environmental Quality Management, Inc.
1800 Carillon Boulevard
Cincinnati, OH 45240
Contract No. 68-C-00-186
Task Order No. 0019
and
U.S. Environmental Protection Agency
QAPP Technical Development Team
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Al QUALITY ASSURANCE PROJECT PLAN
APPROVAL SHEET
EVALUATION OF AN
ALTERNATIVE ASBESTOS CONTROL METHOD
FOR BUILDING DEMOLITION
Contract No. 68-C-00-186
Task Order No. 0019
John R Kommsky, Project Manager Date
Environmental Quality Management, Inc., Cincinnati, OH
Jackie Doan, Quality Assurance Manager Date
Environmental Quality Management, Inc, Cincinnati, OH
Lauren Drees, Quality Assurance Officer Date
ORD,NRMRL, US EPA
Glenn M. Shaul, Task Order Manager Date
ORD,NRMRL, US EPA
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A2 TABLE OF CONTENTS
Section
Project Management . . . ... 1 of 65
Al Title and Approval Sheet . . 2 of 65
A2 Table of Contents . 3 of 65
A3 Acknowledgment and Distribution List . . ... . . .. 12 of 65
A3 1 Acknowledgment ... 12 of 65
A3 2 Distribution List . . . . . .. 12 of 65
A4 Project Task/Organization .... .... . 13 of 65
A4 1 Project Organization . . . ... 13 of 65
A5 Problem Definition/Background . . . .16 of 65
A5 1 Background . . ... .... 16 of 65
A52 Objective . . . . . 17 of 65
A521 Primary Objectives . .18 of 65
A5 2 2 Secondary Objectives .. . . 18 of 65
A6 Project/Task Description . ... . . .22 of 65
A6 1 Technical Approach .. 22 of 65
A6 1 1 Pre-Demolition Inspection of Buildings . . . 27 of 65
A6 1 1 1 Asbestos Inspection of Buildings . . .. 27 of 65
A6 1.1 2 Lead Paint Inspection of Buildings . . 30 of 65
A6.1 1 3 Concentrations of Asbestos in Soil.. . . . 31 of 65
A6 1 2 Demolition of Buildings and Site Management . . 32 of 65
A6 1 3 Environmental Monitoring During Demolition
of Buildings ... . 33 of 65
A6 1 3 1 Perimeter Air Monitoring During Demolition . 33 of 65
A6.1 3 2 Personal Air Monitoring of Workers During
Demolition .... . — 34 of 65
A6 1 3 3 Impact on Soil from Demolition ... . . 36 of 65
A6.1 3 4 Settled Dust from Demolition . 36 of 65
A6.1 3 5 Water Used During Demolition. . . 36 of 65
A6 1 3 6 Soil Elutriation Tests . . . . 37 of 65
A6 1 4 Air Monitoring at Landfill . ... . 37 of 65
A6 1 4 1 Perimeter Air Monitoring During Landfilling
ofDebns .. .37 of 65
A6.1 4 2 Perimeter Air Monitoring During Landfilling
of Bagged ACM from NESHAP Method
Building ... 38 of 65
A6 1 4 3 Air Monitoring of Workers During Landfilling 38 of 65
A6 1 5 Background Perimeter Air Monitoring . . . 38 of 65
A6.1 5.1 Air Monitoring Prior to Asbestos Abatement
of NESHAP Method Building .... ... 38 of 65
A6 1 5 2 Air Monitoring Prior to Demolition of the
Alternative Control Building 39 of 65
A6 1 5.3 Air Monitoring Prior to Landfilling of Bagged
ACM and Building Debns . ... . 39 of 65
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TABLE OF CONTENTS (continued)
Section Page
A6 1 6 Air Monitoring During Asbestos Abatement of
NESHAP Method Building . 39 of 65
A6 161 Air Monitoring of Discharge Air from
HEPA-Filtration Units .. 39 of 65
A6 162 Air Monitoring of Ambient Air During Loading
of Bagged ACM 40 of 65
A62 Personnel . . ... . . . 40 of 65
A6.3 Project Schedule . ... .... 40 of 65
A7 Quality Objectives and Criteria for Measurement Data... 41 of 65
A71 First Primary Objective . .. . 41 of 65
A7 1 1 Step 1 State the Problem 41 of 65
A7 1.2 Step 2 Identify the Decision.. . . 42 of 65
A7 13 Step 3 Identify Inputs to the Decision ... . 42 of 65
A7 1.4 Step 4 Define the Study Boundaries . 42 of 65
A7.15 Step 5 Develop a Decision Rule . . . ... 43 of 65
A7 1 6 Step 6 Tolerable Limits on Decision Errors . 43 of 65
A7 1 7 Step 7 Optimize the Design for Obtaining Results 48 of 65
A7 1 8 Analytical Sensitivity . . ... 48 of 65
A7.1 9 Data Quality Indicators (DQI) 49 of 65
A7.1 91 Sample Collection DQI ... .49 of 65
A7 1 9 2 Sample Analysis DQI . ... . 50 of 65
A72 Second Primary Objective . 51 of 65
A7 2.1 Step 1 State the Problem . . . 51 of 65
A7 2 2 Step 2. Identify the Decision . . 51 of 65
A7 2 3 Step 3 Identify Inputs to the Decision 51 of 65
A7 2 4 Step 4 Define the Study Boundaries .. . . 51 of 65
A7 2.5 Step 5 Develop a Decision Rule .. .. 52 of 65
A7 2 6 Step 6 Tolerable Limits on Decision Errors . 52 of 65
A7 2.7 Step 7 Optimize the Design for Obtaining Results . . 53 of 65
A7 2.8 Analytical Sensitivity . . . . .54 of 65
A7.2 9 Data Quality Indicators (DQI) . 54 of 65
A7 2 9 1 Sample Collection DQI .. .. . . 54 of 65
A7 2 9 2 Sample Analysis DQI 54 of 65
A73 Third Primary Objective ... . . . 54 of 65
A7 3 1 Step 1- State the Problem . 54 of 65
A7 3 2 Step 2 Identify the Decision.. . 55 of 65
A7 3 3 Step 3 Identify Inputs to the Decision . 55 of 65
A7 3 4 Step 4 Define the Study Boundaries . 56 of 65
A7 3 5 Step 5 Develop a Decision Rule . . 56 of 65
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TABLE OF CONTENTS (continued)
Section Page
A7 3 6 Step 6 Tolerable Limits on Decision Errors . 56 of 65
A7 3 7 Step 7 Optimize the Design for Obtaining Results . 56 of 65
A8 Special Training Requirements/Certifications . . . . 57 of 65
A8 1 Field Personnel. 57 of 65
A8 2 Laboratory Personnel . 57 of 65
A9 Documentation and Records ... .... . 58 of 65
A91 Field Operations Records. . . . 58 of 65
A91.1 Sample Documentation . . 58 of 65
A91 2 Meteorological Measurements . . .. 64 of 65
A9.1 3 Photo Documentation . . . .64 of 65
A92 Cham-of-Custody Records . . 64 of 65
A9 3 Laboratory Records . . . . 64 of 65
A9.3 1 TEM Reporting (Air) .. . . .65 of 65
A9 3 2 TEM Reporting (Soil) . ... . 65 of 65
B Measurement/Data Acquisition . . .. ... 1 of 64
Bl Building Demolition . 1 of 64
Bl 1 Air Dispersion Modeling. ... . . . 1 of 64
Bl 1 1 Source Identification . . . . 1 of 64
Bl 1 1 1 Source No 1 1 of 64
Bl.l 1 2 SourceNo.2 .. . ..2of64
Bl 1 1 3 Model Selection . . . 2 of 64
Bl 1 1 4 Source Characterization . . . 2 of 64
Bl 1 1 5 SCREEN3 Model 3 of 64
Bl 1 1 6 ISCST3 Model ... 8 of 64
B1.2 Air Monitoring During Demolition . .. .. .11 of 64
Bl 2 1 Perimeter Air Monitoring During Demolition. . . .11 of 64
B1.2 2 Worker Exposure Monitoring During Building Demolition 15 of 64
Bl 2 2 1 Worker Activity Exposure Monitoring 16 of 64
Bl 2 3 Soil Sampling .... . . . . 16 of 64
B1.2 4 Asbestos from Soil Elutnation Method . ... . 17 of 64
Bl.2 5 Settled Dust from Demolition 19 of 64
Bl 26 Surface Water from Demolition ... . .19 of 64
B1.2 7 Source Water for Wetting Structure and
Demolition Debris . 19 of 64
Bl 3 Monitoring During Landfilling of Demolition Debns 21 of 64
Bl 3.1 Perimeter Air Monitoring During Landfilling of
Demolition Debris 21 of 64
Bl 3 2 Air Monitoring of Workers During Landfilling 21 of 64
Bl 4 Background Air Monitoring . 22 of 64
Bl 4 1 Background Air Monitoring at Demolition Site. . 22 of 64
Bl 4 2 Background Air Monitoring at Landfill 23 of 64
Bl 5 Air Monitoring During Asbestos Abatement of
NESHAP Method Building 24 of 64
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TABLE OF CONTENTS (continued)
Section Page
Bl 5 1 Discharge Air from HEPA-Filtration Units 24 of 64
Bl 5 2 Air Monitoring During Loading of Bagged ACM . 25 of 64
Bl 5 3 Air Monitoring During Landfillmg of NESHAP Method
Bagged ACM . ... . . . 25 of 64
Bl 6 Summary of Field Samples . .. 26 of 64
B2 Sampling Method Requirements 27 of 64
B21 Air Sampling . 27 of 64
B2 1 1 Perimeter Air Sampling for Asbestos . . 27 of 64
B2 1.2 Worker Exposure Monitoring for Asbestos and Lead . 27 of 64
B2.2 Real-Time Aerosol Monitoring . . ... .28 of 64
B2 3 Meteorological Monitoring. . . 28 of 64
B24 Soil Sampling 28 of 64
B2 4 1 Preparation of Soil Samples for Asbestos Analysis 29 of 64
B25 Settled Dust Sampling. . 30 of 64
B2 6 Source Water Sampling - Hydrant and Amended Water . 30 of 64
B27 Water Sampling - Contained Runoff Water . 31 of 64
B28 Soil Elutriation Tests . . 31 of 64
B3 Sample Custody Requirements . . . .. 33 of 64
B3 1 Field Cham-of-Custody . . . . 33 of 64
B3 2 Analytical Laboratory .... 33 of 64
B4 Analytical Method Requirements . . . . . 34 of 64
B41 Air Samples (TEM) . 34 of 64
B4 1.1 TEM Specimen Preparation ... 34 of 64
B41 2 Measurement Strategy . . . . 35 of 64
B4 1 3 Determination of Stopping Point . 35 of 64
B42 Air Samples (PCM) . . 38 of 64
B4.3 Air Samples (Lead) . . 38 of 64
B4.4 Soil Samples (TEM) .. .38 of 64
B45 Settled Dust Samples (TEM) . . 3 8 of 64
B46 Water Samples . . . 39 of 64
B47 Soil Elutriation Air Samples .. . . .. 39 of 64
B5 Quality Control Requirements 40 of 64
B5 1 Field Quality Control Checks . . . 40 of 64
B5 1 1 Air Field QC for Asbestos and Total Fibers .. 40 of 64
B51.ll Field Blanks . .... 40 of 64
B5.1.12 Field Duplicates . . . . 41 of 64
B5 1 2 Soil Field QC for Asbestos . ... 41 of 64
B5 1 3 Settled Dust Field QC .41 of 64
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TABLE OF CONTENTS (continued)
Section
B5131 Field Blanks . . 41 of 64
B5 1 3.2 Field Duplicates ... 41 of 64
B5 14 Water Field QC.. .... 41 of 64
B5141 Field Blanks . . 41 of 64
B5.142 Field Duplicate. .... . 42 of 64
B5 2 Laboratory Quality Control Checks . . . 42 of 64
B5 2 1 Air Laboratory QC 42 of 64
B5.21 1 Lot Blanks . . 42 of 64
B5 2.1.2 Laboratory Blank.. .. 42 of 64
B5 2 1 3 Laboratory Clean Area Blanks . ... 49 of 64
B5.2 1 4 Replicate Analysis . . . . . 50 of 64
B5 2 1 5 Duplicate Analysis .. . . ... 50 of 64
B5 2 1 6 Verification Counting. . ... 50 of 64
B5.21.7 Intel-laboratory Dupicates . . 51 of 64
B5 2 2 Soil Laboratory QC . . . .... 51 of 64
B5.2 2 1 Laboratory Blanks . .. 51 of 64
B5 2 2.2 Laboratory Control Samples . . . . 51 of 64
B5 2 2 3 Laboratory Duplicates . . ....52 of 64
B5 2 2 4 Replicate Analysis and Verification Counting 52 of 64
B5.2 2 5 Interlaboratory Duplicates .. . 52 of 64
B5 2 3 Settled Dust Laboratory QC . . 52 of 64
B5 2 3 1 Laboratory Blanks 52 of 64
B5 2 3 2 Laboratory Duplicates . . .. 53 of 64
B5 2 3 3 Replicate Analysis . . . . .53 of 64
B5 2 3 4 Interlaboratory Duplicates . . 53 of 64
B5 2 4 Water Laboratory QC . . 53 of 64
B5 2 4 1 Laboratory Blanks .. . 53 of 64
B5 2 4 2 Laboratory Duplicates . . 53 of 64
B5.2 4 3 Replicate Analysis ... . . 53 of 64
B5 2 5 Elutnator Sample Laboratory QC . 54 of 64
B5 2 5 1 Laboratory Blanks 54 of 64
B5 2 5 2 Laboratory Duplicates .. 54 of 64
B5 2 5 3 Replicate Analysis 54 of 64
B5 2 5 4 Elutnator Duplicates . . . 54 of 64
B5 2 5 5 Elutriation SRMs 55 of 64
B6 Instrumentation/Equipment Testing, Inspection, and
Maintenance Requirements ... .... 56 of 64
B6 1 Field Instrumentation/Equipment . . . .. 56 of 64
B6 2 Laboratory Equipment/Instrumentation 56 of 64
B7 Instrument Calibration and Frequency 57 of 64
B7 1 Field Instrument/Equipment Calibration . ... .57 of 64
B7 1 1 Air Sampling Pumps .. . 57 of 64
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TABLE OF CONTENTS (continued)
Section
B7 1.2 Airflow Calibration Procedure . 57 of 64
B72 Calibration of TEM.. . . 58 of 64
B8 Inspection/Acceptance Requirements for Supplies and Consumables 59 of 64
B8 1 Air Sampling Filter Media ... 59 of 64
B9 Non-Direct Measurements . ... . 60 of 64
BIO Data Management .. . . 61 of 64
BIO 1 Data Assessment .. . 61 of 64
BIO 2 Data Management 61 of 64
B10.3 Statistical Analysis 62 of 64
BIO 3 1 Evaluation of Airborne Asbestos Concentrations . 62 of 64
BIO 3 2 Evaluation of Post-Method Asbestos Soil Concentrations 64 of 64
C Assessment/Oversight . 1 of 3
Cl Assessment and Response Actions . . 1 of 3
Cl 1 Performance and System Audits ... . 1 of 3
Cl 1 1 Field Audit . . . . 1 of 3
Cl 1 2 Laboratory Audit ... . 1 of 3
C1.2 Corrective Action . .. 2 of 3
C2 Reports to Management . . 3 of 3
D Data Validation and Usability . . . . . 1 of 2
Dl Data Review, Verification, and Validation. .. . . 1 of 2
D2 Data and Sample Archival ... . . 2 of 2
E References . . . 1 of 1
Appendices
A Alternative Asbestos Control Method, November 1, 2005
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FIGURES
Number Page
A-l Project Organization . . ... 14 of 65
A-2 Aerial View of Project Location at Fort Chaffee . 23 of 65
A-3 Exterior View of Building #3602 (NESH AP Method) and
#3607 (Alternative Method . . . . . 24 of 65
A-4 Interior View of Building #3602 . . 25 of 65
A-5 Interior View of Building #3607 26 of 65
A-6 Section of'/z-inch Gypsum Wallboard Showing a Multi-layered Joint Interval .. 28 of 65
A-7 Project Schedule for Building Demolition Evaluation at Fort Chaffee. . . 35 of 65
A-8 Sampling Data Form - Air . 59 of 65
A-9 Sampling Data Form - Soil ... 60 of 65
A-10 Sampling Data Form - Water . ... ... . 61 of 65
A-ll Sampling Data Form - Settled Dust .... . . 62 of 65
A-l 2 Meteorological Measurement Log. . .. .... 63 of 65
B-l Configuration of the Type of Building to be Demolished . . . 2 of 64
B-2 Transfer of Building Debns to Truck Bed ... . . 3 of 64
B-3 SCREENS Results for Building Demolition Source (0 to 1,000 feet) 5 of 64
B-4 SCREEN3 Results for Building Demolition Source (0 to 100 feet) . 6 of 64
B-5 SCREEN3 Results for Truck Loading Source (Release Ht = 7 feet) 7 of 64
B-6 SCREENS Results for Truck Loading Source (Release Ht = 12 feet) 7 of 64
B-7 SCREENS Results for Truck Loading Source (Release Ht = 15 feet) . . 8 of 64
B-8 Wind Rose for the Period 1999-2000 and 2002-2004 .. 9 of 64
B-9 Results of ISCST3 Model Run for Year 2004 Represented as
Percent of Total Maximum Concentration .. . .10 of 64
B-l 0 Locations of Air and Settled Dust Monitors around NESHAP Method Building 13 of 64
B-l 1 Locations of Air and Settled Dust Monitors around Alternative Method Building 14 of 64
B-l 2 Soil Sampling Grid within Containment Berm for NESHAP Method Building
and Alternative Method Building .. .. . 18 of 64
B-l3 Analytical Request and Cham-of-Custody Form . . . . 33 of 64
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TABLES
Number Page
A-l Roles and Responsibilities of Key Project Personnel 15 of 65
A-2 Asbestos Content of Building Materials Based on PLM and
Gravimetric Reduction (GR)/TEM Analysis . 29 of 65
A-3 RACM Present in the NESHAP Method and Alternative Method Buildings . . 30 of 65
A-4 Concentrations of Lead in Paint Chip Samples from Interior and
Exterior Building Components 31 of 65
A-5 Asbestos in Soil (PLM) and Gravimetric Reduction (GR/TEM) . .. 32 of 65
A-6 Probability Distribution of Number of Hours Downwind
Between 7 AM and 7 PM (March and April at Fort Smith, AR) .. 46 of 65
A-7 Power of Two-Sample t-Test for Airborne Asbestos Comparison Based
on Sample Size of 18 and 15 . ... 47 of 65
A-8 Power of Two-Sample t-Test for Soil Comparison .... . 53 of 65
B-l Summary of Selected Volume Source Modeling Parameters . . . 4 of 64
B-2 Perimeter Air Monitoring Samples for Asbestos Analysis
During Demolition and Debris Loading . ... . . . . . 12 of 64
B-3 Worker Exposure Monitoring Samples for Asbestos and Lead During
Building Demolition and Debris Loading ... ... . . 15 of 64
B-4 Worker Activity Exposure Monitoring Samples for Asbestos During
Building Demolition . . 16 of 64
B-5 Soil Samples for Asbestos Analysis . . . . .. 17 of 64
B-6 Soil Elutnation Samples for Asbestos Analysis . 17 of 64
B-7 Settled Dust Samples at Perimeter Rings for Asbestos Analysis
During Demolition and Debris Loading 20 of 64
B-8 Surface Water Samples for Asbestos Analysis During Demolition and
Debris Loading . .. . . . .. 20 of 64
B-9 Source Water Samples for Asbestos Analysis ... . . 20 of 64
B-10 Perimeter Air Monitoring Samples for Asbestos Analysis
During Landfilling of Demolition Debris . . 21 of 64
B-l 1 Worker Exposure Monitoring Samples for Asbestos and Lead
During Landfilling of Building Demolition Debns . 22 of 64
B-l 2 Background Air Monitoring Samples for Asbestos Analysis around
NESHAP Method and Alternative Control Buildings . . 23 of 64
B-l3 Background Air Monitoring Samples for Asbestos Analysis at the Landfill
Prior to Disposal of Materials from the NESHAP Method and
Alternative Method Buildings 24 of 64
B-l 4 Air Monitoring Samples for Asbestos Analysis of Discharge Air from
HEP A-Filtration Units ... .. 24 of 64
B-l5 Air Monitoring Samples for Asbestos Analysis dunng Loading of
Bagged ACM from NESHAP Method Building . 25 of 64
B-l 6 Air Samples for Asbestos During Landfilling of Bagged
Asbestos-Containing Waste from Abatement of NESHAP Building 26 of 64
B-l 7 Summary of Field Samples to be Collected for Asbestos Analysis by TEM 26 of 64
B-l 8 Approximate Number of Gnd Openings to Achieve Target Analytical
Sensitivity ....... .... . 36 of 64
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TABLES
Number Page
B-l 9 Analytical Methods and Quality Assurance (QA)/Quality Control (QC) Checks 43 of 64
B-20 Accepted Analytical Variability for Sampler Re-Analysis ... .... 49 of 64
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A3 ACKNOWLEDGEMENT AND DISTRIBUTION LIST
A3.1 Acknowledgement
The following individuals participated in preparation of this Quality Assurance Project
Plan.
U S EPA OAPP Technical Development Team
Keith Bamett, OAQPS
Lee Hoffman, OSW
Ron Rutherford, OECA
Brad Venner, NEIC
U S EPA Resource Members.
Charlotte Bertrand, OPE1
Elvia Evenng, Region 6
Todd Martin, NRMRL
David Eppler, Region 6
Jim Konz, OSRT1
Glenn Shaul, NRMRL
Roger Wilmoth, NRMRL
David Cozzie, OAQPS
Chns Kaczmarek, OGC
Steve Schanamann, OIG
Mark Hansen, Region 6
Mark Maddaloni, Region 2
John Smith, OPPT
Julie Wroble, Region 10
Becky Dolph, Region 7
Marcus Kantz, Region 2
Lynn Slugantz, Region 7
State of Arkansas Resource Members
Lloyd Huntmgton, ADEQ
Torrence Thrower, ADEQ
Contractor Proiect Team.
Mike Beard, RTI International, Research Triangle Park, NC
David Cox, QuanTech, Inc., Arlington, VA
Owen Crankshaw, RTI International, Research Triangle Park, NC
John Harris, Lab/Cor, Inc., Seattle, WA
John Kormnsky, Environmental Quality Management, Inc, Cincinnati, OH
James Millette, MVA Scientific Consultants, Inc, Duluth, GA
Jeanne Orr, Reservoirs Environmental, Inc, Denver, CO
A3.2 Distribution List
Same individuals listed in Section A3 1 with the addition of the following
Lauren Drees, NRMRL
David Gray, U S EPA, Region 6
Sandy Sanders, Fort Chaffee Re-Development Authority
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A4 PROJECT TASK/ORGANIZATION
A4.1 Project Organization
The U S EPA's Office of Research and Development (ORD) and U S EPA Region 6 are
cooperatively conducting this research project Environmental Quality Management, Inc (EQ)
is the prime contractor on the project and will have overall responsibility to ensure that the
project is conducted in accordance with the approved Quality Assurance Project Plan (QAPP)
MVA Scientific Consultants, Inc (MVA), Reservoirs Environmental, Inc. (REI), and Lab/Cor,
Inc will perform the primary laboratory analyses of the samples RTI International will perform
the independent quality assurance analyses of the samples QuanTech Inc will assist EQ in
preparing the study design and will perform the statistical analysis of the data.
The overall project organization is presented in Figure A-l It graphically shows the
functional organization structure and lines of communication for this project The project
structure along with the technical personnel selections are designed to provide efficient
management and a high level of technical competence to accomplish this research project The
roles and responsibilities of key project personnel are summarized in Table A-l
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EPA QAPP
Technical Development
Team
EPA Program Managers
Rogtr Wilrioth, O*D, NRMPL
15'3) 560-750°
,Vi';rk Hanson, Region 6
12--1)065-6529
EPA Region 6
Enforcement Officer
Dowici tippler
Arkansas DEQ
EPA Task Order Manager
Gleni S-iau'. OPD, NRMPL
15 i 3) 569-7406
EPA QA Officer
Lauren Drees, ORD, NRMR:.
;513) 569-7067
EQ Project Manager
'•o\.n komirbky
15! 3) 825-7600
EQ QA Manager
jack.e Doan
(51 3} 82i-750H
EQ Field Team Leaders
John Kom^nsky
Ori'.e Hol'ec
;513) 825-7500
Contractors
isocslos Abcrement
(~o Be Se'etfed)
Demolition
Fort Chaffee
Demolition Site
John KoTir?!^
City of Fort Smith
Landfill
Bn,ce .-icllell
Laboratory Analysis
lin Millerte, MVA
(7701 662-850°
Jeanre Orr, Rfl
(1031 "64-1986
John Morns, :.ab/Ce.r
(2061 78:-0155
QA Analysis
Mike Beoid, RTl
•9 10) 54: -6489
Ow«i Cranks'ncftv RTl
(910)541.7470
Data Analysis
Du.ic! Cox, OuanTech
(7C3J312-7808
*??s
Figure A-l. Project Organization Structure
O -i
NJ
O
O
Ui
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Table A-l. Roles and Responsibilities of Key Project Personnel
Personnel
Roger Wilmoth, U S EPA,
ORD, NRMRL
Mark Hansen, U S EPA,
Region 6
Glenn Shaul, U S EPA, ORD,
NRMRL
David Eppler, U S EPA,
Region 6
Lauren Drees, U S EPA, ORD,
NRMRL
John Kommsky, EQ
Jackie Doan, EQ
David Cox, QuanTech
James Millette, MVA
Jeanne Orr, REI
John Harris, Lab/Cor
Mike Beard, RTI
Owen Crankshavv, RTI
Arkansas Department of
Environmental Quality (DEQ)
QAPP Technical
Development Team
Abatement and Demolition
Contractors (To be Identified)
EQ Field Team Leaders
(J Kommsky and B Hollett)
Role and Responsibility
Co-Program Managers, will have overall administrative and technical
responsibility for this project
Taik Order Manager (TOM), will direct the project and ensure that it
is proceeding on schedule and within budget. Point of contact for EQ.
On-Site Enforcement Officer, will provide technical direction (as
needed) to the EPA TOM Point of contact for Fort Chaffee
ReDevelopment Authority
QA Officer, will provide QA oversight to ensure that the planning and
plan implementation are in accordance with the approved QAPP In
addition, ORD's QA Officer will oversee RTI's audits of MVA, REI,
and Lab/Cor
Project Manager, will have overall administrative and technical
responsibility for EQ and its sub-contractors to ensure that data
collection and analysis and the technical report meet the planned study
objectives
QA Manager, will review and approve the QAPP Provide overall QA
oversight and coordination to ensure acceptable data collection,
recovery, and analysis, as well as data validation
Statistician, will assist EQ's Project Manager with developing the
study designns. and perform the statistical analysis of the data
Microscopist, will provide primary laboratory analysis of asbestos air
samples using transmission electron microscopy (TEM) and phase
contrast microscopy (PCM)
Microscopist, will provide primary laboratory analysis of asbestos soil
and water samples (TEM) REI staff will provide laboratory analysis
of air and soil samples for inorganic lead
Microscopist, will generate and provide the primary laboratory
asbestos analysis of the soil elutriabon samples (TEM).
Microscopist, will direct/provide independent quality assurance (QA)
analysis of selected air and soil samples (TEM) collected for asbestos
Owen Crankshavv will also perform an on-site laboratory audit of
MVA, REI, and Lab/Cor
Inspector, will assure that NESHAP requirements are followed,
empowered to stop work if wind conditions or visible emissions or
adequately wet requirements in QAPP are not met.
Participated in development of the QAPP.
Will perform asbestos abatement of NESHAP Building and demolition
of both the NESHAP and Alternative Method Buildings
Will direct and oversee field sampling efforts
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AS PROBLEM DEFINITION/BACKGROUND
A5.1 Background
The Clean Air Act provides the EPA with the authority to promulgate a "workpractice
standard" if it is not feasible to establish an emission standard Under Section 112 of the Clean
Air Act, asbestos is determined to be a hazardous air pollutant and is regulated under EPA's
asbestos National Emission Standard for Hazardous Air Pollutants (NESHAP), 40 CFR Part 61,
Subpart M.
The asbestos NESHAP (a work practice standard) requires the removal of all regulated
asbestos-containing material (RACM)1 prior to demolition of the facility The asbestos
NESHAP specifies emission control procedures [§61 145(c)] and waste disposal requirements
[§61.150] that must be followed during demolition of a facility that contains asbestos above the
threshold amount.2 Section §61 150 of the asbestos NESHAP requires owners to "discharge no
visible emissions to the outside air" during demolition and renovation activities If a facility is
being demolished because it is structurally unsound and is in danger of imminent collapse,
RACM is not removed prior to demolition, but the RACM must be kept adequately wet during
demolition All of the contaminated debris must be kept adequately wet until disposal and must
be disposed of as ACM
The EPA will perform a controlled demonstration to compare the relative environmental
impacts of the Alternative Asbestos Control Method to the NESHAP method These data would
then be used to help EPA determine whether it is appropnate to include an alternate method in
the current asbestos regulations contained in 40 CFR part 61 subpart M The alternative method,
if determined to be environmentally acceptable but less costly than the current regulations, may
1 Under asbestos NESHAP, RACM means friable asbestos material, Category 1 non-friable ACM that
has become friable, or Category II non-friable ACM that has a high probability of becoming or has
become crumbled, pulverized, or reduced to powder by forces expected to act on the matenal in the
course of demolition
Asbestos NESHAP [§61 145(a)] requires that if the following amounts of RACM are present in a
facility, these materials must be removed prior to demolition: (1) At least 260 linear feet on pipes, or
(2) at least 160 square feet on other facility components; or (3) where the amount of RACM on pipes
or other components could not be measured before stripping, a total of at least 35 cubic feet from all
facility components in a facility being demolished
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have the benefit of allowing municipalities to demolish abandoned buildings that otherwise
would remain standing until they were in danger of imminent collapse
The Alternative Asbestos Control Method requires that certain RACM (such as thermal
system insulation and fireproofing) be removed before demolition in accordance with the
asbestos NESHAP, other RACM (such as wall board joint compound, resilient floonng/mastic,
glazing compound) may remain in place The alternative method varies from the existing
Asbestos NESHAP in the use of an amended-water wetting process, type of demolition
equipment, and demolition techniques Once the required RACM is removed, the demolition
proceeds using amended water suppression before, during, and after demolition to trap asbestos
fibers and minimize the potential release to the air The RACM is less likely to become friable
when the wetting process and demolition techniques specified in the alternative method are used
Wastewater generated during the demolition is collected and filtered, and all debris is disposed
of as asbestos-containing waste Soil in the affected area is excavated and disposed as asbestos-
containing waste Appendix A contains the Alternative Asbestos Control Method that was
developed by EPA Region 6, the EPA ORD, and with input from the EPA QAPP Technical
Development Team
The purpose of this research project is to compare the environmental and cost-
effectiveness of the Alternative Asbestos Control Method vs the current Asbestos NESHAP
method through a side-by-side comparison of the demolition of buildings that are architecturally
identical in composition and structure This research project will assist EPA in comparing
existing demolition practices of the Asbestos NESHAP with potentially more cost-effective
demolition practices
A5.2 Objective
The goal of this research study is to compare the effectiveness of the Alternative
Asbestos Control Method to the current asbestos NESHAP demolition practice on buildings that
are architecturally identical. This means that the environmental releases of asbestos to the air
and to the soil as measured by their respective concentrations are not greater in the case of the
Alternative Method than those of the NESHAP Method In addition, the cost of the Alternative
Method must be less than the NESHAP Method for the Alternative to be attractive All of the
data collected will be evaluated and considered, as appropriate, to make this comparison
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Emissions must be inferred from measured concentrations in receptors (air, soil, water,
dust, and personal monitoring). Because of the complex nature of the potential emissions from
building demolition, it is difficult to state in advance precisely how these data will be evaluated,
but all the data and observations obtained will be used to make the comparison between the two
methods
A5.2.1 Primary Objectives
1 To determine if the airborne asbestos (TEM) concentrations from the Alternative
Method are statistically equal to or less than the NESHAP Method
2 To determine if the post-excavation asbestos concentrations in the soil from the
Alternative Method are statistically equal to or less than the post-demolition NESHAP
Method The Alternative Method requires soil excavation following demolition and the
NESHAP Method does not.
3. To determine if the Alternative Method is more cost-effective than the NESHAP
Method considering all costs, including disposal of all asbestos-contaminated materials
and soils, and projected costs for enforcement
A5.2.2 Secondary Objectives
The following secondary objectives will provide additional information to further
characterize the interrelationships among several multimedia parameters to enhance the
understanding of the process and to further the science These data will also be considered in a
holistic sense in assessing the comparability of the two demolition methods
AIR
1 To determine background asbestos concentrations (TEM) prior to the NESHAP
Abatement and again prior to the Alternative Demolition
2 To determine if the airborne fiber (PCM) concentrations from the Alternative Method
are statistically equal to or less than the concentrations from the NESHAP Method
3 To document visible emissions during both demolitions
4. If wind conditions allow, to determine if the airborne asbestos concentrations
downwind are statistically greater than the upwind concentrations for the Alternative
Method
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If wind conditions allow, to determine if the airborne asbestos concentrations
downwind are statistically greater than the upwind concentrations for the NESHAP
Method
DUST
6 To determine if the asbestos concentrations in the settled dust (TEM) from the
Alternative Method are statistically equal to or less than the concentrations from the
NESHAP Method
WORKER
7 To determine if worker fiber exposure concentrations (PCM) from the Alternative
Method are statistically different than the concentrations from the NESHAP Method
8 To determine if worker asbestos exposure concentrations (TEM) from the Alternative
Method are statistically different than the concentrations from the NESHAP Method
ACTIVITY
9 To document worker asbestos exposure concentrations (TEM) for individuals that are
maintaining the perimeter air monitoring network
SOIL
10 To determine if the asbestos concentration in the post-excavation soil from the
Alternative Method is statistically equal to or less than the pre-demohtion asbestos
concentration
11 To determine if the asbestos concentration in the post-demolition soil from the
NESHAP Method is statistically equal to or less than the pre-demolition asbestos
concentration.
12 To determine if asbestos concentration in the post-excavation soil is statistically
different than the concentration in the post-demolition soils from the Alternative
Method
13 To determine if asbestos concentrations from elutriator tests on the post-excavation
soils from the Alternative Method are statistically equal to or less than the
concentrations from the post-demolition NESHAP Method
14 To determine if asbestos concentrations from elutriator tests on the post-excavation
soils from the Alternative Method are statistically equal to or less than the pre-
demolition concentrations
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15 To determine if asbestos concentrations from elutriator tests on the post-demolition
soils from the NESHAP Method are statistically equal to or less than the pre-
demolition concentrations
16 To determine if asbestos concentrations from elutriator tests on the post-excavation
soil are significantly different than the concentrations from tests on the post-
demolition soil from the Alternative Method.
WATER
17. To measure the asbestos concentrations in the water applied to control emissions from
both the Alternative and NESHAP Methods and to measure the asbestos concentrations
in collected water for both processes during demolition activities
LANDFILL
18 To determine background airborne asbestos concentrations (TEM) prior to
landfilling of the NESHAP Building debns and again prior to landfillmg of the
Alternative Method Building debns
19 To determine if the airborne asbestos concentrations at the landfill (TEM) during
disposal of the Alternative Method debris are statistically equal to or less than the
concentrations during disposal of the NESHAP Method debris
20 To determine airborne asbestos concentrations at the landfill (TEM) during disposal
of the asbestos-containing materials (ACM) removed prior to demolition of the NESHAP
Building
21 To determine if landfill worker fiber exposure concentrations (PCM) from the
Alternative Method are statistically different from the NESHAP Method
22 To determine if landfill worker asbestos exposure concentrations (TEM) from the
Alternative Method are statistically different from the NESHAP Method.
TIME
23 To document the time required for all activities related to the demolition by the
Alternative Method and for the NESHAP Method, including abatement
MODELING
24 To collect additional asbestos, fiber, and dust data necessary for potential future air
dispersion modeling efforts
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Regulatory Requirements for Lead:
In addition, worker exposure sampling will be conducted for lead in accordance with
29 CFR §1926 62, which applies to all abatement, demolition, and landfilling activities involved
in this study.
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A6 PROJECT/TASK DESCRIPTION
A6.1 Technical Approach
The project will gather data on the Asbestos Alternative Control Method's ability to
prevent or minimize the release of asbestos fibers during demolition and disposal of a building
containing RACM versus a building abated and demolished in accordance with the Asbestos
NESHAP These data would then be used by EPA to determine if it is appropriate to include an
alternate method in the current asbestos regulations contained in 40 CFR Part 61 Subpart M All
of the data collected will be evaluated and considered, as appropriate, to support decisions about
the future use of the Alternative Method.
The buildings are located at the Fort Chaffee Redevelopment Authority in Fort Smith,
Arkansas (Figure A-2) The NESHAP (#3602) and Alternative Method (#3607) Buildings are
shown in Figure A-2. In addition, two adjacent buildings were surveyed and the results were
similar but are not presented in this QAPP because the buildings are not part of the study
The demolition site is in a remote, secure location to ensure no public exposure There
are no private residences within a radial distance of one mile from the study buildings The
nearest residence is approximately two miles from the demolition site The buildings have a
clearance of approximately 1,000 linear feet from the nearest occupied military building on the
eastern side, and greater than 1,400 linear feet in all other directions
These 1940-era buildings are architecturally identical both in composition and structure
(Figures A-3 through A-5), which is ideal for the testing and comparative evaluation of the
Alternative Method versus the Asbestos NESHAP Method The building footprint is
approximately 4,500 square feet (30 feet by 150 feet) The buildings are wood frame
construction with wood clapboard exterior siding and asphalt shingle roofs The interior finish is
gypsum wallboard on both the ceiling and walls, and associated painted millwork Resilient
floor tile (9 inch by 9 inch) is present in all areas excluding the bathrooms, which is resilient
sheet vinyl The building has a concrete pier and wooden beam foundation system The
buildings utilized window unit air conditioners with heating formerly supplied by radiant heaters
Forced hot water for the radiant heat was supplied by a central steam plant located elsewhere in
the complex
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Figure A-2. Aerial view of project location at Fort Chaffee. Buildings selected for
demolition are #3602 (NESHAP Method) and #3607 (Alternative Method).
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Figure A-3. (Top) Exterior view of Building #3602 (NESHAP Method)
and (Bottom) #3607 (Alternative Method). Dimensions: 30-feet by 150-feet.
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Figure A-4. Interior view of Building #3602. Interior finishes are
gypsum wallboard (ceiling and walls) and 9- by 9-inch resilient floor tile.
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Figure A-5. Interior view of Building #3607. Interior finishes are gypsum
\\iillhoard (ceiling and walls) and 9- by 9-inch resilient floor tile.
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All asbestos-containing thermal system insulation on the steam pipes associated with
these buildings has been previously abated
The demolition debris will be transported to City of Fort Smith's Subtitle "D" landfill
The landfill is owned and operated by the City of Fort Smith It is located at 5900 Commerce
Road in Fort Smith, which is approximately 7 miles southwest of the demolition site
A6.1.1 Pre-Demolition Inspection of Buildings
A6.1.1.1 Asbestos Inspection of Buildings
A comprehensive pre-demohtion inspection was conducted m accordance with the
Asbestos Hazard Emergency Response Act (40 CFR §763) to identify the type, quantity,
location, and condition of RACM in the buildings [§61 145(a)] (Kommsky 2005, Smith 2005)
The inspection was conducted by a State of Arkansas Department of Environmental Quality
(ADEQ) licensed Asbestos Abatement Consultant The inspection data will be used to determine
the pre-demohtion asbestos abatement plan for these buildings
The samples were analyzed for asbestos content by using polarized light microscopy
(PLM) and dispersion staining in accordance with EPA's "Methodfor the Determination of
Asbestos in Bulk Building Materials" (EPA/600/R-93/116, July 1993) Gravimetric reductions
followed by TEM analyses (as specified in EPA/600/R-93/116, July 1993) were performed on
wallboard joint compound, resilient floor tile, and window glazing compound samples For
materials composed of distinct layers (e g, wallboard joint compound, Figure A-6) or two or
more distinct building materials (e g , shingle and roofing felt), each layer or distinct building
material was treated as a discrete sample The layers or materials were separated and analyzed
individually The laboratory reported a single value for each material or discrete layer In
addition, the laboratory reported a composite value for wallboard joint compound samples.
Composite values were calculated using estimates of the quantity of each layer in the sub-sample
as determined by measuring to a distance as wide as the seam (Figure A-6, dl) on both sides of
the seam (Figure A-6, d2) That is, the sample used to estimate the quantity of each layer is
represented by d2 in Figure A-6
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Figure A-6. Section of '/2-inch gypsum wallboard showing a
multi-layered joint interval. Wallboard was obtained from
Building #3607 at Fort Chaffee.
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Table A-2 summarizes the results of the building material samples collected from the
NESHAP Method (#3602) and Alternative Method (#3607) Buildings
Table A-2. Asbestos Content of Building Materials Based on PLM and
Gravimetric Reduction (GR)/TEM Analysis
Homogeneous Material
Number
of Samples
Mineral
Asbestos Content, %
PLM
GR/TEM
NESHAP Method Building (#3602)
Wallboard
Flooring
Roofing
Joint Compound
Joint Interval Composite
Non- Joint Skim Coat
9- by 9-mch Tile
Sheet
Mastic
Shingle
Felt
Glazing Compound
Attic Insulation
4
4
4
4
4
4
4
4
4
Chrysotile
Chrysotile
Chrysotile
Chrysotile
-
.
-
Chrysotile
-
1-5
NA
NDa-
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Pollution Control and Ecology Commission Regulation 21 (A C A §20-27-1001 and §8-4-11 et
sea) Technical Specifications for Asbestos Abatement will be prepared by an ADEQ licensed
Asbestos Project Designer Prior to demolition of the Alternative Method Building (#3607), no
asbestos-containing materials will be removed
Table A-3. RACM Present in the NESHAP Method and Alternative Method Buildings
Sample
Group
HA"
Material
Description
Sample
Location
Friable/
Non-
Friable
Quantity
Condition
NESHAP Method Building (#3602)
3602-RFC-
02
3602-FT-03
3602-WG-
05
3602-JC-06
2
3
5
6
Red Multi-Colored
Linoleum
Brown Floor Tile
Window Glazing
Wallboard Joint
Compound
Bathrooms
Throughout
Windows
Throughout
Non-Friable
Non-Friable
Friable
Non-Friable
252ft2
3,992 ft2
814 If
20,700 ft2
Good
Good
Damaged
Good
Alternative Method Building (#36(17)
3607-RFC-
02
3607-FT-03
3607-JC-06
2
3
6
Red Multi-Colored
Linoleum
Brown Floor Tile
Wallboard Joint
Compound
Bathrooms
Throughout
Throughout
Non-Friable
Non-Friable
Non-Friable
252 ft2
3,992 ft2
20,700 ft2
Good
Good
Good
"HA = Homogeneous Area
A6.1.1.2 Lead Paint Inspection of Buildings
The NESHAP Method (#3602) and Alternative Method (#3607) Buildings were surveyed
for inorganic lead to characterize the potential for occupational exposure during demolition and
landfilhng of the resultant construction debris3 The samples were prepared for analysis in
accordance with EPA SW-846 Method 3050 and analyzed by inductively coupled plasma atomic
emission spectroscopy (ICP-AES) m accordance with EPA SW-846 Method 6010
The OSHA Lead Standard (29 CFR § 1926 62) does not define lead-paint based on the amount of lead present That
is, the standard does not specify a minimum amount or concentration of lead that triggers a determination that lead is
present and the potential for occupational exposure exists It is theoretically not possible to exceed the OSHA
permissible exposure limit of SO jag/m3, 8-hour time-weighted average (TWA) if the lead-content is <600 ppm
(equivalent to 0 06%) Accordingly, exposure monitoring must be conducted when the lead content of the material is
> 600 ppm to determine if a worker is being exposed to lead at or above the action level of 30 ng/m3 8-hour TWA
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Table A-4 presents the levels of lead measured in paint chip samples obtained from
Buildings #3602 and #3607 Because the paint contains >600 ppm lead, personal exposure
monitoring will be conducted during asbestos abatement of Building #3602 and during
demolition of both buildings in accordance with OSHA Lead Standard 29 CFR §1926 62 Pnor
to demolition of the buildings, three representative composite bulk samples of the lead-
containing building materials will be analyzed to determine the teachable lead content (EPA SW-
846 Method 1311, Toxicity Characteristic Leaching Procedure), as required by the local landfill
operator In addition, subsequent to demolition of the buildings three representative bulk
samples of soil will be collected for teachable lead
Table A-4. Concentrations of Lead in Paint Chip Samples From
Interior and Exterior Building Components
Building Component
Number
of Samples
Concentration of Lead, ppm
Mean
Minimum
Maximum
NESHAP Method (#3602) Building
Millwork
Gypsum wallboard
Exterior clapboard siding
4
4
4
11,400
1,313
81,500
4,400
500
34,000
24,000
2,000
120,000
Alternative Method (#3607) Building
Millwork
Gypsum wallboard
Exterior clapboard siding
4
4
3
12,000
1,225
55,333
8,000
1,000
46,000
15,000
4,000
73,000
A6.1.1.3 Concentrations of Asbestos in Soil
A total of nine individual soil samples were collected for asbestos Three samples were
collected from beneath each of the two buildings, and three samples were collected from the
perimeter of the two buildings at approximately 15 feet from the face of the buildings
The soil samples were collected by using a clean scooping tool to acquire approximately
the top '/z-inch of soil from a 10-inch by 10-inch area. The samples were analyzed for asbestos
content by using PLM and dispersion staining in accordance with EPA's "Methodfor the
Determination of Asbestos m Bulk Building Materials" (EPA/600/R-93/116, July 1993). The
soil samples were also analyzed for asbestos by using gravimetric reduction and subsequent
TEM analysis described in the above method The asbestos contamination levels present in the
soil are summarized in Table A-5
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Table A-5. Asbestos in Soil (PLM and Gravimetric Reduction (GR/TEM)
Location
Number
of Samples
Asbestos Found"
Asbestos Content, %
PLM
GR/TEM
NESHAP Method (#3602) Building
Beneath Building
3
Chrysotile
TRa
BASC
Alternative Method (#3607) Building
Beneath Building
3
Chrysotile, Amosite, Anthophyllite
TR
BAS-005
Perimeter of Buildings
Perimeter
3
ND
ND
NDb
BAS
aTR = Trace, <1% by visual estimate
""ND = None Detected
°BAS = Below analytical sensitivity, 0 001 (mass %)
dlf detected, no more than one fiber was observed in any sample.
A6.1.2 Demolition of Buildings and Site Management
The NESHAP Method Building (#3602) will be demolished in accordance with the
procedures specified in 40 CFR Part 61, Subpart M, and in the "Guide to Normal Demolition
Practices Under Asbestos NESHAP" (EPA-340/1-92-013, September 1992) The Alternative
Method Building (#3607) will be demolished by using the demolition practices specified in the
"Alternative Asbestos Control Method" contained in Appendix A The NESHAP Method
Building (#3602) will be demolished first (including removal of the foundation and all associated
debris) and then the Alternative Method Building (#3607) will be demolished To prevent the
potential cross contamination of the Alternative Method Building during demolition of the
NESHAP Method Building, the Alternative Method Building as well as the soil within the
containment berm will be covered with 6-rml polyethylene sheeting
To reduce the number of variables involved in the comparison and to evaluate the
NESHAP under optimum conditions in this research study, certain practices of the NESHAP
process are prescribed These practices are listed below
• A new high-efficiency participate air (HEPA) filter will be used in each HEPA-filtration
unit during the abatement of the NESHAP Method Building.
• In-place performance of the HEPA filtration units will be evaluated using an air-
generated dioctyl phthalate (DOP) aerosol as well as by direct measurement (isokinetic
sampling) of the asbestos concentration in the discharge air of each unit
• Demolition equipment will be identical to that used for the Alternative Method Building
• Demolition debris disposal vehicles will be washed before leaving the NESHAP site
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A6.1.3 Environmental Monitoring During Demolition of Buildings
An analysis was conducted of 3,660 hours of meteorological data (wind direction and
wind speed) collected between 07 00 to 18 00 hours from March 1 through Apnl 30 during the
years of 1999, 2000, and 2002 through 2004 at the Fort Smith Municipal Airport (Station
#13964), see Figure B-8, Section Bl 1 The demolition study is projected to be conducted
during March 2006, see Figure A-7 The wind direction varied between up to six 20-degree
sectors during a given day Hence, it was concluded that the primary air sampling design should
be based on a concentric ring approach rather than on an upwind to downwind approach (see
Section Bl) This study design is consistent with the primary objective of this project i e, to
compare the effectiveness of the Alternative Asbestos Control Method to the Asbestos NESHAP
Method
A6.1.3.1 Perimeter Air Monitoring During Demolition
A series of stationary air monitors will be positioned to measure the concentration of
airborne asbestos fibers from demolition of the NESHAP Method (#3602) and Alternative
Method (#3607) Buildings. The movement of the released asbestos fibers with the prevailing
winds (transport), the vertical movement of the fibers due to turbulence (dispersion), and the
amount of fibers removed due to deposition will be influenced by the physical properties of
asbestos fibers, the release characteristics during demolition and debris handling, and by
meteorological conditions
The perimeter air monitoring network will consist of three concentric rings around the
rectangular-shaped buildings (see Section Bl) The monitors will be distributed at
approximately equal distances along each of the three rings The monitors will be placed at two
heights (5- and 15-ft) on Ring #1 (the primary ring) and will be placed at a height of 5-ft on
Rings #2 and #3
The distance of the rings from the face of the building was determined by using two
EPA dispersion models SCREEN3 and ISCST3 (see Section Bl) SCREENS (a Gaussian
plume dispersion model) is a screening tool that uses a worst-case meteorology to produce a
conservative one-hour average air concentration estimate A refined modeling analysis was then
conducted by using the ISCST3 (a steady-state Gaussian model) to predict location (i e , lateral
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distance and height above ground level) where the maximum concentration of airborne asbestos
is likely to occur.
The placement of the monitors will be sited and documented by using a global
positioning system (Thales® Navigation MobileMapper G1S Data Collection System)
Meteorological conditions (such as wind direction and wind speed) will be determined
during sampling For this study, if sustained wind speeds of 15 mph (60-mmule average) or
gusts above 20 mph are encountered, demolition and momtonng will pause until the wind speed
is less than these conditions.
The demolition activities will be divided into two periods' morning and afternoon All
stationary monitors will be activated shortly before demolition activities begin, and will continue
until demolition activities cease for that period Each building demolition is expected to take one
day
A6.1.3.2 Personal Air Monitoring of Workers During Demolition
All workers directly involved with demolition of the building and handling of resultant
debris will wear personal protective equipment as specified in the site-specific Health and Safety
Plan (HASP) In accordance with OSHA Standards 29 CFR §1926 1101 (Asbestos) and 29 CFR
§1926 62 (Lead), each worker's personal breathing zone exposure concentration to asbestos fibers
and lead will be measured In addition, this momtonng will provide a reasonable
characterization of the asbestos and lead concentrations in air closest to the source of any
potential release, i e., building demolition and debris loading
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A6.1.3.3 Impact on Soil from Demolition
The potential impact on the soil will be evaluated by comparing the asbestos
concentrations in the soil before ("baseline") and after demolition For the NESHAP Method
Building, the asbestos concentration in the soil following demolition will be used for this
comparison For the Alternative Method Building, since the Alternative Asbestos Control
Method requires that two to three inches of soil be excavated following demolition, the asbestos
concentration in the soil after excavation will be used for this comparison
A6.1.3.4 Settled Dust from Demolition
The amount (concentration) of asbestos deposited on surfaces around the site during
building demolition and debns handling of the Asbestos NESHAP Method Building will be
compared to that deposited during building demolition and debns handling using the Alternative
Asbestos Control Method The samplers will be placed at the same locations as some of the
perimeter air samples (see Section A6 1 3 1).
A6.1.3.5 Water used During Demolition
Source Water—Samples of the source water (i e, fire hydrant water) applied during both
the NESHAP Method and Alternative Asbestos Control Methods will be collected for asbestos
analysis at both the commencement and completion of the respective building demolitions Also,
background water samples from the hydrant will be taken and analyzed for asbestos prior to the
test If the source water contains asbestos, an alternative non-asbestos-containing water supply
will be used for this study
The hydrant water will be applied to both the NESHAP Method and Alternative Method
Buildings with a variable rate 11-G (11 gpm) or 30-G (30 gpm) nozzle A water meter (or
equivalent device) will be installed at the hydrant to measure the volume of water applied to each
of the buildings
For the Alternative Method Building, the surfactant used to create the amended water will
be applied using an in-line eductor. A sample of the amended water used will also be collected
Surface Water—Representative samples of surface water will be collected during the
duration of the demolition activity for both the NESHAP Method and Alternative Method
Buildings Small impervious drainage channels will be constructed to assure surface water
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runoff collection in metal-fabncated basins located within the containment berm The
containment berm will be sufficiently spaced from the building to permit the movement of the
demolition equipment and to allow the truck loading to occur within the enclosed space The
sampling of the collected runoff water will be spaced over the duration of the demolition activity
Sample collection volumes will be noted as a function of time and as a function of the
progression of the demolition
A6.1.3.6 Soil Elutriation Tests
Soil samples will be collected to measure the asbestos concentration in respirable dust
from residual asbestos fibers in the soil before and after demolition of the buildings The soil
samples will be prepared for analysis using the Modified Elutriator Method for the
Determination of Asbestos in Soils and Bulk Materials (Revision 1), May 23, 2000. see Section
B27
A6.1.4 Air Monitoring at Landfill
A6.1.4.1 Perimeter Air Monitoring During Landfilling of Debris
A series of stationary air monitors will be positioned to measure the release of airborne
asbestos fibers during landfilling of the demolition debris from the NESHAP Method (#3602)
and Alternative Method (#3607) Buildings
The perimeter air monitoring network will consist of one ring of monitors The goal will
be to place the monitors at 40-degree intervals measured along a radius from the center of the
asbestos landfilling activity as site conditions permit, i e , topography and other landfilling
activities The monitors will be placed at a height of five feet above ground The monitors will
be sited and documented by using a global positioning system (Thales® Navigation
MobileMapper CIS Data Collection System)
Meteorological conditions (such as wind direction and wind speed) will be determined
during sampling If sustained wind speeds of 15 mph (60-mmute average) or gusts above 20
mph are encountered, landfilling will pause until the wind speed subsides below these levels.
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A6.1.4.2 Perimeter Air Monitoring During Landfilling of Bagged ACM Debris from
NESHAP Method Building
A series of stationary air monitors will be positioned to measure the release of airborne
asbestos fibers during landfillmg of bagged ACM from the NESHAP Method Building (#3602)
The perimeter air monitoring network will consist of one ring of monitors The goal will be to
place the monitors at 40-degree intervals measured along a radius from the center of the asbestos
landfillmg activity as site conditions permit, i.e, topography and other landfillmg activities. The
monitors will be placed at a height of 5 feet above ground The monitors will be sited and
documented by using a global positioning system (Thales® Navigation MobileMapper GIS Data
Collection System)
Meteorological conditions (such as wind direction and wind speed) will be determined
during sampling If sustained wind speeds of 15 mph (60-minute average) or gusts above 20
mph are encountered, landfillmg will pause until the wind speed subsides below these levels
A6.1.4.3 Air Monitoring of Workers During Landfilling
All workers directly involved with the landfillmg of the demolition debns will wear
personal protective equipment as specified in the site-specific Health and Safety Plan (HASP)
In accordance with OSHA Standard 29 CFR §1926.1101 (Asbestos) and 29 CFR §1926 62
(Lead), each worker's personal breathing zone exposure concentration to asbestos fibers and lead
will be measured In addition, this monitoring will provide a reasonable characterization of the
asbestos and lead concentrations in air closest to the source of any potential release, i e ,
landfilling of the debris
A6.1.5 Background Perimeter Air Monitoring
A6.1.5.1 Air Monitoring Prior to Asbestos Abatement of NESHAP Method Building
Air monitoring prior to asbestos abatement of the NESHAP Method Building will be
conducted to collect data to compare air concentrations of asbestos dunng demolition to
comparative background4 concentrations. The monitoring will be conducted on one day
immediately prior to abatement of the building Monitoring will be conducted between
Environmental''comparative" background is the airborne concentration of asbestos that is normally
present in the area of the subject activity, i e , building demolition site at Fort Chaffee or landfilling
activity at the City of Fort Smith Class D Landfill
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approximately 08 00 and 12 00 hours and between 12-00 to 16-00 hours The same number of
samples will be collected during each sampling event The air monitoring network will consist
of one ring of monitors around the building The monitors will be placed at 60-degree intervals
measured along a radius from the center of the building The monitors will be placed within 15
feet of the building and at a height of 5 feet above ground If wind conditions exceed 15 mph
average or 20 mph gusts, sampling will be delayed until acceptable conditions resume
The monitors will be sited and documented, and the meteorological conditions (such as
wind direction and wind speed) will be determined as described in Section A6 1 3 1
A6.1.5.2 Air Monitoring Prior to Demolition of Alternative Control Building
Air monitoring prior to demolition of the Alternative Control Building will be conducted
to collect data to compare air concentrations of asbestos during demolition to comparative
background concentrations The monitoring will be conducted prior to demolition as described
in Section A6 1 5 1
The monitors will be sited and documented, and the meteorological conditions (such as
wind direction and wind speed) will be determined as described in Section A6 1 3.1
A6.1.5.3 Air Monitoring Prior to Landfllling of Bagged ACM and Building Debris
Air momtonng prior to landfilling will be conducted to collect data to compare air
concentrations of asbestos during landfilling to comparative background concentrations The
monitoring will be conducted prior to landfilling as described in Section A6 1 5 1
The monitors will be sited and documented, and the meteorological conditions (such as
wind direction and wind speed) will be determined as described in Section A6 1 3 1
A6.1.6 Air Monitoring During Asbestos Abatement of NESHAP Method Building
A6.1.6.1 Air Monitoring of Discharge Air from HEPA-Filtration Units
Previous studies conducted by EPA of air filtration units equipped with HEPA filtration
to maintain a negative static air pressure at asbestos abatement sites showed that a large
percentage of the units discharged asbestos fibers (Kommsky et al 1989, and Wilmoth et al
1993). In-duct monitoring of the discharge air from each HEPA-filtration unit used during the
abatement of the NESHAP Building will be conducted In-place performance will be conducted
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to determine each HEPA filtration unit's particle-removal efficiency using an air-generated
dioctyl phthalate (DOP) aerosol (Kommsky et al 1989) Isokmetic sampling5 will also be
conducted of the discharge air of each air filtration unit during abatement to determine the
asbestos fiber concentration (Wilmoth et al 1993)
A6.1.6.2 Air Monitoring of Ambient Air during Loading of Bagged ACM
The air around the disposal container (e g , truck or roll-off container) will be monitored
to determine whether this loading activity releases airborne asbestos fibers above comparative
background (see Section A6 151) The removed materials (e g , gypsum wallboard) will be
double bagged in 6-mil polyethylene bags The bagged material will be stored in the building
and loaded out during one event If space restrictions require the material to be loaded out more
frequently, each event will be monitored
The monitors will be placed at 60-degree intervals measured along a radius from the
center of the disposal container. The monitors will be placed within 10 feet of the loading area
and at heights of 5 feet and IS feet above ground The monitors will be sited and documented,
and the meteorological conditions (such as wind direction and wind speed) will be determined as
described in Section A6 1 3 1
A6.2 Personnel
The key project personnel are identified in the project organization chart presented in
Figure A-l
A6.3 Project Schedule
The proposed project schedule is presented in Figure A-7 The project schedule
commences with Contract Award on May 23, 2005 and is completed with submission of the final
report on December 29, 2006 The project schedule shows the major tasks, duration, and
deliverables.
In isokuietic sampling, the velocity of air entering the sample nozzle (Vn) is the same as the velocity of
the air stream (Vs) That is, the area of the sample nozzle tip opening (An) and the sample volume flow
rate (Qs) must be adjusted to obtain a velocity (Vn = Qs/An) equal to the air stream velocity (Vs) at the
sampling point The sampling constraint (Vn = Vs) is termed isokmetic sampling or equal velocity
sampling
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A7 QUALITY OBJECTIVES AND CRITERIA FOR MEASUREMENT DATA
The overall quality assurance objective of this project is to implement procedures for
field sampling, laboratory analysis, and reporting that will provide data for the development of
scientifically valid conclusions and support decision making regarding the project objectives
identified in Section A5 2 EPA has developed a seven-step Data Quality Objective (DQO)
procedure designed to ensure that data collection plans are carefully thought out and to maximize
the probability that the results of the project will be adequate to support decision-making (EPA
QA/G-4, August 2000, EPA/600/R-96/055) This seven-step decision process has been applied
to the Primary Project Objectives
A7.1 First Primary Objective
To determine if the airborne asbestos (TEM) concentrations from the Alternative Method
are statistically equal to or less than the NESHAP Method
A7.1.1 Step 1: State the Problem
The asbestos NESHAP (40 CFR Part 61, Subpart M) requires the removal of all RACM
pnor to demolition of the facility Asbestos removal in accordance with NESHAP can account
for a significant portion of the total demolition cost Reportedly, a common practice among
municipalities is to allow orphaned structures to decay to the point of collapse prior to
demolition due to the expense of NESHAP abatement Demolition of these asbestos-containing
buildings that have been declared to be unsafe for entry could result in the release of asbestos to
the environment
The EPA will perform a controlled demonstration as part of the Agency's effort to
compare the effectiveness of the Alternative Asbestos Control Method to the NESHAP Method
The Alternative Asbestos Control Method, if successful, would likely accelerate the demolition
of many orphaned buildings around the nation that remain standing and present a variety of
potentially serious risks to nearby residents
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A7.1.2 Step 2: Identify the Decision
Is the airborne concentration of asbestos during demolition of a building and debris
loading using the Alternative Asbestos Control Method equal to or less than the concentration of
asbestos during demolition of a building and debris loading in accordance with the Asbestos
NESHAP Method?
A7.1.3 Step 3: Identify Inputs to the Decision
Information that is required to resolve the decision statement
1 Accurate and representative measurements of airborne asbestos concentrations
released during demolition of the buildings using the NESHAP Method and
Alternative Asbestos Control Methods
2 An analytical sensitivity that is sufficiently low to detect a difference between the
two demolition methods
3. Accurate and representative measurements of the wind speed and wind direction
during demolition of the buildings
A7.1.4 Step 4: Define the Study Boundaries
1 Spatial boundary of the decision statement This decision related to the air
concentration of asbestos is defined as the area within the outermost ring around
the NESHAP Method Building (#3602) and the Alternative Method Building
(#3607) The outermost ring is approximately 100 feet from the face of the
building The spatial boundary around Buildings #3602 and #3607 is shown in
Figures B-10 and B-l 1, respectively (see Section B) Further, decisions regarding
the air matrix apply to air within the breathing zone of potentially exposed
individuals engaged in demolition and debris handling at the Fort Chaffee site
2 Temporal boundary of the decision statement Weather conditions such as
freezing temperatures will impede the demolition contractor's ability to
adequately wet the structure Rain conditions may influence the transport and
deposition of asbestos fibers released from demolition and debris handling The
study will not be conducted dunng rain conditions Sustained wind speeds of 15
mph (60-mmute average) or gusts above 20 mph may affect the transport and
dispersion of asbestos fibers, i e, the asbestos concentration would be inversely
proportional to the wind speed To ensure that this does not occur, demolition and
sampling will cease when the wind speed in the area exceeds these values and will
resume when conditions stabilize To ensure adequate conditions to detect any
visible emissions that are visually detectable without the aid of instruments, the
demolition will be conducted dunng daylight hours (07:00 to 19 00 hours)
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3 Practical constraints on data collection
• Loading of paniculate on a single sample filter collected over the entire
one-day period of the demolition and debris loading activities could
prevent the direct preparation of the filters for TEM analysis.6 To
minimize the probability of such an occurrence, two consecutive samples
of 4-5 hours will be collected over a single workday Although
undesirable, should overloading occur on most filters, an indirect TEM
method will be used for analysis (ISO 13794 1999)
• The number and placement of stationary air monitors could be affected by
demolition and debris handling activities. This is particularly applicable
on the north side of the buildings where the demolition excavator is
located and debris loading activities will occur Physical constraints for
demolition equipment access may necessitate the movement of some
samplers as the physical conditions require
A7.1.5 Step 5: Develop a Decision Rule
The decision rule is based on the comparison of the air concentration of asbestos from the
demolition of the Alternative Method Building to that for the NESHAP Method Building The
null hypothesis is that the geometric mean airborne asbestos concentration from the demolition
of the Alternative Method Building is equal to or less than the geometric mean concentration
from the demolition of the Asbestos NESHAP Method Building The alternative hypothesis is
that the geometric mean airborne concentration released from the demolition of the Alternative
Method Building is greater than the geometric mean concentration from the demolition of the
Asbestos NESHAP Method Building All tests will be conducted at the 0 05 level of
significance
A7.1.6 Step 6: Tolerable Limits on Decision Errors
Airborne asbestos measurements tend to be highly variable and to follow a significantly
skewed distribution, most of which are conveniently modeled using the lognormal distribution
A lognormal random variable Y is such that the natural logarithm, X = ln(Y), has a normal
distribution N(u., a2) with mean u. and standard deviation a Alternatively, Y = ex where X has a
normal distribution As this formulation shows, all values of a lognormal random variable are
The direct transfer TEM method (ISO 10312-1995) should not be used if the general paniculate
loading of the sample collection filter exceeds approximately 10 ug/cm2 of filter surface, which
corresponds to approximately 20 percent coverage of the collection filter by paniculate
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strictly positive Therefore, any nondetect airborne asbestos measurements (i e , samples for
which no asbestos fibers are detected on any of the grid openings viewed by the analyst) must be
assigned a positive value for purposes of lognormal modeling The assigned value should be less
than or equal to the airborne asbestos concentration corresponding to a single measured fiber,
which is the smallest detectable value that can be reported The simplest approach is to assign
to any nondetect measurement an airborne asbestos concentration one-half that corresponding to
a single measured fiber. Recognizing that this assignment is somewhat arbitrary, we will test the
robustness of our conclusions by performing a sensitivity analysis That is, we will repeat the
statistical test described in this section using different fixed assigned values for nondetects, and
also using a random assigned value for each nondetect We expect that the sensitivity analysis
will show the same results as the base analysis However, if it does not, the results of the
lognormal model will be considered inconclusive, and alternative approaches (e g ,
nonparametnc approaches such as the Wilcoxon rank test, see Section 3 1 below) will be
explored
The statistical model on which the comparison of airborne asbestos concentrations
between the two methods is based is as follows
ln(N) = N(u,,o-2)
ln(A)=N(u2,a2)
where N refers to the NESHAP Method and A refers to the Alternative Method The hypothesis
test to be conducted is
Ho U2Hl
That is, the null hypothesis HO is that airborne asbestos concentrations from the
Alternative Asbestos Control Method are less than or equal to those from the Asbestos NESHAP
Method, while the alternative HI is that airborne asbestos concentrations from the Alternative
Asbestos Control Method are greater than those from the Asbestos NESHAP Method Because
of the lognormaJ model, the companson is implicitly between the geometric mean concentrations
from the two methods
The hypothesis test will be carried out using the two sample t-test (Bickel and Doksum
1997) applied to the natural logs of the 18 airborne asbestos measurements taken at the five-ft
level in the primary nng (see Section Bl) for each method If the mean asbestos concentration is
higher for samples collected at the 15-ft feet height than the mean asbestos concentration at the
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five-ft height for both the NESHAP Method and Alternative Method tests, then the 15-ft sample
concentrations will be used for the comparison A detailed discussion of the statistical analysis is
presented in Section BIO 3 The null hypothesis will be rejected, i e , we will conclude that
airborne asbestos releases from the Alternative Asbestos Control Method are greater than those
from the Asbestos NESHAP Method, if
T > t34(0 95) = 1 6909
where T is the two-sample t-statistic and t34(0 95) is the 95th percentile of the t-distnbution with
34 degrees of freedom (df) This test has a Type I error rate of 5%, i e , there is no more than a
5% probability of falsely rejecting the null hypothesis HO Thus, there is only a 5% chance of
falsely concluding that airborne asbestos concentrations from the Alternative Asbestos Control
Method are greater than those from the Asbestos NESHAP Method
The statistical power of the test, also called the Type II error rate, refers to the probability
that the test will reject the null hypothesis, i e , will correctly conclude that airborne asbestos
concentrations from the Alternative Asbestos Control Method are greater than those from the
Asbestos NESHAP Method when, in fact, they are The power of the test depends on the
magnitude of the difference between the methods and on the variability to be expected in the
airborne asbestos measurements Specifically, under the alternative hypothesis HI, the two-
sample t-statistic has a noncentral t distribution with 34 df and noncentrality parameter
The probability of detecting a given difference (^2- Mi) between the methods is given by
Pr(T(34, 8) > 1 6909)
where i(34, 5) is the noncentral t-distnbution with 34 df
In order to evaluate this probability, an estimate of the standard deviation a of the natural
log of a single airborne asbestos measurement is needed. To develop this estimate, a
meteorological database of measurements of wind direction at Fort Smith was used The
database contained 5 years of wind direction data from 07 00 to 18.00 hours during the months
of March and April (the years available were 1 999, 2000 and 2002-2004) For each day, the
database contains the number of hours during the 12-hour period between 07 00 to 19:00 hours
that the wind blew from each of eighteen 20-degree sectors For example, on March 18, 2003,
the wind was in the 20-degree sector north of due east for 4 of the 12 hours, and in the 20-degree
sector to the south of due east for 8 hours
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The most important factor influencing the amount of asbestos collected at each of the 18
primary monitors to be positioned around each building during demolition is the number of hours
that each monitor is downwind from the demolition activity The meteorological data were used
to estimate the probability distribution of the number of hours a randomly-positioned monitor
would be downwind during March and April at Fort Smith. Table A-6 shows the results of the
calculation
Let D represent the airborne asbestos measurement that would be obtained by a monitor
downwind from demolition for 1 hour, and let B represent background airborne asbestos
concentration Let Y be a random variable representing the airborne asbestos measurement
reported from a randomly-placed monitor on a random day in March or April at Fort Smith
Then the mean, variance, and coefficient of variation (CV) of Y are computed as follows (using
the probabilities in Table A-6)
E(Y) = B(0 71512) + (B+D)(0.12149) + (B+2D)*(0 06557) + + (B+11D)*(0 00091)
V(Y) = E(Y2) - E(Y)2
CV(Y) = V(Y)05/E(Y)
Table A-6. Probability Distribution of Number of Hours Downwind Between
7 AM and 7 PM (March and April at Fort Smith, AR)
Hours Downwind
0
1
2
3
4
5
6
7
8
9
10
11
12
TOTAL
Frequency
3926
667
360
219
146
80
52
16
13
6
5
0
0
5490
Probability
071512
012149
0 06557
0 03989
0.02659
001457
0 00947
0 00291
0 00237
000109
0 00091
0 00000
0 00000
1.00000
Calculations show that the CV increases with the ratio D/B, reaching a limiting value of
2 07 when D/B is very large, i e, the downwind concentration is much larger than background
For a lognormal distribution, a CV of 2.07 corresponds to a value a = 1 29 for the underlying
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normal distribution Therefore, these calculations indicate that a = 1.29 is likely a conservative
value to use in the power calculations for the two-sample t-test above.
Table A-7 shows the power of the two-sample t-test to detect various differences between
the Alternative Asbestos Control Method and the Asbestos NESHAP Method with a = 1 29
The differences are expressed as the ratio of the geometric mean concentration for the
Alternative Method to the geometric mean concentration for the NESHAP Method
Table A-7 shows that a 5-fold difference between the Alternative Asbestos Control
Method and the Asbestos NESHAP Method has a 98% probability of being detected by the two-
sample t-test based on 18 samples per building in the primary ring, even with a conservative
estimate of the variability of airborne asbestos levels during the demolition To the extent that
a< 1 29, the power of the test will be increased. For example, if the downwind asbestos level D
for the NESHAP method is comparable to, or at least not many times greater than, the
background level B, the ability to detect differences between the Alternative and NESHAP
methods will be enhanced Once the data are available from the study, a variety of statistical
approaches, both parametric and non-parametric, will be utilized to determine which most
appropriately fits the data set
Table A-7. Power of Two-Sample t-Test for Airborne Asbestos Comparison
Based on Sample Sizes of 18 and 15
GM*(Alternate)/GM(NESHAP)
2
3
4
5
6
7
Detection Probability
(N=18)
047
081
094
098
0993
0997
Detection Probability
(N=15)
042
074
088
095
098
099
Geometric Mean
The statistical design is robust with respect to the accidental loss of a small number of
monitoring stations (samples) during the demolition process For example, Table A-7 compares
the power of the proposed two-sample t-test for comparison of airborne asbestos concentrations
between the NESHAP and Alternative methods for the full sample size of 18 monitoring stations
versus a smaller sample size of 15 stations Table A-7 shows only a modest decrease in
detection capability even if 3 monitors of the 18 originally specified (17%) were to be randomly
damaged or destroyed during the demolition process.
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A7.1.7 Step 7: Optimize the Design for Obtaining Results
1. EPA dispersion models SCREENS and 1SCST3 were used to estimate the location
where the maximum airborne asbestos concentrations during demolition and
debris loading would most likely occur The lateral (distance from building and
debris loading activities) and vertical (height above ground) placements predicted
by the models were evaluated using best engineering judgment to determine the
reasonableness of the predicted locations
2. The most important factor influencing the airborne asbestos concentration
measured at one of the 18 primary monitors (i e, innermost ring) to be positioned
around each building during demolition is the number of hours that monitor is
downwind from the demolition activity The project team's statistician performed
an analysis of 5 years (1999, 2000, 2002-2004) of meteorological data to estimate
the probability distribution of the number of hours that a monitor is downwind
from the demolition activity The wind direction varied between up to six 20-
degree sectors during a given day. Hence, it was concluded that the primary air
sampling design should be based on a concentric ring approach rather than on an
upwind to downwind approach
A7.1.8 Analytical Sensitivity
The data generated for this project must be obtained with an analytical sensitivity
sufficiently low to detect a difference between the two demolition methods The target analytical
sensitivity will be 0.0005 structure/cubic centimeter of air (s/cm3) for all asbestos structures
(minimum length of >0 5 um)
An analytical sensitivity of 0 0005 s/cm3 was selected for the following reasons 1) It is
believed to be sufficiently low to detect a difference between the air concentrations of asbestos
generated by the two demolitions methods 2) It is near concentrations that have been reported
as a background level of asbestos in ambient air (EPA 1986) 3) It has been used in other EPA
ambient air studies (Stewart 2003; California Environmental Protection Agency 2003;
Wilmoth et al 2004, Wilmoth et al 1990, Kominsky and Freyberg 1995 and Contaminants of
Potential Concern Committee of the World Trade Center Indoor Air Task Force Working
Group" (May 2003)
Achieving the analytical sensitivity for asbestos in air samples is generally dependent on
two factors' the volume of air collected through the filter and the area of the filter analyzed, i e ,
the number of grid sections analyzed multiplied by the area of the grid sections analyzed The
required analytical sensitivity will be achieved for each collected air sample by collecting as
large a volume of air as practical and by increasing the filter search areas, as needed
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A7.1.9 Data Quality Indicators (DQI)
A7.1.9.1 Sample CollectionDQI
• Precision is the agreement between the measurements collected by two identical
devices or measures Precision is reported as relative percent difference (RPD)
between duplicate samples or sample analyses. Precision will be measured by
collecting duplicate samples during the sampling events Duplicate "co-located"
samples will be collected during the morning and afternoon sampling events These
samples will also serve as a combined check on the sample collection and analysis
procedures
\Result 1-Result 21 x 100
Mean
Precision catena for co-located samples is presented in Table B-20 If these criteria
are not met the effect on project conclusions will be evaluated
• Completeness is defined as follows
V
%Completeness = —xlOO
N
where V is the number of measurements judged valid, and N is the number of
measurements planned. An overall measure of completeness will be given by the
percentage of samples specified in the sampling design that yield usable "valid" data
Although every effort will be made to collect and analyze all of the samples specified
in the sample design, the sample design is robust to sample loss The loss of a few
samples, provided they are not concentrated at a set of contiguous sectors, will likely
have little effect on the false-negative error rate The project goal is to collect at least
95 percent of the samples specified in the sample design If completeness objectives
are not met the effect on conclusions will be evaluated
• Representativeness is a subjective measure of the degree that the data accurately and
precisely represent the sample collection conditions of the environment
Representative sample collection depends on the expertise and knowledge of the
personnel to make sure the samples are collected in a manner that reflects the true
concentration in the environment The sampling locations (as predicted by dispersion
modeling), number of samples (18 samples per ring per height), sampling periods, and
sampling durations have been selected to ensure reasonable representativeness
Sample collection at two elevations (5 feet and 15 feet) at the inner ring, and at 5-ft at
the 2nd and 3rd rings will adequately capture the asbestos air release from demolition
and debns loading activities
• Comparability is a qualitative term that expresses the measure of confidence that one
data set can be compared to another and combined for the decision to be made Data
collection using a standard sampling and analytical method (e g, ISO 10312 1995,
counting structures longer than and shorter than 5 urn in length, and PCM equivalent
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fibers7) maximizes the comparability of the results with both past sampling results (if
such exist) and future sampling results
A7.1.9.2 Sample Analysis DQI
Analysis of identical image fields as measured by the principal analytical laboratory
(MVA) and the QC laboratory (RTI) will determine the precision data quality indicator
Precision in number of asbestos fibers and asbestos fiber dimensions from the same filters and
image fields from selected tests will be measured Filters loaded with asbestos collected by air
filtration have an inherent van ability that is exacerbated by the exceedingly small area analyzed
by TEM Although the variability cannot be mitigated by sampling strategies or sampling
preparation strategies, it can be quantified, and if factors exist that are artificially magnifying the
variability, those factors can in theory be isolated and identified The best approach to this is
through mterlaboratory re-preparation and re-analysis of filters and intra-laboratory re-
preparation and re-analysis of filters Intel-laboratory re-analysis establishes that the variability is
not caused by the laboratory's sample preparation and analytical techniques If the laboratory
was improperly preparing the samples and was causing the results to consistently bias high or
low, then the second laboratory's analysis of numerous samples should reveal this trend If the
samples had exceedingly high variability across the filter (or if the lab was causing artificial
variability through sample preparation and analysis techniques), then this would be revealed by
re-preparation and analysis of the filter by the same laboratory
Because no reference materials are available to assess the accuracy of the TEM
measurements, the best approach is to establish consensus standards through duplicate analysis
of precise sub-samples This is accomplished through a procedure called "verified counting,"
which is documented in a National Institute of Standards and Technology (NIST) technical guide
and used by asbestos analytical laboratories Two laboratories (in this case the principal
analytical laboratory and the QC laboratory) analyze precise identical areas of the sampling
filter, and compare their results, which consist of numbers of asbestos structures and drawings
and dimensions of each asbestos structure In this fashion, the)' can mutually agree on the
concentration of asbestos in the sub-sample, and can verify that each is following the very
A PCM (phase contrast microscopy) equivalent fiber is a fiber with an aspect ratio greater than or
equal to 3-1, longer than 5 urn, and which has a diameter equal to or greater than 0 25 urn
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specific guidelines for asbestos structure counting by TEM Any lack of precision or presence of
bias can be readily established and quantified
See Section B5 regarding the QA/QC catena for the analytical method data quality
indicators (DQI)
A7.2 Second Primary Objective
To determine if the post-excavation asbestos concentrations in the soil from the
Alternative Method are statistically equal to or less than the post-demolition NESHAP
Method
A7.2.1 Step 1: State the Problem
Demolition of buildings could result in contamination of the soil beneath and around the
building The extent and magnitude of any such release is not known This information is
important in comparing the Alternative Asbestos Control Method to the NESHAP Method
A7.2.2 Step 2: Identify the Decision
Is the post-excavation asbestos concentration in the soil from the Alternative Method
statistically equal to or less than the concentration from the post-demolition NESHAP Method"?
A7.2.3 Step 3: Identify Inputs to the Decision
Information that is required to resolve the decision statement
1 Accurate and representative measurements of asbestos concentrations in the post-
excavation soil from the Alternative Method and in the post-demolition soil from
the NESHAP Method building demolitions
2 An analytical sensitivity that is sufficiently low to detect a difference between the
two demolition methods as well as comparative background soil concentrations
that will be measured prior to demolition
A7.2.4 Step 4: Define the Study Boundaries
Spatial boundary of the decision statement- This decision related to the release of
asbestos to soil is defined as the area within the containment berm for the NESHAP Method
Building (#3602) and that for the Alternative Method Building (#3607)
U.S EPA Headquarters Library
Mail code 3404T
1200 Pennsylvania Avenue NW
Washington, DC 20460
202-566-0556
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A7.2.5 Step 5: Develop a Decision Rule
The decision rule is based on the comparison of the asbestos concentration in the post-
excavation soil from the Alternative Method Building to the post-demolition soil from the
NESHAP Method Building The null hypothesis is that the geometric mean asbestos
concentration in the post-excavation soil from demolition of the Alternative Method Building is
equal to or less than the geometric mean concentration in the soil from demolition of the
Asbestos NESHAP Method Building The alternative hypothesis is that the geometric mean
concentration in post-excavation soil from the Alternative Method Building is greater than the
geometric mean concentration in the post-demolition soil from the Asbestos NESHAP Method
Building All tests will be conducted at the 0 OS level of significance
A7.2.6 Step 6: Tolerable Limits on Decision Errors
The comparison of post-method asbestos soil concentrations for the NESHAP Method
and Alternative Method buildings wall be based on 10 interleaved composite samples per
containment berm of the building A detailed discussion of the statistical analysis is presented
in Section BIOS Once the data are available from the study, a variety of statistical approaches,
both parametric and non-parametnc, will be utilized to determine which most appropriately fits
the data set Since the chrysotile airborne asbestos concentrations often best fit a log-normal
distribution, we will assume that the lognormal model used for the airborne asbestos comparison
is also applicable to the soil concentrations In this case, with 10 samples per containment berm,
the two-sample t-test rejects the null hypothesis that the post-excavation asbestos concentration
in the soil from the Alternative Asbestos Control Method is equal to or less than the post-
demolition asbestos concentration in the soil from the Asbestos NESHAP Method if
T > ti8(0 95) = 1 7341
where the statistic T is computed using the natural logarithms of the measured asbestos soil
concentrations As for the airborne measurements, nondetect values will be assigned a soil
concentration one-half that corresponding to a single measured fiber A sensitivity analysis will
also be performed as described for the airborne asbestos measurements (see Section A7 1 6
"Tolerable Limits on Decision Errors") Under the alternative hypothesis that the post-
excavation asbestos concentration in the soil from the Alternative Asbestos Control Method is
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greater than the Asbestos NESHAP Method, the statistic T has a noncentral t distribution with 14
df and noncentral ity parameter
5 = 224(n2-m)/a
where e^1 (respectively, e^2) is the geometric mean asbestos soil concentration for the Alternative
Method (respectively, the NESHAP Method), and a is the standard deviation for the underlying
normal distribution We will assume that the value a = 129, used for the power calculations for
the airborne asbestos comparison, is also conservative for the soil comparison After all,
variability in the wind direction is the primary contributor to the variability in airborne levels.
This source of variability is far less relevant to the soil comparison Table A-9 shows the results
of the power calculation for a range of values of a less than or equal to 1 29, for various values
of the ratio of the geometric mean for the Alternate Method, GM(A), to the geometric mean for
the NESHAP Method, GM(N)
Table A-8. Power of Two-Sample t-Test for Soil Comparison
GM(A)/GM(N)
2
3
5
7
10
a
0.25
>0999
>0999
>0999
>0999
>0999
0.50
091
0.999
>0999
>0999
>0.999
0.75
064
093
0999
>0999
>0999
1.00
044
076
097
099
>0999
1.25
033
060
087
096
099
Thus, for moderate values of a less than or equal to 0 75, a 3-fold difference between
geometric mean soil concentrations for the Alternative and NESHAP Methods has a high
probability of detection by the two-sample t-test based on 10 samples per containment berm of
each building. Even with a conservative estimate of variability (a = 1 25), a 5-fold difference
between methods has an 87% probability of being detected
A7.2.7 Step 7: Optimize the Design for Obtaining Results
The sample design allows conclusions to be drawn about the entire area sampled within
the contamment-berm, which is consistent with the project objective. That is, the area within the
containment berm will be separated by using an equally-dimensioned 10-part gnd system The
sampling points for each of the ten components that comprise the composite sample will be
randomly selected
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A7.2.8 Analytical Sensitivity
The soil samples will be analyzed by using EPA Method 600/R-93/116 (July 1993)
"Method for the Determination of Asbestos in Bulk Building Materials This method has an
analytical sensitivity of 0 1%
A7.2.9 Data Quality Indicators (DQI)
A7.2.9.1 Sample Collection DQI
• Precision Interleaved composite sampling will minimize the van ability in sample
concentrations.
• Completeness The project goal is to collect 100 percent of the samples specified in
the sample design If completeness objectives are not met the effect on conclusions
will be evaluated
• Representativeness Composite sampling of the soil using a 10-part equally-
dimensioned grid system is intended to be representative of the soil within the
containment berm.
• Comparability Consistent sampling and analytical approaches for pre-demolition,
post-demolition, and post-excavation sampling events will ensure comparability
A7.2.9.2 Sample Analysis DQI
REI will be the principal analytical laboratory and RTI will be the QC laboratory See
Section B5 regarding the QA/QC criteria for the analytical method data quality indicators (DQI)
A7.3 Third Primary Objective
To determine if the Alternative Method is more cost-effective than the NESHAP Method
considering all costs, including disposal of all asbestos-contaminated debris and soils,
and projected costs for enforcement
A7.3.1 Step 1: State the Problem
Asbestos removal in accordance with the asbestos NESHAP can account for a significant
portion of the total demolition costs In many cities, the cost of pre-demohtion asbestos removal
prohibits the timely demolition of substandard structures that are not in danger of imminent
collapse but which, if left standing, could become structurally unsound over a period of years. If
the Alternative Asbestos Control Method proves to be less expensive than the current demolition
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requirements of the Asbestos NESHAP, the demolition of many abandoned buildings around the
nation that remain standing and currently present a variety of potentially serious risks to nearby
residents may be accelerated Although the cost of disposal is higher using the Alternative
Asbestos Control Method, the overall costs are potentially lower
A7.3.2 f Step 2: Identify the Decision
Is the Alternative Method more cost-effective than the NESHAP Method considering all
costs, including disposal of all asbestos-contaminated debris and soils, and projected costs of
enforcement?
A7.3.3 Step 3: Identify Inputs to the Decision
Information that is required to resolve the decision statement
• Accurate and reliable information on the cost of all labor, materials, and supplies
to perform the pre-demohtion removal of RACM (i e, gypsum wallboard and
glazing compound) from the NESHAP Method Building These costs include
preparation of asbestos abatement specifications by a licensed Asbestos Project
Designer, removal of the RACM by a licensed asbestos abatement contractor,
oversight of the abatement, worker exposure monitoring (asbestos and lead), and
clearance testing by a licensed asbestos consultant, transportation and disposal of
the RACM to a licensed asbestos disposal facility
• Accurate and reliable information on the cost of all labor, materials, and supplies
to perform the post-abatement demolition of the NESHAP Building These costs
include, demolition of the structure, transportation and disposal of the
construction debris, and grading for future use
• Accurate and reliable information on the cost of all labor, materials, and supplies
to demolish the Alternative Method Building. These costs include pre-
demolition wetting of the structure, demolition of the structure using asbestos-
trained workers and NESHAP-trained observers, personal protective equipment
and OSHA-mandated monitoring for asbestos and lead, transportation and
disposal of all construction debns as asbestos-containing waste at a licensed
landfill, post-demolition excavation of soil, and transportation and disposal of soil
as asbestos-containing waste at a licensed landfill.
• Accurate and reliable information on the cost of all federal, state, and local
enforcement activities relative to each method of demolition and disposal
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A7.3.4 Step 4: Define the Study Boundaries
Spatial boundary of the decision statement This decision related to all cost for labor,
materials, and supplies associated with the asbestos abatement, demolition, disposal, and
enforcement of the NESHAP Method Building (#3602), and all cost for labor, materials, and
supplies associated with the demolition, disposal, and enforcement of the Alternative Method
Building (#3607) The costs will be specific for this project at this location Costs at other
locations are expected to be site-specific.
A7.3.5 Step 5: Develop a Decision Rule
If the total cost to demolish and dispose of the construction debris and soil, as well as
projected enforcement costs from the Alternative Method Building is less than the abatement,
demolition, and disposal, and projected enforcement costs of the NESHAP Method Building,
then the Alternative Method is more cost-effective than the NESHAP Method
A7.3.6 Step 6: Tolerable Limits on Decision Errors
The total costs for both methods will be documented No limits on decision errors are
needed
A7.3.7 Step 7: Optimize the Design for Obtaining Results
The design is based on a thorough and complete documentation of all costs
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A8 SPECIAL TRAINING REQUIREMENTS/CERTIFICATION
A8.1 Field Personnel
Two separate field teams will support the project one team will be assigned to the Fort
Chaffee demolition site and the other team to the City of Fort Chaffee landfill Both teams will
be headed by an American Academy of Industrial Hygiene ABIH-Certified Industrial Hygiemst.
Each team leader has extensive experience in conducting asbestos-related field research studies
including those related to building demolitions (see Figure A-l) An ADEQ-licensed Asbestos
Abatement Consultant with training in the Asbestos NESHAP (40 CFR Part 61, Subpart M) will
be on site during demolition and debns loading activities to document the release of any visible
emissions as well as oversee the demolition process. Other field personnel will also have
experience in asbestos ambient air monitoring, occupational exposure monitoring, related
environmental measurements, and data recording The field personnel will be trained in the
requirements of the site-specific Health and Safety Plan (HASP)
A8.2 Laboratory Personnel
Primary Laboratories
Quality Control Laboratory
MVA Scientific Consultants
3300 Breckinndge Blvd , Suite 400
Duluth, GA 30096
Contact James Millette, Ph D
(770) 662-8509
Asbestos, air (TEM)
Total fibers (PCM)
DataChem Laboratories, Inc
4388 Glendale-Milford Road
Cincinnati, OH 45249
Contact Jim Baxter
(513)733-5336
Lead, demolition debns and soil
(TCLP)
Reservoirs Environmental, Inc
2059 Bryant Street
Denver, CO 80211
Contact Jeanne Spencer Orr
(330) 964-1986
Asbestos, settled dust (TEM)
Asbestos, soil (PLM and TEM) and
water (TEM)
Lead, air (ICP-AES)
Lab/Cor, Inc
7619 6th Avenue, NW
Seattle, WA 98117
Contact John Harris
(206)781-0155
Asbestos, Soil elutriation (TEM)
RTI International
3040 Cornwallis Road
Research Triangle Park, NC 26609
Contact Michael Beard
(919)541-6489
Owen Crankshavv
(919)541-7470
Asbestos, air (TEM)
Asbestos, soil (PLM and TEM)
Asbestos, setteed dust (TEM)
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A9 DOCUMENTATION AND RECORDS
A9.1 Field Operations Records
A9.1.1 Sample Documentation
The following information will be recorded on Sampling Data Forms (Figures A-8
through A-12), as applicable-
Name(s) of person(s) collecting the sample,
Date of record,
. Description of sampling site (e g, Building #3602, #3607, Fort Smith Landfill),
Description of sample including a photographic image showing the sample number;
Location of sample documented on site map with GPS coordinates, as applicable,
Type of sample (e g., area, personal, settled dust, soil, water, duplicate, field blank),
• Unique sample number that identifies the sampling site, sample type, date, and sequence
number,
Flow meter number and airflow reading (start/stop),
Sample time (start/stop) recorded in military time,
• A pre-pnnted sheet of sample labels (2 identical labels per sample number) will be prepared
One label will be attached to the sample container before sample collection period begins,
and the other matching label will be attached to the field data sheet that records relevant data
on the sample being collected
• Relevant notes descnbing site observations such as, but not limited to, site conditions,
weather conditions, demolition and debns handling equipment, water application technique
(spray or concentrated stream), equipment problems, etc The notes will be recorded in a
bound notebook
Pumps checks will be performed at least every 2 hours during sample collection These
periodic checks will include the following activities
• Observe the sampling apparatus (filter cassette, vacuum pump, etc ) to determine whether it's
been disturbed.
Check the pump to ensure that it is working properly and the flow rate is stable at the
prescribed flow rate
Inspect the filter for overloading and particle desposition
At the end of each day, all samples and the corresponding Sampling Data Forms will be
submitted to the Team Leader at the demolition site or landfill The Team Leader will verify
100% of the information recorded on the Sampling Data Form for completeness and that all
samples are in custody; any discrepancy will be resolved and corrections will be noted, initialed,
and dated on the form.
-------
ENVIRONMENTAL QUALITY
MANAGEMENT INC.
Budding No
Location.
Date
Paae: of
GPS Coordinates
mns
No.
Sample
HI, n.
Enbies hy-
Suiiiple
No.
Pump
No.
Flow
Meter
No.
Plow Rate, 1pm
Start
Stop
Avg.
Calculations by
Time
Start
:
•
•
•
•
:
:
•
•
Stop
•
:
•
:
:
:
•
:
Duration,
mln.
Mr
volume,
liters
Checked by
Figure A-8. Sampling Data Form—Air
o> n o n
1? S S §
!!H
to
o
o
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ENVIRONMENTAL QUALITY
MANAGEMENT, TNC.
Building No.:
Dale:
Page-
Entries by:
of
Sample Number
Sample Type
SoU
Sampling Locations
Sample Time
Held Comments
Figure A-9. Sampling Data Form - Soil
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\ ENVIRONMENTAL QUALITY
MANAGEMENT, INC.
Building No .
Date.
Page
of
Entries by:
Sample Number
Sample Type
Water
Sample Locations
Sample Tune
Field Comments
Figure A- 10. Sampling Data Form - Water
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/
;«
pT \ ENVIRONMENTAL QUALITY
Cjg| | MANAGEMENT, INC.
^v. y. '
Sample Number
Ring No.
Sample,
Ht., ft.
GPS Coordinates
(Location on site map)
3uilding"No,;
Date:
Page
Entries by
of
Sample Time
Start
Stop
Field Comments
"o 5d 2! w
o> n o 2
OQ ^ 13 ^*
0 i n -
S§3§
ON
Figure A-ll. Sampling Data Form - Settled Dust
to
o
o
Lft
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ENVIRONMENTAL QUALITY
MANAGEMENT, INC.
Building No
Landfill
Date
Page
of
Weather Station
Measurement Log
Time
Wind Speed,
MPH
Wind
Direction
Barometric
Pressure, In. Hg
Temperature,
°F
Relative
Humidity, %
Figure A-12. Meteorological Measurement Log
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A9.1.2 Meteorological Measurements
Met One Instruments, Inc , meteorological stations will record temperature, barometric
pressure, relative humidity, wind speed, and wind direction at 5-mmute averages The data files
will be downloaded by using an on-site personal computer These same metrics will also be
noted from the instrument's visual display and recorded on a Meteorologic Data Measurement
Log (Figure A-l 2) at least hourly
A9.1.3 Photo Documentation
A digitized image will be taken of every sampling location This will include the
sampling station and visual debris on or in the soil A S-inch by 7-mch index card (or
equivalent) listing the sample number will be photographed to identify the sample and location
Other digitized images will be taken as necessary to thoroughly document the site conditions
(such as "visible emissions," if such occur) and activities In addition, a camcorder will be used
to videotape the demolition and demolition debns landfillmg operations
A9.2 Chain-of-Custody Records
Standard EQ sample traceabihty procedures described m Section B3 will be used to
ensure sample traceabihty
A9.3 Laboratory Records
Complete data packages will be submitted for all sample analyses (i e, asbestos and total
fibers) for all matrices (air, soil, settled dust, and water). This information will be submitted in
sufficient detail to allow the subsequent verification of the reported analyses Alternative forms
routinely used by the laboratones may be substituted for those forms specified in the referenced
methods The laboratory data package will meet the guidelines in Laboratory Documentation
Requirements for Data Evaluation (R9/Q A/004 1), EPA, March 2001
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A9.3.1 TEM Reporting (Air)
Specifically for TEM analysis the following is required
• Structure counting data shall be recorded on forms equivalent to the example
shown in ISO 10312 1995
• The test report shall contain items (a) to (p) as specified in Section 11, "Test
Report," of ISO 10312 1995 In addition, the files containing the raw data (in
Microsoft Excel format) shall be submitted The format of these files shall be as
directed by the project manager, but shall contain the following items
1. Laboratory Sample Number
2 Proj ect S ampl e N umber
3 Date of Analysis
4 Air Volume
5 Active Area of Sample Filter
6 Analytical Magnification
7. Mean Grid Opening Dimension in mm2
8 Number of Grid Openings Examined
9 Number of Primary Structures Detected
10 One line of data for each structure, containing the following information
as indicated in Figure 7 "Example of Format for Reporting Structure
Counting Data" of ISO 10312.1995, with the exception that the lengths
and widths are to be reported in millimeters as observed on the screen at
the counting magnification
• Grid Opening Number
• Grid Identification
• Grid Opening Identification/Address
• Structure or Sub-structure Number
• Asbestos Type (Chrysotile or Amphibole)
• Morphological Type of Structure (fiber, bundle, matrix, cluster)
• Length of Structure in 1 -mm increments (e g , 32)
• Width of Structure in 0 1-mm increments (e g , 3 2)
• Any Other Comments Concerning Structure (e.g, partly obscured
by grid bar)
A9.3.2 TEM Reporting (Soil)
In addition to the applicable requirements noted in Section A9 3 1 the primary soil
analysis laboratory will provide data (electronic and hard copy) as specified in EPA Method
600/R-93/116 (July 1993) "Method for the Determination of Asbestos m Bulk Building
Materials "
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B MEASUREMENT/DATA ACQUISITION
Bl BUILDING DEMOLITION
Bl.l Air Dispersion Modeling
This section presents the modeling approach used to assist in the placement of ambient
air monitors that will be used to measure the concentration of airborne asbestos fibers during the
demolition of the NESHAP (#3602) and Alternative Method (#3607) Buildings and associated
demolition activities Results of the modeling were used as a predictive tool to evaluate possible
monitoring locations, both laterally (x, y) as well as vertically (z), around these buildings
Bl.1.1 Source Identification
The sources identified for purposes of this modeling consist primarily of two major
operations taking place during the demolition activities 1) the actual demolition of the building
itself and 2) the loading of the truck bed with demolition debris These two operations will be
occurring simultaneously and have the potential to release dust and other airborne parnculate
matter to the atmosphere Therefore, both were included in the modeling analysis to account for
their potential contributions The following describes in further detail the characterization of
these sources
Bl.l.1.1 Source No.l: NESHAP/Alternative Method Building Demolition
Figure B-l is a photograph of the type of building to be demolished as part of the
NESHAP and Alternative Methods The building is approximately 30 feet wide, 150 feet long,
and 15 feet high.
A demolition grappler will be used to remove finite sections of the building and then
transfer the debris to a large open-bed truck The demolition process will start at one end of the
building and work its way down along the length of the building. The source defined in this case
is associated with the extraction of sections of the building being demolished by the grappler
prior to loading the debns onto the truck
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: 15. feet.
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Figure B-l. Configuration of the Type of Building to be Demolished
Bl. 1.1.2 Source No. 2: Transfer of Building Demolition Debris Into Truck Bed
Figure B-2 is a photograph of a grappler loading extracted material from a demolition site
into a truck bed. As shown in the figure, the grappler has extracted a section of a building and is
unloading the debris into the back of a truck. The source defined in this case is associated with
the potential emissions resulting from the transfer of the extracted material into the bed of the
truck.
Bl.1.1.3 Model Selection
Two U.S. EPA-approved models, SCREENS and the Industrial Source Complex Model,
Version 3, in its short-term mode (ISCST3), were considered for use in this analysis. Both
models are based on a steady-state Gaussian plume algorithm, and are applicable for estimating
ambient impacts from point, area, and volume sources out to a distance of about 50 kilometers.
B1.1.1.4 Source Characterization
Due to the nature and extent of the building demolition process, both of these sources are
most appropriately modeled as volume sources. A volume source is used to model emissions
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Figure B-2. Transfer of Building Debris to Truck Bed
that initially disperse three-dimensionally with no plume rise. These sources can either be
surface based, structure based (elevated sources on or adjacent to a structure), or elevated
(elevated sources not on or adjacent to a structure). Typical volume sources include side or roof
building vents, conveyor transfer points, emissions from a crusher or screen, and emissions from
loading and unloading trucks.
The inputs for modeling a volume source include the following:
Emissions rate (g/s)
. Initial lateral dimension of the volume source (070)
Initial vertical dimension, initial depth of the volume source (ozo)
. Release height (m).
Table B-l summarizes these inputs for the building demolition and truck loading
activities:
Bl. 1.1.5 SCREEN3 Model
SCREENS is the U.S. EPA's current regulatory screening model for many New Source
Review (NSR) and other air permitting applications. The SCREENS model utilizes a predefined
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Table B-l. Summary of Selected Volume
Source Modeling Parameters
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Parameter
Emission Rate (g/s)
Init Lateral Dim (oyo)
Init Vertical Dim (ozo)
Release Height (m)
Source
Bldg. Demolition1
Ig/s
0.70 ft
698ft
75ft
~
Truck Loading2
Ig/s
070ft
14ft
~
7,12, 15ft
Basis/Comment
Unit Emission Rate
Defined based on model
guidance for ISCSTS3
Avg Height of Bldg.
(15 ft/2 = 7 5 ft)
Based on multiple drop
distances to truck bed
1 Parameters based on size of grappler (assuming 3 ft x 3 ft) and a building height of IS ft.
2 Parameters based on size of grappler (assuming 3 ft x 3 ft), height of side wall of truck bed, and a
release height evaluated at 7 ft, 12 ft, and IS ft
3 U S EPA, User's Guide for the Industrial Source Complex (ISC3) Dispersion Models Volume 2 -
Description of Model Algorithms, September 1995 (EPA-454/B-95-003b), Table 6-1 "Summary of
Suggested Procedures for Estimating Initial Lateral Dimensions and Initial Vertical Dimensions for
Volume and Line Sources" Refer to the following assumptions described below
Initial Lateral Dimension for both sources
Based on size of grappler (assuming 3 ft x 3 ft), where for single volume source, is equivalent to
length of side divided by 4 3 Thus oy0 = 3 ft / 4 3 = 0 70 ft for both source types
Initial Vertical Dimension for both sources
Building Demolition For an elevated source on or adjacent to a building, the initial vertical
dimension is equivalent to the building height divided by 2 15 Thus ozo= 15ft/2 15 = 6 98 ft
Truck Loading. For an elevated source not on or adjacent to a building, the initial vertical
dimension is equivalent to the vertical dimension of the source divided by 4 3 Thus ozo = 3 ft /
4.3 = 0 70 ft (Assuming the vertical dimension of the grappler is 3 ft)
matrix of meteorological conditions that cover a range of wind speeds and stability categories (A
through F), where the maximum wind speed is stability-dependent The model is designed to
estimate the worst-case impact based on a defined meteorological matrix for use as a
"conservative" screening technique
In order to determine the relative extent of impact due to these operations, the SCREENS
model was used to assess the impacts from the building demolition and truck loading sources
defined previously In lieu of actual emissions data, a unit emission rate of 1 g/s was assigned to
each of the two sources Impacts from these sources were modeled from the source ongm out to
a distance of 1,000 feet Receptors were spaced every 5 feet out to 100 feet, then every 100 feet
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thereafter until reaching a distance of 1000 feet. In addition to the ground level impacts.
SCREENS has the capability to model elevated (free standing) receptors, called flagpole
receptors. Therefore, to assess the potential impacts from these sources at elevations above
ground level, flagpole receptors were modeled at heights of 5,10, and 15 feet.
Results of the SCREENS modeling associated with the building demolition activities for
each of the flagpole heights are shown in Figures B-3 and B-4. Figure B-3 shows the resulting
change in concentration as a function of distance from this source out to a distance of 1000 feet.
As shown in Figure B-3, peak concentrations occur within the first 50 feet of the source and
rapidly taper off as distance from the source increases. Figure B-4 presents the same profile
from the source out to 100 feet. Figure B-4 shows that the peak concentration from the building
demolition source is predicted to occur within 10 feet of the source.
Ft Smith, Arkansas -SCREENS Results - Building Demolition
(Based on Volume Source Where: RH = 7.5', Sigma-y = 0.70', Sigma-z = 6.98')
Receptor Height = 0 feet
Receptor Height = 5 feet
Receptor Height = 10 feet
•»••• Receptor Height =15 feet
.2
E
o
o
2000
300.0
4000
5000
6000
7000
800.0
9000
10000
Distance from Building, feet
Figure B-3. SCREENS Results for Building Demolition Source (0 to 1,000 feet)
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Ft. Smith, Arkansas - SCREEN3 Results - Building Demolition
(Based on Volume Source Where: RH = 7.5', Sigma-y = 0.70', Sigma-z = 6.98')
Receptor Height = Ofeet
*~- Receptor Height = 5 feet
*- Receptor Height = 10 feet
*•••• Receptor Height = 15 feet
--'
100
20.0
30.0
40.0 50.0 60.0
Distance from Building, feet
70.0
80.0
90.0
100.0
Figure B-4. SCREEN3 Results for Building Demolition Source (0 to 100 feet)
A similar procedure was used to assess the SCREENS results for the truck loading
source. Figures B-5, B-6, and B-7 displays the predicted concentration profiles as a function of
distance for source release heights of 7, 12, and 15 feet. Multiple source release heights were
evaluated because as the bed of the truck becomes full, the distance that the material will drop
can change. The data from these figures also shows that the maximum/peak concentrations,
regardless of release height, occur within 15 feet of the source origin.
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Ft. Smith, Arkansas - SCREEN3 Model Results - Truck Loading Operation
(Based on Volume Source Where: RH = 7', Sigma-y = 0.70', Sigma-z = 0.70')
Receptor Height = 0 feet
••«•••• Receptor Height = 5 feet
-*- Receptor Height = 10 feet
••*•••• Receptor Height = 15 feet
00
100
20.0
30.0 40.0 50.0 600
Distance from Truck, feet
700
80 0 90 0
1000
Figure B-5. SCREEN3 Results for Truck Loading Source (Release Ht =7 ft)
Ft. Smith, Arkansas • SCREEN3 Model Results - Truck Loading Operation
(Based on Volume Source Where: RH = 12', Sigma-y = 0.70', Sigma-z = 0.70')
Receptor Height = 0 feet
•-*••• • Receptor Height = 5 feet
-4—Receptor Height = 10 feet
••«•••• Receptor Height = 15 feet
•:-:-:->^..
00
100
20.0 300 400 500 60.0
Distance from Truck, feet
700
800
900 1000
Figure B-6: SCREENS Results for Truck Loading Source (Release Ht =12 ft)
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Ft. Smith, Arkansas - SCREENS Model Results - Truck Loading Operation
(Based on Volume Source Where: RH = 15', Sigma-y = 0.70', Sigma-z = 0.70')
Receptor Height = 0 feet
••«••• Receptor Height = 5 feet
-*—Receptor Height = 10 feet
•••»••• Receptor Height =15 feet
100 20.0 30.0 40.0 50.0 6D.O
Distance from Truck, feet
70.0
80.0
90.0
100.0
Figure B-7. SCREEN3 Results for Truck Loading Source (Release Ht =15 ft)
Bl.1.1.6 ISCST3 Model
The ISCST3 model is a more refined model (as compared to SCREENS) and utilizes
actual hourly meteorological data that have been preprocessed using U.S. EPA's PCRAMMET
program for compiling National Weather Service (NWS) meteorological data. Preprocessed
meteorological data from the Ft. Smith area consisting of representative surface meteorological
observations for Ft. Smith Municipal Airport (NWS No. 13964) and upper air twice-daily mixing
height data from North Little Rock, AK (NWS No. 13963) for use in the ISCST3 model were
obtained for the period 1999 through 2004. Figure B-8 shows a wind rose depicting the wind
patterns for this area.
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Section B
November 23, 2005
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Page 9 of 64
Station «13»6< . FORT SMITHIMUNICIPAL ARPT. A*
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Figure B-8. Wind Rose for the Period 1999-2000 and 2002-2004
The wind rose depicted in Figure B-8 for the period 1999-2000 and 2002-2004 shows a
fairly even distribution of winds throughout the 18 wind sectors evaluated with some dominant
winds blowing from the east. This data depicts the March-April months for all years evaluated
and is representative of the daily time frame of 0700 hours through 1800 hours, the period during
which all demolition and truck-loading activities will take place.
Based on this data, the 1SCST3 Model was run for years 1999-2000 and 2002-2004 for
the sources operating from 0700 to 1800 hours during the months of March and April. An
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November 23, 2005
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example of the results from the ISCST3 modeling for the building demolition source are depicted
in Figure B-9 for the most recent meteorological year - 2004 at a receptor height of 5 meters.
This isopleth shows that for year 2004, maximum concentrations due to building demolition
activities still occur close to the source (consistent with the SCREENS results) and that within
100 meters, the modeled concentration drops to approximately 2-5% of the maximum modeled
concentration near the source origin. This was consistent for all years modeled and for both
sources evaluated (the building demolition and the truck loading).
3906300-
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381900
382000
332100
332200
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Figure B-9. Results of ISCST3 Model Run for Year 2004 Represented as Percent of Total
Maximum Concentration for Building Source
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November 23, 2005
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B1.2 Monitoring During Demolition
Bl.2.1 Perimeter Air Monitoring During Demolition
Modeling conducted using the EPA dispersion models SCREENS and ISCST3 indicates
that the maximum airborne asbestos concentrations during demolition and loading of debris will
most likely occur approximately 15 feet from the building and dunng loading activities at a
height of five feet above the ground Therefore, the comparison of airborne asbestos
concentrations from the NESHAP and Alternative Control Methods will be based on
measurements from monitors placed five feet above ground in a ring (the "primary ring")
approximately 15 feet from the face of each building or as close as possible to the demolition or
debris loading areas Note On the north side of the building the monitors in the primary ring
will be positioned approximately 25 feet from the face of the building to accommodate the space
needed for disposal truck or equivalently approximately 10 feet from north face of truck The
monitors will be placed at even intervals around each building An additional set of monitors
will be positioned at a height of 15 feet in the primary ring directly above the 5-foot-high
monitors If the asbestos concentrations measured at the 15-foot-high monitors are larger than
those observed at the 5-foot height for both the NESHAP and the Alternative Control Method
Buildings, then the 15-foot-high values will be used for the primary assessment, see Section
BIO 3 1 regarding the proposed approach for statistical analysis of the data Note The
perimeter air monitors will be placed immediately outside of the containment berm
Monitors will also be located to collect additional asbestos data necessary for potential
future air dispersion modeling efforts Monitors will be placed 5 feet above ground at even
intervals in each of two additional rings one approximately 50 feet from the building and the
other approximately 100 feet from the building
The perimeter air monitoring network consisting of the three concentric rings is shown
for the NESHAP and Alternative Control Buildings in Figures B-10 and B-l 1, respectively The
estimated number of air samples to be collected and analyzed for asbestos is summarized in
Table B-2 To avoid overloading of the filters with paniculate, air sampling will be conducted
for two sequential periods during each workday It is assumed that the demolition, construction
debns loading, and site grading will occur over one day. All samples will have a target air
volume of 1,920 to 2,400 liters
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Table B-2. Perimeter Air Monitoring Samples for Asbestos Analysis"
During Demolition and Debris Loading
Ring
Rl@
5-ft
Rl@
15-fl
R2@
5-ft
R3@
5-ft
Sam pie Type
Sequential 4-5 hr period
Duplicates
Open field blank
Closed field blank"
Total Samples
Sequential 4-5 hr penod
Duplicates
Open field blank
Closed field blank
Total Samples
Sequential 4-5 hr period
Duplicate
Open field blank
Closed field blank
Total Samples
Sequential 4-5 hr period
Duplicate
Open field blank
Closed field blank
Total Samples
Number of Samples
NESHAP Method
Period 1
18
2
1
1
22
18
2
0
0
20
18
1
1
1
21
18
1
1
1
21
Period 2
18
2
1
1
22
18
2
0
0
20
18
1
1
1
21
18
1
1
1
21
Alternative Method
Period 1
18
2
1
1
22
18
2
0
0
20
18
1
1
1
21
18
1
1
1
21
Period 2
18
2
1
1
22
18
2
0
0
20
18
1
1
1
21
18
1
1
1
21
TOTAL SAMPLES
Total Samples
72
8
4
4
88
72
8
0
0
80
72
4
4
4
84
72
4
4
4
84
336
"Samples will be analyzed both for asbestos (ISO 10312 1995) and total fibers (N1OSH 7400, A Rules)
b Closed field blanks will only be analyzed if asbestos contamination is detected on the open field blanks
-------
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Figure B-ll. Locations of Air Monitors around the Alternative Method Building
to
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-------
Bl.2.2 Worker Exposure Monitoring During Building Demolition
Section B
October 23, 2005
Revision 0
Page 15 of 64
Personal breathing zone samples will be collected from all workers directly involved with
the demolition of the building and the handling of the resultant construction debns Personal
samples for asbestos will be collected during the two sampling penods (morning and afternoon)
to calculate the time-weighted average concentration for comparison to the OSHA Permissible
Exposure Limit for Asbestos (29 CFR §1926 1101) Each worker will be fitted with two
personal sampling pumps The first pump will be used to collect two consecutive samples that
represent the entire demolition activity, the second pump will be used to collect a single sample
that represents the demolition activity The samplers will run the entire time the individual is
performing the specific assigned task For example, the samplers for the truck drivers will
operate from the time they come on site until they leave the site (or the landfill) for the day The
sampling will remain operating during transit between the demolition site and the landfill
Personal samples for Lead (29 CFR §1926 62) will be collected over the entire demolition and
debris handling period The estimated number of air samples to be collected and analyzed for
asbestos, total fibers, and lead is presented in Table B-3
Table B-3. Worker Exposure Monitoring Samples for Asbestos
and Lead During Building Demolition and Debris Loading
Worker
Number of Samples
NESBAP Method
Alternative Method
Total
Samples
Asbestos"
Excavator Operator
Hose Operators (2)
Truck Operators (3)
Open Field Blank
Closed Field Blank"
Total Samples
Period Period
1 2
1 1
2 2
3 3
1
Periods
1 + 2
1
2
3
1
14
Excavator Operator
Hose Operators (2)
Truck Operators (3)
Open Field Blank
Total Samples
6
Period
1
1
2
3
Period
2
1
2
3
1
Periods
1 + 2
1
2
3
1
14
Lead
Periods 1+2
1
2
3
1
7
6
6
12
18
2
2
40
Periods 1 + 2
1
2
3
1
7
2
4
6
2
14
' Samples \vill be analyzed both for asbestos (ISO 10312 1995) and total fibers (NIOSH 7400, A Rules)
b Closed field blanks will only be analyzed if asbestos contamination is detected on the open field blanks
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October 23, 2005
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B 1.2.2.1 Worker Activity Exposure Monitoring
Personal breathing zone monitoring for asbestos will be conducted on workers during
operation of the perimeter air monitors in Ring 1 The sampling will be conducted dunng the
entire demolition activity The estimated number of air samples to be collected and analyzed for
asbestos and total fibers is presented in Table B-4
Table B-4. Worker Activity Exposure Monitoring Samples for
Asbestos During Building Demolition
Worker
Number of Samples
NESHAP Method
Alternative Method
Total
Samples
Asbestos"
Walkers (3)
Open Field Blank
Closed Field Blank6
Total Samples
Period
1
3
Period
2
3
Periods
1+2
3
1
1
8
3
Period
1
3
Period
2
3
Periods
1 +2
3
1
1
8
3
18
2
2
22
' Samples will be analyzed both for asbestos (ISO 10312 1995) and total fibers (NIOSH 7400,
A Counting Rules)
b Closed field blanks will only be analyzed if asbestos contamination is detected on the open field blanks
Bl.2.3 Soil Sampling
Soil samples will be collected prior to demolition of each building Following
demolition, all demolition debris will be removed from each building site and soil samples will
then be collected In the case of the Alternative Method Building, the top 2-3 inches of soil will
then be excavated and removed from the site and an additional set of soil samples will be
collected The comparison of asbestos soil concentrations between the two methods will be
based upon the post-demolition values for the NESHAP Method vs. the post-excavation values
for the Alternative Method
For each of the soil sampling events described above, the containment-berm area will be
evenly divided into a 10-block grid system. Ten interleaved composite samples will be collected
from the bermed area Each sample will be a composite of 30 grab samples, three from a random
location in each of the 10 blocks of the gnd The sampling gnd for the NESHAP Method
Building and Alternative Control Method Building is shown in Figure B-12 The estimated
number of soil samples to be collected and analyzed for asbestos is presented in Table B-5
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October 23, 2005
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Table B-5. Soil Samples for Asbestos Analysis
Phase
Pre-Demohtion
Post-Demolition
Post-Excavation
Type of
Sample
Soil
Total Samples
Soil
Total Samples
Soil
Total Samples
Number of Samples
NESHAP
Method
10
10
10
10
0
0
Alternative
Method
10
10
10
10
10
10
TOTAL SAMPLES
Total
Samples
20
20
20
20
10
10
SO
B 1.2.4 Asbestos from Soil Elutriation Method
Thirty percent of the soil samples collected in Section Bl 2 3 will be submitted for
analysis using an elutnation method This will provide a measure of the asbestos concentration
in respirable dust in the soils The number of soil samples that will be analyzed is presented in
Table B-6
Table B-6. Soil Elutriation Samples for Asbestos Analysis
Phase
Pre-Demohtion
Post-Demolition
Post-Excavation
Type of
Sample
Soil
Soil
Soil
Number of Samples
NESHAP
Method
3
3
0
Alternative
Method
3
3
3
TOTAL SAMPLES
Total
Samples
6
6
3
15
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B 1.2.5 Settled Dust From Demolition
If any asbestos-containing dust is released during the demolition of the buildings and
associated debris-loading activities, it could settle on nearby surfaces. Settled dust collectors
will be placed at the same locations as the pen meter samples in Rings 1, 2, and 3 The dust
collectors will be placed five feet above ground at 40-degree intervals in each of the three
concentric rings The estimated number of settled dust samples for asbestos analysis is presented
Table B-7
B 1.2.6 Surface Water From Demolition
As described in Section A6 1 2, containment berms will be used to trap water runoff
during demolition and debns loading of the NESHAP Method and Alternative Control
Buildings Representative samples of surface water will be collected during the duration of the
demolition activity for both the NESHAP and Alternative Method Buildings Drainage channels
will be constructed to direct water runoff for collection in metal-fabricated basins located within
the containment berm These channels will be small in size, constructed of impervious material,
and are only intended to assure some collection of runoff, not to divert flow This is intended to
have minimal impact on soil permeation The sampling of the collected runoff water will be
spaced over the duration of the demolition activity Sample collection volumes will be noted as a
function of time and as a function of the progression of the demolition The estimated number of
surface water samples that will be collected for asbestos analysis is presented in Table B-8
Bl.2.7 Source Water for Wetting Structure and Demolition Debris
The asbestos concentration of the source water applied to control the paniculate
emissions during demolition and debns loading of the NESHAP Method and Alternative Method
Buildings will be measured A source sample will be collected at both the commencement and
completion of the demolition activities A sample of amended water will be collected in the
morning and in the afternoon The estimated number of source water samples for asbestos
analysis is presented in Table B-9 Note The applicable field blank for these samples is
included in Table B-8
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November 23, 2005
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Table B-7. Settled Dust Samples at Perimeter Rings for Asbestos Analysis
During Demolition and Debris Loading
Ring
R1@5-ft
R2@ 5-ft
R3@ 5-ft
Sample
Type
Settled Dust
Duplicate
Field Blank
Total Samples
Settled Dust
Duplicate
Field Blank
Total Samples
Settled Dust
Duplicate
Field Blank
Total Samples
Number of Samples
NESHAP Method
9
1
1
11
9
1
1
11
9
1
1
11
Alternative Method
9
1
1
11
9
1
1
11
9
1
1
11
TOTAL SAMPLES
Total
Samples
18
2
2
22
IS
2
2
22
18
2
2
22
66
Table B-8. Surface Water Samples for Asbestos Analysis
During Demolition and Debris Loading
Sample Type
Water
Duplicate
Field Blank
Total Samples
Number of Samples
NESHAP
Method
4
1
1
6
Alternative
Method
4
1
1
6
Total Samples
8
2
2
12
Table B-9. Source Water Samples for Asbestos Analysis
Sample Type
Water
(Before Demolition)
Water
(After Demolition)
Amended Water
Total Samples
Number of Samples
NESHAP
Method
1
1
0
2
Alternative
Method
1
1
2
4
Total Samples
2
2
2
6
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November 23, 2005
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B1.3 Monitioring During Landfilling of Demolition Debris
Bl.3.1 Perimeter Air Monitoring During Landfilling of Demolition Debris
Stationary air monitors will be positioned to measure the concentration of airborne
asbestos fibers during landfilling of the demolition debns from the NESHAP Method and
Alternative Method Buildings The perimeter air monitoring network will consist of one ring of
monitors The goal will be to place the monitors at 40-degree intervals measured along a radius
from the center of the asbestos landfilling activity as site conditions permit, i e , topography and
other landfilling activities The monitors will be placed at a height of 5 feet above ground and
approximately 15 feet from the activity, or as close to that as possible.
The estimated number of air samples to be collected and analyzed for asbestos is
summarized in Table B-10 Air sampling will be conducted for two sequential periods per
workday as described for the perimeter air samples at the demolition site, see Section Bl 2 1 It
is assumed that the landfilling of the demolition debris for each building will occur over one day.
All samples will have a target air volume of 1,920 to 2,400 liters
Table B-10. Perimeter Air Monitoring Samples for Asbestos Analysis3
During Landfilling of Demolition Debris
Ring
Rl@5-
ft
Sample Type
Sequential 4-5 hr period
Duplicates
Open field blank
Closed field blank"
Total Samples
Number of Samples
NESHAP Method
Period 1
9
1
Period 2
9
1
1
1
12
10
Alternative
Method
Period 1
9
1
Period 2
9
1
I
1
12
10
Total
Samples
36
4
2
2
44
' Samples will be analyzed both for asbestos (ISO 10312 1995) and total fibers (NIOSH 7400, A Counting Rules)
b Closed field blanks will only be analyzed if asbestos contamination is detected on the open field blanks
B 1.3.2 Air Monitoring of Workers during Landfilling
Personal breathing zone samples will be collected from the bulldozer operator involved
with the landfilling of the demolition debris Personal samples for asbestos and total fibers will
be collected dunng the two sampling periods (morning and afternoon) to calculate the time-
weighted average concentration for comparison to the OSHA Permissible Exposure Limit for
Asbestos (29 CFR §1926 1101) The worker will be fitted with two personal sampling pumps
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The first pump will be used to collect two consecutive samples that represent the entire
demolition activity, the second pump will be used to collect a single sample that represents the
demolition activity. In addition, a fixed-station area sample will be positioned in the cab of the
same bulldozer for asbestos and total fibers analysis Personal samples for Lead (29 CFR
§1926 62) will be collected over the entire day of the landfilling activity The estimated number
of air samples to be collected and analyzed for asbestos and total fibers, and lead is presented in
Table B-ll
Table B-ll. Worker Exposure Monitoring Samples for Asbestos
and Lead During Landfilling of Building Demolition Debris
Worker
Number of Samples
NESHAP Building
Alternative Method Building
Asbestos"
Bulldozer Operator
Cab of Bulldozer
Open Field Blank
Closed Field Blank"
Total Samples
Period Period Periods
1 2 1 + 2
1 1 1
1 1 1
1
1
8
Period
1
1
1
Period
2
1
1
Total
Samples
Periods
1 + 2
1
1
1
1
8
Lead
Bulldozer Operator
Cab of Bulldozer
Open Field Blank
Total Samples
Periods 1+2
1
1
1
3
Periods
6
6
2
2
16
1+2
1
1
1
3
2
2
2
6
" Samples will be analyzed both for asbestos (ISO 10312 1995) and total fibers (NIOSH 7400, A Counting Rules)
b Closed field blanks will only be analyzed if asbestos contamination is detected on the open field blanks
B1.4 Background Air Monitoring
B 1.4.1 Background Air Monitoring at Demolition Site
Air monitonng will be conducted prior to asbestos abatement of the NESHAP Building
and prior to demolition of the Alternative Method Building to collect data necessary for potential
comparison of air concentrations of asbestos and total fibers during demolition. The monitonng
will be conducted prior to the asbestos abatement of the NESHAP Method Building and prior to
demolition of the Alternative Method Building Monitonng will be conducted approximately
between 08.00 to 12 00 hours and 12 00 to 16-00 hours The target air volume for a 4 hour
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Section B
November 23, 2005
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sample at a flow rate of 8 1pm is 1,920 liters. If the wind speed exceeds 15 mph (average) or 20
mph (gusts), sampling will cease until satisfactory conditions resume
The air monitoring network will consist of one ring of monitors around the building The
monitors will be placed at 60-degree intervals measured along a radius from the center of the
building The monitors will be placed within 15 feet of the building and at a height of 5 feet
above ground. The estimated number of air samples to be collected and analyzed for asbestos is
presented in Table B-12
Table B-12. Background Air Monitoring Samples for Asbestos Analysis8
Around the NESHAP Method and Alternative Control Buildings
Phase
(08:00-12 00)
(12 00-16 00)
Type of Sample
Air
Duplicate
Open Blank
Closed Blank"
Total Samples
Air
Duplicate
Total Samples
Number of Samples
NESHAP Method
(Prior to Asbestos Removal)
6
1
1
1
9
6
1
7
Alternative Method
(Prior to Demolition)
6
1
1
1
9
6
1
7
Total Samples
Total
Samples
12
2
2
2
18
12
2
14
32
a Samples will be analyzed both for asbestos (ISO 10312 1995) and total fibers (NIOSH 7400, A Counting Rules)
b Closed field blanks will only be analyzed if asbestos contamination is detected on the open field blanks
B 1.4.2 Background Air Monitoring at Landfill
Air monitoring will be conducted prior to disposal of any materials from the NESHAP
Method and Alternative Method Buildings to collect data necessary for potential comparison of
air concentrations of asbestos and total fibers during disposal The monitoring will be conducted
prior to disposal of the respective waste streams Monitoring will be conducted between 08 00 to
12 00 hours and between 12 00 to 16 00 hours
The air monitoring network will consist of one ring of monitors The monitors will be
placed at 60-degree intervals measured along a radius from the center of the debns landfilling
area. The monitors will be placed as close to the area as feasible (the goal is 15 feet from the
activity) and at a height of 5 feet above ground The estimated number of air samples to be
collected and analyzed for asbestos is presented in Table B-13
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Section B
November 23, 2005
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Table B-13. Background Air Monitoring Samples for Asbestos Analysis3
At the Landfill Prior to Disposal of Materials from the
NESHAP Method and Alternative Method Buildings
Phase
(08 00-12 00)
(1200-1600)
Type of Sample
Air
Duplicate
Open Blank
Closed Blank"
Total Samples
Air
Duplicate
Total Samples
Number of Samples
NESHAP Method
Abatement
6
1
1
1
9
6
1
7
Demolition
6
1
1
1
9
6
1
7
Alternative Method
6
1
1
1
9
6
1
7
Total Samples
Total
Samples
18
3
3
3
27
18
3
21
48
1 Samples will be analyzed both for asbestos (ISO 10312 1995) and total fibers (NIOSH 7400, A Counting Rules)
b Closed field blanks will only be analyzed if asbestos contamination is detected on the open field blanks
B1.5 Air Monitoring During Asbestos Abatement of NESHAP Method Building
Bl.5.1 Discharge Air from HEPA-Filtration Units
In-duct monitoring of the discharge air from each HEPA-filtration unit used during the
abatement of the NESHAP Method Building will be conducted It is assumed that four air
filtration units will be used The estimated number of air samples to be collected and analyzed
for asbestos and total fibers is presented m Table B-14
Table B-14. Air Monitoring Samples for Asbestos(a) Analysis
of Discharge Air From HEPA-Filtration Units
Sample Type
Air
Duplicate
Open Field Blank
Closed Field Blank"
Total Samples
Number of Samples
4
1
1
1
7
0 Samples will be analyzed both for asbestos (ISO 10312 1995)
and total fibers (NIOSH 7400, A Counting Rules)
b Closed field blanks will only be analyzed if asbestos contamination
is detected on the open field blanks
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B 1.5.2 Air Monitoring During Loading of Bagged ACM
The air around the disposal container (e g, truck or roll-off container) will be monitored
to determine whether this activity releases airborne asbestos fibers that are above comparative
background The monitors will be placed at 60-degree intervals measured along a radius from
the center of the disposal container The monitors will be placed within 10 feet of the disposal
container and at heights of 5 feet and 15 feet above ground The estimated number of air
samples to be collected and analyzed for asbestos and total fibers is presented m Table B-15
Table B-15. Air Monitoring Samples for Asbestos Analysis3
During Loading of Bagged ACM from NESHAP Method Building
Sample Height
5 -feet
15-feet
Sample Type
Air
Duplicate
Open Field Blank
Closed Field Blank"
Total Samples
Number of Samples
6
6
1
1
1
15
' Samples will be analyzed both for asbestos (ISO 10312 1995) and total fibers
(NIOSH 7400, A Counting Rules)
b Closed field blanks will only be analyzed if asbestos contamination is detected on the
open field blanks
Bl .5.3 Air Monitoring During Landfilling of NESHAP Method Bagged ACM
The air during landfilling of the bagged asbestos-containing materials from abatement of
the NESHAP Method Building will be monitored to determine whether this activity releases
airborne asbestos fibers that are above comparative background The activity is expected to take
less than four hours The monitors will be placed at 60-degree intervals measured along a radius
from the center of the landfilling activity and at a height of 5 feet above ground In addition, the
bulldozer operator will be fitted with a personal sampling pump which will operate over the
entire period of the activity In addition, a fixed-station area sample will be positioned m the cab
of the same bulldozer for asbestos and total fibers analysis The estimated number of air samples
to be collected and analyzed for asbestos and total fibers is presented in Table B-16.
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Section B
November 23, 2005
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Table B-16. Air Samples for Asbestos3
During Landfilling of Bagged Asbestos-Containing Waste
from Abatement of NESHAP Building
Type of Sample
Perimeter
Bulldozer Operator
Bulldozer Operator Cab
Open Field Blank
Closed Field Blank"
Total Samples
Number of Samples
6
1
1
1
1
10
' Samples will be analyzed both for asbestos (ISO 10312 1995)
and total fibers (N1OSH 7400, A Counting Rules)
b Closed field blanks will only be analyzed if asbestos contamination
is detected on the open field blanks
B1.6 Summary of Field Samples
The number of field samples that will be collected for asbestos analysis by TEM is
summarized in Table B-17
B-17. Summary of Field Samples to be Collected for Asbestos Analysis by TEM
Source Table
B-2 Perimeter air demolition site
B-3 Worker during building demolition
B-5 Bulk soil
B4 Worker activity during demolition
B-6 Soil elutriation
B-7 Perimeter settled dust
B-8 Surface run-off water
B-9 Source water (hydrant and amended)
B-10 Perimeter air landfilhng
B-ll Worker during landfilling
B-12- Background at demolition site
B-13- Background at landfill
B-14 HEP A discharge
B-l 5 Loading bagged ACM at demo site
B-16 Landfill bagged ACM
Total samples
Air"
288
36
-
18
15
-
.
-
36
12
24
36
4
12
8
489
Soil
-
-
50b
-
-
-
.
-
.
-
.
-
.
.
-
50
Water
.
-
.
-
-
.
8
6
.
-
-
-
.
.
-
14
Settled
Dust
-
-
-
-
-
54
.
-
.
-
-
-
.
-
-
54
QC
48
4
-
4
-
12
4
-
8
4
8
12
3
3
2
112
Total
Samples
336
40
50
22
15
66
12
6
44
16
32
48
7
15
10
719
a Samples (excluding soil elutnation and HEPA discharge samples) will also be analyzed for total fibers
(N1OSH 7400, A Counting Rules)
b Soils samples will be analyzed by both PLM and TEM
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B2 SAMPLING METHOD REQUIREMENTS
B2.1 Air Sampling
B2.1.1 Perimeter Air Sampling for Asbestos
The samples for both asbestos and total fibers analysis will be collected on the same
open-face, 25-mm-diameter 0 45-um pore size mixed cellulose ester (MCE) filters with a 5-um
pore size MCE diffusing filter and cellulose support pad contained in a three-piece cassette with
a 50-mm non-conductive cowl This design of cassette has a longer cowl than the design
specified in ISO 10312 1995, but it has been m general use for some years for ambient and
indoor air sampling Disposable filter cassettes with shorter conductive cowls, loaded with the
appropnate combination of filter media of known and consistent origin, do not appear to be
generally available
The filter cassettes will be positioned on a sampling pole that will accommodate cassette
placement at 5 feet and 15 feet above ground The filter face will be positioned at approximately
a 45-degree angle toward the ground At the end of the sampling period, the filters will be turned
upright before being disconnected from the vacuum pump and then stored in this position
The filter assembly will be attached with flexible Tygon® tubing (or an equivalent
material) to an electric-powered [110 volts alternating current (VAC)] 1/10-horsepower vacuum
pump operating at an airflow rate of approximately 8 liters per minute An air volume of 1,920
to 2,400 liters will be achieved for all samples Each pump will be equipped with a flow-control
regulator to maintain the initial flow rate of 8 liters per minute to within +/-10% throughout the
sampling period If a 110-V AC line power is not available (such as at the landfill), portable 15-
20 amp gasoline-powered generators will be used to power the sampling pumps.
B2.1.2 Worker Exposure Monitoring for Asbestos and Lead
Asbestos—Personal breathing samples will be collected on open-face, 25-mm-diameter
0 8-um pore size MCE filters with a cellulose support pad contained in a three-piece cassette
with a 50-mm non-conductive cowl The filter assembly will be attached to a constant-flow,
battery-powered vacuum pump operating at a flow rate of 2 liters per minute An air volume of
480 to 600 liters will be achieved for all samples
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Lead—Personal breathing samples will be collected on closed-face, 37-mm diameter 0 8-
um pore size MCE filters with a cellulose support pad contained in a three-piece cassette The
filter assembly will be attached to a constant-flow, battery-powered vacuum pump operating at a
flow rate of 2 liters per minute An air volume of 480 to 600 liters will be achieved for all
samples
B.2.2 Real-Time Aerosol Monitoring
Real-time measurement and recording of aerosol (dust) concentrations in air at the
demolition site and landfill will be made using a particle measuring device (MEI personal
DataRam Model pDR 1200) It is intended to be used as a semi-quantitative (relative) index of
the concentration of airborne dust particles in the vicinity of workers engaged in the demolition
and landfilling activities The instrument is designed to measure particles in the 0 1 urn to 10
urn range with a concentration measurement range of 0 1 to 400 mg/m
B2.3 Meteorological Monitoring
Two portable meteorological stations manufactured by Met One Instruments, Inc, and
equipped with AutoMet Sensors (or equivalent instruments) will be used to record 5-minute
average wind speed and wind direction data, as well as temperature, barometric pressure, and
relative humidity A meteorological station will be installed at both the Fort Chaffee demolition
site and the City of Fort Smith Landfill The data files will be downloaded and archived by
using an on-site personal computer Periodic (at least hourly) direct readout of the data will be
recorded on a Meteorological Measurement Log (Figure A-12)
B2.4 Soil Sampling
Ten interleaved composite samples will be collected from the within the bermed area
Each sample will be a composite of 30 grab samples, three from random locations in each of the
10 blocks of the grid A second composite sample will be collected over the same study area
following this procedure with different locations sampled within the subsections. This will be
repeated until 10 composite samples are collected Each sample will be collected from an area
measuring 6-mches by 6-mches with approximately a '/2-inch depth The area will be delineated
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by using a template The use of a template will help ensure that each component of the 10-part
composite sample is of similar mass
The soil samples will be collected by using a clean metal scooping tool (e g , a garden
trowel) and placed in a cleaned plastic container with screw cap Between collections of each
sample, the template and trowel will be cleaned with detergent water
The ten composite soil samples will be sent to RTI RTI will dry, homogenize, and
evenly split the samples into two fractions One fraction will be sent to REI for total asbestos
analysis (PLM and TEM) and one-third of the other fraction, chosen at random, will be sent to
Lab/Cor for soil elutnation tests. The remaining two-thirds will be archived by RTI
B2.4.1 Preparation of Soil Samples for Asbestos Analysis
RTI International will receive and process the samples as follows
1. Receive and log sample
2 The modified elutriator method requires the sample be dried at a temperature not
exceeding 60 °C The samples can best be blended and subdivided if they are
dried Therefore, the samples will be dried at a temperature of 60 °C for 24 hours
to comply with these requirements and to facilitate the mixing and sample
apportionment If the sample is not dry after the 24 hour period, the samples will
be dried for additional 24 hour periods until dryness is achieved
3 The dried samples will be subjected to mixing for homogemzation and cone-and-
quarter for splitting the samples into two separate portions as described in EPA
540-R-97-028 Each dried sample will be homogenized by tumbling in a tightly
sealed metal container. Sample material will be introduced into the container
such that the container does not exceed half-full As the container is filled, any
readily visible soil clods or soft aggregates will be reduced by hand to facilitate
mixing. No attempt will be made to reduce the size of any building debns in the
sample The container will be closed and sealed, and will then be rotated, at a rate
of approximately 50 RPMs, through 100 revolutions After waiting 15 minutes to
allow any "fines" to settle, the container will be opened and the contents assessed
for their suitability to be coned and quartered If deemed suitable, the contents
will be emptied onto a large clean surface for holding, and the aforementioned
process will be repeated for the balance of the sample Each homogenized sample
portion will be emptied onto the previously accumulated sample cone until all the
sample portions have been homogenized and combined into one cone The large
cone will then be halved by pushing the plate vertically downward into the cone at
the cone apex. Each sample half will then be placed in a separate container
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If after 100 revolutions, a sample is deemed to be insufficiently homogenized, the
process will be repeated in increments of 100 additional revolutions until
sufficient homogemzation has been achieved
4 The subs am pies will be labeled with the sample identification numbering system
as provided with the samples
5 All devices used for preparing the samples will be thoroughly cleaned before and
between each sample preparation
B2.5 Settled Dust Sampling
Settled dust samples for asbestos and lead analysis will be passively collected by using
ASTM Method D 1739-98 "Method for Collection and Measurement ofDustfall (Settleable
Paniculate Matter " The collection container is an open-topped cylinder approximately 6 inches
in diameter with a height of 12 inches The container will be fastened to the same sampling pole
as the air samples at a height of 6 feet above the ground The sampling time for the ASTM
protocol will be extended one hour beyond the end of demolition activity Upon completion of
sampling the dust collection container will capped and sealed for shipment to the laboratory
B2.6 Source Water Sampling—Hydrant and Amended Water
The sample container will be an unused, 1-liter pre-cleaned, screw-capped glass bottle
Prior to sample collection, the water from the water source must be allowed to run for a
sufficient period to ensure that the sample collected is representative of the source water
Approximately 800 milliliters of source water for each sample will be collected An air
space will be left in the bottle to allow efficient re-dispersal of settled material before analysis
A second bottle will be collected and stored for analysis if confirmation of the results obtained
from the analysis of the first bottle is required
The samples will be transported to the analytical laboratory and filtered by the laboratory
within 48 hours of each sample collection No preservatives or acids will be added At all times
after collection, the samples will be stored in the dark and stored at about 5° C (41° F) in order to
minimize bacterial and algal growth The samples will not be allowed to freeze because the
effects on asbestos fiber dispersions are not known On the same day of collection the samples
will be shipped in a cooler at about 5° C (41° F) to the lab for analysis via one-day courier
service
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B2.7 Water Sampling—Contained Runoff Water
The sample container will be an unused, 1-liter pre-cleaned, screw-capped glass bottle
Samples will be collected by scooping runoff water from the collection basin Approximately
800 mL of source water will be collected An air space will be left in the bottle to allow efficient
redispersal of settled material before analysis A second bottle will be collected and stored for
analysis if confirmation of the results obtained from the analysis of the first bottle is required
The samples will be transported to the analytical laboratory and filtered by the laboratory
within 48 hours of each sample collection No preservatives or acids will be added At all times
after collection, the samples will be stored in the dark and stored at about 5° C (41° F) in order to
minimize bacterial and algal growth The samples will not be allowed to freeze because the
effects on asbestos fiber dispersions are not known On the same day of collection the samples
will be shipped in a cooler at about 5° C (41° F) to the laboratory for analysis via one-day courier
service
B2.8 Soil Elutriation Tests
Once in the laboratory, the soil samples will be prepared and analyzed as described in the
Modified Elutnator Method (Berman and Kolk 2000) Briefly, the method involves placing an
approximately 60 g (weighed) sample in a tumbler (one-inch square cross section), passing
constant humidity air over the sample while tumbling (to pick up entrainable dust), separating
out the respirable fraction8 of dust in a vertical elutriator, and depositing the resulting dust on a
pre-weighed polycarbonate filter, which is re-weighed (to determine the quantity of dust
deposited) and prepared (using a direct transfer procedure) for analysis by TEM (ISO 10312-
1995) for the determination of asbestos Results are reported as the number of asbestos
structures per microgram of respirable dust (as/ugpMio)
The respirable fraction is composed of respirable dust Respirable dust is defined as the set of
structures exhibiting an aerodynamic equivalent diameter (AED) less than or equal to 10 um, which is
captured by devices designed to extract what is termed the ''PMio" fraction of paniculate matter The
AED of a particle is the diameter of a sphere of unit density that exhibits the same settling velocity in
air as that of the actual particle.
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B3 SAMPLE CUSTODY REQUIREMENTS
EQ's cham-of-custody procedures emphasize careful documentation of constant secure
custody of samples during the field, transport, and analytical stages of environmental
measurement projects The sample custodian (and alternate) responsible for the proper cham-of-
custody during this project is'
John R Kommsky (and alternate Bruce A Hollett)
Environmental Quality Management, Inc
1800 Carillon Boulevard, Cincinnati, OH 45240
Phone 513 825 7500, fax 513 825 7495
B3.1 Field Chain-of-Custody
Each sample will have a unique project identification number A unique sample
identification system will be developed for the samples collected at the demolition site and the
samples collected at the landfill The numbering system will also be unique for each building.
i e , #3602 and #3607 QC samples will be blind to the laboratory This identification number
will be recorded on a Sampling Data Form (Figures A-8 through A-12) along with the other
information specified on the form After the labeled sample cassettes and containers are
inspected, the sample custodian will complete an Analysis Request and Cham-of-Custody
Record (Figure B-13). This form will accompany the samples, and each person having custody
of the samples will note receipt of the same and complete an appropriate section of the form
Samples will be sent to the appropriate Laboratory (see Section A8 2) via Federal Express
Overnight Service
B3.2 Analytical Laboratory
The laboratory's sample clerk will examine the shipping container and each sample
cassette or sample container to verify sample numbers and check for any evidence of damage or
tampenng The chain of custody form is checked for completeness and signed and dated to
document receipt Any changes will be recorded on the original cham-of-custody form and then
the form will be forwarded to the EQ Project Manager The sample clerk will log in all samples
and assign a unique laboratory sample identification number to each sample and sample set
Chain-of-custody procedures will be maintained in the analytical laboratory.
-------
ANALYSIS REQUEST AND
CHAW Of CUSTODY RECORD
Raference Document No. A- 0 3 0 5
Page 1 ci
Sample
lab Dotlinallon
Lab Cortw#Pbon$
Lab Purchase Ortsr No. ,
Figure B-13. Analytical Request and Chain-of-Custody Form
ONE CONTAINER PER LINE
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Section B
November 23, 2005
Revision 0
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B4 ANALYTICAL METHOD REQUIREMENTS
B4.1 Air Samples (TEM)
Perimeter Samples—The 0 45-um pore size mixed-cellulose ester (MCE) air sampling
filters will be prepared and analyzed by using ISO Method 10312 1995, Ambient Air -
Determination of Asbestos Fibres - Direct-Transfer Transmission Electron Microscopy Method "
Note After TEM analysis, a sector from the same filter will then be analyzed using PCM (see
Section B4 2 "Air Samples (PCM)") If the samples are overloaded, they will be analyzed by ISO
13794 \999, Ambient Air-Determmation of Asbestos Fibers. Indirect-Transfer Transmission
Electron Microscopy Method (TEM)
Personal Samples— The 0 8-um pore size mixed-cellulose ester (MCE) air sampling
filters will be prepared and analyzed by using ISO Method 10312 1995, Ambient Air -
Determination of Asbestos Fibres - Direct-Transfer Transmission Electron Microscopy Method "
Note- After TEM analysis, a sector from the same filter will then be analyzed using PCM (see
Section B4 2 "Air Samples (PCM)"). If the samples are overloaded, they will be analyzed by
ISO 13794 1999, Ambient Air-Determination of Asbestos Fibers Indirect-Transfer Transmission
Electron Microscopy Method (TEM)
B4.1.1 TEM Specimen Preparation
TEM specimens will be prepared from the air filters by using the dimethylformamide
(DMF) collapsing procedure of ISO 10312 1995, as specified for cellulose ester filters DMF
will be used as the solvent for dissolution of the filter in the Jaffe washer For each filter, a
minimum of two TEM specimen grids will be prepared from a one-quarter sector of the filter by
using 200 mesh-indexed copper grids The remaining part of the filter will be archived, in the
original cassette in clean and secure storage, to be possibly selected for quality assurance
analyses
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Section B
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B4.1.2 Measurement Strategy
1 The minimum aspect ratio for the analyses shall be 3 1, as permitted by ISO
10312 1995
2 Table B-18 presents the size ranges of structures that will be evaluated, and target
analytical sensitivities for each TEM method The laboratories will adjust
individual numbers of gnd openings counted based upon the counting rules and
the amount of material prepared for each sample
3 A minimum often grid openings shall be examined If ten or more structures are
identified, counting is stopped If less than ten structures are identified, counting
is continued until ten structures are identified or the required area is examined
which corresponds to the desired analytical sensitivity
4. The structure counting data shall be distributed approximately equally among a
minimum of two specimen grids prepared from different parts of the filter sector
5 The TEM specimen examinations will be performed at approximately
20,000 magnification
6 PCM-equivalent asbestos fibers will also be determined for the air samples.
7 The type of fiber will be specified In addition to classifying fibers as one of the
six NESHAP-regulated asbestos varieties, all other amphibole mineral particles
meeting the aspect ration of >3'1 and lengths >5 um) will be recorded This
includes non-NESHAP-regulated asbestos amphiboles (e g, winchite, nchtente)
Reference to or implication of either use of the term cleavage fragments and/or
discriminatory counting shall not apply
B4.1.3 Determination of Stopping Point
The analytical sensitivity and detection limit of microscopic methods (such as TEM and
PCM) are a function of the volume of air drawn through the filter and the number of grid
openings or fields counted. In principle, any required analytical sensitivity or detection limit can
be achieved by increasing the number of gnd openings or field examined Likewise, statistical
uncertainty around the number of fibers observed can be reduced by counting more and more
fibers Stopping rules are needed to identify when microscopic examination should end, both at
the low end (zero or very few fibers observed) and at the high end (many fibers observed).
-------
Table B-18. Approximate Number of TEM Grid
Achieve Target Analytical Sensitivity
Section B
November 23, 2005
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Openings to
Method
ISO 10312 - Perimeter Air
Direct Preparation
ISO 10312 -Worker Air
Direct Preparation
EPA/600/R-93/116, 1993-
Soil
ASTM D 5755-03 - Settled
Dust
EPA 100 2 -Water
Hydrant Source and
Runoff Source
Structure
Size Range
All
Structures
(minimum
length of 05
urn, aspect
ratio >3 1)
All Fibers
(minimum
length of 05
um, aspect
ratio >3 1)
All
Structures
(minimum
length of 05
um, aspect
ratio >3 1)
All
Structures
(minimum
length of 05
um, aspect
ratio >3 1)
All
Structures
(minimum
length of 05
um, aspect
ratio >3.1)
Target
Analytical
Sensitivity
0 0005 s/cc
0 005 f/cc
01%
250 s/cm2
0 05 million
s/L Hydrant
2 million
s/L Runoff
Approximate
Magnification
for
Examination
20,000
10,000
20,000
20,000
20,000
Approximate
Grid Area
Examined,
mm2
0 32 based on air
Volume of 2,400 L
0 16 based on air
Volume of 480 L
01
0 1 based on filter
area of 923 mm2
and 100 ml of 500
ml filtered
0 37 based on
filter area of 923
mm2 and 50 ml
filtered,
0 46 based on
filter area of 923
mm2 and 1 ml
filtered
Approximate
Number of
0.01-mnT2 Grid
Openings
Required
32
16
10
10
37
46
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The following stopping rules will be used in this project
Section B
November 23, 2005
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Method
TEM(ISO10312 1995)
perimeter air
TEM (ISO 10312 1995)
worker air
PCM (NIOSH 7400)
EPA/600/R-93/116, 1993 - Soil
ASTM D 5755-03 -
Settled Dust
EPA 100.2-Water
Stopping Rules
Count 10 grid openings or until >10
structures are counted If < 10 structures
are counted, then count the number of grid
openings to achieve an analytical
sensitivity of
0 0005 asbestos structures/cm3
Count 10 grid openings or until >10
structures are counted If < 10 structures
are counted, then count the number of grid
openings to achieve an analytical
sensitivity of
0 005 asbestos structures/cm3
100 fields are viewed or 100 fibers are
counted (but not less than 10 fields must
be counted)
Terminate fiber count at a minimum of
100 fibers or 10 grid openings (whichever
occurs first), providing that an analytical
sensitivity of 0 1% has been achieved. If
not, continue until this analytical
sensitivity has been achieved Always
complete the structure count for the last
grid opening evaluated
Terminate fiber count at a minimum of
100 fibers or 10 grid openings (whichever
occurs first), providing that an analytical
sensitivity of 250 s/cm2 has been achieved
If not, continue until this analytical
sensitivity has been achieved Always
complete the structure count for the last
gnd opening evaluated
Terminate fiber count at a minimum of
100 fibers or 10 grid openings (whichever
occurs first), providing that an analytical
sensitivity of 0 05 million s/L or
2 million s/L depending on water source
has been achieved If not, continue until
this analytical sensitivity has been
achieved Always complete the structure
count for the last gnd opening evaluated
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Section B
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B4.2 Air Samples (PCM)
Perimeter Samples—The 0 45-um pore size MCE air sampling filters (descnbed in
Section B4 1) will be prepared and analyzed for total fibers by using NIOSH Method 7400
"Asbestos Fibers by PCM" (A Counting Rules) Fibers greater than 5 jam in length and with an
aspect ratio greater than 3 1 will be counted
Personal Samples—0 8-um pore size MCE air sampling filters will be prepared and
analyzed for total fibers by using NIOSH Method 7400 "Asbestos Fibers by PCM" (A Counting
Rules) Fibers greater than 5 urn in length and with an aspect ratio greater than 3 1 will be
counted
B4.3 Air Samples (Lead)
The 0 8-um pore size MCE air sampling filters will be prepared and analyzed for
inorganic lead by using NIOSH Method 7300 "Elements bylCP (Nitric/Perchloric Acid
Ashing) "
B4.4 Soil Samples (TEM)
Asbestos—Soil samples will be prepared and analyzed for asbestos by using EPA's
"Method for the Determination of Asbestos in Bulk Building Materials" (EPA/600/R-93/116,
July 1993)
B4.5 Settled Dust Samples (TEM)
The analytical sample preparation and analysis for asbestos will follow ASTM Standard
D5755-03 "Microvacuum Sampling and Indirect Analysis of Dust by Transmission Electron
Microscopy for Asbestos Structure Number Surface Loading" with the following exceptions
• Section 8 - Sampling Procedure for Microvacuum Technique The section is replaced
with ASTM D 1739-98 sample collection procedure
• Section 10.4 1 through 10.4.3. Rinse the sample collection container with approximately
100ml of 50/50 mixture of particle-free water and reagent alcohol using a plastic wash
bottle Pour the suspension through a 1 0 by 1 0 mm opening screen into a pre-cleaned
500 or 1000 ml specimen bottle All visible traces of the sample contained in the
collection device shall be rinsed through the screen into the specimen bottle. Repeat the
washing procedure three times Discard the screen and bring the volume of the
suspension in the specimen bottle up to 500ml with particle free water only
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• Section 162 Recording Data Rules ISO 10312 1995 counting rules will be followed
B4.6 Water Samples
The asbestos content of the water samples will be determined by using EPA Method
100 2 "Analytical Method Determination of Asbestos in Water " All fibers greater than 0 5 um
in length and with an aspect ratio of greater than or equal to 3 1 will be counted
B4.7 Soil Elutriation Air Samples
Air samples will be prepared as described in EPA 540-2-90-005, Modified Elutriator
Method for the Determination of Asbestos m Soils and Bulk Materials (Revision 1) The
elutriated air samples will be analyzed by TEM using ISO Method 10312 1995
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B5 QUALITY CONTROL REQUIREMENTS
The overall quality assurance objective is to provide defensible data of known quality
meeting quality assurance objectives. To that end, procedures are developed and implemented
for field sampling, chain-of-custody, laboratory analysis, reporting, and audits that will provide
results which are scientifically valid and legally defensible in a court of law
B5.1 Field Quality Control Checks
Quality control checks for the field sampling aspects of this project will include, but not
be limited to, the following
• Use of standardized forms (e g, Figures A-8 through A-12, B-13) to ensure
completeness, traceabihty, and comparability of the data and samples collected
• Calibration of air sampling equipment including pre- and post-sample calibrations
using a calibrated precision rotameter
• Proper handling of air sampling filters and sample containers to prevent cross
contamination
• Collection of field blanks and field duplicate samples
• Field cross-checking of data forms to ensure accuracy and completeness Strict
adherence to the sample chain of custody procedures outlined in this QAPP
B5.1.1 Air Field QC for Asbestos and Total Fibers
Field QC air samples will include open and closed field blanks and field duplicates
B5.1.1.1 Field Blanks
Field blank samples are used to determine if any contamination has occurred dunng
sample handling Opened and closed field blanks will be collected each day of sampling
Opened field blanks are filter cassettes that have been transported to the sampling site, opened
for a short-time (< 30 seconds) near an actual sampling location without any air having passed
through the filter, and then sent to the laboratory Closed field blanks are filter cassettes that
have been transported to the sampling site and then sent to the laboratory without being opened
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The opened field blanks will be analyzed, and the closed field blanks will be archived The
closed field blanks will only be analyzed if the opened field blanks show contamination
B5.1.1.2 Field Duplicates
A duplicate sample is a second sample collected concurrently at the same location as the
original sample
B5.1.2 Soil Field QC for Asbestos
Due to the collection of the interleaved composite samples, field duplicate samples are
not applicable.
B5.1.3 Settled Dust Field QC
Field QC settled dust samples will include field blanks and field duplicates
B5.1.3.1 Field Blanks
A field blank is prepared by placing a collection device in the field, removing the lid and
then immediately replacing the lid
B5.1.3.2 Field Duplicates
A duplicate sample is a second sample collected concurrently at the same location as the
original sample
B5.1.4 Water Field QC
Field QC water samples will include field blanks and field duplicates
B5.1.4.1 Field Blanks
A field blank is a clean glass container containing approximately 800 ml of laboratory
water The container filled with water will be provided by the laboratory. The container will be
opened in the field for approximately 30 seconds
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B5.1.4.2 Field Duplicate
A duplicate sample is a second sample collected concurrently at the same location as the
original sample, but is collected after the original sample is collected
B5.2 Laboratory Quality Control Checks
A summary of the analytical methods and the quality assurance/quality control (QA/QC)
checks is presented in Table B-19
B5.2.1 Air Laboratory QC
B5.2.1.1 Lot Blanks
Before air samples are collected, a minimum of 2 percent of unused filters from each
filter lot of 100 filters will be analyzed to determine the mean asbestos structure count The lot
blanks will be analyzed for asbestos structures by using ISO 10312 1995 If the mean count for
all types of asbestos structures is found to be more than 10 structures/mm2 the filter lot will be
rejected
B5.2.1.2 Laboratory Blank
Laboratory blanks are unused filters (or other sampling device or container) that are
prepared and analyzed m the same manner as the field samples to verify that reagents, tools, and
equipment are free of the subject analyte and that contamination has not occurred during the
analysis process The laboratory will analyze at least one blank for every 10 samples or one
blank per prep series Blanks are prepared and analyzed along with the other samples If the
blank control cntena (Section B 5.2 1.1) are not met, the results for the samples prepared with
the contaminated blank are suspect and should not be reported (or reported and flagged
accordingly) The preparation and analyses of samples should be stopped until the source of
contamination is found and eliminated Before sample analysis is resumed, contamination-free
conditions shall be demonstrated by preparing and analyzing laboratory clean area blanks (see
Section B5 2 2 3) that meet the blank control criteria. Laboratory blank count sheets should be
maintained in the project folder along with the sample results.
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Table B-19. Analytical Methods and Quality Assurance (QA)/Quality Control (QC) Checks
Matrix
Perimeter
Air
Analyte
Asbestos by
TEM
Method and
Analytical
Sensitivity
ISO Method
10312 1995,
0.0005 s/cm3
QA/QC Checks
Lot Blanks
Laboratory Blanks
Laboratory Clean
Area Blanks
Replicate Analysis
(recount by same
analyst)
Verification
Counting (mtralab
and mterlab)
Duplicate Analysis
(reprep and analysis
by same analyst)
Interlaboratory
Duplicates
Frequency
2% of unused
filters
Each sample
batch
Whenever
laboratory
blanks do not
meet criteria
3% of samples
1% of samples
3% of samples
5% of samples
Acceptance Criteria
<10 asbestos s/mm2
<10 asbestos s/mmz
<10 asbestos s/mm2
Acceptable Analytical
Variability from
Table B-20
>80% true positives,
<20% false negatives,
<20% false positives
Acceptable Analytical
Variability from
Table B-20
Acceptable Analytical
Variability from
Table B-20
Corrective Action if
Acceptance Criteria Not
Met
Reject filter lot
Collect and analyze clean
area blanks, re-prep filter
samples
Find and eliminate source of
contamination
Re-examine grids to
determine cause of variation
Re-examine grids to
determine cause of variation
Re-examine grids to
determine cause of variation;
re-prep filter samples
Re-examine grids to
determine cause of variation,
re-prep filter samples
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Table B-19. (continued)
Matrix
Worker
Air
Analyte
Total Fibers
by PCM
Total Fibers
by PCM
Asbestos by
TEM
Method and
Analytical
Sensitivity
NIOSH
Method 7400,
0 001 f/cm3
With 2400L
NIOSH
Method 7400,
0.006 f/cm3
(480 L)
0 003 f/cm3
(960 L)
ISO Method
10312:1995,
0 005 s/cm3
QA/QC Checks
Blind recounts on
reference slides
Blind recounts on
filter samples
Blind recounts on
reference slides
Blind recounts on
filter samples
Lot Blanks
Laboratory Blanks
Laboratory Clean
Area Blanks
Replicate Analysis
Venfi cation
Counting
Frequency
Daily
10%
Daily
10%
2% of unused
filters
Each sample
batch
Whenever
laboratory
blanks do not
meet criteria
3% of samples
1% of samples
Acceptance Criteria
Per laboratory control
charts
See Step 13 of Method
7400
Per laboratory control
charts
See Step 13 of Method
7400
<10 asbestos s/mm2
<10 asbestos s/mm2
<10 asbestos s/mm2
Acceptable Analytical
Variability from
Table B-20
>80% true positives,
<20% false negatives,
<20% false positives
Corrective Action if
Acceptance Criteria Not
Met
Investigate source of
imprecision, re-count
reference slides
Investigate source of
imprecision, re-count filter
sample
Investigate source of
imprecision; re-count
reference slides
Investigate source of
imprecision, re-count filter
sample
Reject filter lot
Collect and analyze clean
area blanks, re-prep filter
samples
Find and eliminate source of
contamination
Re-examine grids to
determine cause of variation
Re-examine grids to
determine cause of variation
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Table B-19. (continued)
Matrix
Soil
Analyte
Asbestos by
TEM
Asbestos by
PLM
Method and
Analytical
Sensitivity
EPA/600/R-
93/116
(TEM)
01%
EPA/600/R-
93/116
(PLM)
01%
QA/QC Checks
Duplicate Analysis
(reprep and
analysis by same
analyst)
Intel-laboratory
Duplicates
Laboratory Blanks
Laboratory Control
Samples (spiked
standards)
Replicate Analysis
Duplicate Analysis
Interlaboratory
Duplicates
Laboratory Control
Samples (spiked
standards)
Replicate Analysis
Frequency
3% of samples
5% of samples
Each sample
batch
Each sample
batch
5% of samples
5% of samples
20% of samples
Each sample
batch
5% of samples
Acceptance Criteria
Acceptable Analytical
Variability from
Table B-20
Acceptable Analytical
Variability from
Table B-20
Running average <1 8
s/mm2
Acceptable Analytical
Variability from
Table B-20
Acceptable Analytical
Van ability from
Table B-20
Acceptable Analytical
Variability from
Table B-20
Acceptable Analytical
Variability from
Table B-20
Acceptable Analytical
Variability from
Table B-20
Acceptable Analytical
Variability from
Table B-20
Corrective Action if
Acceptance Criteria Not
Met
Re-examine grids to
determine cause of variation,
re-prep filter samples
Re-examine grids to
determine cause of variation,
re-prep filter samples
Find and eliminate source of
contamination, re-prep
samples
Re-examine sample to
determine cause of variation,
re-prep samples
Re-examine grids to
determine cause of variation
Re-examine grids to
determine cause of variation;
re-prep samples
Re-examine grids to
determine cause of variation
Reprepare and re-examine
sample to determine cause of
variation
Reprepare and re-examine
sample to determine cause of
van ati on
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Table B-19. (continued)
Matrix
Settled
Dust
Analyte
Asbestos by
TEM
(Soil
Elutnation)
Asbestos by
TEM
Method and
Analytical
Sensitivity
Elutnator, ISO
10312 1995,
lxl06s/gpMio
ASTMD
5755-03;
250 str/cm2
QA/QC Checks
Duplicate Analysis
Interlaboratory
Duplicates
Lot Blanks
Laboratory Blanks
Laboratory Clean
Area Blanks
Replicate Analysis
Duplicate Analysis
Elutnation
Duplicate
Elutnation SRMs
Lot Blanks
Frequency
5% of samples
20% of samples
2% of unused
filters
1 per 10
samples or each
sample batch
Whenever
laboratory
blanks do not
meet criteria
3% of samples
3% of samples
2 samples
2 levels
2% of unused
filters
Acceptance Criteria
Acceptable Analytical
Variability from
Table B-20
Acceptable Analytical
Variability from
Table B-20
<10 asbestos s/rnm^
<10 asbestos s/mmz
<10 asbestos s/mm2
Acceptable Analytical
Variability from
Table B-20
Acceptable Analytical
Variability from
Table B-19
None established
None established
<10 asbestos s/mm2
Corrective Action if
Acceptance Criteria Not
Met
Reprepare and re-examine
sample to determine cause of
variation
Reprepare and re-examine
sample to determine cause of
variation
Reject filter lot
Collect and analyze clean
area blanks, re-prep filter
samples
Find and eliminate source of
contamination
Re-examine grids to
determine cause of variation
Reprepare and re-examine
sample to determine cause of
variation
Not applicable
Not applicable
Reject filter lot
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Table B-19. (continued)
Matrix
Water
Analyte
Asbestos by
TEM
Method and
Analytical
Sensitivity
EPA 100 2,
0 OSrmllion
str/liter hydrant
2 million sir/
liter
runoff
QA/QC Checks
Laboratory Blanks
Laboratory Clean
Area Blanks
Replicate Analysis
Duplicate Analysis
Interlaboratory
Duplicates
Lot Blanks
Laboratory Blanks
Frequency
1 per 10
samples or each
sample batch
Whenever
laboratory
blanks do not
meet criteria
3% of samples
3% of samples
5% of samples
2% of unused
filters
1 per 10
samples or each
sample batch
Acceptance Criteria
<1 0 asbestos s/mm2
<10 asbestos s/mm2
Acceptable Analytical
Variability from
Table B-20
Acceptable Analytical
Variability from
Table B-20
Acceptable Analytical
Variability from
Table B-20
<10 asbestos s/mm2
<1 0 asbestos s/mm2
Corrective Action if
Acceptance Criteria Not
Met
Collect and analyze clean
area blanks, re-prep filter
samples
Find and eliminate source of
contamination
Re-examine grids to
determine cause of variation
Reprepare and re-examine
sample to determine cause of
variation, re-prep filter
samples
Reprepare and re-examine
sample to determine cause of
variation, re-prep filter
samples
Reject filter lot
Collect and analyze clean
area blanks, re-prep filter
samples
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Table B-19. ("continued)
Matrix
Analyte
Method and
Analytical
Sensitivity
QA/QC Checks
Laboratory Clean
Area Blanks
Replicate Analysis
Duplicate Analysis
Frequency
Whenever
laboratory
blanks do not
meet criteria
1 sample
1 sample
Acceptance Criteria
<10 asbestos s/mm2
Acceptable Analytical
Variability from
Table B-20
Acceptable Analytical
Variability from
Table B-20
Corrective Action if
Acceptance Criteria Not
Met
Find and eliminate source of
contamination
Re-examine grids to
determine cause of variation
Reprepare and re-examine
sample to determine cause of
variation
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Table B-20 Accepted Analytical Variability for Sample Re-Analysis
Type of sample
Air Samples
Non-Air Samples
replicate
duplicate
mterlab duplicate
co-located
replicate
duplicate
mterlab duplicate
lab control
Accepted Variability
1 96
224
224
250
224
250
250
2.50
* Analytical Variability =
I (Analysis A^ - (Analysis B11
V(Analysis A + Analysis B)
which is the absolute value of the difference of the two analyses, divided by the square root of
the sum, which is an estimate of the standard deviation of the difference based on a Poisson
counting model For replicate air samples, for which the simple Poisson model is most
directly applicable, the value 1 96 is chosen so that the criterion will flag approximately 1
replicate pair out of 20 for which die difference is due only to analytical variability, i e , it has
a "false positive" rate of 5% For the other types of analyses, where greater natural variability
is expected than indicated by a pure Poisson model, the cntenon value has been increased
from 1.96 in order to avoid flagging too many cases where the difference between die values is
due only to normal variation, and not to any problem with either analysis The values 2 24 and
2 50 were selected as targeting false positive rates of 2 5% (1/40) and 1 125% (1/80) for the
Poisson model.
Example 1 For replicate air samples where A = 0 fibers and B = 3 fibers, the vanation is
considered acceptable, while A = 0 and B = 4 would be flagged for further investigation
Likewise A = 1 and B = 6 is acceptable, while A = I and B = 7 is flagged At higher levels,
A = 20 and B = 34 is acceptable, but A = 10 and B = 24 is flagged
Example 2 For mterlab duplicate non-air samples, A = 0 and B = 6 is acceptable, but
A = 0 and B = 7 is flagged Likewise, A = 1 and B = 8 is acceptable, but A = 1 and B = 9 is
flagged
B5.2.1.3 Laboratory Clean Area Blanks
Clean area blanks are prepared whenever contamination of a single laboratory prep blank
exceeds the criteria specified in Section B 5 2 1 lor whenever cleaning or servicing of equipment
has occurred To check the clean area, a used filter is left open on a bench top in the clean area
for the duration of the sample prep process The blank is then prepared and analyzed by using
ISO Method 10312 1995 If the blank control criteria (see Section B 5 2 1 1) are not met, the
area is cleaned by using a combination of HEPA-filter vacuuming and a thorough wet-wiping of
all surfaces with amended water In addition, air samples should be taken in the sample prep
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room to verify clean air conditions At least 2,500 liters of air should be drawn through a 25-
mm-diameter 0 45-um pore size MCE filter by using a calibrated air sampling pump The
samples should then be analyzed by using ISO Method 10312 1995. If blank control criteria are
not met, sample preparation shall stop until the source of contamination is found and eliminated
Clean area sample results shall be documented
B5.2.1.4 Replicate Analysis
The precision of the analysis is determined by an evaluation of repeated analyses of
randomly selected samples A replicate analysis will be performed on a percentage of the
samples analyzed to assess the precision of the counting abilities of the individual analysts A
replicate analysis is a second analysis of the same preparation, but not necessarily the same grid
openings, performed by the same microscopist as in the original analysis The conformance
expectation for the replicate analysis is that the count from the original analysis and the replicate
analysis will fall within an acceptable analytical variability as shown in Table B-20,
B5.2.1.5 Duplicate Analysis
A duplicate sample analysis is also performed on a percentage of the samples analyzed to
assess the reproducibihty of the analysis and quantify the analytical variability due to the filter
preparation procedure. A duplicate analysis is the analysis of a second TEM grid preparation
prepared from a different area of the sample filter performed by the same microscopist as the
original analysis The conformance expectation for the duplicate analysis is that the counts from
the original and duplicate analyses will fall within the acceptable analytical variability shown in
Table B-20
5.2.1.6 Verification Counting
Due to the subjective component in the structure counting procedure, it is necessary that
recounts of some specimens be made by a different microscopist (i e., a microscopist different
than the one that performed the original analysis) in order to minimize the subjective effects
Verification counting will be done by more than one analyst in the initial laboratory and also by
the QC laboratory Counting will involve re-examination of the same grid openings by the
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participating analysts Such recounts provide a means of maintaining comparability between
counts made by different rmcroscopists These quality assurance measurements will constitute
approximately 1 percent of the analyses Repeat results should result in a level of consensus
between laboratories such that both laboratories have >80% true positives, <20% false negatives,
and <20% false positives in their verified counting analysis of asbestos structures
B5.2.1.7 Intel-laboratory Duplicates
The QC laboratory (RTI) will analyze a percentage of the air samples (TEM) as an
independent check of the results of the primary laboratory (MVA) These analyses will be
performed on a separate sector of the filter The filter will be provided by MVA to RTI The
conformance expectation for interlaboratory QC checks is that the counts from the original
analysis and the interlaboratory QC check will fall within the acceptable analytical variability
shown in Table B-20
B5.2.2 Soil Laboratory QC
B5.2.2.1 Laboratory Blanks
A laboratory blank is prepared by filtering 50 mL of water (the same type as used for
sample suspension/somcation) through the same type of filter used to prepare TEM grids A
sample blank should be prepared each time a new batch of filters is opened and each time the
filtering unit is cleaned Blanks will be considered contaminated if they have a running average
fiber loading greater 18 asbestos structures per square millimeter (EPA 1987) This generally
corresponds to three or four asbestos structures found in ten grid openings The source of the
contamination must be found before any further analysis can be performed Reject samples that
are processed along with the contaminated blank samples and prepare new samples after the
source of the contamination is found
B5.2.2.2 Laboratory Control Samples
Laboratory control samples will consist of known amounts of chrysotile mixed in soil
obtained from the Fort Chaffee demolition site at a concentration range of approximately 01%
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These samples will be prepared by the QC laboratory (RTI) and analyzed by REI with each
sample batch
B5.2.2.3 Laboratory Duplicates
A duplicate sample analysis is also performed on 5% of the samples analyzed to assess
the reproducibihty of the sample preparation and analysis A duplicate analysis is the analysis
of a second aliquot of the original soil sample.
B5.2.2.4 Replicate Analysis and Verification Counting
Replicate analysis will be performed on 3% of the samples as described for the air
samples in Section B5 2 1.4
B5.2.2.5 Intel-laboratory Duplicates
The QC laboratory (RTI) will analyze 5% of the soil samples as an independent check of
the results of the primary laboratory (REI) These analyses will be performed on a subsample of
the soil which has been homogenized and prepared by the original laboratory
B5.2.3 Settled Dust Laboratory QC
B5.2.3.1 Laboratory Blanks
A laboratory blank is prepared by filtering water through the same type of filter used to
prepare TEM grids. A sample blank should be prepared each time a new batch of filters is
opened and each time the filtering unit is cleaned. Blanks will be considered contaminated if
they have greater than or equal to 10 asbestos structures per square millimeter The source of the
contamination must be found before any further analysis can be performed Reject samples that
are processed along with the contaminated blank samples and prepare new samples after the
source of the contamination is found
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B5.2.3.2 Laboratory Duplicates
A duplicate sample analysis is also performed on a percentage of the samples analyzed to
assess the reproducibihty of the sample preparation and analysis A duplicate analysis is the
analysis of a second aliquot of the original dust samples aqueous suspension
B5.2.3.3 Replicate Analysis
Replicate analysis will be performed on a percentage of the samples as described for the
air samples in Section B5 2 1
B5.2.3.4 Intel-laboratory Duplicates
The QC laboratory (RTI) will analyze a percentage of the dust samples as an independent
check of the results of the primary laboratory (REI) These analyses will be performed on a
subsample of the dust aqueous suspension which has been filtered by the original laboratory
B5.2.4 Water Laboratory QC
B5.2.4.1 Laboratory Blanks
A laboratory blank is prepared by filtering 100 mL of water through the same type of
filter used to prepare TEM grids A sample blank will be prepared with each sample set
BS.2.4.2 Laboratory Duplicates
A duplicate sample analysis is also performed on one of the samples analyzed to assess
the reproducibility of the sample preparation and analysis A duplicate analysis is the analysis of
a second aliquot of the original water sample.
B5.2.4.3 Replicate Analysis
Replicate analysis will be performed on one of the samples as described for the air
samples in Section B5 2 1 4
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B5.2.5 Elutriator Sample Laboratory QC
B5.2.5.1 Laboratory Blanks
Laboratory blanks are unused filters (or other sampling device or container) that are
prepared and analyzed m the same manner as the field samples to verify that reagents, tools, and
equipment are free of the subject analyte and that contamination has not occurred during the
analysis process The laboratory will analyze at least one blank for every 10 samples or one
blank per prep series Blanks are prepared and analyzed along with the other samples If the
blank control criteria (Section B 5 2 1 1) are not met, the results for the samples prepared with
the contaminated blank are suspect and should not be reported (or reported and flagged
accordingly) The preparation and analyses of samples should be stopped until the source of
contamination is found and eliminated Before sample analysis is resumed, contamination-free
conditions shall be demonstrated by preparing and analyzing laboratory clean area blanks
(Section B5 2 1 3) Laboratory blank results shall be documented Laboratory blank count
sheets should be maintained in the project folder along with the sample results
B5.2.5.2 Laboratory Duplicates
A duplicate sample analysis is also performed on a percentage of the samples analyzed to
assess the reproducibility of the sample preparation and analysis A duplicate analysis is the
analysis of a second aliquot of the original elutnator filter sample
B5.2.5.3 Replicate Analysis
Replicate analysis will be performed on a percentage of the samples as described for the
air samples in Section B5 2 1 4
B5.2.S.4 Elutriarion Duplicates
The laboratory conducting the generation of the elutnator samples will duplicate a
percentage of the soil samples to provide a measure of the precision of the sample generation
procedure
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B5.2.5.5 Elutriation SRMs
To provide a basis for determining relative releasabihty of asbestos structures from soils
and recovery of these structures during elutnation, soils from the site will be spiked with
prepared asbestos standards at two concentrations. The preparation of standards will be
accomplished by gently milling Standard Reference Material (SRM) asbestos standards for a
predetermined amount of time The milled material is weighed and analyzed by light and
electron microscopy to determine the distribution of asbestos structures per gram of SRM
material for all size ranges A low and high amount of asbestos standard by weight is added to
soil and blended gently into the soil by mixing After conditioning, the soils are loaded into the
elutnator tumbler and elutriated as per EPA method EPA 540-2-90-005, Modified May 23,
2000. Soils will be sieved through selective sieve sizes down to a 10 micron sieve. The final
fraction is weighed to estimate the PMio portion to the total weight of soil
Results from the elutnator are reported in number of structures per gram PMio of
particulate released from the soil by the elutnation process By knowing the number of
structures per gram of SRM standard within the PMio size range, based on fiber lengths less than
or equal to 10 micrometers with widths less than or equal to 3 0 micrometers, an estimate can be
made of the number of respirable fibers available for release from the PMio portion of soil This
estimate can be compared to the actual number of structures per gram PMio result from the
elutnation The ratio of the two results should give a recovery factor at 2 different
concentrations
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B6 INSTRUMENT/EQUIPMENT TESTING, INSPECTION,
AND MAINTENANCE REQUIREMENTS
B6.1 Field Instrumentation/Equipment
Field equipment/instruments (e g , sampling pumps, meteorological instrumentation) will
be checked and calibrated before they are shipped or carried to the field The equipment and
instruments will be checked and calibrated at least daily in the field before and after use Spare
equipment such as air sampling pumps, precision rotameters, and flow control valves will be
kept on site to minimize sampling downtime Backup instruments (e g , meteorological
instrumentation) will be available within one day of shipment from a supplier
B6.2 Laboratory Equipment/Instrumentation
As part of the Laboratory's (MVA, REI, RTI, and Lab/Cor) QA/QC Program, a routine
preventive maintenance program is performed to reduce instrument failure and other system
malfunctions of transmission and scanning electron microscopes The laboratory has an internal
group and equipment manufacturers' service contract to perform routine scheduled maintenance,
and to repair or to coordinate with the vendor for the repair of the electron microscope and
related instruments All laboratory instruments are maintained in accordance with manufacturer
specifications and the requirements of ISO Method 10312 1995
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B7 INSTRUMENT CALIBRATION AND FREQUENCY
B7.1 Field Instrument/Equipment Calibration
B7.1.1 Air Sampling Pumps
Before the sampling pumps are used in the field, their performance will be evaluated by a
qualified EQ industrial technician The air sampling pumps, which are the primary air sampling
item, will be evaluated to determine that they are capable of maintaining a stable flow rate for a
given static pressure drop, i e, the pressure drop created by a 25-mm, 0.45 um MCE membrane
filter with a 5 (am pore-sized MCE backup diffusing filter and cellulose support pad contained in
a three piece cassette at a flow rate of 8 1pm @ STP.
The air sampling pumps with a flow control valve will be evaluated to ensure that they
are capable of maintaining a stable flow rate for a given static pressure drop, i e, the pumps can
maintain an initial volume flow rate of within +/-10% throughout the sampling period Prior to
use, the sampling pumps will be tested against the pressure drop created by a 25-mm-diameter
0 45-um pore size MCE filter with a 5-um pore size MCE backup diffusing filler and cellulose
support pad contained in a three-piece cassette with 50-mm cowl at a flow rate of approximately
8 liters per minute at standard temperature and pressure (STP)
B7.1.2 Airflow Calibration Procedure
An in-line flow meter will be used to regulate the flow rate through the sampling train
during sampling The airflow rate will be determined both before and after sampling by using a
calibrated in-line flow meter The flow meter (a secondary calibration standard) will be
calibrated by using a primary standard airflow calibrator (Gilabrator electronic flow meter or
equivalent)
A detailed written record will be maintained of all calibrations The record will include
all relevant calibration data, including the following elements
Gilabrator model and serial number
• Flow meter model and serial number
« Sampling train (pump, flow control valve, and filter)
• X- and Y- coordinate calibration data
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. Intercept, slope, and correlation coefficient from a linear regression analysis of the
calibration data, and resulting linear regression equation that will be used to
determine the sampling flow rate
• Relevant calculations
• Dry bulb temperature
. Name of person/affiliation that performed the calibration and linear regression
analysis
B7.2 Calibration of TEM
The TEM shall be aligned according to the specifications of the manufacturer The TEM
screen magnification, electron diffraction (ED) camera constant, and energy dispersive X-ray
analysis (EDXA) system shall be calibrated in accordance with the specifications in ISO Method
10312 1995, AnnexB
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B8 INSPECTION/ACCEPTANCE REQUIREMENTS FOR
SUPPLIES AND CONSUMABLES
B8.1 Air Sampling Filter Media
See Section B 5 2 1 1 regarding the quality control check of the filter media
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B9 NON-DIRECT MEASUREMENTS
No data are needed for project implementation or decision making that will be obtained
from non-measurement sources such as computer data bases, programs, literature files, or
historical data bases
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BIO DATA MANAGEMENT
Commercially available computer hardware and software will be used to manage
measurement data to ensure the validity of the data generated Controls include system testing to
ensure that no computational errors are generated and evaluation of any proposed changes to the
system before they are implemented Commercially available software does not require testing,
but validation of representative calculations is required by using alternative means of
calculations
B10.1 Data Assessment
Sample data will be reviewed by the laboratory during the reduction, verification, and
reporting process During data reduction, all data will be reviewed for correctness by the
microscopist or analyst A second data reviewer will also verify correctness of the data Finally,
the Laboratory Director at MVA, REI, RTI, or Lab/Cor (as applicable) will provide one
additional data review to verify completeness and compliance with the project QAPP Any
deficiencies in the data will be documented and identified in the data report
B10.2 Data Management
Field and laboratory data will be entered into a Microsoft Excel spreadsheet (or other
applicable spreadsheet) to facilitate organization, manipulation, and access to the data Field
data will include information such as sampling date, sample number, sampling site, sample
description and location, sample type, air volume, and sampling period Laboratory data will
include information such as sample number, sample date received and analyzed, type of analysis,
magnification, grid location, grid square area, filter type, number of grids examined, number of
asbestiform structures counted, structure type (fiber, bundle, cluster, or matrix), and structure
length and width An example format for reporting the structure counting data is contained in
Figure 7 of ISO Method 10312-1995
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B10.3 Statistical Analysis
B 10.3.1 Evaluation of Airborne Asbestos Concentrations
The proposed primary statistical method for comparison of airborne asbestos
concentrations between the two methods is a two-sample t-test applied to the natural logarithms
of the 18 airborne concentrations measured in the primary ring for each method, this method
treats nondetect values as equivalent to measuring one-half a fiber in the sample The proposed
method depends on the assumption that the measured airborne asbestos concentrations follow a
lognormal distribution Goodness-of-fit tests such as the Kolmogorov test and the ShapiroWilk
test will be used to test this assumption Should such tests indicate that the normal distribution is
a better approximation to the distribution of measured airborne asbestos concentrations than the
lognormal, the t-test will be performed on the untransformed data rather than on the natural
logarithms Should neither the normal nor the lognormal distribution apply to the airborne
asbestos data, nonparametnc approaches will be used such as the Wilcoxon rank test, a
nonparametnc form of the two-sample t-test (Bickel and Doksum 1977)
While the two-sample t-test applied to the natural logarithms of the 18 airborne asbestos
concentrations measured for each method at the 5-foot height in the innermost ring has been
proposed as the primary statistical comparison, it is recognized that a rich dataset will result from
the demolition experiment For example, a variety of ancillary variables will be measured. The
most important include wind speed and direction at 5-minute intervals, the location of the actual
demolition activity as a function of time, and the position of the truck(s) for debris removal as a
function of time These variables can have a significant effect on the asbestos concentrations on
the monitors For example, a monitor that is downwind from the actual demolition activity when
that activity is close to the monitor is likely to have a higher asbestos concentration than a
monitor that is always upwind from the activity Monitors close to the truck where debns is
dumped for long periods of time are likely to show higher concentrations of asbestos A
regression model including the ancillary variables as predictors may therefore explain a
significant fraction of the variability in the airborne asbestos concentrations, thereby increasing
the power of the statistical analysis
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A second factor to consider is that airborne asbestos concentrations will also be measured
at the 15-foot height in the inner ring and at the 5-foot height in rings 2 and 3 While it is
expected, based on the dispersion modeling results, that the 5-foot samples in the first ring will
have the highest asbestos concentrations, it is possible that the 15-foot samples, or the samples in
the outer rings, could have higher values or at least values comparable to those at the 5-foot level
in the inner ring. In such cases, it will be necessary to construct a more elaborate model
accounting for all the airborne asbestos concentrations, and including the ancillary variables
discussed above as well as the distances of the 3 rings from the building This approach will
ensure that all the data collected in the experiment is taken into account in assessing the
comparability of the NESHAP and Alternative Methods.
In addition to the primary comparison, i e, to determine if airborne asbestos
concentrations from the Alternative Asbestos Control Method are statistically equal to or less
than the Asbestos NESHAP Method, it is of interest to evaluate whether airborne asbestos
concentrations downwind from the demolition are statistically greater than levels upwind If
they are not, then one can argue that asbestos concentrations from the demolition do not exceed
background levels in the vicinity of the buildings This question is of interest for the NESHAP
Method as well as for the Alternative Method because few statistical evaluations of airborne
asbestos concentrations from NESHAP demolitions have been conducted to date
The most efficient design for comparing upwind and downwind concentrations would be
to place monitors m paired locations upwind and downwind from the demolition, as opposed to
the ring placement proposed at Fort Chaffee A major shift in wind direction during the
demolition could result in little or no useful data being obtained with the upwind/downwind
approach Given the considerable cost of experimental setup, staging, and demolition of a
building, this is an unacceptable risk
A possible approach to the upwind/downwind comparison using the data collected from
the ring design is as follows. The hypothesis test to be conducted is
Ho H2<_Hi vs HI: H2>Hi
where the null hypothesis H0 is that airborne asbestos concentrations downwind from demolition
do not exceed levels upwind. If Ho is true, then the airborne asbestos level reported from a
monitor should be independent of the amount of time the monitor is actually downwind during
the demolition That is, the airborne asbestos concentrations YI, ¥2, . Yig should be
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independent of the percent of time PI, P2,. Pi8 each monitor is downwind during the
demolition Under the alternative hypothesis that airborne asbestos concentrations downwind
from demolition are greater than upwind levels, YI, ¥2, Yig are positively correlated with PI,
P2, PIS The Spearman rank correlation test can therefore be used as a hypothesis test.(6) This
test involves calculating a correlation between YI, Y2, . Yig and PI, P2, Pig by replacing the
observations with their ordered ranks
B 10.3.2 Evaluation of Post-Method Asbestos Soil Concentrations
In the evaluation of post-method asbestos concentrations in soil, similar analyses to those
described above for the airborne asbestos comparison will be conducted to validate the
assumptions of the two-sample t-test If the assumptions do not hold, alternative nonparametnc
methods will be used
The data collected during the building demolitions will be analyzed by using standard
analysis of variance (ANOVA) techniques The ANOVA is a formal statistical procedure that
tests whether two or more groups of data are significantly different, on average The natural
logarithm of each sample concentration will be used in the comparisons Log-transformation is
used to make the variances more equal and to provide data that are better approximated by a
normal distribution The use of a log-transformation is equivalent to assuming the data follow a
log-normal distribution, the log-normal distribution is commonly assumed for asbestos
measurements and other environmental contaminants Sample results reported as non-detected
will be replaced by the analytical sensitivity divided by two to calculate summary statistics and
to perform all statistical analyses All statistical comparisons will be made at the 0 05 level of
significance
U.S EPA Headquarters Library
Mail code 3404T
1200 Pennsylvania Avenue NW
Washington, DC 20460
202-566-0556
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November 23, 2005
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C ASSESSMENT/OVERSIGHT
Cl ASSESSMENT AND RESPONSE ACTIONS
Cl.l Performance and System Audits
Cl.1.1 Field Audit
EPA-ORD (or their representative) who is independent of field activities will audit the
field sampling and data collection activities at both the Fort Chaffee demolition site and the City
of Fort Smith Landfill The audit will include, but not be limited to. the examination of sample
collection and equipment calibration procedures, sample labeling, sampling data and cham-of-
custody forms, and other sample collection and handling requirements specified in the QAPP
The auditor will document any deviations from the QAPP so that they can be corrected in a
timely manner
Prior to leaving the site, the auditor will debnef the EPA-ORD Task Order Manager,
EPA-ORD Quality Assurance Officer, and the EQ Project Manager regarding the results of the
audit and any recommendations, if necessary The results of the audit will be presented in a
written report prepared by the auditor to the EPA-ORD Quality Assurance Officer and Task
Order Manager
Cl.1.2 Laboratory Audits
Mr Owen Crankshaw of RTI International will conduct one independent laboratory
quality assurance audit of MVA, REI, and Lab/Cor with oversight by the EPA-ORD QA Officer
Prior to the audit, RTI will prepare a detailed checklist based on the approved QAPP This
checklist will be reviewed and approved by the EPA-ORD QA Officer These audits will be
conducted as soon after the laboratones receive the samples as practical to ensure compliance
with the approved QAPP The auditor will summarize the results of the audit(s) with input from
the EPA-ORD QA Officer in a memorandum to the EQ Project Manager within two weeks of the
audit. The memorandum will clearly spell out any areas in which corrective actions are
necessary If any serious problems are identified that require immediate action, the auditor will
convey these to the EQ Project Manager verbally or through electronic mail on the day that such
problems are identified The laboratory will not analyze any samples until all audit
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November 23, 2005
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recommendations have been resolved and documented in a memorandum to the EQ Project
Manager The EPA-ORD QA Manager will keep the EPA-ORD TOM informed of audit results
and corrective actions.
C1.2 Corrective Action
Sampling and analytical problems may occur dunng sample collection, sample handling
and documentation, sample preparation, laboratory analysis, and data entry and review
Immediate on-the-spot corrective actions will be implemented whenever possible and will be
documented in the project record Implementation of the corrective action will be confirmed in
writing through a memorandum to the EQ Project Manager The EQ Project Manager will then
forward a copy to the EPA Task Order Manager.
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Section C
November 23, 2005
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C2 REPORTS TO MANAGEMENT
Effective communication is an integral part of a quality system Planned reports provide
a structure to inform management of the project schedule, deviations from the approved QAPP,
impact of the deviations, and potential uncertainties in decisions based on the data
The EQ Project Manager will provide verbal progress reports to the EPA Task Order
Manager These reports will include pertinent information from the data processing and report
writing progress reports and corrective action reports, as well as the status of analytical data as
determined from conversations with the laboratory. The EQ Project Manager will promptly
advise the EPA-ORD Task Order Manager on any items that may need corrective action
A written report will be prepared for each field and laboratory audit. The audit reports
will be prepared by the person who conducts the audit These reports will be submitted to the
EPA Task Order Manager with a copy to the EPA ORD Quality Assurance Officer.
The final project report will be prepared in accordance with the guidelines specified in
the EPA Handbook for Preparing ORD Reports, EPA/600K/95/002
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Section D
November 23, 2005
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D DATA VALIDATION AND USABILITY
Dl DATA REVIEW, VERIFICATION, AND VALIDATION
The analytical laboratory will perform m-house analytical data reduction and verification
under the direction of the laboratory's Quality Assurance Manager. The laboratory's Quality
Assurance Manager is responsible for assessing data quality and advising of any data rated as
"unacceptable" or other notations that would caution the data user of possible unreliability. The
analytical results will be compared to the stated data quality indicators for each data quality
objective.
Data verification and data validation will be conducted in accordance with EPA
"Guidance on Environmental Data Verification and Data Validation," EPA QA/G-8
(EPA/240/R-02/004, November 2002 This will be performed by EQ's QA Officer
Data verification is the process of evaluating the completeness, correctness, and
conformance/comphance of a specific data set against the method or QAPP requirements The
goal of data verification is to ensure and document that the data are what they purport to be, that
is, that the reported results reflect what was actually done
Data validation is the analyte- and sample-specific process that extends the evaluation of
the data beyond data verification. Data validation continues with the review of the raw analytical
data and analysis notes The data review will identify any out-of-control data points and data
omissions Based on the extent of the deficiency and its importance in the overall data set, the
laboratory may be required to re-analyze the sample Included in the data validation of a sample
set will be an assessment of chain-of-custody and analyses of field quality control samples
(opened and closed field blanks). Analytical data not appearing to be valid or not meeting data
quality indicators will be flagged and reported to the EQ Project Manager The EQ Project
Manager will then transfer this information to the EPA Task Order Manager
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D2 DATA AND SAMPLE ARCHIVAL
Data and sample storage encompasses an archival of all collected samples, generated
electronic files, and any laboratory notes collected during collection or analysis of samples
Upon completion of the analysis, the respective laboratory will store the remaining portions of
the samples or sample preparations (e g , TEM grids) until such materials are requested to be
shipped to EPA Note No samples or sample preparations will be discarded Following
submission of the final project report, all laboratory and field records/files (paper and electronic)
will be transferred to the EQ Project Manager The EQ Project Manager will then transfer the
complete project file to the EPA-ORD Task Order Manager for permanent retention
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November 23, 2005
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El REFERENCES
1 Bickel, P J, and K A Doksum Mathematical Statistics Basic Ideas and Selected Topics
Hoi den-Day, San Francisco 1977
2 Berman, D W and A J Kolk Draft- Modified Elutnator Method for the Determination
of Asbestos in Soils and Bulk Materials, Revision 1. Submitted to the U S EPA, Region
8 May3, 2000
3 California Environmental Protection Agency Air Resources Board Sampling for
Airborne Naturally Occurring Asbestos at Oak Ridge High School, June 2003. (Report
dated November 6, 2003)
4 Kominsky, J R Environmental Quality Management, Inc Sampling and Analysis Plan
Pre-Demolition Asbestos and Lead Inspection of Buildings 3602, 3603, 3607, and 3606
at Ft Chaffee, Fort Smith, Arkansas Contract No 68-C-00-186/Task Order No 0019
July 16, 2005.
5 Kominsky, J R, R W Freyberg, J M Boiano, et al Performance Evaluation of HEP A-
Filtration Systems at Asbestos-Abatement Sites Contract No 68-03-4006 U S EPA,
September 30,1989
6 Kominsky, J R and R W Freyberg Ambient Airborne Asbestos Levels in Alviso, CA
Report prepared under Contract No 68-CO-0048, Work Assignment 0-65,
Environmental Quality Management, Inc , Cincinnati, OH April 21,1995
7. Smith, B E Environmental Enterprise Group, Inc Asbestos Inspection Report for
Buildings 3602 and 3607 at Fort Chaffee, Arkansas 72917 August 23, 2005
8 Wilmoth, R C , J R Kominsky, J. Boiano, et al Quantitative Evaluation of HEP A
Filiations Systems at Asbestos Abatement Sites The Environ Inform Associa J Vol 2
(1)6-12 1993
9 Wilmoth, R.C , B A. Hollett, J R Kominsky, et al Fugitive Emissions of Asbestos
During Building Demolition and Landfillmg of Demolition Debris Santa Cruz, CA
U S EPA, RREL, Cincinnati, OH October 17, 1990
10 Contaminants of Potential Concern Committee of the World Trade Center Indoor Air
Task Force Working Group World Trade Center Indoor Environment Assessment
Selecting Contaminants of Potential Concern and Setting Health-Based Benchmarks
New York, NY May 2003
11 US EPA AHERA, 40 CFR Part 763, FR Vol 52, No 210, Oct 30, 1987
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APPENDIXA
ALTERNATIVE ASBESTOS CONTROL METHOD
Developed by EPA Region 6 and EPA Office of Research and Development
(ORD)
November 1, 2005 version
Background
In response to Section 112 of the Clean Air Act which requires EPA to develop emission
standards for hazardous air pollutants, EPA promulgated the National Emission Standards for
Hazardous Air Pollutants (NESHAP) 40 CFR Part 61 Subpart M (Asbestos NESHAP)
specifically addresses asbestos, including demolition activities
Asbestos NESHAP regulations require that all regulated asbestos-containing materials
(RACM) above a specified amount be removed from structures prior to demolition Asbestos-
containing materials (ACM) are defined as those materials containing more than one-percent
asbestos as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763,
Section 1, Polarized Light Microscopy (PLM) RACM includes friable ACM, Category I non-
fnable ACM that have become friable, Category I non-friable ACM that will be or has been
subjected to sanding, grinding, cutting, or abrading, and Category II non-friable ACM that have a
high probability of becoming or has become crumbled, pulverized, or reduced to powder by the
forces expected during demolition operations. Asbestos removal can account for a significant
portion of the total demolition costs In many cities, the cost of asbestos removal prohibits
timely demolitions and results in substandard structures which become fire and safety hazards,
attract criminal activity, and lower property values
For structures that are structurally unsound and in imminent danger of collapse, the
Asbestos NESHAP requires that the portion of the structure which contains RACM must be kept
adequately wet during demolition and during handling and loading of debris for transport to a
disposal site No other engineering controls are required.
This Alternative Asbestos Control Method was developed by EPA as an alternative work
practice to the Asbestos NESHAP, where certain RACM are removed prior to demolition and
other RACM are left in place The goal is to provide significant cost savings while achieving an
equal or better standard of protection of human health and the environment This method is
much more restrictive than the Asbestos NESHAP requirements for buildings in imminent
danger of collapse.
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Applicability
This Alternative Asbestos Control Method applies to any structure subject to the
Asbestos NESHAP regulation (i e , structures that meet the definition of facility under the
Asbestos NESHAP), except as noted below
The size of structures which can be demolished using this method is limited to three
stories or less (maximum height of 35 feet) This allows adequate wetting of both the interior
and exterior of the structures and is within the working reach of both the wetting and the
demolition equipment
Building Inspection /Asbestos Assessment
A comprehensive inspection of the interiors and exteriors of structures to be demolished
shall be conducted in accordance with EPA's Asbestos Hazard Emergency Response Act
(AHERA, 40 CFR Part 763) Specific catena for inspection, sampling, and assessment are in
Subpart E (763 85, 763 86, and 763.88, respectively) The inspection shall be performed by an
accredited asbestos building inspector
Asbestos Removal
The table below summarizes the ACM that may be present in buildings and whether or
not the ACM must be removed prior to demolition
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Asbestos-Containing Material
Thermal System Insulation (TSI)
tank insulation
pipe insulation
elbow/fitting/valve insulation
boiler insulation
duct insulation
cement and patching compound
Surfacing Matenal
mastic for flooring
asbestos-impregnated plaster, stucco
spray-applied fireproofing
spray-applied surface coatings (popcorn ceiling,
vermiculite treatments)
spray applied acoustical or decorative surfacing
troweled-on crows foot texture, splatter texture,
and joint compound
spray-applied surface coatings crows foot texture,
splatter texture, etc
window caulking
Miscellaneous Matenal
fire curtains in auditoriums
fire doors
vibration-dampening cloths
asbestos-cement tiles, sheets, roofing shingles, and
transite
asbestos-impregnated roofing cement and asphalt
roofing
shingles
linoleum or other floor tile
roll flooring
ceiling tile
asbestos-impregnated pipe
vermiculite insulation
Removed Prior to
Demolition?
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
No
No
No
No
No
Optional
Optional
No
No
No
No
No
No
No
No
Yes
All TSI and spray-applied fireproofing shall be removed due to the inability to adequately
wet these materials during demolition. Fire curtains may be removed if it is easier to do so than
to adequately wet and handle this heavy material.
Vermiculite insulation, if present, shall be removed pnor to demolition as an RACM,
regardless of the measured asbestos concentration
All asbestos removal operations shall be performed in accordance with state and federal
law by a licensed asbestos abatement contractor.
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Demolition Practices
Several demolition work practice standards shall be employed to ensure that the method
is protective of human health and the environment. These standards involve the equipment used,
the wetting process, the demolition process, and visible emissions Demolition contractors shall
provide an Asbestos NESHAP-tramed individual to oversee the demolition process
Equipment Used
Track hoes and rubber-tired end loaders shall be used during demolition to minimize the
generation of dust No bulldozers, explosives, or burning will be permitted
Wetting Process
Structures to be demolished will be thoroughly and adequately wetted with amended water
(water to which surfactant chemicals have been added) prior to demolition, during demolition,
and dunng debris handling and loading Surfactants reduce the surface tension of the water,
increasing its ability to penetrate the ACM. Amended water will be prepared as a 0 16 percent
solution (one ounce to five gallons) of a 50 50 mixture of polyoxylene ester and polyoxylene
ether, or equivalent, in water as recommended in EPA-560/5-85-024, Guidance for Controlling
Asbestos-Containing Materials in Buildings
For this method, the Asbestos NESHAP definition for "adequately wet" will be used That is,
"sufficiently mix or penetrate with liquid to prevent the release of parti culates If visible
emissions are observed coming from the asbestos-containing material (ACM), then that material
has not been adequately wetted However, the absence of visible emission is not sufficient
evidence of being adequately wet" The demolition contractor's Asbestos NESHAP-tramed
individual will verify that ACM are adequately wetted
Amended water shall be applied with a minimum of two hoses The water shall be delivered as a
mist Direct high-pressure water impact of RACM is prohibited
The wetting process consists of three stages In each stage, both interior and exterior wetting of
the structure shall be performed To the extent feasible, cavity areas and interstitial wall spaces
shall be wetted during each of the wetting stages On the day before the demolition, access
openings shall be made into the attic spaces from the exterior The structure shall be first pre-wet
(until adequately wet) from the interior and then from the constructed exterior attic access
openings to enhance water retention and maximize wetting effectiveness This pre-wetting shall
prohibit further access into the structure, because of safety concerns The structure shall be re-
wet (until adequately wet) from the exterior through the windows, doors, and attic access
openings on the day of demolition prior to demolition Finally, wetting (until adequately wet)
shall be done dunng the demolition and dunng loading of debris into lined disposal containers
Demolition Process
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To prevent dust generation and fiber release, structures shall be demolished so that minimal
breaking of material occurs (only what is necessary to fit into the waste disposal container)
Additional compacting of the ACM in the waste haulers is not allowed All demolition shall be
completed m a timely manner that will allow the debris generated during that day to be
completely removed from the demolition site for disposal.
Visible Emissions
The Asbestos NESHAP standard of "no visible emissions" shall be employed Visible emissions
means any emissions, which are visually detectable without the aid of instruments, coming from
RACM or asbestos-containing material This does not include condensed, uncombmed water
vapor The demolition contractor's NESHAP-tramed individual shall verify the absence of
visible emissions and has the authority to stop work if visible emissions are observed During a
demolition, it is often not possible to distinguish visible emissions from ACM and those from
construction debris, therefore, should a visible emission be observed, the demolition effort shall
pause until the deficiencies in the application of the wetting controls eliminate the visible
emission
Weather Restrictions
Demolition activities shall be delayed/halted in the case of any inclement weather that
will impede the demolition contractor's ability to adequately wet the structure (e g , freezing
temperatures)
In addition, if visible dusting is observed in the vicinity of the demolition site, the
demolition shall be delayed/halted
Monitoring Requirements
Demolition contractors are required to comply with all applicable OSHA (29 CFR 1926)
regulations for worker protection dunng asbestos removal and demolition activities This
includes the use of personal protective equipment (PPE) such as Tyvek suits or equivalent,
respirators (as necessary), and gloves (as necessary), and personal monitoring
Because, like the Asbestos NESHAP, this method is designed to be a work practice
standard, monitoring of air (other than that mandated by OSHA statute), soil, and other media is
not required
Waste Handling
Several wastes are generated during demolition activities, including demolition debns,
disposable PPE, and potentially contaminated water and soil, and must be properly disposed All
wastes generated must be removed from the site at the end of the day and transported to an
appropriate disposal facility Transport and disposal shall be in accordance with all federal,
state, and local requirements All waste haulers shall be leak-proof Double-lining of the haulers
with 4-rml or thicker polyethylene film and then sealing the top seams of the film is a suggested
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mechanism, but the contractor must do what is required to prevent leaks from the transport
vehicles Vehicles shall be decontaminated within the bermed area before leaving the demolition
area
Demolition Debris
Segregation of portions of a structure that may contain RACM from portions of a structure that
clearly do not contain RACM shall be done when practical in an effort to minimize RACM
debris For example, segregation may be used if a large warehouse is being demolished and only
a small portion (e g , office space) contains RACM
When segregation is not practical, all demolition debns shall be disposed as RACM in a licensed
asbestos disposal facility Debris shall be kept adequately wet during loading into containers.
Containers shall be covered during transport
PPE
All disposable PPE shall be disposed as RACM
Potentially Contaminated Water and Impervious Surfaces
No potentially contaminated water runoff is permitted from the site during the demolition period.
All impervious surfaces will be thoroughly washed with amended water before site closure
Construction site best management practices shall be used to prevent water runoff Drains and
sewer connections must be capped or plugged prior to wetting Berms must be created as
necessary to prevent runoff of water from the demolition site The berm must be sufficiently
spaced from the building to permit the movement of the demolition equipment and to allow the
truck loading to occur within the enclosed space If large water volume use or impermeable
conditions surrounding the building create excessive water volume and simple containment and
percolation is not feasible, the water must be pumped and either disposed as ACM or filtered
through a series of filters ultimately removing all fibers equal to or larger than five microns
before discharge to the neighboring environment
Potentially Contaminated Soil
Following the removal of demolition debns, bare soil within the bermed area shall be excavated
to a minimum depth of two inches or until no debns is found Berms created shall also be
removed and disposed as potentially asbestos-contaminated. All removed soil shall be disposed
as RACM
Site Closure
Following demolition and waste disposal, all waste and debris must be gone from the site
and the site must be secured so as not to create a safety hazard
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