EPA/600/R-08/094
October 2008
Revised December 2009
Comparison of the Alternative Asbestos Control Method and the NESHAP
Method for Demolition of Asbestos-Containing Buildings
Notice
In 2006 and 2007 the Environmental Protection Agency (EPA) conducted three tests to
examine the cost and environmental effectiveness of Alternative Asbestos Control
Method (AACM). Two tests were conducted in Fort Chafee, Arkansas and one was
conducted in Forth Worth, Texas. The EPA discontinued testing the AACM due to
technical deficiencies. The AACM remains unapproved and should not be used.
By
Roger C. Wilmoth l, Lauren M. Drees l, John R. Kominsky 3, Glenn M. Shaul l,
David Cox4, David B. Eppler 2, William M. Barrett1, Fred D. Hall3, and Julie A. Wagner3
Environmental Protection Agency
National Risk Management Research Laboratory
Cincinnati, OH 45268
2US Environmental Protection Agency
Region 6
Dallas, TX 75202
3Environmental Quality Management, Inc.
1800 Carillon Boulevard
Cincinnati, OH 45240
4QuanTech, Inc.
Arlington, VA
January 25, 2008
Contract No. 68-C-00-186
Task Order No. 0019
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Foreword
The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the
Nation's land, air, and water resources. Under a mandate of national environmental laws, the
Agency strives to formulate and implement actions leading to a compatible balance between
human activities and the ability of natural systems to support and nurture life. To meet this
mandate, EPA's research program is providing data and technical support for solving
environmental problems today and building a science knowledge base necessary to manage our
ecological resources wisely, understand how pollutants affect our health, and prevent or reduce
environmental risks in the future.
The National Risk Management Research Laboratory (NRMRL) is the Agency's center for
investigation of technological and management approaches for preventing and reducing risks
from pollution that threaten human health and the environment. The focus of the Laboratory's
research program is on methods and their cost-effectiveness for prevention and control of
pollution to air, land, water, and subsurface resources; protection of water quality in public water
systems; remediation of contaminated sites, sediments and ground water; prevention and control
of indoor air pollution; and restoration of ecosystems. NRMRL collaborates with both public and
private sector partners to foster technologies that reduce the cost of compliance and to anticipate
emerging problems. NRMRL's research provides solutions to environmental problems by:
developing and promoting technologies that protect and improve the environment; advancing
scientific and engineering information to support regulatory and policy decisions; and providing
the technical support and information transfer to ensure implementation of environmental
regulations and strategies at the national, state, and community levels.
This publication has been produced as part of the Laboratory's strategic long-term research plan.
It is published and made available by EPA's Office of Research and Development to assist the
user community and to link researchers with their clients.
Sally Gutierrez, Director
National Risk Management Research Laboratory
Office of Research and Development
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Notices
Erratum: This report has been revised to correct the asbestos level used for occupancy of
residential structures surrounding the World Trade Center. The correct value is 0.0009 s/cm^,
not the value of 0.009 s/cm^ cited in the previous version of this report.
Mention of trade names, products, or services does not convey, and should not be interpreted as
conveying, official EPA approval, endorsement, or recommendation.
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CONTENTS
Section Page
LIST OF TABLES ix
LIST OF FIGURES xiii
EXECUTIVE SUMMARY xv
ACKNOWLEDGMENT xix
ABBREVIATIONS AND ACRONYMS xxi
SECTION 1 INTRODUCTION 1
SECTION 2 PROJECT OBJECTIVES 11
2.1 Primary Objectives 11
2.2 Secondary Objectives 11
2.2.1 Air 11
2.2.2 Dust 12
2.2.3 Worker 12
2.2.4 Activity 12
2.2.5 Soil 12
2.2.6 Water 13
2.2.7 Landfill 13
2.2.8 Time 13
2.2.9 Modeling 14
SECTIONS SITE INFORMATION 15
3.1 Site Selection 15
3.2 Site Description 15
3.3 Pre-Demolition Inspection of Buildings 20
3.3.1 Asbestos Inspection of Buildings 20
3.3.2 Lead Paint Inspection of Buildings 23
3.3.3 Concentrations of Asbestos in Soil 24
3.3.4 Concentrations of Asbestos in Source Water 25
3.3.5 Background Air Sampling 25
SECTION 4 STUDY DESIGN AND IMPLEMENTATION 27
4.1 Sampling Strategy 27
4.1.1 Meteorological Monitoring 28
4.1.2 Weather Restrictions 28
4.1.3 Demolition Site Sampling 28
4.1.3.1 Background Air Monitoring 28
4.1.3.2 Perimeter Air Asbestos, Total Fibers, Settled Dust, and Particulate Sampling
During Demolition 29
4.1.3.3 Work Area Sampling 33
4.1.3.3.1 Discharge Air Sampling During Asbestos Abatement of NESHAP
Building 33
4.1.3.3.2 Personal Breathing Zone Sampling During Abatement 33
4.1.3.3.3 Personal Breathing Zone Sampling During Demolition 33
4.1.3.3.4 Personal Breathing Zone Activity Sampling 34
4.1.3.4 Soil Sampling 34
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4.1.4 Water for Wetting Structure and Demolition Debris 34
4.1.4.1 Source Water 34
4.1.4.2 Amended Water 35
4.1.4.3 Surface Water from Demolition 35
4.1.5 Landfill 35
4.1.5.1 Background Air Sampling at Landfill 35
4.1.5.2 Air Sampling During Landfilling of NESHAP Drummed ACM 35
4.1.5.3 Work Area Sampling during Landfilling of Demolition Debris 36
4.1.5.4 Perimeter Air Asbestos and Total Fiber Sampling During Landfilling of
Demolition Debris 36
4.2 Abatement of the NESHAP Building 36
4.3 Site Preparation 40
4.3.1 Surface Water Control 40
4.3.2 Sampling Network 42
4.3.3 Cross-contamination control 45
4.4 Planned demolition and disposal of buildings 45
4.4.1 NESHAP demolition and disposal 46
4.4.2 AACM demolition and disposal 49
4.4.2.1 Amended Water System 49
4.4.2.2 AACM Pre-Wetting 52
4.4.2.3 AACM Demolition Phase 52
SECTIONS SAMPLING AND ANALYTICAL METHODOLOGY 63
5.1 Sampling Method Requirements 63
5.1.1 Perimeter Air Sampling for Asbestos/Total Fibers 63
5.1.2 Personal Breathing Zone and Work Area Sampling for Asbestos/Total Fibers and
Lead 63
5.1.3 Total Particulate Sampling 64
5.1.4 Meteorological Monitoring 64
5.1.5 Asbestos Soil Sampling 64
5.1.6 Settled Dust Sampling 65
5.1.7 Water Sampling—Flush Hydrant, Amended Water, and Pooled Surface Water..65
5.2 Analytical Methods 66
5.2.1 Air Samples (TEM) 66
5.2.1.1 TEM Specimen Preparation 67
5.2.1.2 Measurement Strategy 67
5.2.1.3 Determination of Stopping Point 69
5.2.2 Air Samples (PCM) 70
5.2.3 Air Samples (Lead) 70
5.2.4 Soil Samples 70
5.2.4.1 Soil Preparation 70
5.2.4.2 Soil Analysis (TEM and PLM) 71
5.2.4.3 Elutriation 72
5.2.5 Settled Dust Samples (TEM) 72
5.2.6 Water Samples 72
SECTION 6 RESULTS 73
6.1 Demolitions 74
6.1.1 Meteorology 74
6.1.2 Perimeter Air 77
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6.1.2.1 Asbestos in Air Samples 77
6.1.2.1.1 Background Air 77
6.1.2.1.2 Demolition Air 78
6.1.2.2 Asbestos in Settled Dust 81
6.1.2.2.1 Total Fibers in Air Samples 83
6.1.2.2.1.1 Background Air 83
6.1.2.2.2 Demolition Air 84
6.1.2.3 Total Particulate in Air Samples 85
6.1.3 Water 86
6.1.4 Soil 90
6.1.4.1 Moisture 90
6.1.4.2 Total Asbestos 90
6.1.4.2.1 Soil Fraction 90
6.1.4.2.2 Rocks/Organics Fraction 94
6.1.4.2.3 Building Debris Fraction 94
6.1.4.3 Soil Elutriation 96
6.1 A A Visible Emissions 98
6.1.5 Workers 98
6.1.5.1 Asbestos (TEM) and Fibers (PCM) 98
6.1.5.1.1 Demolition and Abatement Workers 98
6.1.5.1.2 Walkers 100
6.1.5.1.3 Worker Summary 101
6.1.5.2 Lead (Pb) 102
6.2 Results From Landfilling Demolition Debris 102
6.2.1 Meteorology 102
6.2.2 Perimeter Air 103
6.2.3 Workers 104
6.2.3.1 Asbestos and Total Fibers 104
6.2.3.2 Lead (Pb) 105
SECTION 7 STATISTICAL ANALYSES 107
7.1 Primary Objective 1 107
7.1.1 Day 1 NESHAP vs. Day 1 and 2 AACM 107
7.1.2 Day 1 Comparisons: AACM versus NESHAP 110
7.2 Primary Objective 2 112
7.3 Secondary Obj ective 2 114
7.4 Secondary Objectives 4 and 5 118
7.5 Secondary Obj ective 6 121
7.6 Secondary Obj ective 7 122
7.7 Secondary Obj ective 8 123
7.8 Secondary Objective 9 125
7.9 Secondary Objectives 11, 12, and 13 126
7.10 Secondary Objectives 14, 15, 16, and 17 128
7.11 Secondary Objectives 20, 21, and 22 129
7.12 Additional Secondary Objective 129
7.13 Summary of Statistical Conclusions 131
SECTION 8 COST COMPARISON OF DEMOLITION OF NESHAP AND AACM
BUILDINGS 135
8.1 Methodology 135
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8.2 Cost Items 137
8.2.1 Pre-Demolition Asbestos Compliance Inspection 137
8.2.2 NESHAP Abatement 137
8.2.2.1 Abatement Specification 137
8.2.2.2 Asbestos Abatement 137
8.2.2.3 Abatement Oversight and Monitoring 138
8.2.3 OSHA Compliance Monitoring 138
8.2.4 Site Mobilization and Demobilization 138
8.2.5 Demolition 138
8.2.6 Water and Amended Water Surfactant 139
8.2.7 Demolition Debris Transportation and Disposal (asbestos and non-asbestos)... 139
8.2.7.1 Trucking Costs 139
8.2.7.2 Lining the Trucks 139
8.2.7.3 Cost of Disposal 140
8.2.7.3.1 NESHAP Building 140
8.2.7.3.2 AACM Building 140
8.3 Summary 141
8.4 Applicability of Costs for Different Sites 142
SECTION 9 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) RESULTS 143
9.1 QAPP Development 143
9.2 Audits 143
9.2.1 Field Audit 143
9.2.2 Laboratory Audit for Air Samples 144
9.2.3 Laboratory Audit for Soil Samples 146
9.3 Asbestos QA/QC Sample Results 149
9.3.1 Air QA/QC Results 149
9.3.1.1 Lot Blanks 150
9.3.1.2 Field Blanks 150
9.3.1.3 Field Duplicates 150
9.3.1.4 Method Blanks 150
9.3.1.5 Replicates 151
9.3.1.6 Duplicates 152
9.3.1.7 Verified Counts 153
9.3.1.8 Interlaboratory QA/QC 153
9.3.2 Soil QA/QC Results 155
9.3.2.1 Method Blanks 155
9.3.2.2 Replicates 156
9.3.2.3 Duplicates 156
9.3.2.4 Spiked Samples 157
9.3.2.5 Interlaboratory QA/QC 157
9.3.3 Elutriation QA/QC 158
9.3.3.1 Replicates 158
9.3.3.2 Duplicates 158
9.3.3.3 Elutriation Spikes 159
9.3.4 Settled Dust QA/QC 159
9.3.4.1 Field Blanks 159
9.3.4.2 Field Duplicates 159
9.3.4.3 Method Blanks 160
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9.3.4.4 Replicates 160
9.3.4.5 Duplicates 161
9.3.5 Water QA/QC Results 161
9.3.5.1 Field Blank 161
9.3.5.2 Field Duplicate 161
9.3.5.3 Method Blank 162
9.3.5.4 Replicates 162
9.3.5.5 Duplicates 162
9.4 QA/QC Summary 162
SECTION 10 CONCLUSIONS 163
SECTION 11 LESSONS LEARNED 167
SECTION 12 REFERENCES 169
APPENDIX A - DATA LISTINGS 173
APPENDIX B - KIDDE MSDS 195
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LIST OF TABLES
Number Page
Table ES-0-1. Simplified Comparison of Results for the NESHAP and AACM Demolitions at
Fort Chaffee xviii
Table 3-1. Asbestos Content of Building Materials 22
Table 3-2. ACM Present in the NESHAP Method and AACM Buildings 23
Table 3-3. Lead in Paint Chip Samples from Interior and Exterior Building Components 24
Table 3-4. Asbestos in Soil (PLM) and Gravimetric Reduction (GR/TEM) 24
Table 4-1. Summary of Field samples (excluding quality control samples) Collected for
Asbestos Analysis by TEM 27
Table 4-2. Summary of Personal Breathing Zone Samples Collected for Lead 28
Table 4-3. Summary of Ring 1 Air Samples Collected for Total Particulate 28
Table 4-4. Summary of NF-3000 Quality Monitoring During AACM Demolition Activities....51
Table 5-1. Number of TEM grid openings to achieve target analytical sensitivity 68
Table 5-2. Stopping rules for asbestos counting 69
Table 6-1. ISO 10312:1995 Reporting Convention for Structure Counts Between Zero and Four
74
Table 6-2. Descriptive Statistics for Wind Speed 77
Table 6-3. Airborne asbestos (TEM) during demolition of NESHAP and AACM buildings 79
Table 6-4. Asbestos (TEM) in settled dust during demolition of NESHAP and AACM buildings.
81
Table 6-5. Background total fibers (PCM) prior to demolition of NESHAP and AACM
buildings 83
Table 6-6. Airborne total fibers (PCM) during demolition of NESHAP and AACM buildings. .84
Table 6-7. Airborne total particulate during demolition of NESHAP and AACM buildings 85
Table 6-8. Summary of source (hydrant) water usage during the NESHAP and AACM building
demolition 86
Table 6-9. Asbestos (TEM) in water from the NESHAP and AACM building demolitions 88
Table 6-10. Soil Moisture Content 90
Table 6-11. Asbestos (PLM and TEM) results in soil fraction 91
Table 6-12. Asbestos Content in the Building Debris Fraction of the Soil 94
Table 6-13. Weight of Vinyl Asbestos Tile (VAT) fragments in the soil samples 95
Table 6-14. Elutriation air samples (TEM) from soil collected before and after demolition 97
Table 6-15. Personal breathing zone concentrations of asbestos (TEM) and total fibers (PCM)
during demolition of the NESHAP and AACM buildings 99
Table 6-16. Concentrations of asbestos (TEM) and total fibers (PCM) during abatement of the
NESHAP building 99
Table 6-17. Background air levels of asbestos (TEM) and total fibers (PCM) prior to landfill of
demolition debris from NESHAP and AACM buildings 103
Table 6-18. Airborne asbestos (TEM) and Total Fibers (PCM) during landfilling of NESHAP
and AACM buildings demolition debris 104
Table 6-19. Personal breathing zone concentrations of asbestos (TEM) and total fibers (PCM)
during landfilling of demolition debris from NESHAP and AACM buildings 104
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Table 7-1. Airborne Asbestos Concentrations (s/cm3) for Total Asbestos (TEM) and PCME
(TEM) Structures for the AACM (Days 1 and 2 Combined) and NESHAP Method and Ranks for
the Wilcoxon Rank-Sum Test 108
Table 7-2. Airborne Asbestos Concentrations (s/cm3) for Total Asbestos (TEM) for the AACM
and NESHAP Method by Day Ill
Table 7-3. Asbestos in Soil (s/g) by TEM by the AACM and NESHAP Method / Ranks for the
Wilcoxon Rank-Sum Test (NESHAP POST vs. AACM POST-EXCAV) 112
Table 7-4. Descriptive Statistics for the AACM (POST-EXCAVATION) and NESHAP (POST-
DEMOLITION) Structure Counts 114
Table 7-5. Total Fiber Concentrations by PCM (f/cm3) for the AACM and NESHAP Method by
Day 115
Table 7-6. Median Adjusted Total Fiber Concentrations by PCM (f/cm3) for the AACM and
NESHAP / Ranks for the Wilcoxon Rank-Sum Test 116
Table 7-7. Total Airborne Asbestos Concentrations (TEM) and Percent of Time Downwind, for
AACM (Days 1 and 2 Combined) and NESHAP Method 119
Table 7-8. Asbestos Loadings (TEM) in Settled Dust (s/cm2) in the Inner Ring 121
Table 7-9. Descriptive Statistics for Asbestos Loadings in the Settled Dust (s/cm2) in the Inner
Ring for the AACM and NESHAP Method (Sample Size= 18) 122
Table 7-10. Total Particulate Concentrations (mg/m3) for the AACM and NESHAP Method
Methods / Ranks for the Wilcoxon Rank-Sum Test 123
Table 7-11. Total Fibers (f/cm3 by PCM) on Worker Personal Monitors Measured at NESHAP
and AACM Buildings during Demolition and Removal of Debris 124
Table 7-12. Total Asbestos (s/cm3 by TEM) on Worker Personal Monitors Measured at NESHAP
and AACM Buildings During Abatement, Building Demolition, and Removal of Debris 125
Table 7-13. Degree of Censoring for Secondary Objectives 11, 12, and 13 126
Table 7-14. Asbestos Structure Counts in Soil (s/g) by TEM by the AACM and NESHAP
Methods / Ranks for the Wilcoxon Rank-Sum Tests 127
Table 7-15. Asbestos in Soil (s/g) by TEM by the AACM and NESHAP Method 127
Table 7-16. Asbestos Soil Concentrations (TEM) from Elutriator Tests 128
Table 7-17. Percent by Weight of Asbestos-Containing Material (ACM) in Soil Samples for the
NESHAP Method and AACM 130
Table 8-1. Cost comparison of NESHAP and AACM Building Demolitions at Fort Chaffee, AR.
141
Table 9-1. Summary of Audit Observations, Recommendations, and Resolution 145
Table 9-2. Total Air QA/QC Samples 150
Table 9-3. Field Duplicates for Air Samples 151
Table 9-4. Replicates for Air Samples 152
Table 9-5. Duplicates for Air Samples 152
Table 9-6. Verified Counts for Air Samples 153
Table 9-7. Intel-laboratory Verified Counts 154
Table 9-8. Interlaboratory Duplicates for Air Samples 155
Table 9-9. Number of Soil QA/QC Samples 155
Table 9-10. Replicates for Soil Samples 156
Table 9-11. Duplicates for Soil Samples 156
Table 9-12. Spikes for Soil Samples 157
Table 9-13. Interlaboratory Duplicates for Soil Samples 157
Table 9-14. Replicates for Elutriation Samples 158
Table 9-15. Duplicates for Elutriation Samples 158
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Table 9-16. Spikes for Elutriation Samples 159
Table 9-17. Field Duplicates for Settled Dust Samples 160
Table 9-18. Replicates for Settled Dust Samples 160
Table 9-19. Duplicates for Settled Dust Samples 161
Table 9-20. Field Duplicate for Water Samples 161
Table 9-21. Replicate for Water Samples 162
Table 9-22. Duplicate for Water Samples 162
Table 10-1. Summary Comparison of the Results of the NESHAP and AACM Demolitions at
FortChaffee 166
Table A-1. Laboratory Data: Sample Key 174
Table A-2 NESHAP Building - Airborne Asbestos and Total Fibers in Rings 1 and 2 175
Table A-3. AACM Building - Airborne Asbestos and Total Fibers in Rings 1 and 2 177
Table A-4. Background Levels of Airborne Asbestos and Total Fibers - Ring 1 at NESHAP and
AACM Buildings, and Landfill 181
Table A-5. Levels of Airborne Asbestos and Total Fibers at Ring 1 - During Landfill of
Demolition Debris from NESHAP and AACM Buildings 182
Table A-6. NESHAP and AACM Buildings - Asbestos in Water 183
Table A-7. Asbestos in Settled Dust in Rings 1 and 2 of NESHAP and AACM Buildings 184
Table A-8. NESHAP and AACM Buildings - Airborne Total Particulate in Ring 1 187
Table A-9. Worker breathing zone samples for airborne asbestos and total fibers during
demolition of NESHAP and AACM Buildings and landfill of debris 188
Table A-10. Asbestos and total fibers measured on workers during abatement of NESHAP
Building and landfill of debris 189
Table A-ll. Soil - Modified Vertical Elutriator Method 190
Table A-12. Asbestos in Soil (PLM and TEM) by Fraction 191
Table A-13. Weight of Vinyl Asbestos Tile Fragments and other ACM in Soil Samples 193
XI
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LIST OF FIGURES
Number Page
Figure 3-1. Project location at Fort Chaffee. Buildings selected for demolition are #3602
(NESHAP Method) and #3607 (AACM) 16
Figure 3-2. (Top) Exterior view of Building #3602 (NESHAP Method) and (Bottom) #3607
(AACM). Dimensions: 30-feetby 150-feet 17
Figure 3-3. Interior view of Building #3602 (NESHAP). Interior finishes are gypsum wallboard
(ceiling and walls) and nine-by-nine-inch resilient floor tile 18
Figure 3-4. Interior view of Building #3607 (AACM). Interior finishes are gypsum wallboard
(ceiling and walls) and nine-by-nine-inch resilient floor tile 19
Figure 3-5. Section of %-inch gypsum wallboard showing a multi-layered joint interval.
Wallboard was obtained from Building #3 607 (AACM) 21
Figure 4-1. Location of Ring 1 and 2 samplers around the NESHAP Method building 31
Figure 4-2. Location of soil sampling grid around the NESHAP building 32
Figure 4-3. Wetting and removal of drywall during abatement of NESHAP building 37
Figure 4-4. Loading abated material into barrels 38
Figure 4-5. Loading asbestos-containing material into roll-off container 38
Figure 4-6. Abated area after application of encapsulant 39
Figure 4-7. Abated area after final clearance 39
Figure 4-8. Covering abatement debris at the landfill 40
Figure 4-9. Pooled surface water collection sump 41
Figure 4-10. Water accumulation near the berm during the AACM demolition 41
Figure 4-11. Water filtration system and holding tank 42
Figure 4-12. Sampling stations at Ring 1 and Ring 2 43
Figure 4-13. The five-ft high sampling array on the inner ring (Ring One) 43
Figure 4-14. Red band denotes NESHAP building; a green band seen in other photos denotes
AACM building. Rl denotes Ring 1 and Ml monitoring Location 1. Two pumps support filters
at five-ft height and one at 15-ft height. Samplers were numbered in clockwise order, with
sample #1 located at front (north) right (west) side of building. The same nomenclature applied
to Ring 2, but with samplers only at five-ft height 44
Figure 4-15. Pre-calibrated rotameters with sight gauges set at two and four liter/min 44
Figure 4-16. Preparation of site prior to demolition of NESHAP Method building (left) 45
Figure 4-17. Starting demolition of the NESHAP building 47
Figure 4-18. Loading NESHAP debris into trucks 47
Figure 4-19. Finishing NESHAP demolition 48
Figure 4-20. Aerial view showing NESHAP building nearly demolished 48
Figure 4-21. Wetting agent supply tank for the AACM demolition 49
Figure 4-22. Calibration Curve for the NF-3000 Wetting Agent 51
Figure 4-23. Pre-wetting with Amended Water 53
Figure 4-24. Pre-wetting the hallway with Amended Water 53
Figure 4-25. Pre-wetting the attic with Amended Water 54
Figure 4-26. Amended Water seeping through ceiling drywall joints 54
Figure 4-27. Amended Water seeping through wall openings 55
Figure 4-28. Wetting through openings on the day of the AACM demolition 55
Figure 4-29. Double-lining the trucks for hauling of the AACM debris (View 1) 57
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Figure 4-30. Double-lining the trucks for hauling of the AACM debris (View 2) 57
Figure 4-31. Starting the AACM demolition 58
Figure 4-32. Progressing with the AACM demolition 58
Figure 4-33. Loading the AACM demolition debris 59
Figure 4-34. Sealing the -burrito wrap" before leaving the AACM site 59
Figure 4-35. Washing the trucks with water before leaving the site 60
Figure 4-36. Nearing the completion of the AACM demolition 60
Figure 4-37. An aerial view nearing completion of the AACM demolition 61
Figure 5-1. Soil sampling after the NESHAP demolition 65
Figure 5-2. Sampling pooled water 66
Figure 6-1. Rainfall history at the Fort Chaffee project site during the study 75
Figure 6-2. Wind rose during the hours of the NESHAP building demolition 76
Figure 6-3. Wind rose during the hours of the AACM building demolition 76
Figure 6-4. Wind rose during the hours of the AACM building soil removal 77
Figure 6-5. Airborne asbestos (TEM) during demolition of buildings 80
Figure 6-6. Asbestos (TEM) loading in settled dust resulting from the demolitions 83
Figure 6-7. Rainfall, Water Application, and Activity History During Demolition Study Period
87
Figure 6-8. Asbestos in water samples 89
Figure 6-9. Asbestos structures longer than ten microns in water samples 89
Figure 6-10. Soil asbestos concentrations by PLM for both building demolitions 92
Figure 6-11. Soil asbestos concentrations by TEM for both demolitions 93
Figure 6-12. Mean soil asbestos concentrations (TEM) 93
Figure 6-13. Weight fraction of soils that were VAT and ACM building debris 96
Figure 6-14. Soil elutriation air concentrations of asbestos (TEM) 97
Figure 6-15. Abatement worker personal breathing zone concentrations of asbestos and total
fibers 100
Figure 6-16. Worker breathing zone asbestos (TEM) data from the NESHAP and AACM
demolition processes 101
Figure 6-17. Landfill wind rose during the NESHAP debris disposal 102
Figure 6-18. Landfill wind rose during the AACM debris disposal 103
Figure 7-1. Box plots for the Background Total Fiber Concentrations by PCM (f/cm3) for the
AACM and NESHAP Method 117
Figure 7-2. Box plots for the Background Total Fiber Concentrations by PCM (f/cm3) Adjusted
for Background AACM and NESHAP Methods by Day 118
Figure 7-3. NESHAP Total Airborne Asbestos Concentrations (TEM) by Percent of Time
Downwind. (Filled Circles = Detect Values; Unfilled Circles = Non-detect Values) 120
Figure 7-4. AACM Total Airborne Asbestos Concentrations (TEM) (Days 1 and 2 Combined)
by Percent of Time Downwind. (Filled Circles = Detect Values; Unfilled Circles = Non-detect
Values) 120
Figure 7-5. Empirical Cumulative Distributions for the Asbestos Loadings in the Settled Dust
(s/cm2) in the Inner Ring for the AACM and NESHAP Method 122
Figure 7-6. Box plots for Total Fibers (f/cm3 by PCM) on Worker Personal Monitors during
Demolition and Removal of Debris 124
Figure 7-7. Box plots for Percent by Weight of Asbestos-Containing Material (ACM) in Soil
Samples for the NESHAP Method and AACM 130
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EXECUTIVE SUMMARY
The Asbestos NESHAP (National Emission Standard for Hazardous Air Pollutants) requires the
removal of all Regulated Asbestos-Containing Material (RACM) prior to the demolition of the
buildings that fall under the auspices of the NESHAP. This removal process can be a costly and
time-consuming endeavor and contributes to the growing crises of abandoned buildings in this
country. The Alternative Asbestos Control Method (AACM) allows certain asbestos-containing
materials (ACM) to remain in the building during demolition. In addition to leaving most of the
ACM in the building, the AACM process differs from the NESHAP process in that it requires
pre-wetting of the interior of the building with amended water (water with a wetting agent
added), continuous wetting with amended water during demolition of the building, containment
of all runoff, removal of two or more inches of soil after demolition, disposal of all material as
regulated asbestos-containing waste, and the use of respirators and protective garments
throughout the entire demolition process.
This research effort compared the use of the NESHAP process with the AACM process on two
architecturally identical asbestos-containing buildings in a remote location at the Fort Chaffee
Redevelopment Authority near Fort Smith, AR. The buildings contained significant quantities of
asbestos-containing wall systems and vinyl asbestos floor tile.
EPA does not endorse the AACM at this time as an approved method under the asbestos
NESHAP for demolishing buildings containing RACM.
Conclusions
The following conclusions are relevant to the demolitions of the identical structures at Fort
Chaffee Redevelopment Authority:
Primary Objectives
* The airborne asbestos concentrations measured by transmission electron microscopy
(TEM) during both the NESHAP and the AACM demolition processes were orders of
magnitude below any EPA existing health or performance criterion. At an analytical
sensitivity of 0.0005 asbestos structures per cubic centimeter of air (s/cm3), the
maximum asbestos air concentration was 0.0005 s/cm3 (one structure observed) for the
NESHAP process and 0.0019 s/cm3 (four structures observed) for the AACM process.
* The airborne asbestos (TEM) concentrations were near or below the limit of detection.
The statistical analyses for the demolition phase of both processes showed that the
airborne asbestos (TEM) concentrations from the AACM were equal to the NESHAP
(based upon the observed proportion of detects). The statistical analyses comparing both
total processes (including the soil removal phase of the AACM) showed that the airborne
asbestos (TEM) concentrations from the AACM were not equal to the airborne asbestos
(TEM) concentrations from the NESHAP Method (p=0.0006, where p represents a
strength of evidence that the null hypothesis is true. The smaller the p-value, the stronger
the evidence is that the null hypothesis should be rejected. In this study, the null
xv
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hypothesis was rejected for p values less than 0.05.). The empirical evidence (the
proportion of non-detects and the maximum values) from the investigation suggests
airborne asbestos (TEM) concentrations from the AACM were greater than the airborne
asbestos (TEM) concentrations from the NESHAP Method. Based upon the observed
proportion of detects, it was concluded that the difference between the two methods is a
function of the Day 2 AACM activities (soil excavation and removal). This was likely
due to an operational error where no water was added during the soil removal stage of the
process.
• The statistical analyses showed that the post-excavation asbestos TEM concentrations in
the soil from the AACM were not equal to the post-demolition asbestos concentrations in
the soil from the NESHAP Method (p=0.033). Based on descriptive statistics, it was
concluded that the post-excavation asbestos concentrations in the soil from the AACM
were less than the post-demolition asbestos concentrations in the soil from the NESHAP
Method. Polarized Light Microscopy (PLM) analyses for all soil samples from both
processes indicated very low concentrations of asbestos; the NESHAP post-demolition
soil had only one often samples with detectable asbestos (0.3 percent) whereas the
AACM post-excavation soil had no samples with detectable asbestos at an analytical
sensitivity of 0.1 percent.
• The cost of the NESHAP demolition process ($108,331) was approximately twice the
cost of the AACM demolition process ($57,864) for this site. Costs specific to conducting
the research were not included.
Secondary Objectives
• Based upon descriptive statistics, the fiber concentrations in air from the AACM as
measured by phase contrast microscopy (PCM) were equal to the fiber concentrations
from the NESHAP Method.
• A brief visible emission was observed during the removal of a concrete foundation
structure during the NESHAP demolition, but it was not an asbestos-containing material.
No visible emissions were observed during the AACM demolition.
* Settled dust asbestos loadings during the AACM demolition were equal to the settled dust
loadings during the NESHAP demolition.
* The statistical analyses showed that the total particulate concentrations, as collected and
measured by National Institute of Occupational Safety and Health's (NIOSH) Method
0500, from the AACM were not equal to the total particulate concentrations from the
NESHAP Method. Based on the observed proportion of detects, the total particulate
concentrations from the AACM were higher than the total particulate concentrations from
the NESHAP Method. This is attributed the extended sampling period for the AACM
process, which included soil removal and disposal. Since wetting was inadvertently not
performed during the soil removal, it is possible that this increased the particulate
loading.
xvi
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* Based on the observed proportion of non-detects, the worker breathing zone asbestos
concentrations (TEM) from the AACM were less than the worker breathing zone asbestos
concentrations (TEM) from the NESHAP method. This was due to the concentrations
encountered by workers during the abatement required by the NESHAP. The maximum
breathing zone asbestos concentration was 0.093 s/cm3 for the NESHAP process
(abatement phase) whereas no asbestos was detected on any of the AACM worker
breathing zone samples (<0.005 s/cm3).
• One NESHAP worker had an Eight-Hour Time-Weighted Average (TWA) fiber (PCM)
concentration which equaled the Occupational Safety and Health Administration (OSHA)
PEL (Personal Exposure Limit) of 0.1 f/cm3. The maximum TWA fiber concentration for
the AACM was 0.03 f/cm3.
• Based on descriptive statistics, the NESHAP post-demolition soil asbestos (TEM)
concentrations were greater than the NESHAP pre-demolition soil concentrations; the
AACM pre-demolition soil asbestos (TEM) concentrations wee greater than the post-
excavation soil concentrations; and the AACM post-demolition soil asbestos (TEM)
concentrations were greater than the AACM post-excavation soil concentrations.
• The time required to perform the AACM process (l!/2 days) was about one-fifth the time
required to perform the NESHAP process (ten days) for this site. The abatement phase of
the NESHAP process was very labor intensive (nine days) and took nine times longer
than the demolition itself (one day) for this site.
• Both the NESHAP and the AACM processes left minimal amounts of small fragments of
asbestos-containing material (ACM) debris, primarily vinyl asbestos floor tile, in the soil
at the completion of the processes; however, the AACM process (post-excavation) left
less ACM debris than the NESHAP process (post-demolition).
Results for other secondary objectives of lesser significance are found in the body of the report.
A simplified comparison of results is presented in Table ES-0-1.
xvn
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Table ES-0-1. Simplified Comparison of Results for the NESHAP
and AACM Demolitions at Fort Chaffee
PARAMETER
Asbestos (TEM) in
Air
(Demolition Only)
Asbestos (TEM) in
Air- (Demolition
and Soil Removal)
Asbestos (TEM) in
Soil
Asbestos (PLM) in
Soil
Cost
Visible Emissions
Fibers (PCM) in
Air
Asbestos in Settled
Dust (TEM)
Asbestos (TEM) in
Worker Breathing
Zone
Fibers (PCM) in
Worker Breathing
Zone
Particulate in Air
Time
Asbestos (PLM)
Debris in Soil
REPORT
SECTION
REFERENCE
6.1.2.1
6.1.2.1
6.1.4
6.1.4
8
4.4.1
4.4.2
6.1.2.3
6.1.2.2
6.1.5
6.1.5
6.1.2.4
4.2
4.4.1-4.4.2
6.1.4.2.3
MORE
EFFECTIVE
NESHAP
Sv
s
AACM
^
^
^
s
s
s
EQUAL
^
^
^
^
^
1 Concentrations were near or below the limit of detection limit for both processes.
Water was inadvertently not added during AACM soil removal phase.
xvm
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ACKNOWLEDGMENT
This was truly a multi-faceted team effort bridging not only the asbestos expertise within EPA
and in the Arkansas Department of Environmental Quality, but also the highest caliber
contractual support to accomplish the objectives of this study. Each individual listed made
significant contributions to assist in the success of the project. The onsite support received from
the individuals in the Fort Chaffee Redevelopment Authority/Fort Smith/Fort Chaffee
organizations was exemplary. Their cordiality, hospitality, helpfulness, and willing assistance
were essential components for the execution and completion of the research project.
U.S. EPA QAPP Technical Development Team: Keith Barnett, OAQPS; David Eppler and
Mark Hansen, Region 6; Lee Hoffman, OSW; Jim Konz, OSRTI; Mark Maddaloni, Region 2;
Ron Rutherford, OECA; Roger Wilmoth and Glenn Shaul, NRMRL; John Smith, OPPT; Brad
Venner, NEIC; and Julie Wroble, Region 10.
U.S. EPA Resource Members: Charlotte Bertrand, OPEI; David Cozzie, OAQPS; Becky Dolph
and Lynn Slugantz, Region 7; Elvia Evering, Region 6; Chris Kaczmarek, OGC; Marcus Kantz,
Region 2; Lauren Drees and Todd Martin, NRMRL; and Steve Schanamann, OIG.
State of Arkansas Resource Members: Lloyd Huntington and Torrence Thrower, ADEQ.
QAPP Formal Peer Review Panel Members: Timothy Buckley, Ohio State University; Ed Cahill,
EMSL Analytical, Inc.; Fred Cone, Lawrence Livermore National Laboratory; William Ewing,
Compass Environmental; David Goldsmith, George Washington University; and Peter Scheff,
University of Illinois at Chicago.
Contractor Project Team: John Kominsky, Fred Hall, Julie Wagner, and Randall Cook,
Environmental Quality Management, Inc., Cincinnati, OH; Michael Weeks, Boelter & Yates,
Inc.; Chicago, IL; Bob Ed Smith, James Waldo, and Chris Platt, Environmental Enterprise
Group, Inc., Russellville, AR; Alan Segrave, Clayton Group Services, Kennesaw, GA; John
Harris and Kate March, Lab/Cor, Inc., Seattle, WA; Jeanne Orr and Stacy Gardalen, Reservoirs
Environmental, Inc., Denver, CO; James Baxter, DataChem, Cincinnati, OH; David Cox,
QuanTech, Inc., Arlington, VA; Mike Beard and Owen Crankshaw, RTI International, Research
Triangle Park, NC; Larry Weatherford, G.W. -9ub" Rose, and Virginia Herion, Crawford
Construction Co., Fort Smith, AR; Greg Gerken, Gerken Environmental Enterprises, Inc., Fort
Smith, AR; Daryl Brashears, Unlimited Electric Co., Fort Smith, AR; Bryan Rambo and John
Vieweger, Kidde National Foam, Exton, PA, and Steven Jones, Steven Jones Photography, Fort
Smith, AR.
Final Report Formal Peer Review Panel Members: Ronald Dodson, Dodson Environmental
Consulting, Inc.; Ron Dokell, Demolition Consultants; Steve Hayes, Gobbell Hays Partners, Inc.;
Tom Laubenthaul, The Environmental Institute; Fredy Polanco, Polanco Enterprises, Inc.; and
James Webber, New York State Department of Health.
Fort Chaffee Redevelopment Authority: Sandy Sanders, Larry Evans, Rosemary Stallings, and
Janet Menshek.
xix
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Fort Chaffee: Col. Tommy Hunt, US Army Reserve; and Lynne Pincumbe, DOE.
City of Fort Smith: Landfill Manager Charlie Sanders, Fire Chief Jerry Tomlin, Battalion Chief
Mike Richards, and Fire Fighters Marcus Brown, Josh Price, Brad Turner, John Parr, Carey St.
Cyr, Peter Gross, Ed Barton and Brandon Sharp.
State of Arkansas: Denise Chiarizzio, ADEQ.
U.S. EPA Senior Management: Bill Farland, Richard Greene, Larry Starfield, Jim Gulliford,
Louise Wise, Tim Oppelt, Sally Gutierrez, Kevin Teichman, and John Blevins.
U.S. EPA Staff: David Gray, David Bary, Gordon Evans, Esteban Herrera, David Garcia, Mary
Goldade, Marilyn Joos, Phyllis McKenna, Pati Schultz, Dave Ferguson, Bill Barrett, John
McCready, Bob Olexsey, Mike Hennessey, Neil Stiber, Janey Wilmoth, and Lynne Lewis.
Special thanks are extended to Vicki Ann Lancaster of Neptune & Company for providing
additional insight into the statistical analyses.
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ABBREVIATIONS AND ACRONYMS
AACM Alternative Asbestos Control Method
ACM Asbestos-Containing Material
ADEQ Arkansas Department of Environmental Quality
AED Aerodynamic Equivalent Diameter
AHERA Asbestos Hazard and Emergency Response Act
AQMD Air Quality Management District
ASTM American Society for Testing and Materials
C&D Construction and Demolition
CDF Cumulative Distribution Function
DL Detection Limit
DMF Dimethylformamide
DOE US Department of Energy
EPA US Environmental Protection Agency
GPM Gallons per Minute
GR Gravimetric Reduction
GRR Gravimetric Reduction Ratio
HEPA High Efficiency Particulate Air
ISO International Standards Organization
ICP-AES Inductively Coupled Plasma Atomic Emission Spectroscopy
K-S Test Komolgorov-Smirnov Test
MCE Mixed Cellulose Ester Filter
MDL Method Detection Limit
NEIC USEPA National Enforcement Investigations Center
NESHAP National Emission Standard for Hazardous Air Pollutants
NFPA National Fire Protection Association
NIOSH US National Institute of Occupational Safety and Health
NRMRL USEPA National Risk Management Research Laboratory
OAQPS USEPA Office of Air Quality Planning and Standards
OECA USEPA Office of Enforcement and Compliance Assurance
OGC USEPA Office of General Counsel
OIG USEPA Office of the Inspector General
OPEI USEPA Office of Policy, Economics, and Innovation
OPPT USEPA Office of Pollution Prevention and Toxics
ORD USEPA Office of Research and Development
OSHA US Occupational Safety and Heath Administration
OSRTI USEPA Office of Superfund Remediation and Technology Innovation
OSW USEPA Office of Solid Waste
PCM Phase Contrast Microscopy
PCME Phase Contrast Microscope Equivalent
PPE Personal Protective Equipment
PVC Polyvinyl Chloride
PEL Personal Exposure Limit
PLM Polarized Light Microscopy
PSI Pounds per Square Inch
xxi
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QAPP Quality Assurance Project Plan
PvACM Regulated Asbestos-Containing Material
RCRA Resource Conservation and Recovery Act
T&D Transportation and Disposal
TEM Transmission Electron Microscopy
TSI Thermal System Insulation
TWA Time-Weighted Average
VAC Volts Alternating Current
VAT Vinyl Asbestos Tile
WTC World Trade Center
xxn
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SECTION 1 INTRODUCTION
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 and §61.154] 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 the collection, processing,
packaging, or transporting of any asbestos-containing waste material generated by the source.
If a facility is being demolished because it is structurally unsound and is in danger of imminent
collapse, RACM [§61.145(a)(3)J 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 regulated asbestos-containing material (ACM)
[§61.150(a)(3)].
The EPA performed a controlled demonstration to compare the relative environmental impacts of
the Alternative Asbestos Control Method (AACM) to the NESHAP method. This study was
intended as a stand-alone evaluation of the environmental and cost-effectiveness of two
demolition processes on buildings that are architecturally identical in composition and structure
and which contain asbestos, meeting the qualifications of containing greater than 160 ft2 of
RACM. These data may be used to help EPA determine whether it is appropriate to include an
alternative method in the current asbestos regulations contained in 40 CFR Part 61 Subpart M.
1 Under Asbestos NESHAP[§61.141], RACM means (a)friable asbestos material, (b) Category I non-friable
ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding,
grinding, cutting, or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or
has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the
course of demolition or renovation operation regulated by this subpart.
2 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. Also, under 40CFR 61.145 (c)(l), ACM has to be removed if, among other things, it is Category I
nonfriable ACM that is in poor condition and is friable or it is Category II nonfriable ACM and there is a
probability that the materials will become crumbled, pulverized, or reduced to powder during demolition.
(These regulations may be supplanted by more stringent local governmental (state, city, etc.) regulations that
govern such activities.)
1
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The AACM, if determined to be environmentally acceptable but less costly than the current
regulations, may have the benefit of allowing municipalities to demolish abandoned buildings
that otherwise would remain standing until they were in danger of imminent collapse.
Previous studies indicated that there were situations where undesirable releases of asbestos were
documented from demolition activities. These studies included both demolitions conducted by
the NESHAP process and ones conducted under imminent danger of collapse situations
(Wilmoth et al 1993, Wilmoth et al 1994, City of Saint Louis 2004).
Exhibit 1 contains the Alternative Asbestos Control Method that was developed by EPA Region
6 and EPA Office of Research and Development (ORD) with input from the EPA Quality
Assurance Project Plan (QAPP) Technical Development Team. The applicability criteria listed in
Exhibit 1 were developed to conceptually show the types of buildings where it is believed this
method can be effective. Depending on the types of building tested, the types of asbestos
materials present in the tested buildings, and the test results, additional restrictions on the
applicability may be added/removed.
The AACM requires that certain RACM (such as thermal system insulation and fireproofmg) be
removed before demolition in accordance with the Asbestos NESHAP; other RACM (such as
wallboard joint compound, resilient flooring/mastic, glazing compound) may remain in place.
The AACM differs 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 release fibers to the air when the wetting process and demolition
techniques specified in the AACM are used. Wastewater generated during the demolition is
collected and filtered, and all debris is disposed of as regulated asbestos-containing waste. Soil in
the affected area is excavated and disposed as regulated asbestos-containing waste.
The purpose of this research project was to compare the environmental and cost-effectiveness of
the AACM 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 yet equally protective demolition practices.
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Page 1 of7
ALTERNATIVE ASBESTOS CONTROL METHOD
Developed by EPA Region 6 and EPA Office of Research and Development
January 25, 2008
1.0 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-friable ACM that has 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 has 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 (AACM) 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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Page 2 of7
2.0 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.
3.0 Building Inspection/Asbestos Assessment
A comprehensive inspection of the interior and exterior of the structure to be demolished shall be
conducted in accordance with EPA's Asbestos Hazard Emergency Response Act (AHERA, 40
CFR Part 763). Specific criteria 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.
4.0 Asbestos Removal
Table 1 summarizes the ACM that may be present in buildings and whether or not the ACM must
be removed prior to demolition.
All thermal system insulation (TSI) and spray-applied fireproofmg 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 prior 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.
5.0 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-trained individual to oversee the
demolition process.
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Page 3 of 7
5.1 Equipment Used
Track hoes and end loaders or equivalent shall be used during demolition to minimize the
generation of dust. No bulldozers, explosives, or burning will be permitted.
5.2 Wetting Process
Structures to be demolished will be thoroughly and adequately wetted with amended water (water
to which a surfactant has been added) prior to demolition, during demolition, and during debris
handling and loading. Surfactants reduce the surface tension of the water, increasing its ability to
penetrate the ACM.
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 particulates. 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-trained
individual will verify that ACM is 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.
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Page 4 of7
Table 1. Asbestos Removal Requirements of AACM
Asbestos-Containing Material
Removed Prior to
Demolition?
Thermal System Insulation (TSI)
• Tank insulation
• Pipe insulation
• Elbow/fitting/valve insulation
• Boiler insulation
• Duct insulation
• Cement and patching compound
Yes
Yes
Yes
Yes
Yes
Yes
Surfacing Material
• 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.
No
Yes
No
No
No
No
Miscellaneous Material
• 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
• Mastic for flooring
• Window Cauking
Optional
Optional
No
No
No
No
No
No
No
No
Yes
No
No
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Page 5 of 7
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 during the demolition and during loading of debris into lined
disposal containers.
5.3 Demolition Process
The demolition contractor shall minimize breakage of asbestos-containing materials. All
demolition shall be completed in a timely manner that will allow the debris generated during that
day to be completely removed from the demolition site for disposal.
5.4 Visible Emissions
The Asbestos NESHAP standard of -fto visible emissions" shall be employed. Visible emissions
mean any emissions, which are visually detectable without the aid of instruments, coming from
RACM or asbestos-containing material. This does not include condensed, uncombined water
vapor. The demolition contractor's NESHAP-trained 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.
6.0 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.
7.0 Monitoring Requirements
Demolition contractors are required to comply with all applicable OSHA (29 CFR 1926)
regulations for worker protection during asbestos removal and demolition activities. This
7
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Page 6 of 7
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.
8.0 Waste Handling
Several wastes are generated during demolition activities, including demolition debris, 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-mil or
thicker polyethylene film and then sealing the top seams of the film is a suggested 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.
8.1 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 debris 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.
8.2 PPE
All disposable PPE shall be disposed as RACM. Reusable PPE shall be decontaminated in
accordance with OSHA standard practices.
8.3 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 and/or trenches must be
created as necessary to prevent runoff of water from the demolition site. If possible, the
bermed/trenched area should extend 25 ft from the building and/or loading area. If not possible,
adjacent areas and structures need to be covered with plastic.
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Page 7 of 7
The berm/trench 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. All
plastic shall be disposed as RACM.
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 transporting to a publicly-owned treatment works or
discharging to a sanitary sewer. The filters must be disposed as RACM.
8.4 Potentially Contaminated Soil
Following the removal of demolition debris, bare soil within the bermed area shall be excavated
to a minimum depth of three inches or until no debris is found. Berms created shall also be
removed and disposed as potentially asbestos-contaminated. All removed soil shall be disposed
as RACM. Wetting will be continued throughout the soil removal process.
9.0 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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SECTION 2 PROJECT OBJECTIVES
The goal of this research study was to compare the effectiveness of the AACM to the current
Asbestos NESHAP demolition practice on buildings that were architecturally identical.
Primarily, this means that the environmental releases of asbestos to the air and to the soil as
measured by their respective concentrations should not be greater in the case of the AACM than
those of the NESHAP Method. In addition, the cost of the AACM must be less than the
NESHAP Method for the alternative to be attractive. All of the data collected were evaluated and
considered, as appropriate, to make this comparison.
The quality assurance project plan (QAPP), Evaluation of an Alternative Asbestos Control
Method for Building Demolition, March 2006 was developed by ORD in combination with the
select EPA QAPP Technical Develpoment Team to serve as the guide for collecting and
analyzing the data from this research effort. The QAPP was also formally peer-reviewed and
offered for public comment. The QAPP as revised specified the following project objectives:
2.1 Primary Objectives
1. To determine if the airborne asbestos (TEM) concentrations from the AACM are
statistically equal to or less than the NESHAP Method.
2. To determine if the post-excavation asbestos concentrations in the soil from the AACM
are statistically equal to or less than the post-demolition NESHAP Method. The AACM requires
soil excavation following demolition and the NESHAP Method does not.
3. To determine if the AACM 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.
2.2 Secondary Objectives
The following secondary objectives provided 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 were also considered in a holistic sense in
assessing the comparability of the two demolition methods:
2.2.1 Air
1. To determine background asbestos concentrations (TEM) prior to the NESHAP and
AACM demolitions.
2 To determine if the airborne fiber (analyzed by phase contrast microscopy -PCM)
concentrations from the AACM are statistically equal to or less than the concentrations from the
NESHAP Method.
11
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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 NESHAP Method.
5. If wind conditions allow, to determine if the airborne asbestos concentrations
downwind are statistically greater than the upwind concentrations for the AACM.
2.2.2 Dust
6. To determine if the asbestos concentrations in the settled dust (TEM) from the AACM
are statistically equal to or less than the concentrations from the NESHAP Method.
7. To determine if the total particulate concentrations (as collected and measured by
NIOSH Method 0500) from the AACM are statistically equal to or less than the concentrations
from the NESHAP Method.
2.2.3 Worker
8. To determine if worker breathing zone fiber concentrations (PCM) from the AACM
are statistically equal to or less than the concentrations from the NESHAP Method.
9. To determine if worker breathing zone asbestos concentrations (TEM) from the
AACM are statistically equal to or less than the concentrations from the NESHAP Method.
2.2.4 Activity
10 To document worker breathing zone asbestos concentrations (TEM) for individuals
that are maintaining the perimeter air monitoring network.
2.2.5 Soil
11. To determine if the asbestos concentration in the post-excavation soil from the AACM
is statistically equal to or less than the pre-demolition asbestos concentration.
12. 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.
13 To determine if asbestos concentration in the post-excavation soil is statistically equal
to or less than the concentration in the post-demolition soils from the AACM.
12
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14. To determine if asbestos concentrations from elutriator tests on the post-excavation
soils from the AACM are statistically equal to or less than the concentrations from the
post-demolition NESHAP Method
15. To determine if asbestos concentrations from elutriator tests on the post-excavation
soils from the AACM are statistically equal to or less than the pre-demolition
concentrations.
16. 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.
17. To determine if asbestos concentrations from elutriator tests on the post-excavation
soil are significantly equal to or less than the concentrations from tests on the post-
demolition soil from the AACM.
2.2.6 Water
18. To measure the asbestos concentrations in the water applied to control emissions from
both the AACM and NESHAP Method and to measure the asbestos concentrations in collected
water for both processes during demolition activities.
2.2.7 Landfill
19 To determine background airborne asbestos concentrations (TEM) prior to
landfilling of the NESHAP building debris and again prior to landfilling of the AACM building
debris.
20. To determine if the airborne asbestos concentrations at the landfill (TEM) during
disposal of the AACM debris are statistically equal to or less than the concentrations during
disposal of the NESHAP Method debris.
21. To determine if landfill worker breathing zone fiber concentrations (PCM) from the
AACM are statistically equal to or less than the concentrations from the NESHAP Method.
22. To determine if landfill worker breathing zone asbestos concentrations (TEM) from
the AACM are statistically equal to or less than the concentrations from the NESHAP Method.
2.2.8 Time
23. To document the time required for all activities related to demolition by the NESHAP
Method, including abatement, and for the AACM.
13
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2.2.9 Modeling
24. To collect additional asbestos and fiber data necessary for potential future air
dispersion modeling efforts.
25. To compare the modeled emission factors from the AACM with those from the
NESHAP Method.
14
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SECTION 3 SITE INFORMATION
3.1 Site Selection
EPA conducted a nationwide search for buildings that contained, as a minimum, asbestos-
containing wall systems and vinyl asbestos floor tile. Other ACM components such as popcorn
ceilings, window glazing, transite, and vermiculite attic insulation were considered a plus in this
search. Another major criterion was that the buildings needed to be identical in construction.
The most significant criterion, and the most limiting as well, was the EPA requirement that the
structures needed to be about 1,000 feet from the nearest occupied residence. The task of
locating paired structures was a truly difficult endeavor, and many locations were investigated
before the ones used in this research effort were located.
The buildings were located at the Fort Chaffee Redevelopment Authority in Fort Smith,
Arkansas (Figure 3-1). The NESHAP (#3602) and AACM (#3607) buildings are shown in
Figure 3-2.
The demolition site was in a remote, secure location to ensure no public exposure. There were
no private residences within a radial distance of one mile from the study buildings. The nearest
residence was approximately two miles from the demolition site. The buildings had 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.
The demolition debris was transported to City of Fort Smith's Subtitle -9" landfill, which is
approved to accept asbestos-containing waste materials. 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 seven miles southwest of the demolition site.
3.2 Site Description
These 1940-era buildings were architecturally identical both in composition and structure (Figure
3-3 and Figure 3-4), which was ideal for the testing and comparative evaluation of the AACM
versus the Asbestos NESHAP Method. The building footprint is approximately 4,500 square
feet (30 feet by 150 feet). The buildings were wood-frame construction with wood clapboard
exterior siding and non-ACM asphalt shingle roofs. The interior finish was gypsum wallboard
on both the ceiling and walls, and associated painted millwork. Resilient floor tile (nine inch by
nine inch) was present in all areas excluding the bathrooms, which was resilient sheet vinyl. The
building had a concrete pier and wooden beam foundation system with one large concrete box
structure whose function was not known. 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.
All asbestos-containing thermal system insulation on the steam pipes associated with these
buildings had been previously abated in 1999.
15
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Figure 3-1. Project location at Fort Chaffee. Buildings selected for demolition are #3602
(NESHAP Method) and #3607 (AACM).
16
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Figure 3-2. (Top) Exterior view of Building #3602 (NESHAP Method) and (Bottom) #3607
(AACM). Dimensions: 30-feetby 150-feet.
17
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Figure 3-3. Interior view of Building #3602 (NESHAP). Interior finishes are gypsum wallboard
(ceiling and walls) and nine-by-nine-inch resilient floor tile.
18
-------
Figure 3-4. Interior view of Building #3607 (AACM). Interior finishes are gypsum wallboard
(ceiling and walls) and nine-by-nine-inch resilient floor tile.
19
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3.3 Pre-Demolition Inspection of Buildings
Several months before the scheduled demolitions, samples of site building materials, soil, source
(hydrant) water, and background air were collected and analyzed to determine the suitability of
the site for the comparative method evaluation.
3.3.1 Asbestos Inspection of Buildings
A comprehensive pre-demolition inspection was conducted in accordance with the Asbestos
Hazard Emergency Response Act (AHERA) (40 CFR §763) to identify the type, quantity,
location, and condition of ACM in the buildings [§61.145(a)] (Kominsky 2005; Smith Aug
2005). Under NESHAP 40 CFR 61.145(a), not only RACM must be identified prior to
demolition or renovation but also Category I and Category II nonfriable ACM. The inspection
was conducted by a State of Arkansas Department of Environmental Quality (ADEQ) licensed
Asbestos Abatement Consultant. The inspection data were used to determine the pre-demolition
asbestos abatement plan for these buildings (Smith Nov 2006).
The samples were analyzed for asbestos content 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 (GR) 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 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 sample as determined by measuring to a distance as wide as the seam (Figure 3-5,
d2). That is, the sample used to estimate the quantity of each layer is represented by d2 in Figure
3-5.
20
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Reference area for visual estimation of relative component percentages
Figure 3-5. Section of %-inch gypsum wallboard showing a multi-layered joint interval.
Wallboard was obtained from Building #3607 (AACM)
Table 3-1 summarizes the results of the building material samples collected from the NESHAP
Method (#3602) and AACM (#3607) buildings. Table 3-2 lists the ACM present in the
NESHAP Method (#3602) and AACM (#3607) buildings and their corresponding quantities and
locations. These buildings contain ACM that are commonly present in structures that could
conceivably fall under the AACM. Window glazing was not asbestos-containing by PLM in
Building 3602 but TEM revealed that it was asbestos-containing. The glazing had apparently
been replaced by non-ACM glazing in Building 3607. According to NESHAP rules, the glazing
compound would not have been required to have been removed since it was less than one percent
asbestos by PLM.
21
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Table 3-1. Asbestos Content of Building Materials
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-inch Tile
Sheet
Mastic
Shingle
Felt
Glazing Compound
Attic Insulation
4
4
4
4
4
4
4
4
4
Chrysotile
-
Chrysotile
Chrysotile
-
-
-
Chrysotile
-
1-5
NA
NDa
10-20
15-25
ND
ND
ND
TRb
ND
10-19
4-7
NA
14-24
NAC
NA
NA
NA
8-9
NA
AACM Method Building (#3607)
Wallboard
Flooring
Roofing
Joint Compound
Joint Interval Composite
Non- Joint Skim Coat
9- by 9-inch Tile
Sheet
Mastic
Shingle
Felt
Glazing Compound
Attic Insulation
4
4
4
4
4
4
4
38
4
Chrysotile
Chrysotile
Chrysotile
Chrysotile
-
-
-
-
-
1-5
NA
ND
10-20
15-25
ND
ND
ND
ND
ND
4-10
1-4
<0.3-2
17-20
NA
NA
NA
NA
<0.1
NA
aND = None Detected, < 1% visual estimate.
bTR = Trace, <1% visual estimate.
°NA = Not analyzed.
22
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Table 3-2. ACM Present in the NESHAP Method and AACM Buildings.
Sample
Group
HAa
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
Gypsum
Wallboard
Bathrooms
Throughout
Windows
Throughout
Non-Friable
Non-Friable
Friable
Non-Friable
252ft2
3,992 ft2
814 If
20,700 ft2
Good
Good
Damaged
Good
AACM Building (#3607)
3607-RFC-02
3607-FT-03
3607-JC-06
2
3
6
Red Multi-
Colored
Linoleum
Brown Floor
Tile
Gypsum
Wallboard
Bathrooms
Throughout
Throughout
Non-Friable
Non-Friable
Non-Friable
252ft2
3,992 ft2
20,700 ft2
Good
Good
Good
aHA = Homogeneous area
3.3.2 Lead Paint Inspection of Buildings
The NESHAP Method (#3602) and AACM (#3607) buildings were surveyed for inorganic lead
to characterize the potential for occupational exposure during demolition and landfilling of the
resultant construction debris.3 The samples were prepared for analysis in accordance with EPA
SW-846 Method 3050A and analyzed by inductively coupled plasma atomic emission
spectroscopy (ICP-AES) in accordance with EPA SW-846 Method 601 OB (Smith, 2006).
Table 3-3 presents the concentrations of lead measured in paint chip samples obtained from
Buildings #3602 and #3607. Because the paint contained >600 ppm lead, personal breathing
zone monitoring was conducted during asbestos abatement of Building #3602 and during
demolition and landfilling of both buildings in accordance with OSHA Lead Standard 29 CFR
§1926.62. Representative composite bulk samples of the lead-containing building materials
were analyzed to determine the teachable lead content (EPA SW-846 Method 1311, Toxicity
Characteristic Leaching Procedure), as required by the local landfill operator. All samples
showed a teachable lead content of <5 mg/L RCRA criterion.
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 50 ng/m3, eight-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 j-ig/m eight-hour
TWA.
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Table 3-3. 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
1,310
81,500
4,400
500
34,000
24,000
2,000
120,000
AACM (#3607) Building
Millwork
Gypsum wallboard
Exterior clapboard siding
4
4
3
12,000
1,220
55,300
8,000
1,000
46,000
15,000
4,000
73,000
3.3.3 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 purpose of these
samples was to provide a preliminary assessment of the background soil asbestos concentrations.
The soil samples were collected using a clean scooping tool to acquire approximately the top 1/2-
inch of soil from a six-inch by six-inch area. The samples were analyzed for asbestos content
using PLM and dispersion staining in accordance with EP'A''s Methodfor the Determination of
Asbestos in Bulk Building Materials (EPA/600/R-93/116, July 1993). The soil samples were
also analyzed for asbestos using gravimetric reduction and subsequent TEM analysis described
in the above method. The asbestos concentrations present in the soil are summarized in Table
3-4.
Beneath the buildings, asbestos concentrations near the analytical sensitivity were observed in
some samples. This was attributed to the prior removal of thermal system insulation (pipe wrap)
noted in section 3.2.
Table 3-4. Asbestos in Soil (PLM) and Gravimetric Reduction (GR/TEM).
Location
Number
of Samples
Asbestos Founda
Asbestos Content, %
PLM
GR/TEM
NESHAP Method (#3602) Building
Beneath Building
3
Chrysotile
TRb
BASC
AACM (#3607) Building
Beneath Building
3
Chrysotile, Amosite, Anthophyllite
TR
BAS-0.005
Perimeter of Buildings
Perimeter
3
NDd
ND
BAS
alf detected, no more than one fiber was observed in any sample.
bTR = Trace, <1% by visual estimate.
CBAS = Below analytical sensitivity, 0.001 (mass %).
dND = None Detected, <1% visual estimation.
24
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3.3.4 Concentrations of Asbestos in Source Water
Three one-liter samples of the source water were obtained from the flush hydrant at the
demolition site in January 2006, approximately four months prior to the study. Prior to
collecting the samples, the hydrant was operated until the water stream was relatively clear. The
samples were analyzed for asbestos by EPA Method 100.2 (TEM). All sample concentrations
were below the analytical method measurement sensitivity concentrations, which ranged from
0.04-1.91 million asbestos structures per liter.
3.3.5 Background Air Sampling
Preliminary background asbestos air sampling was conducted at the demolition site and at the
landfill in January 2006, approximately four months prior to the study. Five-fixed station area
samples were collected around the NESHAP and AACM buildings. Six fixed-station area
samples were collected at the Fort Smith Landfill in the area selected to receive the demolition
debris from both buildings. The samples were analyzed for asbestos using the International
Standards Organization (ISO) Method 10312:1995. All sample concentrations were below the
analytical method measurement sensitivity concentrations of 0.0005 structures/cm .
This background sampling was done for pre-assessment purposes. Prior to the actual
demolitions, additional background sampling was performed as described later in this document.
25
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SECTION 4
STUDY DESIGN AND IMPLEMENTATION
4.1 Sampling Strategy
The overall summary of the field samples collected during the study is presented in Table 4-1
through Table 4-3. These tables summarize the numbers and type of samples collected for each
media for both the NESHAP and AACM demolitions and disposal operations. Sections 4.1.3
through 4.1.5 present the details of the sampling strategies for the demolition site and the landfill.
Table 4-1. Summary of Field samples (excluding quality control samples)
Collected for Asbestos Analysis by TEM.
Description of Sample
NESHAP Building
Aira
Soil"
Water
Settled
Dust
AACM Building
Air
Soil
Water
Settled
Dust
Background Sampling Prior to Building Demolition
Demolition site at Ring 1
Fort Smith landfill at Ring 1
6
6C
-
-
-
-
-
-
6
-
-
-
-
-
-
Asbestos Abatement of NESHAP Building
Worker
Asbestos abatement
Loadout of drummed
ACM
Equipment operator
landfill drummed ACM
FtEPA unit discharge air
6
3
4
4
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Demolition of Buildings
Rings 1 and 2
Worker
Soil
Water
Hose and equipment
operators, and truck
drivers
Walkers outside of
containment berm
Bulk
Elutriation
Source hydrant
Amended
Pooled surface
54
-
8
3
-
-
-
-
-
-
-
-
-
20
6
-
-
-
-
-
-
-
-
-
2
-
-
-
36
-
-
-
-
-
-
-
107
-
8
3
-
-
-
-
-
-
-
-
-
30
9
-
-
-
-
-
-
-
-
3
2
7
-
36
-
-
-
-
-
-
-
Landfill of Demolition Debris
Ring 1
Landfill equipment operator
Total samples
9
3
106
-
-
26
-
-
2
-
-
36
18
4
146
-
-
39
-
-
12
-
-
36
a Samples (excluding soil elutriation and HEPA unit discharge) were also analyzed for total fibers.
b Samples were analyzed by both PLM and TEM.
0 Applicable also to AACM.
27
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Table 4-2. Summary of Personal Breathing Zone Samples Collected for Lead.
Description of Sample
During abatement
During building demolition
During landfill of building debris
Number of Air Samples
NESHAP Building
13
8
O
AACM Building
NAa
8
2
"Not applicable.
Table 4-3. Summary of Ring 1 Air Samples Collected for Total Particulate
Description of Sample
During building demolition
Number of Air Samples
NESHAP Building
18
AACM Building
18
4.1.1 Meteorological Monitoring
Meteorological conditions were determined and continuously monitored during sampling at both
the demolition site and the landfill using MetOne Automet Meteorological Monitoring Systems
(Automet 466A). The meteorological parameters that were measured included wind direction
and speed, air temperature, relative humidity, and barometric pressure. The monitoring station at
the landfill site failed at the beginning of the study, but meteorological data from the Fort Smith
Airport site, located about 1000-ft from the landfill, was used.
4.1.2 Weather Restrictions
The demolition was not conducted during rain or snow conditions. For this study, if sustained
wind speeds of 15 mph (60-minute average) or gusts above 20 mph were encountered,
demolition and monitoring would pause until the wind speed was less than these conditions. The
maximum limits were established to attempt to prevent the higher winds speeds from excessively
modifying the micrometeorology. Operations would resume upon the winds returning to stable
conditions (15-minutes minimum allowable within the confines of the test), or would be delayed
until satisfactory conditions exist. Wind conditions at the site were continuously monitored by
the onsite weather station. During the study, none of the weather restriction situations were
encountered.
4.1.3 Demolition Site Sampling
4.1.3.1 Background Air Monitoring
Air monitoring was conducted prior to demolitions of the NESHAP and the AACM buildings to
collect data necessary for potential comparison of air concentrations of asbestos and total fibers
28
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during demolition. The target air volume for an eight hour sample at a flow rate of four liter/min
was 1,920 liters.
The air monitoring network for the background data consisted of one ring of six fixed-station
samplers around the building. The samplers were placed at 60-degree intervals measured along a
radius from the center of the building. The samplers were placed within 15 feet of the building
and at a height of five feet above ground. The background monitoring was prior to the respective
demolition.
4.1.3.2 Perimeter Air Asbestos, Total Fibers, Settled Dust, and Particulate Sampling
During Demolition
Since the demolition study was initially scheduled to be performed during the March-April time
frame, 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 April 30 during the
years of 1999, 2000, and 2002 through 2004 at the Fort Smith Municipal Airport (Station
#13964). The results of this analysis showed that the wind direction varied between up to six 20-
degree sectors during a given day. 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. This
study design is consistent with the primary objective of this project: i.e., to compare the
effectiveness of the AACM to the Asbestos NESHAP Method.
The distance of the rings from the face of the building was determined using two EPA dispersion
models: SCREENS and ISCST3. 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 using the ISCST3 (a
steady-state Gaussian model) to predict location (i.e., lateral distance and height above ground
level) where the maximum concentration of airborne asbestos was likely to occur.
Modeling conducted using the EPA dispersion models SCREENS and ISCST3 indicated that the
maximum airborne asbestos concentrations during demolition and loading of debris would most
likely occur approximately 15 feet from the building at a height of five feet above the ground.
Therefore, the samplers were placed 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 samplers in the first ring (Ring 1) were positioned approximately 25 feet from the
face of the building to accommodate the space needed for loading the construction debris
disposal trucks. This provided about ten feet between the truck side and the building.
Eighteen samplers (for each asbestos/total fibers, particulate, and settled dust) were evenly
spaced at 20-degree intervals around each building in Ring 1 at the five-ft height. An additional
18 samplers (asbestos/total fibers) were positioned at a height of 15 feet in the primary ring
(Ring 1) on the same sampling poles, directly above the five-ft-high samplers. The perimeter air
samplers were placed immediately outside of the containment berm. The samplers were in
numerical order corresponding to the manner in which the samplers were placed around the
buildings. That is, the first sample in each group of 18 corresponded to the location on the front
right (northwest) corner of the building and then were numbered in a clockwise fashion around
29
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the structures. The trucks were loaded along the front of the building as the demolitions
progressed (samplers one through seven in each grouping).
Samplers were also located to collect additional data necessary for potential future air dispersion
modeling efforts. A second ring (Ring 2) of 18 evenly-spaced samplers (asbestos/total fibers and
settled dust) was located about 50 ft away from the building. The Ring 2 samplers were placed
at the five-ft height above ground.
If any asbestos-containing dust was released during the demolition of the buildings and
associated debris-loading activities, it could settle on nearby surfaces. As previously mentioned,
settled dust collectors were placed at the five-ft heights at the same locations as the air samples
in Rings 1 and 2.
In order to provide a measure of total particulate in the air from the two demolitions, samples
were collected at the same locations as the perimeter air asbestos samples in Ring 1.
The perimeter air sampling network consisting of the two concentric rings is shown for the
NESHAP and AACM buildings in Figure 4-1 and Figure 4-2, respectively.
All primary air samples were collected at an airflow rate of four liter/min for approximately eight
to ten hours to achieve a target air volume of 1,920 to 2,400 liters. Additionally, lower volume
samples were collected at a flow rate of two liter/min for approximately eight to ten hours to
achieve an air volume of 960 to 1,200 liters, to serve as backup samples if the primary ones were
overloaded. The primary samples were not overloaded; therefore these low flow samples were
not analyzed and were archived.
All air samplers were activated shortly before demolition activities began, and were continued
until demolition activities ceased for that day.
For the AACM, the demolition was completed on the first day (Day 1). Air sampling for
asbestos/total fibers was halted and the filters were capped and removed for analysis. Concrete
structures and some small residual debris remained. On the second day, removal of the concrete
structures and remaining debris and the subsequent soil sampling was delayed until the afternoon
because of rain. Prior to the initiation of Day 2 activities, to assure no filter overloading, new
filters were positioned for asbestos/total fiber sampling. Due to the rain, concrete/debris
removal, and the subsequent soil sampling which required a significant amount of time, soil
excavation was delayed until the third day. The asbestos/total fiber filters were capped overnight
and during periods of inactivity on Days 2 and 3. These samples, which reflect AACM activities
over the second and third day, are referred to as Day 2 samples throughout this report. The
settled dust samplers and particulate filters were positioned for the entire duration of the AACM
study and capped overnight and during periods of inactivity.
30
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25ft
©
M12
(o)
M12
M13
Building 3602
Footprint
30tt X150ft
M3
M1
25ft
©
M5
(2)
M4
©
M3
M2
Ring 1 Sampling Station
©
M1
Ring 2 Sampling Station
Figure 4-1. Location of Ring 1 and 2 samplers around the NESHAP Method building.
-------
to
^C«.
Berm: Just Inside Ring 1
176ft
Ringl
*-t15ft
>
\ ,
i
' *i
1
Hj
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r
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i
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r
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aro
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r
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25ft
Ring 2
Soil Sampling Block Outline
-*"
Figure 4-2. Location of soil sampling grid around the NESHAP building.
-------
4.1.3.3 Work Area Sampling
4.1.3.3.1 Discharge Air Sampling During Asbestos Abatement ofNESHAP Building
Previous studies conducted by EPA of air filtration units equipped with High Efficiency
Particulate Air (HEPA) filtration to maintain a negative static air pressure at asbestos abatement
sites showed that a large percentage of the units discharged asbestos fibers (Kominsky et al
1989; and Wilmoth et al 1993).
In-duct isokinetic samples of the discharge air from each HEPA-filtration unit used during the
abatement of the NESHAP Method building were collected according to the procedures outlined
in Wilmoth, et al, 1993 and analyzed for asbestos by direct transfer preparation. Four air
filtration units were required to maintain the static negative air pressure within the building.
Because the discharge air was being processed through new HEPA filters that were specifically
installed for this study, it was expected that the particulate loading on the filter would be
minimal, and this was the case. Accordingly, each sample was collected over three consecutive
eight- to ten-hour work shifts.
4.1.3.3.2 Personal Breathing Zone Sampling During Abatement
Personal breathing zone sampling for asbestos, total fibers, and lead was conducted during the
abatement and during the load-out of the bagged and drummed ACM to determine the extent of
asbestos fiber release during these activities. This sampling approach provides a reasonable
characterization of the asbestos concentrations in air closest to the source of any potential
release. Six personal breathing zone samples were collected from workers during the abatement
process. The selection of the workers was random, but there was no formalized selection
process. In addition, three personal breathing zone samples were obtained during the load-out
process. A sampler was placed on the worker responsible for transferring the bagged and/or
drummed ACM into the disposal container.
4.1.3.3.3 Personal Breathing Zone Sampling During Demolition
Personal breathing zone samples were collected and analyzed for asbestos, lead, and total fibers
from all workers directly involved with the demolition of the buildings and the handling of the
resultant construction debris. In addition, fixed station area samples were collected in the cab of
the excavator as a backup to the personal breathing zone samples. For each of the two building
demolitions, samples were collected during the demolition sampling periods to calculate the
time-weighted average (TWA) concentration for comparison to the OSHA Permissible Exposure
Limit for Asbestos (29 CFR §1926.1101) and lead (29 CFR §1926.62). The samplers ran the
entire time the individual was performing the specific assigned task. For example, the samplers
for the truck drivers operated from the time they came on site until they left the site (or the
landfill) for the day. The samplers operated during transit between the demolition site and the
landfill.
33
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4.1.3.3.4 Personal Breathing Zone Activity Sampling
It was felt that -^walker samples" would provide additional insight to complement the data from
the perimeter samplers surrounding the demolition. These walker samplers were placed in the
breathing zone of individuals who maintained the sampling stations both in Ring 1 and in Ring 2.
4.1.3.4 Soil Sampling
There were five soil sampling events. Baseline soil samples were collected prior to abatement of
the NESHAP Method building and prior to demolition of the AACM building. Following
demolition, all demolition debris was removed from each building site and soil samples were
then collected. In the case of the AACM, approximately the top two to three inches of soil were
then excavated and removed from the site and an additional set of soil samples collected. The
comparison of asbestos soil concentrations between the two methods was based on the post-
demolition samples for the NESHAP Method vs. the post-excavation samples for the AACM.
For each of the soil sampling events described above, the area within the containment berm was
evenly divided into a ten-block grid system. Each block was approximately 32 ft by 35 ft. Three
random grab samples were collected from each block and composited to form an interleaved"
composite to represent the entire footprint of the bermed area. This process was repeated ten
times to provide ten Interleaved" composite samples. Each of the ten interleaved samples was
therefore a composite of 30 grab samples, three from random locations in each of the ten blocks
of the grid. The entire sampling process produced ten final interleaved composites from 300
grab samples. The sampling grid for the NESHAP Method building and AACM building is
shown in Figure 4-2.
For each sampling event, ten composite samples were submitted to the laboratory and analyzed
by PLM and TEM. For each sampling event, three of the ten composites were also submitted for
analysis using the elutriation method. The elutriator samples were collected to provide additional
information on the potential asbestos soil contamination by providing a measure of the asbestos
concentration in respirable dust in the soils.
4.1.4 Water for Wetting Structure and Demolition Debris
4.1.4.1 Source Water
Measurements were taken of the asbestos concentrations of the source water from a flushed fire
hydrant applied to control the particulate emissions during demolition and debris loading of the
NESHAP Method and AACM buildings. A source water sample was collected at both the
commencement and completion of the demolition activities.
34
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4.1.4.2 Amended Water
Samples of the wetting agent used to prepare the amended water used in the AACM demolition
were collected and analyzed for asbestos.
4.1.4.3 Surface Water from Demolition
As described in Section 1, Exhibit 1, earthen containment berms were constructed to trap water
runoff during demolition and debris loading of the NESHAP and AACM buildings.
Representative samples of surface water were intended to be collected during the demolition
activity for both the NESHAP and AACM buildings. Drainage channels were constructed to
direct water runoff for collection in plastic fabricated basins located within the containment
berm. These channels were small in size, constructed of impervious material, and were only
intended to ensure some collection of runoff, not to divert flow. This was intended to have
minimal impact on soil permeation. The sampling of the collected runoff water was spaced over
the duration of the demolition activity. Sample collection volumes were noted as a function of
time and as a function of the progression of the demolition. No water runoff occurred during
demolition of the NESHAP building.
4.1.5 Landfill
4.1.5.1 Background Air Sampling at Landfill
Air sampling was conducted prior to disposal of any materials from the NESHAP and AACM
buildings to collect data necessary for potential comparison of air concentrations of asbestos and
total fibers during disposal. The sampling was conducted prior to disposal of the respective
waste materials. The target air volume for an eight-hour sample at a flow rate of four liter/min
was 1,920 liters.
The air monitoring network for the background data consisted of one ring of six fixed-station
perimeter samplers. The samplers were placed at 60-degree intervals measured along a radius
from the center of the debris landfilling area. The samplers were placed as close to the disposal
area as feasible (the goal was 15 feet from the activity) and at a height of five feet above ground.
4.1.5.2 Air Sampling During Landfilling of NESHAP Drummed ACM
During landfilling of the drummed ACM from abatement of the NESHAP building, the air was
sampled to determine whether this activity released airborne asbestos fibers. The activity took
approximately 30 minutes per load of drummed ACM. The bulldozer operator was fitted with a
personal sampling pump which operated only during the period when the drummed ACM was
being dumped and covered. In addition, fixed-station area samples were positioned in the cab
and on the exterior of the cab of the bulldozer as backups for the personal breathing zone
samples for asbestos analysis. The duration of the sampling integrated the ACM dumping
35
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activities over the nine days of abatement. The samples were collected at a flow rate of one
liter/min for an estimated air volume of 810 liters.
4.1.5.3 Work Area Sampling during Landfilling of Demolition Debris
Personal breathing zone samples were collected from the bulldozer operator involved with the
landfilling of the demolition debris. Personal samples for asbestos and total fibers were collected
to calculate the time-weighted average concentration for comparison to the OSHA Permissible
Exposure Limit (PEL) for Asbestos. In addition, a fixed-station area sample was positioned in
the cab of the same bulldozer as a backup for total asbestos analysis. Personal samples for lead
were also collected on the bulldozer operator each day of the landfilling activity for comparison
to the PEL for lead (29 CFR §1926.62).
4.1.5.4 Perimeter Air Asbestos and Total Fiber Sampling During Landfilling of
Demolition Debris
Air samples were collected for asbestos and total fibers during landfilling of the demolition
debris from the NESHAP and AACM buildings.
The perimeter air sampling network consisted of one ring of samplers. The goal was to place the
samplers at 40-degree intervals measured along a radius from the center of the asbestos
landfilling activity as site conditions permitted, i.e., site topography and other ongoing landfilling
activities. The samplers were placed at a height of five feet above ground and approximately 15
feet from the activity, or as close to that as possible. All samples had a target air volume of
1,920 to 2,400 liters.
4.2 Abatement of the NESHAP Building
The first phase of the NESHAP demolition was the abatement. Prior to demolition of the
NESHAP Method building (#3602), all of the gypsum wallboard and glazing compound
(windows and doors) were removed in accordance with the technical specifications for asbestos
abatement prepared by an ADEQ-licensed asbestos project designer, Environmental Enterprise
Group, Inc (EEG) (Smith, November 2005). The RACM was meticulously removed under full
containment, loaded into barrels, and sealed for transport to the landfill by an ADEQ-licensed
asbestos abatement contractor (Gerken Environmental Enterprises Inc.) in accordance with the
Arkansas Pollution Control and Ecology Commission Regulation 21 (A.C.A. §20-27-1001 and
§8-4-11 et sea). The vinyl asbestos tile and asbestos-containing linoleum were left in place.
This effort began on April 10 and continued for nine working days, with the completion and final
acceptance on April 18, 2006. During this time, workers were monitored for asbestos (TEM) as
well as total fibers (PCM) and lead for OSHA compliance. At the completion of the removal, the
interior of the building was locked down with latex paint as an encapsulant and then final
acceptance samples were collected in accordance with ADEQ requirements (PCM).
36
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Throughout the period of the abatement, air discharges from the HEP A-filtration units were
monitored for asbestos using isokinetic sampling and analysis by TEM. Although not normal
industry practice, a new high-efficiency particulate air (HEPA) filter was used in each HEPA-
filtration unit during the abatement of the NESHAP building.
The abatement process took nine days (4/10 to 4/18), the crew size ranged from seven to ten with
a mean of nine workers, and the process required an abatement team commitment of 823 man-
hours or 103 man-days. Visual inpection and clearance testing by PCM was completed at the end
of the abatement process, The site passed both tests but those data are not presented in this
document because they were not governed by the EPA QAPP.
The EPA and contractor staff inspected the abated area following acceptance and commented
that this was a rigorous application of the NESHAP process. Figure 4-3 through Figure 4-7
illustrate the condition of the building during and after abatement and Figure 4-8 shows disposal
at the landfill.
Figure 4-3. Wetting and removal of drywall during abatement of NESHAP building.
37
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Figure 4-4. Loading abated material into barrels
Figure 4-5. Loading asbestos-containing material into roll-off container.
38
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Figure 4-6. Abated area after application of encaosulant
111 III I
II! « i
Figure 4-7. Abated area after final clearance.
39
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Figure 4-8. Covering abatement debris at the landfill.
4.3 Site Preparation
4.3.1 Surface Water Control
For this study, separate earthen containment berms were constructed surrounding the NESHAP
building and the AACM building. The location of these coincided with the location of the inner
ring of samplers: i.e., about 15 ft from the buildings on three sides and 25 ft from the buildings
on the front (north) side (to permit haul truck access). Water within the containment berm was
captured, filtered through a 50-|im pre- and 5-|im final filters, stored in a 2,400 gallon tank, and
then transported and discharged to the Fort Smith Wastewater treatment Plant. Figures 4-9
through 4-11 illustrate the surface water control system. No surface water formed pools of a size
sufficient to sample during the demolition of the NESHAP building. Figure 4-10 illustrates the
pooling which occurred during the AACM building demolition.
40
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Figure 4-9. Pooled surface water collection sumo.
Figure 4-10. Water accumulation near the berm during the AACM demolition.
41
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Figure 4-11. Water filtration system and holding tank.
4.3.2 Sampling Network
The sampling stations were located on 3-in schedule 40 polyvinyl chloride (PVC) poles inserted
into a 4-in PVC schedule 40 PVC standpipe imbedded in concrete. A pulley/rope system was
used to position the 15-ft sample cassette at the desired elevation. The five-ft high sampling
cassettes were attached to the standpipe using eyebolts. The settled dust samplers were affixed
to the standpipe with cable ties.
The asbestos sampling cassettes were connected to the 1/10 hp, 110 VAC pumps using Tygon®
tubing. Electrical service to each sampling station was provided by underground conduit. Nine
sampling stations were connected to each 20-amp circuit. No two adjacent stations were on the
same circuit to prevent wholesale loss of samples. In addition, constant flow, battery-powered
vacuum pumps were used to collect total particulate. All pumps were placed on a wooden table
affixed to the standpipe. Figure 4-12 through Figure 4-15 show the sampling stations in Ring 1
and Ring 2.
42
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Figure 4-12. Sampling stations at Ring 1 and Ring 2.
Figure 4-13. The five-ft high sampling array on the inner ring (Ring One).
43
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Figure 4-14. Red band denotes NESHAP building; a green band seen in other photos denotes
AACM building. Rl denotes Ring 1 and Ml monitoring Location 1. Two pumps support filters
at five-ft height and one at 15-ft height. Samplers were numbered in clockwise order, with
sample #1 located at front (north) right (west) side of building. The same nomenclature applied
to Ring 2, but with samplers only at five-ft height.
Figure 4-15. Pre-calibrated rotameters with sight gauges set at two and four liter/min.
44
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4.3.3 Cross-contamination control
To prevent potential cross-contamination of the AACM building as well as the soil within its
containment berm during demolition of the NESHAP building, the AACM building and
associated bermed area were covered with six-mil polyethylene sheeting as illustrated in Figure
4-16.
Figure 4-16. Preparation of site prior to demolition of NESHAP Method building (left).
4.4 Planned demolition and disposal of buildings
The NESHAP Method building (#3602) was 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-34071-92-013, September 1992). The AACM building (#3607)
was demolished using the demolition practices specified in the -Alternative Asbestos Control
Method" contained in SECTION 1, Exhibit 1. The NESHAP Method building was demolished
first (including removal of the foundation and all associated debris) and then the AACM building
was demolished.
To reduce the number of variables involved in the comparison and to evaluate the NESHAP
Method under optimum and ideal conditions, certain practices were specifically required for the
NESHAP process that are not normal industry practice:
• Demolition equipment was identical to that used for the AACM building. It is not likely
that the demolition equipment used on the NESHAP would have been used if not
prescribed in this test. The demolition contractor stated that it would have been more
typical to use a bulldozer to knock the structure down, run over it repeatedly to compact
it, and then using an end loader to fill the unlined trucks.
• Demolition debris disposal vehicles were washed before leaving the NESHAP building
demolition site. This too is not normal industry practice.
In addition, the bulldozer at the landfill was washed prior to the disposal of the debris from both
demolitions to prevent cross-contamination.
45
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4.4.1 NESHAP demolition and disposal
The demolition began on April 26, 2006 and was completed the same day, rather than the two
days that had originally been envisioned. No significant problems were encountered during this
demolition.
A Caterpillar 330BL track-hoe was used for demolition and for debris loading. A single water
spray (about 30-gpm maximum) was used to control fugitive dust emissions. A single visible
emission was observed, but it was during the removal of a concrete foundation and did not
constitute an emission from ACM. No water pooled within the bermed area and therefore it was
not possible to obtain samples of the water resulting from wetting the building. The debris was
disposed as construction and demolition debris (C&D) in unlined trucks. Some soil was removed
during the NESHAP demolition and debris cleanup as an inevitable result of the operation of the
track-hoe.
Figure 4-17 through Figure 4-20 illustrate the demolition process. Based on a negative exposure
assessment using objective data obtained by OSHA, neither respiratory protection nor protective
garments were required during the demolition of the NESHAP building.
Soil sampling was conducted following the demolition, site cleanup, and grading. Soil sampling
proved to be an onerous task, requiring about four hours to collect the required composite
samples.
46
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Figure 4-17. Starting demolition of the NESHAP building.
Figure 4-18. Loading NESHAP debris into trucks.
47
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Figure 4-19. Finishing NESHAP demolition
Figure 4-20. Aerial view showing NESHAP building nearly demolished.
48
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4.4.2 AACM demolition and disposal
Prior to demolition of the AACM building (#3607), no asbestos-containing materials were
removed; however in 1999 as previously noted, there was removal of thermal system insulation
(pipe wrap) beneath both buildings.
4.4.2.1 Amended Water System
Amended water is water to which a surfactant (wetting agent) has been added to improve the
penetrating capability of water. The surfactant reduces the surface tension of the water which
allows it to penetrate a material where water might normally run off, to reach interior spaces of
materials. For this study, the chosen surfactant was a Kidde Fire Fighting NF-3000 Class -A"
Foam Concentrate, as shown on Figure 4-21. Foaming ingredients give water the ability to
adhere to vertical surfaces, which allows the water longer contact with the surface. The material
safety data sheet (#NFC970) for NF-3000 is contained in the appendix.. This wetting agent is
similar to Kidde Fire Fighting product Knockdown® that is used by firefighters to aid in
extinguishing a fire.
The NF-3000 wetting agent was added to achieve target application strength of one percent
concentration. For this study, a one-percent concentration was used to ensure adequate
proportioning and provide confidence that sufficient wetting agent was always present in the
application of amended water. According to the manufacturer, the surfactant is effective at
significantly lower concentrations. Optimizing the application concentration was not a research
goal of this project.
Figure 4-21. Wetting agent supply tank for the AACM demolition.
49
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The system layout consisted of a flush hydrant equipped with a water meter, gasoline-powered
portable-water pump, nitrile rubber weave construction fire hose, ball shutoff nozzle, and in-line
foam eductor system. To ensure accurate proportioning (one-percent solution) of the NF-3000
wetting agent, the target operating pressure at the gauge on the inlet to the eductor was 200 psi
(range 175 to 225 psi). To assure adequate proportioning, the nozzles were operated in a full-
open position. The system was designed and supplied by Kidde Fire Fighting of National Foam
Inc. The pump system employed in this study was used for the purpose of the research effort
only, and it is not anticipated to be required in any real-world application of the AACM process.
It is expected that simple and low-cost in-line eductors operating at typical hydrant pressures
would suffice.
The wetting agent application system used during the pre-wetting of the building consisted of a
single 90-gpm high-foaming nozzle and matching eductor. This system provided the best foam
quality, but had less application range. That is, the maximum reach of the foam from the 90-gpm
nozzle was approximately 30 feet, which would not be adequate during demolition of the
building.
The wetting agent application system used during demolition employed two matched 30-gpm
non-aspirating variable-pattern nozzles and matching in-line eductor (30 gpm at 200 psi design
pressure).
Wetting agent proportioning was verified by performing periodic conductivity measurements of
the application flow throughout the duration of the AACM demolition process. According to the
National Fire Protection Association (NFPA) Standard for Low-, Medium, and High-Expansion
Foam (NFPA 11, 2005 Edition), there are two acceptable methods for measuring the wetting
agent concentrate in water: (1) Refractive Index Method and (2) Conductivity Method. Both
methods are based on generating a baseline calibration curve comparing percent concentrations
(of pre-measured foam solutions) to the instrument reading. The method selected for the NF-
3000 solution concentration determination for this study was the conductivity method.
As stated previously, the target application strength of the NF-3000 wetting agent was
approximately one percent. Therefore, following the procedures contained in the NFPA 11
Standard using the Conductivity Method, three standard solutions were prepared using the
hydrant water and the foam concentrate from the application system. The percent concentrations
for the three standards were 0.5, 1, and 1.5 based on a target concentration of one percent. The
conductivity of each foam solution standard was then measured and a plot created of the foam
concentration versus conductivity. Figure 4-22 shows the plot serving as the baseline calibration
curve for the test series.
Throughout the duration of the AACM demolition activities, the concentration of the wetting
agent was monitored by taking conductivity measurements at a minimum of every four hours as
recommended by Kidde Fire Fighting. Sample collection took place after water flowed for
enough time to assure a good sample. The real-time sample conductivity measurements were
compared with the baseline calibration curve (conductivity versus concentration) shown in
Figure 4-22. A summary of the conductivity monitoring is presented in Table 4-4. With the
exception of two instances, the resulting concentrations based on conductivity measurements of
the application flow show that foam concentrations ranged from 0.81 to 1.26 percent as
50
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compared to a target concentration of one percent. This was well within the calibration range of
0.5 to 1.5 percent.
Concentration (%)
Figure 4-22. Calibration Curve for the NF-3000 Wetting Agent.
Table 4-4. Summary of NF-3000 Quality Monitoring During AACM Demolition Activities.
Date
5/1/06
5/1/06
5/1/06
5/1/06
5/1/06
5/1/06
5/1/06
5/2/06
Time of
Measurement
(hours)
0743 (L1,L2)
0821 (L1,L2)
0838
1042
(Ll,L2)c'd
1104(Ll,L2)e
1529 (LI)
1523 (L2)
1740 (LI)
1742 (L2)
1448
Number
of
Nozzles/
Flow
Rate,
gpm
Two/30
Two/30
One/90
Two/30
Two/30
Two/30
Two/30
One/90
Conductivity,
mS
NF-3000
Concentration
(%) a
Line 1
0.751
0.114
0.728
0.630
0.696
0.528
0.741
0.555
1.26
b
1.21
1.02
1.15
0.81
1.24
0.87
Conductivity,
mS
NF-3000
Cone a (%)
Line 2
0.749
0.114
1.26
b
N/A
0.135
0.648
0.689
0.684
0.02
1.05
1.14
1.13
N/A
a Concentration was calculated based on the calibration curve (conductivity versus concentration) generated for the
NF-3000 wetting agent and measured conductivity readings throughout the AACM demolition activities.
b Measurements taken at 0821 hours on 5/1/06 indicated problems with the 30-gpm (1.5-inch line) eductors causing
non-foam proportioning. The two 30-gpm lines were replaced with the alternate 90-gpm foam nozzle and in-line
eductor while investigating the problem.
0 30-gpm (1.5-inch line) eductors back in use, replacing the alternate 90-gpm foam nozzle and in-line eductor.
dMeasurements taken at 1042 hours on 5/1/06 indicated that the Line 1 (30-gpm) eductor was working properly (as
evidenced by the resulting conductivity and concentration readings); however measurements from the Line 2
eductor showed non-foam proportioning. Samples from both lines were retaken at 1104 hours.
e Measurements retaken at 1104 hours on 5/1/06 indicated that both 30-gpm eductors were operating properly (as
evidenced by the resulting conductivity and concentration readings). It was speculated that the non-foam
proportioning occurring with Line 2 at 1042 hours was due to the nozzle not being fully opened during operation.
51
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4.4.2.2 AACM Pre-Wetting
The AACM building (#3607) was pre-wetted on April 30, 2006, the evening before the
demolition. The interior of the building was wetted first using the 90-gpm foaming nozzle
(Figure 4-23 through Figure 4-27). This part of the pre-wetting process required 17 minutes.
Respiratory protection was worn by the worker because of the mild acute irritancy of the
amended water. After the interior was wetted, the amended water was applied to the attic,
alternately through the gable vents at both ends of the building. The attic wetting took about 22
minutes per gable or 45 minutes total for the attic. The amended water was quite effective in
soaking through the drywall joints, particularly in the ceiling. By the next morning (about 12
hours later), several sections of drywall ceiling had collapsed into the rooms.
On the day of the demolition (May 1, 2006), the attic was rewetted through the gables with the
amended water (taking about seven minute per gable or 15 minutes total) and the interior of the
structure was re-wetted by knocking out the windows and spraying the rooms from the exterior
(requiring an extra ten minutes). The 90-gpm foaming nozzle was used for this rewetting. Figure
4-28 illustrates this process. The amended water was dripping from several areas beneath the
building and from beneath the doors.
In total, the pre-wetting process required roughly an hour (62 minutes) on the day before the
demolition and a half-hour (25 minutes) on the day of the demolition.
4.4.2.3 AACM Demolition Phase
The demolition of the AACM building was conducted on May 1, 2006. Amended water was
used continuously during the demolition and truck-loading operations. Two 30-gpm nozzles
were used to apply the amended water during demolition of the building and debris loading
activities. A standard garden hose (approximately four gpm of hydrant water) was used to wash
the trucks before they left the containment (bermed) area.
The trucks hauling the AACM debris to the landfill were lined with two layers of six-mil
polyethylene. This lining process took about five minutes per truck.
After loading of the debris, the two layers of plastic were folded together over the top of the
truck bed and sealed with tape into a burrito-wrap configuration. This closing and sealing
process required an average of approximately seven minutes per truck.
Some brief but easily surmountable complications were encountered during this AACM
demolition. First, the application rate of the wetting agent during the first 15 to 30 minutes of the
demolition was indeterminable because a leak developed in the wetting agent eductor for the 30-
gpm nozzles, breaking the suction on the eductor. The 90-gpm nozzle was substituted for the two
30-gpm nozzles for about a 30-min period of demolition, until the cause of the leak could be
remedied (tightened the nozzles as they were drawing air rather than wetting agent) and the two
52
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Figure 4-23. Pre-wetting with Amended Water.
•
Figure 4-24. Pre-wetting the hallway with Amended Water.
53
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Figure 4-25. Pre-wetting the attic with Amended Water.
mm mum
Figure 4-26. Amended Water seeping through ceiling drywall joints.
54
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Figure 4-27. Amended Water seeping through wall openings.
Figure 4-28. Wetting through openings on the day of the AACM demolition.
55
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30-gpm nozzles and matched eductor were returned to service. Secondly, about a one-hour delay
was encountered while resolving paper manifest issues with the trucks hauling the debris to the
landfill. During this delay, the pump overheated because no water was flowing and ruptured a
plastic pressure line. This was repaired on site in about 15 minutes. Demolition was halted
during these periods.
There were several periods where the demolition was halted awaiting trucks to return from the
landfill as several previous days of rain at the landfill caused the first truck in line to get stuck.
The AACM building was demolished by approximately 6:00 pm of the first day (May 1) and the
concrete piers were removed, washed, and stockpiled at the site, leaving a single concrete
box/pier and a small amount of residual debris to be removed the following day.
On the following day (May 2), it rained in the morning so all work was halted. In the afternoon,
the remaining stockpiled concrete, the concrete box/pier, and the small debris were removed
from the site and taken to the landfill. The post-demolition soil sampling was completed, which
required about four hours. The amended water was extremely effective in wetting the soil and
keeping it wet, making soil sampling quite difficult.
Also, some pooled water had saturated the berm and seeped below it in a couple of spots and
created a wetted area about four feet outside the berm on the downhill side (rear) of the site. This
water was sampled.
The morning rain, which re-wetted the area, made soil sampling increasingly difficult. This
extended the time required for post-demolition soil sampling and delayed the final soil
excavation until the following day (May 3). The soil excavation took approximately two hours
and then the post-excavation soil sampling was conducted, taking almost five additional hours to
complete.
No visible emissions were observed during the entire AACM demolition/soil removal process.
If soil sampling and the aforementioned complications had not delayed the project, the
demolition and soil removal for the AACM building would have been completed in a single day,
taking a couple of hours longer than the demolition of the NESHAP building.
Under normal circumstances, the extra time to implement the AACM would include:
* lining the trucks (five minutes/truck),
* sealing the burrito wrap (seven minutes/truck), and
* excavating/removing the soil (approximately two hours).
Figure 4-29 through Figure 4-37 document the AACM demolition process.
56
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Figure 4-29. Double-lining the trucks for hauling of the AACM debris (View 1).
Figure 4-30. Double-lining the trucks for hauling of the AACM debris (View 2).
57
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Figure 4-31. Starting the AACM demolition.
Figure 4-32. Progressing with the AACM demolition.
58
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Figure 4-33. Loading the AACM demolition debris.
Figure 4-34. Sealing the -burrito wrap" before leaving the AACM site.
59
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Figure 4-35. Washing the trucks with water before leaving the site.
Figure 4-36. Nearing the completion of the AACM demolition.
60
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Figure 4-37. An aerial view nearing completion of the A ACM demolition.
61
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62
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SECTION 5 SAMPLING AND ANALYTICAL METHODOLOGY
5.1 Sampling Method Requirements
5.1.1 Perimeter Air Sampling for Asbestos/Total Fibers
The samples for both asbestos and total fibers analysis were collected on the same open-face, 25-
mm-diameter 0.45-|im pore size mixed cellulose ester (MCE) filters with a 5-|im pore size MCE
diffusing filter and cellulose support pad contained in a three-piece cassette with a 50-mm
conductive cowl. This design of cassette has a longer cowl than the design specified in ISO
10312:1995, but it has been in general use for some years for ambient and indoor air sampling.
Disposable filter cassettes with shorter conductive cowls, loaded with the appropriate
combination of filter media of known and consistent origin, do not appear to be generally
available.
The filter cassettes were positioned on a sampling pole that accommodated cassette placement at
five feet and 15 feet above ground. The filter face was positioned at approximately a 45-degree
angle toward the ground. At the end of the sampling period, the filters were turned upright
before being disconnected from the vacuum pump, capped, and then stored in this position.
The filter assembly was attached with flexible Tygon® tubing (or an equivalent material) to an
electric-powered (110-volt alternating current) 1/10-hp vacuum pump operating at an airflow
rate of approximately four liter/min. An air volume of 1,920 to 2,400 liters was targeted for all
samples. Each pump was equipped with a flow-control regulator and individually-calibrated
rotameter to measure and maintain the initial flow rate of four liter/min to within +/- 10%
throughout the sampling period. The target flow rate for each pump was demarcated on the
rotameter, checked approximately every two hours throughout the sampling period, and adjusted
if required. Lower volume samples (960-1,200 liters) from the same locations were also
collected and archived.
5.1.2 Personal Breathing Zone and Work Area Sampling for Asbestos/Total
Fibers and Lead
Asbestos/Total Fibers—Personal breathing zone and work area samples were collected on open-
face, 25-mm-diameter 0.8-|im pore size MCE filters with a cellulose support pad contained in a
3-piece cassette with a 50-mm conductive cowl. The filter assembly was attached to a constant-
flow, battery-powered vacuum pump operating at a flow rate of either one or two liters per
minute. An air volume of approximately 480 to 960 liters was targeted for these samples.
Lead—Personal breathing zone and work area samples were collected on closed-face, 37-mm-
diameter 0.8-|im pore size MCE filters with a cellulose support pad contained in a three-piece
cassette. The filter assembly was attached to a constant-flow, battery-powered vacuum pump
operating at a flow rate of two liter/min. An air volume of 960 to 1,200 liters was targeted for
these samples.
63
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5.1.3 Total Particulate Sampling
Fixed-station area air samples were collected on closed-face, tared 37-mm diameter 5-|im pore
size poly vinyl chloride (PVC) filters with a cellulose support pad contained in a three-piece
cassette. The filter assembly was attached to a constant-flow, battery-powered vacuum pump
operating at a flow rate of two liters per minute. An air volume of 960 to 1,200 liters was
targeted for all samples.
5.1.4 Meteorological Monitoring
Two portable meteorological stations manufactured by Met One Instruments, Inc., and equipped
with AutoMet Sensors (or equivalent instruments) were used to record five-minute average wind
speed and wind direction data, as well as temperature, barometric pressure, and relative
humidity. A meteorological station was installed at both the Fort Chaffee demolition site and the
City of Fort Smith Landfill. The data files were downloaded and archived using an on-site
personal computer. Periodic (at least hourly) direct readout of the data was recorded on a
Meteorological Measurement Log. The wind speed and wind direction sensors of the
meteorological station located at the landfill malfunctioned during the study. Fortunately, the
Fort Smith Airport Weather Station was about 1000 ft away and the meteorological data were
obtained from this station and were used for the disposal portion of the study.
5.1.5 Asbestos Soil Sampling
For each of the soil sampling events described previously, the area within the containment berm
was evenly divided into a ten-block grid system. Each block was approximately 35 ft by 32 ft.
Three random grab samples were collected from each block and composited to form an
Interleaved" composite to represent the entire footprint of the bermed area. This process was
repeated ten times to provide ten interleaved" composite samples. Each of the ten interleaved
samples was therefore a composite of 30 grab samples; the entire sampling process produced ten
final interleaved composites from 300 grab samples. Each grab sample was collected from an
area measuring six-inches by six-inches with approximately a %-inch depth. The area was
delineated using a metal template, which helped ensure that each component of the ten-part
composite sample was of similar mass. Rocks and organic material (e.g., roots) larger than Ys-
inch were excluded.
The grab samples were collected using a clean metal scooping tool (e.g., a garden trowel) and
placed in a clean one-gallon metal container with lid (Figure 5-1). The 30 grab samples were
composited in a two-gal plastic container for shipment to the laboratory. Between collections of
each sample, the template and trowel were cleaned with detergent water.
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Figure 5-1. Soil sampling after the NESHAP demolition.
5.1.6 Settled Dust Sampling
Settled dust samples for asbestos analysis were passively collected using ASTM Method D
1739-98 "Methodfor Collection and Measurement ofDustfall (Settleable Paniculate Matter). "
The collection container was an open-topped cylinder approximately six inches in diameter with
a height of 12 inches. The container was fastened to the same sampling pole as the air samples at
a height of five feet above the ground. The sampling time for the ASTM protocol was extended
one hour beyond the end of demolition activity. Upon completion of sampling, the dust
collection container was capped and sealed for shipment to the laboratory.
5.1.7 Water Sampling—Flush Hydrant, Amended Water, and Pooled
Surface Water
The sample container was an unused, one-liter pre-cleaned, screw-capped amber glass bottle.
Prior to sample collection, the water from the water source was allowed to run for a sufficient
period to ensure that the sample collected was representative of the source water.
Approximately 800 milliliters of water for each sample were collected. An air space was left in
the bottle to allow efficient re-dispersal of settled material before analysis. A second bottle was
65
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Figure 5-2. Sampling pooled water.
collected and stored for analysis if confirmation of the results obtained from the analysis of the
first bottle was required.
The samples were transported to the laboratory and filtered by the laboratory within 48 hours of
sample collection. No preservatives or acids were added. At all times after collection, the
samples were stored in the dark at about 5° C (41° F) in order to minimize bacterial and algal
growth. The samples were not allowed to freeze because the effects on asbestos fiber dispersions
are not known. On the same day of collection, the samples were shipped in a cooler at about 5°
C (41° F) to the lab for analysis via one-day courier service. Figure 5-2 shows the collection of
pooled water.
5.2 Analytical Methods
5.2.1 Air Samples (TEM)
Perimeter Samples—The 0.45-|im pore size MCE air sampling filters were prepared and
analyzed 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 was then analyzed using PCM.
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Personal Samples— The 0.8-|im pore size MCE air sampling filters were prepared and analyzed
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 was then analyzed using PCM.
5.2.1.1 TEM Specimen Preparation
TEM specimens were prepared from the air filters using the dimethylformamide (DMF)
collapsing procedure of ISO 10312:1995, as specified for cellulose ester filters. DMF was used
as the solvent for dissolution of the filter in the Jaffe washer. For each filter, a minimum of three
TEM specimen grids were prepared from a one-quarter sector of the filter using 200 mesh-
indexed copper grids. The remaining part of the filter was archived in the original cassette in
clean and secure storage.
5.2.1.2 Measurement Strategy
1. The minimum aspect ratio for the analyses was 3:1, as permitted by ISO 10312:1995. As
required in the ISO method, any identified compact clusters and compact matrices were
counted as total asbestos structures, even if the 3:1 aspect ratio was not met.
2. Table 5-1 presents the size ranges of structures that were evaluated, and target analytical
sensitivities for each TEM method. The laboratories adjusted individual numbers of grid
openings counted based upon the counting rules, the amount of material prepared for
each sample, and the air volume, as applicable.
3. The structure counting data was distributed approximately equally among a minimum of
three specimen grids prepared from different parts of the filter sector.
4. The TEM specimen examinations were performed at approximately 20,000x
magnification.
5. PCM-equivalent asbestos structures, as defined by ISO 10312:1995, were also
determined.
6. The type of structure was specified. In addition to classifying structures as one of the six
NESHAP-regulated asbestos types, any other amphibole mineral particles meeting the
aspect ratio of >3:1 and lengths >0.5 um) were required to be recorded, if present (e.g.,
winchite, richterite) However, none of these non-regulated amphiboles were
observed. Reference to or implication of use of either of the terms cleavage fragments
and/or discriminatory counting did not apply.
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Table 5-1. Number of TEM grid openings to achieve target analytical sensitivity.
Method
ISO
10312:1995
Perimeter
Air
Direct
Preparation
ISO
10312:1995
Worker Air
Direct
Preparation
EPA/600/R-
93/1 16
-X ~J/ 1 1 w,
1993 Soil
ASTMD
5755-03 -
Settled Dust
EPA 100.2
Water, Flush
Hydrant, and
Pooled
Surface
Water
Structure
Size Range
All
Structures
(minimum
length of
0.5 pm;
aspect ratio
All Fibers
(minimum
length of
0.5 pm;
aspect ratio
All
Structures
(minimum
length of
0.5 um;
aspect ratio
All
Structures
(minimum
length of
0.5 pm;
aspect ratio
All
Structures
(minimum
length of
0.5 pm;
aspect ratio
Target
Analytical
Sensitivity
0.0005 s/cc
0.005 f/cc
0.1%
250 s/cm2
0.05
million s/L
Hydrant
2 million
s/L Surface
Approximate
Magnification
for
Examination
20,000x
10,000x
20,000x
20,000x
20,000x
Approximate
Grid Area
Examined,
mm2
0.32 based on
air Volume of
2,400 L
0.1 6 based on
air Volume of
480 L
0.1
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-mm2 Grid
Openings
Required
32
16
10
10
37
46
68
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5.2.1.3 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 grid openings or fields 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 5-2
identifies the stopping rules used for this study.
Table 5-2. Stopping rules for asbestos counting.
Method
Stopping Rules
TEM (ISO 10312:1995)
Perimeter air
Count a minimum of 10 grid openings. If >10 structures are
identified, counting is stopped. If < 10 structures are identified,
count until 10 structures are identified or the required number of grid
openings to achieve an analytical sensitivity of 0.0005 asbestos
structures/cm3.
TEM (ISO 10312:1995)
Worker air
Count a minimum of 10 grid openings. If >10 structures are
identified, counting is stopped. If < 10 structures are identified,
count until 10 structures are identified or the required number of grid
openings to achieve an analytical sensitivity of 0.005 asbestos
structures/cm3.
PCM (NIOSH 7400)
Perimeter air
100 fields are viewed or 100 fibers are counted (but not less than 10
fields must be counted).
EPA/600/R-93/116,
1993
Soil
TEM~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.
PLM—Sample is point counted until 0.1% sensitivity has been
achieved.
ASTMD 5755-03
Settled Dust
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 grid opening evaluated.
EPA 100.2
Water
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 grid opening evaluated.
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5.2.2 Air Samples (PCM)
Perimeter Samples—The 0.45-|im pore size MCE air sampling filters were prepared and
analyzed for total fibers using NIOSH Method 7400 -Asbestos Fibers by PCM" (A Counting
Rules). Fibers greater than five jim in length and with an aspect ratio greater than 3:1 were
counted.
Personal Samples—0.8-|im pore size MCE air sampling filters were prepared and analyzed for
total fibers using NIOSH Method 7400 -Asbestos Fibers by PCM" (A Counting Rules). Fibers
greater than 5 jim in length and with an aspect ratio greater than 3:1 were counted.
The applicable stopping rules in Section 5.2.1.3 were used.
5.2.3 Air Samples (Lead)
The 0.8-|im pore size MCE air sampling filters were prepared and analyzed for inorganic lead
using NIOSH Method 7300 -Elements by ICP (Nitric/Perchloric Acid Ashing). "
5.2.4 Soil Samples
5.2.4.1 Soil Preparation
The composite soil samples were shipped to the laboratory where the samples were dried,
homogenized, and evenly split for total asbestos analysis (PLM and TEM) and for soil elutriation
tests.
The laboratory processed the samples as follows:
» All sample preparation was conducted under a negative air ventilation hood with a HEPA
filter. Samples were weighed to the nearest 0. Ig prior to and after the every step of the
preparation process.
• Using ASTM 2540G, moisture content was first determined. Then, using flat dishes, the
sample was spread out as much as possible to maximize surface area. The wet soil was
manually reduced to pieces < % inch in size. Samples were dried in a convection oven at
60°C for a period of 24-48 hours, or until a constant weight was obtained. A constant
weight was determined when less than 4% of the previous weight or O.Smg was lost.
* If necessary, large chunks of the dried soil were reduced to < % inch in size. If rocks or
organics were observed, these were removed and if present the mass and asbestos type
and percentage were documented. If pieces of building materials were observed, these
were removed and analyzed by PLM, and if present the mass and asbestos type and
percentage were documented.
• The remaining sample was transferred to its original clean air-tight heat dried container
until it was transferred to a riffle splitting facility in the Port Orchard EPA laboratory.
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Using the riffle splitter, the sample was distributed into two receiving pans. One pan was
immediately returned to its original container (3A of original). This portion was archived
and stored if reanalysis was necessary. The second pan was further split to create a
portion to be used for elutriation (-one liter in size) and a portion to be used for
PLM/TEM (-one liter in size). Each portion was weighed and its dry weight recorded on
the prep sheet. These portions were coned and quartered to generate optimal sample
sizes for elutriation (-40-60 grams) and PLM/TEM (-20 grams). These sample portions
were transferred to clean airtight bottles.
5.2.4.2 Soil Analysis (TEM and PLM)
Soil samples were prepared and analyzed for asbestos using EPA's -Methodfor the
Determination of Asbestos in Bulk Building Materials'" (EPA/600/R-93/116, July 1993). The
following approach was used to prepare the samples for analysis:
• As described in Section 5.2.4.1, after the samples were dried and homogenized, large
rocks/organics and building debris were removed and weighed. Confirmation of asbestos
type and concentration was done by PLM analysis. Representative portions of the
remaining soil were then prepared for analysis for both PLM and TEM.
• The soil sample was ground and homogenized, using a standard plate grinder, to a
particle size of approximately 250 micrometers. The soil sample was concentrated using
gravimetric reduction by ashing and hydrolysis. A portion of the ground sample was
weighed and ashed in a muffle furnace for one hour at 250°C and for four hours at 480°C.
After weighing the ashed sample, it was then hydrolyzed in concentrated hydrochloric
acid, ground lightly for one minute using a mortar and pestle, filtered onto tared MCE
filters, and weighed. The gravimetric reduction ratio (GRR) was calculated.
A representative portion of the residue was point-counted using PLM by placing it on a slide,
and counting until 0.1-weight percent sensitivity was achieved (1000 points).
Another representative portion of residue was prepared for TEM analysis. The residue was
suspended in water, acidified to approximately pH 3 with acetic acid, hand shaken for 30
seconds, sonicated for three minutes, hand shaken for another 30 seconds, and allowed to settle
for two minutes. A range of aliquots was pipetted onto MCE filters to ensure optimal loading.
The filters were prepared for asbestos analysis using a direct transfer preparation. The required
grid openings were analyzed evenly over a minimum of two grids. Results in structures/gram
(s/g) were reported.
The measurement strategy and stopping rules provided in Section 5.2.1.2 and 5.2.1.3 were used,
as applicable to soils.
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5.2.4.3 Elutriation
Soil samples were prepared as described in EPA 540-2-90-005, ModifiedElutriator Methodfor
the Determination of Asbestos in Soils and Bulk Materials (Revision 1). The elutriated air
samples were analyzed by TEM using ISO Method 10312:1995.
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 fraction4 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 gram of respirable dust (s/gPMio).
5.2.5 Settled Dust Samples (TEM)
The analytical sample preparation and analysis for asbestos followed ASTM Standard D5755-03
-4Aicrovacuum Sampling and Indirect Analysis of Dust by Transmission Electron Microscopy for
Asbestos Structure Number Surface Loading", modified as described in the following discussion.
The sample collection container was rinsed with approximately 100 ml of 50/50 mixture of
particle-free water and reagent alcohol using a plastic wash bottle. The suspension was poured
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 were rinsed through the screen into
the specimen bottle. The washing procedure was repeated three times. The volume of the
suspension in the specimen bottle was brought to 500 ml with particle free water. An aliquot of
this suspension was filtered onto a MCE filter. These filters were prepared and analyzed using
ISO 10312:1995.
The measurement strategy and stopping rules provided in Section 5.2.1.2 and 5.2.1.3 were used,
as applicable to settled dust.
5.2.6 Water Samples
The asbestos content of the water samples was determined using EPA Method 100.2 -Analytical
Method Determination of Asbestos in Water." The method was modified to count all structures
greater than or equal to 0.5 jim in length and with an aspect ratio of greater than or equal to 3:1.
The measurement strategy and stopping rules provided in Section 5.2.1.2 and 5.2.1.3 were used,
as applicable to water
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 -PMi 0" 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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SECTION 6 RESULTS
The results obtained for samples collected during the demolition (Section 6.1) and landfill
activities (Section 6.2) are provided in this section, including process monitoring. Detailed
statistical discussions are provided in Section 7. Only the results from the closest ring of
samplers (Ring 1) were used for the statistical comparisons because modeling indicated that the
samplers closet to the demolition had the highest probability of detecting releases. The cost
analysis is provided in Section 8.
The vast majority of airborne asbestos data yielded non-detects at very low limits of detection. It
was initially anticipated that a value of one-half the analytical sensitivity would be substituted for
those values that were less than the analytical sensitivity. Further comparisons would
then be made substituting additional variants below the analytical sensitivity to evaluate the
effect of the substituted value. Overall, close to 90 percent of the air samples for asbestos during
the demolitions were non-detect at 0.0005 s/cm3 analytical sensitivity. All but one were at or
below the limit of detection of 0.0015 s/cm3 ( 2.99 times the analytical sensitivity); the one
concentration above the limit of detection was 0.0019 s/cm3.
In asbestos analyses, one either sees and counts asbestos structures in a specified number of grid
openings or sees none (zero). In the case of non-detects, zero asbestos structures were seen in
the grid openings observed. The use of one-half the analytical sensitivity would reflect that one-
half of a structure was seen, when in fact, none was seen. In an 18-sample set (as in Ring 1 for
example), the addition of one-half structure per sample for 16 non-detects would artificially add
the observance of eight asbestos structures (again when none were observed); therefore, for the
purpose of descriptive statistics, zero was used for non-detects. For inferential statistical
analyses, the zeros don't adversely affect non-parametric tests which were used in this
evaluation. Also, tests of significance using the -eensored data" approach were considered but
not employed because of the extreme proportion of non-detects (Helsel 2006).
The ISO 10312:1195 protocol suggests reporting conventions for asbestos measurements that
include the 95-percentile upper and lower confidence levels for any observed asbestos structure
count. Table F. 1 in the ISO 10312 suggests the following reporting convention for the structure
counts observed in the air samples in this study as shown in Table 6-1.
Since the lower confidence limits are less than one for structures counts from zero to three, ISO
recommends the use of reporting less than the corresponding one-sided 95-percent confidence
limits rather than the calculated concentration. In this study, the ISO reporting convention was
not strictly adopted as it was believed that reporting the individual observed concentrations was a
more comprehensive approach. With the caveats of ISO reporting methodology, any conclusions
that are based upon counts less than four, as almost all the ones in this study were, should be
used with some caution as there is probably no real difference between these numbers.
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Table 6-1. I
SO 103 12: 1995 Re
Structure Count
0
1
2
3
4
porting Convention for Structure Counts Between Zero and Four
95-% Confidence
Lower Limit
0
0.025
0.242
0.619
1.090
95-%
Confidence
Upper Limit
3.689
5.572
7.225
8.767
10.242
To summarize:
• For descriptive statistics, a value of zero was substituted for non-detects.
• In cases where there were less than five-percent non-detect data and substituting one-half
the analytical sensitivity would not affect the conclusions of the inferential test, the
parametric methods proposed in the QAPP were employed. In those cases, one-half the
analytical sensitivity was used.
• In cases where there were between five- and 90-percent non-detect data, nonparametric
methods based on ranks and adjusted for ties were employed.
• In cases where there were greater than 90-percent non-detect data for either method, no
statistical analyses were conducted.
6.1 Demolitions
6.1.1 Meteorology
Late April-early May weather in Arkansas, like elsewhere, is unpredictable. Rain loomed
throughout the study and the AACM demolition was delayed for several days for the uncertainty
of rain. However, no rain occurred during sampling or demolition of either building. Rain was
encountered one morning following the AACM demolition but prior to the removal of the
concrete structures and small residual debris from the site, which delayed the effort one half day.
The rainfall history during the demolition of the buildings is graphically presented in Figure 6-1.
It is clear that both demolitions had significant rain events of approximately one inch of rainfall
preceding the demolition. The disadvantage that the AACM building had was that it was down-
gradient from the NESHAP building. Therefore, the rain on April 25, plus the wetting during the
NESHAP demolition on April 26, plus the rain on April 28 and 29, saturated the soil for the
AACM building demolition on May 1.
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The wind rose for the NESHAP demolition is shown in Figure 6-2 and the wind roses for the
AACM demolition are presented in Figure 6-3 for the demolition and in Figure 6-4 for the soil
removal as those activities took place on separate days. For each wind rose, the wind is blowing
from the indicated direction. For example, in Figure 6-2, the dominant wind direction is from the
southwest at one to four mph. In general, the winds were mild for all events, generally blowing
from the south/southwest at less than seven mph. The descriptive statistics for wind speed are
presented in Table 6-2.
1.2
1
0.8
0.6
0.4
0.2
0
Rainfall, inches
•
Figure 6-1. Rainfall history at the Fort Chaffee project site during the study.
75
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WIND SPEED
(Knots)
H -= -
, 17-21
^| 11-17
^| 7- 11
^| 4- 7
n --4
Calms: 0 00%
Figure 6-2. Wind rose during the hours of the NESHAP building demolition.
NORTH"'--,,
Figure 6-3. Wind rose during the hours of the AACM building demolition.
76
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NORTH
1
WEST
\
! _.-""
1 * C
\ • _
• \
~™,
11%
k \
EAST
WIND SPEED
(Knots)
i 7-21
H 1-17
t «rm 000%
Figure 6-4. Wind rose during the hours of the AACM building soil removal.
Table 6-2. Descriptive Statistics for Wind Speed
Mean Wind Speed,
mph
Min Wind Speed,
mph
Max Wind Speed,
mph
NESHAP Building - Day 1
3.1
2.3
3.8
AACM Building - Day 1
4.7
2.7
7.1
AACM Building - Day 2
3.6
1.3
3.8
AACM Building - Total for Both Days
4.2
1.3
7.1
6.1.2 Perimeter Air
6.1.2.1 Asbestos in Air Samples
6.1.2.1.1 Backgroun d A ir
All of the background samples showed that the asbestos concentration was below the analytical
sensitivity (<0.00049 s/cm3). The individual sampling results are contained in Table A-4 of
77
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Appendix A. These levels are consistent with the pre-study assessment samples done several
months earlier and shown in the same table.
The Health Effects Research Institute-Asbestos Research (1991) reported -average
concentrations on the order of 0.00001 f/mL for outdoor rural air (except near asbestos-
containing rock outcroppings) and average concentrations up to about 10-fold higher in the
outdoor air of urban environments" for asbestos fibers longer than five microns (essentially
PCME structures). In naturally-occurring asbestos areas such as California, the ambient levels
can range from eight to 80 PCME fibers per cubic meter (0.008 s/cm3) at Sonora to 50 to 500
PCM(E) fibers per cubic meter (0.005 to 0.080 s/cm3) at South Gate (California Air Resources
Board, 1986). EPA reported urban ambient concentrations ranging from non-detect to 0.008
s/cm3 for PCME-type asbestos structures (Chesson 1985).
6.1.2.1.2 Demolition Air
Table 6-3 presents the descriptive statistics for the airborne asbestos concentrations measured
during demolition of the NESHAP building, and demolition and soil removal from the A ACM
building. The individual sample results for the NESHAP building are contained in Table A-2 of
Appendix A. The individual sample results for the AACM building are contained in Table A-3
of Appendix A. The individual asbestos concentrations are illustrated in Figure 6-5. One sample
was inadvertently not removed and replaced at the end of Day 1 but operated for the duration of
all sampling activities. Since no asbestos was detected for this sample, it was assumed that the
results for this location for Day 1 and Day 2 were also non-detect.
In each grouping of samples presented in Figure 6-5, the samples are in numerical order in the
manner in which the samplers were placed around the buildings (Figure 4-1). That is, the first
sample in each group of 18 corresponds to the location on the front right (northwest) corner of
the building and then were numbered in a clockwise fashion around the structures. The trucks
were loaded along the front of the building as the demolitions progressed (samples one through
seven in each grouping). Visually, there does not appear to be any correlation between sample
location and the small concentrations of asbestos observed in the air samplers. The wind was
generally blowing from the front left to the rear right (from the south-southwest) of the buildings.
For the AACM, the demolition was completed on the first day (Day 1). Air sampling for
asbestos/total fibers was halted and the filters were capped and removed for analysis. Concrete
structures and some small residual debris remained. On the second day, removal of the concrete
structures and remaining debris and the subsequent soil sampling was delayed until the afternoon
because of rain. Prior to the initiation of Day 2 activities, to assure no filter overloading, new
filters were positioned for asbestos/total fiber sampling. Due to the rain, concrete/debris
removal, and the subsequent soil sampling which required a significant amount of time, soil
excavation was delayed until the third day. The asbestos/total fiber filters were capped overnight
and during periods of inactivity on Days 2 and 3. These samples, which reflect AACM activities
over the second and third day, are referred to as Day 2 samples. The settled dust samplers and
particulate filters were positioned for the entire duration of the AACM study and capped
overnight and during periods of inactivity.
78
-------
Table 6-3. Airborne asbestos (TEM) during demolition of NESHAP and AACM buildings.
Sample
Location
(Position and
Height)
Total Asbestos
n/Na
Asbestos
Structures
Counted,
Total per
ring and
max per
filter
Mean"
(s/cm3)
Min
(s/cm3)
Max
(s/cm3)
PCME Asbestos
n/Na
Asbestos
Structures
Counted,
Total per
ring and
max per
filter
Mean"
(s/cm3)
Min
(s/cm3)
Max
(s/cm3)
NESHAP Building - Day 1
Pinrr 1
Ring 2
5-ft
15-ft
5-ft
1/18
3/18
1/18
1 total
1 max
3 total
1 max
3 total
3 max
0.00003
0.00008
0.00008
0
0
0
0.00049
0.00049
0.0015
1/18
2/18
1/18
total
max
2 total
max
total
max
0.00003
0.00005
0.00005
0
0
0
0.00049
0.00049
0.00098
AACM Building - Day 1
T?inrr 1
Ring 2
5-ft
15-ft
5-ft
2/18
1/18
1/18
3 total
2 max
1 total
1 max
1 total
1 max
0.00008
0.00003
0.00003
0
0
0
0.00096
0.00049
0.00049
0/18
0/18
0/18
0 total
0 max
0 total
0 max
0 total
0 max
0
0
0
0
0
0
0
0
0
AACM Building - Day 2
T?inrr 1
Ring 2
5-ft
15-ft
5-ft
6/18
5/18
2/18
6 total
1 max
8 total
4 max
2 total
1 max
0.00016
0.00021
0.00005
0
0
0
0.00049
0.0019
0.00049
2/18
2/18
1/18
2 total
1 max
2 total
1 max
1 total
1 max
0.00005
0.00005
0.00003
0
0
0
0.00049
0.00049
0.00048
a Denotes number of samples at or above analytical sensitivity/total number of samples. The analytical sensitivity ranged from 0.00048 to 0.00049 s/cm3.
The ISO limit of detection for asbestos is equal to three times the analytical sensitivity (<0.0015 s/cm3) for TEM.
b Calculated based on the use of zero for values less than the analytical sensitivity.
79
-------
s/cm:
0.1 f#v
0.01
0.001
ITotal Asbestos •PCME Asbestos Structures •Non-detects
AHERA Limit 0.022 s/cm3
Region 6 Katrina Risk-Based Limit 0.01 s/cm3
Analytical Sensitivity 0.00049 s/cm3
i^ ^
NESHAP Bldg.
AACM Bldg. Day 1
AACM Bldg.Day 2
Non-detects are shown as near zero for illustration.
Figure 6-5. Airborne asbestos (TEM) during demolition of buildings.
During actual demolition of both the NESHAP and AACM buildings (Day 1 for the AACM),
approximately ten percent (5/54 samples) and eight percent (4/54 samples) of the samples
showed asbestos concentrations above the analytical sensitivity (Table 6-3), respectively. The
largest total asbestos concentrations observed during demolition of both buildings was measured
in Ring 1 of the AACM building (0.0019 s/cm3), with 0.0015 s/cm3 measured in Ring 2 of the
NESHAP building. Four of the 54 samples from the NESHAP building showed measurable
PCME asbestos concentrations (0.00049 to 0.00098 s/cm3). The largest total asbestos
concentration (0.00096 s/cm3) observed during demolition of the AACM building (Day 1) was
measured in Ring 1 (Table 6-3). None of the 54 samples from AACM Day 1 showed measurable
concentrations of PCME-structures.
The AACM building soil removal process (Day 2) resulted in measurable total asbestos
concentrations in 13 of 54 samples (Table 6-3 and Figure 6-5). Five of the 54 samples showed
concentrations at the analytical sensitivity (0.00048 to 0.00049 s/cm3) of PCME-structures. It is
noted that no application of the wetting agent occurred during soil removal because the ground
was saturated due to rainfall as well as from application of the wetting agent during building
demolition. In retrospect, this was a judgmental error. It is probable that the edges of the
containment berms and the berms themselves dried out somewhat during soil sampling and they
may have been the source of the few asbestos fibers observed during analysis of the air samples
collected during the soil removal phase.
80
-------
As stated previously, the airborne asbestos concentrations observed were near or below the limit
of detection. The highest total asbestos concentrations (0.0015 s/cm3 observed during demolition
of the NESHAP building and 0.0019 observed during demolition of the AACM), are
significantly less than AHERA (40 CFR §763) clearance criterion (0.022 s/cm3) and the level
(0.01 s/cm3) established by EPA for Hurricane Katrina recovery (EPA 2005). The highest
concentration of PCME-structures was 0.00098 s/cm3. The highest concentration observed (0.0019
s/cm3) was about three times lower than the average ambient air concentrations (0.0057 s/cm3)
reported by the California Air Resources Board for Eldorado County between 1998 and 2001
(State of California 2003).
The statistical analyses (Section 7.1) showed that the airborne asbestos (TEM) concentrations
from the AACM are not equal to the airborne asbestos (TEM) concentrations from the NESHAP
Method. The empirical evidence (the proportion of non-detects and the maximum values) from
the investigation suggests airborne asbestos (TEM) concentrations from the AACM are greater
than the airborne asbestos (TEM) concentrations from the NESHAP Method. Based upon the
observed proportion of detects, it was concluded that the difference between the two methods is a
function of the Day 2 AACM activities (soil excavation and removal).
6.1.2.2 Asbestos in Settled Dust
Table 6-4 presents the descriptive statistics for the settled dust samples collected in Rings 1 and
2 at the five-ft height during demolition of the NESHAP and AACM Method buildings. The
individual sample results are contained in Table A-7 of Appendix A and are illustrated in Figure
6-6. The results are reported as number of asbestos structures per unit area of surface (s/cm2). A
calculated deposition rate in asbestos structures per unit area per time (s/cm2/hour) is also
presented.
Although the following information is not directly applicable to this project, it is provided as a
point of reference for settled dust data interpretation. The draft report from the Contaminants of
Potential Concern Committee of the World Trade Center Indoor Air Task Force Working Group
Table 6-4. Asbestos (TEM) in settled dust during demolition of NESHAP and AACM buildings.
Sample
Description
Total Asbestos Loading,
s/cm2
n/Na
Meanb
Minimum
Maximum
Asbestos Deposition Rate,
s/cm2/hour
Meanb
Minimum
Maximum
NESHAP Building
Ring 1
Ring 2
14/18
10/18
6,649
435
0
0
46,771
2,315
741
48
0
0
5,146
245
AACM Building
Ring 1
Ring 2
17/18
14/18
5,079
925
0
0
21,625
4,686
238
44
0
0
1,012
221
a Denotes number of samples at or above analytical sensitivity/total number of samples.
The analytical sensitivity ranged from 146-243 s/cm2.
b Calculated based on the use of zero for values less than the analytical sensitivity.
81
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discussed dust analyses and the significance of the results. This report (USEPA 2005) suggests
the following action levels to initiate cleanup for residential structures:
* 5,000 s/cm2 for living spaces and
* 50,000 s/cm2 for inaccessible spaces.
The report goes on to reference that the cleanup action level at Libby Montana Superfund Site is
5,000 s/cm2 in generally accessible areas.
As shown in Figure 6-6, the settled dust results were highly variable. The laboratory identified
evidence of dried particulate in several of the dust containers; the higher concentrations observed
typically were associated with dust containers that had evidence of dried particulate. This most
likely can be attributed to the closeness of the sampling stations to the demolition activities and
the associated splashing of water used during the demolition (and particularly the loading of wet
debris into the adjacent trucks). There was much more evidence of splashing in Ring 1 of both
the NESHAP and AACM processes than in Ring 2 as judged by the color of the filters that were
produced from the respective dust samplers in preparing the samples for analysis. Also, there
was far more coloration on the samples located next to the side of the building where the trucks
were loaded. The Ring 1 AACM samples were more highly colored than the NESHAP dust
samples, which is consistent with the extra water (and wetting agent) used during the AACM
demolition.
There was considerably more asbestos measured in the settled dust than in the co-located air
samples for both the NESHAP and the AACM processes. Also for both processes, the asbestos
loadings in the settled dust samples in Ring 1 were higher than those measured in Ring 2.
Presumably, the asbestos was attached to dust or water particles which settled rapidly. Since the
filter cassettes for the air samples faced slightly downward, the air samplers didn't capture that
fraction of the asbestos associated with the heavier particles.
Since there was about an order of magnitude reduction (Table 6-4) in the dust asbestos loadings
between Ring 1 (which was 15 ft from the building and/or loading) and Ring 2 (which was an
additional 25-ft away from Ring 1), it is clear from the settled dust perspective that the
containment berms should have been further away from the building than they were. If possible,
the berm should be located a minimum of 25 ft from the building.
The statistical analyses (Section 7.5) showed that there is insufficient information to conclude
that the asbestos loadings in the settled dust (TEM) from the AACM are not equal to the asbestos
loadings in the settled dust (TEM) from the NESHAP Method. Based on descriptive statistics,
plots of the empirical cumulative distribution functions (CDFs), and the Komolgorov Smirnov
(K-S) test, one would conclude the AACM asbestos loadings in settled dust are equal to the
NESHAP asbestos loadings in settled dust.
82
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Thousands
WTC Inaccessible Space Action Level
Total Asbestos. s/cm2
WTC (proposed) and Libby Action Level
Typical Analytical Sensitivity
NESHAP Bldg.
AACM Bldg.
Figure 6-6. Asbestos (TEM) loading in settled dust resulting from the demolitions.
6.1.2.2.1 Total Fibers in Air Samples
6.1.2.2.1.1 Background Air
Table 6-5 presents the descriptive statistics for the background total fiber concentrations. The
individual sample results are contained in Table A-4 of Appendix A.
Table 6-5. Background total fibers (PCM) prior to demolition of
NESHAP and AACM buildings.
Total Fibers, f/cm3
n/Na
Mean"
Minimum
Maximum
NESHAP Building
3/6
0.001
0
0.002
AACM Building
6/6
0.003
0.002
0.005
a Denotes number of samples at or above analytical sensitivity/total number of samples.
The analytical sensitivity was 0.001 f/cm3.
b Calculated based on the use of zero for values less than the analytical sensitivity.
83
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The background concentration of total fibers ranged from <0.001 to 0.002 f/cm (mean =
O.OOlf/cm3) around the NESHAP building. The concentration of total fibers ranged from 0.002
to 0.005 f/cm3 (mean = 0.003 f/cm3) around the AACM building.
6.1.2.2.2 Demolition A ir
Table 6-6 presents the descriptive statistics for the airborne concentrations of total fibers
measured by PCM during demolition of the NESHAP building, and demolition and soil removal
from the AACM building. The individual fiber concentrations are shown in Table 6-6 and Table
A-3 of Appendix A. One sample was inadvertently not removed and replaced at the end of Day 1
but operated for the duration of all sampling activities.
The PCM data (Table 6-6), when compared to the TEM data (Table 6-3), illustrate that PCM
analysis is a poor indicator of asbestos concentrations. Only four of the 54 NESHAP samples and
five of the 107 AACM samples collected during the demolitions showed measurable
concentrations of PCME-asbestos structures. Of the 161 PCM samples, 153 had detectable
fibers. Eighty-seven percent (47/54 samples) collected around the NESHAP building and 100%
(107/107) of the samples from the AACM building showed measurable concentrations of total
fibers. Obviously, the PCM fibers (Table 6-6) were almost entirely not asbestos.
Of 29 individual fibers identified as asbestos by TEM, nine (or about one-third) were PCME-size
and might have been counted by PCM (Table A-2 and Table A-3).
The statistical analyses (Section 7.3) showed that there is insufficient information to conclude
that the airborne fiber (PCM) concentrations from the AACM are not equal to the airborne fiber
(PCM) concentrations from the NESHAP Method. Based on descriptive statistics one would
conclude the fiber (PCM) concentrations for the two methods are equivalent.
Table 6-6. Airborne total fibers (PCM) during demolition of NESHAP and AACM buildings.
Sample Location
n/Na
Total Fibers, f/cm3
Meanb
Minimum
Maximum
NESHAP Building - Day 1
Ring 1
Ring 2
5-ft
15-ft
5-ft
15/18
17/18
15/18
0.002
0.003
0.002
0
0
0
0.006
0.006
0.004
AACM Building - Day 1
Ring 1
Ring 2
5-ft
15-ft
5-ft
17/17
18/18
18/18
0.003
0.003
0.003
0.001
0.001
0.001
0.004
0.005
0.004
AACM Building - Day 2
Ring 1
Ring 2
5-ft
15-ft
5-ft
17/17
18/18
18/18
0.003
0.004
0.003
0.001
0.002
0.001
0.006
0.016
0.004
a Denotes number of samples at or above analytical sensitivity/total number of samples.
The analytical sensitivity was 0.001 f/cm3.
b Calculated based on the use of zero for values less than the analytical sensitivity.
84
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6.1.2.3 Total Particulate in Air Samples
Table 6-7 presents the descriptive statistics for the airborne concentrations of total particulate
measured during demolition of the NESHAP building, and demolition and soil removal from the
AACM building. Individual results are in Table A-8 of Appendix A.
The AACM results reflect the cumulative concentration for both the demolition and the soil
removal aspects, as overloading the filters was not a concern for particulate; i.e., the same filters
were used throughout the AACM process and opened only during the active times for both the
demolition and soil removal operations. The particulate concentrations, though uniformly low
values, were larger during the AACM than for the NESHAP demolition. This is attributed to
both the extended sampling period for the AACM process, which included soil removal and
disposal. Since wetting was inadvertently not performed during the soil removal, it is possible
that this increased the particulate loading.
Although the OSHA PEL (29 CFR §1910, Table Z-l) for particulates not otherwise regulated
(PNOR) of 15 mg/m3 is not directly applicable, it provides a relative comparison to illustrate the
very low concentrations of total particulate observed in both demolitions. The values observed
are at least 100 times lower than the PEL.
The statistical analyses (Section 7.6) showed that the total particulate concentrations (as
collected and measured by NIOSH Method 5000) from the AA CM are not equal to the total
particulate concentrations from the NESHAP Method. Based on the observed proportion of
detects, it was concluded that the total particulate concentrations from the AACM are higher
than the total asbestos concentrations from the NESHAP Method.
Table 6-7. Airborne total particulate during demolition of NESHAP and AACM buildings.
Sample Location
n/Na
Total Particulate, mg/m3
Meanb
Minimum
Maximum
NESHAP Building - Day 1
Ring 1
Ring 1
5-ft
7/18
0.032
0
0.11
AACM Building - Day 1 & 2
5-ft
17/18
0.084
0
0.15
a Denotes number of samples at or above analytical sensitivity/total number of samples.
The analytical sensitivity ranged from 0.02-0.06 mg/m3.
b Calculated based on the use of zero for values less than the analytical sensitivity.
85
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6.1.3 Water
Table 6-8 shows the volume of water used during the demolition of the NESHAP and AACM
buildings. The water addition, rainfall history, and activity timing are illustrated in Figure 6-7.
Overall, the AACM received more than ten times the water quantity applied to the NESHAP.
During the NESHAP building demolition, no pooled surface water was present at the collection
sumps. Hence, no samples of pooled surface water were obtained. With the intervening rainfall
plus the water from the NESHAP demolition, the soil appeared saturated when the AACM
demolition was conducted. This pre-saturation, plus the quantity of water that was applied during
the AACM demolition, as well as the effectiveness of the wetting-agent to improve wetting of
the soil, provided a cumulative effect that allowed two small areas on the down-gradient side of
the berm in the rear of the AACM building to seep beyond the berm. In the two particular down-
gradient spots, a small amount of water accumulated outside the berm and samples were
obtained. There was no visible flow; simply two small wet areas that developed. While it was
not possible to measure the volume of water that escaped through the berm, it was estimated to
be less than one percent, since it was a seep and no flow was observed. It was however clear that
the source was the water from within the berm. Overall, 4100 gallons (about 20 percent of the
23833 gallons of amended water that were applied) were collected, filtered, trucked, and
disposed at the Fort Smith Sewage Treatment Plant. Roughly 80 percent of the amended water
that was applied either percolated into the soil or was taken to the landfill as part of the debris.
Table 6-8. Summary of source (hydrant) water usage during the
NESHAP and AACM building demolition.
Day
Hydrant Meter
Reading
Start
Time
Stop
Time
Hydrant Meter
Reading (ft3)
Start
Stop
Source Water Usage
ft3
gallons
Cumulative,
Gallons
NESHAP BUILDING
Day 1
(04/26/06)
0800
1157
1157
1436
211,272
211,530
211,530
211,659
258
129
1,930
965
1930
2895
AACM Building
Pre-wetting
(4/30/06)
Day 1
(05/01/06
Day 2
(05/02/06)
Day 3
(05/03/06)
1521
0709
1300
1641
1840
1604
211688
212,252
214,666
21251
214,666
214,875
564
2,414
209
4214
18,059
1,560
Water not used.
4214
22273
23833
23833
86
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1.5
0.5
Rainfall, inches
Water Applied, 10,000 gal
> /
Figure 6-7. Rainfall, Water Application, and Activity History During Demolition Study Period
Table 6-9 presents the asbestos analysis of the source water with and without the wetting agent,
as well as pooled surface water resulting from the demolitions. The analytical results indicate
that pooled surface water collected from inside and outside the berm contained asbestos. Figure
6-8 illustrates the total asbestos content of water sampled during the AACM demolition. Figure
6-9 illustrates the asbestos structures longer than 10 microns that were present in the pooled
water from the AACM building demolition.
The only current EPA regulations on asbestos in water are the drinking water standards. The U.S.
EPA National Primary Drinking Water Standards (40CFR 141.51, 2002) mandates a limit for
the concentration of asbestos fibers (longer than ten microns) at seven million fibers per liter;
i.e., the Maximum Contaminant Level (MCL) for asbestos in drinking water. Although the
Federal Drinking Water Standard is clearly not applicable in this situation, this discussion is
provided to establish a relative frame of reference for the asbestos concentrations observed in the
water phase. The maximum asbestos concentration in the pooled surface water was about five
times greater than the EPA standard. This is not unexpected since the AACM anticipates
transfer of some asbestos to the water, but the water is captured and filtered before ultimate
disposal. Where soil exists around the structure, the water permeates into the soil transferring the
asbestos into the soil matrix; therefore the AACM requires the removal of some soil from the site
at the completion of the demolition. Neither water capture or soil removal are required with the
existing NESHAP process.
87
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Table 6-9. Asbestos (TEM) in water from the NESHAP and AACM building demolitions.
Sample Description
Number of Asbestos
Structures Counted
Asbestos
Concentration
(million s/L)
Asbestos
Structures >10 um
(million s/L)
NESHAP Building a
Day 1 Source Hydrant Pre-Demo
Day 1 Source Hydrant Post -Demo
0
0
<0.36
<0.05
<0.36
<0.05
AACM Building
Day 1 Source Hydrant Pre-Demo
Day 1 Source Hydrant Post -Demo
Day 2 Source Hydrant Post -Demo
Day 1 Surface Water from demo
(morning)
Day 1 Surface Water from demo
(afternoon)
Day 2 Surface Water from demo
(afternoon)
Day 1 Surface water outside of
berm (location 1)
Day 1 Surface water outside
of berm (location 2)
Day 2 Surface water outside
of berm
1% wetting agent in distilled water
1% wetting agent in distilled water
0
0
0
106
108
84
105
100
12
0
0
<0.36
<0.76
<0.04
2,770
3,290
745
1,600
2,280
103
<0.0004
<0.0003
EPA Drinking Water Standard
<0.36
<0.76
<0.04
<26
30.4
35.5
30.4
<23
<8.6
<0.0004
<0.0003
7
"No surface water was present.
-------
3500
3000
Total Asbestos (TEM), million s/L.
• PCME Asbestos Structures (TEM), million s/L
rj Asbestos structures >10 micron long, million s/L.
Figure 6-8. Asbestos in water samples.
40
35
30
25
20
15
10
<
5
0
rn Asbestos structures >10-micron long, million s/L
Drinking Water Standard 7 million sfl
Figure 6-9. Asbestos structures longer than ten microns in water samples.
89
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6.1.4 Soil
Ten replicate composite samples were collected during each sampling event. These samples
really represent individual measurements of the overall asbestos concentration within each
bermed area.
6.1.4.1 Moisture
Each of the composite samples was dried in the laboratory and homogenized. Any visible
rocks/organic material and building debris were removed and weighed. The remaining soil was
split into two fractions - one fraction for elutriation and the other fraction for analyses by PLM
and TEM. The individual sampling results are contained in Table A-12 of Appendix A.
The descriptive statistics for soil moisture results during both demolitions are presented in Table
6-10. The soil moisture concentrations illustrate an increase in water content of the soil as a
result of the wetting agent used during the AACM demolition and the rainfall encountered
following the AACM building demolition but prior to soil sampling, soil removal, and final soil
sampling. Note that all soil analyses were performed on the dried samples.
Table 6-10. Soil Moisture Content.
Phase
% Moisture Content
Mean
Minimum
Maximum
NESHAP Building
Pre-Demo
Post-Demo
19.5
11.5
13.3
9.9
23.8
13.1
AACM Building
Pre-Demo
Post-Demo
Post-Excavation
15.2
21.4
20.2
11.4
19.9
12.1
18.7
23.5
24.8
6.1.4.2 Total Asbestos
The soil fraction was analyzed for asbestos by PLM point counting and TEM. The
rocks/organics were analyzed by PLM using visual estimation. The building debris fraction was
also analyzed by PLM using visual estimation.
6.1.4.2.1 Soil Fraction
Table 6-11 presents the descriptive statistics for the asbestos analyses (PLM and TEM) for the
soil fraction. The individual sample results are contained in Table A-12 of Appendix A.
90
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The PLM results for the soil fraction from all samples of the demolitions were largely non-detect
at an analytical sensitivity of 0.1 percent, as shown in Table 6-11 and illustrated in Figure 6-10.
Only one NESHAP post-demolition sample showed a detectable concentration of asbestos by
PLM. None of the post-excavation AACM samples showed detectable asbestos by PLM.
Although the NESHAP definition of an asbestos-containing material (one percent) is not directly
applicable to soil, all of the concentrations were well below this concentration.
The individual TEM asbestos concentrations are illustrated in Figure 6-11 and the mean TEM
concentrations are illustrated in Figure 6-12. With increased sensitivity by this method, the
variability is apparent. The higher asbestos concentrations observed in the pre-demolition data
from both buildings are attributed to the removal of pipe wrapping from beneath the buildings,
which was performed many years earlier. This variability represents the sum of variabilities from
both the sampling process (including heterogeneity of the site) and the analytical process. It is
very difficult to generate a representative, consistent filter loading for TEM analysis, as a very
small portion of the sample must be used to prevent overloading.
Table 6-11. Asbestos (PLM and TEM) results in soil fraction.
%of
Sample
by wt.
Mean
PLM - Point Count
Asbestos (% )
n/Na
Meanb
Minimum
Maximum
TEM
Asbestos (106 Structures/gm)
n/Na
Meanb
Minimum
Maximum
NESHAP Building - Pre-Demolition
99.1
0/10
0
0
0
6/10
33
0
165
NESHAP Building - Post-Demolition
95.8
1/10
0.03
0
0.34
8/10
181
0
1600
AACM Building - Pre-Demolition
97.9
2/10
0.05
0
0.33
6/10
1160
0
11500
AACM Building - Post-Demolition
92.9
1/10
0.03
0
0.33
7/10
51
0
211
AACM Building - Post-Excavation
94.6
0/10
0
0
0
3/10
17
0
151
a Denotes number of samples at or above analytical sensitivity/total number of samples.
The analytical sensitivity for PLM point count was 0.1 percent. The analytical sensitivity for TEM ranged from
3.94xl06 to 2.15xl07 structures/gm.
b Calculated based on the use of zero for values less than the analytical sensitivity.
91
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1.2
0.8
0.6
0.4
0.2
4
0
EPA current definition of asbestos-containing (one percent)
OAsbestos Concentration ( PLM point count), %
Analytical Sensitivity 0.1%
pv ^°"
^°
NESHAP Bldg.
AACM Bldg.
Figure 6-10. Soil asbestos concentrations by PLM for both building demolitions.
The statistical analyses (Section 7.2) showed that the post-excavation asbestos concentrations in
the soil from the AACM are not equal to the post-demolition asbestos concentrations in the soil
from the NESHAP Method. Based on descriptive statistics, one would conclude the post-
excavation asbestos concentrations in the soil from the AACM are less than the post-demolition
asbestos concentrations in the soil from the NESHAP Method.
The descriptive statistics (Section 7.2) show that: the AACMpre-demolition soil concentrations
are greater than the post-excavation soil concentrations in the upper tails of the distributions;
the NESHAP pre-demolition soil concentrations are less than the post-demolition soil
concentrations in the upper tails of the distributions; and the AACM post-demolition soil
concentrations are greater than the AACM post-excavation soil concentration in the upper tails
of the distributions.
92
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Million s/g
100000
10000
1000
100
10
1
-------
6.1.4.2.2 Rocks/Organ ics Fraction
Asbestos was not present above the detection limit (one percent) in any of the rocks/organics
fractions.
6.1.4.2.3 Building Debris Fraction
Table 6-12 presents the descriptive statistics for the asbestos results (PLM) for the building
debris fraction. The individual results are presented in Table A-12 of Appendix A.
There were interesting observations about the building debris that remained at the end of each
demolition process and the amount of asbestos therein. At the conclusion of the demolitions, all
ten post-demolition samples for the NESHAP building contained building debris that was
asbestos-containing; seven of the ten post-excavation AACM samples contained building debris
Table 6-12. Asbestos Content in the Building Debris Fraction of the Soil
Weight % of
debris in soil
Mean
PLM
Asbestos in building debris
by visual estimation,%
n/Na
Meanb
Minimum
Maximum
NESHAP Building - Pre-Demolition
0.012
2/10
1.2
0
8.3
NESHAP Building - Post-Demolition
0.28
10/10
2.5
0.16
5.0
AACM Building - Pre-Demolition
0.04
1/10
0.06
0
0.62
AACM Building - Post-Demolition
0.87
9/10
0.87
0
2.46
AACM Building - Post-Excavation
0.68
7/10
0.21
0
0.6
a Denotes number of samples at or above analytical sensitivity/total number of samples.
The analytical sensitivity for PLM was 0.1 percent.
b Calculated based on the use of zero for values less than the analytical sensitivity.
that was asbestos-containing. The majority of this asbestos-containing building debris was
identified as brown vinyl asbestos floor tile (VAT).
Since the soil samples were weighed after drying at the lab and the suspect ACM, including
VAT fragments, were removed and weighed, the percentage of ACM and further of VAT
fragments can be expressed on strictly a weight basis. These VAT fragment data are presented in
Table 6-13.
94
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Table 6-13. Weight of Vinyl Asbestos Tile (VAT) fragments in the soil samples.
Weight % of VAT fragments in soil samples
n/Na
Meanb
Minimum
Maximum
NESHAP Building - Pre-Demolition
1/10
0.003
0
0.03
NESHAP Building - Post-Demolition
10/10
0.07
0.01
0.15
AACM Building - Pre-Demolition
0/10
0
0
0
AACM Building - Post-Demolition
9/10
0.08
0
0.26
AACM Building - Post-Excavation
7/10
0.01
0
0.03
Denotes number of samples at or above analytical sensitivity/total number of samples.
The analytical sensitivity for the balance was 0.01 g.
b Calculated based on the use of zero for values less than the analytical sensitivity.
The final mean soil concentration was 0.07 percent by weight asbestos-containing building
debris for the NESHAP process and the final mean soil concentration was 0.01 percent ACM by
weight for the AACM process. Of those small quantities of asbestos-containing building debris,
90 percent of the NESHAP quantity was VAT fragments and the remaining ten percent was
other asbestos-containing materials. For the AACM process, all the ACM building debris in the
post-excavation soil was composed of VAT fragments.
Figure 6-13 illustrates the trends of the VAT fragments and of the total ACM present in the
building debris as a percentage of the original dry weight of the soil sample. These data clearly
illustrate the decrease in VAT fragments in the soil as a result of the AACM as compared to the
NESHAP method.
The statistical analyses (Section 7.12) showed that the post-excavation percent by weight of
asbestos-containing material (ACM) (primarily vinyl asbestos tile (VAT)) in the soil from the
AACM is not equal to the post-demolition percent by weight of asbestos-containing material
(ACM) (primarily vinyl asbestos tile (VAT)) in the soil from the NESHAP Method. Additional
analyses using box plots lead one to conclude the post-excavation percent by weight of asbestos-
containing material (ACM) (primarily vinyl asbestos tile (VAT)) in the soil from the AACM is
less than the post-demolition percent by weight of asbestos-containing material (ACM)
(primarily vinyl asbestos tile (VAT)) in the soil from the NESHAP Method.
95
-------
0.2
0.1
0
nVAT in Debris, % by wt
• Non-VAT ACM in Debris, % by wt
^
Figure 6-13. Weight fraction of soils that were VAT and ACM building debris.
6.1.4.3 Soil Elutriation
Thirty percent of the soil samples were analyzed using the Modified Elutriator Method. Table
6-14 presents the descriptive statistics for the soil elutriation air samples generated from soil
collected before and after demolition of the NESHAP and AACM Method buildings. The
individual results are contained in Table A-l 1 of Appendix A and illustrated in Figure 6-14.
The statistical analyses (Section 7.10) showed that there was insufficient data to evaluate that
the post-excavation asbestos concentrations from elutriator test on soil from the AACM are
equal to the post-demolition asbestos concentrations from elutriator test on soil from the
NESHAP Method; that the post-excavation asbestos concentrations from elutriator test on soil
from the AACM are equal to the pre-demolition asbestos concentrations from elutriator test on
soil from the AACM; that the post-demolition asbestos concentrations from elutriator test on soil
from the NESHAP Method are equal to the pre-demolition asbestos concentrations from
elutriator test on soil from the NESHAP Method; or that the post-excavation asbestos
concentrations from elutriator test on soil from the AACM are equal to the post-demolition
asbestos concentrations from elutriator test on soil from the AACM.
It appears that the soil elutriation total asbestos concentrations are lower following demolition
for both the NESHAP and the AACM methods.
96
-------
Table 6-14. Elutriation air samples (TEM) from soil collected before and after demolition
Sample Description
Total Asbestos Concentration,
106 s/gPMio
n/Na
Meanb
Min
Max
PCME Asbestos Concentration,
106 s/gPMio
n/Na
Meanb
Min
Max
NESHAP Building
Pre-Demolition
Post-Demolition
3/3
2/3
20
2.3
13
0
31
3.6
3/3
1/3
1.6
2.8
8.4
0
26
1.7
AACM Building
Pre-Demolition
Post-Demolition
Post-Excavation
3/3
2/3
2/3
28
3.1
11
9.0
0
0
38
5.2
32
2/3
2/3
1/3
8.6
1.5
0.7
0
0
0
14
2.6
2.2
Denotes number of samples at or above analytical sensitivity/total number of samples. The analytical sensitivity
ranged from 2.19xl06 to 1.07xl07 s/gPM10. The ISO limit of detection for asbestos is equal to three times the
analytical sensitivity (<6.6 x 106 s/cm3 to 3.2xl07 s/cm3) for TEM.
b Calculated based on the use of zero for values less than the analytical sensitivity.
100000000
10000000
1000000
100000
Total Asbestos Structures (1EIV), s/g PM10
PCIVE Asbestos Fibers (TEIV), f/g PM10
^
[NESHAPBIdgT
AACMBIdg.
Figure 6-14. Soil elutriation air concentrations of asbestos (TEM).
97
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6.1.4.4 Visible Emissions
A brief visible emission was observed during the removal of a concrete foundation structure
during the NESHAP demolition, but it was not an asbestos-containing material. No visible
emissions were observed during the AACM demolition.
6.1.5 Workers
Workers were monitored during all phases of the study, including abatement of the NESHAP
building, demolition of both buildings, and -^walkers" attending the sampling stations during the
demolitions. Individual sample results are presented in Table A-9 of Appendix A.
6.1.5.1 Asbestos (TEM) and Fibers (PCM)
6.1.5.1.1 Demolition and Abatement Workers
Table 6-15 presents the descriptive statistics for the personal breathing zone concentrations of
asbestos (TEM) and total fibers (PCM) measured during demolition of the NESHAP and AACM
buildings.
The demolition worker samples were analyzed by TEM and by PCM (Table 6-15). All the
AACM worker breathing zone samples were non-detect for total asbestos (all asbestos structures
>0.5 microns in length and >3:1 aspect ratio) at the 0.005 s/cm3 analytical sensitivity level. The
NESHAP demolition worker samples showed only a few fibers of asbestos and those were <5
microns in length. Overall, none of the worker samples showed detectable PCME asbestos
structures (>5 microns in length and >3:1 aspect ratio) during the demolitions. Time-weighted
averages, based upon the PCM fiber counts above, were all below the OSHA Personal Exposure
Limit (PEL) of 0.1 f/cm3. Table 6-16 presents the descriptive statistics for the personal breathing
zone concentrations of total fibers and asbestos measured during abatement of the NESHAP
buildings. Results from the sampling of the negative-air HEP A-filtration units are also presented.
The breathing zone samples from the abatement workers, which are part of the NESHAP
process, indicated total asbestos concentrations as high as 0.093 s/cm3.
The highest concentration of total fibers (0.12 f/cm3) expressed as an eight-hr time-weighted
average (TWA), was equal to the OSHA Personal Exposure Limit (PEL) of 0.10 f/cm3.
Figure 6-15 illustrates the breathing zone concentrations for the abatement workers.
It is apparent in Figure 6-15 that PCM measurements have no relationship to the asbestos
concentrations. The highest PCM concentration had a much lower PCME concentration (the
asbestos fibers that are in the size range measured by PCM). Also, there are considerably more
small fibers than PCME fibers in the abatement. This is consistent with previous studies
98
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Table 6-15. Personal breathing zone concentrations of asbestos (TEM) and total fibers (PCM)
during demolition of the NESHAP and AACM buildings.
Worker
Total Asbestos, s/cm
n/Na
Meanb
Min
Max
PCME Asbestos, s/cm3
n/Na
Meanb
Min
Max
Total Fibers, f/cm3
n/N
Meanb Min ^
Demolition of NESHAP Building
Excavator
and hose
operators;
laborers
Truck
drivers
Walkers
2/5
0/3
0/3
0.002
0
0
0
0
0
0.005
0
0
0/5
0/3
0/3
0
0
0
0
0
0
0
0
0
5/5
3/3
3/3
0.019
0.061
0.022
0.009
0.042
0.009
0.036/
(0.05)
0.086/
(0.07)
0.03 1/
(0.02)
Demolition of AACM Building
Excavator
operator;
laborers
Truck
drivers
Walkers
0/5
0/3
0/3
0
0
0
0
0
0
0
0
0
0/5
0/3
0/3
0
0
0
0
0
0
0
0
0
5/5
3/3
3/3
0.009
0.011
0.013
0.004
0.007
0.008
0.016/
(0.03)
0.017/
(0.01)
0.018/
(0.01)
a Denotes number of samples at or above analytical sensitivity/total number of samples.
The analytical sensitivity was 0.0049 s/cm3 for TEM and 0.001 f/cm3 for PCM. The ISO limit of detection for
asbestos is equal to three times the analytical sensitivity (<0.015 s/cm3) for TEM.
b Calculated based on the use of zero for values less than the analytical sensitivity.
Table 6-16. Concentrations of asbestos (TEM) and total fibers (PCM)
during abatement of the NESHAP building.
Sample Description
Asbestos(TEM), s/cm3
n/Na
Meanb
Min
Max
Total Fibers(PCM), f/cm3
n/N
Mean
Min
Max
TWA
Max
Asbestos Abatement of NESHAP Building
Abatement Workers
4/6
0.032
0
0.071
4/6
0.052
0
0.12
0.10
Load-out of Containerized ACM from NESHAP Building
Abatement Load-out
Workers0
3/3
0.065
0.041
0.093
3/3
0.018
0.009
0.024
NA
HEPA-Filtration Units in NESHAP Building
Discharge Aird
0/4
0
0
0
2/4
0.0007
0
0.002
NA
a Denotes number of samples at or above analytical sensitivity/total number of samples.
The analytical sensitivity was 0.0049 s/cm3 for TEM and 0.001 f/cm3 for PCM. The ISO reportable detection limit
for asbestos was <0.015 s/cm3 for TEM.
b Calculated based on the use of zero for values less than the analytical sensitivity.
0 The sample was integrated over three days with each sampling period being
-------
• Total Asbestos (TEM), s/cm3
• PCME Asbestos Structures (TEM), s/cm3
Q PCM, f/cm3
Non-detects are shown as near zero for illustration.
Figure 6-15. Abatement worker personal breathing zone concentrations
of asbestos and total fibers.
(Wilmoth et al 1993) which showed that as many as 99 percent of the asbestos fibers during
abatement activities are less than five microns in length.
The statistical analyses (Section 7.7) showed that the worker breathing zone fiber concentrations
(PCM) from the AA CM are not equal to the worker breathing zone fiber concentrations (PCM)
from the NESHAP Method. Based on descriptive statistics, one would conclude the worker
breathing zone fiber concentrations (PCM) from the AACM are less than the worker breathing
zone fiber concentrations (PCM) from the NESHAP Method.
Based on the observed proportion of detects (Section 7.8), the worker breathing zone asbestos
concentrations (TEM) from the AACM are less than the worker breathing zone asbestos
concentrations (TEM) from the NESHAP method.
6.1.5.1.2 Walkers
The walkers were members of the contractor team who continually surveyed and inspected the
performance of the samplers, both personal and stationary. All walker samples for both
demolitions were non-detect for asbestos at the 0.005 s/cm3 analytical sensitivity level (Table
100
-------
6-15). PCM analysis of the same filters showed total fiber concentrations that ranged from 0.008
to 0.018 f/cm3 with an average concentration of 0.013 f/cm3.
All walker samplers showed a calculated eight-hr time-weighted average (TWA) concentration
which was far below the OSHA PEL.
6.1.5.1.3 Worker Summary
Worker breathing zone samples for the abatement workers, which constituted the longest time
component (by a factor of nine) of the NESHAP Method, registered elevated levels of asbestos
by TEM and fibers by PCM (one equaling the OSHA PEL). In one instance, an EPA observer
entered the containment area during the abatement and observed an abatement worker who had
removed his respirator and was working without respiratory protection.
Demolition worker breathing zone samples for asbestos were almost all non-detect for both the
NESHAP Method and the AACM.
Figure 6-16 illustrates the relative magnitude of both total and PCME asbestos concentrations for
all demolition worker breathing zone samples, which include results from the landfill workers
Total Asbestos
PCME Asbestos
Analytical Sensitivity 0.005 s/cm3
NESHAP Bldg.
AACM Bldg.
Non-detects are shown as near zero for illustration.
Figure 6-16. Worker breathing zone asbestos (TEM) data from the NESHAP
and AACM demolition processes.
101
-------
that are discussed in Section 6.2.3. Since the NESHAP process includes the abatement process,
the AACM offers a significant improvement in the reduction of workplace asbestos
concentrations as compared to the overall NESHAP process.
6.1.5.2 Lead(Pb)
Personal breathing zone samples were collected on the same workers sampled for asbestos and
total fibers. Lead was not present in any of the samples at an analytical limit of detection of one
jig per sample, which is equivalent to a volume adjusted detection limit of <2 |ig/m3.
6.2 Results From Landfilling Demolition Debris
6.2.1 Meteorology
The wind speed and wind direction sensors of the meteorological station located at the landfill
malfunctioned during the study. Fortunately, the Fort Smith Airport Weather Station was about
1000 ft away and the meteorological data were obtained from this station and were used for the
disposal portion of the study. Figure 6-17 illustrates the wind rose for the NESHAP disposal.
Figure 6-18 illustrates the wind rose for the AACM disposal.
Figure 6-17. Landfill wind rose during the NESHAP debris disposal.
102
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Figure 6-18. Landfill wind rose during the AACM debris disposal.
6.2.2 Perimeter Air
At the landfill, perimeter air samples for asbestos and total fibers were collected. Table 6-17
presents the descriptive statistics for the background airborne asbestos and total fiber
concentrations measured prior to landfilling of the NESHAP and AACM building debris.
Individual sample results are presented in Table A-4 of Appendix A. One of the six samples
showed an asbestos concentration at the analytical sensitivity of 0.00049 s/cm3.
Table 6-18 presents the descriptive statistics for the airborne asbestos and total fiber
concentrations measured during landfilling of the NESHAP and AACM building debris, which
includes soil from the AACM building. Individual sample results are presented in Table A-5 of
Appendix A.
The asbestos results indicate concentrations at or near background levels. Similar to the asbestos
concentrations, the fiber concentrations, as measured by PCM, were low values near the
analytical sensitivity; however, in contrast to the asbestos results, there were fibers detected at all
sampling stations but one.
Table 6-17. Background air levels of asbestos (TEM) and total fibers (PCM) prior to landfill of
demolition debris from NESHAP and AACM buildings.
Asbestos, s/cm
n/Na
1/6
Meanb
0.00008
Minimum
0
Maximum
0.00049
Total Fibers, f/cm3
n/N
3/6
Meanb
0.0020
Minimum
0
Maximum
0.0052
a Denotes number of samples at or above analytical sensitivity/total number of samples.
The analytical sensitivity was 0.00049 s/cm3 for TEM and 0.002 f/cm3 for PCM. The ISO limit of detection for
asbestos is equal to three times the analytical sensitivity (<0.0015 s/cm3) for TEM.
b Calculated based on the use of zero for values less than the analytical sensitivity.
103
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Table 6-18. Airborne asbestos (TEM) and Total Fibers (PCM) during landfilHng
of NESHAP and AACM buildings demolition debris.
Asbestos , s/cm
n/Na
Meanb
Minimum
Maximum
Total Fibers, f/cm3
n/N
Mean"
Minimum
Maximum
NESHAP Building
0/9
0
0
0
8/9
0.0022
0
0.0032
AACM Building - Day 1
1/9
0.00005
0
0.00048
9/9
0.0021
0.0010
0.0031
AACM Building - Day 2
1/9
0.00005
0
0.00049
9/9
0.0039
0.0022
0.0076
a Denotes number of samples at or above analytical sensitivity/total number of samples.
The analytical sensitivity ranged from 0.00047 to 0.00049 s/cm3 for TEM and 0.001 f/cm3 for PCM. The ISO
reportable detection limit for asbestos was O.0015 s/cm3 for TEM.
b Calculated based on the use of zero for values less than the analytical sensitivity.
Because of the large proportion of non-detects, it was not possible to conduct meaningful
inferential statistical tests or use the descriptive statistics to make conclusions using the TEM
data.
6.2.3 Workers
6.2.3.1 Asbestos and Total Fibers
Personal breathing zone samples were collected from the workers at the landfill, including the
bulldozer operator and the compactor operator. The data for these samples are presented in
Table 6-19. Individual sample results are presented in Table A-10 of Appendix A.
The eight-hr TWA for this study was calculated by multiplying the observed breathing zone fiber
(PCM) concentration by the number of hours in that working environment and dividing that by
eight hours (the basis for the PEL is an eight-hr workday). In this study, the filters were operated
the entire time that a worker was involved in the task.
Table 6-19. Personal breathing zone concentrations of asbestos (TEM) and total fibers (PCM)
during landfilling of demolition debris from NESHAP and AACM buildings.
Asbestos,
s/cm3
Total Fibers, f/cm3
Sample Period
Eight-hr TWA
Landfill of NESHAP Building Demolition Debris
Bulldozer Operator
Compactor Operator
0.0048
0
0.043
0.16
0.06
0.26
Landfill of AACM Building Demolition Debris
Bulldozer Operator
Compactor Operator
0
0
0.023
0.053
0.02
0.22
The analytical sensitivity ranged from 0.0048 to 0.0049 s/cm3 for TEM and 0.001 f/cm3 for PCM.
The ISO limit of detection for asbestos is equal to three times the analytical sensitivity (<0.015
s/cm3) for TEM.
104
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The eight-hr TWA concentration of total fibers during landfilling of the demolition debris
exceeded the OSHA PEL for the compactor operator for both the NESHAP and AACM
demolition debris disposal situations. However, it should be noted that these fibers were not
asbestos since the analysis of the same filter by TEM indicated asbestos values at or below the
analytical sensitivity.
Because of the large proportion of non-detects, it was not possible to conduct meaningful
inferential statistical tests or use the descriptive statistics to make conclusions using the TEM
data.
6.2.3.2 Lead(Pb)
All landfill worker samples for lead were non-detect at an analytical sensitivity of 4 |ig/m3.
105
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SECTION 7 STATISTICAL ANALYSES
Due to the large number of non-detect data, the statistical methods proposed in the QAPP were
not always employed. For the inferential tests discussed in this section, the following approaches
were used for the treatment of non-detects:
* In cases where there were less than five percent non-detect data and substituting one-half
the detection limit would not affect the conclusions of the inferential test, the parametric
methods proposed in the QAPP were employed, unless the assumptions of the parametric
test were not met.
* In cases where the percent of non-detects was between 5 and 90, nonparametric methods
based on ranks and adjusted for ties (Lehmann 2006, Chapter 1, Section 4) were
employed.
• In cases where there were greater than 90% non-detect data for either method, no
statistical analyses were conducted.
• As previously discussed in Section 6 (Results), zeros were substituted for the non-detects
in calculating the descriptive statistics.
The data from Ring 1 were used in performing the statistical analyses as required in the QAPP.
7.1 Primary Objective 1
Null hypothesis: The airborne asbestos (TEM) concentrations from the A ACM are equal
to the airborne asbestos (TEM) concentrations from the NESHAP Method.
7.1.1 Day 1 NESHAP vs. Day 1 and 2 AACM
The total asbestos data consists of measurements at two heights at eighteen monitoring locations.
Data for the NESHAP method were collected on one day and consist of thirty-six measurements
(duplicate measurements are identical, all are non-detects). Thirty-two of the thirty-six total
asbestos measurements are non-detects (89% of the data are censored). Data for the AACM
were collected on two days and consist of seventy-two measurements (duplicate measurements
are identical, all are non-detects). Fifty-nine of the seventy-two total asbestos measurements are
non-detects (82% of the data are censored).
Prior to calculating descriptive statistics and conducting an inferential test for method
differences, the AACM data for days one and two were combined by sampling location. The
data were combined as follows:
• if Day 1 was a detect and Day 2 was a non-detect, the detect value was kept;
• if Day 1 was a non-detect and Day 2 was a detect, the detect value was kept;
• if both days were non-detects, the larger non-detect value was kept;
• if both days were detects, the detect values were summed.
The data from both methods are provided in Table 7-1.
107
-------
Table 7-1. Airborne Asbestos Concentrations (s/cm ) for Total Asbestos (TEM) and PCME
(TEM) Structures for the AACM (Days 1 and 2 Combined) and NESHAP Method and Ranks for
the Wilcoxon Rank-Sum Test.
Monitor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Height
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
TOTAL ASBESTOS (s/cm3)
AACM
ND*/54
ND/10
0.00145/71
0.00049 / 54
0.00049 / 54
ND/10
ND/54
0.00049 / 54
0.00049 / 54
ND/10
ND/28.5
ND/28.5
ND/28.5
ND/28.5
ND/54
0.00049 / 54
NDV54
0.00049 / 54
ND/54
0.00049 / 54
0.00194/72
ND/10
0.00049 / 54
ND/54
ND/54
0.00049 / 54
0.00049 / 54
ND/10
ND/54
ND/54
0.00049 / 54
ND/10
ND/28.5
ND/28.5
ND/54
ND/28.5
NESHAP
ND/10
ND/10
ND/54
ND/28.5
ND/54
ND/54
ND/10
ND/28.5
ND/28.5
ND/54
ND/28.5
ND/10
ND/10
ND/28.5
0.00049 / 54
ND/28.5
ND/10
ND/28.5
ND/10
ND/54
0.00049 / 54
ND/10
ND/28.5
0.00049 / 54
ND/54
ND/10
0.00049 / 54
ND/10
ND/10
ND/54
ND/28.5
ND/54
ND/10
ND/10
ND/28.5
ND/28.5
PCME ASBESTOS (s/cm3)
AACM
ND
ND
0.00049
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND1
0.00049
ND
ND
0.00048
ND
ND
ND
ND
0.00049
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NESHAP
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.00049
ND
ND
ND
ND
ND
ND
ND
ND
0.00049
ND
ND
0.00049
ND
ND
ND
ND
ND
ND
ND
ND
ND
*ND = 0.00033, 0.00048, or 0.00049 s/cm3
Sample 17 was inadvertently not changed out at the end of Day 1, but operated for the entire sampling
period; however, no asbestos structures were seen.
108
-------
To evaluate the null hypothesis, the Wilcoxon Rank-Sum test (Bickel 1977) was conducted using
the total asbestos concentrations. The total asbestos concentration ranks used to calculate the test
statistic are displayed in Table 7-1. The Wilcoxon Rank-Sum test statistic provided a p-value of
0.006; therefore, it was concluded that the airborne asbestos (TEM) concentrations from the
AACM are not equal to the airborne asbestos (TEM) concentrations from the NESHAP Method.
Due to the large proportion of censored data for both methods, an additional nonparametric test
was employed to test the null hypothesis that the proportion of NDs for the two methods are
equivalent (proportion of NDs for AACM = 0.64 (23 out of 36) versus the proportion of NDs for
NESHAP = 0.89 (32 out of 36)). The Chi-Square statistic for difference in proportions (Bickel
and Doksum, 1977, Section 8.3) was conducted and provided a test statistic of ^ = 6.24 and p-
value = 0.004; therefore, it was concluded that the proportion of non-detects for the two methods
is not equivalent.
A parametric evaluation of the total asbestos data was conducted assuming a Poisson
distribution. In addition to the two nonparametric tests applied, the AACM and NESHAP
Method can also be compared using fiber count data from the TEM analyses. The model for this
comparison is as follows. For a single TEM analysis, we will use the notation below:
A = Effective filter area;
a = Area viewed by the TEM (randomly selected);
V = Air volume drawn through the filter;
N = True total number of asbestos fibers on the filter;
C = Observed TEM asbestos fiber count.
When fibers are sparse, the observed count C has approximately a Poisson distribution with
parameter (mean) X = a*N/A, the expected number of fibers in the (small) area examined by
TEM. The detection limit (DL) for the analysis (estimated airborne asbestos concentration
corresponding to a single observed fiber) is
DL = A*a/V
The estimated airborne asbestos concentration for the sample is
(C*A)/(a*V) = C*DL
In the air analyses conducted for this project, the area of each filter examined by TEM was
varied to ensure a constant detection limit of 0.00049 for all the samples. Thus, the estimated
mean airborne asbestos concentration for all the AACM samples is given by
Mean airborne asbestos concentration = DL*(ŁC;)/36
where Q, i = I,...,36 are the individual sample results. This formula reduces to Mean AACM
airborne asbestos concentration = (Total AACM fiber count)*constant where the constant =
DL/36 = 1.35*10"5. Since the individual TEM analyses are independent, the total fiber count also
has a Poisson distribution (Bickel and Doksum, 1977).
109
-------
The mean NESHAP airborne asbestos concentration is proportional to the total NESHAP fiber
count, and the proportionality constant is the same, because the DL and the number of samples
are the same for both methods. Thus, under the null hypothesis that the AACM concentrations
are equal to the NESHAP concentrations, the total fiber counts for the two methods are
independent Poisson random variables with the same parameter. The null hypothesis will
therefore be rejected when the total AACM fiber count is sufficiently larger than the total
NESHAP fiber count.
Let C(A) and C(N) be the total fiber counts for the two methods. Although the parameter of the
common Poisson distribution is not known, and therefore cannot be used to determine the
statistical test, there is a conditional test which is independent of the value of the Poisson
parameter. Specifically, if C(A) and C(N) are independent Poisson variables with the same
parameter, the conditional distribution of C(A), given the combined total C(A)+C(N), has a
binomial distribution with parameters C(A)+C(N) and 0.5. This binomial distribution can be
used to determine the one-sided critical value for C(A), as follows. Referring to Table 7-1,
samples listed as non-detect (ND) had 0 fibers counted, those at 0.00049 had one fiber, 0.000145
had three fibers and 0.00194 had four fibers. The total fiber count for AACM was 18, and for
NESHAP, 4. Under the null hypothesis, the AACM count would be binomial with parameters 22
and 0.5. The probability of a value of 18 or greater is 0.002. The null hypothesis is therefore
rejected with p = 0.002.
Since the Poison analysis confirms the conclusions reached by the Chi-Square and Wilcoxon
tests, it was concluded that the airborne asbestos (TEM) concentrations from the AACM are not
equal to the airborne asbestos (TEM) concentrations from the NESHAP Method. In fact, the
empirical evidence (the proportion of non-detects and the maximum values) from the
investigation suggests airborne asbestos (TEM) concentrations from the AACM are greater than
the airborne asbestos (TEM) concentrations from the NESHAP Method.
The PCME data in Table 7-1 were collected under the same conditions as total asbestos and
received the same data treatment prior to any analyses. In this case, since 89% of the NESHAP
measurements and 92% of the AACM measurements are censored, no statistical analysis was
conducted.
7.1.2 Day 1 Comparisons: AACM versus NESHAP
In order to better understand the difference in total asbestos concentrations between the two
methods, a comparison was conducted using only the data from the actual building demolitions
(Table 7-2). As stated previously, thirty-two of the thirty-six total asbestos measurements for the
NESHAP method are non-detects (89% of the data are censored). Thirty-three of the thirty-six
total asbestos measurements for the AACM are non-detects (92% of the data are censored).
Although neither nonparametric test is appropriate for analyzing these data, the observed
proportion of detects would lead one to conclude that for this demonstration the difference
between the two methods is a function of the AACM Day 2 activities (soil excavation and
removal).
110
-------
Table 7-2. Airborne Asbestos Concentrations (s/cm ) for Total Asbestos (TEM)
for the AACM and NESHAP Method by Day.
Monitor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Height
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
AACM
Day 1
ND
ND
0.00096
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.00049
ND1
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.00049
ND
ND
ND
ND
ND
NESHAP
Day 1
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.00049
ND
ND
ND
ND
ND
0.00049
ND
ND
0.00049
ND
ND
0.00049
ND
ND
ND
ND
ND
ND
ND
ND
ND
AACM
Day 2
ND
ND
0.00049
0.00049
0.00049
ND
ND
0.00049
0.00049
ND
ND
ND
ND
ND
ND
ND
ND1
0.00049
ND
0.00049
0.00194
ND
0.00049
ND
ND
0.00049
0.00049
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND = 0.00048, or 0.00049 s/cm3
Sample 17 was inadvertently not changed out at the end of Day 1, but operated for the entire sampling
period; however, no asbestos structures were seen.
Ill
-------
7.2 Primary Objective 2
Null hypothesis: The post-excavation asbestos concentrations in the soil from the AACM
are equal to the post-demolition asbestos concentrations in the soil from the NESHAP
Method.
For each method and phase of the project (PRE-demolition, POST-demolition and POST-
excavation (AACM only)), ten composite soil samples were collected. Three fractions (soil,
rocks/organics, and building debris) of each composite sample were analyzed for asbestos. For
Primary Objective 2, the comparison of the AACM and NESHAP methods was based on the
number of asbestos structures per gram (s/g) of soil in the first fraction, as determined by TEM
(Table 7-3). Table 7-3 shows that the soil fraction was more than 95% of the sample by weight
in most cases. Within each method and phase, there is considerable variation (at least an order of
magnitude) in asbestos concentrations between different composites. Since each composite
represents, in theory, the average asbestos soil concentration within the bermed area for the
phase in question, the variation in reported levels is due to a combination of spatial variation in
asbestos soil concentrations, sub-sampling variability during sample preparation, and variability
of the TEM structure count.
Two of the ten structure count measurements for the post-demolition NESHAP method are non-
detects (20% of the data are censored). Seven of the ten structure count measurements for the
post-excavation AACM are non-detects (70% of the data are censored). The Wilcoxon Rank -
Sum test was used to evaluate the null hypothesis. The structure count ranks used to calculate
the test statistic are displayed in Table 7-3 for AACM post-excavation and NESHAP post-
demolition observations. The test provided a test statistic value of 2.1322 and p-value of 0.033;
therefore one would conclude the post-excavation asbestos concentrations in the soil from the
AACM are not equal to the post-demolition asbestos concentrations in the soil from the NESHAP
Method. Examination of the descriptive statistics for the structure counts reveals that the AACM
Table 7-3. Asbestos in Soil (s/g) by TEM by the AACM and NESHAP Method / Ranks for the
Wilcoxon Rank-Sum Test (NESHAP POST vs. AACM POST-EXCAV).
Method
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
Phase
PRE
PRE
PRE
PRE
PRE
PRE
PRE
PRE
PRE
PRE
POST
Composite
No.
1
2
3
4
5
6
7
8
9
10
1
Weight %
99.3
100
99.7
99.6
98.5
98.2
99.2
100
98.6
97.9
91.5
Asbestos
(s/g)
ND*
6.59E+07
ND
ND
3.29E+08
2.54E+07
5.73E+06
ND
7.75E+06
5.84E+07
8.96E+06
Structure
Count/
Rank
0
2
0
0
22
3
1
0
1
2
1/12.5
112
-------
Table 7-3. Asbestos in Soil (s/g) by TEM by the AACM and NESHAP Method / Ranks for the
Wilcoxon Rank-Sum Test (NESHAP POST vs. AACM POST-EXCAV). (Continued)
Method
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
Phase
POST
POST
POST
POST
POST
POST
POST
POST
POST
PRE
PRE
PRE
PRE
PRE
PRE
PRE
PRE
PRE
PRE
POST
POST
POST
POST
POST
POST
POST
POST
POST
POST
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
Composite
No.
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
Weight %
97.5
95.8
96.2
97.4
96.3
96.6
95.3
95.3
96.1
98.7
98.7
98.6
96.5
97.8
95.8
98.7
96.7
98.7
99.1
90.9
85.3
93.0
90.1
92.0
95.0
96.1
96.4
96.2
94.3
94.5
92.6
94.9
96.2
95.2
93.8
93.7
95.3
95.9
93.4
Asbestos
(s/g)
1.56E+08
ND
ND
5.79E+06
4.06E+06
1.60E+09
1.52E+07
9.17E+06
2.37E+07
ND
1.90E+07
ND
1.09E+07
ND
1.02E+07
ND
4.25E+07
1.51E+07
1.15E+10
ND
4.34E+07
1.76E+08
2.11E+08
9.67E+06
ND
2.97E+07
2.68E+07
ND
1.02E+07
8.07E+06
ND
ND
7.99E+06
1.51E+08
ND
ND
ND
ND
ND
Structure
Count/
Rank
71/19
0/5
0/5
1/12.5
1/12.5
119/20
2/16.5
1/12.5
2/16.5
0
3
0
1
0
1
0
4
2
136
0
6
13
24
1
0
4
4
0
1
1/12.5
0/5
0/5
1/12.5
11/18
0/5
0/5
0/5
0/5
0/5
*Note that composite samples for which the TEM structure count is zero are considered non-detects (ND).
113
-------
Table 7-4. Descriptive Statistics for the AACM (POST-EXCAVATION)
and NESHAP (POST-DEMOLITION) Structure Counts.
Method
NESHAP
AACM
Minimum
0
0
1SIQuartile
1
0
Median
1
0
3m Quartile
2
1
Maximum
119
11
has lower counts for the 1st, 2nd (median), and 3rd quartiles as well as the maximum (Table 7-4).
Therefore, the empirical evidence from this investigation suggests the post-excavation asbestos
concentrations in the soil from the AACM are less than the post-demolition asbestos
concentrations in the soil from the NESHAP Method.
7.3 Secondary Objective 2
Null hypothesis: The airborne fiber (PCM) concentrations from the AACM are equal to
the airborne fiber (PCM) concentrations from the NESHAP Method.
Table 7-5 displays the total fiber concentrations, as measured by PCM, for the AACM and
NESHAP method.
Prior to conducting a hypothesis test, the background data from both methods were evaluated.
The six background values surrounding the buildings to be demolished by each method are
displayed using box plots5 in Figure 7-1. The box plots show that the background concentration
in the area of the AACM demolition is higher than the area of the NESHAP demolition. The
AACM background median is 0.0025 f/cm3 and NESHAP background median is 0.0014 f/cm3.
Therefore prior to conducting any inferential tests, the appropriate median background
concentration was subtracted from the empirical values displayed in Table 7-5.
The null hypothesis was evaluated by conducting a Wilcoxon Rank Sum test (due to the non-
normality of the data), using the data from Day 1 for the NESHAP Method and the combined
data from Days 1 and 2 for the AACM, adjusted for background. The median adjusted data along
with the ranks used to calculate the test statistics are displayed in Table 7-6. The Wilcoxon test
provided a test statistic of-1.211 and a p-value of 0.2259; therefore, one would conclude there is
insufficient information to reject the null hypothesis that the airborne fiber (PCM)
concentrations from the AACM are equal to the airborne fiber (PCM) concentrations from the
A box plot is a rectangle in which the top and bottom of the rectangle represent the upper and lower quartiles of the
data and the horizontal line within the rectangle represents the median. Lines, in the shape of a -T-", extend from the
box to the nearest value not beyond a standard span from the quartiles. These lines are often referred to as
whiskers. Values beyond the end of the whiskers are drawn individually.
The standard span is l.Sinter-Quartile Range (IQR), where the upper quartile is the 75th quantile, Q(.75), the lower
quartile is the 25th quantile, Q(.25) and the IQR = Q(.75) Q(.25).
The box plot of a set of observations that are normally distributed will be symmetric with the median in the center of
the box.
114
-------
Table 7-5. Total Fiber Concentrations by PCM (f/cm ) for the
AACM and NESHAP Method by Day.
Monitor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
1
2
O
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Height
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
NESHAP (f/cm3)
DAY1
ND*
0.0014
ND
0.0016
0.0022
0.0013
0.0017
0.0018
0.0062
0.0045
0.0021
0.0034
0.0017
0.0029
0.0024
0.0025
0.0023
ND
0.0023
0.0013
0.0014
0.0032
0.0020
0.0011
0.0024
0.0039
0.0045
0.0022
0.0021
0.0030
0.0022
0.0035
ND
0.0056
0.0019
0.0017
AACM (f/cm3)
DAY1
0.0032
0.0034
0.0033
0.0024
0.0021
0.0012
0.0015
0.0042
0.0044
0.0018
0.0040
0.0031
0.0024
0.0037
0.0020
0.0029
i
0.0035
0.0021
0.0029
0.0053
0.0013
0.0026
0.0020
0.0023
0.0022
0.0023
0.0029
0.0027
0.0040
0.0038
0.0029
0.0027
0.0012
0.0028
0.0032
DAY 2
0.0029
0.0023
0.0037
0.0035
0.0028
0.0041
0.0026
0.0011
0.0046
0.0021
0.0048
0.0046
0.0041
0.0012
0.0023
0.0055
i
0.0022
0.0024
0.0018
0.0036
0.0019
0.0017
0.0033
0.0027
0.0160
0.0024
0.0019
0.0024
0.0044
0.0036
0.0029
0.0021
0.0034
0.0033
0.0024
TOTAL
0.0061
0.0057
0.0070
0.0059
0.0049
0.0053
0.0041
0.0053
0.0090
0.0039
0.0088
0.0077
0.0065
0.0049
0.0043
0.0084
0.0017
0.0057
0.0045
0.0047
0.0089
0.0032
0.0043
0.0053
0.0050
0.0182
0.0047
0.0048
0.0051
0.0084
0.0074
0.0058
0.0048
0.0046
0.0061
0.0056
*ND= 0.0012 f/cm3.
1 Sample 17 was inadvertently not changed out at the end of Day 1, but operated for the entire sampling period.
115
-------
Table 7-6. Median Adjusted Total Fiber Concentrations
the AACM and NESHAP / Ranks for the Wilcoxon
by PCM (f/cm3) for
Rank-Sum Test.
Monitor
1
2
O
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Height
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
5-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
15-ft
NESHAP (f/cmj)
[Day 1 - Median] *
/Rank
-0.0002/15.5
0/23
-0.0002/15.5
0.0002/26
0.0008/43
-0.0001/20.5
0.0003/29.5
0.0004/33
0.0048/71
0.0031/63.5
0.0007/37.5
0.002/57.5
0.0003/29.5
0.0015/54
0.001/48.5
0.0011/50
0.0009/46.5
-0.0002/15.5
0.0009/46.5
-0.0002/15.5
0/23
0.0018/56
0.0006/36
-0.0003 / 10
0.001/48.5
0.0025/61
0.0031/63.5
0.0008/43
0.0007/37.5
0.0016/55
0.0008/43
0.0021/59
-0.0002/15.5
0.0042 / 70
0.0005/34
0.0003/29.5
AACM (f/cmj)
[Day 1 + Day 2 -
2*Median] / Rank
0.0011/51.5
0.0007/39.5
0.002/57.5
0.0009/45
-0.0001/18.5
0.0003/29.5
-0.0009/4
0.0003/29.5
0.004/69
-0.0011/3
0.0038/67
0.0027 / 62
0.0015/53
-0.0001/18.5
-0.0007/5.5
0.0034/65.5
-0.0033 / 1
0.0007/39.5
-0.0005/7
-0.0003 / 10
0.0039/68
-0.0018/2
-0.0007/5.5
0.0003/29.5
0/23
0.0132/72
-0.0003 / 10
-0.0002/15.5
0.0001/25
0.0034/65.5
0.0024 / 60
0.0008/41
-0.0002/15.5
-0.0004 / 8
0.0011/51.5
0.0006/35
116
-------
NESHAP Method. Figure 7-2 displays box plots for the median adjusted airborne fiber (PCM)
concentrations for the AACM and NESHAP Method on Day 1, the AACM on Day 2, and
the AACM where both days are combined. The box plots confirms the result from the
hypothesis test, the box plots for the NESHAP Method Dayl and the AACM combined do not
appear to differ.
A Day 1 comparison of the airborne fiber (PCM) concentrations between the two methods was
conducted using the Wilcoxon Rank-Sum test. Like the conclusion from PO1, the test provided
a significant p-value of 0.0167; therefore, one would conclude the airborne fiber (PCM)
concentrations for the two methods are not equal on Day 1. Based on the box plots displayed in
Figure 7-1 one would conclude that the airborne fiber (PCM) concentrations for the AACM are
less than the airborne fiber (PCM) concentrations for the NESHAP for the demolition day.
8-
8-
Filled Circles = Detect Values
Unfilled Circles = Non-detect Values (DL)
X = Mean Value
Figure 7-1. Box plots for the Background Total Fiber Concentrations by
PCM (f/cm3) for the AACM and NESHAP Method.
117
-------
Filled Circles = Detect Values
Unfilled Circles = Non-detect Values
X = Mean
T
I
NESHAP Day 1 AACM Day 1 AACM Day 2 AACM Day 1 +2
Figure 7-2. Box plots for the Background Total Fiber Concentrations by PCM (f/cm )
Adjusted for Background AACM and NESHAP Methods by Day.
7.4 Secondary Objectives 4 and 5
Null hypothesis 4: The NESHAP airborne asbestos (TEM) concentrations downwind are
equal to the NESHAP airborne asbestos concentrations upwind.
Null hypothesis 5: The AACM airborne asbestos (TEM) concentrations downwind are
equal to the AACM airborne asbestos concentrations upwind.
During the NESHAP demolition, the wind blew from west-southwest approximately 75% of the
time, and from northeast-north the other 25% of the time. For the AACM demolition, the wind
blew between west and south approximately 50% of the time, between east and south
approximately 30% of the time, and between East and East-Northeast 20% of the time. For the
AACM soil excavation and removal, the wind was between south and southeast 100% of the
time. Since the wind direction was variable during the processes for both methods, the terms
-ttpwind" and -downwind" are not unambiguously defined for the entire duration of the process.
Therefore, Secondary Objectives 4 and 5 cannot be directly evaluated using the study data.
However, as suggested in the Q APP, it may still be of interest to determine whether there is a
relationship between the airborne asbestos concentration at a sampling location and the amount
of time that location was downwind from the demolition site.
Figure 4-1 and Figure 4-2 show the inner ring of samplers (monitors) approximately equally
spaced on a rectangle around the building. The monitors are numbered in clockwise order,
118
-------
starting with Ml located at the northwest corner of the ring. Using this figure and the three wind
roses for the NESHAP and AACM, the percent of time each monitor was downwind of the
building was estimated. For the AACM, the percent of time downwind is an average for the two
days. Table 7-7 shows the results, as well as the total airborne asbestos concentration at each
monitor. Data treatment prior to constructing Table 7-7 and conducting analyses are identical to
Primary Objective 1.
The data in Table 7-7 are displayed by method in Figure 7-3 and Figure 7-4, where the unfilled
circles display the non-detect values and the filled circles display the detect values. (Note the
non-detect measurements were given a value of zero for plotting in order to better distinguish the
non-detects from detect values). Based on Figure 7-3 and Figure 7-4, the data are inconclusive
with regard to Secondary Objectives 4 and 5. One would conclude the data from this
investigation are not sufficient to establish a relationship between percent of time downwind and
total airborne asbestos concentration.
Table 7-7. Total Airborne Asbestos Concentrations (TEM) and Percent of Time
Downwind, for AACM (Days 1 and 2 Combined) and NESHAP Method.
MONITOR
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
NESHAP
DOWNWIND
0%
12%
67%
74%
74%
74%
74%
67%
67%
0%
20%
27%
27%
27%
27%
27%
14%
0%
TOT. ASB.
(s/cm3)
ND*
ND
0.00049
ND
ND
0.00049
ND
ND
0.00049
ND
ND
ND
ND
ND
0.00049
ND
ND
ND
AACM
DOWNWIND
64%
77.5%
87.5%
87.5%
87.5%
84%
23.5%
13.5%
13.5%
0%
0%
2.5%
2.5%
2.5%
2.5%
2.5%
9%
70.5%
TOT. ASB.
(s/cm3)
ND
0.00049
0.00339
0.00049
0.00098
ND
ND
0.00098
0.00098
ND
ND
ND
0.00049
ND
ND
0.00049
ND
0.00049
*ND = 0.00033, 0.00048, or 0.00049 s/cm3
119
-------
•a g
o o o o
40 60
Percent Downwind
Figure 7-3. NESHAP Total Airborne Asbestos Concentrations (TEM) by
Percent of Time Downwind. (Filled Circles = Detect Values;
Unfilled Circles = Non-detect Values).
o o o
40 60
Percent Downwind
Figure 7-4. AACM Total Airborne Asbestos Concentrations (TEM)
(Days 1 and 2 Combined) by Percent of Time Downwind.
(Filled Circles = Detect Values; Unfilled Circles = Non-detect Values).
120
-------
7.5 Secondary Objective 6
Null hypothesis: The asbestos loadings in the settled dust (TEM)from the AACMare
equal to the asbestos loadings in the settled dust (TEM) from the NESHAP Method.
Table 7-8 shows asbestos loadings in settled dust (s/cm2) in the inner ring of monitoring stations
for each method. Despite a low percent of censored data, five percent (one out of 18) of the
NESHAP measurements and twenty-two percent (four out of 18) of the AACM data are
censored, the null hypothesis was evaluated by conducting a Wilcoxon Rank Sum test due to the
non-normality of the distributions. The Wilcoxon test provided a test statistic value of 0.3164
and a p-value of 0.7517; therefore, one would conclude there is insufficient information to reject
the null hypothesis that the asbestos loadings in the settled dust (TEM) from the AACMare equal
to the asbestos loadings in the settled dust (TEM) from the NESHAP Method.
Examining the data using the empirical cumulative distributions would lead one to conclude
there is no difference in the settled dust distributions of the two methods (see Figure 7-5). The
Kolmogorov-Smirnov test, which tests the relationship between two distributions (the null
hypothesis is there is no difference in the empirical distributions), confirms this observation with
a test statistic value of 0.2222 and p-value of 0.781. The descriptive statistics (Table 7-9) show a
slight difference at the lower quartiles, and at the upper quartiles the AACM concentrations are
less than the NESHAP. Based on Figure 7-5, Table 7-9, and the results of the Kolmogorov-
Smirnov test, one would conclude there is no difference in the settled dust distributions of the two
methods.
Table 7-
-8. Asbestos Loadings (TEM) in Settled Dust (s/cm2) in the Inner Ring.
MONITOR
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
AACM
243
10,852
11,158
21,625
485
1,455
19,976
728
2,547
243
849
1,698
9,302
1,941
2,426
926
ND
4,851
NESHAP
ND*
ND
463
ND
ND
980
4,862
8,005
46,771
424
10,882
6,020
15,050
9,262
10,825
3,396
2,084
212
* ND = 212, 222, 232 s/cm2.
121
-------
Table 7-9. Descriptive Statistics for Asbestos Loadings in the Settled Dust (s/cm )
in the Inner Ring for the AACM and NESHAP Method (Sample Size=18).
Method
NESHAP
AACM
Minimum
106
116
1stQuartile
265
758
Median
2740
1819
3rd Quartile
8948
8189
Maximum
46771
21625
Comparison of Empirical cdfs of AACM.dust and NESHAP.dust
dotted line is cdf of NESHAP.dust
Figure 7-5. Empirical Cumulative Distributions for the Asbestos Loadings in the Settled Dust
(s/cm2) in the Inner Ring for the AACM and NESHAP Method.
7.6 Secondary Objective 7
Null hypothesis: The total paniculate concentrations (as collected and measured by
NIOSH Method 5000) from the AACM are equal to the total paniculate concentrations
from the NESHAP Method.
Table 7-10 shows total particulate concentrations (mg/m3) by monitor in the inner ring for the
NESHAP and AACM buildings. Since fifty-five percent (ten out of 18) of the NESHAP
measurements and five percent (one out of 18) of the AACM measurements are censored, the
Wilcoxon Rank Sum test was used to evaluate the null hypothesis. . The total particulate
concentration ranks used to calculate the test statistic are displayed in Table 7-10. The
Wilcoxon Rank Sum test statistic provided a p-value of 0.002; therefore, one would reject the
null hypothesis and conclude the total particulate concentrations (as collected and measured by
122
-------
Table 7-10. Total Particulate Concentrations (mg/m3) for the AACM and NESHAP
Method Methods / Ranks for the Wilcoxon Rank-Sum Test.
MONITOR
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
AACM
0.15/35.5
0.14/33
0.14/33
0.04/5
0.15/35.5
0.1/29.5
0.14/33
0.096/28
0.067/20
0.048/6
0.072/26
ND/14
0.068/22
0.062/18
0.067/20
0.03/3.5
0.083/27
0.067/20
NESHAP
0.11/31
0.07/24
ND*/14
ND/1.5
ND/14
ND/14
ND/8.5
ND/14
0.06/14
ND/14
0.07/24
ND/8.5
ND/8.5
0.1/29.5
ND/8.5
0.07/24
0.03/3.5
ND/1.5
*ND = 0.02, 0.05, and 0.06 mg/m3.
NIOSHMethod 5000) from the AACM are not equal to the total particulate concentrations from
the NESHAP Method.
Based on the observed proportion of detects, one would conclude that for this demonstration the
total particulate concentration from the AACM are higher than the total particulate
concentration from the NESHAP method.
7.7 Secondary Objective 8
Null hypothesis: The worker breathing zone fiber concentrations (PCM) from the AACM
are equal to the worker breathing zone fiber concentrations (PCM) from the NESHAP
Method.
Table 7-11 displays the worker breathing zone data (PCM) during demolition operations for the
two methods. The -Walker" samples were collected on personal monitors of personnel walking
the two rings of samplers to check for personal breathing zone asbestos concentrations during
that activity. Since these samples were not taken on typical workers who would be involved in
either a NESHAP or AACM demolition, they were excluded from the analysis. A two-sample li-
test was used to evaluate the null hypothesis, since there were no non-detects for the AACM and
two out of seventeen non-detects for the NESHAP Method. The t-test statistic provided a test
statistic value of-2.604 and a p-value of 0.015; therefore, one would reject the null hypothesis
and conclude the worker breathing zone fiber concentrations (PCM) from the AACM are not
equal to the worker breathing zone fiber concentrations (PCM) from the NESHAP Method.
123
-------
Table 7-11. Total Fibers (f/cm3 by PCM) on Worker Personal Monitors Measured at NESHAP
and AACM Buildings during Demolition and Removal of Debris.
WORKER
Excavator Operator
Hose Operator 1
Hose Operator 2
Laborer 1
Laborer 2
Truck Operator 1
Truck Operator 2
Truck Operator 3
Walker 1
Walker 2
Walker 3
Abatement Worker 1
Abatement Worker 2
Abatement Worker 3
Abatement Worker 4
Abatement Worker 5
Abatement Worker 6
AACM
0.0038
0.0073
0.0051
0.013
0.016
0.0091
0.017
0.0070
0.0077
0.013
0.018
N/A
N/A
N/A
N/A
N/A
N/A
NESHAP
0.023
0.017
0.0089
0.012
0.036
0.042
0.056
0.086
0.027
0.0090
0.031
0.022
ND*
0.12
0.083
ND
0.084
*ND = 0.00 If/cm3
Figure 7-6 displays the box plots for worker fiber breathing zone concentrations (PCM)
for the two methods. Based on Figure 7-6, one would conclude the worker breathing zone fiber
concentrations (PCM) from the AACM are less than the worker breathing zone fiber
concentrations (PCM) from the NESHAP Method.
Filled Circles = Detect Values
Unfilled Circles = Non-detect Values
X = Mean
Figure 7-6. Box plots for Total Fibers (f/cm3 by PCM) on Worker Personal Monitors
during Demolition and Removal of Debris.
124
-------
Note that there were too few samples (n=4 for AACM and n=3 for NESHAP) from landfill
workers to conduct an inferential test (Appendix A, Table A-9). A similar trend (NESHAP was
higher than the AACM) was observed in the data, where the mean of the NESHAP Method is
0.115 f/cm3 and the mean of the AACM is 0.032 f/cm3.
7.8 Secondary Objective 9
Null hypothesis: The worker breathing zone asbestos concentrations (TEM) from the
AACM are equal to the worker breathing zone asbestos concentrations (TEM) from the
NESHAP Method.
Table 7-12 displays the total asbestos concentrations measured on worker personal monitors
during all phases of both methods. Since 100 percent (eight out of eight) of the AACM
measurements and 50 percent (seven out of 14) of the NESHAP measurements are censored, no
inferential test was conducted. Based on the observed proportion of detects, one would conclude
that for this demonstration the worker breathing zone asbestos concentrations (TEM) from the
AACM are less than the worker breathing zone asbestos concentrations (TEM) from the
NESHAP method.
Table 7-12. Total Asbestos (s/cm3 by TEM) on Worker Personal Monitors Measured at NESHAP
and AACM Buildings During Abatement, Building Demolition, and Removal of Debris.
WORKER
Excavator Operator
Hose Operator 1
Hose Operator 2
Laborer 1
Laborer 2
Truck Operator 1
Truck Operator 2
Truck Operator 3
Abatement Worker 1
Abatement Worker 2
Abatement Worker 3
Abatement Worker 4
Abatement Worker 5
Abatement Worker 6
AACM
ND*
ND
ND
ND
ND
ND
ND
ND
N/A
N/A
N/A
N/A
N/A
N/A
NESHAP
ND
ND
0.00049
0.00048
ND
ND
ND
ND
0.06500
0.00190
0.03500
0.01800
ND
0.07100
*ND = 0.00041, 0.00046, 0.00047, 0.00048, and 0.00049 s/cm3
125
-------
7.9 Secondary Objectives 11,12, and 13
Null hypothesis 11: The post-excavation asbestos concentration in the soil from the
AACM are equal to the pre-demolition asbestos concentration for the AACM.
Null hypothesis 12: The post-demolition asbestos concentration in the soil from the
NESHAP Method are equal to the pre-demolition asbestos concentration for the
NESHAP Method.
Null hypothesis 13: The post-excavation asbestos concentration in the soil from the
AACM are equal to the post -demolition asbestos concentration for the AACM.
The data are displayed in Table 7-3. The percent censoring for each of the three secondary
objectives is displayed in Table 7-13.
For Secondary Objectives 11, 12, and 13, the Wilcoxon Rank-Sum test was used to evaluate the
null hypothesis. In each case, the null hypothesis was not rejected. The structure counts as well
as the structure counts ranks used to calculate the test statistic are displayed in Table 7-14. The
p-values are 0.94, 0.32, and 0.98 for Secondary Objectives 11, 12 and 13, respectively.
One would conclude there was insufficient information to reject the null hypotheses that: the
post-excavation asbestos concentrations in the soil from the AACM are equal to the pre-
demolition asbestos concentrations for the AACM; the post-demolition asbestos concentrations
in the soil from the NESHAP Method are equal to the pre-demolition asbestos concentrations for
the NESHAP Method; and the post-excavation asbestos concentrations in the soil from the
AACM are equal to the post-demolition asbestos concentrations for the AACM.
Table 7-13. Degree of Censoring for Secondary Objectives 11, 12, and 13.
Secondary Objective
11
Secondary Objective
12
Secondary Objective
13
Post-Excavation AACM
80% censored (8 out of 10)
Post-Demolition NESHAP
20% censored (2 out of 10)
Post-Excavation AACM
70% censored (7 out of 10)
Pre-Demolition AACM
40% censored (4 out of 10)
Pre-Demolition NESHAP
40% censored (4 out of 10)
Post -Demolition AACM
30% censored (3 out of 10)
126
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Table 7-14. Asbestos Structure Counts in Soil (s/g) by TEM by the AACM and NESHAP
Methods / Ranks for the Wilcoxon Rank-Sum Tests.
SO11
AACM
PRE
0/6
3/17
0/6
1/13.5
0/6
1/13.5
0/6
4/18
2/16
136/20
AACM
POST-
EXCAV
1/13.5
0/6
0/6
1/16.5
11/19
0/6
0/6
0/6
0/6
0/6
SO12
NESHAP
PRE
0/3.5
2/14.5
0/3.5
0/3.5
22/18
3/17
1/9.5
0/3.5
1/9.5
2/14.5
NESHAP
POST
1/9.5
71/19
0/3.5
0/3.5
1/9.5
1/9.5
119/20
2/14.5
1/9.5
2/14.5
SO13
AACM
POST
0/5.5
3/17
13/19
24/20
1/12.5
0/5.5
4/15.5
4/15.5
0/5.5
1/12.5
AACM
POST-
EXCAV
1/12.5
0/5.5
0/5.5
1/12.5
11/18
0/5.5
0/5.5
0/5.5
0/5.5
0/5.5
The descriptive statistics in Table 7-15, show that: the AACMpre-demolition soil concentrations
are greater than the post-excavation soil concentrations in the upper tails of the distributions;
the NESHAP pre-demolition soil concentrations are less than the post-demolition soil
concentrations in the upper tails of the distributions; and the AACM post-demolition soil
concentrations are greater than the AACM post-excavation soil concentration in the upper tails
of the distributions.
Table 7-15. Asbestos in Soil (s/g) by TEM by the AACM and NESHAP Method.
Method
NESHAP
Pre-Demolition
NESHAP
Post-Demolition
AACM
Pre-Demolition
AACM
Post-Demolition
AACM
Post-Excavation
Minimum
0
0
0
0
0
1st
Quartile
0
1
0
0
0
Median
1
1
1
3
0
3ra
Quartile
2
2
2.73
6
0
Maximum
22
119
136
24
11
127
-------
7.10 Secondary Objectives 14,15, 16, and 17
Null hypothesis 14: The post-excavation asbestos concentration from elutriator test on
soil from the AACM is equal to the post-demolition asbestos concentration from
elutriator test on soil from the NESHAP Method.
Null hypothesis 15: The post-excavation asbestos concentration from elutriator test on
soil from the AACM is equal to the pre-demolition asbestos concentration from elutriator
test on soil from the AACM.
Null hypothesis 16: The post-demolition asbestos concentration from elutriator test on
soil from the NESHAP Method is equal to the pre-demolition asbestos concentration from
elutriator test on soil from the NESHAP Method.
Null hypothesis 17: The post-excavation asbestos concentration from elutriator test on
soil from the AACM is equal to the post-demolition asbestos concentration from
elutriator test on soil from the AACM.
Table 7-16 displays the asbestos concentrations from soil elutriator tests (millions of structures
per gram PMio), by method and phase. Three of the ten composite soil samples (see Primary
Objective 2) were analyzed using the elutriator test for each method and phase. Non-detects
(zero asbestos fibers counted) are reported as ND.
Due to the small sample sizes (n=3), no inferential tests were conducted.
Table 7-16. Asbestos Soil Concentrations (TEM) from Elutriator Tests.
METHOD
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
PHASE
PRE
PRE
PRE
POST
POST
POST
PRE
PRE
PRE
POST
POST
POST
POST-EXCAV
POST-EXCAV
POST-EXCAV
COMPOSITE
2
5
8
2
5
8
2
5
8
2
5
8
2
5
8
TOTAL ASBESTOS
(106s/gPM10)
16.9
31.2
12.7
2.21
ND*
3.55
37.6
9.04
37.3
4.06
5.22
ND
ND
2.19
32.0
*ND = 2.19E+06, 2.47E+06, and 2.78E+06 millions of structures/g PM10.
128
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7.11 Secondary Objectives 20, 21, and 22
Null hypothesis 20: The airborne asbestos concentrations (TEM) at the landfill during
the disposal of debris from the AACM are equal to the airborne asbestos concentrations
(TEM) at the landfill during the disposal of debris from the NESHAP Method.
Null hypothesis 21: The landfill worker breathing zone fiber concentrations (PCM) from
the AACM are equal to the landfill worker breathing zone fiber concentrations (PCM)
from the NESHAP Method.
Null hypothesis 22: The landfill worker breathing zone asbestos concentrations (TEM)
from the AACM are equal to the landfill worker breathing zone asbestos concentrations
(TEM) from the NESHAP Method.
A total of 27 samples were taken during disposal operations at the landfill, of which only two
showed detectable concentrations of airborne asbestos by TEM (one fiber observed for each
method). Since over ninety percent of the data are censored, no inferential test was conducted
for Secondary Objective 20.
With regard to worker exposure during landfill operations, all TEM samples were non-detect.
Since 100 percent of the data are censored, no inferential test was conducted for Secondary
Objective 21.
With regard to worker exposure during landfill operations, the number of PCM samples was too
small (n=2) for a meaningful comparison, so no inferential test was conducted for Secondary
Objective 22.
7.12 Additional Secondary Objective
Null hypothesis: The post-excavation percent by weight of asbestos-containing material
(ACM) (primarily vinyl asbestos tile (VAT)) in the soil from the AACM is equal to the
post-demolition percent by weight of asbestos-containing material (ACM) (primarily
vinyl asbestos tile (VAT)) in the soil from the NESHAP Method.
Table 7-17 displays the percent by weight of asbestos-containing material (ACM) in the ten
composite samples from the post-excavation phase of the AACM compared to the post-
demolition phase of the NESHAP Method. A two sample t-test was conducted to evaluate the
null hypothesis. Since the t-test statistic provided a test statistic of 4.279 and a p-value of
0.0005, one would reject the null hypothesis and conclude the post-excavation percent by weight
of asbestos-containing material (ACM) (primarily vinyl asbestos tile (VAT)) in the soil from the
AACM is not equal to the post-demolition percent by weight of asbestos-containing material
(ACM) (primarily vinyl asbestos tile (VAT)) in the soil from the NESHAP Method. In fact, based
on the box plots in Figure 7-7, one would conclude the post-excavation percent by weight of
asbestos-containing material (ACM) (primarily vinyl asbestos tile (VAT)) in the soil from the
AACM is less than to the post-demolition percent by weight of asbestos-containing material
(ACM) (primarily vinyl asbestos tile (VAT)) in the soil from the NESHAP Method.
129
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Table 7-17. Percent by Weight of Asbestos-Containing Material (ACM) in
Soil Samples for the NESHAP Method and AACM.
METHOD
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
NESHAP
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
AACM
PHASE
POST
POST
POST
POST
POST
POST
POST
POST
POST
POST
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
POST-EXCAV
COMPOSITE
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
% ACM BY WEIGHT
0.172
0.047
0.071
0.013
0.115
0.115
0.064
0.020
0.104
0.141
0.038
0.007
0
0
0.023
0.011
0
0.016
0.023
0.020
Filled Circles = Detect Values
X = Mean
NESHAP
AACM
Figure 7-7. Box plots for Percent by Weight of Asbestos-Containing Material (ACM)
in Soil Samples for the NESHAP Method and AACM.
130
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7.13 Summary of Statistical Conclusions
OBJ.
CONCLUSION
STATISTICAL
TEST
P-
VALUE
PO1
Reject the null hypothesis and conclude the
airborne asbestos (TEM) concentrations from
the AACMare not equal to the airborne
asbestos (TEM) concentrations from the
NESHAP Method. The empirical evidence (the
proportion of non-detects and the maximum
values) from the investigation suggests
airborne asbestos (TEM) concentrations from
the AACM are greater than the airborne
asbestos (TEM) concentrations from the
NESHAP Method.
Wilcoxon
Rank-Sum
Chi-square
0.0006
0.004
PO2
Reject the null hypothesis and conclude the
post-excavation asbestos concentrations in the
soil from the AACM are not equal to the post-
demolition asbestos concentrations in the soil
from the NESHAP Method. Based on
descriptive statistics, one would conclude the
post-excavation asbestos concentrations in the
soil from the AACM are less than the post-
demolition asbestos concentrations in the soil
from the NESHAP Method.
Wilcoxon
Rank-Sum
0.033
S02
Conclude there is insufficient information to
reject the null hypothesis that the airborne
fiber (PCM) concentrations from the AACM
are equal to the airborne fiber (PCM)
concentrations from the NESHAP Method.
Based on descriptive statistics one would
conclude the fiber (PCM) concentrations for
the two methods are equivalent.
Wilcoxon
Rank-Sum
0.2259
S04
Based on scatter plots, one would conclude
there is no relationship between the NESHAP
airborne asbestos (TEM) concentrations
downwind and the NESHAP airborne asbestos
concentrations upwind.
No inferential test conducted
due to censored data.
SOS
Based on scatter plots, one would conclude
there is no relationship between the AACM
airborne asbestos (TEM) concentrations
downwind and the AACM airborne asbestos
concentrations upwind.
No inferential test conducted
due to censored data.
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OBJ.
CONCLUSION
STATISTICAL
TEST
P-
VALUE
S06
Conclude there is insufficient information to
reject the null hypothesis that the asbestos
loadings in the settled dust (TEM) from the
AACMare equal to the asbestos loadings in
the settled dust (TEM) from the NESHAP
Method. Based on descriptive statistics, plots
of the empirical CDFs, and the K-S test, one
would conclude the AACM asbestos loadings
in settled dust are equal to the NESHAP
asbestos loadings in settled dust.
Wilcoxon
Rank-Sum
0.7517
SO7
Reject the null hypothesis and conclude the
total particulate concentrations (as collected
and measured by NIOSH Method 0500) from
the AACM are not equal to the total particulate
concentrations from the NESHAP Method.
Based on the observed proportion of detects,
conclude that for this demonstration the total
particulate concentrations from the AACM are
higher than the total particulate
concentrations from the NESHAP Method.
Wilcoxon
Rank-Sum
0.002
SOS
Reject null hypothesis and conclude the worker
breathing zone fiber concentrations (PCM)
from the AACM are not equal to the worker
breathing zone fiber concentrations (PCM)
from the NESHAP Method. Based on
descriptive statistics, one would conclude the
worker breathing zone fiber concentrations
(PCM) from the AACM are less than the
worker breathing zone fiber concentrations
(PCM) from the NESHAP Method.
Two Sample
t-test
0.015
S09
Based on the observed proportion of detects,
conclude that for this demonstration the
worker breathing zone asbestos concentrations
(TEM) from the AACM are less than the
worker breathing zone asbestos concentrations
(TEM) from the NESHAP method.
No inferential test conducted
due to greater than 90%
censored data.
SO11
Conclude there is insufficient information to
reject the null hypothesis that the post-
excavation asbestos concentration in the soil
from the AACM are equal to the pre-
demolition asbestos concentrations. The
descriptive statistics show that the AACMpre-
demolition soil concentrations are greater than
the AACM post-excavation soil concentrations
in the upper tails of the distributions.
Wilcoxon
Rank-Sum
0.94
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OBJ.
CONCLUSION
STATISTICAL
TEST
P-
VALUE
S012
Conclude there is insufficient information to
reject the null hypothesis that the post-
demolition asbestos concentration in the soil
from the NESHAP Method are equal to the
pre-demolition asbestos concentrations. The
descriptive statistics show that the NESHAP
pre-demolition soil concentrations are less
than the post-demolition soil concentrations in
the upper tails of the distributions.
Wilcoxon
Rank-Sum
0.32
S013
Conclude there is insufficient information to
reject the null hypothesis that the post-
excavation asbestos concentrations in the soil
from the AA CM are equal to the post-
demolition asbestos concentrations. The
descriptive statistics show that the AACMpost-
demolition soil concentrations are greater than
the AACM post-excavation soil concentration
in the upper tails of the distributions.
Wilcoxon
Rank-Sum
0.98
SO14
Insufficient data to evaluate the null hypothesis
that the post-excavation asbestos
concentrations from elutriator test on soil from
the AACM are equal to the post-demolition
asbestos concentrations from elutriator test on
soil from the NESHAP Method.
No inferential test conducted
due to small sample size
(n=3).
SO15
Insufficient data to evaluate the null hypothesis
that the post-excavation asbestos
concentrations from elutriator test on soil from
the AACM are equal to the pre-demolition
asbestos concentrations from elutriator test on
soil from the AACM.
No inferential test conducted
due to small sample size
(n=3).
S016
Insufficient data to evaluate the null hypothesis
that the post-demolition asbestos
concentrations from elutriator test on soil from
the NESHAP Method are equal to the pre-
demolition asbestos concentrations from
elutriator test on soil from the NESHAP
Method.
No inferential test conducted
due to small sample size
(n=3).
SO17
Insufficient data to evaluate the null hypothesis
that the post-excavation asbestos
concentrations from elutriator test on soil from
the AACM are equal to the post-demolition
asbestos concentrations from elutriator test on
soil from the AACM.
No inferential test conducted
due to small sample size
(n=3).
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OBJ.
CONCLUSION
STATISTICAL
TEST
P-
VALUE
S020
Unable to conduct inferential test to evaluate
the null hypothesis the airborne asbestos
concentrations (TEM) at the landfill during the
disposal of debris from the AACM are equal to
the airborne asbestos concentrations (TEM) at
the landfill during the disposal of debris from
the NESHAP Method.
No inferential test conducted
due to greater than 90%
censored data.
SO21
Unable to conduct inferential test to evaluate
the null hypothesis the landfill worker
breathing zone fiber concentrations (PCM)
from the AACM are equal to the landfill
worker breathing zone fiber concentrations
(PCM) from the NESHAP Method.
No inferential test conducted
due to greater than 90%
censored data.
S022
Unable to conduct inferential test to evaluate
the null hypothesis the landfill worker
breathing zone asbestos concentrations (TEM)
from the AACM are equal to the landfill
worker breathing zone asbestos concentrations
(TEM) from the NESHAP Method.
No inferential test conducted
due to greater than 90%
censored data.
ADD.
SO
Reject the null hypothesis and conclude the
post-excavation percent by weight of asbestos-
containing material (ACM) (primarily vinyl
asbestos tile (VAT)) in the soil from the AACM
is not equal to the post-demolition percent by
weight of asbestos-containing material (ACM)
(primarily vinyl asbestos tile (VAT)) in the soil
from the NESHAP Method. Additional
analyses using box plots lead one to conclude
the post-excavation percent by weight of
asbestos-containing material (ACM)
(primarily vinyl asbestos tile (VAT)) in the soil
from the AACM is less than the post-
demolition percent by weight of asbestos-
containing material (ACM) (primarily vinyl
asbestos tile (VAT)) in the soil from the
NESHAP Method.
Two Sample
t-test
0.0005
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SECTION 8 COST COMPARISON OF DEMOLITION OF NESHAP
AND AACM BUILDINGS
The costs associated with the building demolitions were documented and analyzed to clearly and
transparently assign the appropriate cost element to the individual demolition. Costs attributable
to conducting the research effort were excluded from these demolition costs. Ultimately, the
total costs per cost element were obtained and summarized for both the NESHAP demolition and
the AACM demolition. This allowed for effective costs comparisons between the total cost of
both processes as well as the cost elements in each process.
Specifically, the demolition costs presented include:
• The cost of all labor, materials, and supplies to perform the abatement of the NESHAP
building. These costs included: 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.
• The cost of all labor, materials, and supplies to perform the post-abatement demolition of
the NESHAP building. These costs included: demolition of the structure, transportation
and disposal of the construction debris, and grading for future use.
» The cost of all labor, materials, and supplies to demolish the AACM building. These
costs included: 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 debris as asbestos-containing waste at a licensed landfill; post-demolition
excavation of soil; and transportation and disposal of soil as asbestos-containing waste at
the Fort Smith landfill.
* The cost of all federal, state, and local enforcement activities relative to each method of
demolition and disposal.
8.1 Methodology
A cost comparison was performed of the demolition of Building 3602 (NESHAP) and Building
3607 (AACM). In order to provide a fair comparison of the two methods, research project-
related sampling effort (labor and equipment), site preparation costs related to the sampling
effort, redundant equipment onsite due to the research effort that would not normally be required
for a typical demolition project, other redundancies (excess workers), and down time of
demolition equipment and personnel due to delays caused by non-demolition related items (e.g.,
work delay due to unacceptable weather conditions) were excluded from the demolition costs.
Specific costs items excluded from the presented demolition costs include:
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* Project planning and QAPP development.
* Sampling related to the research effort that would not normally be required.
* Site preparation such as roadwork, installation of sampling stations, onsite trailers,
fencing, plastic cover for surrounding buildings.
* Redundant capabilities not typical on demolition projects.
* Onsite electrical installed for sampling equipment.
* Downtime due to weather delays or truck delays (in case of AACM Building).
« Onsite security for sampling equipment.
• Other miscellaneous costs not directly related to the demolition.
Invoices from contractors and material purchases, time sheets, trucking invoices, and waste
disposal tickets were used to develop the demolition costs. As such, the costs were the actual
costs incurred during the demolition of Buildings 3602 and 3607 and reflected labor and
equipment rates available in Fort Smith, Arkansas. It should be noted that construction crew
stand-by costs resulting from weather-related delays were excluded from the presented
demolition costs. For similar demolition activities performed in other locations, the cost may
increase or decrease depending on local conditions and the competitiveness of firms offering
these services.
Costs that apply to both buildings include the pre-demolition Asbestos NESHAP (40 CFR §61,
Subpart M) compliance inspection, site mobilization and demobilization, labor and equipment
for demolition, and transportation and disposal of demolition wastes.
Method-specific demolition costs for the NESHAP building included asbestos abatement,
including preparation of the specification and the abatement oversight and monitoring, plus
OSHA Compliance monitoring for lead (29 CFR §1926.62).
Method-specific demolition costs for the AACM building included the presence of a NESHAP
observer during the demolition, rental of the scaffolding required to line the trucks and the liners,
and OSHA Compliance monitoring for asbestos (29 CFR §1926.1101) and lead (29 CFR
§1926.62).
The costs for removal of the pipe wrapping beneath both buildings, which was done many years
earlier, was not included in this cost comparison. The comparison between the NESHAP and the
AACM dealt with the buildings as they were at the time, not how they had been in the past.
Inclusion of hypothetical costs for the removal of pipe wrap that had been accomplished many
years earlier is not appropriate because EPA does not know the quantity of pipe wrap that was
removed nor the cost for removing it. If the amount of pipe wrap did not exceed the NESHAP
limits (260 linear feet), then NESHAP would not have required it to be removed for the
NESHAP building but the AACM would have required its removal prior to the AACM
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demolition. In this case, there would have been an extra cost for the AACM. If the amount of
pipe wrap exceeded the NESHAP threshold, it would have been removed in both cases and the
costs for TSI removal from each building would have been the same; thus there would have been
little impact on the cost advantage of the AACM.
8.2 Cost Items
The following sections provide the details of the individual cost items that are summarized in
Table 8-1, which is located at the end of this section.
8.2.1 Pre-Demolition Asbestos Compliance Inspection
A pre-demolition asbestos NESHAP compliance inspection was required for both the NESHAP
and the AACM building, which typically costs $2,400 each. This cost is based on an estimate
from Environmental Enterprises Group (EEG), who performed this service on the buildings at
Fort Chaffee Redevelopment Authority. This cost includes collection of up to 40 bulk building
samples for asbestos analysis by PLM and a written inspection report.
8.2.2 NESHAP Abatement
The NESHAP method requires that RACM be removed from any regulated building that is to be
demolished. This cost did not apply to this AACM demolition at the Fort Chaffee
Redevelopment Authority.
8.2.2.1 Abatement Specification
An asbestos abatement specification was prepared for obtaining competitive bids for the asbestos
abatement and to provide instructions for the selected abatement contractor. The cost of this
item ($4,272) is based on the cost of the labor hours required to develop the specification, issue
the bid, conduct pre-bid conference, evaluate bids, and award the contract.
8.2.2.2 Asbestos Abatement
The abatement contractor was selected based on low bid, which ranged from $58,725 to $82,700
including ACM disposal. The general contractor overhead costs (ten percent) and fee (an
additional ten percent on the original plus overhead or 21 percent of the original) were added to
the asbestos abatement cost of $58,725 for a total loaded cost of $71,057. To compare actual
ACM disposal costs between the two buildings, the cost of ACM disposal, $5,893 (based on 78
actual tons of ACM, including barrels, at $75.55 per ton) was subtracted from the total loaded
abatement cost and included on the ACM cost line item in Table 8-1. Therefore, the amount of
the abatement minus the cost item for disposal is $65,164 ($71,057 -$5,893) and this is shown in
the Asbestos Abatement category in Table 8-1.
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8.2.2.3 Abatement Oversight and Monitoring
Abatement oversight and monitoring task was performed by EEG. The cost of $11,977 is the
amount invoiced from EEG to perform these activities.
8.2.3 OSHA Compliance Monitoring
The cost of OSHA compliance monitoring (lead) for the NESHAP demolition includes 12 hours
of monitoring and the collection and analysis of three lead samples. The cost of the OSHA
monitoring for the abatement portion of the NESHAP was previously included above. The cost
of OSHA compliance monitoring (lead and asbestos) for the AACM demolition includes 12
hours of monitoring and the collection and analysis of five lead samples and five asbestos
samples.
8.2.4 Site Mobilization and Demobilization
Site mobilization and demobilization includes the delivery and removal of equipment prior to
and at the end of the demolition. Mr. Larry Weatherford with Crawford Construction provided
an estimate of $4,000 (includes both mobilization and demobilization) for either the NESHAP or
AACM building.
8.2.5 Demolition
Demolition costs include the cost of the excavator and operator and labor for both the NESHAP
and AACM buildings and the cost of a NESHAP observer for the AACM demolition. The
excavator was billed at $95/hr and the excavator operator was billed at $55/hr (total $150/hr).
Labor hours required for both NESHAP and AACM demolitions are based on reported hours on
timesheets and an average labor cost of $45/hr. Labor hours during delays caused by weather
and the research sampling effort are not included.
The demolition of the NESHAP building required eight hours for eight workers (64 hours) for a
total of $2,880, not including operation of the excavator. The excavator operated for eight hours
during the demolition of the NESHAP building for a total coast of $1,200.
Labor for the AACM took place over a four-day period from April 30 to May 3, 2006 and totaled
223 hours. The AACM building required pre-wetting the interior and rafters of the building on
April 30 for about two hours and re-wetting the rafters on May 1 for about one hour prior to the
demolition (three workers each). The demolition and debris cleanup required about 11 hours for
16 workers on May 1 and another three hours for 12 workers on May 2. Due to soil sample
collection required by the research project, the final removal of surface soil did not take place
until the morning of May 3. Soil excavation required another two hours for one worker (does not
include trucking). At an average rate of $45/hr, the labor cost of the AACM demolition was
$10,035, not including operation of the excavator. The excavator operated for 16 hours during
the demolition of the AACM building for a total cost of $2,400.
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8.2.6 Water and Amended Water Surfactant
Water spray was used during the NESHAP demolition to control dust. Water containing a
surfactant with a foaming agent was used during the AACM demolition to control dust and
prevent the release of asbestos into the air. Water was supplied through a hydrant operated by
the city of Fort Smith. Hydrant charges over the test program were $168.24. The water usage
costs for each of the buildings was based on 10.8-percent use for the NESHAP building ($18)
and 89.2-percent use ($150) for the AACM building. The cost of the wetting agent, used only
for the AACM building, was based on actual surfactant use of 170 gallons at a cost of $11.85 per
gallon or $2,015.
8.2.7 Demolition Debris Transportation and Disposal (asbestos and non-
asbestos)
The costs of transportation and disposal include cost of the trucks and truck drivers and the
disposal of asbestos and non-ACM wastes at the Fort Smith landfill. Field notes, landfill
invoices, disposal manifests, and contractor invoices were reconciled to determine disposal
weights and costs.
8.2.7.1 Trucking Costs
Trucks used in this effort were either owned and operated by Crawford Construction or obtained
from independent local contractors. The billing rate for truck and driver was $65/hr and was used
for all the trucks.
For the NESHAP demolition, trucking use was 59 hours for a total cost of $3,835. For the
AACM, total truck use was 94.5 hours for a total cost of $6,143.
8.2.7.2 Lining the Trucks
Liners were used in the truck beds hauling asbestos waste for the AACM building only.
Scaffolding was necessary for installing two liners in each truck. The liners were sealed with
glue and tape after the asbestos waste was loaded in the trucks. The costs for the scaffolding and
liners are not applicable to the NESHAP demolition.
For the AACM demolition, the cost of the liners is based on the use of 142 liners plus glue and
tape. Crawford Construction purchased 200 liners (typically used to line rolloff boxes) at $44.08
plus the cost of glue and tape for a total cost of $9,688. A ratio of 142 divided by 200 was used
to obtain the cost of the liners ($6,878). An allowance of $200 was included for the rental of the
scaffolding.
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8.2.7.3 Cost of Disposal
The costs for disposal of asbestos and non-asbestos waste were based upon invoices from the
City of Fort Smith Landfill Department. The cost of disposal of general (non-asbestos) waste
was $26 per ton. The cost of disposal of ACM was $75.55 per ton. Tonnages were determined
at the landfill by originally determining the weight of the load for the first two shipments for
each truck, averaging those, and then counting the number of loads each truck delivered to the
landfill. The total weight was then the number of trips per truck times the average load for that
particular truck.
8.2.7.3.1 NESHAP Building
During abatement of the NESHAP building, 78 tons of ACM (including containers) was
disposed at a cost of $5,893. Debris from the demolition of the NESHAP building included
some soil that was commingled with the debris. Based on the demolition contractor records,
NESHAP demolition waste (all non-ACM) totaled 217 additional tons, for a disposal cost of
$5,642.
8.2.7.3.2 AA CM Building
Disposal of debris from the AACM building occurred over a three-day period due to the
requirement to collect soil samples after building demolition and a weather delay on the second
day. On the first day of the demolition process, a total of 142 tons of asbestos-containing
building demolition debris was disposed at the landfill. There was a rain delay on the morning of
the second day, and disposal operations began at about noon. On the second day, approximately
30 additional tons of asbestos-containing building debris/soil mixture was disposed. In addition,
easily-segregated concrete piers and the large gravel-filled concrete structure were disposed as
non-asbestos-containing building debris, totaling 103 tons. Soil excavation occurred on the third
day, following the post-demolition sampling. Approximately 75 tons of soil was disposed as
ACM. The total disposal tonnages and costs for the AACM building were 103 tons of non-ACM
at a cost of $2,678 and 247 tons of ACM at a cost of $18,660. Water should have been applied
during the soil removal phase but inadvertently was not; an additional $500 was estimated for
this cost.
Water that collected within the bermed containment area was filtered and pumped to a 2,400
gallon holding tank for storage prior to being trucked to the City of Fort Smith Wastewater
Treatment Plant. The cost for on-site filtering and containment of water collected during the
demolition was $2,031.85 for one month's rental of the holding tank and particle filters,
including the cost of the filter cartridges; and $146.68 for rental of the sump pump. The cost of
trucking water from the site to the wastewater treatment plant was included as part of the
demolition and not broken out separately. There was no cost for disposing of the 4,100 gallons of
water collected during the demolition of the AACM building at the wastewater treatment facility.
The total additional cost for collection, treatment, and disposal of the collected water was
$2,277.53 for the one-month rental of the sump pump, on-site filtering equipment and holding
tank. The project cost for this equipment was determined by pro-rating the total cost for the one
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month rental based upon the need for the equipment at the site for the two days of building
demolition and one day of soil excavation, and one day each for mobilization and
demobilization, or five days. As a result, the cost of wastewater treatment and collection entered
in the table was $570, obtained by prorating the monthly cost, assuming 20 working days per
month.
8.3 Summary
Table 8-1 presents the comparative costs of the demolition of Buildings 3602 and 3607 by the
NESHAP Method and AACM, respectively.
Table 8-1. Cost comparison of NESHAP and AACM Building Demolitions at Fort Chaffee, AR.
Cost Item
Costs, $
NESHAP Building
#3602
AACM Building
#3607
Pre-Demolition
Pre-demolition Asbestos NESHAP inspection
Asbestos abatement specifications
(Preparation and bidding)
Asbestos abatement
Asbestos abatement oversight and monitoring
OSHA compliance monitoring
(asbestos and lead)
Site mobilization and demobilization by
General Contractor
2,400
4,272
65,164
11,977
1,050
4,000
2,400
NA
NA
NA
1,235
4,000
Building Demolition
Excavator
Labor
Hydrant flush water and surfactant
1,200
2,880
18
2,400
10,035
2,165
Construction Debris T&D (asbestos and non-asbestos)
Transportation
Scaffold for lining of trucks and liners
Asbestos waste disposal
Non-asbestos waste disposal
Water collection and disposal
3,835
NA
5,893
5,642
0
6,143
7,078
18,660
2,678
570
Miscellaneous Costs
Watering during soil removal
0
500
Totals
Total cost
Unit cost, $/ft2 (based on 4,500 ft2)
108,331
24.07
57,864
12.86
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The cost of the NESHAP demolition was approximately $108,331 and the cost of the AACM
demolition was approximately $57,864 or about 53 percent of the cost of the NESHAP
demolition. The cost per square foot was $24.07/ft2 for the NESHAP and $12.86/ft2 for the
AACM.
8.4 Applicability of Costs for Different Sites
The costs for these demolitions at the Fort Chaffee Redevelopment Authority are very site
specific and may vary at other sites according to building type, size, asbestos type and extent,
etc. The AACM building at Fort Chaffee did not contain ACM that would require abatement
prior to demolition. Different buildings at different locations may have greater or lesser cost
differences between the NESHAP process and the AACM process, As the proportion of the
building's contents that require removal under the AACM increase (e.g., sprayed-on TSI,
vermiculite attic insulation, large quantities of pipe wrap, etc), the cost advantage of the AACM
relative to the cost of the NESHAP will decrease. Conversely, some local regulations exceed the
requirements of the NESHAP and mandate the removal of vinyl asbestos floor tile; this was not
the case at Fort Chaffee. If the VAT had been removed as required by several local statutes, the
cost and time requirements of the abatement would have significantly increased and the cost and
time advantages of the AACM observed in this study would have been far greater. The ultimate
choice of the NESHAP vs. the AACM will be made based upon cost and time considerations.
There will always be some structures where the NESHAP will be more practical to apply than
the AACM.
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SECTION 9 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)
RESULTS
Due to the potential use of the results of this research study in assisting in the evaluation of an
alternative method to current regulations, the project was designated a NRMRL QA Category 2.
Based on this designation, QA/QC activities for the study included the development of a detailed
quality assurance project plan (QAPP), field and laboratory audits, analysis of multiple QA/QC
samples, and data validation.
9.1 QAPP Development
The QAPP was prepared to conform to EPA QA/R-5, Requirements for QAPPs, EPA/2 40/B-01/00 3,
March 2001. Input was provided by an EPA Technical Development Team, which included
asbestos experts from across the Agency. Following internal reviews, the QAPP was submitted for
public and peer review comments. The peer review panel provided composited comments which
included those received from the public; these composited comments were then addressed prior to
finalizing the QAPP.
9.2 Audits
A field audit and two laboratory audits (Clayton Group Services, who analyzed the air samples, and
Lab/Cor, who analyzed the soil samples) were conducted.
9.2.1 Field Audit
This audit was conducted on April 24, 2006, the planned first day of the demolition of the building
using the NESHAP method. However, weather delayed the demolition and the audit was limited to
an assessment of the planned activities (i.e., a readiness review). The audit was conducted by Dr.
Ching Chen, PE, CIH of Science Applications International Corporation (SAIC), through a
subcontract agreement with Neptune and Co., Inc., under a Quality Support Contract with the EPA.
Audit activities were overseen by Lauren Drees, the EPA NRMRL QA Manager.
The EQ personnel interviewed included Mr. John Kominsky, Project Manager, and Julie Wagner,
Field Data Manager. The audit evaluated sampling activities at the demolition site at Ft. Chaffee,
Arkansas and the City of Ft. Smith, Arkansas Class D landfill site. The audit included reviews of the
following:
* Detailed review of flow meter calibration procedure and record
* Review of the records of completed background asbestos air and soil sampling
• Inspection of sampling pole and sampling equipment set up at both the demolition and
landfill sites
• Inspection of the weather monitoring stations at both the demolition and landfill sites
• Review of sampling data forms
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Table 9-1 provides a summary of the Observations that were identified during the audit. These
Observations did not have a significant effect on data quality, but, when corrected, data collection
efficiency was improved and ambiguity was minimized.
9.2.2 Laboratory Audit for Air Samples
An audit of Clayton Group Services in Kennesaw, GA was conducted on May 11, 2006 by Owen
Crankshaw of RTI International through a subcontract agreement with EQ. Audit activities were
overseen by Lauren Drees, the EPA NRMRL QA Manager.
The Clayton laboratory would be conducting analysis of air samples collected for asbestos and fibers
by TEM and PCM, respectively. The audit focused on the following key areas:
• personnel qualifications
• laboratory equipment
understanding of the project
sample preparation procedures
sample analysis procedures
quality assurance and calibration of all data
• project-specific data handling and reporting
• sample handling and disposition
All aspects of sample preparation and analysis were discussed with laboratory personnel, and the lab
was in compliance with project QAPP requirements. In some instances, specific QA procedures
documented in the project QAPP were clarified to make the data more meaningful.
The following items represent clarifications/recommendations that resulted from the audit:
* The audit team spent adequate time with lab director Alan Segrave to ensure that all
analytical requirements of the QAPP would be met by the laboratory staff. The lab was told
to contact the contractor and the EPA Q A staff should issues arise that need method
modification.
• Indirect prep is to be avoided, as all samples should share the same prep procedures. If a
sample is overloaded with particulate material (or marginally overloaded), John Kominsky is
to be contacted for direction.
* Lab will utilize a comprehensive laboratory information management system (LIMS) for log
in, recording of sample prep, analytical data, QA, and reporting.
* Audit team ensured that QC assignments will target appropriate sample batches and agreed
on the assignment scheme with Alan Segrave.
• For QC samples (replicates, duplicates, intralaboratory and interlaboratory verified samples,
and interlaboratory duplicates), lab will assign QC to achieve good batch representation, and
will make sure at least one QC sample is assigned to each batch.
144
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Table 9-1. Summary of Audit Observations, Recommendations, and Resolution.
No.
Observation
Recommendation
Resolution
LackofQAPP
Training Record
Document the QAPP training for
all field personnel
Training of all field personnel was
documented by signature on a QAPP
acknowledgement form.
Insufficient
documentation of flow
meter calibration
Record the following information
on calibration datasheets:
Model and serial number of the
primary standard flow meter used
Name of person who performed the
calibration
Time and date of calibration
Location of calibration
Type of filter cassette used for
calibration
The individual flow meter calibration
sheets were updated to include the model
and serial number of the primary standard
used; name of person who performed the
calibration; time and date of calibration;
location of calibration, and type of filter
cassette used for calibration.
Insufficient clarity in
sampling data forms
Insert additional data columns on
sampling forms to clearly record
the flow meter readings and
corresponding flow rates at pump
start and stop time; label the
columns accordingly
Clearly identify the flow meter data
recorded on the form during the 2-
hr checks of pump operation, where
applicable, as flow meter readings
Re-check all datasheets for the
background air sampling completed
to ensure that correct flow rates are
used in calculating sample volume
The air sampling data forms were revised
to include columns to document the start
and stop times and corresponding flow rate.
The flow meter performance check form
was updated to include the time and flow
rate for each 2-hour check. The sampling
datasheets for the background sampling
were reviewed and verified that the correct
flow rates were used in the air sample
volumes.
Malfunctioning wind
direction sensor at the
landfill site weather
station
Replacement sensor (temperature
and wind direction) is on order and
is expected to arrive within a few
days.
Meteorological data was obtained from a
NWS Station and from Fort Smith City
airport, which were approximately 0.5 and
0.2 miles from the landfill monitoring area.
Lack of formal
documentation of
QAPP changes
Document all changes to the QAPP
as an addendum. Changes
identified so far have included:
Integrated, instead of daily, samples
during abatement monitoring
Soil sampling grid changes
Potential deletion of duplicate
samples for the low-volume
standby asbestos air samples
Representative photo
documentation of sampling poles,
instead of photos for all sampling
poles
No immediate pre-abatement
sampling; background sampling
was conducted in January 2006
Updated sampling data forms
A written addendum to the QAPP
documented the note changes to the QAPP.
It also includes the following post-audit
changes:
Integrated air and settled dust samples for
the AACM building on Day 2 and Day 3
due to the brief activities (soil removal)
which occurred on these days.
Increasing the air sampling flow rate to 7
liter/min for the Day 2 and 3 AACM
building perimeter samples for the
aforementioned reason.
Based on the EPA audit of the soil
laboratory, developed a standard operating
procedure (SOP) for drying and mixing the
soil; the SOP is an addendum to the QAPP.
145
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* Verified analysis will be conducted on samples containing asbestos, if available. Preference
will be given to appropriately loaded samples (5-10 structures per grid opening). Ten grid
openings will be analyzed for each verified count, all on the same grid. When possible,
intralaboratory and interlaboratory verified counts will be performed on the same grid
openings.
* For any samples with high asbestos concentrations, lab can apply ISO 10312 stopping rules.
* Calculations are done by LIMS; lab will hand calculate 2% of all analytical results (for all
analyses).
• Lab needs input from EPA and EQ regarding number of grid openings to analyze when
volumes on samples are lower than were projected for those samples. These samples need
higher numbers of grid openings to be counted to meet analytical sensitivity specifications.
• All records will be backed up daily to the central server and copied to CD.
* Sample filters, slides, and grids will be stored until the end of the project in the lab director's
office.
• Lab will send individual batch reports and a comprehensive Excel spreadsheet with a
summary of all results.
« The two liter/min samples collected at the five-ft height in Ring 1 for the AACM Method
were not marked as requiring archival. This was documented by Lauren Drees on the COC
form at the time of the audit.
• Lab will use an independent chain of custody for QC samples going to and from the QC lab.
All QC samples will be returned to Clayton.
It was concluded that the laboratory operates under a comprehensive and appropriate QA system,
has qualified personnel, has a comprehensive LIMS system, and has all necessary and appropriate
equipment.
9.2.3 Laboratory Audit for Soil Samples
An audit of Lab/Cor in Seattle, WA (soil prep, TEM ,and elutriator analyses) and Lab/Cor in
Portland, OR (PLM) was conducted on May 1 and 2, 2006 by Owen Crankshaw of RTI International
through a subcontract agreement with EQ. Audit activities were overseen by Lauren Drees, the EPA
NRMRL QA Manager.
The Lab/Cor laboratory would be conducting analysis of soil samples collected for asbestos as noted
above. The audit focused on the following key areas:
* personnel qualifications
* laboratory equipment (including unique equipment for elutriation of soil)
* understanding of the project
• sample preparation procedures
• sample analysis procedures
• quality assurance and calibration of all data
• project-specific data handling and reporting
146
-------
* sample handling and disposition
* development of a project-specific standard operating procedure (SOP) for sample preparation
and analysis
The laboratories had recently been audited by NVLAP (and successfully completed the audits with
no deficiencies), which helped allow the auditors to spend adequate time on critical aspects of the
soil preparation and analysis procedures. All aspects of sample preparation and analysis were
worked out and agreed upon with laboratory personnel. In some instances, specific QA procedures
documented in the project QAPP were clarified to make the data more meaningful.
The following items represent clarifications/recommendations that resulted from the audit:
• The soil SOP for this project was developed by the lab representatives and the audit team
before, during, and after the audit. This SOP will replace Section B4.4 of the QAPP. Lab
needs to ensure that all analysts have an approved copy of the SOP prior to conducting any
analysis. Considerable effort and time was spent by the audit team to refine the SOP such
that the analysis conducted will be properly conducted and has appropriate QC measures.
The audit team is satisfied at this point that the SOP addresses all issues that can reasonably
be anticipated. Lab will be expected to contact the contractor and the EPA Q A staff should
issues arise that need method modification.
• Portland staff does analysis only; all soil sample preparation will be conducted in Seattle to a
stage suitable for point counting by PLM.
• John Harris will be principal tracking person for the overall contract and for the Seattle lab;
Amber Basting will be the sample tracking person for the Portland lab.
• Due to the large sample quantities received, it is necessary that Lab/Cor utilize the larger
hoods at the Region 10 Port Orchard facility. All drying of soils (initial drying) will be done
in the Port Orchard, WA USEPA laboratory, following standard chain of custody for sample
delivery both directions.
» All wet soils received were being maintained at 0-8 °C, which was a difficult task. The soil
SOP was modified to clarify that only samples that will undergo elutriation will be
maintained at that temperature per the elutriation method.
* The Seattle lab is currently not set up to perform PLM analyses. However, visual estimation
by PLM of the original soil, as well as the dried/split soil, is needed. Provisions will be made
so that the Seattle lab can perform these analyses.
• Balances and ovens are in Seattle where all sample preparation will be conducted. Lab
agrees to calibrate balances daily using traceable weights. Balances are also calibrated by an
independent agency.
* Kate March will be responsible for selection of QC samples in Seattle (concentrating on
AACM post-excavation and NESHAP post demolition samples), and Darvey Santner will be
in charge of sample assignment in Portland. QC checks will meet percentage criteria, and
will be split among personnel to maximize the utility of the data.
• Lab will prepare 0.1% AND 1% spikes (using chrysotile) for each of the five sets often soil
samples. The QAPP only required the 0.1% spike, but since the 1% spike will be prepared
for the elutriation analyses, it was agreed that it would also be analyzed by PLM/TEM. The
same spikes above will be analyzed by the elutriation method. These spikes will not be
147
-------
prepared using the background soils sieved to PM10 as this was determined to be
impractical. The background soil will be dried, split, and ground and then spiked.
* Two types of elutriator duplicates will be utilized: a re-preparation of a filter by a different
analyst (preferably a sample that had measurable asbestos), and a re-elutriation of a 60g soil
split. Two of each of these duplicates are required.
* A soil duplicate for TEM will start with the two-gram aliquot from which 100 mg were
suspended, and will suspend a new 100-mg sub-aliquot.
* Samples will arrive in batches often, and will be processed as much as possible in batches.
* Lab will choose samples 2, 5, and 8 from each batch often soil samples for elutriator
preparation.
• Lab will use electronic data entry by PC at the microscope.
* Lab will prepare 20 slide mounts for each PLM point-count.
« All PLM point count calculations will be rechecked. Because TEM and elutriation
calculations are done by spreadsheet, each TYPE of calculation will be rechecked by hand on
a regular basis.
« Lab will use ISO 10312 counting rules for elutriator samples. Stopping rules will be 100
asbestos structures or when an analytical sensitivity of 1 x 106 structures/gram is reached.
• During PLM analysis, analysts will identify chrysotile and amphibole, and quantify
independently and in combination. Identification of any non-asbestos fibrous material will
be attempted, but is not required. Non-asbestos fibrous material will not be point counted.
The lab will, however, provide a visual estimate of non-asbestos fiber (<1% if trace, and
visual estimation if >1%; no further quantification below 1% will be provided).
• PLM slides will not be archived or mounted in permount.
* Portland lab will receive from Seattle, along with samples data regarding sample reduction so
that final calculations related to original sample (post drying but prior to sample reduction)
can be performed.
* Portland lab will report anything unusual found in the samples during PLM analysis.
» Portland lab may count less than 1000 point counts if sample reduction level justifies it, as
long as 0.1% analytical sensitivity is achieved.
• All soil samples analyzed by Portland will be returned to Seattle by John Harris (utilizing
chain of custody) and stored with other project archival material.
• Portland lab will create one master spreadsheet for all PLM data to accompany individual
analytical reports.
* Portland lab will use sample numbers initiated in Seattle.
* Warehouse space will be used for original soil samples and splits; all other materials will be
stored in the Seattle lab (including point-counted soil samples).
* All soil samples for PLM analysis will be delivered in person (both directions) by John
Harris. A new chain of custody will be used for sample transportation to and from Portland.
Chain of custody will also be maintained when transferring samples to and from the Region
10 Port Orchard facility.
It was concluded that the laboratory operates under a comprehensive and appropriate QA system,
has qualified personnel, and has all necessary and appropriate equipment.
148
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9.3 Asbestos QA/QC Sample Results
QA/QC samples were analyzed for each sample type, i.e., air (including worker), soil, settled dust,
and water, as described in the QAPP. These QA/QC samples included lot blanks; field blanks; field
duplicates; laboratory method blanks, replicates, duplicates, verified counts, and spiked samples; and
interlaboratory duplicates and verified counts. The results of the analyses are provided in the
following sections, as applicable for the different sample types.
For each matrix, in cases where two analyses have the same analytical sensitivity, variability was
calculated using the following equation:
SI — S2
Variability = — . (Equation 1 }
where SI and S2 are the two total structure counts observed.
For each matrix, in cases where the two analyses have different analytical sensitivities, variability
was calculated using the following equation:
Variability . (Equation 2}
7 / ^»i rr/^ ^ A 7
Where:
^(MŁ>Ł2-MŁ>Z1)
a~ (MDL2 + MDU)
and
_ o / (MDR-MDI2)
(MDU+MDL2)
MDL is the method detection limit (i.e., analytical sensitivity). Note that all variabilities were
calculated using (Equation 1} unless otherwise noted.
9.3.1 Air QA/QC Results
The QAPP specified the required numbers of QA/QC samples. The minimum required number of
each type of QA/QC sample was met in all cases. In many cases, the number of QA/QC samples
analyzed exceeded the required number. Table 9-2 summarizes the total air samples collected and
the QA/QC samples analyzed. The number of QA/QC samples analyzed exceeded the required
number in all cases, except for the interlaboratory verified count. As no problems were encountered
for the one interlaboratory verified count sample analyzed (Table 9-7, below), data quality is not
affected.
149
-------
Table 9-2. Total Air QA/QC Samples
Total 259
Samples
Required by
QAPP
Samples
Actually
Analyzed
+j
u
~Q.
S
Q
•a
3
E
23
None
Specified
8.9%
W5
"O ^
4) S3
2 •—
PQ
52
None
Specified
20.1%
=
—
PQ
o
_]
H
H
12
2%
4.6%
%
+*
w
"a,
rt
3
W
H
14
3%
5.4%
•^
w
a
s
Q
g
W
H
18
3%
6.9%
•a
?S K
L. *^
S s-
^ s
^\ o
S ^
H
3
1%
1.2%
^
^ *^
« «
TI t>
S3 .—
CH "^
Q
H
16
5%
6.2%
_o •*-
«2 fi
1 §
~^^ ^J
T^
^
g c
H ^
^
1
1%
0.4%
9.3.1.1 Lot Blanks
All lot blanks had non-detected asbestos concentrations at less than 0.0005 s/cm
9.3.1.2 Field Blanks
A field blank is a filter cassette that has been transported to the field, opened for a short time (<30
seconds), and then sent to the laboratory. All field blanks had non-detected asbestos concentrations
at <7 s/mm2.
9.3.1.3 Field Duplicates
A field duplicate is a second sample collected concurrently at the same location as the original
sample (co-located). Results for field duplicates are presented in Table 9-3. All field duplicates met
the acceptance criteria for variability.
9.3.1.4 Method Blanks
All method blanks had non-detected asbestos concentrations less than 7 s/mm
150
-------
Table 9-3. Field Duplicates for Air Samples
Sample ID
AIR-AACM-ASB-4L-BG-R1 -Ml 3
AIR-AACM-ASB-4L-D1-R1-H1-M17
AIR-AACM-ASB-4L-D 1 -Rl -HI -M5
AIR-AACM-ASB-4L-D1-R1-H2-M12
AIR-AACM-ASB-4L-D 1 -Rl -H2-M2
AIR-AACM-ASB-4L-D1-R2-H1-M1
AIR-AACM-ASB-4L-D1-R2-H1-M15
AIR-AACM-ASB-7L-D2-R1-H1-M12
AIR-AACM-ASB-7L-D2-R1-H1-M17
AIR-AACM-ASB-7L-D2-R1 -HI -M2
AIR-AACM-ASB-7L-D2-R1 -HI -M5
AIR-AACM-ASB-7L-D2-R2-H1-M1
AIR-AACM-ASB-7L-D2-R2-H1-M15
AIR-LANDFILL-ASB-4L-BG-M8
AIR-LF- AACM- ASB-4L-D 1 -H 1 -M8
AIR-LF-AACM-ASB-4L-D2-H1-M8
AIR-LF-NESH-ASB-4L-D 1 -HI -M8
AIR-NESHAP-ASB-4L-BG-R1 -M5
AIR-NESH-ASB-4L-D1-R1-H1-M17
AIR-NESH-ASB-4L-D 1 -Rl -HI -M5
AIR-NESH-ASB-4L-D1-R1-H2-M12
AIR-NESH-ASB-4L-D 1 -Rl -H2-M2
AIR-NESH-ASB-4L-D1-R2-H1-M1
AIR-NESH-ASB-4L-D1-R2-H1-M15
Method
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
Sample
Result
0
0
0
0
0
0
1
0
0
1
1
0
0
0
0
0
0
0
0
0
0
0
3
0
Duplicate
Result
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
Actual
Variability
0
0
0
0
0
0
1
0
0
1
1
0
1
0
0
0
0
0
0
0
0
0
1.7
0
Acceptable
Variability
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
9.3.1.5 Replicates
A replicate analysis is a second analysis of the same preparation, but not necessarily the same grid
openings, by the same microscopist as the original analyses. Results for replicates are presented in
Table 9-4. All replicates met the acceptance criteria for variability.
151
-------
Table 9-4. Replicates for Air Samples.
Sample ID
AIR-AACM-ASB-4L-D1-R1-H1-M16
AIR-AACM-ASB-4L-D 1 -Rl -H2-M5
AIR-AACM-ASB-4L-D1-R2-H1-M12
AIR-AACM-ASB-7L-D2-R1 -HI -M5
AIR-AACM-ASB-7L-D2-R1-H2-M15
AIR-AACM-ASB-7L-D2-R2-H1-M4
AIR-LF- AACM- ASB-4L-D 1 -H 1 -M4
AIR-LF-NESH-ASB-4L-D 1 -HI -M6
AIR-NESHAP-ASB-4L-BG-R1 -M8
AIR-NESH-ASB-4L-D 1 -Rl -HI -M2
AIR-NESH-ASB-4L-D 1 -Rl -H2-M2
AIR-NESH-ASB-4L-D 1 -R2-H1 -M5
WORKER- AACM-ASB-D 1 -EO 1
WORKER-NESHAP-ASB-D 1 -H02
Method
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
Sample
Result
1
0
0
1
0
0
0
0
0
0
0
0
0
1
QA/QC
Result
1
0
0
1
0
0
0
0
0
0
0
0
0
1
Actual
Variability
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Acceptable
Variability
.96
.96
.96
.96
.96
.96
.96
.96
.96
.96
.96
.96
.96
.96
9.3.1.6 Duplicates
A duplicate is an analysis of a second TEM grid preparation prepared from a different area of the
sample filter performed by the same microscopist as the original analyses. Results for duplicates are
presented in Table 9-5. All duplicates met the acceptance criteria for variability.
Table 9-5. Duplicates for Air Samples
Sample ID
AIR-AACM-ASB-4L-D 1 -Rl -HI -M3
AIR-AACM-ASB-4L-D 1 -Rl -H2-M6
AIR-AACM-ASB-4L-D1-R2-H1-M13
AIR-AACM-ASB-7L-D2-R1 -HI -M4
AIR-AACM-ASB-7L-D2-R2-H1-M8
AIR-LANDFILL-ASB-4L-BG-M1
AIR-LF- AACM- ASB-4L-D 1 -H 1 -M-3
AIR-LF-NESH-ASB-4L-D 1 -HI -M5
AIR-NESHAP-ASB-4L-BG-R1 -M8
AIR-NESH-ASB-4L-D1-R1-H1-M15
AIR-NESH-ASB-4L-D 1 -Rl -H2-M3
AIR-NESH-ASB-4L-D1-R2-H1-M1
AIR-NESH-ASB-4L-D1-R2-H1-M12
AIR-NESH-ASB-4L-D1-R2-H1-M16
WORKER- AACM-ASB-D 1 -LA2
WORKER-NESHAP-ABATE-ASB-4
WORKER-NESHAP-ABATE-B3602-
ASB-1
WORKER-NESHAP-ASB-D 1 -DUP 1
Method
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
ISO
Sample
Result
2
0
0
1
0
0
0
0
0
0
0
o
6
0
0
0
5
12
1
QA/QC
Result
1
0
0
0
0
0
0
0
0
0
1
0
0
0
0
10
21
0
Actual
Variability
0.58
0
0
1
0
0
0
0
0
0
1
1.73
0
0
0
1.29
1.57
1
Acceptable
Variability
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
152
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9.3.1.7 Verified Counts
Verified counting involves the re-examination of the same grid openings by a different microscopist.
Results for verified counts are presented in Table 9-6. All verified counts met the acceptance
criteria.
Table 9-6. Verified Counts for Air Samples
Sample ID
AIR-AACM-ASB-7L-D2-R1-
H1-M4
AIR-NESH-ASB-4L-D 1 -R2-
H1-M1
WORKER-NESHAP-
ABATE-ASB-4
Method
ISO
ISO
ISO
Sample
Result
1
o
J
5
QA/QC
Result
1
3
5
Actual
Variability
100% True
Positives
100% True
Positives
100% True
Positives
Acceptable
Variability
>80% True
Positives
<20% False
Negatives
<20%False
Positives
9.3.1.8 Intel-laboratory QA/QC
After analysis by Clayton, selected filters and grid preparations were sent to RTI for analysis as an
independent QA/QC check. Interlaboratory QA/QC sample analyses for the air samples included
duplicates and verified counts by TEM. These results are summarized in Table 9-7 and
153
-------
Table 9-8. All interlaboratory duplicates and the interlaboratory verified count analysis met the
acceptance criteria.
Table 9-7. Interlaboratory Verified Counts
Sample ID
AIR-NESH-ASB-4L-D1-R2-H1-M1
Method
TEM
Sample
Result
2
QA/QC
Result
2
Actual
Variability
100% True
Positives
Acceptable
Variability
>80% True
Positives
<20% False
Negatives
<20%False
Positives
154
-------
Table 9-8. Interlaboratory Duplicates for Air Samples
Sample ID
AIR-AACM-ASB-4L-D1-R1-H2-M1 1
AIR-LF-AACM-ASB-4L-D 1 -Rl -HI -M3
AIR-LF-NESH-ASB-4L-D 1 -HI -M5
AIR-NESH-ASB-4L-D 1 -Rl -H2-M3
AIR-AACM-ASB-7L-D2-R1 -HI -M3
AIR-AACM-ASB-7L-D2-R1 -H2-M2 (Dup)
AIR-NESH-ASB-4L-BG-R1 -M8
AIR-NESH-ASB-4L-D1-R1-H1-M15
AIR-AACM-ASB-4L-D1-R2-H1-M13
AIR-AACM-ASB-7L-D2-R2-H1-M3
WORKER-NESH-ASB-D 1 -Dup 1
WORKER- AACM-LF-ASB-D2-FB 1
WORKER-NESH-ABATE-B3602-ASB-1
AIR-AACM-ASB-4L-D 1 -Rl -H2-M6
AIR-LF-ASB-4L-BG-M1
WORKER- AACM-ASB-D 1 -LA2
Method
TEM
TEM
TEM
TEM
TEM
TEM
TEM
TEM
TEM
TEM
TEM
TEM
TEM
TEM
TEM
TEM
Sample
Result
0
0
0
1
1
0
0
1
0
0
1
0
12
1
1
0
QA/QC
Result
0
0
0
0
2
0
1
1
0
0
0
0
7
0
1
0
Actual
Variability
0
0
0
1
0.57
0
1
0
0
0
1
0
1.1
1
0
0
Acceptable
Variability
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
2.24
9.3.2 Soil QA/QC Results
The QAPP specified the required numbers of QA/QC samples for the soil samples. Table 9-9
summarizes the total soil samples collected and the QA/QC samples analyzed.
Table 9-9. Number of Soil QA/QC Samples
Total
Samples
Required
By
QAPP
Actually
Analyzed
No.
Samples
50
PLM
Replicate
3
5%
6%
PLM
Duplicate
2
5%
4%a
PLM
Laboratory
Control
Sample
2
I/batch
I/batch
TEM
Replicate
2
5%
4%a
TEM
Duplicate
2
5%
4%a
TEM
Laboratory
Control
Sample
2
1 /batch
1 /batch
TEM
Inter-
laboratory
Duplicates
2
5%
4%a
During the laboratory audit, it was agreed that QC would be performed on one post-demolition NESHAP sample and
one post-excavation AACM sample.
9.3.2.1 Method Blanks
All method blanks had non-detected asbestos concentrations at less than <7 s/mm
155
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9.3.2.2 Replicates
A replicate is an analysis from the same sample prep performed by the same analyst. Results for
replicates are presented in Table 9-10. All replicates met the acceptance criteria for variability.
Table 9-10. Replicates for Soil Samples.
Sample ID
SOIL-AACM-POST-
DEMO-COMP-2
SOIL-NESHAP-
POST-DEMO-2
SOIL-NESHAP-PRE-
COMP-9
SOIL-AACM-PRE-
COMP-10
SOIL-AACM-POST-
DEMO-COMP-2
Method
TEM
TEM
PLM
PLM
PLM
Sample
Result
6
71
0
0.33
0.33
QA/QC
Result
12
90
0.10
0.20
0.10
Actual
Variability
1.41
1.50
0.32
0.18
0.35
Acceptable
Variability
2.24
2.24
2.24
2.24
2.24
9.3.2.3 Duplicates
A duplicate is an analysis from different sample preps performed by the same analyst. Results for
duplicates are presented in Table 9-11. One of the duplicate TEM analyses did not meet the
acceptance criteria for variability and the other, while acceptable, was variable. Since replicate
analyses were acceptable (Table 9-10), this appears to be due to the combined sample preparation
and analysis process. The preparation involves suspending a portion of the soil in water and filtering
this suspension through a filter, which is then subjected to TEM analysis. Only a small portion of
the soil can be suspended so that the filter is not overloaded. It may have been difficult to obtain
filter samples that were consistently loaded. In addition, only a very small area of the filter was
examined. The variability of soil TEM results must be considered in any project conclusions.
Table 9-11. Duplicates for Soil Samples.
Sample ID
SOIL-NESHAP-
POST-COMP-2
SOIL-AACM-POST-
EVAC-4
SOIL-NESHAP-
POST-COMP-2
SOIL-AACM-POST-
EXCAV-COMP-4
Method
TEM
TEM
PLM
PLM
Sample
Result
71
11
0
0
QA/QC
Result
40
24
0
0
Actual
Variability
2.94
2.20
0
0
Acceptable
Variability
2.50
2.50
2.50
2.50
156
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9.3.2.4 Spiked Samples
Background soil from Ft. Chaffee was spiked with chrysotile fibers at concentrations of 0.1% and
1%. These spiked soils were analyzed by PLM and TEM to provide a measure of recovery for the
methods. Results for spiked samples are presented in Table 9-12. While no acceptance criteria were
specified, the results indicate that recoveries were generally good, meaning that these concentrations
could be accurately measured, if present.
Table 9-12. Spikes for Soil Samples.
Sample ID
0.1% Chrysotile spike
1.0% Chrysotile spike
0.1% Chrysotile spike
1.0% Chrysotile spike
Method
TEM
TEM
PLM
PLM
Actual
Value
0.1%
1.0%
0.1%
1.0%
QA/QC
Result
0.11%
0.51%
0.09%
0.86%
%
Recovery
110%
51%
90%
86%
Acceptable
Recovery
None
specified
None
specified
None
specified
None
specified
9.3.2.5 Intel-laboratory QA/QC
After analysis by Lab/Cor, selected soil samples were sent to RTI for analysis as an independent
QA/QC check. Interlaboratory QA/QC sample analyses for the soil samples included duplicates by
both PLM and TEM. These results are summarized in Table 9-13. One of the interlaboratory PLM
duplicates exceeded the acceptance criteria for variability, which again may be attributed to the
difficulty of obtaining consistent soil suspensions.
Table 9-13. Interlaboratory Duplicates for Soil Samples.
Sample ID
SOIL-NESHAP-POST-COMP-2
SOIL-AACM-POST-EXCAV-COMP-5
SOIL-NESHAP-POST-COMP-2
SOIL-AACM-POST-EXCAV-COMP-5
Method
TEM
TEM
PLM
PLM
Sample
Result
71
11
0
0
QA/QC
Result
22
o
3
i
8
Actual
Variability
0.89a
2.4 a
1
2.8
Acceptable
Variability
2.50
2.50
2.50
2.50
QA/QC result analytical sensitivity was different than the sample result analytical sensitivity Equation 2 was used.
157
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9.3.3 Elutriation QA/QC
9.3.3.1 Replicates
A replicate is an analysis from the same sample prep performed by the same analyst. Results for
replicates are presented in Table 9-14.
Table 9-14. Replicates for Elutriation Samples.
Sample ID
SOIL-AACM-PRE-OMP-28
Method
TEM
Sample
Result
13
QA/QC
Result
13
Actual
Variability
0
Acceptable
Variability
2.24
9.3.3.2 Duplicates
Elutriation duplicates included both analysis of different preps of the same filter (filter duplicate) and
reprocessing of soil samples through the elutriation procedure (elutriation duplicate). These
duplicates are summarized in Table 9-15. All elutriation duplicates met the acceptance criteria for
variability.
Table 9-15. Duplicates for Elutriation Sam
pies.
Sample ID
SOIL-NESHAP-POST-
COMP-8 (filter dup)
SOIL-AACM-POST-EXCAV-
COMP-5 (filter dup)
SOIL-NESHAP-POST-
COMP-8 (elutriation dup)
SOIL-AACM-POST-EXCAV-
COMP-5 (elutriation dup)
Method
TEM
TEM
TEM
TEM
Sample
Result
2
1
2
1
QA/QC
Result
1
0
2
2
Actual
Variability
0.58
1
0
0.58
Acceptable
Variability
2.50
2.50
2.50
2.50
158
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9.3.3.3 Elutriation Spikes
No standards are available for the elutriation method. In order to provide some information about
the recovery of asbestos from PMio particulates, spiked standards were prepared using background
soil from Ft. Chaffee subjected to the elutriation method. Refer to Section 9.3.2.4. The results of
these spikes are presented in Table 9-16. While no true elutriation values for the spikes are known,
it is noted that the results for the one -percent spike are only approximately twice the results for the
0.1-percent spike; however, these results do provide evidence that significant fibers can be released
from the Ft. Chaffee matrix, if present in the quantities used for spiking.
Table 9-16. Spikes for Elutriation Samples.
Sample ID
0.1% Chrysotile spike
1.0% Chrysotile spike
Method
TEM
TEM
Actual
Value
0.1%
1.0%
QA/QC
Result,
s/gPM10
8.95E+09
1.84E+10
Acceptable
Recovery
None
specified
None
specified
9.3.4 Settled Dust QA/QC
9.3.4.1 Field Blanks
A field blank is prepared by placing a sample container in the field, removing the lid, and
immediately replacing the lid. All field blanks had non-detected asbestos concentrations at less than
200 s/cm2.
9.3.4.2 Field Duplicates
A field duplicate is a second sample collected concurrently at the same location as the original
sample. Results for field duplicates are presented in Table 9-17. One settled dust field duplicate
exceeded the acceptance criteria for variability. The laboratory noted that several of the dust
containers had evidence of dried paniculate on the inner sides (possibly from splashing into the
container). The highly variable sample below contained a significant amount of this dried
particulate. This indicates that some of the asbestos measured in the settled dust samples may have
come from splashing during demolition activities.
159
-------
Table 9-17. Field Duplicates for Settled Dust Samples.
Sample ID
SDUST-NESH-ASB-
R1-H1-M4
SDUST-NESH-ASB-
R1-H1-M16
SDUST-NESH-ASB-
R2-H1-M2
SDUST-NESH-ASB-
R2-H1-M15
SDUST-AACM-
ASB-R1-H1-M4
SDUST-AACM-
ASB-R1-H1-M16
SDUST-AACM-
ASB-R2-H1-M2
SDUST-AACM-
ASB-R2-H1-M15
Method
TEM
TEM
TEM
TEM
TEM
TEM
TEM
TEM
Sample
Result
0
16
1
1
9
4
6
5
Duplicate
Result
5
8
2
1
18
248
4
1
Actual
Variability
2.2
1.6
0.58
0
1.7
15
0.63
1.6
Acceptable
Variability
2.50
2.50
2.50
2.50
2.50
2.50
2.50
2.50
9.3.4.3 Method Blanks
All method blanks had non-detected asbestos concentrations at less than 10 s/mm2.
9.3.4.4 Replicates
A replicate analysis is a second analysis of the same preparation, but not necessarily the same grid
openings, by the same microscopist as the original analysis. Results for replicates are presented in
Table 9-18. All replicate analyses met the acceptance criteria for variability.
Table 9-18. Replicates for Settled Dust Samples
Sample ID
SDUST-NESH-ASB-R2-H1-M2
SDUST-NESH-ASB-R2-H1-M15
SDUST-AACM-ASB-R1 -HI -M4
Method
TEM
TEM
TEM
Sample
Result
1
1
9
QA/QC
Result
1
1
9
Actual
Variability
0
0
0
Acceptable
Variability
2.24
2.24
2.24
160
-------
9.3.4.5 Duplicates
A duplicate analysis is the analysis of a second aliquot of the original dust sample aqueous
suspension. Results for duplicates are presented in Table 9-19. All duplicate analyses met the
acceptance criteria for variability.
Table 9-19. Duplicates for Settled Dust Samples
Sample ID
SDUST-NESH- ASB-R1 -HI -
M16
SDUST- AACM- ASB-R1 -HI -
M6
SDUST-AACM-ASB-R2-H1-
M15
Method
TEM
TEM
TEM
Sample
Result
16
6
5
QA/QC
Result
15
6
7
Actual
Variability
0.18
0
0.58
Acceptable
Variability
2.50
2.50
2.50
9.3.5 Water QA/QC Results
9.3.5.1 Field Blank
A field blank is a clean sample container with approximately 800 mL of laboratory water which is
opened in the field for approximately 30 seconds. The field blank had a non-detected asbestos
concentration of less than 10 s/mm2.
9.3.5.2 Field Duplicate
A field duplicate is a second sample collected concurrently at the same location as the original
sample. Results for the field duplicate are presented in Table 9-20. This duplicate met the
acceptance criteria for variability.
Table 9-20. Field Du
)licate for Water Samples.
Sample ID
Water-AACM-
Dayl- Surface- AM
Method
EPA100.2
Sample
Result
106
Duplicate
Result
104
Actual
Variability
0.14
Acceptable
Variability
None Specified
161
-------
9.3.5.3 Method Blank
The method blank had a non-detected asbestos concentration of less than 10 s/mm2.
9.3.5.4 Replicates
A replicate analysis is a second analysis of the same preparation, but not necessarily the same grid
openings, by the same microscopist as the original analysis. Results for the replicate are presented in
Table 9-21. The replicate analysis met the acceptance criteria for variability.
Table 9-21. Replicate for Water Samples.
Sample ID
Water-NESHAP-Dayl-
Source-Predemo
Method
EPA100.2
Sample
Result
0
QA/QC
Result
0
Actual
Variability
0
Acceptable
Variability
2.24
9.3.5.5 Duplicates
A duplicate analysis is the analysis of a second aliquot of the original water sample. Results for the
duplicate are presented in Table 9-22. The duplicate analysis met the acceptance criteria for
variability.
Table 9-22. Duplicate for Water Samples.
Sample ID
Water-AACM-
Day 1 - Surface- AM
Method
EPA100.2
Sample
Result
106
QA/QC
Result
111
Actual
Variability
0.34
Acceptable
Variability
2.50
9.4 QA/QC Summary
All air and water QA/QC samples for asbestos met acceptance criteria and can be used with
confidence in making project conclusions using the air and water results. Some variability was
observed for some soil QA/QC samples and this variability should be considered in making project
conclusions using for the soil results. For the settled dust samples, a highly variable field duplicate
was observed, indicating possible splashing into the dust containers from the demolition activities,
which should be considered in making project conclusions using the settled dust results.
162
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SECTION 10 CONCLUSIONS
Conclusions
The following conclusions are relevant to the demolitions of the identical structures at Fort
Chaffee Redevelopment Authority:
Primary Objectives
• The airborne asbestos concentrations measured by transmission electron microscopy
(TEM) during both the NESHAP and the AACM demolition processes were orders of
magnitude below any EPA existing health or performance criterion. At an analytical
sensitivity of 0.0005 asbestos structures per cubic centimeter of air (s/cm3), the
maximum asbestos air concentration was 0.0005 s/cm3 (one structure observed) for the
NESHAP process and 0.0019 s/cm3 (four structures observed) for the AACM process.
« The airborne asbestos (TEM) concentrations were near or below the limit of detection.
The statistical analyses for the demolition phase of both processes showed that the
airborne asbestos (TEM) concentrations from the AACM were equal to the NESHAP
(based upon the observed proportion of detects). The statistical analyses comparing both
total processes (including the soil removal phase of the AACM) showed that the airborne
asbestos (TEM) concentrations from the AACM were not equal to the airborne asbestos
(TEM) concentrations from the NESHAP Method (p=0.0006, where p represents a
strength of evidence that the null hypothesis is true. The smaller the p-value, the stronger
the evidence is that the null hypothesis should be rejected. In this study, the null
hypothesis was rejected for p values less than 0.05.). The empirical evidence (the
proportion of non-detects and the maximum values) from the investigation suggests
airborne asbestos (TEM) concentrations from the AACM were greater than the airborne
asbestos (TEM) concentrations from the NESHAP Method. Based upon the observed
proportion of detects, it was concluded that the difference between the two methods is a
function of the Day 2 AACM activities (soil excavation and removal). This was likely
due to an operational error where no water was added during the soil removal stage of the
process.
* The statistical analyses showed that the post-excavation asbestos TEM concentrations in
the soil from the AACM were not equal to the post-demolition asbestos concentrations in
the soil from the NESHAP Method (p=0.033). Based on descriptive statistics, it was
concluded that the post-excavation asbestos concentrations in the soil from the AACM
were less than the post-demolition asbestos concentrations in the soil from the NESHAP
Method. Polarized Light Microscopy (PLM) analyses for all soil samples from both
processes indicated very low concentrations of asbestos; the NESHAP post-demolition
soil had only one often samples with detectable asbestos (0.3 percent) whereas the
AACM post-excavation soil had no samples with detectable asbestos at an analytical
sensitivity of 0.1 percent.
163
-------
* The cost of the NESHAP demolition process ($108,331) was approximately twice the
cost of the AACM demolition process ($57,864) for this site. Costs specific to conducting
the research were not included.
Secondary Objectives
• Based upon descriptive statistics, the fiber concentrations in air from the AACM as
measured by phase contrast microscopy (PCM) were equal to the fiber concentrations
from the NESHAP Method.
* A brief visible emission was observed during the removal of a concrete foundation
structure during the NESHAP demolition, but it was not an asbestos-containing material.
No visible emissions were observed during the AACM demolition.
• Settled dust asbestos loadings during the AACM demolition were equal to the settled dust
loadings during the NESHAP demolition.
• The statistical analyses showed that the total particulate concentrations, as collected and
measured by NIOSH's Method 0500, from the AACM were not equal to the total
particulate concentrations from the NESHAP Method. Based on the observed proportion
of detects, the total particulate concentrations from the AACM were higher than the total
particulate concentrations from the NESHAP Method. This is attributed the extended
sampling period for the AACM process, which included soil removal and disposal. Since
wetting was inadvertently not performed during the soil removal, it is possible that this
increased the particulate loading.
» Based on the observed proportion of non-detects, the worker breathing zone asbestos
concentrations (TEM) from the AACM were less than the worker breathing zone asbestos
concentrations (TEM) from the NESHAP method. This was due to the concentrations
encountered by workers during the abatement required by the NESHAP. The maximum
breathing zone asbestos concentration was 0.093 s/cm3 for the NESHAP process
(abatement phase) whereas no asbestos was detected on any of the AACM worker
breathing zone samples (<0.005 s/cm3).
• One NESHAP worker had an Eight-Hour Time-Weighted Average (TWA) fiber (PCM)
concentration which equaled the OSHA PEL (Personal Exposure Limit) of 0.1 f/cm3. The
maximum TWA fiber concentration for the AACM was 0.03 f/cm3.
* Based on descriptive statistics, the NESHAP post-demolition soil asbestos (TEM)
concentrations are greater than the NESHAP pre-demolition soil concentrations; the
AACM pre-demolition soil asbestos (TEM) concentrations are greater than the post-
excavation soil concentrations; and the AACM post-demolition soil asbestos (TEM)
concentrations are greater than the AACM post-excavation soil concentrations.
• The time required to perform the AACM process (l!/2 days) was about one-fifth the time
required to perform the NESHAP process (ten days) for this site. The abatement phase of
164
-------
the NESHAP process was very labor intensive (nine days) and took nine times longer
than the demolition itself (one day) for this site.
* Both the NESHAP and the AACM processes left minimal amounts of small fragments of
asbestos-containing material (ACM) debris, primarily vinyl asbestos floor tile, in the soil
at the completion of the processes; however, the AACM process (post-excavation) left
less ACM debris than the NESHAP process (post-demolition).
A summary comparison is presented in Table 10-1.
165
-------
Table 10-1. Summary Comparison of the Results of the NESHAP
and AACM Demolitions at Fort Chaffee
PARAMETER
Asbestos(TEM) in Air1
(Range)
Asbestos(PLM) in Soil1
(Range)
Asbestos (TEM) in Soil1
(Range)
Cost
Visible Emissions
Fibers(PCM) in Air1
(Range)
Asbestos (TEM) in
Dust1
(Range)
Asbestos (TEM) in
Worker
Breathing Zone (max)
Fibers (PCM) in
Worker Breathing
Zone (max TWA)
Particulate in Air1
(Range)
Time
Asbestos (PLM) Debris
in Soil1
(Range)
NESHAP
0.000054 s/cm3
(0 to 0.00049 s/cm3)
0.03 %
(0 to 0.34 %)
l.SlxlO8 s/g
(0 to 1.6xl09 s/g)
$108,331
One Observed
(not from ACM)
0.002 f/cm3
(0 to 0.006 f/cm3)
6,650 s/cm2
(0 to 46,800 s/cm2)
0.093 s/cm3
0.10 f/cm3
0.032 mg/m3
(0 to 0.11 mg/m3)
10 days
0.07%
(0.01 to 0.15 %)
AACM
0.00012 s/cm3
(0 to 0.0019 s/cm3)
0%
(0 to 0 %)
1.67xl07 s/g
(0 to l.SxlO8 s/g)
$57,864
None
Observed
0.003 f/cm3
(0 .001 to 0.016 f/cm3)
5,080 s/cm2
(0 to 21,600 s/cm2)
0 s/cm3
0.03 f/cm3
0.084 mg/m3
(0 to 0.15 mg/m3)
V/2 days
0.01%
(0 to 0.03 %)
Comment
All concentrations
near or below the
limit of detection;
however, AACM
greater than
NESHAP2
No statistical tests
performed
AACM less than
NESHAP
No statistical
difference
No statistical
difference
NESHAP had one
concentration at PEL
AACM greater than
NESHAP
AACM less than
NESHAP
1 Means
2 For Day 1 there was no difference between the methods. When Days 1 and 2 were combined for the
AACM, a difference was observed, likely due to the lack of wetting during soil removal.
166
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SECTION 11 LESSONS LEARNED
During the course of the implementation of this evaluation, the following lessons were learned:
* The berms and Ring One samplers were placed 15-ft from the structures and 25 ft on the
side where the trucks were loaded with debris. This was too close because dried
particulate from the demolition and debris loading process was observed in the settled
dust containers. A 25-ft distance is more reasonable (35 ft on the loadout side).
• Minimal leakage was observed through the berm of the AACM. It appears that the
wetting agent enhanced the permeability of the soil berm. Methods to control leakage
need to be employed, such as placing plastic film over the berm.
« A one-percent solution of wetting agent was used to ensure adequate proportioning and
measurement of the concentration in this implementation of the AACM process.
Consultation with the supplier indicates that the concentration to achieve effective
wetting could be 0.5 percent or lower.
• Two 30-gpm nozzles were used at the recommendation of the supplier. Based upon field
observations, it is likely an equally effective wetting could be achieved with significantly
less water.
• As there appears to be a correlation between airborne asbestos concentrations at the five-
and 15-ft heights in the inner ring, and lower concentrations were observed in the outer
ring, multiple heights and multiple rings are probably unnecessary for any future
monitoring efforts.
* It is critically important to continue the wetting throughout the soil removal and loadout
portion of the implementation of the AACM, and particularly during the berm removals.
167
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168
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SECTION 12 REFERENCES
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School, http://www.arb.ca.gov/toxics/asbestos/orhs.htm . Nov 2003.
Technical Report on: Area Air, Soil, and Water Monitoring During Asbestos Demolition
Method. Prepared for City of Saint Louis by Industrial Hygiene and Safety Technology, Inc.,
Carrollton, TX. December 2004.
U.S. EPA. AHERA, 40 CFRPart 763, FR Vol. 52, No. 210, Oct. 30, 1987.
U.S. EPA. National Primary Drinking Water Standards, 40 CFR 141.51, July 1, 2002.
170
-------
U.S. EPA. Hurricane Katrina Sample Screening Document. 2005.
U.S.EPA. Method for the Determination of Asbestos in Bulk Building Materials. EPA 600/R-
93/116, July 1993.
U.S.EPA. Test Methods for Evaluating Solid Waste, Physical Chemical Methods.
http://www.epa.gov/epaoswer/hazwaste/test/sw846.htm . October 2006.
U.S. EPA. World Trade Center Indoor Indoor Dust Test And Clean Program Plan, Nov. 2005.
Wilmoth, R.C., B.A. Hollett, J.R. Kominsky, et al. Fugitive Emissions of Asbestos During
Building Demolition and Landfilling of Demolition Debris: Santa Cruz, CA. U.S. EPA, RREL,
Cincinnati, OH. October 17, 1990.
Wilmoth, R.C., J.R. Kominsky, J. Boiano, et al. Quantitative Evaluation of HEP A Filtrations
Systems at Asbestos Abatement Sites. The Environmental Information Association. J. Vol. 2
(1):6-12. 1993.
Wilmoth, R.C., M.S. Taylor, and B.E.Meyer. Asbestos Release From the Demolition of Two
Schools in Fairbanks, AK. Applied Occupational and Environmental Hygiene Volume 9, No.6.
June 1994.
Wilmoth, R.C., P.J.Clark, B.R. Hollett, T.Powers, and J. Millette. Asbestos Release During
Building Demolition. Environmental Choices Technical Supplement, Volume 1, No. 2, Atlanta,
GA. March/April 1993.
171
-------
172
-------
APPENDIX A - DATA LISTINGS
173
-------
Table A-l. Laboratory Data: Sample Key
Label Category
MEDIA
LOCATION/
BUILDING
COPC
PUMP FLOW RATE
TIME
RING NUMBER
HEIGHT
Label ID
AIR
WATER
SOIL
SDUST
WORK
ISOKINETIC
NESH (or NESHAP)
AACM
LF
ASB
PB
PART
4L
2L
7L
Dl (orDAYl)
D2 (or DAY2)
D3 (or DAYS)
AM
PM
PRE
POST
DEMO
EXCAV
Rl
R2
HI
H2
ID Description
Air
Water
Soil
Settled Dust
Worker Air
Isokinetic
NESHAP Building
Alternative Asbestos Control
Method Building
Landfill
Asbestos
Lead
Paniculate
Target Air Flow Rate: 4LPM
Target Air Flow Rate: 2LPM
Target Air Flow Rate: 7 LPM
Sample Day 1
Sample Day 2
Sample Day 3
Morning (between 0600-1200
hours)
Afternoon (after 1200 hours)
Pre- (Building) Demolition:
NESHAP & AACM
Post- (Building) Demolition:
NESHAP
Post- (Building) Demolition:
AACM
Post-Excavation: AACM
Ring No. 1 (inner ring of
monitors around building)
Ring No.2 (outer ring of
monitors around building)
Sample Height No. 1 (five feet)
Sample Height No.2 (15 feet)
Relevant Media
NA
NA
NA
NA
NA
NA
ALL
ALL (except
Isokinetic)
Air, Worker Air
ALL
Air, Worker Air
Air
Air
Air
Air
ALL (except
Isokinetic/soil)
ALL (except
Isokinetic/soil)
ALL (except
Isokinetic/soil)
Water
Water
Soil
Soil
Soil
Soil
Air, Settled Dust
Air, Settled Dust
Air, Settled Dust
Air, Settled Dust
174
-------
Table A-2 NESHAP Building - Airborne Asbestos and Total Fibers in Rings 1 and 2
Sample Number
NESH-ASB-4L-D1-R1-H1-M1
NESH-ASB-4L-D 1 -Rl -HI -M2
NESH-ASB-4L-D 1 -Rl -HI -M3
NESH-ASB-4L-D 1 -Rl -HI -M4
NESH-ASB-4L-D 1 -Rl -HI -M5
NESH-ASB-4L-D 1 -Rl -HI -M6
NESH-ASB-4L-D 1 -Rl -HI -M7
NESH-ASB-4L-D 1 -Rl -HI -M8
NESH-ASB-4L-D 1 -Rl -HI -M9
NESH-ASB-4L-D1-R1-H1-M10
NESH-ASB-4L-D1-R1-H1-M1 1
NESH-ASB-4L-D1-R1-H1-M12
NESH-ASB-4L-D1-R1-H1-M13
NESH-ASB-4L-D1-R1-H1-M14
NESH-ASB-4L-D1-R1-H1-M15
NESH-ASB-4L-D1-R1-H1-M16
NESH-ASB-4L-D1-R1-H1-M17
NESH-ASB-4L-D1-R1-H1-M18
NESH-ASB-4L-D1-R1-H1-DUP1 (M5)
NESH-ASB-4L-D1-R1-H1-DUP2 (M17)
NESH-ASB-4L-D1-R1-H2-M1
NESH-ASB-4L-D 1 -Rl -H2-M2
NESH-ASB-4L-D1-R1-H2-M3
NESH-ASB-4L-D 1 -Rl -H2-M4
NESH-ASB-4L-D1-R1-H2-M5
NESH-ASB-4L-D 1 -Rl -H2-M6
NESH-ASB-4L-D 1 -Rl -H2-M7
NESH-ASB-4L-D1-R1-H2-M8
NESH-ASB-4L-D1-R1-H2-M9
NESH-ASB-4L-D1-R1-H2-M10
NESH-ASB-4L-D1-R1-H2-M1 1
Sample
Volume,
Liters
1772
1805
1786
1732
1814
1756
1748
1786
1733
1680
1759
1833
1776
1896
1744
1602
1638
1665
1713
1638
1776
1794
1786
1775
1763
1752
1794
1737
1775
1721
1410
Grid
Openings
Analyzed1
49
48
48
50
48
49
49
48
50
51
49
47
49
46
50
54
53
52
50
53
49
48
49
49
49
49
48
50
49
50
61
Structures Counted
Chrysotile
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
1
0
0
1
0
0
Amphibole
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Asbestos (TEM)2— s/cm3
Chrysotile
0.00049
O.00049
0.00049
O.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
0.00049
O.00049
0.00049
Amphibole
0.00049
O.00049
0.00049
O.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
Total
0.00049
O.00049
0.00049
O.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
0.00049
O.00049
0.00049
PCME
0.00049
O.00049
0.00049
O.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
0.00049
O.00049
0.00049
Total
Fibers
(PCM),
fibers/cm3
0.0011
0.0014
0.0011
0.0016
0.0022
0.0013
0.0017
0.0018
0.0062
0.0045
0.0021
0.0034
0.0017
0.0029
0.0024
0.0025
0.0023
O.0012
0.0012
0.0023
0.0023
0.0013
0.0014
0.0032
0.0020
0.0011
0.0024
0.0039
0.0045
0.0022
0.0021
175
-------
Table A-2 NESHAP Building - Airborne Asbestos and Total Fibers in Rings 1 and 2 (Continued)
Sample Number
NESH-ASB-4L-D1-R1-H2-M12
NESH-ASB-4L-D1-R1-H2-M13
NESH-ASB-4L-D1-R1-H2-M14
NESH-ASB-4L-D1-R1-H2-M15
NESH-ASB-4L-D1-R1-H2-M16
NESH-ASB-4L-D1-R1-H2-M17
NESH-ASB-4L-D1-R1-H2-M18
NESH-ASB-4L-D1-R1-H2-DUP1 (M2)
NESH-ASB-4L-D1-R1-H2-DUP2 (M12)
NESH-ASB-4L-D1-R2-H1-M1
NESH-ASB-4L-D 1 -R2-H1 -M2
NESH-ASB-4L-D 1 -R2-H1 -M3
NESH-ASB-4L-D 1 -R2-H1 -M4
NESH-ASB-4L-D 1 -R2-H1 -M5
NESH-ASB-4L-D 1 -R2-H1 -M6
NESH-ASB-4L-D 1 -R2-H1 -M7
NESH-ASB-4L-D 1 -R2-H1 -M8
NESH-ASB-4L-D 1 -R2-H1 -M9
NESH-ASB-4L-D1-R2-H1-M10
NESH-ASB-4L-D1-R2-H1-M1 1
NESH-ASB-4L-D1-R2-H1-M12
NESH-ASB-4L-D1-R2-H1-M13
NESH-ASB-4L-D1-R2-H1-M14
NESH-ASB-4L-D1-R2-H1-M15
NESH-ASB-4L-D1-R2-H1-M16
NESH-ASB-4L-D1-R2-H1-M17
NESH-ASB-4L-D1-R2-H1-M18
NESH-ASB-4L-D1-R2-H1-DUP1 (Ml)
NESH-ASB-4L-D1-R2-H1-DUP2 (M15)
Sample
Volume,
Liters
1647
1455
1720
1664
1602
1591
1623
1746
1380
1758
1746
1735
1775
1724
1814
1670
1752
1744
1786
1782
1687
1816
1714
1665
1613
1739
1687
1805
1710
Grid
Openings
Analyzed1
52
59
50
52
54
54
53
49
62
49
49
50
49
50
48
52
49
50
48
49
51
49
50
52
53
50
51
48
50
Structures Counted
Chrysotile
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Amphibole
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Asbestos (TEM)2 — s/cm3
Chrysotile
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00098
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
Amphibole
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
Total
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.0015
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
PCME
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00098
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
Total
Fibers
(PCM),
fibers/cm3
0.0030
0.0022
0.0035
O.0012
0.0056
0.0019
0.0017
0.0019
0.0034
0.0030
0.0026
0.0019
0.0011
0.0013
0.0021
0.0012
0.0044
0.0020
0.0013
0.0017
0.0019
0.0019
0.0011
0.0017
0.0025
0.0022
0.0018
0.0026
0.0015
:Grid opening size = 0.0091 mm ; effective filter area = 385 mm .
2Less than values represent the analytical sensitivities; detection limits are 2.99 times higher, per ISO 10312.
176
-------
Table A-3. AACM Building - Airborne Asbestos and Total Fibers in Rings 1 and 2.
Sample Number1
AACM-ASB-4L-D1-R1-H1-M1
AACM-ASB-4L-D 1 -Rl -HI -M2
AACM -ASB-4L-D1-R1-H1-M3
AACM -ASB-4L-D1-R1-H1-M4
AACM -ASB-4L-D1-R1-H1-M5
AACM -ASB-4L-D1-R1-H1-M6
AACM -ASB-4L-D1-R1-H1-M7
AACM -ASB-4L-D1-R1-H1-M8
AACM -ASB-4L-D1-R1-H1-M9
AACM -ASB-4L-D1-R1-H1-M10
AACM -ASB-4L-D1-R1-H1-M11
AACM -ASB-4L-D1-R1-H1-M12
AACM -ASB-4L-D1-R1-H1-M13
AACM -ASB-4L-D1-R1-H1-M14
AACM -ASB-4L-D1-R1-H1-M15
AACM -ASB-4L-D1-R1-H1-M16
AACM -ASB-4L-D1-R1-H1-M173
AACM -ASB-4L-D1-R1-H1-M18
AACM-ASB-4L-D1-R1-H1-DUP1 (M5)
AACM -ASB-4L-D1-R1-H1-DUP2 (M17)
AACM-ASB-4L-D 1 -Rl -H2-M1
AACM -ASB-4L-D1-R1-H2-M2
AACM -ASB-4L-D1-R1-H2-M3
AACM -ASB-4L-D1-R1-H2-M4
AACM -ASB-4L-D1-R1-H2-M5
AACM -ASB-4L-D1-R1-H2-M6
AACM -ASB-4L-D1-R1-H2-M7
AACM -ASB-4L-D1-R1-H2-M8
AACM -ASB-4L-D1-R1-H2-M9
AACM -ASB-4L-D1-R1-H2-M10
AACM -ASB-4L-D1-R1-H2-M11
AACM -ASB-4L-D1-R1-H2-M12
Sample
Volume,
Liters
2782
2850
2846
2768
2909
2827
2748
2894
2816
2734
2804
2723
2789
2859
2782
2632
3
2843
2760
2701
2861
2850
2842
2839
2831
2902
2848
2820
2886
2808
2804
2723
Grid
Openings
Analyzed1
31
31
31
31
30
31
32
30
31
32
31
32
31
30
31
33
3
31
31
32
30
30
31
31
31
30
31
31
30
31
31
32
Structures Counted
Chrysotile
0
0
2
0
0
0
0
0
0
0
0
0
0
0
0
1
3
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Amphibole
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Asbestos (TEM)2 — s/cm3
Chrysotile
O.00049
0.00048
0.00096
0.00049
0.00048
O.00048
0.00048
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
3
O.00048
O.00049
0.00049
O.00049
0.00049
O.00048
0.00048
O.00048
0.00049
O.00048
0.00048
O.00049
0.00049
O.00049
0.00049
Amphibole
O.00049
0.00048
O.00048
0.00049
0.00048
O.00048
0.00048
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
3
O.00048
O.00049
0.00049
O.00049
0.00049
O.00048
0.00048
O.00048
0.00049
O.00048
0.00048
O.00049
0.00049
O.00049
0.00049
Total
O.00049
0.00048
0.00096
0.00049
0.00048
O.00048
0.00048
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
0.00049
3
O.00048
O.00049
0.00049
O.00049
0.00049
O.00048
0.00048
O.00048
0.00049
O.00048
0.00048
O.00049
0.00049
O.00049
0.00049
PCME
O.00049
0.00048
O.00048
0.00049
0.00048
O.00048
0.00048
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
3
O.00048
O.00049
0.00049
O.00049
0.00049
O.00048
0.00048
O.00048
0.00049
O.00048
0.00048
O.00049
0.00049
O.00049
0.00049
Total
Fibers
(PCM),
fibers/cm3
0.0032
0.0034
0.0033
0.0024
0.0021
0.0012
0.0015
0.0042
0.0044
0.0018
0.0040
0.0031
0.0024
0.0037
0.0020
0.0029
-4
0.0035
0.0024
0.0047
0.0021
0.0029
0.0053
0.0013
0.0026
0.0020
0.0023
0.0022
0.0023
0.0029
0.0027
0.0040
177
-------
Table A-3. AACM Building - Airborne Asbestos and Total Fibers in Rings 1 and 2.(Continued)
Sample Number1
AACM -ASB-4L-D1-R1-H2-M13
AACM -ASB-4L-D1-R1-H2-M14
AACM -ASB-4L-D1-R1-H2-M15
AACM -ASB-4L-D1-R1-H2-M16
AACM -ASB-4L-D1-R1-H2-M17
AACM -ASB-4L-D1-R1-H2-M18
AACM-ASB-4L-D1-R1-H2-DUP1 (M2)
AACM -ASB-4L-D1-R1-H2-DUP2 (M12)
AACM-ASB-4L-D1-R2-H1-M1
AACM -ASB-4L-D1-R2-H1-M2
AACM -ASB-4L-D1-R2-H1-M3
AACM -ASB-4L-D1-R2-H1-M4
AACM -ASB-4L-D1-R2-H1-M5
AACM -ASB-4L-D1-R2-H1-M6
AACM -ASB-4L-D1-R2-H1-M7
AACM -ASB-4L-D1-R2-H1-M8
AACM -ASB-4L-D1-R2-H1-M9
AACM -ASB-4L-D1-R2-H1-M10
AACM -ASB-4L-D1-R2-H1-M11
AACM -ASB-4L-D1-R2-H1-M12
AACM -ASB-4L-D1-R2-H1-M13
AACM -ASB-4L-D1-R2-H1-M14
AACM -ASB-4L-D1-R2-H1-M15
AACM -ASB-4L-D1-R2-H1-M16
AACM -ASB-4L-D1-R2-H1-M17
AACM -ASB-4L-D1-R2-H1-M18
AACM-ASB-4L-D1-R2-H1-DUP1 (Ml)
AACM -ASB-4L-D1-R2-H1-DUP2 (M15)
AACM-ASB-7L-D2-R1-H1-M1
AACM-ASB-7L-D2-R1 -HI -M2
AACM -ASB-7L-D2-R1-H1-M3
AACM -ASB-7L-D2-R1-H1-M4
AACM -ASB-7L-D2-R1-H1-M5
Sample
Volume,
Liters
2789
2859
2782
2705
2701
2766
2775
2723
2775
2779
2917
2839
2760
2906
2678
2823
2745
2890
2812
2808
2804
2874
2720
2642
2855
2851
2925
2793
2088
2104
2098
2058
2155
Grid
Openings
Analyzed1
31
30
31
32
32
31
31
32
31
31
30
31
31
30
32
31
32
30
31
31
31
30
32
33
30
30
30
31
41
41
41
42
40
Structures Counted
Chrysotile
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
1
1
1
Amphibole
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Asbestos (TEM)2— s/cm3
Chrysotile
0.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00049
O.00049
0.00048
O.00048
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00048
O.00048
0.00049
O.00049
0.00049
0.00049
0.00049
0.00049
Amphibole
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00049
O.00049
0.00048
O.00048
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00048
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
Total
0.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00049
O.00049
0.00048
O.00048
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00048
O.00048
0.00049
O.00049
0.00049
0.00049
0.00049
0.00049
PCME
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00049
O.00049
0.00048
O.00048
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
0.00048
O.00048
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
Total
Fibers
(PCM),
fibers/cm3
0.0038
0.0029
0.0027
0.0012
0.0028
0.0032
0.0019
0.0023
0.0026
0.0028
0.0027
0.0018
0.0024
0.0015
0.0034
0.0035
0.0028
0.0022
0.0029
0.0033
0.0021
0.0028
0.0017
0.0025
0.0014
0.0038
0.0024
0.0021
0.0029
0.0023
0.0037
0.0035
0.0028
178
-------
Table A-3. AACM Building - Airborne Asbestos and Total Fibers in Rings 1 and 2.(Continued)
Sample Number1
AACM -ASB-7L-D2-R1-H1-M6
AACM -ASB-7L-D2-R1-H1-M7
AACM -ASB-7L-D2-R1-H1-M8
AACM -ASB-7L-D2-R1-H1-M9
AACM -ASB-7L-D2-R1-H1-M10
AACM -ASB-7L-D2-R1-H1-M11
AACM -ASB-7L-D2-R1-H1-M12
AACM -ASB-7L-D2-R1-H1-M13
AACM -ASB-7L-D2-R1-H1-M14
AACM -ASB-7L-D2-R1-H1-M15
AACM -ASB-7L-D2-R1-H1-M16
AACM -ASB-7L-D2-R1-H1-M171
AACM -ASB-7L-D2-R1-H1-M18
AACM -ASB-7L-D2-R1-H1-DUP1 (M5)
AACM -ASB-7L-D2-R1-H1-DUP2 (M17)
AACM-ASB-7L-D2-R1-H2-M1
AACM -ASB-7L-D2-R1-H2-M2
AACM -ASB-7L-D2-R1-H2-M3
AACM -ASB-7L-D2-R1-H2-M4
AACM -ASB-7L-D2-R1-H2-M5
AACM -ASB-7L-D2-R1-H2-M6
AACM -ASB-7L-D2-R1-H2-M7
AACM -ASB-7L-D2-R1-H2-M8
AACM -ASB-7L-D2-R1-H2-M9
AACM -ASB-7L-D2-R1-H2-M10
AACM -ASB-7L-D2-R1-H2-M11
AACM -ASB-7L-D2-R1-H2-M12
AACM -ASB-7L-D2-R1-H2-M13
AACM -ASB-7L-D2-R1-H2-M14
AACM -ASB-7L-D2-R1-H2-M15
AACM -ASB-7L-D2-R1-H2-M16
AACM -ASB-7L-D2-R1-H2-M17
Sample
Volume,
Liters
2086
2097
2108
2062
2062
2083
2016
2071
2071
2026
1986
4140
2040
Grid
Openings
Analyzed1
41
41
41
42
42
42
43
42
42
43
44
31
42
Structures Counted
Chrysotile
0
0
1
1
0
0
0
0
0
0
0
0
1
Amphibole
0
0
0
0
0
0
0
0
0
0
0
0
0
Asbestos (TEM)2— s/cm3
Chrysotile
O.00049
0.00049
0.00049
0.00049
O.00049
0.00048
0.00049
0.00049
O.00049
0.00049
O.00048
3
0.00049
Amphibole
O.00049
0.00049
O.00049
0.00049
O.00049
0.00048
0.00049
0.00049
O.00049
0.00049
O.00048
3
0.00049
Total
O.00049
0.00049
0.00049
0.00049
O.00049
0.00048
0.00049
0.00049
O.00049
0.00049
O.00048
3
0.00049
PCME
O.00049
0.00049
O.00049
0.00049
O.00049
0.00048
0.00049
0.00049
O.00049
0.00049
O.00048
3
0.00049
Total
Fibers
(PCM),
fibers/cm3
0.0041
0.0026
0.0011
0.0046
0.0021
0.0048
0.0046
0.0041
0.0012
0.0023
0.0055
-4
0.0022
Sample Lost
2013
2088
2104
2132
2092
2097
2120
2074
2074
2096
2005
1993
1243
2038
2038
2058
1986
1980
43
41
41
41
41
41
41
42
42
41
43
43
70
43
43
42
44
44
0
0
1
4
0
1
0
0
1
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0.00049
O.00049
0.00049
0.0019
O.00049
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
0.00049
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
0.00049
O.00049
O.00049
0.00048
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
0.00049
O.00049
0.00049
0.0019
O.00049
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
0.00049
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
0.00049
O.00049
O.00049
0.00048
O.00049
0.00049
O.00049
0.00049
0.00049
0.00049
O.00049
0.00049
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
0.0026
0.0024
0.0018
0.0036
0.0019
0.0017
0.0033
0.0027
0.016
0.0024
0.0019
0.0024
0.0044
0.0036
0.0029
0.0021
0.0034
0.0033
179
-------
Table A-3. AACM Building - Airborne Asbestos and Total Fibers in Rings 1 and 2.(Continued)
Sample Number1
AACM -ASB-7L-D2-R1-H2-M18
AACM -ASB-7L-D2-R1-H2-DUP1 (M2)
AACM -ASB-7L-D2-R1-H2-DUP2
(M12)
AACM-ASB-7L-D2-R2-H1-M1
AACM -ASB-7L-D2-R2-H1-M2
AACM -ASB-7L-D2-R2-H1-M3
AACM -ASB-7L-D2-R2-H1-M4
AACM -ASB-7L-D2-R2-H1-M5
AACM -ASB-7L-D2-R2-H1-M6
AACM -ASB-7L-D2-R2-H1-M7
AACM -ASB-7L-D2-R2-H1-M8
AACM -ASB-7L-D2-R2-H1-M9
AACM -ASB-7L-D2-R2-H1-M10
AACM -ASB-7L-D2-R2-H1-M11
AACM -ASB-7L-D2-R2-H1-M12
AACM -ASB-7L-D2-R2-H1-M13
AACM -ASB-7L-D2-R2-H1-M14
AACM -ASB-7L-D2-R2-H1-M15
AACM -ASB-7L-D2-R2-H1-M16
AACM -ASB-7L-D2-R2-H1-M17
AACM -ASB-7L-D2-R2-H1-M18
AACM -ASB-7L-D2-R2-H1-DUP1 (Ml)
AACM -ASB-7L-D2-R2-H1-DUP2
(M15)
Sample
Volume,
Liters
2007
2139
2016
2028
2016
2049
2031
2025
2025
1986
2046
2007
2040
2034
2006
2028
2086
1983
1950
2002
2040
2062
1950
Grid
Openings
Analyzed1
44
40
44
43
43
42
43
43
43
44
42
43
42
43
43
43
41
44
44
43
44
42
45
Structures Counted
Chrysotile
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
1
0
1
Amphibole
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Asbestos (TEM)2— s/cm3
Chrysotile
O.00048
0.00049
O.00048
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00048
O.00049
0.00049
0.00049
0.00048
O.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00048
O.00049
0.00049
Amphibole
O.00048
0.00049
O.00048
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00048
O.00049
0.00049
O.00049
0.00048
O.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00048
O.00049
0.00049
Total
O.00048
0.00049
O.00048
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00048
O.00049
0.00049
0.00049
0.00048
O.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00048
O.00049
0.00049
PCME
O.00048
0.00049
O.00048
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00048
O.00049
0.00049
O.00049
0.00048
O.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00048
O.00049
0.00049
Total
Fibers
(PCM),
fibers/cm3
0.0024
0.0012
0.0038
0.0032
0.0043
0.0029
0.0033
0.0035
0.0017
0.0024
0.0015
0.0014
0.0020
0.0031
0.0021
0.0028
0.0020
0.0015
0.0032
0.0024
0.0034
0.0033
0.0021
Grid opening size = 0.0091 mm ; effective filter area = 385 mm .
2Less than values represent the analytical sensitivities; detection limits are 2.99 times higher, per ISO 10312.
Sample AACM -ASB-4L-Di-Ri-m-Mi7 was inadvertently not changed out at the end of Day 1, but operated for the entire sampling period; however, no asbestos
structures were seen at an analytical sensitivity of 0.00033 s/cm3.
4Sample AACM -ASB-4L-D1-R1-H1-M17 was inadvertently not changed out at the end of Day 1, but operated for the entire sampling period; however, the total
fiber concentration was of 0.0017 f/cm3.
180
-------
Table A-4. Background Levels of Airborne Asbestos and Total Fibers - Ring 1 at NESHAP and AACM Buildings, and Landfill
Sample Number
NESHAP- ASB-4L-BG-R1 -M2
NESHAP- ASB-4L-BG-R1 -M5
NESHAP- ASB-4L-BG-R1 -M8
NESHAP-ASB-4L-BG-R1 -Ml 1
NESHAP-ASB-4L-BG-R1 -M14
NESHAP-ASB-4L-BG-R1 -Ml 7
NESHAP-ASB-4L-BG-R1-DUP1 (M5)
AACM-ASB-4L-BG-R1 -Ml
AACM-ASB-4L-BG-R1 -M4
AACM-ASB-4L-BG-R1 -M7
AACM-ASB-4L-BG-R1 -Ml 0
AACM-ASB-4L-BG-R1 -Ml 3
AACM-ASB-4L-BG-R1 -Ml 6
AACM-ASB-4L-BG-R1-DUP1 (M13)
LANDFILL-ASB-4L-BG-M1
LANDFILL-ASB-4L-BG-M2
LANDFILL-ASB-4L-BG-M4
LANDFILL-ASB-4L-BG-M5
LANDFILL-ASB-4L-BG-M7
LANDFILL-ASB-4L-BG-M8
LANDFILL-ASB-4L-BG-DUP1 (M8)
Sample
Volume,
Liters
1847
1927
1919
1960
2001
1851
1820
1824
1776
1824
1776
1824
1776
1776
960
960
960
960
936
936
912
Grid
Openings
Analyzed1
47
45
45
44
43
47
47
47
49
47
49
47
49
49
90
90
90
90
92
92
94
Structures Counted
Chrysotile
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
Amphibole
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Asbestos (TEM)2— s/cm3
Chrysotile
<0. 00049
<0. 00049
<0. 00049
0.00049
0.00049
0.00049
0.00049
0. 00049
0. 00049
0. 00049
0. 00049
0. 00049
0.00049
0.00049
0.00049
0.00049
0. 00049
0. 00049
0. 00049
0.00049
0. 00049
Amphibole
0. 00049
0. 00049
0. 00049
0.00049
0.00049
0.00049
0.00049
0. 00049
0. 00049
0. 00049
0. 00049
0. 00049
0.00049
0.00049
0.00049
0.00049
0. 00049
0. 00049
0. 00049
0.00049
0. 00049
Total
0. 00049
0. 00049
0. 00049
0.00049
0.00049
0.00049
0.00049
0. 00049
0. 00049
0. 00049
0. 00049
0. 00049
0.00049
0.00049
0.00049
0.00049
0. 00049
0. 00049
0. 00049
0.00049
0. 00049
PCME
0. 00049
0. 00049
0. 00049
0.00049
0.00049
0.00049
0.00049
0. 00049
0. 00049
0. 00049
0. 00049
0. 00049
0.00049
0.00049
0.00049
0.00049
0. 00049
0. 00049
0. 00049
0.00049
0. 00049
Total
Fibers
(PCM),
fibers/cm3
0.0020
O.0010
0.0017
0.0018
0.00096
0.0010
O.0011
0.0027
0.0021
0.0025
0.0045
0.0026
0.0023
0.0025
0.0036
0.0034
0.0052
O.0020
O.0021
0.0021
0.0033
Pre-Study Background Asbestos Levels at Demolition Site — January 11, 2006
1-11-FCN-04A
1-11-FCN-04B
1-11-FCE-05A
1-11-FCE-05B
1-11-FCS-06A
2510
2008
2400
1920
2400
34
43
36
45
36
0
0
0
0
0
0
0
0
0
0
0.0005
0.0005
0.0005
O.0005
O.0005
0.0005
0.0005
0.0005
O.0005
O.0005
0.0005
0.0005
0.0005
O.0005
O.0005
Not analyzed.
Pre-Study Background Asbestos Levels at Landfill — January 11, 2006
1-11-LF-01A
1-11-LF-01B
1-H-LF-02A
1-H-LF-02B
1-H-LF-03A
1-11-LF-03B
2700
2157
2680
2144
2660
2128
32
40
32
40
32
40
0
0
0
0
0
0
0
0
0
0
0
0
0.0005
O.0005
O.0005
O.0005
O.0005
O.0005
0.0005
O.0005
O.0005
O.0005
O.0005
O.0005
0.0005
O.0005
O.0005
O.0005
O.0005
O.0005
Not analyzed
:Grid opening size = 0.0091 mm2; effective filter area = 385 mm2.
2Less than values represent the analytical sensitivities; detection limits are 2.99 times higher, per ISO 10312.
181
-------
Table A-5. Levels of Airborne Asbestos and Total Fibers at Ring 1 - During Landfill
of Demolition Debris from NESHAP and AACM Buildings
Sample Number
LF-NESH-ASB-4L-D1-H1-M1
LF-NESH-ASB-4L-D 1 -HI -M2
LF-NESH-ASB-4L-D 1 -HI -M3
LF-NESH-ASB-4L-D 1 -HI -M4
LF-NESH-ASB-4L-D 1 -HI -M5
LF-NESH-ASB-4L-D 1 -HI -M6
LF-NESH-ASB-4L-D 1 -HI -M7
LF-NESH-ASB-4L-D 1 -HI -M8
LF-NESH-ASB-4L-D 1 -HI -M9
LF-NESH-ASB-4L-D1-H1-DUP1 (M8)
LF-AACM-ASB-4L-D1-H1-M1
LF- AACM- ASB-4L-D 1 -H 1 -M2
LF- AACM- ASB-4L-D 1 -H 1 -M3
LF- AACM- ASB-4L-D 1 -H 1 -M4
LF- AACM- ASB-4L-D 1 -H 1 -M5
LF- AACM- ASB-4L-D 1 -H 1 -M6
LF- AACM- ASB-4L-D 1 -H 1 -M7
LF- AACM- ASB-4L-D 1 -H 1 -M8
LF- AACM- ASB-4L-D 1 -H 1 -M9
LF-AACM-ASB-4L-D1-H1-DUP1 (M8)
LF-AACM-ASB-4L-D2-H1-M1
LF-AACM-ASB-4L-D2-H1-M2
LF-AACM-ASB-4L-D2-H1-M3
LF-AACM-ASB-4L-D2-H1-M4
LF-AACM-ASB-4L-D2-H1-M5
LF-AACM-ASB-4L-D2-H1-M6
LF-AACM-ASB-4L-D2-H1-M7
LF-AACM-ASB-4L-D2-H1-M8
LF-AACM-ASB-4L-D2-H1-M9
LF-AACM-ASB-4L-D2-H1-DUP1 (M8)
Sample
Volume,
Liters
1884
1884
1880
1814
1902
1940
1840
1836
1737
1836
2580
2584
2519
2459
2592
2592
2592
2717
2588
2584
1089
1113
1124
1132
1084
1089
1116
1085
1080
1080
Grid
Openings
Analyzed1
48
46
46
48
45
45
47
47
50
48
34
34
34
35
34
34
34
32
34
34
79
77
77
76
79
79
77
79
80
80
Structures Counted
Chrysotile
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
Amphibole
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Asbestos (TEM)2— s/cm3
Chrysotile
0.00047
O.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00049
O.00048
0.00048
O.00048
0.00049
0.00049
O.00048
0.00048
0.00048
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
Amphibole
0.00047
O.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00049
O.00048
0.00048
O.00048
0.00049
0.00049
O.00048
0.00048
0.00048
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
Total
0.00047
O.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00049
O.00048
0.00048
O.00048
0.00049
0.00049
O.00048
0.00048
0.00048
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
PCME
0.00047
O.00049
0.00049
O.00049
0.00049
O.00048
0.00049
O.00049
0.00049
O.00048
0.00048
O.00048
0.00049
0.00049
O.00048
0.00048
0.00048
O.00049
0.00048
O.00048
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
0.00049
O.00049
Total Fibers
(PCM),
fibers/cm3
0.0010
0.0023
0.0016
0.0021
0.0032
0.0030
0.0030
0.0025
0.0017
0.0016
0.0019
0.0031
0.0019
0.0014
0.0029
0.0028
0.0014
0.0010
0.0021
0.0014
0.0076
0.0040
0.0033
0.0022
0.0053
0.0028
0.0045
0.0025
0.0028
0.0076
Grid opening size = 0.0091 mm ; effective filter area
2Less than values represent the analytical sensitivities;
= 385 mm .
detection limits are 2.99 times higher, per ISO 10312.
182
-------
Table A-6. NESHAP and AACM Buildings - Asbestos in Water.
Sample Number
NESHAP-Day 1-Source-Pre-Demo
NESHAP-Day 1 -Source-Post-Demo
AACM-Day 1-Source-Pre-Demo
AACM-Day 1 -Source-Post-Demo
AACM-Day 2-Source-Post-Demo
AACM-Day 1-Surface-AM
AACM-Day 1-Surface-PM
AACM-Day 2-Surface-PM
AACM-Day 1-Surface-Berm-Outl
AACM-Day l-Surface-Berm-Out2
AACM-Day 2-Surface-Berm-Outl
1 -Amended Water- AACM-Source
2-Amended Water- AACM-Source
AACM-Day 1-Surface-DUP 1
Aliquot Deposited
on Filter, mL1
0.5
8
0.5
2
8
0.1
0.1
0.02
0.1
0.2
0.02
500
500
0.1
Grid Openings
Analyzed2
102
47
102
10
52
7
6
103
12
4
106
104
105
9
Asbestos Structures
Counted
0
0
0
0
0
106
108
84
105
100
12
0
0
104
Asbestos Concentration,
million s/L
<0.36
<0.05
<0.36
<0.76
<0.04
2,767
3,289
745
1,599
2,284
103
<0.0004
<0.0003
2,112
Pre-Study Water from Hydrant - January 10, 2006
1-10-W-Ol
1-10-W-02
1
1
10
10
0
0
<1.91
<1.91
Aliquot deposited on filter based on observed paniculate loading in water sample.
2Grid opening size = 0.0110 mm2; effective filter area = 201 mm2.
183
-------
Table A-7. Asbestos in Settled Dust in Rings 1 and 2 of NESHAP and AACM Buildings
Sample Number
SDUST-NESH-ASB-R1 -HI -Ml
SDUST-NESH-ASB-R1 -HI -M2
SDUST-NESH-ASB-R1 -HI -M3
SDUST-NESH-ASB-R1 -HI -M4
SDUST-NESH-ASB-R1 -HI -M5
SDUST-NESH-ASB-R1 -HI -M6
SDUST-NESH-ASB-R1 -HI -M7
SDUST-NESH-ASB-R1 -HI -M8
SDUST-NESH-ASB-R1 -HI -M9
SDUST-NESH-ASB-R1 -HI -Ml 0
SDUST-NESH-ASB-R1-H1-M1 1
SDUST-NESH-ASB-R1-H1-M12
SDUST-NESH-ASB-R1 -HI -Ml 3
SDUST-NESH-ASB-R1-H1-M14
SDUST-NESH-ASB-R1 -HI -Ml 5
SDUST-NESH-ASB-R1 -HI -Ml 6
SDUST-NESH-ASB-R1 -HI -Ml 7
SDUST-NESH-ASB-R1 -HI -Ml 8
SDUST-NESH-ASB-R1-H1-DUP1 (M4)
SDUST-NESH-ASB-R1 -HI -(Ml 6)
SDUST-NESH-ASB-R2-H1 -Ml
SDUST-NESH-ASB-R2-H1 -M2
SDUST-NESH-ASB-R2-H1 -M3
SDUST-NESH-ASB-R2-H1 -M4
SDUST-NESH-ASB-R2-H1 -M5
SDUST-NESH-ASB-R2-H1 -M6
SDUST-NESH-ASB-R2-H1 -M7
SDUST-NESH-ASB-R2-H1 -M8
SDUST-NESH-ASB-R2-H1 -M9
SDUST-NESH-ASB-R2-H1 -Ml 0
SDUST-NESH-ASB-R2-H1 -Ml 1
Aliquot
Deposited
on Filter,
mL1'2
100
100
50
50
50
100
100
50
50
100
50
100
100
100
100
100
100
100
50
100
50
100
100
100
100
100
50
100
100
100
100
Grid
Openings
Analyzed3
12
12
24
22
23
13
11
22
10
12
21
11
11
11
11
12
11
12
21
13
22
12
13
12
12
13
33
14
11
12
14
Structures Counted
Chrysotile
0
0
2
0
0
5
15
30
77
2
38
23
53
31
38
7
7
1
5
5
9
1
0
0
0
0
1
o
J
6
6
0
Amphibole
0
0
0
0
0
0
6
o
J
24
0
9
o
J
12
9
13
9
2
0
0
3
1
0
0
0
0
0
0
0
2
0
0
Total
0
0
2
0
0
5
21
33
101
2
47
26
65
40
51
16
9
1
5
8
10
1
0
0
0
0
1
3
8
6
0
Total
Asbestos4,
s/cm2
<212
<212
463
<232
<221
980
4,862
8,005
46,771
424
10,882
6,020
15,050
9,262
10,825
3,396
2,084
212
1,213
1,567
2,315
212
<196
<212
<212
<196
154
546
1,852
1,273
<182
Sample
Time, min
564
559
557
555
551
549
548
546
545
543
538
535
533
530
526
524
520
520
556
523
566
564
562
562
562
560
560
559
557
557
556
Deposition Rate
s/cm2/hour
<23
<23
50
<25
<24
107
532
880
5,149
47
1,214
675
1,694
1,048
1,235
389
240
24
131
180
245
23
<21
<23
<23
<21
17
59
200
137
<20
184
-------
Table A-7. Asbestos in Settled Dust in Rings 1 and 2 of NESHAP and AACM Buildings (Continued)
Sample Number
SDUST-NESH-ASB-R2-H1 -M12
SDUST-NESH-ASB-R2-H1 -Ml 3
SDUST-NESH-ASB-R2-H1 -M14
SDUST-NESH-ASB-R2-H1 -Ml 5
SDUST-NESH-ASB-R2-H1 -Ml 6
SDUST-NESH-ASB-R2-H1 -Ml 7
SDUST-NESH-ASB-R2-H1 -Ml 8
SDUST-NESH-ASB-R2-H1-DUP1 (M2)
SDUST-NESH-ASB-R2-H1 -(Ml 5)
SDUST-AACM-ASB-R1 -HI -Ml
SDUST- AACM -ASB-R1-H1-M2
SDUST- AACM -ASB-R1-H1-M3
SDUST- AACM -ASB-R1-H1-M4
SDUST- AACM -ASB-R1-H1-M5
SDUST- AACM -ASB-R1-H1-M6
SDUST- AACM -ASB-R1-H1-M7
SDUST- AACM -ASB-R1-H1-M8
SDUST- AACM -ASB-R1-H1-M9
SDUST- AACM -ASB-R1-H1-M10
SDUST- AACM -ASB-R1-H1-M1 1
SDUST- AACM -ASB-R1-H1-M12
SDUST- AACM -ASB-R1-H1-M13
SDUST- AACM -ASB-R1-H1-M14
SDUST- AACM -ASB-R1-H1-M15
SDUST- AACM -ASB-R1-H1-M16
SDUST- AACM -ASB-R1-H1-M17
SDUST- AACM -ASB-R1-H1-M18
SDUST- AACM -ASB-R1-H1-DUP1 (M4)
SDUST- AACM -ASB-R1-H1-DUP2 (M16)
SDUST- AACM -ASB-R2-H1-M1
SDUST- AACM -ASB-R2-H1-M2
SDUST- AACM -ASB-R2-H1-M3
SDUST- AACM -ASB-R2-H1-M4
Aliquot
Deposited
on Filter,
mL1'2
100
50
100
250
250
100
100
100
250
50
50
50
1
50
50
1
50
50
50
100
50
50
50
50
100
50
50
1
50
50
50
50
50
Grid
Openings
Analyzed3
12
22
14
7
8
13
13
13
7
21
21
21
106
21
21
102
21
20
21
12
21
22
21
21
11
22
21
101
4
21
22
21
21
Structures Counted
Chrysotile
0
1
1
1
1
0
0
2
1
1
43
44
9
2
6
8
o
J
9
0
4
2
25
5
10
4
0
18
18
245
3
5
7
4
Amphibole
0
0
0
0
0
0
0
0
0
0
6
2
0
0
0
0
0
1
0
0
5
17
3
0
0
0
2
0
2
0
1
5
1
Total
0
1
1
1
1
0
0
2
1
1
49
46
9
2
6
8
3
10
0
4
7
42
8
10
4
0
20
18
247
3
6
12
5
Total
Asbestos4,
s/cm2
<212
232
182
146
127
<196
<196
392
146
243
10,852
11,158
21,625
485
1,455
19,976
728
2,547
243
849
1,698
9,302
1,941
2,426
926
<232
4,851
45,391
314,549
728
1,389
2,911
1,213
Sample
Time, min
556
555
554
554
552
551
550
564
554
1287
1283
1281
1281
1279
1279
1277
1278
1275
1275
1274
1271
1270
1269
1269
1267
1267
1265
1282
1269
1286
1281
1280
1283
Deposition Rate
s/cm2/hour
<23
25
20
16
14
21
21
42
16
11
508
523
1,012
23
68
939
34
120
<11
40
80
440
92
115
44
<11
230
2,124
14, 872
34
65
136
57
185
-------
Table A-7. Asbestos in Settled Dust in Rings 1 and 2 of NESHAP and AACM Buildings, (Continued)
Sample Number
SDUST- AACM -ASB-R2-H1-M5
SDUST- AACM -ASB-R2-H1-M6
SDUST- AACM -ASB-R2-H1-M7
SDUST- AACM -ASB-R2-H1-M8
SDUST- AACM -ASB-R2-H1-M9
SDUST- AACM -ASB-R2-H1-M10
SDUST- AACM -ASB-R2-H1-M1 1
SDUST- AACM -ASB-R2-H1-M12
SDUST- AACM -ASB-R2-H1-M13
SDUST- AACM -ASB-R2-H1-M14
SDUST- AACM -ASB-R2-H1-M15
SDUST- AACM -ASB-R2-H1-M16
SDUST- AACM -ASB-R2-H1-M17
SDUST- AACM -ASB-R2-H1-M18
SDUST- AACM -ASB-R2-H1-DUP1 (M2)
SDUST- AACM -ASB-R2-H1-DUP2 (M15)
Aliquot
Deposited
on Filter,
mL1'2
50
50
50
100
100
250
250
250
250
250
100
250
100
100
50
50
Grid
Openings
Analyzed3
22
22
21
12
12
7
7
7
5
5
20
7
13
12
22
22
Structures Counted
Chrysotile
2
2
0
0
0
0
2
o
J
22
10
5
1
1
2
2
1
Amphibole
1
0
0
0
0
0
0
0
1
0
0
0
0
0
2
0
Total
3
2
0
0
0
0
2
3
23
10
5
1
1
2
4
1
Total
Asbestos4,
s/cm2
695
463
<243
<212
<212
<146
291
437
4,686
2,038
637
146
196
424
926
232
Sample
Time, min
1283
1281
1280
1279
1278
1276
1277
1275
1273
1273
1272
1270
1268
1267
1281
1272
Deposition Rate
s/cm2/hour
33
22
<11
<10
<10
<7
14
21
221
96
30
7
9
20
43
11
All settled dust containers rinsed and brought to 500 mL.
2Aliquot deposited on filter based on observed paniculate loading in rinsate sample.
3Grid opening size = 0.0110 mm2; effective filter area = 1017 mm2.
4Area sampled = 181.5 cm2.
186
-------
Table A-8. NESHAP and AACM Buildings - Airborne Total Particulate in Ring 1
NESHAP Building
Sample Number
NESH-PART-D1-R1-H1-M1-PVC237
NESH-PART-D 1 -Rl -HI -M2-PV226
NESH-PART-D 1 -Rl -HI -M3 -PV243
NESH-PART-D1-R1-H1-M4-PV236
NESH-PART-D1-R1-H1-M5-PV227
NESH-PART-D 1 -Rl -HI -M6-PV246
NESH-PART-D 1 -Rl -HI -M7-PV240
NESH-PART-D1-R1-H1-M8-PV230
NESH-PART-D 1 -Rl -HI -M9-PV245
NESH-PART-D1-R1-H1-M10-PV23 1
NESH-PART-D1-R1-H1-M1 1-PV242
NESH-PART-D1-R1-H1-M12-PV228
NESH-PART-D1-R1-H1-M13-PV224
NESH-PART-D1-R1-H1-M14-PV241
NESH-PART-D1-R1-H1-M15-PV238
NESH-PART-D1-R1-H1-M16-PV234
NESH-PART-D1-R1-H1-M17-PV229
NESH-PART-D1-R1-H1-M18-PV232
NESH-PART-D1-R1-H1-DUP1 (M5) PV225
NESH-PART-D1-R1-H1-DUP2 (M17) PV235
Sample
Volume,
Liters
943
934
924
920
916
914
924
905
905
899
891
879
876
833
863
851
853
853
842
862
Total
Particulate
mg/m3
0.11
0.07
O.05
0.05
O.05
0.05
O.05
0.06
0.06
0.06
0.07
O.06
0.06
0.1
0.06
0.07
0.06
0.1
0.15
0.07
AACM Building
Sample Number
AACM-PART-D1-R1-H1-M1-PVC252
AACM-PART-D 1 -Rl -HI -M2-PVC264
AACM-P ART-D 1 -Rl -H 1 -M3 -P VC267
AACM-PART-D 1 -Rl -HI -M4-PVC263
AACM-P ART-D1-R1-H1-M5-PVC270
AACM-PART-D 1 -Rl -HI -M6-PVC249
AACM-PART-D 1 -Rl -HI -M7-PVC257
AACM-PART-D 1 -Rl -HI -M8-PVC265
AACM-P ART-D1-R1-H1-M9-PVC259
AACM-P ART-D1-R1-H1-M10-PVC251
AACM-P ART-D1-R1-H1-M1 1-PVC262
AACM-P ART-D1-R1-H1-M12-PVC256
AACM-P ART-D1-R1-H1-M13-PVC250
AACM-P ART-D1-R1-H1-M14-PVC253
AACM-P ART-D1-R1-H1-M15-PVC266
AACM-P ART-D1-R1-H1-M16-PVC260
AACM-P ART-D1-R1-H1-M17-PVC261
AACM-P ART-D1-R1-H1-M18-PVC247
AACM-P ART-D1-R1-H1-DUP1 (M5) PVC255
AACM-P ART-D1-R1-H1-DUP2 (M17) PVC
Sample
Volume,
Liters
2059
2034
2059
1876
2065
2082
2150
2075
2087
2070
2092
2048
2069
1933
2082
2048
2046
2082
2084
1918
Total
Particulate
mg/m3
0.15
0.14
0.14
0.04
0.15
0.10
0.14
0.096
0.067
0.048
0.072
O.02
0.068
0.062
0.067
0.03
0.083
0.067
0.12
0.073
187
-------
Table A-9. Worker breathing zone samples for airborne
of NESHAP and AACM Buildings
asbestos and total fibers during demolition
and landfill of debris.
Sample Number
NESHAP-ASB-D1-EO1
NESHAP-ASB-D1-HO1
NESHAP-ASB-D 1 -HO2
NESHAP-ASB-D1-LA1
NESHAP-ASB-D 1 -LA2
NESHAP-ASB-D 1 -TO 1
NESHAP-ASB-D 1 -TO2
NESHAP-ASB-D 1-TO3
NESHAP-ASB-D 1 -DUP 1
NESHAP-ASB-D1-WLK1
NESHAP-ASB-D 1 -WLK2
NESHAP-ASB-D 1 -WLK3
NESHAP-LF-ASB-D 1 -EDO
NESHAP-LF-ASB-D 1 -CPO
NESHAP-LF-ASB-D 1 -CPCAB
AACM-ASB-D1-EO1
AACM -ASB-D1 -HOI
AACM-ASB-D1-HO2
AACM-ASB-D1-LA1
AACM-ASB-D1-LA2
AACM-ASB-D1-TO1
AACM-ASB-D1-TO2
AACM-ASB-D1-TO3
AACM -ASB-D1-DUP1
AACM-ASB-D1-WLK1
AACM -ASB-D1-WLK2
AACM-ASB-D1-WLK3
AACM-LF-ASB-D 1 -EDO
AACM-LF-ASB-D 1 -BDCAB
AACM-LF-ASB-D 1 -CPO
AACM-LF-ASB-D 1 -CPCAB
Sample
Volume,
Liters
344
305
308
326
322
361
232
379
333
370
361
356
367
283
286
860
545
536
637
552
633
545
500
579
648
656
651
719
580
117
116
Grid
Openings
Analyzed1
25
29
28
27
27
24
37
24
26
25
24
25
24
30
30
10
16
16
14
16
14
16
18
18
14
14
14
12
15
74
74
Structures Counted
Chrysotile
0
0
1
1
0
0
0
0
1
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Amphibole
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Asbestos (TEM)2— s/cm3
Chrysotile
0.0049
0.0048
0.0049
0.0048
O.0049
0.0049
O.0049
0.0047
0.0049
0.0046
O.0049
0.0048
0.0048
0.0048
O.0049
0.0049
O.0049
O.0049
0.0047
O.0048
0.0048
O.0049
0.0047
O.0041
0.0047
O.0046
0.0046
0.0049
O.0049
0.0049
O.0049
Amphibole
0.0049
0.0048
O.0049
0.0048
O.0049
0.0049
O.0049
0.0047
O.0049
0.0046
O.0049
0.0048
O.0048
0.0048
O.0049
0.0049
O.0049
O.0049
0.0047
O.0048
0.0048
O.0049
0.0047
O.0041
0.0047
O.0046
0.0046
0.0049
O.0049
0.0049
O.0049
Total
0.0049
0.0048
0.0049
0.0048
O.0049
0.0049
O.0049
0.0047
0.0049
0.0046
O.0049
0.0048
0.0048
0.0048
O.0049
0.0049
O.0049
O.0049
0.0047
O.0048
0.0048
O.0049
0.0047
O.0041
0.0047
O.0046
0.0046
0.0049
O.0049
0.0049
O.0049
PCME
0.0049
0.0048
O.0049
0.0048
O.0049
0.0049
O.0049
0.0047
O.0049
0.0046
O.0049
0.0048
O.0048
0.0048
O.0049
0.0049
O.0049
O.0049
0.0047
O.0048
0.0048
O.0049
0.0047
O.0041
0.0047
O.0046
0.0046
0.0049
O.0049
0.0049
O.0049
Total Fibers
(PCM),
fibers/cm3
0.023
0.017
0.0089
0.012
0.036
0.042
0.056
0.086
0.059
0.027
0.0090
0.031
0.043
0.16
0.14
0.0038
0.0073
0.0051
0.013
0.016
0.0091
0.017
0.0070
0.010
0.0077
0.013
0.018
0.023
0.011
0.053
0.052
Md opening size = 0.0091 mm2; effective filter area = 385 mm2.
2Less than values represent the analytical sensitivities; detection limits are 2.99 times higher, per ISO 10312.
188
-------
Table A-10. Asbestos and total Fibers measured on workers during abatement of NESHAP Building and landfill of debris.
Sample Number
WORKER-NESHAP-ABATE-ASB-1
WORKER-NESHAP-ABATE-ASB-2
WORKER-NESHAP-ABATE-ASB-3
WORKER-NESHAP-ABATE-ASB-4
WORKER-NESHAP-ABATE-ASB-5
WORKER-NESHAP-ABATE-ASB-6
WORKER-NESHAP-ABATE-B3602-
ASB-1
WORKER-NESHAP-ABATE-B3602-
ASB-2
WORKER-NESHAP-ABATE-B3602-
ASB-3
WORKER-NESHAP-ABATE-LF-ASB-
1C
WORKER-NESHAP-ABATE-LF-ASB-
OP
WORKER-NESHAP-ABATE-LF-ASB-
OC1
WORKER-NESHAP-ABATE-LF-ASB-
OC2
HEPA-Units
Discharge
Air
NESHAP-ASB-NE
NESHAP-ASB-NW
NESHAP-ASB-SE
NESHAP-ASB-SC
Sample
Volume,
Liters
510
1110
1200
1200
60
1140
820
820
820
231
231
231
231
8778
8047
8047
8047
Grid
Openings
Analyzed1
14
10
10
10
144
10
10
10
10
37
37
Structures Counted
Chrysotile
11
0
10
5
0
19
12
8
18
0
0
Amphibole
0
0
0
0
0
0
0
0
0
0
0
Asbestos (TEM)2— s/cm3
Chrysotile
0.065
0.0038
0.035
0.018
O.0049
0.071
0.062
0.041
0.093
0.0050
O.0050
Amphibole
O.0059
0.0038
O.0035
0.0035
O.0049
0.0037
0.0052
0.0052
O.0052
0.0050
O.0050
Total
0.065
0.0038
0.035
0.018
O.0049
0.071
0.062
0.041
0.093
0.0050
O.0050
PCME
0.0059
0.0038
O.0035
0.0035
O.0049
0.0037
0.0052
0.010
O.0052
0.0050
O.0050
Total Fibers
(PCM),
fibers/cm3
0.022
0.0017
0.12
0.083
O.032
0.084
0.024
0.019
0.0095
0.013
0.018
Sample overloaded - not analyzed
Sample overloaded - not analyzed
10
10
10
10
0
0
0
0
0
0
0
0
0.00048
O.00053
0.00053
O.00053
0.00048
O.00053
0.00053
O.00053
0.00048
O.00053
0.00053
O.00053
0.00048
O.00053
0.00053
O.00053
0.028
0.00022
0.0020
0.00024
0.00081
:Grid opening size = 0.0091 mm2; effective filter area
2Less than values represent the analytical sensitivities;
= 385 mm .
detection limits are 2.99 times higher, per ISO 10312.
189
-------
Table A-11. Soil - Modified Vertical Elutriator Method.
Sample Number
NESHAP-PRE-COMP-2
NESHAP-PRE-COMP-5
NESHAP-PRE-COMP-8
NESHAP-POST-COMP-2
NESHAP-POST-COMP-5
NESHAP-POST-COMP-8
AACM-PRE-COMP-2
AACM-PRE-COMP-5
AACM-PRE-COMP-8
AACM-POST-DEMO-COMP-2
AACM-POST-DEMO-COMP-5
AACM-POST-DEMO-COMP-8
AACM-POST-EXCAV-COMP-2
AACM-POST-EXCAV-COMP-5
AACM-POST-EXCAV-COMP-8
Sample Mass
on Filter, g
1.55E-4
1.26E-4
1.05E-4
1E-4
1.20E-4
1.25E-4
1.02E-4
1.31E-4
1.09E-4
1.09E-4
1.13E-4
1.35E-4
1.06E-4
1.37E-4
2.77E-5
Grid
Openings
Analyzed
122
120
120
120
90
120
90
90
85
120
90
90
90
90
90
Structures Counted
Total
12
17
6
1
0
2
13
4
13
2
2
0
0
1
3
PCME-ISO
11
14
4
0
0
1
4
0
5
1
1
0
0
1
0
Asbestos Concentration, s/gPMlO
Total
1.69E+07
3.12E+07
1.27E+07
2.21E+06
<2.47E+06
3.55E+06
3.76E+07
9.04E+06
3.73E+07
4.06E+06
5.22E+06
<2.19E+06
<2.78E+06
2.16E+06
3.20E+07
PCME-ISO
1.55E+07
2.57E+07
8.44E+06
<2.21E+06
<2.47E+06
1.77E+06
1.16E+07
<2.26E+06
1.43E+07
2.03E+06
2.61E+06
<2.19E+06
<2.78E+06
2.16E+06
<1.07E+07
Grid opening size = 0.01449 mm ; effective filter area = 385 mm.
2Less than values represent the analytical sensitivities; detection limits are 2.99 times higher, per ISO 10312.
190
-------
Table A-12. Asbestos in Soil (PLM and TEM) by Fraction.
Sample Number
SOIL-NESHAP-PRE-COMP-1
SOIL-NESHAP-PRE-COMP-2
SOIL-NESHAP-PRE-COMP-3
SOIL-NESHAP-PRE-COMP-4
SOIL-NESHAP-PRE-COMP-5
SOIL-NESHAP-PRE-COMP-6
SOIL-NESHAP-PRE-COMP-7
SOIL-NESHAP-PRE-COMP-8
SOIL-NESHAP-PRE-COMP-9
SOIL-NESHAP-PRE-COMP- 1 0
SOIL-NESHAP-POST-COMP-1
SOIL-NESHAP-POST-COMP-2
SOIL-NESHAP-POST-COMP-3
SOIL-NESHAP-POST-COMP-4
SOIL-NESHAP-POST-COMP-5
SOIL-NESHAP-POST-COMP-6
SOIL-NESHAP-POST-COMP-7
SOIL-NESHAP-POST-COMP-8
SOIL-NESHAP-POST-COMP-9
SOIL-NESHAP-POST-COMP- 1 0
SOIL-AACM-PRE-COMP-1
SOIL-AACM-PRE-COMP-2
SOIL-AACM-PRE-COMP-3
SOIL-AACM-PRE-COMP-4
SOIL-AACM-PRE-COMP-5
SOIL-AACM-PRE-COMP-6
SOIL-AACM-PRE-COMP-7
SOIL-AACM-PRE-COMP-8
SOIL-AACM-PRE-COMP-9
SOIL-AACM-PRE- COMP-10
Fraction 01 (Soil)
%of
Sample
byWt
99.3
100
99.7
99.6
98.5
98.2
99.2
100
98.6
97.9
91.5
97.5
95.8
96.2
97.4
96.3
96.6
95.3
95.3
96.1
98.7
98.7
98.6
96.5
97.8
95.8
98.7
96.7
98.7
99.1
PLM
Point
Count,
%
Asbestos
0.1
<0.1
0.1
O.I
0.1
O.I
0.1
O.I
0.1
O.I
0.1
O.I
0.1
O.I
O.I
0.1
0.34
0.1
O.I
0.1
O.I
0.1
O.I
0.1
O.I
O.I
0.1
O.I
0.11
0.33
TEM (Asbestos)
Sample
mass on
Filter, g
7.8E-4
5.0E-5
1.7E-4
2.1E-4
1.2E-4
2.2E-4
3.0E-4
2.2E-4
2.2E-4
5.6E-5
1.9E-4
8.1E-4
2.6E-4
2.2E-4
3.0E-4
4.3E-4
1.3E-4
2.3E-4
1.9E-4
1.5E-4
2.7E-4
2.7E-4
3.8E-4
1.6E-4
4.5E-4
1.7E-4
1.1E-4
1.6E-4
2.3E-4
1.1E-4
Grid
Openings
Analyzed1
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Str/gm
<2.15E+07
6.59E+07
<9.62E+06
<7.87E+06
3.29E+08
2.54E+07
5.73E+06
<7.59E+06
7.75E+06
5.84E+07
8.96E+06
1.56E+08
<6.57E+06
<7.97E+06
5.79E+06
4.06E+06
1.60E+09
1.52E+07
9.17E+06
2.37E+07
<7.03E+06
1.90E+07
<4.64E+06
1.09E+07
<3.94E+06
1.02E+07
<1.62E+07
4.25E+07
1.51E+07
1.15E+10
Structure
Count
0
2
0
0
22
o
6
i
0
i
2
1
71
0
0
1
1
119
2
1
2
0
3
0
1
0
1
0
4
2
136
Fraction 02 (Rocks
and Organics)
%of
Sample
byWt
0.72
0
0.35
0.44
1.47
1.81
0.82
0
1.35
2.12
8.14
2.35
4.06
3.68
2.01
3.45
3.28
4.48
4.35
3.48
1.3
1.34
1.44
3.45
2.23
4.04
1.28
3.26
1.24
0.83
PLM
Visual
Estimate,
%
asbestos
<1
-
<1
<1
<1
<1
<1
-
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
Fraction 03 (Building
Debris)
%of
Sample
byWt
0
0
0
0
0
0.01
0
0
0.09
0.02
0.33
0.2
0.12
0.14
0.57
0.26
0.11
0.25
0.38
0.39
0.04
0.01
0.01
0.02
0
0.12
0.06
0
0.04
0.11
PLM
Visual
Estimate,
%
asbestos
-
-
-
-
-
8.33
-
-
3.5
<1
3.6
0.93
4.7
0.54
5.03
1.52
4.01
0.16
2.2
2.2
<1
0.62
<1
<1
-
<1
<1
-
<1
<1
191
-------
Table A-12. Asbestos in Soil (PLM and TEM) by Fraction. (Continued)
Sample Number
SOIL-AACM-POST-COMP- 1
SOIL-AACM-POST-COMP-2
SOIL-AACM-POST-COMP-3
SOIL-AACM-POST-COMP-4
SOIL-AACM-POST-COMP-5
SOIL-AACM-POST-COMP-6
SOIL-AACM-POST-COMP-7
SOIL-AACM-POST-COMP-8
SOIL-AACM-POST-COMP-9
SOIL-AACM-POST- COMP -10
SOIL-AACM- POST - EXCAV -1
SOIL-AACM- POST - EXCAV -2
SOIL-AACM- POST - EXCAV -3
SOIL-AACM- POST - EXCAV -4
SOIL-AACM- POST - EXCAV -5
SOIL-AACM- POST - EXCAV -6
SOIL-AACM- POST- EXCAV -7
SOIL-AACM- POST - EXCAV -8
SOIL-AACM- POST - EXCAV -9
SOIL-AACM- POST - EXCAV -10
Fraction 01 (Soil)
%of
Sample
byWt
90.9
85.3
93.0
90.1
92.0
95.0
96.1
96.4
96.2
94.3
94.5
92.6
94.9
96.2
95.2
93.8
93.7
95.3
95.9
93.4
PLM
Point
Count,
%
Asbestos
<0.1
0.33
<0.1
0.1
O.I
0.1
O.I
0.1
O.I
0.1
0.1
O.I
0.1
O.I
0.1
O.I
0.1
O.I
O.I
0.1
TEM (Asbestos)
Sample
mass on
Filter, g
6.8E-5
2.4E-4
1.3E-4
2.0E-4
1.8E-4
2.2E-4
2.3E-4
2.5E-4
2.2E-4
1.7E-4
1.9E-4
2.0E-4
1.6E-4
2.2E-4
1.3E-4
2.4E-4
4.4E-4
3.0E-4
2.2E-4
1.4E-4
Grid
Openings
Analyzed1
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Str/gm
<5.48E+06
4.34E+07
1.76E+08
2.11E+08
9.67E+06
<7.89E+06
2.97E+07
2.68E+07
<8.23E+06
1.02E+07
8.07E+06
<1.02E+07
<1.13E+07
7.99E+06
1.51E+08
<7.31E+06
<3.98E+06
<5.99E+06
<8.01E+06
<1.32E+07
Structure
Count
0
6
13
24
1
0
4
4
0
1
1
0
0
1
11
0
0
0
0
0
Fraction 02 (Rocks
and Organics)
%of
Sample
byWt
7.96
13.5
5.67
8.92
7.16
4.75
3.41
2.69
1.91
4.99
4.53
6.91
4.78
3.67
4.52
5.05
3.97
4.42
3.59
6.36
PLM
Visual
Estimate,
%
asbestos
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
Fraction 03 (Building
Debris)
%of
Sample
byWt
1.12
1.18
1.3
0.01
0.82
0.22
0.51
0.9
1.91
0.7
0.97
0.46
0.36
0.18
0.3
1.14
2.33
0.3
0.49
0.28
PLM
Visual
Estimate,
%
asbestos
2.13
2.46
0.36
0.04
1.19
<1
0.06
0.27
0.22
1.98
0.23
0.11
<1
<1
0.6
0.03
<1
0.42
0.24
0.44
Grid opening size = 0.01007 mm ; effective filter area = 193 mm
192
-------
Table A-13. Weight of Vinyl Asbestos Tile Fragments and other ACM in Soil Samples.
Sample
Composite
Number
Wt of original
sample, g
Wtof
VAT,g
Wtof other
ACM, g
VAT, wt
%
Non-VAT
ACM , wt %
NESHAP PRE-DEMOLITION
1
2
3
4
5
6
7
8
9
10
10946.3
10491.9
10854.8
10582.7
10582.5
11126.5
10945.5
11580.5
10719.1
11552.9
0
0
0
0
0
0
0
0
3.45
0
0
0
0
0
0
0.5
0
0
0
0
0
0
0
0
0
0
0
0
0.03
0
0
0
0
0
0
0.0005
0
0
0
0
NESHAP POST-DEMOLITION
1
2
o
6
4
5
6
7
8
9
10
11021.2
9870.9
10053.7
11144.2
9483.5
8381.3
9464.9
11047.1
10730.3
9764.9
17.0
4.16
6.35
1.26
5.93
4.28
5.39
1.97
9.79
12.1
0
0
0
0
3.56
4.22
0
0
0
0
0.15
0.04
0.06
0.01
0.06
0.05
0.06
0.02
0.09
0.12
0
0
0
0
0.04
0.05
0
0
0
0
AACM PRE-DEMOLITION
1
2
3
4
5
6
7
8
9
10
10452.3
9156.5
9679.1
10381.3
10584.7
10211.1
9592.7
10285.1
10082.3
10278.9
0
0
0
0
0
0
0
0
0
0
0
0.02
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0.0002
0
0
0
0
0
0
0
0
AACM POST-DEMOLITION
1
2
o
3
4
5
6
7
8
9
10
14473.2
14333.6
13895.2
13609
14511
9868.9
13816.8
12954.2
12556.6
12008.2
17.7
36.7
8.46
0.71
19.3
0
0.6
3.1
5.8
16.4
3.25
0
0
0
0
0
0
0
0
0
0.12
0.26
0.06
0.01
0.13
0
0.004
0.02
0.05
0.14
0.02
0
0
0
0
0
0
0
0
0
193
-------
Table A-13. Weight of Vinyl Asbestos Tile Fragments and other ACM in Soil Samples.
(Continued)
Sample
Composite
Number
Wt of original
sample, g
Wtof
VAT,g
Wtof other
ACM, g
VAT, wt
%
Non-VAT
ACM , wt %
AACM POST-EXCAVATION
1
2
3
4
5
6
7
8
9
10
13398.4
12255.2
13163.8
12979.2
13201.8
8691.8
9558.6
12265.8
12086.6
13163.6
3.98
0.78
0
0
2.35
0.76
0
1.41
2.23
2.16
0.03
0.01
0
0
0.02
0.01
0
0.01
0.02
0.02
0
0
0
0
0
0
0
0
0
0
194
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APPENDIX B - KIDDE MSDS
195
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DATA SHEET
8NFC970
NF-3000
Foam & Wetting Agent
Concentrate
Ł>escr/pt/on
Environmentally respons ble NF-30DQ Wetting Agent con-
cenfate. is a un que new •ormulation providing unmatched
wetting performance, foamability and flexibility. NF-3000
s specially desgnec '"or use :n industrial and remedial
wetting applications. N--33CD can be aseo through con-
ventional fca-ri -rak ng devices Class A3 ba- systems
and is excellent for Compressed Air Foam Systems
(CAPS). This environmentally responsible formulation
does not contain reportable components under SARA
Title ML Section 313 of 40 CFR-372, or CERCLA.
NF-3QOO improves trie penetrating capability of water. It
•ecjces the surace tenser of wate'. ivnich 5 lews it to
perpetrate surfaces where water might normally run off.
Foamirg and welting ingredients give water the abi ity to
adhere to vertical surfaces tiat allows longer contact with
the material to be penetrated. The longer the water is in
contact with an absc'bent material, the more water is ab-
sorbed.
Features
• Environmentally responsible formulation.
• Excellent Wetting and Foaming for dust control and
contain Tent.
• Excellent for wetting materials which may contain haz-
ardous dusts and particles such as abestos.
* Premix is stable lor more than 3D days (using potable
water), which Is significantly longer than traditional
Class A foam solutions.
• Contains NO alcohols for higher flash point and
oornrjatib ity with Class A'B Systems.
• Can be used with fresh, brackish and sea water.
1 Exhibts gocc fcamabil ty, even n cold water.
• Can Be used as a Class A firefighting foam concen-
trate.
Typical Physical Properties
Appearance Pale yellow liquid
Specific Sravily @ 77°F (25°C) „ _..1.D5
pH e.o
Minimum Usable Conce-ntrate Temp 2D°F(-7SC)
Maximum Usable ConcentrateTemp 12D°F(49=C)
Freezing Point 6°F(-14=C)
Viscosity @ 7C"F (21*C) 20 csks
Viscosity @ 2Q°F |-75C) 22 csks
Surface Tension at D.1% Cone 25.7 Dynes/cm
Surface Tens or atC.5?fc Core 2**-. 1 Dynes.'c^i
Rash Point: Pensky Martens
C DSSC CLO Vetnoc >2u5=F
Freez&'Thaw: No Effects on Concentrate Properties
Typical Proportioning Settings
Wetting 0.3%-1.0%
Foaming. Aspirated 0.7%-1.0%
Compressed Air Application 0.1% - 0.5%
Standards & Approvals
• NFPA1B
Compatibility
It is recommended that NF-3000 not be mixed with any
other type of foam concentrate n long-te'm storage. SLOT:
mixing could lead ta cnemica changes ir the product and
a possible reduction in or loss of its capability.
Storage and Handling
The recorrvnendeo storage temperature range for NF-30CO
•concentrate ;s2D0F|>7'C; IE 12rj°Fi49=Cj. NF-30DO foam
concentrate is not affected by freeze/thaiv eye es. and t
nas unque prem.x stabi ity prop-erties. Sarrpes of KF-
30.CO, premixed witri potabee municipal water sucp!ss, have
been shewn to be stable and not suffer any significant toss
of expansion or dra inage properties after 30 days. Actua
results may vary based en the water supply.
KF-330D shojld be stored ir its original shipping corta ner
or in tanks or other containers that have been designed
www.Kidde-Fire.com
Fire Fighting
196
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for such foam storage. Recommended construction ma-
terials are stainless steei (Type 304Lor 316). high-density
cross-linked polyethylene, or reinforced fiberglass polyes-
ter (isophthalic polyester resi n) with a vinyl ester resin in-
ternal layer coaling (Ł0 -1 CO mite).
Foam concentrates are subject to evaporation which ac-
celerates wnen the product is exposed to ai r. Storage tanks
should be sealed and fitted with a pressure vacuum vent
to prevent free exchange of sir
Shelf Life, Inspection, and Testing
The shelf life of any foam concentrate is maximized by
proper storage conditions and maintenance. Factors af-
fecting shelf life .are wide temperature changes, extreme
high or low temperatures, evaporation, dilution, and con-
tamination by foreign materials. Th« expected shelf life
of NF-3DCO foam concentrate is 2D years or more, if stored
property, according to the manufacturers recommenda-
tions. Should the concentrate becomecontaminated, test-
ing to ensure original foam concentrate physical proper-
lies is a servce available from National Foam. Annual
testing of foam concentrates is recommended to ensure
reliability.
Environmental and Toxicologies! Information
NF-3COD is biodegradable. However, as with any sub-
stance, care shou'd be taken to prevent discharge from
entering ground water, surface water, or storm drains. With
advance notice, NF-3COO foam concentrate or foam solu-
tion can be treated by "local biological sewage treatment
systems. Since facilities vary widely by location, advance
notice shay-id be given, and disposal should be made in
accordance with federal, state, and local regulations.
The bcilogical oxygen demand (BOO) and chemical oxy-
gen demand (COO) of NF-30DO are as follows:
COD
Concentrate
380,030 mg.'kg
782,000 mg.'kg
0.5% Sol.
3.9CO mgfKg
4,220 moykg
7,930 mg/kg
Tests for acute oral toxicity have proved negative. NF-
3000 concentrate is a primary skin irritant. Repeated skin
contact will remove o;:ls 'rorri the skin and cause dryness.
K F-3QOO is classified as a primary eye irrrtant, and contact
with the eyes should be avoided. Users are advised to
wear protective eyewear. If the foam concentrate enters
the eyes, flush them well with water and sect immediate
medical attention. For further details seethe NF-3COO Ma-
terial Safety Data Sheet.
This product does NOT contain reportable
components under SARA Title III, Section 313 of 40
CFR-372 or CERCLA
Ordering Information
Capacity Description
E-Galion Pails (Round)
(19 iitres;
65-Gallon Drums
(2C8 litres)
275-Gallon IBC Reusable Tote Tank
(1C41 litres;
Per Gallon Bulk Delivery
Part Number
2170-9340-6
2170-S4B1-6
2170-8725-6
2170-9001-6
Shipping Weight
ibs. (kg)
4S (20.8)
603 (22B.D)
2E4S (.1159-0)
8.75 (4.0)
Approximate Shipping
Cube Ft 5 (m5)
1.13 (0.029)
11.10 < 0.328)
48.20 «; 1.081)
Trfc irrfsrrraJm IE arty 3 gereral gUtfe'lie "tie csrrpauy rese-vss ine ncfrt te ctiange any portion or tMs Mt&nraKon wttiou: ncttce. Terms ard
condlttsrs of sae ifpif ard are an'al'aBte on reqijed.
NATIONAL FOAM, INC.
P.O. Box 695 • Exton, PA 19341-0695 • (610) 363-1400 • Fax: (610) 524-9073
www.Kidde-Fire.com
197
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ID.
mnamalFotm
MATERIAL SAFETY DATA SHEET #NMS970
NF-3000
Synthetic Foam
Section 1. CHEMICAL PRODUCT/COMPANY IDENTIFICATION
Material Identification
Product; NF-3CKX}
Synonyms: Synthetic Detergent. Wetting Agent
CAS No: Mixture - No single CAS * applicable
Company Identification
Manufacturer:
National Foam, Inc.
150 Gordon Drive
P.O. Bos 695
Extoii. PA 19341-0695
Emergency Phone Number (Red Alert): (610) 363-1400 (U.S.A.)
Fax (610)524-9073
http: v.-.^.v .kidde-fire. com- nf.. 3b:nil
Secrion 2. COMPOSITION / INFORMAHON ON INGREDIENTS
Components CAS Number
Water 7732-1S-5
Proprietary mixture of svoietic detergent? No single CAS 3* applicable
1, 2 Propanediol 57-55-6
(2-Me±oxynie±yle±oxy) Propanol 34590-94-8
Proprietary mixture of corrosion inhibitors No quisle CAS f applicable
Page 1 of 8
198
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Section 3. HAZARDS IDENTIFICATION
Potential Health Effects
Inhalation
Vapor? are minimal at room temperature- If product is heated or sprayed as an aerosol, airborne
material may cause respiratory irritation.
Skin Contact
Contact with liquid may cause moderate irritation or dermatitis due to removal of oils from the
skin.
Eye Contact
Product is an eye irritant.
Ingestion
Not a hazard in normal industrial use. Small amounts swallowed dining normal handling
operations are not likely to cause injury; swallowing large amounts may cause injury or
irritation.
Additional Health Effects
Existing eye or skin sensitivity may be aggravated by exposure.
Carcmogenkity Information
No data available.
Section 4. FIRST AID MEASURES
Inhalation
No specific treatment is necessary since this material is not likely to be hazardous by inhalation.
If exposed to excessive levels of airborne aerosol mists, remove to fresh air. Seek medical
attention if effects occur.
Skin Contact
In case of skin contact, wash off in flowing water or shower. Launder clothing before reuse.
Eye Contact
In case of eye coeraer: flush eyes promptly with water for 15 minutes. Retract eyelids often to
ensure thorough rinsing. Consult a physician if irritation persists.
Ingestion
Swallowing less than an ounce is not expected to cause significant harm. For larger amounts, do
not induce vomiting. Give milk or water. Never give anything by mouth to an unconscious
person. Seek medical attention.
Page 2 of 8 04'10'M
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Section 5. FIRE FIGHTING MEASURES
Flammable Properties
Flash Point -Not applicable
Fire and Esplosion Hazards
Avoid contact with water reactive material;, burning metals and electrically energized
equipment.
Extinguishing Media
Product K an extingiushing media. Use media appropriate for surrounding materials.
Special Fire Fighting Instructions
This product will produce foam when mixed with water.
Section 6. ACCIDENTAL RELEASE MEASURES
Safeguards (Personnel)
NOTE: Review FIRE FIGHTING MEASURES and HANDLING (Personnel) sections before
proceeding with clean-up. Use appropriate Personal Protective Equipment during clean-up.
Accidental Release Measures
Concentrate
Stop flow if possible. Use appropriate protective equipment during clean up. For small volume
release?, collect spilled concentrate with absorbent material; place in approved container. For
large volume releases, contain and collect for use where possible. Flush area with water until it
no longer foams. Exercise caution surfaces may be shppery. Prevent discharge of concentrate to
waterways. Disposal should be made in accordance with federal state and local regulations.
FoaHL'Toam Solution
See above. Flush with water. Prevent discharge of foam/foam solution to waterways. Do not
discharge into biological sewer treatment systems without prior approval. Disposal should be
made in accordance with federal, state and local regulations.
Section 7, HANDLING AND STORAGE
Handling (Personnel)
Avoid contact with eyes, skin or clothing. Avoid ingestton or inhalation. Rinse skin and eyes
thoroughly in case of contact. Review HAZARDS and FIRSI AID sections.
Storage
Recommended storage environment is between 20CF (-7°C) and 120:'F (49°C). Store product ID
original shipping container or tanks designed for product storage.
YMS=»70 Page 3 of 8 04/IO'M
200
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Section 8. EXPOSURE CONTROLS/PERSONAL PROTECTION
Engineering Controls
Special ventilation is not required.
Personal Protective Equipmf nt
Respiratory
Recommended exposure limits (OSHA-PEL and ACGIH-TLV) have not been determined for
this material. A qualified health specialist should evaluate the need for respiratory protection.
Protective Clothing
Rubber or PVC gloves recommended.
Eye Protection
Safety glasses, face shield or chemical splash goggles must be worn when possibility exists for
eye contact. Contact lenses should not be worn. Eye wash facilities .are recommended.
Other Hygienic Practices
Use good personal hygiene practices. Wash hands before eating, drinking, smoking, or using
toilet facilities. Promptly remove soiled clothing and wash thoroughly before re-use.
Erposure Guidelines
Exposure Limits
(2-Methoxymethylethoxy) Propanol (34590-94-8)
PEL (OSHA)
100 ppm. 8 hr. TWA Skin
150 ppm. 15 min. STEL Skin
TLV (ACGffl)
100 ppm. 8 hr. TWA Skin
150 ppm. 15 min. STEL Skin
Section 9. PHYSICAL AND CHEMICAL PROPERTIES
Physical Data
Boiling Point: Not applicable
Vapor Pressure: Not applicable
Vapor Density: Not applicable
Melting Point: Not applicable
Evaporation Race: ''1 (Butyl Acetate = 1.0)
NMS*»70 Page 4 of S (U/NMW
201
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Solubility in Water:
pH:
Specific Gravity:
Odor:
Form:
Color:
10G%
8.0
1.05 lit 25°C
Bland
Liqiud
Pale Yellow-
Section 10, STABILITY AM) REACTIVITY
Chemical Stability
Stable.
Incompatibility. Material? to Avoid
Avoid use of product on burning metals, electrically-energized equipment and contact
with water reactive material;.
Polymerization
Will not occur.
Section 11. TOXICOLOGICAL INFORMATION
Mammalian Toxicitv
Acute Oral Toxicity - Sprasue-Dawley Rats
Acute Dermal Toxicity — New Zesiaad
Witte Rabbits
Primary Deimal Irritation — N'ew Zealand
Wilts Rabbits
Primary Eye Irritation — Unwashed Eyas
New Zealand White Rabbit;
Primary Eye limitation — Washed Eyas
New Zealand White Rabbits
Concentrate
LD« :-- 5000 mgAg
LDsc > 2000 mgig
Slightly iiitattug
(Toxicitj' Categoiy TV)
Moderately Lritatmg
{Toxicity C atsgon- 1)
Mildly Irritating
(To«icity Cateaoiy IE)
1% Solution
LD«n > 5000 jcg'lcg
LD«n '•-•• 2000 iog.'ltH
Nos-Initaang (Toxicsty
Categon'IXO
MimmaLly Iniiatinf
(Toxicitj- Categor>' TV)
Practically N'on- Initating
(Toxicity Category TV)
Section 12. ECOLOGICAL INFORMATION
Ecotoxicological Information Aquatic Toxicity
96 hr. LCjj for Rainbow Trout (oBcorliwclius mykis;) is reported to be 28 mg.'liter.
Page 5 of 8
ca.'l6/fl«
202
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Environmental Fate
BODs
COD
Concentrate
389.000 nig,tg
782:000mg,''kg
0.5% Solution
2.140mg;kg
3.900 me/kg
1.0% Solution
4.220 mg.'lg
7.960rag^g
This product meet? the cntena for Readily Biodegradable when tested in accordance to EPA
QPPTS 835-3110. Section 0. Ready Biodegradability (greater than 60% biodegradation in 28
days).
Section 13. DISPOSAL CONSIDERATIONS
NF-SOOO. as sold, is not a RCRA-listed waste or hazardous waste as characterized by 40 CFR
261. However. Stare and local requirements for waste disposal may be more restrictive or
otherwise different from Federal regulations. Therefore, applicable local and scate regulatory
agencies should be contacted regarding disposal of waste foam concentrate or foam/foam
solution.
Concentrate
Do not discharge into biological sewer treatment systems without prior approval. Specific
concerns are high BOD load and foaming tendency. Low dosage flow rate or antifoaming agents
acceptable to the treatment plant may be helpful. Do noc flush to waterways. Disposal should be
made in accordance with federal, state and local regulations.
Foam/Foam Solution
NF-3000 solution can be treated by wastewater treatment facilities. Discharge into biological
sewer treatment facilities may be done with prior approval Specific concerns are high BOD
load. Dilution will reduce BOD and COD factors proportionately. Low dosage flow rate or
antifoaming agents acceptable to the treatment plant may be helpful. Do not flush ro waterways.
Disposal should be made in accordance with federal state and local regulations.
NOTE: As a service to our customers. National Foarn has approvals in place with disposal
facilities throughout the U.S. for waste water treatment and solidification and landfill of our
foam liquid concentrates and foam solutions. If required. National Foam. Inc. can also provide
information on the disposal of drums used for shipping our concentrates. Please contact National
Foam's Pask Management Administrator at (610) 363-1400 for additional information.
Section 14, TRANSPORTATION INFORMATION
Shipping Information
Proper Shipping Name: Fire Extinguisher Charges or Compounds N.O.L. Class 60
National Motor Freight Code: 69160 Sub 0
Hazard Class: None
UN Number: None
Page 6 of 8
(U/10'W
203
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Section 15. REGULATORY INFORMATION
U.S. Federal Regelations
Toxic Substances Control Act (TSCA)
All components of this product are listed in the TSCA inventor,'.
Superfimd Amendments and Reanthorization Act of 1986 (SARA). Title III
Section 502/304
There are no components of diis material with known CAS numbers which are on the
Extremely Hazardous Sub-stances (EHS) list.
Section 311& 312
Based on available iuformaaon. this matenal contains the following components which
are classified as the following health and/or physical hazards according to Section 311 &
312:
(2-Methoxyrnethylethoxy) Propanoi 34590-94-8 (Flammability)
Section 313
This material does nor contain any chemical components subject to Section 313 reporting
requirements.
COMPREHENSIVE ENVIRONMENTAL RESPONSE. COMPENSATION, AND
LIABILITY ACT (CERCLA)
This matenal does not contain any components subiect to the reporting requirements of
CERCLA.
OTHER REGULATORY INFORMATION
None.
STATE REGULATIONS
PENNSYLVANIA RIGHT-TO-KNOW HAZARDOUS SUBSTANCES LIST
PA Hazardous Substances present at levels greater than 1%:
L 2 Prapanediol 57-55-0
(2-Methoxymethylethoxy) Propanoi 34590-94-8
Section 16. OTHER INFORMATION
NFPA Rating WHMIS Rating
Health 0 D2B
Flamniability 0
Reactivity 0
Pa-ge?of8
204
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ADDITIONAL IXFORMATIQN
Revision Summary
3/13.-06 New Issue
The information contained herein is furnished without warranty either expressed or
impied. This data sheet is not ,1 part of any contract of sale. The information contained
herein is believed to be correct or is obtained from sources believed to be generally reliable.
However, it is the responsibility of the user of these materials to investigate, understand
and comply with federal, state and local guidelines and procedures for safe handling and
use of these materials. National Foam. Inc. shall not be liable for any loss or damage arising
directly or indirectly from the use of this product and National Foam. Inc. assumes no
obligation or liabilities for reliance on the information contained herein or omissions
herefrom.
MIS«M>70 PageS of 8
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