Asbestos in Soil and Made Ground



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Asbestos in Soil and Made Ground Professor Paul NATHANAIL CGeol SiLC University of Nottingham & Land Quality Management Ltd SiLC Annual Forum, Royal Society of Chemistry, Burlington House, 30 April 2013

Identification difficulties: Visual Analysis Asbestos fines are difficult to see, both soils contain > 0.1% asbestos

Guidance initiatives Just like buses; you wait forever then three are en route at once! AGS Interim Guidance: Site Investigation Asbestos Risk Assessment For the protection of Site Investigation and Geotechnical Laboratory Personnel (amended) (2012) Ciria RP961 Guide to managing and understanding the risks of asbestos in soil and on brownfield sites (2013) EIC/CL:AIRE Joint Industry Working Group Industry code of practice practitioners guide (201?)

Ciria RP961 Written by LQM (Nathanail & Ogden) and IOM (Jones & Robertson) Overseen by a large and diverse PSG Chaired by Claire Dickinson (AECOM) Due mid 2013 Aims to improve the performance of practitioners and other professionals when undertaking risk assessments Suggest a valid approach to characterising, assessing and managing asbestos in soils, aggregates and made ground under Part 2A and Planning Including: Relevant legislation International guidance Asbestos and asbestos containing materials (ACM) Health effects Release of fibres from ACM Desk Top Study and site reconnaissance Conceptual model and preliminary risk assessment Soil sampling & analysis and air monitoring Exposure estimation models, estimates, measurements Risk evaluation and communication Remedial strategies Appointing specialists Case studies

CLAIRE/EIC JIWG Will hopefully follow on from and build on - Ciria RP961 Aiming to publish a draft for consultation in 201? Proposed scope: Introduction and Background Regulation of Asbestos UKAS and Accreditation Requirements Training and Qualification Requirements Insurance Requirements Site Investigation and Sampling protocols Laboratory analysis Human Health Risk Assessment Remediation of Asbestos- Contaminated Soils and Ground Materials Waste management

Today we will: Summarise some key technical issues relating to the investigation and assessment of asbestos-containing soils Highlight some of the complexities and remaining uncertainties [and explore these in a group exercise/discussion]

Basic principles Establish the legal context CAR2012 (and other H&S legislation) has significant implications from owners or contractors working with asbestos in soil Compensation Act 2006: joint and several liability for negligence wrt asbestos As well as Part 2A, Planning, common law, EDR, etc. Develop a conceptual site model including relevant uncertainties & likely changes with time Adopt a lines of evidence approach to risk evaluation

Key messages Asbestos is primarily hazardous by inhalation Asbestos has been proved to cause mesothelioma and lung cancers in humans Different types of asbestos have different potencies. In general, it seems crocidolite > amosite > chrysotile Very little guidance on asbestos in soil in the UK or elsewhere Also a limited amount of research to base guidance on Only existing UK guidance (ICRCL 64/85 ver2) notes that 0.001% asbestos in soil can exceed occupational exposure limits (0.1 f/ml air) Risks from asbestos in soil can be assessed using BS10175:2011/CLR11 approach but: Specific precautions will be need during all site works Sampling and testing strategies may be different from other contaminants Asbestos-specific techniques will be needed for site investigation, risk estimation and evaluation Asbestos is potentially present at nearly all types of post industrial site, but likely mostly at low concentrations Asbestos is identified in all DOE Industry Profiles

Key messages 2 Particular issues may be present: At or near asbestos handling sites Waste may have been tipped or sold for use on neighbouring land Railway land, heavy engineering (dockyards), old waste sites/scrapyards and power stations Sites were structures were demolished (particularly before 2000) Sites were demolition rubble/mage ground was imported from the above Unlike most other contaminants, soil concentrations are not sufficient on their own to assess risks It is the release of asbestos fibres into the air that poses a risk Bound vs friable (e.g. AC vs lagging vs free fibres) Good condition vs weathered/ degraded Depth Moisture content Soil type Surface cover (vegetative or hard surfacing) Land use/ receptor activities

Key messages 3 Better laboratory tests are needed that can identify low levels (0.001%) of asbestos fibres (not just pieces of ACM) determine its condition/fibre release potential cost? Additional lines of evidence may be needed (e.g. air monitoring, Activity-based sampling or fibre release tests) Occupational air monitoring (LoD 0.01 f/ml) are not sufficient to demonstrate that a site is safe (NPPF para 120) or suitable for use (NPPF para 121) and must be able to identify asbestos type Likely to requires electron microscopy and long sampling times cost? Activity-based sampling (ABS) measures airborne concentrations during simulated activities (e.g. gardening or sports) under controlled and safe conditions (e.g. RPE) - costs? Permitted? Fibre release tests are laboratory tests to measure worst case airborne concentrations generated from soils (not (?) currently available in UK) costs? Under CAR2012 all analysis must be UKAS accredited

Key messages 4 Multiple Lines of evidence should be used agreement between different methods and techniques Assessment will require different techniques to other contaminants CLEA, and other models, are not appropriate Methods are available to estimate airborne fibre concentrations from soil concentrations but they are crude and their accuracy uncertain Several models are available to predict excess lifetime cancer risks from airborne fibre concentrations but their accuracy at low environmental exposures is questionable Do these tools accurately reflect likely risks from asbestos in soil? Multiplication of conservatism? But the potential health effects should not be trivialised or ignored!!

A long time ago, in a galaxy far, far away... A primary school somewhere was built in the 1980s with a playing field Soil samples were collected in preparation for building an extension and MUGA ASBESTOS! was identified!!! The results of further sampling suggested : The site had been built up with dredgings topped with ~0.3m of made ground containing demolition wastes (=asbestos?)

How could the risks be estimated? Addison et al. 1988 measured the release of airborne fibre from dry soils ( sandy, intermediate and clay ) containing between 1-0.001% free asbestos fibre (3 types) "Clay" soil "Intermediate" soil "Sandy" soil 10.00 10.00 10.00 1.00 1.00 1.00 f m l- 1 /m g m - 3 0.10 0.01 Amosite Chrysotile f m l- 1 /m g m - 3 0.10 0.01 f m l- 1 /m g m - 3 0.10 0.01 0.00 Crocidolite 0.001 0.01 0.1 1 0.00 0.001 0.01 0.1 1 0.00 0.001 0.01 0.1 1 % Asbestos in soil % Asbestos in soil % Asbestos in soil Source: Land Quality Management, 2012 based on data in Table 3.1 in Addison et al. 1989

Nature of the models All models are based on occupational exposure of young adults (~30yrs old) to relatively high asbestos concentrations (mixtures of fibres) over relatively short periods (~5yrs) but we are considering children exposed to much lower concentrations Involves extrapolating to low concentrations and other assumptions WATCH considers that all of these uncertainties impose limitations on the reliability of risk estimates produced by the model, particularly when it is extrapolated to exposure situations and populations beyond those covered by observed data....risk estimates derived by extrapolation of the model should not be taken to be reliable absolute risk values. The limitations on the reliability of risk estimates derived using the model become more pronounced the further the model is extrapolated from the occupational exposure scenarios and data on which it is based. (HSE WATCH committee 2011)

Model predictions 1000 Lifetime (80yrs) Risk per 100,000 100 10 10 11 0.1 0.1 0.01 0.01 0.001 0.001 63.5 75.3 13.8 10.0 4.1 4.5 2.0 2.2 2.7 1.1 Combined risk from mesothelioma and lung cancer 1:100,000 is usually considered minimal risk worst case scenario (<LoQ) (<LoQ) (<LoQ) (<LoQ) Worst Worst case case Worst Worst case case Worst Worst case case Worst Worst case case reasonable scenario (<LoQ) (<LoQ) (<LoQ) (<LoQ) Realistic Realistic Realistic Realistic Realistic Realistic Risk type Air monitoring Realistic Realistic Site Site Data Data Site Site Data Data

Summary Asbestos in soil is NOT A NEW concern Tools are available to help us evaluate the risks from asbestos in soil but none of them are perfect There is lots of uncertainty Procurement of relevant expertise is essential for land owners developers/ regulators; Overly cautious approaches will: Scare lots of people Lead to lots of costly remediation Cavalier approaches may: Put people at real risk of a horrible death Multiple lines of evidence help to balance the uncertainties But we need: New research (e.g. predicting release of fibres from soils, health risks at low airborne concentrations) More guidance (how to work on site, waste issues, how to apply risk models) New government policy (e.g. safe air or soil concentrations)

Keeping in touch paul.nathanail@nottingham.ac.uk Follow me on twitter @cpnathanail Join the contaminated-land-strategies jiscmail forum http://tinyurl.com/bo2kl99 Join the contaminated land management LinkedIn group Nottingham s online masters in contaminated land learn; work & earn http://tinyurl.com/c2ce9om