Asbestos NESHAP Inspection and Safety Procedures Course Chapter

Asbestos NESHAP Inspection and Safety Procedures Course Chapter Ten Asbestos Air Sampling And Analysis 2014

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

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 3

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. 4

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. 5

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 air sampling. § 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. 6

OSHA 7

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: 1) To protect unprotected workers in the workplace 2) To validate respirator choice (protection factor) 8

Exposure Limits Permissible Exposure Limit (PEL) 0. 1 f/cc – 8 hour Time Weighted Average (TWA) Excursion Limit (EL) 1. 0 f/cc - 30 minute sample 9

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

Filter Cassettes 11

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 12

Exposure Assessment, cont. § 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! 13

Periodic Monitoring – Class I & II Work § Daily personal air monitoring unless an NEA has been performed or supplied air respirators that are in the positive pressure mode § Periodic monitoring to validate exposure prediction 14

Number of Samples § “…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 15

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. 16

Notification & Observation § 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) § Designated representatives must have opportunity to observe and provided with necessary PPE if required to enter the work area. § They must comply with regs…medical monitoring, fit testing, etc. 17

Clearance Monitoring – OSHA §OSHA does not specifically address clearance monitoring. §OSHA 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 29 CFR 1926. 1101 (g)(6)(ii) & (g)(4)(ii)(B) 18

Air Sampling – 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. 19

Air Sampling – General Industry Practices, cont. § 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! 20

Air Sampling at Worksite 21

Air Sampling – General Industry Practices, cont. § Negative Air Machines § It is a published fact that these machines can “leak” if improperly maintained. § Sampling should be a few feet away (610’) from exhaust, NOT directly in front of exhaust. § Daily sampling also in or near clean rooms and waste load out areas; these are major points of contamination! 22

PCM Analysis – Sample Prep 23

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

EPA FINAL CLEARANCE ISSUES 25

EPA/AHERA Final Clearance SS/SD No Clearance Required 160 ft 2/260 LF PCM Clearance 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 TEM Clearance Required Clearance in schools is NOT an option 26

EPA/AHERA Final Clearance – TEM Protocol § § § 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/1 outside/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 27

Aggressive Air Sampling 28

AHERA Clearance Sampling Targets § TEM: 70 structures/mm 2; 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 <3850 L> and a 16 lpm max. flow rate using standard (0. 8µm) PCM cassettes. 29

PCM vs. TEM § PCM § Counts all fibers (including fiberglass, plant and carpet fibers, and others) § Not specific for asbestos § Operates at 400 X § Does not discern fibers smaller than 0. 25µm § Used for OSHA compliance (personal samples) and many area air samples § TEM § Specific for asbestos § Typically operated at 20, 000 X § Can “see” all airborne asbestos (0. 25 -0. 0025µm) § Required for most AHERA-related final clearance § Recommended for all clearance air 30 samples

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

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

Sample Pump 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 33 spelled rotameter).

Rotometers Typical Field Rotometers 34

Rotometers, cont. § 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. 35

Primary and Intermediate Calibration Standards Intermediate Standards Primary Standard Bios DC Lite & Gilian Gilibrator Bubble Burette 36

Hi-Vol Rotometer Being Calibrated with BIOS Dry Cal 37

Rotometer Being Used to Calibrate Pump 38

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. ) 39

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 40

Other Sampling Issues § Problem: The absence of actually drawing air through an air sampling cassette during the reported sampling period. The 55 MPH Air Sampling Procedure speed 3 = distance 1 / time 2 ette Air S amp ass ling C 1 = distance from job site to the lab (per “sample”) 2 = “sampling” time 3 = EFR; Effective flow rate 41

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!. 42

Lockdown Encapsulant ~20 K magnification ~5 K magnification TEM pictures of filter mounts rendered unusable because of lockdown encapsulant fouling 43

Questions? 44