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Asbestos-Contaminated Soil Regulations in Colorado. Colleen Brisnehan Colorado Department of Public Health And Environment Hazardous Materials and Waste Management Division. Asbestos-contaminated soil

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Asbestos contaminated soil regulations in colorado l.jpg
Asbestos-Contaminated Soil Regulations in Colorado

Colleen Brisnehan

Colorado Department of Public Health And Environment

Hazardous Materials and Waste Management Division


Background l.jpg

Asbestos-contaminated soil

Asbestos-contaminated soil has been identified at several sites in Colorado; it is also an emerging national issue

Potential exposure risks when disturbed

Proper management necessary to prevent exposure

Background


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Background

  • Management previously conducted under:

    • Colorado Solid Waste Act and Regulations

    • Colorado Hazardous Waste Act

    • Air Quality Control Commission Regulation No. 8

  • These regulations lacked specific requirements for management of asbestos-contaminated soil

  • Needed clear regulations that codified the risk-management approach already applied at sites in Colorado


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New Regulations

  • Amendment to the Colorado Solid Waste Regulations (6 CCR 1007-2, Part 1):

    • Section 1.2 - Definitions

    • Section 5.5 - Asbestos-Contaminated Soil

  • Adopted February 15, 2006

  • Became Effective April 30, 2006


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Overview of Asbestos Exposure and Risk Issues

  • Asbestos is a generic term used to describe the fibrous varieties of six minerals which fall into two categories: serpentine and amphibole.

  • Asbestos is known to be persistent in the environment.

  • All types of asbestos are a known human carcinogen and can cause nonmalignant lung and pleural diseases.

  • The 1% threshold for asbestos in soil/debris may not be protective of human health and should not be used as the default action level (EPA, 2004).

  • Soil/debris containing significantly <1% of all types of asbestos can pose unreasonable risk to human health (EPA, 2004).

  • Asbestos fibers in soil/debris do not inherently pose a risk to human health if left undisturbed.


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Overview of Asbestos Exposure and Risk Issues (cont.)

  • Health risks from asbestos-contaminated soil/debris will depend on the potential for asbestos to become airborne and be inhaled.

    • EPA IRIS cancer risk-based acceptable (“safe”) level of asbestos in air = 0.000004 f/cc at a risk level of 1 in a million.

    • The concentration of asbestos in soil corresponding 0.000004 f/cc in air is not known at this time.

  • Asbestos health risk assessment is an evolving science and EPA is developing a risk assessment toolbox.

  • Current risk assessment methods can be used to:

    • Demonstrate complete exposure pathway(s); and

    • Estimate risk qualitatively/semiquantitatively


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Exposure Evaluation

  • Several studies using a variety of approaches to evaluate the release of asbestos fibers from significantly <1% asbestos in soil/debris demonstrated:

    • All types of asbestos fibers can be released into the air or breathing zone during soil disturbing activities resulting in unacceptable risk:

      • Significantly above acceptable cancer risk level of

        1 in a million at 0.000004 f/cc (EPA IRIS)

      • Even above the OSHA limit of 0.1 f/cc, in some cases

Irrespective of fiber type or soil type, as low as 0.001 % asbestos in soil can generate airborne respirable asbestos concentration of >0.1 f/cc (Addison et al., 1988)


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Exposure: Activity-Based Personal Monitoring

  • Libby studies (EPA, 2001 Weis Memo):

    • Rototilling of garden soil (<1% asbestos)

      • 0.066 f/cc in personal monitor (Cancer risk = 1 in 100,000)

      • 0.019 f/cc in stationary monitor

    • Soil bagging and sweeping floors (<1% to 6% asbestos)

      • >5.0 f/cc (above OSHA limit of 0.1 f/cc)

  • Oregon studies (EPA, 2004 Januch and McDermott):

    • Leaf blowing (soil <1% asbestos)

      • 0.045 f/cc for equipment operator

      • 0.033 f/cc for observer


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Exposure: Modified Elutriator MethodBerman and Kolk (2000)

  • Initial Health Risk Assessment at the Former Lowry Air Force Base, Colorado (Parsons, 2004):

    <1% chrysotile in surface soil resulted in excess potential cancer risks, for example:

    • Running and walking by residents = 1 or 4 in 100,000

    • Construction worker = 2 in 10,000

Overall potential risks are underestimated due to major limitations of dust models used to predict airborne asbestos exposures


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Assessment Of Health Risks For Asbestos-Contaminated Soil/Debris

  • Potential Exposure Pathways:

    • Outdoor activities routinely performed by residents (child and adult), for example:

      • Gardening; rototilling; weeding; bagging and sweeping of excavated soils; children playing with soil/debris;

    • Transport from outdoor to indoor:

      • Wind through open doors and windows

      • Track-in of adhered fibers on clothing and shoes of children and adults, and through pet animals

      • Children physically carrying asbestos-contaminated soil/debris

Outdoor and indoor asbestos sources act as a reservoir of fibers that could continue to be released to the air as a result of routine activities


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Current Issues In Risk Assessment of Asbestos-Contaminated Soil/Debris

Examples of Major Issues/Limitations:

  • Improved methods are being developed for asbestos analyses and to determine asbestos release

  • Potential future indoor exposures as a result of outdoor-to-indoor transport are difficult to quantify

  • Exposure assessment provides a snap-shot in time

  • Cancer and noncancer toxicity is being re-evaluated

  • Better definition of asbestos fiber to relate to its toxic potential is needed

Current methods for estimating asbestos exposure dose allow qualitative/semiquantitative screening risk assessment


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New Regulations - Our Goal Soil/Debris

  • Take a pragmatic approach to regulation of asbestos-contaminated soil

    • Management of disturbed soils; not remediation

    • Triggers:

      • visible asbestos

      • reason to know asbestos is present in soil

    • Key Sections: Applicability/Exemptions

  • Put new asbestos-contaminated soil regulations into Solid Waste Regulations

    • HMWMD versus APCD (soil contamination; not abatement)

    • SW versus HW (asbestos is not a listed or characteristic hazardous waste)


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Changes to Solid Waste Regulations Soil/Debris

  • Updates to existing language:

    • Section 1.2 – Definitions

    • Part 5 (Sections 5.1 though 5.4) – Asbestos Waste Disposal Sites

  • New Section 5.5 for asbestos-contaminated soil


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Requires proper management - Soil/DebrisONLY when asbestos-contaminated soil is disturbed

No requirement to ‘chase’ or remediate asbestos contamination

Clarifies requirements for:

Identification

Onsite management

Disposition

Section 5.5 Asbestos-Contaminated Soil


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Applicability Soil/Debris

Owners or Operators of sites:

With asbestos-contaminated soil based on:

  • visible observation

  • past sampling, or

  • knowledge/data of historical activities

    And, with current or planned soil-disturbing activities

    Removal of Asbestos-Containing Material

  • On a facility component

    And, on or in soil that will be disturbed

    And, below AQCC Regulation No. 8 trigger levels

  • Pieces that are not on a facility component

    And, on or in soil that will be disturbed


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    Exemptions Soil/Debris

    Does Not Apply to:

    • Removal of solely non-friable asbestos from soil

    • Abatement of facility components under AQCC Regulation No. 8

    • Spill response under AQCC Regulation No. 8

    • Naturally occurring asbestos

    • “Background” not associated with site activities

    • De Minimis Projects

      • Less than 1 cubic yard

      • And, using low-emission excavation methods

    • Projects by home owner on primary residence


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    Key Definitions Soil/Debris

    Asbestos-Contaminated Soil

    Soil containing any amount of asbestos.

    Soil-Disturbing Activities

    Excavation, grading, tilling, or any other mechanical activity.

    Facility Component

    Any part of a “facility” including equipment.

    “Facility” - as defined in AQCC Regulation No. 8


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    Unplanned Asbestos Discovery Soil/Debris

    • Immediate actions

      • Stop soil-disturbing activities

      • Control site access

      • Stabilize surface soil

    • 24-hour notification

      • Property and project information

    • Interim Actions

      • Take appropriate measures to control emissions

      • Submit a Soil Characterization and Management Plan,

        or implement approved standard procedures


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    Planned Asbestos Management Soil/Debris

    • Ten working day notification

      • Property and project information

    • Soil Characterization and Management Plan

      • Site Information

      • Any proposed characterization

      • The proposed soil-disturbing activities

      • Proposed exposure mitigation and asbestos fiber control measures

        • Site access control

        • Air monitoring plan

        • Emissions control plan

        • Exposure mitigation plan for asbestos left in place

        • Disposal plan


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    Remediation Soil/Debris

    If property owner chooses to remediate:

    • Submit an asbestos remediation plan that complies with Section 5.5 and includes:

      • Soil Characterization and Management Plan

      • Detailed description of planned remediation

      • Proposed use of the property and area of remediation

      • Any planned engineering controls to prevent exposure to any asbestos left in place


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    Training and Certification Soil/Debris

    • On-the-job asbestos-contaminated soil awareness training

      • Individuals conducting soil-disturbing activities

    • Asbestos awareness training, in accordance with OSHA requirements

      • Individuals conducting soil-disturbing activities in areas with asbestos

    • Training conducted by:

      • Asbestos Supervisor, Building Inspector or Project Designer certified in accordance with AQCC Regulation No. 8

      • With 6 months of asbestos-contaminated soil experience


    Training and certification cont l.jpg
    Training and Certification Soil/Debris (cont.)

    • Inspection and identification of asbestos

      • Asbestos Building Inspector certified in accordance with AQCC Regulation No. 8

      • And, with 6 months of asbestos-contaminated soil experience

    • Soil Characterization and Management Plans

      • Prepared and signed by an Asbestos Project Designer certified in accordance with AQCC Regulation No. 8

    • Air monitoring

      • By an Air Monitoring Specialist certified in accordance with AQCC Regulation No. 8


    Disposal l.jpg
    Disposal Soil/Debris

    Asbestos-Contaminated Soil with:

    • Visible friable asbestos

      • Transported and disposed in leak tight containers

      • Disposed of as friable asbestos waste

    • Only visible non-friable asbestos

      • Transported and disposed in leak tight containers

      • Disposed of as non-friable asbestos waste

    • No visible asbestos

      • Transported and disposed in leak tight containers

      • Disposed of in the same manner as non-friable asbestos waste

    Soil that is not asbestos-contaminated can be replaced into the disturbed area


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    Fees Soil/Debris

    • In accordance with Section 1.7.2

    • Based on total documented costs

      • Review of Soil Characterization and Management Plan

      • Review of related documents

      • Department oversight activities

    • Paid by the owner, operator, or person conducting soil-disturbing activities


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    Guidance Document Soil/Debris

    • Broad overview of asbestos-contaminted soil

      • Solid Waste Regulations

      • Hazardous Waste Regulations

      • Voluntary Cleanup Program

    • Best management practices andexposure mitigation methods

    • Working draft - continue to solicit stakeholder input

    • Update as necessary based on feedback during implementation of the regulations


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    Additional Information Soil/Debris

    Solid Waste Regulations

    http://www.cdphe.state.co.us/regulations/solidwaste/

    100702disposalsites&facilities.pdf

    Draft Guidance Document

    http://www.cdphe.state.co.us/hm/asbestosinsoil.pdf

    Contact Information

    Colleen Brisnehan

    (303) 692-3357

    colleen.brisnehan@state.co.us