Compliance and Enforcement of the Asbestos Airborne Toxic Control Measure for Construction and Grading in the SF Bay Area

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1 Association of Engineering Geologists (AEG) Symposium Assessment, Monitoring and Mitigation of Naturally-Occurring Asbestos (NOA) Hazards in the Western U.S. December 18, 2014 (BAAQMD) Compliance and Enforcement of the Asbestos Airborne Toxic Control Measure for Construction and Grading in the SF Bay Area Kevin Vo Air Quality Specialist

2 Naturally-Occurring Asbestos (NOA) Naturally occurring mineral found in Serpentinite rock Serpentine is the California State Rock Principle forms of asbestos include Chrysotile, Crocidolite, Amosite, Tremolite, Actinolite and Anthophyllite. NOA found in soil in 44 of California s 58 counties 2 of 2 14

3 NOA Locations in the Bay Area 3 3 of 14

4 Regulatory Background California Air Resources Board developed an Air Toxic Control Measure (ATCM) for NOA. The ATCM established notification and work practice requirements that reflect best dust mitigation measures. The ATCM was adopted into California law in July, (Title 17, CCR, Section 93105) Air District implemented its enforcement program for NOA in November, of 14

5 NOA ATCM Requirements Operators of large construction projects (> 1 acre) required to submit an Asbestos Dust Mitigation Plan (ADMP) ADMP must specify measures to ensure controlling NOA emissions. Road construction and maintenance operations Quarries and surface mines must also obtain District ADMP Air monitoring is based on a sensitive receptors analysis. There are no ambient air standards for NOA in the ATCM. BAAQMD has approved 102 ADMPs to date. 5 5 of 145

6 BAAQMD NOA Applications 7 of 6 14

7 ADMP Review Process Company and Project Information (responsible property owner contact info) Detailed Project Information (start/stop date; end use) Detailed Site Information (basis for known NOA; disturbed acres) Track-out control measures Active Storage Piles Inactive Areas and Storage Piles On-Site Traffic Control Earth Moving Activities Off-Site Transport of Materials Post-Construction Stabilization NOA Air Monitoring Assessment (downwind sensitive receptor map analysis) 7 6 of 14

8 Asbestos Monitoring Apparatus 8 9 of 14

9 Transmission Electron Microscopy (TEM) Asbestos Fiber as seen under a TEM 10 of 9 14

10 Public Health Protection In the interest of protecting public health, the District set NOA air monitoring Action Levels. The District determined NOA health risks using established risk assessment protocols developed by the Office of Environmental Health Hazard Assessment (OEHHA). 7 of 10 14

11 Action Levels Action Levels are indicator and to alert the project that more stringent controls may be needed in order to effectively control NOA emissions. Per the ATCM, the District has amended multiple ADMPs to include more stringent mitigation measures in response to repeated elevated air monitoring results. Multiple projects have voluntarily requested that the Action Levels be included in their ADMP. 8 of 11 14

12 NOA Mitigation of 14

13 Compliance Assurance Air District staff conducts daily surveillance at ADMP sites ensuring that the projects follow the measures in their ADMPs. Regular compliance inspections continue until projects no longer disturb NOA of 14

14 Questions? Kevin Vo (415)