Assignment 2: Site Assessment by Team Delta

Assignment 2: Site Assessment

By Team Delta

David Seidel Daniel South Doug Sposito
Mary Steffen-Deaton Stacey Stephenson
Rob Walker Andrew Watson



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Solid Waste Management Unit (SWMU)
By Stacy Stephenson

A SWMU is basically any unit and/or area that serves as a storage place for solid waste or has served in the past. They can be as general as an entire building such as a permitted storage building or 90 day area, more defined such as a waste pile with designated perimeters or very specific, such as an underground storage tank. A portion of the ground itself can also be a SWMU if a spill has occurred (http://www.lejeune.usmc.mil/emb/rab/swmu/swmu.htm).

SWMUs can be intentional or unintentional. Regardless of the intent, if an area has seen contamination it could be a SWMU.

To ensure environmental compliance, SWMUs must be indicated and properly inspected. Companies in the field of waste management are aware of the requirements and what is expected as far as reporting but what about the average person with no experience or knowledge of solid waste, hazardous waste, and potential problems and liabilities? This is often the problem when someone wants to purchase land that is potentially dangerous due to contamination.

For example, you find a piece of land that you want to purchase for commercial purposes. Let’s say that the previous owner had drums of waste spill on the ground but didn’t let anyone know. He thinks, “It’s ok. I’ll cover it up, the ground will soak it up and no one will ever know”. The previous owner was responsible for the release and now you, the new owner, will also be liable for contamination on your property. You now have a SWMU.

This is where an Environmental Site Assessment (ESA) comes into play. A phase one is simply looking at the property for indications of contamination and to gather history of a site such as records, reports and conversations with past owners and employees. Since this is a period of gathering and analyzing information, sampling usually is not conducted in a Phase I although it certainly can be. After careful examination of historical data, if there are no indications of contamination and records are accurate, a Phase II Assessment may not be needed. It is always a good idea though to follow through with one if no documentation from previous owners is available stating that no spills and/or contamination occurred and no past sample results are available. Also, be aware of any containers, buildings, or discolored areas of the ground and grass especially if no one can document their use. They could be past SWMUs.

When considering purchasing any site for commercial use, an ESA should be performed. Phase I is the most common type but when dealing with established or potential SWMUs, a Phase II is usually needed. This is the phase that includes sampling such as surface water, groundwater, soils, drums of waste and anything else that may be questionable (keep in mind that not all SWMUs will contain those listed above). Results of a Phase II could indicate that a Phase III is needed as well. This is after sampling and analysis has confirmed contamination and the extent of it must be determined. Phase III is a much more in depth assessment. Often, neighboring property must be assessed and sampled. This stage usually comes into play when remediation of the site is imminent. (Fundamentals of Site Remediation, Second Edition, 2007, John Pichtel, Chapter 5).

SWMUs can easily be “forgotten” without intent because they can be anywhere and of any size that can get overlooked. A complete ESA, although costly, is essential in avoiding future liabilities.


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Field Testing for an Environmental Site Assessment Phase II
By Mary Steffen-Deaton

Once a phase I Environmental Site Assessment (ESA) has deemed it necessary to investigate a property further for contamination or hazard then a phase II ESA will begin. In the phase II ESA investigation, depending on the site, there will be “…extensive field data on soil, subsurface materials, groundwater, vegetation, and other materials on site” (Pichtel, 2007). Field testing will be necessary to acquire the data to determine the type and amount of contamination present at a site.

There are two sampling field methods: passive sampling and active sampling. Passive sampling is just that, passive. It is based on the knowledge of diffusion (Veasey et al., 2005). An example of passive sampling would be if an employee wears a badge clipped to his clothing which contains a sampling medium designed to measure a specific contaminate. Air diffuses and adheres into the badge media then after the monitoring period is over the badge is then sent off for analysis at a laboratory. Active sampling is when a sample is taken by using a pump to extract sample then pushed through a medium which traps contaminates in the medium which can then be sent to lab for analysis (Veasey et al., 2005). Colorimetric detector tubes are one example of active sampling.


For an example of a badge for passive sampling, please go to:
http://www.skcinc.com/prod/500-100.asp


For another example of badge for passive testing, please go to: http://www.leederconsulting.com/enviro_air_analysis_workplace_passive_sampling.html

In Fundamentals of Site Remediation by John Pichtel, he discusses the four common ways to collect active soil vapor samples which are as follows. The first way is to install a borehole. This is done by using a drill or auger which rotates into the ground creating a borehole. The drill or auger is ground into the earth and then a portable instrument probe can be inserted to take readings (Pichtel, 2007). The second and third ways both involve driving a hollow steel probe into the soil in order to collect a sample but they are collected differently. The second way collects the sample by using a “gas-tight syringe and injecting into a field instrument for analysis” (Pichtel, 2007). An example of this method is the use of a direct push technology such as GeoprobeTM to hydraulically extract soil vapor samples which hammers into the ground instead of rotating a drill. The third method collects samples in polyethylene bags which are then analyzed by a portable field instrument. This method is used to analyze headspace of soil or water. The final way is by “direct in-line sampling with a portable analytical field instrument (i.e. PID or FID) from a driven probe” (Pichtel, 2007). In-line sampling tubes can be an easy and inexpensive way of detecting contaminants.

For an example of a GeoProbeTM please go to http://www.rsidrilling.com/?div=rigs

There are many different types of field sampling instruments that can be used during a phase II ESA. Colorimetric detector tubes, photoionization detector (PID), flame ionization detector (FID), and portable chromatograph are most commonly used. Colorimetric detector tubes are small glass tubes containing a color changing reagent inside. A number of different types of pumps can be used to pump air through the tube. Inside the tube, the reagent will color change if it is exposed to a specific chemical and will registering an estimated concentration. This method tests for one contaminate at a time. Colorimetric detector tubes are fairly inexpensive: costing around $30 for a box of ten and easy to follow directions. Advantages to using colorimetric detector tubes are that they provides instant results for a wide range of contaminates, measuring more than 150 contaminates (McDermott and Ness, 2004) and can change sampling contaminates by simply changing a tube (McManus,1999). One big disadvantage is that colorimetric detectors have cross interference with other contaminates that could be present creating a false color change. Another limitation with colorimetric tubes is since a chemical reaction occurs in the tube factors such humidity, temperature and pressure can affect and change the outcome (Veasey, et al, 2006).



For examples of Dräger Pump and Colorimetric Tubes, please see: http://www.cardinalsafetysupply.com/GasDetection.htm

A photoionization detector (PID) is an electronic direct reading instrument. “The PID is a portable, nonspecific, vapor/gas detector employing the principle of photoionization to detect a variety of chemical compounds, both organic and inorganic, in air.” (EPA, 1994). In this method UV lights breakdown the gas or vapor into ions which are collected on plates creating an electrical current. This electrical current is proportional to contaminants in the air sample (Veasey et al., 2006). One advantage to using this device that by switching out the interchangeable lights you can sample different contaminants. A limitation on photoionization is that it doesn’t measure methane, propane or ethane so it is not useful with monitoring light hydrocarbons (Jones, 1993). Also the PID are sensitive to high humidity and temperatures below 50 Fahrenheit working the best in dry climates (Pichtel, 2007).

For an example of a photoionization detector, please see:
http://www.directindustry.com/prod/ion-science/photo-ionization-detector-pid-11667-41831.html

The flame ionization detector (FID) is an electronic direct reading instrument which is similar to a photoionization detector. Like a photoionization detector, a flame ionization detector is a nonspecific detector of organic vapors and gases but a FID uses a hydrogen flame to ionize VOC’s present in the sample (Pichtel, 2007). The flame ionization detector only detects organic contaminates and is most effective on measuring hydrocarbons and flammable constituents. A FID doesn’t respond to inorganic compounds like carbon monoxide, hydrogen sulfide and ammonia (Veasey et al., 2006).

For an illustration of the flame ionization concept, please see:
http://www.etslabs.com/images/methods/11.gif

For an example of a portable flame ionization detector, please see: http://www.envisupply.com/rentals/instruments/FlameIonizationDetector.htm.


A portable gas chromatograph (GC) is a powerful, versatile and portable device. It uses a “…reactive column to analyze and isolate constituents” of a sample in conjunction with a flame ionization detector or photoionization detector system (Pichtel, 2007). A GC is capable of detecting VOC’s, and toxic chemicals. Even though it is portable they can range from the size of a suitcase to large unit and still be very accurate. A GC is generally made up of an injection system, a separator column, and a detector. A sample is injected into the GC where it then is separated in the column and carries the different components at different rates to the detector (Pichtel, 2007). A disadvantage to using the GC method, even though it is fairly easy to maintain, is that it requires a high level of training to use and understand the data output which could result in sampling problems.

For an example of a Voyager portable gas chromatograph, please see:
http://www.photovac.com/Voyager.aspx

References:
EPA. PHOTOIONIZATION DETECTOR (PID) HNU. 1994. SOP#2114
From: http://www.dem.ri.gov/pubs/sops/wmsr2114.pdf

Jones, Frank E. Toxic Organic Vapors in the Workplace. 1993. Page 58. Lewis Publishers, Boca Raton, Florida.
McDermott, Henry J. and Ness, Shirley A. Air Monitoring for Toxic Exposure. 2004. Volume 2. Page 30. Wiley and Sons, Hoboken, New Jersey.
McManus, Neil. Safety and health in confined spaces. 1999. Volume 55, Page 429. Lewis Publishers, Boca Raton, Florida.
Pichtel, John. Fundamentals of Site Remediation. 2007. Page 126,138-139. Government Institutes, Lanham, MD.
Veasey, D. Alan, Lisa Craft McCormick, Barbara M. Hilyer, Kenneth W. Oldfield, Sam Hansen, Theodore H. Krayer. Confined Space Entry And Emergency Response. 2006. Page 62, 64, 68, 75. Wiley and Sons, Hoboken, New Jersey.



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Statistics and EPA Methods
By Rob Walker

In Environmental Remediation, sampling strategy and sampling techniques must be sufficient to minimize the risk of change to the samples. Samples must be handled so that properties do not change and contaminants are not added to the sample. The analytical methods (SW-864 and EPA Methods) must be adhered to in order to maintain quantitative objectives; and regulatory detection limits required by regulatory agencies in addition to proper documentation required. (Office of Solid Waste, 2002) Sampling and analysis results are statistical based and an understanding of statistical concepts and terminology is necessary to fully evaluate data and avoid errors (John P. Maney, 2002) (Quality Assurance Management Staff, 2004) (Office of Solid Waste, 2002)

Statistics is the scientific discipline that allows us to evaluate data. Statistical analysis is used to organize, summarize and draw an effective conclusion from raw data. (Jay Devore & Roxy Peck, 2007) In order to understand statistics a basic understanding of the definitions are needed. A sample is a subset of a population, which is taken from a larger population which represents the larger population for the purpose of estimating properties of the population. (Jay Devore & Roxy Peck, 2007) (Office of Solid Waste, 2002) Simple Random sample: A set of samples from the desired population that have the same probity of being selected. (Jay Devore & Roxy Peck, 2007) (Office of Solid Waste, 2002) Representative sample: A sample of a population which is expected to exhibit similar properties of the sampled population. (Office of Solid Waste, 2002) Bias is a systemic or habitual misrepresentation of sampling, analyzing, or analysis of a sample.
There are three types of sampling bias that can affect your sampling; improper sampling, implementation of a poorly designed sampling plan, Improper handing of sample. Improper sampling can be introduced by careless handing in the field or in the laboratory in the course of selection of and use the use of improper sampling devices for the make up of the sample i.e. taking too small of sample when a larger amount of sample is required. (Office of Solid Waste, 2002) (Quality Assurance Management Staff, 2004) (Jay Devore & Roxy Peck, 2007). The implementation of a poorly designed sampling plan can cause parts of a population to be over represented statistically in the data i.e. not getting a representative sample of the desired population. (Quality Assurance Management Staff, 2004) (Office of Solid Waste, 2002) (Jay Devore & Roxy Peck, 2007). Improper handing of the collected sample can introduce contaminants or loss of contaminants in the field or in the lab, i.e. the improper decontamination of sampling tools between samples. (Office of Solid Waste, 2002) (Quality Assurance Management Staff, 2004).

Analytical Bias is a methodical error caused by calibration drift, instrument contamination, blank contamination, improper instrumentation maintenance, matrix interference, and so on. For example improperly prepared standards will yield analytical bias. A Statistical Bias can occur when the assumptions that are made about the population is not constant with the general population or when the wrong statically algorithm is used to determine the data. (Quality Assurance Management Staff, 2004) (Office of Solid Waste, 2002).

In each Method in SW-864 and EPA Methods they have criteria that help detect and minimize statistical error. The methods designate what matrix, interferences, instrumentation, sample collection and preservation, quality control and precision & accuracy, maximum holding time and sample preservation are needed for that particular method (Lawrence H Keith, 1996/2000) in order to minimize error.

Proper environmental sampling is one of the first steps in developing an environmental site assessment plan. Understanding the importance of sampling statistics and analyzing resulting data in a statistically accurate manor is crucial to proper site clean up. Being aware of the potential statistical errors such as sampling bias, analytical bias and statistical bias will minimize errors in environmental sight assessments.

References
Jay Devore, J. D., & Roxy Peck, R. P. (2007). Statistics The Exploraton and Analysis of Data (3rd). Pacific Grove CA: Duxbury Press.
John P. Maney, J. P. M. (2002, October 1). Optimization Data Collection Design. Enviromental Science & Technology.
Lawrence H Keith (Ed.). (2000). Compilation of EPA's Sampling and Analysis Methods (2nd ed.). New York: Lewis Publishers. (Original work published 1996)
Office of Solid Waste. (2002, August). Planning, Implementation, and Assessment. RCRA Waste Sampling Draft Technical Guidance. www.epa.gov/osw: United States Environmental Protection Agency.
Quality Assurance Management Staff. (2004, September). Guidance For The Data Quality Objectives Process Final. EPA QA/G-4: United States Environmental Protection Agency.

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Environmental Site Assessment
Health and Safety Plan (HASP)
David J. Seidel

Introduction
One of the key requirements of phase 1 environmental site assessments, cited in Pichtel, is to ensure worker and public safety via exposure to soil, water, and air contamination. This is accomplished principally by the preparation and implementation of a Health and Safety Plan (HASP) for the remediation site.

Health and Safety Plan
A Health and Safety Plan (HASP) is required for work at any remediation site. The Health and Safety Plan is required as a supplement to the site sampling plan. A HASP is required for work at sites that have identified contamination. The HASP is required to ensure that site activities are protective of worker and public health from acute and chronic exposures to toxic chemicals during site remediation. Medical surveillance procedures, air monitoring procedures for site activities and required personal protection equipment, are some of the vital subjects specified in the plan.

The Site-Specific HASP
OSHA, 29 CFR 1910.120 (b), requires that a site-specific HASP be developed and reviewed by qualified contractor personnel for each remedial action. Subcontractors can modify the plan to cover their own work; however, their plans have to be incorporated into the general site plan. Only one HASP is applicable to a specific remediation site. The HASP must be kept on site and be available for review by employees, emergency response personnel, or employee representatives.

The plan should be based on specific characterizations, anticipated hazards and the anticipated work conditions at the remediation site. OSHA requires that the plan include the following elements:
(1) A safety and health risk or hazard analysis for each site task and operation found in the work plan.
(2) Employee training.
(3) Personal protective equipment for each task or operation.
(4) Medical surveillance.
(5) Frequency and types of air monitoring, personal monitoring, environmental sampling techniques, instrumentation, and methods to be used.
(6) Site control measures.
(7) Decontamination procedures.
(8) An Emergency Response Plan.
(9) Confined Space entry procedures
(10) A spill containment program.

Health and Safety Plan Improvements
Feedback or communications from safety meetings, training and routine inspections can be used to amend and improve the HASP. The HASP should outline procedures for response to health and safety inquiries and for modification of operations. The OSHA worker protection standard does require on-going inspections or monitoring. These efforts may require changes to the HASP. Modifications to the HASP should be drafted by the professional staff, such as the prime contractor’s industrial hygienist or safety engineer and could be approved by the site construction manager or other line management.

OSHA HASP Compliance Issues At Remediation Sites
In 1992 the Occupational Safety and Health Administration (OSHA) teamed with the Environmental Protection Agency (EPA), to form the EPA/Labor Superfund Health and Safety Task Force. Over a 34-month period, the task force reviewed the safety and health plans of eighteen Superfund remediation sites and conducted comprehensive site safety and health audits of the contractors’ programs. Audits assessed a remediation site's implementation of OSHA's Hazardous Waste Operations and Emergency Response standard (HAZWOPER, 29 CFR 1910.120), and team members reviewed each contractor's written site safety and health plan. FindingsThe site health and safety plan was found to be a major source of citations at remediation sites. Audit teams looked at many plans that had been developed during the early phases of a project, before worker exposures had been characterized. The plans hadn’t been updated, so the listed exposure levels, work practices descriptions, monitoring protocols, and site PPE requirements did not reflect the current conditions on-site. Other inaccuracies included descriptions of the site organizational structure and lists of emergency contacts. HASPs containing adequate site exposure data usually lacked other site-specific detail. General statements about safety and health practice were common in sections rather than necessary detailed descriptions of the actual site safety and health practices that addressed subjects like heat stress, decontamination, and spill containment. Every written plan that was reviewed contained inadequate job hazard analysis. Overly broad categorization of site tasks was common place. The hazards associated with site tasks were also described in broad terms, such as exposure to contaminated materials or slips, trips, and falls, offering no specificity. Also, none of the written plans provided hazard analyses for site maintenance tasks, which are often some of the most hazardous jobs in site remediation operations. The hazard analyses were deemed to be of little value to safety and health professionals who need to recommend engineering control measures, or to workers who will require training on the specific site hazards associated with their jobs. Some required HASP elements were often found to be left out altogether. For example, in many of the HASPs reviewed, the requirement for a spill containment program, as required in HAZWOPER paragraph (b) (4) (ii) (J), was ignored.

Recommendations
Throughout the project life of a remediation project, the contractor's written safety and health plan should provide an accurate, detailed description of the contractor's safety and health practices at that site. The use of boilerplate documents should be avoided, replaced instead, with accurate job hazard analyses that are developed for each site task or operation. Before completion of the first draft of a HASP, the contents should be compared with the list of required elements in HAZWOPER paragraph (b) (4) (ii) (A-J) (listed above). The plan should be a working document, with both the job hazard analyses and the safety and health requirements that are based on the hazard analyses that is updated regularly. An up-to-date written HASP documents current safety and health practices and can be used by contractors as a checklist to ensure that effective site safety and health practices are being maintained.

References
1. Pichtel, John. Fundamentals of Site Remediation, 2007, Pg.107, Government Institutes, Lanham, Maryland
2. http://www.osha.gov/SLTC/hazardouswaste/osha.html site last visited on 5 October 2009
3. http://www.epa.gov/superfund/cleanup/pdfs/rdra/health.pdf site last visited on 5 October 2009
4. http://books.google.com/books?id=hIelz286mpQC&pg=PA170&lpg=PA170&dq=Remediation+Sites+Health+and+Safety+Plan&source=bl&ots=SYZ35C47bC&sig=a9ytPHeO6_v96A_Eu0wzwJaUZ6E&hl=en&ei=qOLJSuDRH4vQtAOxxoGiBQ&sa=X&oi=book_result&ct=result&resnum=6#v=onepage&q=Remediation%20Sites%20Health%20and%20Safety%20Plan&f=false site last visited on 5 October 2009

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Asbestos
By Andrew Watson

History of asbestos
Asbestos is a natural occurring mineral that has both strength and fire retardant properties. Asbestos has been used in a variety of building materials such as, roofing shingles, ceiling and floor tiles, insulation, and drywall products. Asbestos has also been used in the automotive industry in brake pads/shoes, clutch pads (standard shifting automobiles), gaskets, and transmission components. The use of asbestos goes back as far as 2500 B.C where people mined asbestos to mix into mud and applied it to woven stick walls to keep out wind and rain. Around 500 B.C, a young Roman Senator and author, Pliny the Younger, wrote about the direct correlation of mining or working with asbestos and serious health effects it had on workers (OSHA webpage, 2009). Now in the 21st century, we have scientific proof that asbestos can cause serious health problems when microscopic asbestos fibers are inhaled into the lungs.

Asbestos Types
There are six types of asbestos; Chrysotile, Tremolite, Actinolite, Anthophyllite, Amosite, and Crocidolite. Although, six types of asbestos were being mined and used, Chrysotile and Tremolite were used the most in the manufacture of building supplies and materials in the United States (Ehow.com, 2009).

Health Affects
Exposure to airborne asbestos may lead to serious illnesses and prolonged exposure can eventually cause death. The three main types of illnesses are:

Asbestosis – Scarring of the lung tissue due to asbestos fibers irritating lung tissue. The scarred lung tissue does not allow proper oxygen transfer inside the lungs.

Lung Cancer – Largest type of illness related to exposure to asbestos. Most affected are people in the mining, milling and manufacture of asbestos.

Mesothelioma – Rarest type of cancer related to exposure to asbestos but it affects other organs other than just the lungs. The thin membrane that surrounds the lungs, abdomen, heart, and chest are affected from exposure to asbestos and symptoms do not show up until later in life (Rhode Island Department of health, 2009).

Asbestos Regulations
Asbestos use in products was at its peak during the late 19th century and as more people began to get sick with lung disease and illnesses, the use of asbestos in products needed to be reduced and eventually eliminated. From 1973 to 1978, the Environmental Protection Agency (EPA) banned the use of asbestos from sprayed fireproofing/ insulation, pipe and block insulation used for boiler and hot water tank installations, drywall board, and drywall spackling. Ten years later, the EPA banned the use of asbestos in corrugated paper, commercial paper, flooring felt, and any new uses for asbestos. Although the EPA banned asbestos use in a number of products, they also continued to allow its use in certain applications. The EPA allowed asbestos use in cement boards, fire proof clothing, roof felt, floor tile, transmission products, disk brake pads, drum brake linings, gaskets, and roof coatings (Colorado Department of Public Health & Environment, 2009). The list of approved products that use asbestos have been greatly reduced with the advancement of new technologies and products that have similar strength and fire proof characteristics like asbestos. However, some products that we use today are still produced with asbestos until a cost effective alternative is invented or improved upon.

In 1986, the Asbestos Hazard and Emergency Response Act (AHERA) was enacted to protect school children from asbestos. This act mandated all schools, public and private, to inspect their school building for asbestos containing building materials (ACBM) (Rhode Island Department of health, 2009). To properly inspect the school buildings, trained and certified inspectors were required to look for suspect materials, identify suspect materials, obtain samples, and send samples to an approved lab for testing. Also, if the building did test positive for asbestos, the building owner or designated person is required to create a management plan to manage the asbestos in place or abate it. Asbestos that is managed in place; reinspection is required every six months, and all inspections have to be well documented. In addition to the management plan, the building owner or designated person needs to provide asbestos awareness training to maintenance and custodial workers and label areas that contain asbestos (EPA, 2009).

Suspect materials
Suspect materials in a building are anything that is friable. Determining friability is quite simple; anything that a person can crush or break apart with hand pressure is friable. During an inspection, building inspectors are required to touch all suspect materials (by hand) to determine if they are friable. Building inspectors typically suspect: drywall board, drywall joint compound, joint tape, texture, ceiling tiles, floor tile, sheet vinyl, cove base board, carpeting, floor tile, tile mortar, tile grout, window /door caulking, roof shingles, roofing cement, roofing felt paper, concrete, stucco, bricks, blocks, piping insulation or ductwork insulation. Suspect material that are not friable, still get inspected and are not typically sampled during an AHERA inspection. The only exempted building materials from inspection are wood, metal, and glass (EPA, 2009).

The inspection
Asbestos building inspectors must be trained and certified by an EPA approved training facility. Inspectors must pass certification tests, receive a certificate, and be provided with an EPA identification number and badge. The certified inspector has to collect samples in a random order which represents the homogeneous area and the sample size needs to be at least one centimeter squared. All samples must be packaged separately from other random samples; no consolidated samples are acceptable. A homogeneous area is an area which exhibits the same characteristics. For example, carpeting inside a building typically is the same texture, color, and installed in the same manner; all the carpeting would be homogeneous. Now, the correct numbers of samples need to be taken. If the carpeted area is less than 1000 square feet, three random samples need to be taken. If the carpeted area is greater than 1000 square feet but less than 5000 square feet, five random samples need to be taken. If the carpeted area is more than 5000 square feet, seven random samples need to be taken. The number of samples for piping insulation is different than other flat surface materials. Three random samples need to be taken for suspect piping insulation and fittings such as tees, elbows, and valve bodies (EPA, 2009). Once the sampling has been completed, the inspector will send them to the lab for analysis and document the results in an inspection report. Analysis typically takes 3-5 business days for results.

Testing
Suspect asbestos samples must be sent to an approved lab which is accredited by the National Bureau of Standards (NBS) for polarized light microscopy (PLM) analysis (EPA, 2009). Polarized light microscopy is mostly used for detecting asbestos because it is an effective and inexpensive analysis. PLM uses light which passes through crystals or fibers and the definition can be refined by using different type of filters. As the light passes through the sample, it is compared with known mineral species to detect a match. If a direct match cannot be determined, a more advanced testing method can be used such as, Scanning Electron Microscopy (SEM) or Transmission Electron Microscopy (TEM) to determine if the fibers are asbestos or not. If the sample has greater than one percent of asbestos, the sample is considered positive for asbestos containing materials (ACM) and all homogeneous areas the sample represents is also considered positive. EPA considers samples containing less than one percent not to be containing asbestos (Fiber quant webpage, 2009).

Final Report
Asbestos building inspectors are required to generate a final report stating the building(s) that were sampled, locations where samples were obtained, sample testing results, and provide any recommendations to the building owner or designated person in charge of the building. Also, the building inspector must include a copy of his credentials indicating that licensing and certification is up to date at the time of inspection. If no asbestos was present in any of the locations, the report must be filed, made available to any employee or occupant of the building, and the owner must reinspect the exact locations every three years. However, if asbestos was present, the building owner or designated employee may choose to manage the asbestos in place (if locations are not severely damaged) or abate it.

Conclusion
Asbestos is an inexpensive mineral that was integrated into a variety of products and in doing so, products lasted longer and provided better protection than before. Unfortunately, asbestos had a serious downside to it; it made people very sick. Although asbestos exhibited beneficial properties, peoples’ health outweighed what asbestos could do for mankind. Even though the United State passed laws banning asbestos in certain products, it is imperative that buildings are inspected because other countries, which we import from, have not passed laws banning asbestos in building materials. So, the new house or commercial building being built down the block may contain asbestos.

References:
http://www.cdphe.state.co.us/ap/asbestos/asbestosbans.pdf

http://www.ehow.com/about_5373857_types-asbestos.html?ref=fuel&utm_source=yahoo&utm_medium=ssp&utm_campaign=yssp_art

http://www.epa.gov/asbestos/pubs/2003pt763.pdf

http://www.fiberquant.com/asbestos.htm
http://www.health.ri.gov/environment/occupational/asbestos/schools.php
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10005








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Some Lessons from a Phase II Investigation: A Personal Account
By Dan South

There are many things that need to be considered when conducting a Phase II Investigation including things that may be unique to the site. For example, I participated in a Phase II investigation of the Pueblo Chemical Depot (PCD) in Pueblo, Colorado that left me with a lot of lessons learned. The official report of this Phase II investigation is found in the report entitled Phase II Site Investigation, Pueblo Chemical Depot SWMUs 12 & 13, Harding Lawson Associates, 1996, that was submitted to the United States Environmental Protection Agency.

Let me give you a little background first. PCD is an active military installation whose primary mission is to store and eventually destroy thousands of chemical munitions. Being an active facility, it is governed by the rules of the Resource Conservation and Recovery Act (RCRA) and its many contaminated areas are divided into solid waste management units (SWMUs). One that I had been involved with concerned a burial site for old munitions. Sometime back in the 1950’s and 1960’s, the army had buried an unknown number of munitions that may have included mustard agent bombs. Our job was to assess whether the munitions were contaminating the environment.

In order to gather the information we needed to make that assessment we had to collect subsurface soil samples and groundwater samples for analyses. It doesn’t sound difficult, just grab some soil and drill into the water table for some groundwater. Well, it turned out to be a bit more complicated than that.

The first item to be accomplished in the field was to clear the surface of any munitions. When the Army sent people out to bury the bombs, apparently they weren’t always attentive and some bombs fell off the truck. We hired munitions specialists to come and clear the surface. They found several bombs on the surface, removed them, and pronounced the area clear. This is the first lesson: when it comes to your safety, don’t completely rely on others. Within a few days of declaring the surface clear I found another munition partially buried right in our work area. This shut down work for another day. Finally they declared the site cleared again and we went back to work. Twice more during the project we found munitions on the surface that shut us down again.

The second task was to locate the buried munitions so that we did not drill right into them. A geophysicist came to the site and performed a geophysical survey including a magnetic survey and resistivity survey to give us an idea of where the munitions were buried. One source for more information on geophysical techniques is located at http://www.swri.org/4ORG/d20/home/expertise/gpserv.htm.

Now that we knew where to drill, we arranged for the use of a hollow-stem auger drilling rig. Just like we saw in lecture, we used split spoon samplers to collect the soil. Again, due to the site safety concerns we had to arrange some special procedures. The munitions specialist used special magnetometers to scan ahead of the drill bit. This was to avoid drilling into a buried bomb which would ruin our day. They would clear two feet below the bit and then the drillers would sample that two feet with a split-spoon and then drill to that depth. The drill rig would then pull out its augers and back off fifteen feet so that the next two feet could be cleared. The sequence would resume and the hole was cleared for two more feet, the drillers would sample and drill that two feet and then pull off. The sequence repeated for twenty feet and after that depth the munitions personnel were no longer needed. More than once the sensors would detect some metal and the borehole would have to be abandoned and we would offset to start again. This clearance of every two feet significantly slowed down the drilling operations, and of course, time is money so the cost of the investigation jumped. This is the next lesson: look at the operation and try to find beforehand what aspects are going to cause delays.

There was a second drag on production during drilling. Each two-foot sample of soil that came up had to be brought over to a mobile chemical agent detection unit. This mobile lab would bring its sensors over the sample checking for any chemical agent. If it had a positive response then our sample was confiscated, the operation was shut down and we had to clear the site until further testing confirmed or cleared the preliminary detection. At least twice our operation was shut down for most of a day while false positives were cleared. For more information on chemical agents, see http://www.bt.cdc.gov/agent/agentlistchem.asp.

Once the sample was cleared by the lab we could bottle it or describe the sample in our boring logs. The soil was thoroughly mixed and put into appropriate jars for the different analyses that were required and labeled. The jars were then put into an iced cooler for delivery to a laboratory. As for the logging of the sample, there are preferred ways of doing that as well. The color, type of material, grain size, moisture content, structure, and suspected origin are recorded in the few minutes before something else requires your attention. This is another lesson: Concentrate hard and work as fast as you can or you’ll get swamped.

Finally we would reach bedrock. In this case it was a hard shale that served as a fine aquitard. We could now build the monitoring well. The augers were removed and a wooden plug was put into the tip of the lead auger. The borehole was re-drilled and the bit brought to the depth the geologist had decided should be the bottom of the borehole. The appropriate screen was measured and attached to the riser and placed in the augers. The casing was then used to knock out the wooden plug. When you are building a well, the casing is put into the desired position and suspended while the drillers pour in the sand that will make the filter pack. If the drillers pour the sand too quickly it can form a blockage leaving a void around the screen. If the water is muddy, the sand can remain suspended so that too much sand is added. This is very important if the zone in which the well is being installed is a confined aquifer because it may allow a passage for contamination from one zone to another. The sandpack is brought up to the desired level, usually one to two feet above the top of the screen. A bentonite seal is then installed above the sandpack. Bentonite is a type of clay that swells greatly when hydrated. It serves to seal off the layers above the screen and to prevent any cement which is added next from reaching the screen. The cement seals the well from water infiltration from the surface. Sometimes a bentonite grout slurry is used instead of cement for this stage. Once the cement or bentonite has set, the wells are surged and developed for proper flow. For more information on well installation, you can see the following: http://www.pdhcenter.com/courses/c168/c168.htm. It has a link to a PDF file of the US Army Corps of Engineers Manual, "Monitoring Well Design, Installation and Documentation at Hazardous, Toxic and Radioactive Waste Sites", EM 1110-1-4000 (1998 Edition, 51 pages).

At PCD, we also wanted to collect groundwater samples to assess any impact on the groundwater. This portion of the operation was uneventful and each well was purged of three casing volumes with a stainless steel bailer and sample was collected and placed into appropriate bottles. For more information on groundwater sampling, please see Ground-water Sampling Guidelines for Superfund and RCRA Project Managers at http://www.epa.gov/tio/tsp/download/gw_sampling_guide.pdf

There were a few other items that affected the performance of the Phase II investigation at PCD. Field personnel had to wear protective level C at the site which includes a paper cover-all, rubber boots, two pairs of rubber gloves, and a face mask with breathing cartridge filters. It was summer time and heat stress was a significant danger. In summer at PCD there was another danger: rattlesnakes. We encountered two or three rattlesnakes during our activities. This is another lesson: Think how the environment you will be working in changes with seasons or time.

The Phase II assessment concluded that the buried munitions had not affected the environment. The last I had heard the site was to be excavated and the munitions removed, but I have not heard whether that has actually occurred yet.
This has been a personal account of work on a Phase II Investigation and a few of the lessons that I came away with. Conducting a Phase II investigation can be fun and rewarding, but it must be planned and executed with thoughtful awareness.

For more information on chemical munitions, see the US Chemical Materials Agency at http://www.cma.army.mil/home.aspx.

For more information on the RCRA clean-up at PCD, see the Hazardous Materials and Waste Management Division, Pueblo Chemical Depot, Chemical Demilitarization Program at http://www.cdphe.state.co.us/HM/pcd/index.htm.

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Arizona’s Voluntary Remediation Program
By Doug Sposito

Arizona revised Statutes Title 49 article 5 describes the states Voluntary site Remediation Program (VRP), it was established on April 10th 2000 to provide for the redevelopment or other use of parcels of land or water that have soil contamination[i]. This program can only consist of a maximum one hundred sites across the state.

The statute allows private property owners to clean up hazardous sites with the cooperation of the Arizona Department of Environmental Quality (ADEQ). Its purpose is to encourage and facilitate by providing assistance through a remediation specialist and a single point of contact at ADEQ for the property owner.

On completion of the site remediation the remediation specialist has to give to the property owner a document that states that no further action is required to remediate the known releases on the site and states that the work was performed in compliance with federal and state law, rules and regulations. A copy of this document is also provided to ADEQ.

The remediation specialist also provides the department with signed and sealed copies of all relevant documentation on the remediation including test results and other reports, all of which will be maintained as public records in the department of environmental quality[ii].

There are two programs under Arizona’s current laws[iii]:

The VRP which enables the eligible volunteer to conduct a remediation to cleanup a site under ADEQ guidance and

The Greenfield’s Pilot Program that provides opportunities for parties not currently subject to enforcement action to perform soil remediation actions and clean ups under third party oversight.


The volunteer’s actions must be consistent with all applicable ADEQ laws to insure “How clean is Clean”.[iv]

The VRP is a reimbursement based program and applicants are billed for the direct oversight costs once the application has been accepted.


The major provisions of Arizona’s VRP are:

Eligibility Any person may request VRP oversight where a notice of violation has been issued and there is no financial assistance through the State Assurance Fund (SAF) and no judgment has already been entered (not voluntary).
Application Must cover general site information and remediation objectives
Access Legal access must be granted to the ADEQ during activities
Reimbursement A VRP participant must reimburse the state for all costs reasonable and necessary to review the remedial actions and pay a $2000.00 application fee.
Closure The participant will issue closure documents that state the level of cleanup achieved and the standards met. These documents are transferable if the property is sold.

The Greenfields pilot program is intended to allow for the redevelopment or other use of parcels of land that have soil contamination, including parcels that are abandoned or vacant or that could become productive commercial, industrial, agricultural, residential or recreational sites after remediation. Through voluntary participation by property owners, the program is intended to encourage the cleanup of sites that might otherwise not be remediated[v].

If a site is accepted into a Greenfields program the participant must publish a notice of the planned remediation in a local newspaper along with remediation notices posted at the site.

The major provisions of Arizona’s Greenfields program are:

Eligibility
The site must be certified by a Certified Remediation Specialist (CRS) to contain only soil contamination that has not impacted ground water. The site must not be subject to current criminal nor civil actions.

Application
The application must cover general site information and remediation objectives.

Access
Legal access must be granted to the ADEQ during activities and will be terminated 180 days after completion of remediation.

Reimbursement
A Greenfields participant must pay a $2200.00 when the CRS submits application. A participant must reimburse the state for all costs reasonable and necessary to review the remedial actions.
Closure The participant will issue closure documents that state the level of cleanup achieved and the standards met. The CRS must prepare a document of No Further Action (DNFA). These documents are transferable if the property is sold.

Audit
If the ADEQ determines that remediation was not performed in accordance with the DNFA and other required submittals the DNFA can be revoked.

ADEQ has established a risk based standard that allows the participant to select from three different approaches for determining the appropriate soil remediation level:

Soil Remediation Levels (SRL) SRL’s are predetermined standard corresponding to a fixed level of human risk posed by the contaminated soil. The participant can decide to remediate to a more protective residential standard or less protective non-residential depending on how the property will be used.

Site specific Risk Assessment levels A customized approached that allows the participant to develop site specific remedies that still protect human health

Back ground levels Allows a site to be cleaned to levels consistent with natural background levels of contaminants.

The SRL’s allow flexibility for the participant to select a remediation standard suited for the use of the property while maintaining a standard that is protective to human health.


[i] ARS 49-171
[ii] ARS 49-154
[iii] Todd S. Davis, Edition “Brownfields: a comprehensive guide to redeveloping contaminated property”,Second Edition American Bar Association, 2002
[iv] Arizona Administrative Code 18-7-201
[v] ARS 49-104-12

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[1] ARS 49-171
[1] ARS 49-154
[1] Todd S. Davis, Edition “Brownfields: a comprehensive guide to redeveloping contaminated property”,Second Edition American Bar Association, 2002
[1] Arizona Administrative Code 18-7-201
[1] ARS 49-104-12