Asbestos in Soil Who Knew? A Consulting Perspective 1 st Annual Southeast Brownfields Association

Transcription

1 Asbestos in Soil Who Knew? A Consulting Perspective 1 st Annual Southeast Brownfields Association Presented by: Russell E. Stauffer, PE AMEC Environment & Infrastructure, Inc. October 30, East Amelia Street, Suite # W. Laurel Street Orlando, FL Tampa, FL Asbestos in Soil Who Knew? A Consulting Perspective How d it get there? Naturally occurring? Contamination? Crawlspaces? Demolitions? Other debris? Illegal dumping? Pipe bursting? 2

2 Naturally Occurring? / Contamination? Naturally occurring Geological veins California Elsewhere Contamination Libby Montana!!! Superfund Vermiculite 3 Naturally Occurring? / Contamination? 4

3 Crawlspaces? Old construction No maintenance No access 5 Demolitions? Marketing driven issues Redevelopment vs. remediation Limited land available Missing owner Maybe not quite right? Money!!?? 6

4 Other Debris? / Illegal Dumping? Much too common After demolitions Over time build-up / convenience 7 Pipe Bursting? New technology Applications Advantages Issues? Pipe bursting: a trenchless methody of replacing buried pieplines (such as sewer, water, or natural gas pipes) without the need for a traditional construction trench. Launching and receiving pits replace the trench needed by conventional pipe-laying. -Wikipedia Pipe bursting can be used for almost any type of pipe, including clay, asbestos cement, cast-in-place and reinforced concrete, cast iron, steel, ABS styrene, polyethylene, and polyvinyl chloride 8

5 Asbestos in Soil Who Knew? A Consulting Perspective What do the REGS say? EPA NESHAPS EPA Soil/Site Pipe Bursting OSHA Worker Exposure Other comments (Libby Montana) 9 What do the REGS say? EPA NESHAPS National Emission Standards for Hazardous Air Pollutants (NESHAPS) NESHAPS are found in 40 CFR Part 61 and 40 CFR Part 63. Part 61 NESHAPS regulates only 7 hazardous air pollutants Asbestos (Asbestos-Containing Material {ACM}. >1% asbestos) Beryllium Mercury Vinyl chloride Benzene Arsenic Radon/radionuclides 10

6 What do the REGS say? EPA NESHAPS (continued) Regulated asbestos-containing material (RACM) means: Friable asbestos material, Category I nonfriable ACM that has become friable, Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or Category II nonfriable 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 operations regulated by this subpart. Friable asbestos material means any material containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763, section 1, Polarized Light Microscopy, that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. Category I nonfriable asbestos-containing material (ACM) means asbestoscontaining packings, gaskets, resilient floor covering, and asphalt roofing products Category II nonfriable ACM means any material, excluding Category I nonfriable ACM, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. 11 What do the REGS say? EPA Soil/Site 12

7 What do the REGS say? Pipe Bursting Florida Department of Environmental Protection (Memo 4/19/14) Asbestos Cement Pipes: Fragments created by pipe bursting of asbestos concrete pipes might be considered friable asbestos material that is subject to regulation under the Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP). The water supplier should contact the DEP Air Program to determine what, if anything, the water supplier will have to do to comply with Asbestos NESHAP regulations. 13 What do the REGS say? Pipe bursting (continued) 14

8 What do the REGS say? 15 What do the REGS say? United States Department of Labor Occupational Safety & Health Administration 29 CFR Construction (b) Definitions Asbestos includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these minerals that has been chemically treated and/or altered Asbestos-containing material (ACM) means any material containing more than one percent asbestos (>1%) However : Per OSHA Letter of Interpretation (October 10, 2003) Question: Do the wet handling, prompt clean up, and disposal requirements set forth in 29 CFR (g)(1)(ii) and (iii) apply to demolition operations involving material containing <1% asbestos? Reply: Yes, those requirements do apply to demolition operations involving material containing <1% asbestos. 16

9 What do the REGS say? OSHA worker exposure (a) Scope and application. This section regulates asbestos exposure in all work as defined in 29 CFR (b), including but not limited to the following: (a)(1) Demolition or salvage of structures where asbestos is present; (a)(2) Removal or encapsulation of materials containing asbestos; (a)(3) Construction, alteration, repair, maintenance, or renovation of structures, substrates, or portions thereof, that contain asbestos; (a)(4) Installation of products containing asbestos; (a)(5) Asbestos spill/emergency cleanup; and (a)(6) Transportation, disposal, storage, containment of and housekeeping activities involving asbestos or products containing asbestos, on the site or location at which construction activities are performed 17 How do you find it? Numbers of samples NESHAPS - Thoroughly inspected? Visual Debris? EPA AHERA (Schools ) 7 minimum samples? EPA Framework Activity Based Sampling (ABS) EPA Crawlspace PCBs 7 to 37 samples? ASTM E-1368 Crawlspace OSHA Personals? Analytical methods: PLM TEM??? 18

10 What do you do with it? 2014 Construction changes The 2014 construction season began in May and EPA anticipates removals at close to 70 properties this year. Beginning in 2014, EPA is mobilizing to properties even if the only contamination is asbestos just above trace levels. All soil with asbestos concentrations above trace (0.2 percent) will be removed. Upon completion of removal action, the majority of every property will have no detectable levels of asbestos in soil. We have also changed our approach regarding vermiculite. Vermiculite can be an indicator of asbestos but doesn t necessarily mean that asbestos is present. 19 What do you do with it? Monitoring during the clean-up Soil samples used for screening only Excavation surface tested until non-detect at 0.25% 0.25% was the detection level available and is not a risk-based number Visual observation for vermiculite 20

11 What do you do with it? Leave and manage it? Cover it? Remove it? Clearance soil samples? Monitoring air sampling? 21 What do you do with it? Leave and manage it? Cover it? Remove it? Clearance soil samples? Monitoring air samples? 22

12 Thank you Questions?