Asbestos NESHAP Inspection and Safety Procedures Course Chapter 6 Asbestos Bulk Sampling And Analysis 2014 1 INTRODUCTION Topics Understand the concept of a building/site
inspection Protective Equipment Sampling Equipment/Materials Procedural Guidelines for Asbestos Sampling Pre-sampling Procedures Sampling Procedures Post-Sampling Activities Bulk Sample Analysis/Quality Control 2 NESHAP Regulates building materials that contain more than 1% asbestos
Collection of bulk samples is an essential component of a NESHAP inspection Without bulk samples, it is difficult to determine compliance status 3 AHERA Does not apply to NESHAP compliance inspections. Only EPA rule describing inspection and bulk sampling procedures. Many inspectors will follow AHERA protocols for any asbestos inspection they perform.
NESHAP requires a thorough inspection. AHERA inspections are often not NESHAP compliant. Usually do not involve destructive sampling. 4 Recommendations Collect samples whenever feasible Especially where violations are suspected and enforcement action is anticipated. Follow written standard operating procedures
Only use accredited laboratories for bulk sample analysis. Ask the laboratory to archive the samples for you. 5 Recommendations Inspectors must be able to testify that the samples: Accurately represent conditions at the site Were maintained using proper chain of custody Were acquired and analyzed using proper methodology
6 Protective Equipment Follow EPAs Health and Safety Guidelines for EPA Asbestos Inspectors Protective Clothing
Disposable, full-body coveralls Eye protection Hard hat Disposable gloves Safety shoes, hearing protection and other safety equipment as needed 7 Protective Equipment Respiratory Protection Should wear NIOSH-approved full-face, air purifying respirators with P-100 filters. Can also wear powered air-purifying respirators
(PAPRs) Required in OSHA Class I work areas where: No negative exposure assessment Exposure assessment indicates exposure level will not exceed 1.0f/cm3 (8 hour TWA) 8 Sample Equipment/Materials Sample containers Use dry, sealable and clean container OSHA recommends against the use of paper or plastic bags
Spray bottle Duct tape 9 Sample Equipment/Materials Bathroom caulking, water-activated repair cloth or encapsulant To repair sampled area Tamperproof tape/labels 10
Field logbook Plastic clipboard Inspection checklist Watch Sample labels Chain-of-custody forms Waterproof pens Overhead transparency sheets 12 Sample Equipment/Materials Plastic drop cloth Glove bags
Labeled waste disposal bags See Appendix A: Inspection Equipment Checklist in the student manual. 13 Folding locking knife Asbestos Inspection Supplies For samplin
g roofing, asbesto s Difficult to 14 14 Procedural Guidelines for Asbestos Sampling The asbestos NESHAP does not address techniques for taking bulk
samples Several EPA and ASTM documents provide procedures EPA Purple Book (June 1985) EPA Pink Book (October 1985) Health and Safety Guidelines for EPA Asbestos Inspectors (March 1991) ASTM E2356 15 The Basics Bulk samples an essential part of a NESHAP inspection
Proving violations requires bulk samples proper sampling technique proper documentation proper analysis 16 What is an Asbestos Inspection?
Documenting sampling locations and taking necessary field notes so that reports written later will accurately reflect site conditions. Taking photographs of materials found on the site and documenting on photo logs. Sending samples to a laboratory to be analyzed for asbestos type(s) and percentages. Generating reports that describe the activities, sampling and analytical results. The final reports from these activities will be the backbone of enforcement actions and potential litigation. 17
NESHAP demolition and renovation requirements Thoroughly inspect prior to disturbance Nondestructive AHERA likely inadequate roofing material exterior materials beneath carpets between walls 18 NESHAP demolition and renovation
requirements Determine presence of RACM, Category I or Category II nonfriable ACM, and friability Remove RACM prior to renovation or demolition. Notification to regulatory agency for all demolitions and most renovation activities. Most agency NESHAP notification forms require evidence of a building inspection and inspector information. 19 Pre-sampling Procedures (Noncontaminated Areas)
Discuss with building officials how the samples will be obtained. Determine equipment needed Discuss notification of employees Identify when samples will be collected Limit access 20 Pre-sampling Procedures (Noncontaminated Areas) Determine the minimum number of people necessary in the sampling area. PPE may be necessary for these individuals
Determine how the area will be decontaminated. Determine what PPE is necessary for the inspector. 21 Sampling Procedures Asbestos Inspectors may have to collect bulk samples: RACM in pre-abatement, active and postabatement areas Other project areas such as roll-off waste containers, trailers Abandoned buildings
Waste disposal sites Demolition sites 22 Sampling Procedures The following procedures should be followed: Identify homogeneous materials Similar in color and texture
Determine friability Select sample site to minimize disturbance Place plastic under sampling site if necessary Spray the area to be sampled with amended water 23 Sampling Procedures Collect a complete core or cross-section of suspect materials. For multi-layered systems:
If the sample remains intact through all layers, containerize the sample as is. If the sample crumbles or breaks down, take samples from discrete layers. Carefully identify each layer and its position in the multi-layer system. 24 Sampling Procedures Collect sufficient sample quantities per the labs recommendation. Always sample all the way through the suspect material!
Floor tiles, roofing felts, paper insulation, etc. 3-4 square inches Ceiling tiles, lose-fill insulation, pipe insulation, etc. 1 cubic inch 25 Sampling Procedures Collect a minimum of three representative samples from each homogeneous area of suspect material associated with a possible
violation. AHERA requirements will be addressed shortly. Place samples in airtight containers. Clean sampling equipment and wash hands or change gloves to avoid crosscontamination. 26 Sampling Procedures Use repair materials to seal the spot where the sample was taken, if necessary. Seal containers so that tampering will be evident and to prevent accidental opening.
Write unique identification and initials on each container. Record sample information in field notes. 27 Sampling Procedures If dry material is encountered and a wetting violation is suspected, record this information in the field logbook and note in both the logbook and on the chain-of-custody form that the material was wetted during sample
collection. 28 Sampling Procedures Photograph sampling location(s) Place an item of familiar size in the picture as a size reference. Make a drawing of the inspection site. Note where samples and photographs were taken.
Decontaminate tools, sample containers and self. Dispose of asbestos-contaminated waste properly. 29 ) m l fi ic ( er t s
Pla ntain to ag e co b ide ampl s n i ds l o h
Collecting bulk samples Full PPE if hazards are present and always required if fiber count is >PEL/EL ALWAYS wear your respirator Always decontaminate between samples and clean up all sampling debris. 30 Sample Collection Area Preparation Limit access to area Protect area where sample is
being collected, especially if in an ocuppied building. Polyethylene sheeting on floor or other horizontal surfaces Have a small HEPA vacuum for pre-cleaning and post-cleaning decontamination (if necessary) 31 AHERA Sampling Requirements The next few slides depict AHERA's sampling requirements for performing asbestos inspections in schools.
The sample amounts given apply to each homogeneous material. AHERA sampling procedures are required by many State/local asbestos regulations. NESHAP: thoroughly inspect 32 Surfacing Materials <1,000 ft2 a minimum of 3 samples 1,000 - 5,000 ft2 at least 5 samples >5,000 ft2 a minimum of 7 samples EPA recommends 9 samples - Pink Book
Minimum sample amount: ~1 tablespoon (sample all the way to the substrate) Statistically random sampling required! May need or want to collect more samples than called for by AHERA. 33
Thermal System Insulation(TSI) Minimum of 3 samples per homogeneous area Amount of material to sample: Sample the material down to the substrate! Some TSI can be quite thick (boilers) One pipe may have multiple homogeneous areas straight run elbow
valve replacement Randomly distributed samples There is no easy statistical sampling protocol for surfacing material. Sample widely! Patch = <6 linear or square feet, 1 sample 34 Miscellaneous Materials an accredited inspector shall collect bulk samples from each homogeneous area of friable miscellaneous
material that is not assumed to be ACM. Essentially the same requirements apply for nonfriable Minimum of two samples always collect adequate samples. Do not under sample!! In a manner sufficient to determine No statistical sampling protocol. In other words, take numerous samples throughout the material! Amount of material to sample: ~2-4 square inches (sample each layer if multiple layers/materials). 35 Examples of TSI Bulk Sampling The next couple of slides depict how
inspectors gather TSI samples. There are other methods that also work well. There are NO specified methods of sampling in the regulations. It is up to you to determine how best to conduct bulk sampling. 36 Moisten (but do not soak) the sample location before sampling. Re-spray as needed. Place sample in a rigid
container. Surround the container with a resealable plastic bag to catch debris. 37 Sampling using a single-use coring device. Use a wet wipe as you withdraw the coring device to limit dust and debris. If possible, sample above
horizontal to limit falling dust or debris. 38 Bulk Sampling Miscellaneous Materials No simple method of sampling this wide array of materials. The following slide shows sampling of floor tile. Be sure to take enough sample, often ~2-4 square inches.
Always look for multiple layers in such areas as floors, roofing, and exterior walls. 39 Often mastic has to be sampled separately to obtain enough to analyze 40
Always clean your tools! If not, you WILL contaminate subsequent samples. When sampling surfacing materials and TSI, wiping tools with wet wipes may be adequate. Mastics and roofing materials may require solvent cleaning. If solvents are used in larger quantities, an MSDS may be required on site! Make sure knife blades are locked before cleaning. Some firms do not allow the used of fixed-blade knives on their sites. 41 41 Multi-layered System Sampling May need to determine the applicability of
the NESHAP to multi-layered systems that are encountered. Such systems include: Plaster wall or ceiling Resilient flooring Plaster/stucco Wallboard with add-on layers
42 Multi-layered System Sampling EPA has received many questions about the applicability of the asbestos NESHAP to multi-layered systems. Published the following: Asbestos NESHAP Clarification Regarding Analysis of Multi-layered Systems (59 FR 542, January 5, 1994) 43
Multi-layered System Sampling Plaster/Stucco If the layers can be distinguished, they must be analyzed separately. Add-on Materials Sprayed-on materials, paint, ceiling and wall texture added to wallboard or other base materials must be analyzed separately if possible. 44
Wallboard EPA does not consider plasterboard (commonly called sheetrock, wallboard and gypsum board), by itself a multi-layered material under AHERA and NESHAP. Asbestos Sampling Bulletin (September 30, 1994) When joint compound or tape is applied to wallboard, it becomes an integral part of the wallboard. Where demolition or renovation impacts such a material, composite sampling should be
conducted. 45 Joint Compound Take a minimum of three samples Inside or outside corners At wallboard joint intervals Around nail/screw heads
Vertical Drywall Horizontal Drywall 46 Demolition/Renovation Sampling Considerations Try to obtain intact multi-layered samples. If layers start to separate, hold sample together with a rubber band. If layers separate during sampling, sample each layer individually. Make clear to the lab the nature of multi-layer samples. Inspector should also indicate the relative
positions of the layers in the material. Document site conditions and sample locations, and take photos to support potential enforcement actions. 47 Add-on Materials Take a minimum of three samples where joints are not expected. Since a laboratory cannot distinguish joint compound at joints from the same materials used as a skim coat, the inspector must clearly describe the sample composition so
that appropriate analysis is conducted and results are reported. 48 Add-on Materials At the laboratory, all samples with an outer layer having >1% asbestos will be noted. When this applies, the following must be considered: If only joint sampling areas are >1% asbestos, then the material is joint compound and analytical results of the layers are composited. If the composite result is <1%, no management is
necessary. If the composite result is >1%, the material is RACM as defined by the NESHAP and management is necessary. 49 Add-on Materials If samples from both joint compound and non-joint areas show layers with >1% asbestos, the material is considered a skim coat or add-on material. In this case the results must not be composited and must be reported for each layer. Material so located must be treated as separate RACM layers according to the NESHAP.
50 Add-on Materials EPA recommended the use of an improved analytical method for the analysis of bulk samples (59 FR 38970). Directs laboratories to analyze individual layers or strata of a multi-layered sample and to report a single result for each layer. The 1982 interim method had allowed analytical results for the discrete layers to be combined and reported as one result. 51
Add-on Materials As a result, multi-layered systems that may have contained asbestos in a single layer may have been reported by laboratories as non-asbestoscontaining. NESHAP inspectors, therefore, cannot rely on previous analysis of multi-layered materials to determine applicability of the NESHAP unless results of each layer's analysis are available. OSHA DOES NOT allow compositing of analytical results. 52
Other Sampling Issues Under sampling of materials can 2 drywall joint compound samples represent an entire building? Material quantity estimates A contractor will often use the quantities estimated by the asbestos inspector on NESHAP notifications. These can be poorly estimated for example, the quantity of asbestos containing wallboard (SF), window glazing compound (typically LF) or TSI (LF). When determining compliance during onsite visits the NESHAP inspector may find that quantities on-site differ from those listed on notifications. The owner or operator making the notification should
verify material quantities. 53 Demolition/Renovation Sampling Considerations The materials may be disturbed and mixed Sample a variety of materials that may have constituted the original homogeneous areas. Try to relate samples of debris to existing undisturbed materials, if possible. 54
Not all site sampling is simple! Photos/Peggy Forney/US EPA Denver We'll look more... in the Facility Inspections chapter. Wheres the ACM? 55 Dust Sampling Procedures In some situations, such as a post-removal inspection or an improperly-run abatement site, inspectors may encounter settled dust
and need to determine whether it contains asbestos. EPA has no official policy regarding dust sampling and analysis. The American Society for Testing and Materials (ASTM) Committee D22 has developed two dust sampling collection and 56 analytical methods. Microvacuum Samples NESHAP inspectors are encouraged to follow the microvacuum techniques
described in ASTMs Standard Test Method for Microvacuum Sampling and Indirect Analysis of Dust by Transmission Electron Microscopy for Asbestos Structure Number Surface Loading (ASTM D 5755-03). 57 Microvacuum Dust Sampling Usually a 10 cm x 10 cm sampling area From the Millette/Hays book (p. 50) <1000 structures (s)/cm2 = background
>10,000 s/cm2 = above background Use protective clothing, not street clothes! >100,000 s/cm2 = elevated There are NO federal dust levels! 58 Wipe Samples Asbestos NESHAP inspectors are encouraged to follow the wipe sampling techniques described in ASTMs Standard Test Method for Wipe Sampling, Indirect Preparation, and Analysis for Asbestos
Structure Number Surface Loading by Transmission Electron Microscopy (D 648005). 59 Tape Lift Samples In the tape lift method, adhesive materials such as transparent tape, self-stick office notes, or forensic tape are used to gather the dust sample. Duct tape should never be used since recovery of the dust particles for analysis is essentially impossible.
60 Passive Samples In passive sampling, a clean collection surface such as a shallow metal lid is deployed to collect dust over a measured period of time. The dust is rinsed out of the container and then analyzed via TEM. Since the collection time is usually several weeks, asbestos NESHAP inspectors do not often use this method. 61
Post-Sampling Activities Complete all documentation including checklist entries and chain-of-custody (COC) form. A sample COC form is provided in Figure 6-1. If a commercial lab is used for analysis, it may supply appropriate COC forms. Regulatory agencies often use their own COC forms. 62
Post Sampling Activities Secure samples before conducting another inspection. Minimize the number of individuals who handle the samples thereafter. Ensure that anyone who acquires custody of the samples signs the COC form. 63 Post Sampling Activities Chain of custody is best maintained by personal delivery of samples to the analytical laboratory.
If this is not possible, the U.S. Postal Service or a commercial courier service may be used. Since packaging and labeling requirements may differ depending on the organization chosen, inspectors should contact these couriers before shipping samples. 64 Post Sampling Activities Package bulk samples securely so that asbestos will not be released during transport.
Make sure the sample vials are securely taped shut and well-cushioned to prevent breakage. 65 Post Sampling Activities Analyze samples as necessary. It is advisable to collect extra samples and analyze only enough to satisfy the evidence requirements. Retain original samples until an enforcement action is completed.
66 Bulk Sample Analysis Bulk sample analysis is performed to determine whether the material from which samples have been collected contains greater than 1% asbestos. EPA provided guidance regarding the analysis of asbestos in bulk samples in Method for the Determination of Asbestos in Bulk Building Materials (EPA/600/R-93/116, July 1993). 67
1993 Analytical Method Improved upon the previous 1982 method. Was designed to address: Low percentage samples (<10%) Asbestos obscured by matrix binder (e.g. vinyl or asphalt) Presence of small and/or thin fibers Included additional sample preparation techniques and the use of Transmission Electron Microscopy (TEM).
68 Bulk Sample Analysis Analysis begins with a careful examination of the sample using a stereomicroscope. The sample is then viewed under a polarized light microscope (PLM). In most cases, these steps will suffice to characterize a sample as asbestos-containing (asbestos present >1%) or non-asbestoscontaining (no asbestos detected, or 1% or less in the sample). 69
Stereomicroscopic Examination A preliminary visual examination, which will help determine: Homogeneity Texture
Friability Color Extent of fibrous components This information helps guide the selection of further, more definitive, qualitative and quantitative asbestos analytical methods. 70 Stereomicroscope 71
Polarized Light Microscopy Used to distinguish the various forms of asbestiform minerals on the basis of their unique optical crystallographic properties. Also used to perform a semi-quantitative analysis of bulk samples; i.e., visual area estimation. May need to be supplemented by other techniques such as point counting, gravimetric preparation and TEM analysis 72 er
St sc eo e op PLM Typical bulk sample analysis work station 73 Polarized
Light Microscope 74 Chrysotile at ~100X An ideal view Typical PLM view of chrysotile in a bulk
sample Courtesy US EPA Denver 75 Chrysotile Dispersion staining views through the PLM Tremolite 76 Visual Area Estimation
Per EPAs 1993 methodology, visual area estimates are made by comparing the sample to calibration materials that have similar textures and fiber abundance. Analytical results are reported as area percent. If no asbestos fibers are seen, the analyst commonly reports this result as no asbestos observed. 77 Point Counting For samples at the 1% level, point
counting may be used to quantitatively determine asbestos %. Measuring 1% vs 2% is difficult/impossible For materials where asbestos is present but at less than or equal to 1% by visual estimation, point counting is required to declare the material non-ACM. 78 Point Counting In point counting, 8 slide mounts
are made 50 non-negative points are typically counted mechanically over 8 slide mounts for a total of 400 points. 5 asbestos fibers in a 400 point count = 1.25% 79 8 slides with material dispersed Crosshairs
50 non-negative points per slide A point is where the crosshairs intersect Courtesy US EPA - Denver 80 Point Counting Point counts are usually reported in quarter percents (1.25%, 1.50%, 1.75%, etc.). Point counts are more defensible for low
percentages compared to visual estimations. The NESHAP requires point count procedures on materials from trace to 10%. EPA 5 Page Memo (May 18, 1991) allows for visual estimations if the client is aware of data usage limitations. 81 Gravimetry Gravimetry is a process in which acids, solvents and ashing (heating the sample to burn off organic materials) are used to
selectively remove the binder components from a sample. Gravimetric procedures are designed to meet the following objectives: Isolate asbestos from the sample to allow weight determination. Concentrate asbestos, thereby lowering the detection limit in the total sample. Aid in the detection and identification of fibrous components. Remove organic fibers that are optically similar to 82 asbestos.
Gravimetry If the sample is friable and contains organic components, the ashing procedure should be followed. If the sample is friable and contains HClsoluble components, the acid dissolution procedure should be followed. If the sample is friable and contains both types of components, or if the sample is nonfriable; e.g., floor tiles, the two procedures can be applied, preferably with acid dissolution following ashing. 83
X-Ray Diffraction (XRD) XRD is a technique that reveals a mineral's unique "fingerprint" on film. Typically used in conjunction with PLM or TEM. The technique is more expensive than PLM and cannot distinguish between fibrous and non-fibrous forms of asbestos. XRD will provide qualitative, semi-quantitative and quantitative results. 84 Analytical Electron
Microscopy (AEM) AEM analysis, often referred to as TEM analysis, is a reliable, although more expensive, method for the detection and positive identification of asbestos in some bulk building materials. 85 Analytical Electron Microscopy (AEM) The method is particularly useful in the analysis of floor tiles and plasters,
materials that contain a large amount of interfering materials and contain asbestos fibers that may not be resolved by PLM techniques. Can be used to quantify asbestos concentrations. 86 TEM Analysis Fiber Chemistry (EDS) TEM Sample Grid
Fibers magnified ~20,000X Diffraction Pattern (SAED) Other Analytical Techniques Scanning electron microscopy is very useful for observing surface features in complex particle matrices and for determining elemental compositions. SEM cannot, however, detect small diameter fibers (~<0.2 mm) and cannot determine crystal structure. Field test kits should never be used to confirm the presence or absence of asbestos
since their results are unreliable. 88 Quality Assurance Sample Identification Numbers Chain-of-Custody (COC) Forms Quality Control (QC) Samples Accredited Laboratories 89 Sample Identification Numbers A unique identification number must be assigned to each sample.
Could be a combination of a site code and the date and time the sample was taken. For example, a sample obtained at St. Joseph's Hospital on July 1, 2010 at 2:17 pm, could be assigned the following number: SJH 100701 1417 90 Sample Identification Numbers Use of such a numbering system can
help reduce a microscopist's potential bias. Be sure to reference sample numbers properly in project notes, COC forms and final reports. Failure to do so can attract negative scrutiny. 91 Chain-of-Custody (COC) Forms EPA requires that a COC form be completed and accompany the samples when they leave the possession of the inspector.
The form should contain the following information: Project name and address Date of inspection/sampling Sample identification numbers Name/signature of sampler and date of sampling Name/signature of recipient(s) and date(s) of receipt Type of analysis to be performed 92 Chain-of-Custody (COC) Forms Other pertinent COC information Use of glove-bag sampling method
It is very important that the glove-bag technique be noted on the COC form. When using the glove-bag technique the inspector may NOT wet the sample as would be done ordinarily. The laboratory probably will note that a particular sample was received dry and others were wet. Use of unusual sample container Dry material wetted by inspector, etc. 93
Chain-of-Custody (COC) Forms Avoid lengthy notes on the COC form. Since some laboratories require the use of their own COC forms, inspectors should contact them ahead of time to learn proper procedures. A COC form should be completed immediately after the inspection. If mistakes are made in transferring information from field notes or sample containers to the form, a new form should be completed. 94 Chain of Custody Form
95 Chain-of-Custody (COC) Forms The form should not be signed until just before the samples leave the custody of the inspector. Every person who takes custody of the collected samples must sign the COC form. Samples should remain in the custody of one inspector until they are released to the laboratory in order to mitigate negative scrutiny on how the samples were handled post-inspection. 96
Quality Control (QC) Samples Collection of side-by-side duplicates is recommended at the rate of one QC sample per building or one QC sample for every 20 samples taken, whichever is larger. Since analyses of QC samples can help determine both sampling and analytical precision, it is important that the laboratory conducting the analysis not know which samples are QC samples. 97
Quality Control (QC) Samples Inspectors can help ensure nonbiased analysis by collecting a side-by-side sample non-sequentially. The inspector should gather several samples at the facility and then go back to one of the sample locations for the side-by-side duplicate. In this way the side-by-side samples' identification numbers are not consecutive in time or number. 98 Quality Control (QC) Samples Side-by-side duplicates are analyzed to
determine the consistency of analysis within a laboratory. Significant differences in analytical results for duplicate samples should not be encountered. Splits of side-by side duplicates may also be sent to a second laboratory to confirm the results of the first analyses. Any significant disagreements should be investigated. 99 Accredited Laboratories
NIST/NVLAP Accreditation Programs For PLM and TEM labs performing work for AHERA-related analysis. Required by many government agencies for NESHAP inspections. AIHA Lab Accreditation Available for PLM labs Acceptable for Non-AHERA compliance 100 Accredited Laboratories Be sure to contact the laboratory before
conducting the inspection and discuss the following: Required type of analysis Sampling procedures Sample amounts Sample containers Chain of custody forms Packaging of materials for shipment Turnaround time for analysis Cost of analysis 101 QUESTIONS?
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