Asbestos NESHAP Inspection and Safety Procedures Workshop

1. Asbestos NESHAP Inspection and Safety Procedures Workshop Section Ten Asbestos Air Sampling And Analysis October 2008

2. Topics For Discussion • Air Sampling • Regulations • Work Practices & Standards • Training, Calibration & QC • Other Related Asbestos Sampling and Analysis Issues • Q&A

3. Before We Begin…. • Question: • How many types of air samples are required by federal requirements on an asbestos abatement project? • Answer: • TWO…. • OSHA; Personnel Sampling • EPA (AHERA); Final clearance • Are others taken during a project? • Yes! We’ll talk about those too

4. Before We Begin…. • All other types of air sampling on asbestos abatement projects are: “GENERAL INDUSTRY PRACTICES” • In other words, they should be performed as a “STANDARD OF CARE” and are called for in many job specifications (including NIBS, military etc.), State regs, and inferred in OSHA regulations (1926.1101 <d>) • To not do others would be a mistake and a potential liability on most projects

5. One last point before we begin;NESHAP issues… • NESHAP does not contain any provisions for air sampling • The regulation is based on “visible emissions” • Knowledge of this information is essential to understand OSHA, EPA (AHERA) and State/Local program compliance • State/Local programs can have extensive air sampling requirements • We’ll be addressing federal requirements and general industry practices in this section

6. Relevant Standards • OSHA Asbestos Regulations • 29 CFR 1926.1101 - Construction • 29 CFR 1910.1001 - General Industry • 29 CFR 1915.1001 - Shipyard • OSHA Reference Method, Appendix A • This is the mandatory section for personal sampling issues • EPA Asbestos Regulations • 40 CFR Part 763 – AHERA • NIOSH 7400 Method (Issue 2, 1994) • This is the analysis method for job site air samples • ASTM E-1368 <Visual Inspection> • An inspection method for asbestos abatement; not a regulation

7. OSHA ISSUES

8. Air Sampling Issues – OSHA Remember…. The OSHA asbestos standard is not an “abatement spec” There are two reasons we run air samples for OSHA compliance: • To protect unprotected workers in the workplace 2) To validate respirator choice (protection factor)

9. Air Sampling Issues – OSHA (c) Exposure Limits Permissible Exposure Limit (PEL) 0.1 f/cc – 8 hour TWA Excursion Limits (EL) 1.0 f/cc - 30 minute sample Hint: This is a “must know”

10. Worker Wearing Personal Air Sampling Device Air Sample Cassette In The Breathing Zone

11. Filter Cassettes 11

12. Air Sampling Issues – OSHA (f) Exposure Assessment “Each employer…shall ensure that a “competent person” conducts an exposure assessment before or at the initiation of the operation to ascertain expected exposures…” Q: Who is the competent person on an abatement job? A: Typically the SUPERVISOR

13. Air Sampling Issues – OSHA (f) Exposure Assessment General Monitoring for PEL/EL Initial Exposure Assessment Negative Exposure Assessment (NEA) • Objective Data • material cannot release asbestos above PEL/EL • Prior Data • “closely resembling” process, material,control methods, environ. conditions, training/experience • Initial Exposure Assessment • Note: an NEA is only good for one year!

14. Air Sampling Issues – OSHA • Periodic Monitoring – Class I & II • Daily personal air monitoring unless an NEA has been performed or supplied air respirators in the positive pressure mode • Periodic monitoring to validate exposure prediction

15. Air Sampling Issues – OSHA • Number of personal samples to obtain: • “…that is representative of the exposure of each employee” • Interpretation: sample from each type of work • Industry lore has been 25% of the work force

16. Air Sampling Issues – OSHA • Termination of Monitoring • “…statistically reliable…” data below PEL/EL • Additional monitoring is required any time there is a change in process, control equipment, personnel or work practices or if suspected that fiber levels may exceed PEL/EL – even if an NEA has been produced

17. Air Sampling Issues – OSHA • Employee Notification • Must notify ASAP of receipt of results; in writing or centrally posted • But not later than 5 days (1926.1101) or 15 days (1910.1001) • Observation of Monitoring • Designated representatives must have opportunity to observe and provided with necessary PPE if required to enter work area • They must comply with regs…medical monitoring, fit test etc

18. Air Sampling Issues – OSHA • Clearance Monitoring – OSHA • OSHA does not specifically address clearance monitoring, but it uses clearance levels (AHERA) and PCM sampling (compared to background levels before work begins) to assure that control methods prevent contamination outside of a regulated area • See sections 29 CFR 1926.1101 (g)(6)(ii) & (g)(4)(ii)(B)

19. Air Sampling Issues – General Industry Practices • Outdoor/Indoor Background • To have comparison fiber levels before work begins • Outside Containments • A must to ensure that fiber levels do not exceed specified standards and cause contamination; heavily inferred by OSHA • These are obtained daily from a variety of locations; outside critical barriers, floors above/below, and others. Locations often change daily to make sure all accessible areas have been checked for increased fiber levels

20. Air Sampling Issues – General Industry Practices • Inside Work Area • OSHA mandated personal sampling • Occasionally personal sampling pumps are hung inside the work are to gauge work practices; no specific federal regulatory requirement for these • Never bring a high volume pump inside the work area during abatement: Pump contamination!

21. Air Sampling at Worksite 21

22. Air Sampling Issues – General Industry Practices • Negative Air Machines • It is a published fact that these machines can “leak” if improperly maintained • Sampling should be a few feet away (6-10’) from exhaust, NOT directly in front of exhaust • Daily sampling also on clean rooms and waste load out areas; these are major points of contamination!

23. PCM Analysis – Sample Prep

24. PCM Analysis PCM view of fibers (400X) PCM Microscope

25. EPA FINAL CLEARANCE ISSUES

26. Air Sampling Issues –EPA/AHERA Final Clearance SS/SD 160 ft2/260 LF No Clearance Required PCM Clearance TEM Clearance Required Clearance in schools is NOT an option Small scale/short duration (SS/SD) is almost identical to OSHA Class III work. ALSO: Some States mandate AHERA-TEM clearance for asbestos abatement work in the private sector

27. Air Sampling Issues – EPA/AHERA Final Clearance • The TEM Protocol in brief: • 13 samples submitted to lab (schools; all 13!) • 5 inside the work area • 5 outside the work area (“make up air”) • 3 blanks (1 inside/1outside/1 sealed) • 1200-1800 liter sampling volume • 10 lpm max. flow rate • TEM cassettes • 0.45µm filter, different than PCM (0.8µm)! • Visual Inspection(s)/Aggressive Air Sampling • Air sampling firm MUST be independent of contractor • Z Test compares inside/outside (rarely used) • In most cases if failure – re-clean and retest

28. Air Sampling Issues – EPA/AHERA Final Clearance

29. Air Sampling Issues – EPA/AHERA Final Clearance • Project Clearance Sampling Targets • TEM: 70 structures/mm2; typically an average of the 5 inside samples • PCM: 0.01 f/cc; samples are NOT averaged • 5 samples inside, no outside • As a general industry practice 0.01 f/cc is commonly used as a target value for sampling outside the abatement area during abatement work • Required by most specs and some State/Local programs • NOTE: sample volumes for PCM are NOT the same as TEM; • For PCM from NIOSH 7400; at least 3000 liters <3850L> and a 16 lpm max. flow rate using standard (0.8µm) PCM cassettes Know the TEM & PCM clearance numbers!

30. PCM Counts all fibers (including fiberglass, plant and carpet fibers, and others) Not specific for asbestos Operates at 400X for fiber counting Does not discern fibers smaller than 0.25µm Used for OSHA compliance (personal samples) and for all other air samples during the project TEM Specific for asbestos fibers Typically operated at 20,000X Small fiber size is irrelevant; it can “see” all airborne asbestos (0.25-0.0025µm) Required for most AHERA-related final clearance Recommended for all clearance air samples (full demo excepted) Used sometimes for bulk materials PCM vs. TEM

31. TEM Analysis Fiber Chemistry (EDS) TEM Sample Grid Fibers magnified ~20,000X Diffraction Pattern (SAED)

32. Air Sampling Devices Personal Sampling Pump High Volume Sampling Pump with Sampling Stand Air Sampling Cassettes

33. Air Sampling Issues – Calibration How and why do we calibrate pumps? To calibrate a sampling pump means to know what the flow rate is (in liters per minute) through the sampling system or “train” (pump/tubing/cassette) Calibration is an industrial hygiene standard and a regulatory requirement Every air sampling pump must be calibrated before (and after) its use!! This is normally accomplished in the field with a calibrated rotometer (sometimes spelled rotameter)

34. Air Sampling Issues – Calibration Typical Field Rotometers

35. Air Sampling Issues – Calibration The numbers on a rotometer are not accurate! Rotometers must be calibrated with a device called a “primary or intermediate standard” They should be recalibrated with some regularity – based on use

36. Air Sampling Issues – Calibration Intermediate Standards Bios DC Lite & Gilian Gilibrator Primary Standard Bubble Burette

37. Hi-Vol Rotometer Being Calibrated with BIOS Dry Cal

38. Rotometer Being Used to Calibrate Pump

39. Air Sampling Issues – QC • Proficiency Analytical Testing (PAT) • Program administered by AIHA • Those analyzing PCM samples for OSHA compliance; a general industry practice; required in most specs • Asbestos Analyst Registry (AAR) • Also administered by AIHA • For individual counters, not OSHA required • But can be called for in specs (Military etc.)

40. Air Sampling Issues – Training • NIOSH 582 (equivalent) • Required for those that will analyze PCM samples for OSHA compliance • Asbestos Supervisor Training • In addition to NIOSH 582, required by many States for those that do asbestos air sampling; recommended for complete air sampling tech training • On-site Training of Air Sampling Techs • Not required, but highly recommended • Some State/Local programs require specific training and licensing for those obtaining and/or analyzing air samples

41. Other Analytical Issues • Problem: The absence of actually drawing air through an air sampling cassette during the reported sampling period The 55 MPH Air Sampling Procedure speed3 = distance1 / time2 1 = distance from job site to the lab (per “sample”) 2 = “sampling” time 3 = EFR; Effective flow rate Air Sampling Cassette

42. Other Analytical Issues Lockdown Encapsulant After spraying the final lockdown encapsulant, the contractor MUST allow for some period of drying time If not, the filter surface of the sampling cassette will be covered with encapsulant and cannot be analyzed by PCM or TEM How much time? Depends of size of room!

43. Other Analytical Issues ~20K magnification ~5K magnification TEM pictures of filter mounts rendered unusable because of lockdown encapsulant fouling

44. Questions?