SOP_26_Asbestos_Inspection_Procedures_04-10.pdf

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SOP NO. 26

Standard Operating Procedure For

ASBESTOS INSPECTION PROCEDURES

FOR SURFACE AND SUBSURFACE SOIL

Denver Federal Center Site-Wide RCRA Facility Investigation

Prepared for:

General Services Administration

Rocky Mountain Region Denver, Colorado

Prepared by:

ECC/PWT/CDPHE/GSA

April 2010

Revision 7.0

Denver Federal Center SOPs Revision No. 7.0

April 2010 Page i of iii

SOP NUMBER 26 ASBESTOS INSPECTION PROCEDURES FOR SURFACE AND SUBSURFACE SOIL

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1.0 PURPOSE AND SCOPE............................................................................................... 26-1

2.0 PERSONNEL QUALIFICATIONS .............................................................................. 26-1

3.0 MATERIALS AND EQUIPMENT............................................................................... 26-2

4.0 PROCEDURES.............................................................................................................. 26-3

4.1 INSPECTION PROCEDURES FOR SURFACE ASBESTOS ................................ 26-3

4.2 SAMPLING OF SUSPECT ASBESTOS MATERIAL ............................................ 26-4

4.2.1 Inspection Only (No Hand-Removal) – For Determination of the Presence of Asbestos on the Surface ..................................................................................... 26-4

4.2.2 Inspection and “Pick and Go” – For Potential Clearance for Asbestos on the Surface ............................................................................................................... 26-5

4.3 POST INSPECTION ACTIVITIES FOR SURFACE ASBESTOS.......................... 26-7

4.4 INSPECTION PROCEDURES FOR SUBSURFACE ASBESTOS

(TRENCHING).......................................................................................................... 26-7

5.0 DOCUMENTATION .................................................................................................... 26-9

6.0 VEHICLE ACCESS AND DECONTAMINATION PROCEDURES ......................... 26-9

List of Attachments Attachment A Asbestos Material Sample Field Data Sheet – Form 26-A1

Asbestos Surface Soil Sample Field Data Sheet – Form 26-A2

Asbestos Subsurface (Trench) Soil Sample Field Data Sheet – Form 26-A3

Attachment B Surface Asbestos Grid Inspection Form – Form 26-B1

Subsurface Asbestos Trench Inspection Form – Form 26-B2

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REVISION LOG

Revision Number Description Date

0.0 Original SOP No. 26 (prepared by

ECC/PWT/CDPHE/GSA)

May 2000

7.0 SOP No. 26 April 2010

April 2010 Page iii of iii

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LIST OF ABBREVIATIONS AND ACRONYMS

ACS Asbestos-contaminated soil AM Asbestos Material AHERA Asbestos Hazard Emergency Response Act BGS Below Ground Surface DFC Denver Federal Center FSP Field Sampling Plan SOP Standard Operating Procedure CDPHE Colorado Department of Public Health and Environment EPA United States Environmental Protection Agency PLM Polarized Light Microscopy PPE Personal Protection Equipment SSHO Site Safety and Health Officer

April 2010 Page 26-1 of 26-20

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1.0 PURPOSE AND SCOPE

This Standard Operating Procedure (SOP) provides technical guidance and methods that will be used to identify, inspect, and investigate both surface and subsurface soils when asbestos material is suspected or discovered during excavation(s) or RCRA Facility Investigation projects at the Denver Federal Center (DFC). This SOP serves as a supplement to the Investigation Area specific work plans and Field Sampling Plans (FSPs) and is intended to be used in conjunction with other existing DFC SOPs.

Prior to any additional activities (e.g., subsurface and/or surface soil investigation) on those areas slated for inspection for the presence or absence of AM and/or ACS, the AM or ACS inspection or investigation must be completed. Only with approval from CDPHE may other activities occur on areas slated for AM or ACS inspection/investigation.

This SOP is not to be used for remediation of asbestos-contaminated soil (ACS), which typically involves more complex and tailored procedures. Remediation of ACS will be conducted under a site-specific Corrective Measures Work Plan (CMWP) submitted in accordance with GSA’s Compliance Order on Consent and approved by CDPHE.

Asbestos abatement that is associated with intact facility steam lines and ancillary equipment and other asbestos-containing utilities is not covered by SOP No. 26, but rather under Colorado Air Division Regulation 8 (5 CCR 1001-10, Regulation No. 8 - The Control of Hazardous Air Pollutants, Part B - The Control of Asbestos).

2.0 PERSONNEL QUALIFICATIONS

Personnel overseeing, directing, inspecting and/or handling asbestos material or ACS (including suspect asbestos material) will have at a minimum, the following qualifications:

• A current United States Environmental Protection Agency (EPA) and Asbestos Hazard Emergency Response Act (AHERA) compliant 40-hour worker or Contactor/Supervisor certification.

• A current EPA/AHERA compliant 8-hour refresher course certification.

• A current annual physical with medical release/respirator usage form.

• A current Colorado State Asbestos Building Inspector Certification with a minimum of six months of experience in asbestos-contaminated soil management (Inspectors only).

• All required certificates and licenses will be in accordance with the provisions set fourth in Colorado Air Quality Control Commission Regulation No. 8.

• Meet the requirements of CDPHE’s asbestos in soil regulations (6 CCR 1007-2, Part 1 - Regulations Pertaining to Solid Waste Sites and Facilities, Section 5.5 - Management of Asbestos-Contaminated Soil).

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Ancillary personnel not directly performing fieldwork such as QA/QC oversight staff, management, and GSA project staff are required to attend an asbestos awareness class prior to initial visit of the site.

All personnel working on the site will be advised and directed to not disturb areas (unless doing asbestos inspections under Section 4.0) where suspected or known asbestos is present. Personnel driving onto the site to perform inspections or an oversight management roll will be notified of suspect or known asbestos locations and directed to not drive on or otherwise disturb those areas.

3.0 MATERIALS AND EQUIPMENT

The following materials may be needed during the course of discovery, inspection, or investigation of asbestos material or ACS:

• Appropriate field monitoring instruments (high and low flow air sampling pumps, personnel pumps, wind meters, polarized light microscopy (PLM) microscopes, etc).

• Camera (35 millimeter or digital), field logbooks.

• Personal Protective Equipment (PPE) and cold weather gear as required.

• Tape measure and pin flags.

• GPS equipment.

• Garden trowel (s) and/or rakes.

• Shovels, wheelbarrow.

• Garden sprayers.

• Marked (label stating, “Caution –Contains Asbestos. Avoid opening or breaking bag or container. Breathing asbestos may cause serious bodily harm.”) 6 mil polyethylene disposal bags, sample bags, generator labels, and manifests.

• Heavy plastic sheeting.

• Soil sampling supplies (sample containers or plastic bags, labels, chains-of-custody, coolers, collection bowl, decontamination supplies).

• Suitable lab/sample reading area.

• Documentation forms (inspection forms, soil sample field data sheets, logbook, site sample maps).

Larger investigation projects such as trenching may require additional equipment such as a backhoe, trailer-mounted sprayers, or water trucks for more extensive dust control measures, and investigation-derived waste (IDW) containers such as roll-off bins or drums with single or double plastic liners.

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4.0 PROCEDURES

Upon initial discovery of any suspected asbestos, field personnel who are not Asbestos Building Inspectors will immediately stop work and notify a supervisor. Field personnel will take actions necessary to assure that the suspect material is not disturbed while waiting for appropriately trained personnel to arrive on site. Field personnel shall stake, flag, demarcate or measure and mark on a map the suspect materials and warn crews to avoid that area until directed otherwise.

The appropriately trained asbestos superintendent or inspector (see Section 2.0) will handle activities beyond initial discovery including but not limited to:

• Conducting inspections to assess the presence and extent of asbestos.

• Documenting, collecting, packaging, and transporting suspect asbestos.

• Directing qualified personnel to conduct items mentioned above.

At a minimum, appropriate PPE must be worn when doing asbestos inspections or otherwise accessing an area suspected or known to contain asbestos. GSA requires at a minimum that personnel performing the inspection and/or pickup of nonfriable asbestos must wear disposable booties and rubber gloves, which should then be discarded as asbestos waste prior to exiting the site. GSA requires at a minimum that personnel completing the pickup of friable asbestos and the associated 3 CY of soil must wear disposable outer protective clothing, booties and rubber gloves, which should then be discarded as asbestos waste prior to exiting the site. Additional personal protective requirements may be required as determined by the contractor's health and safety officer. See Section 6 of this SOP for personnel and equipment decontamination procedures.

Inspections for visible asbestos must be conducted when the soil surface being inspected is dry.

The inspections must also be conducted when there is adequate lighting. Avoid early morning or late afternoon inspections if shading becomes a problem.

All inspection and investigation procedures within a 100 ft of friable asbestos material or asbestos contaminated soil in this SOP must cease when any of the following wind stoppage criteria are met, in order to limit potential exposure to workers and airborne emissions of asbestos from the site:

• Any wind gust reaches or exceeds 20 miles per hour as determined by a hand-held meter;

• Sustained wind speeds reach or exceed 12 mph averaged over a period of 10 minutes;

• Winds produce visible emissions or create movement of dust or debris in or near the work area; or

• Winds impact the ability of engineering controls to work as designed.

4.1 INSPECTION PROCEDURES FOR SURFACE ASBESTOS

This section describes the procedures for surface asbestos inspections, AM collection, and clearance, which were developed in accordance with 6 CCR 1007-2, Part 1, Section 5.5 -

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Management of Asbestos-Contaminated Soil and the “Asbestos-Contaminated Soil Guidance Document” (April 2007).

Details of the surface asbestos investigation will be contained in a site-specific FSP or other work plan. In general, one of two different approaches will be specified. The first approach (Section 4.1.2) consists of a visual inspection only, for the presence of asbestos materials on the surface, with no hand removal of asbestos material. The second approach (Section 4.1.3) consists of the visual inspection and limited hand-removal or “pick and go” of asbestos material for potential clearance for asbestos on the surface.

Prior to conducting a surface inspection for asbestos, the area of concern will be gridded out.

The number of grids and the grid dimensions must be preapproved by GSA and CDPHE and the contractor must obtain a site map from GSA with the numbered grid overlay on it prior to proceeding. Following approval, the grid system shall be staked in the field and the inspection conducted in accordance with the following procedures (Section 4.1.1 through 4.1.3):

4.2 SAMPLING OF SUSPECT ASBESTOS MATERIAL

A. If the Asbestos Building Inspector encounters materials that are suspect of containing asbestos, the contractor is required to collect representative samples of each type of the material(s) for analysis.

a. Adequately wet the suspect material to be sampled and immediate surrounding soil. Collect the suspect asbestos material and place it in appropriate sample containers such as sample bags or jars.

b. Submit the material(s) for analysis to a certified asbestos lab for PLM analysis using proper chain-of-custody protocol.

c. Take digital photos of the suspect asbestos materials. Complete a photo log for each type of suspect asbestos material sampled. The photo log shall contain the grid location, date and time of each sample, a description of the suspect asbestos material and degree of friability, and the laboratory results. The photos shall be close-ups that would allow a 3-inch piece of suspect material to fill the camera view frame and be in focus. A scale shall be included in each photo.

d. For each AM sample collected, completely fill out Form 26-A1 (Attachment A).

B. Based on the analysis conducted in A above, along with inspection results where known asbestos materials were found, the Asbestos Building Inspector shall make a determination as to whether each grid inspected contains visible asbestos material. This information will be documented in accordance with Section 5.0 of this SOP.

4.2.1 Inspection Only (No Hand-Removal) – For Determination of the Presence of Asbestos on the Surface

(This subsection is not to be used unless specifically required by the contractor's SOW.)

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A. Conduct shoulder-to-shoulder visual inspection of each grid. At a minimum, each grid must be completely inspected in two directions, which are perpendicular to each other.

This may be accomplished by multiple inspectors at arms length inspecting the surface together, or a single inspector. However, a single inspector must make more transects than multiple inspectors do. A single inspector's area of vision is no more than 5 ft meaning a minimum of five passes of the 25ft side of the grid and 10 passes of the 50 ft side of the gird. Detailed close examination of the ground surface is required. The inspector should use invasive inspection techniques, such as periodically sifting the soil surface after wetting and closely inspecting the disturbed area. For each grid, fill out Form 26-B1 (Attachment B) completely, even if no known or suspect asbestos material is present. A complete description of all AM identified during the inspection is required on the form.

B. Flag, demarcate, or measure and mark on a map (see Form 26-B1) the location of any known or suspect asbestos material discovered in the grid. Log location with GPS unit if applicable. Obtain samples of suspect asbestos material for laboratory analysis per Section 4.1.1. Go to Section 4.2.

4.2.2 Inspection and “Pick and Go” – For Potential Clearance for Asbestos on the Surface A. Conduct shoulder-to-shoulder visual inspection of each grid. At a minimum, each grid must be completely inspected in two directions, which are perpendicular to each other.

This may be accomplished by multiple inspectors at arms length inspecting the surface together, or a single inspector. However, a single inspector must make more transects than multiple inspectors do. A single inspector's area of vision is no more than 5 ft meaning a minimum of 5 passes of the 25ft side of the grid and 10 passes of the 50 ft side of the gird. Detailed close examination of the ground surface is required. The inspector should use invasive inspection techniques, such as periodically sifting the soil surface after wetting and closely inspecting the disturbed area. For each grid, fill out Form 26- B1 completely, even if no known or suspect asbestos material is present. A complete description of all AM identified during the inspection is required on the form.

B. Flag, demarcate, or measure and mark on a map (see Form 26-B1) the location of any known or suspect asbestos material discovered in the grid. Log location with GPS unit if applicable. Obtain samples of suspect asbestos material for laboratory analysis per Section 4.1.1.

C. If clearance of the grid is directed by GSA, and it is feasible by hand-picking up pieces (defined as approximately less than 25 separate pieces of asbestos material – multiple pieces in a single location that is less than 1 sq ft may count as one), follow the proce-dures listed below. If clearance of the grid is not directed by GSA, or is not feasible (more than 25 pieces), then go to Section 4.2.

D. Use amended water (surfactant consisting of one ounce of a solution of 50% polyoxyethylene ester and 50% polyoxyethylene ether mixed with five gallons of water) to adequately wet the material and surrounding soil.

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E. For nonfriable asbestos material, gather and place the material and a couple of inches of surrounding soil in 6 mil bags. For friable asbestos material, gather and place material and 3 cubic feet of surrounding soil in 6 mil bags (double bags). Continue work with extra attention to possible additional asbestos in that vicinity.

F. Stage waste bags in a lined drum or roll-off container. Document waste as solid waste, which contains asbestos, on container inventory sheet.

G. Conduct a follow-up visual inspection of the grid by repeating procedures A-E above until no more visible asbestos material is found in the grid. Each subsequent inspection must be conducted in a direction perpendicular to the previous pass. If not clear on how to proceed, consult with GSA either to defer the grid for stabilization/remediation or to repeat the inspection procedure. Number of inspections to be determined by GSA and the Asbestos Building Inspector, however, it is generally anticipated that 2 to 3 inspections at most will be performed. (Each inspection may be an additional level-of-effort).

H. If no more visible asbestos material is discovered and GSA wishes to obtain final clearance for the grid surface, proceed with soil clearance by collecting a 10-point composite soil sample over the grid. Aliquot locations will be representative of the entire grid; however, aliquots must be placed where any visible friable asbestos material was found. Sampling will be performed as per DFC SOP No. 4, Section 4.2, except do not homogenize the sample in the field; this will be done by the laboratory. Sampling personnel will complete an Asbestos Surface Soil Sample Field Data Sheet (Form 26-A2) for each sample.

I. Label and handle the sample containers as specified in DFC SOP No. 6. Decontaminate all non-disposable sampling equipment between samples in accordance with DFC SOP No. 4.

J. All samples will be analyzed using accepted PLM methodology for asbestos bulk samples by laboratories accredited according to the provisions set forth in Colorado AQCC Regulation No. 8. Proper chain-of-custody protocols for all samples submitted will be followed. All samples will be homogenized by the laboratory prior to sample analysis.

K. If no asbestos fibers are detected in the soil sample, the grid is classified as “soil surface clear of asbestos.” If suspect or known asbestos material was observed but not removed from the surface, or asbestos fibers are detected in the soil sample above regulatory limits (acceptable level is non-detect), the grid is required to be remediated or stabilized. Go to Section 4.2.

L. Dispose of waste in marked 6 mil bags with affixed generator labels. Waste shall be double-bagged. All waste must be disposed per CDPHE's Solid Waste Regulations (6 CCR 1007-2, Part 1, Sec. 5).

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4.3 POST INSPECTION ACTIVITIES FOR SURFACE ASBESTOS

A. Grids with nonfriable asbestos material left on grid surface or soil sample from grid contains detectable asbestos (ACS) per PLM results:

a. The grid surface is determined to be contaminated with asbestos and may be required to be stabilized or remediated during a future action.

b. Delineate grid with “caution” or red “asbestos” tape, orange construction fencing, or other means to prevent entry.

c. Close area to all foot and vehicle traffic.

B. Grids with friable asbestos material left on surface:

a. The grid surface is determined to be contaminated with asbestos and is required to be stabilized or remediated during a future action.

b. Delineate with "caution" tape, or red “asbestos” tape, orange construction fencing, or other means to prevent entry.

c. Close area to all foot and vehicle traffic.

d. Unless remediation is scheduled to begin immediately, the location(s) of friable asbestos material shall be picked up without the underlying 3 cu ft of soil and the location(s) shall then be covered with either 6 inches of clean fill (crushed concrete, gravel, soil, or similar type material that will not blow away) or 10-mil poly sheeting. Poly sheeting is generally used only for temporary measures and must be secured and inspected daily to assure it remains in place in strong winds.

The cover will extend at least one foot past the surface occurrence of the friable asbestos. Soil from the site shall not be used as cover unless it has been sampled and shown to be non-detect for asbestos in soil per PLM analysis.

e. Continue to maintain all access restrictions per b. and c. above.

4.4 INSPECTION PROCEDURES FOR SUBSURFACE ASBESTOS (TRENCHING)

Subsurface investigation for asbestos must be detailed in a site-specific work plan to be approved by CDPHE. Subsurface investigation methods may include drilling, potholing, or trenching, with or without soil sampling. The number, location and depth of trenches will be specified in the FSP. This section of the SOP is intended to be used in conjunction with DFC SOP No. 16, Test Pit/Trench Excavation and Sampling.

Dust control measures may increase significantly during trenching depending upon the current situation and the site-specific work plan. Dust control during trenching will be continually assessed and modified as needed to best accommodate changing site conditions. Visible emissions shall not be generated at any time during the trenching process.

Important: Unless specified in the FSP and HSP, personnel will not enter a test pit/trench at any time. Substantial local, state, and federal regulations and site-specific health and

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A. Trenches will be excavated at the locations and to the total depths specified in the work plan.

Prior to trenching, the contractor shall adequately wet the first lift of soil to prevent visible emissions. During trenching, the contractor shall use a mister on the track hoe or hand-operated misters/sprayers to ensure that the soil and any suspect asbestos material are adequately wet to prevent visible emissions.

B. Carefully excavate thin layers of soil, no more than 2 feet thick with each scoop of the backhoe. The Asbestos Building Inspector will conduct a subsurface visual inspection for asbestos material as trenching proceeds. Inspect the soil during removal and as it is stock-piled or directly loaded into IDW containers. The Asbestos Building Inspector shall inspect the floor and each sidewall of the trench for every 2-foot lift removed. Detailed close examination of all trench surfaces is required. The inspector should use invasive inspection techniques, such as periodically sifting the soil and closely inspecting the disturbed area.

Temporarily, flag and photograph in place any known or suspect asbestos material. Obtain samples of suspect asbestos material for laboratory analysis per Section 4.1.1.

C. The anticipated total depth of a trench will be specified in the work plan. However, if asbestos material is still present at the anticipated total depth, the contractor shall notify GSA and continue excavating in 1-foot lifts to a depth where visible asbestos is no longer observed and there is a high degree of confidence that “native” or “undisturbed” soil is encountered.

D. For each trench, the Asbestos Building Inspector will complete Form 26-B2, even if no visible asbestos material is observed. A geologist will also log the trench contents and lithology at 6-inch intervals in accordance with DFC SOP No. 16. The geologist shall document on the log whether the soil is fill/disturbed soil or native/undisturbed soil for each interval.

E. When the trench is complete, if required, soil samples for asbestos analysis shall be collected from each trench as follows:

a. Collect a separate 10-point composite soil sample from each trench sidewall and from the floor. Aliquots shall be representative but must include any locations of observed friable asbestos. Sampling personnel will complete an Asbestos Subsurface (Trench) Soil Sample Field Data Sheet (Form 26-A3) for each sample.

b. Label and handle the sample containers as specified in DFC SOP No. 6, Sample Handling. Decontaminate all non-disposable sampling equipment between samples in accordance with DFC SOP No. 4.

c. All samples will be analyzed using accepted PLM methodology for asbestos bulk samples by laboratories accredited according to the provisions set forth in Colorado AQCC Regulation No. 8. Proper chain-of-custody protocols for all samples submitted will be followed. All samples will be homogenized by the laboratory prior to sample analysis.

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F. Excavated soil will be placed in designated IDW containers unless otherwise specified in the FSP. This will be done in accordance with SOP No. 5, Investigation Derived Waste Management except that the soil will be loaded using all necessary procedures to prevent visible emissions. These include misting/wetting during the loading process, keeping the bucket as close as possible to the interior of the container before dumping, and slow dumping to allow adequate wetting. Use of leak tight containers and other disposal requirements will be in accordance with Section 5.5.7 of the Colorado Solid Waste Regulations (e.g., burrito wrap).

G. The trenches will be backfilled immediately after sampling using clean fill material in accordance with DFC SOP No. 16. Soil from the site cannot be used as backfill unless it has been representatively sampled for ACS, analyzed using PLM, and is non-detect. If pits/trenches are to be left open overnight, access to the area must be restricted and any exposed portions of the trench or soil piles containing known or suspect visible asbestos or ACS must be covered or otherwise stabilized.

5.0 DOCUMENTATION

All asbestos discoveries, corrective actions, handling, and disposal will be communicated with CDPHE by GSA from discovery through completion in addition to the normal site channels.

The Asbestos Building Inspector is responsible for documenting all asbestos inspection observations and sampling activities. Detailed, complete, and accurate record will be documented on all applicable Forms contained in this SOP during the field activities. If an item on a form is not applicable, NA will be indicated on the form.

The Asbestos Building Inspector will also be responsible for maintaining the photo log and the project field logbook. The purpose of the field logbook is to document a semi-narrative record of the field conditions, activities, and events relevant to the field program on a daily basis.

Information to be documented in the logbook includes air monitoring, wind stoppage events, health and safety monitoring, decontamination procedures, IDW handling, sample collection, and any other pertinent information not already contained on the inspection and sampling Forms in this SOP.

Within 30 days of completion of fieldwork, a letter report will be generated that describes field operations and analytical results, if not part of some greater project report. This report will contain all of the information required above, along with summary maps and tables clearly detailing the results of the asbestos inspections.

6.0 VEHICLE ACCESS AND DECONTAMINATION PROCEDURES

The purpose of this protocol is to allow limited access for personnel and equipment and to specify decontamination procedures that must be followed when performing asbestos inspections contained in this SOP. It is not intended to be used for other soil disturbing activities that may require more extensive procedures and that would be contained in a Soil Characterization and Management Plan per Solid Waste Regulations Section 5.5.4 or other approved work plan.

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IN GENERAL, EVERY EFFORT SHALL BE TAKEN TO AVOID DRIVING IN GRIDS

OR AREAS THAT ARE KNOWN TO CONTAIN ASBESTOS OR HAVE THE

POTENTIAL TO CONTAIN ASBESTOS. For surface inspections, asbestos inspectors should enter the site on foot and bagged waste should be hand-carried or transported using a wheelbarrow to the site perimeter from where vehicles may transport it for disposal. In cases where vehicles or larger equipment must be used at the site to conduct subsurface investigations (such as backhoes), access is subject to the following conditions:

1. No driving is allowed on any grid that has been access-restricted under Section 4.2.

2. Under Subsection 4.1, an Asbestos Building Inspector may do a limited clearance of a grid or an area within a grid to allow vehicle crossing. For grids containing friable asbestos, the grid must be confirmed clean by soil sampling prior to allowing access.

3. Prior to driving in the area, the established access route must be clearly demarcated in the field using flagging, tape, stakes, signs, etc.

4. Rubber-tired vehicles will be used to the maximum extent feasible.

5. Vehicles entering the area will avoid causing the release of fugitive dust. Vehicle operators will be observant by driving in a slow, cautious manner.

6. An Asbestos Building Inspector with 6 months soil experience must be in front of the vehicle to guide the vehicle from driving across any visible asbestos material. Should the inspector observe any suspect or known asbestos materials, the operator/driver will alter course to avoid them.

7. Vehicle access routes may be required to be wetted as needed to make the ground surface damp so that fugitive dust is not generated when driven on. Determination if wetting is required is based on a case-by-case basis between GSA and CDPHE.

8. Decontamination: The wheels of vehicles exiting the area will be thoroughly rinsed as each vehicle exits the area determined to have asbestos present on the surface. The driver will then drive onto a poly tarp and re-rinse the wheels. A 60 mil or greater liner may be used multiple times, or 10 mil tarp may be used for a single decontamination event. If 10 mil poly sheeting is used, care must be used to prevent it from tearing. All water must be collected, filtered with 5-micron filter, and then disposed in a sanitary sewer. Subject to GSA site-specific approval, the rinsate may be collected and placed on a known asbestos grid. The water must not run-off an asbestos grid onto a non-contaminated grid or toward any surface water feature. The 60 ml or greater liners may be decontaminated for reuse and one-time use poly sheeting will be disposed as asbestos waste.

Covering: If covering is the chosen option, the contractor may either place 6 inches of clean fill (crushed concrete, gravel, soil, or similar type material) or 10-mil poly sheeting and be allowed to drive across the grid.

Personnel and equipment performing work under this SOP will be decontaminated in accordance with the procedures in DFC SOP No. 1. All equipment must be decontaminated before use at the

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DFC, prior to sample collection, and before being removed from the DFC. Decontamination of personnel, sampling equipment, vehicles, and heavy equipment is required to ensure the health and safety of personnel, reduce the potential for cross-contamination, and reduce the potential for contamination to enter or leave the DFC on personnel or equipment.

Personnel performing asbestos inspections should wear disposable outer protective suits (Tyveks) and booties, which should then be discarded as asbestos waste prior to exiting the site.

Any nondisposable personnel items must be decontaminated in accordance with DFC SOP No.

1.

Sampling equipment, drill rigs, augers, backhoe buckets, wheelbarrows, vehicles, and other equipment that comes in contact with soil known to contain, or potentially containing, asbestos shall be decontaminated in accordance with DFC SOP No. 1, Sections 4.1.3 and 4.1.5 between each sample, hole, or excavation to avoid potential cross-contamination, and before leaving the site. The rinsate will be managed as stated above (see 8).

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ATTACHMENT A

ASBESTOS MATERIAL SAMPLE FIELD DATA SHEET

FORM 26-A1

ASBESTOS SURFACE SOIL SAMPLE FIELD DATA SHEET

FORM 26-A2

ASBESTOS SUBSURFACE (TRENCH) SOIL SAMPLE FIELD DATA SHEET

FORM 26-A3

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Form 26-A1: Asbestos Material Sample Field Data Sheet

Sample Identification No.

Project Information Area Name: Lot/Grid Number

Asbestos Contractor: Inspector Name:

Sample Information Date and Time of Sample Collection:

Sample Depth (ft. bgs):

Sample Description:

Sample Containers Number Analyses (PLM, TEM)

Associated QA/QC Sample Nos.:

Comments/Observations:

Sampler's Name and Signature:

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Form 26-A2: Asbestos Surface Soil Sample Field Data Sheet

Area Name: Lot/Grid Number

Asbestos Contractor: Inspector Name:

Sample Information Date and Time of Sample Collection:

Sample Depth (ft. bgs):

Sample Collection Method (circle): Scoop/Spoon/Trowel Shovel Other:

Sample Type (circle): Discrete Composite

Discrete: Volume of sample

Composite: Number of Aliquots Volume of Each Aliquot

Sample Lithologic Description:

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Form 26-A3: Asbestos Subsurface (Trench) Soil Sample Field Data Sheet

Area Name: Lot/Grid Number

Trench Location in Grid:

Asbestos Contractor: Inspector Name:

Sample Information

Date and Time of Sample Collection:

Sample Location (circle): N Sidewall S Sidewall W Sidewall East Sidewall Floor

Sample Depth (ft. bgs):

Sample Collection Method (circle): Scoop/Spoon/Trowel Shovel Other:

Sample Type (circle): Discrete Composite

Discrete: Volume of sample

Composite: Number of Aliquots Volume of Each Aliquot

Sample Lithologic Description:

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ATTACHMENT B

SURFACE ASBESTOS GRID INSPECTION FORM

FORM 26-B1

SUBSURFACE ASBESTOS TRENCH INSPECTION FORM

FORM 26-B2

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Form 26-B1: Surface Asbestos Grid Inspection Form

Area: Inspector:

Lot//Grid No: Date:

1. Number of pieces of known or suspect asbestos material observed in grid:

0 1 2-10 10-25 > 25 pieces

2. Any friable asbestos material in grid? ___________ Number of pieces of friable____________

3. Complete Map and Materials Inventory below for any suspect or known asbestos material observed in grid. (Any suspect material should be submitted for laboratory analysis; if so, also complete Form 26-A1).

4. List any other non-asbestos debris observed in grid (type and approx. # of pieces):

5. Grid Disposition (check one):

_______Inspected, no asbestos material observed.

_______Inspected and all asbestos material hand-removed.

_______Inspected and all asbestos material left on grid, any friable locations picked and covered (Section 4.2). Access restrictions applied.

6. Surface soil sample collected for PLM? ______. If yes, fill in Sample

ID:____________________________________

(If yes, also complete Form 26-A2).

7. Comments:

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Asbestos Materials Inventory Grid Map Number (Place on grid map)

Known or Suspect Asbestos Material

Description

Friable (F) or

Nonfriable

(NF)

Sample ID (if applicable

(SOP6))

N orth

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Form 26-B2: Subsurface Asbestos Trench Inspection Form

Area: Inspector:

Lot/Grid No: Date:

Trench Location in Grid:

1. Final dimensions of trench (ft): Depth Length Width

2. Number of pieces of known or suspect asbestos material observed in trench:

0 pieces 1 pieces 2-10 10-25 > 25 pieces

3. Any friable asbestos material in trench? Number of pieces of friable:

4. Complete Materials Inventory below for any suspect or known asbestos material observed in trench.

(Any suspect material should be submitted for laboratory analysis; if so, also complete Form 26-A1).

5. List any other non-asbestos debris observed in trench:

6. Soil samples collected for PLM? ___. If yes, fill in Sample IDs below and complete Form 26-A3 for each sample:

Floor _________

Sidewalls _____________

7. Describe any comments and final disposition of trench:

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Asbestos Materials Inventory

Location. In Trench

(W,E,S,N,F (floor))

Asbestos Material Description (Suspect or Known)

Depth

(ft. bgs)

Friable (F) or Nonfriable NF)

Sample ID (if applicable)

B. Based on the analysis conducted in A above, along with inspection results where known asbestos materials were found, the Asbestos Building Inspector shall make a determination as to whether each grid inspected contains visible asbestos material. This information will be documented in accordance with Section 5.0 of this SOP.
Important: Unless specified in the FSP and HSP, personnel will not enter a test pit/trench at any time. Substantial local, state, and federal regulations and site-specific health and safety requirements apply for entry into excavations. GSA and the project health and safety officer must be notified prior to any activity involving entry of personnel into excavations.
A. Trenches will be excavated at the locations and to the total depths specified in the work plan. Prior to trenching, the contractor shall adequately wet the first lift of soil to prevent visible emissions. During trenching, the contractor shall use a mister on the track hoe or hand-operated misters/sprayers to ensure that the soil and any suspect asbestos material are adequately wet to prevent visible emissions.
B. Carefully excavate thin layers of soil, no more than 2 feet thick with each scoop of the backhoe. The Asbestos Building Inspector will conduct a subsurface visual inspection for asbestos material as trenching proceeds. Inspect the soil during removal and as it is stockpiled or directly loaded into IDW containers. The Asbestos Building Inspector shall inspect the floor and each sidewall of the trench for every 2-foot lift removed. Detailed close examination of all trench surfaces is required. The inspector should use invasive inspection techniques, such as periodically sifting the soil and closely inspecting the disturbed area. Temporarily, flag and photograph in place any known or suspect asbestos material. Obtain samples of suspect asbestos material for laboratory analysis per Section 4.1.1.
C. The anticipated total depth of a trench will be specified in the work plan. However, if asbestos material is still present at the anticipated total depth, the contractor shall notify GSA and continue excavating in 1-foot lifts to a depth where visible asbestos is no longer observed and there is a high degree of confidence that “native” or “undisturbed” soil is encountered.
D. For each trench, the Asbestos Building Inspector will complete Form 26-B2, even if no visible asbestos material is observed. A geologist will also log the trench contents and lithology at 6-inch intervals in accordance with DFC SOP No. 16. The geologist shall document on the log whether the soil is fill/disturbed soil or native/undisturbed soil for each interval.
E. When the trench is complete, if required, soil samples for asbestos analysis shall be collected from each trench as follows:
F. Excavated soil will be placed in designated IDW containers unless otherwise specified in the FSP. This will be done in accordance with SOP No. 5, Investigation Derived Waste Management except that the soil will be loaded using all necessary procedures to prevent visible emissions. These include misting/wetting during the loading process, keeping the bucket as close as possible to the interior of the container before dumping, and slow dumping to allow adequate wetting. Use of leak tight containers and other disposal requirements will be in accordance with Section 5.5.7 of the Colorado Solid Waste Regulations (e.g., burrito wrap).
G. The trenches will be backfilled immediately after sampling using clean fill material in accordance with DFC SOP No. 16. Soil from the site cannot be used as backfill unless it has been representatively sampled for ACS, analyzed using PLM, and is non-detect. If pits/trenches are to be left open overnight, access to the area must be restricted and any exposed portions of the trench or soil piles containing known or suspect visible asbestos or ACS must be covered or otherwise stabilized.

File details come from the government source that posted it. Updated .