SOP_26A_Asbestos_Excavation_Procedures_Utility_Const_04-10.pdf

SOP NO. 26A

Standard Operating Procedure For

ASBESTOS EXCAVATION PROCEDURES

FOR UTILITY CONSTRUCTION

Denver Federal Center Site-Wide RCRA Facility Investigation

Prepared for:

General Services Administration

Rocky Mountain Region Denver, Colorado

Prepared by:

URS Corporation

April 2010

Revision 5.0

Denver Federal Center SOPs Revision No. 5.0

April 2010 Page i of iii

SOP NUMBER 26A ASBESTOS INSPECTION PROCEDURES

FOR SURFACE AND SUBSURFACE SOIL

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

2.0 PERSONNEL QUALIFICATIONS ........................................................................ 26A-2

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

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

4.1 INSPECTION PROCEDURES FOR SURFACE ASBESTOS .............................. 26A-4

4.1.1 Sampling of Suspect Surface Asbestos Material ............................................ 26A-5

4.1.2 Inspection Only (No Hand-Removal) – for Determination of the Presence of

Asbestos on the Surface .................................................................................. 26A-6

4.1.3 Inspection and “Pick and Go” – for Potential Clearance for Asbestos on the

Surface ............................................................................................................ 26A-6

4.2 POST INSPECTION ACTIVITIES FOR SURFACE ASBESTOS........................ 26A-8

4.3 TRENCHING APPROACH - ASBESTOS EXCAVATION FOR PRIOR IDENTIFIED

SURFACE ACM/ACS EXPRESSION (PLANNED ENCOUNTER).................... 26A-9

4.4 TRENCHING APPROACH – ASBESTOS EXCAVATION WITH NO PRIOR

SURFACE ACM/ACS EXPRESSION ................................................................. 26A-11

5.0 AIR MONITORING REQUIREMENTS.............................................................. 26A-13

6.0 DOCUMENTATION ............................................................................................ 26A-14

7.0 VEHICLE ACCESS AND DECONTAMINATION PROCEDURES ................. 26A-15

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 Corridor Inspection Form – Form 26-B1 Subsurface Asbestos Trench Inspection Form – Form 26-B2

Attachment C DFC SOP No. 1

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REVISION LOG

Revision Number Description Date

0.0 Original SOP No. 26A (prepared by

ECC/PWT/CDPHE/GSA)

May 2000

5.0 SOP No. 26A (modified by

FOH/CH2M HILL/GSA)

Designer: Deborah Fernandez, Project Design Certification 9022 Federal Occupational Health Phone: (303) 236-8000

Asbestos Project Designer

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LIST OF ABBREVIATIONS AND ACRONYMS

ACS Asbestos-contaminated soil AHERA Asbestos Hazard Emergency Response Act AM Asbestos Material BGS Below Ground Surface CABI Certified Asbestos Building Inspector CDPHE Colorado Department of Public Health and Environment DFC Denver Federal Center EPA United States Environmental Protection Agency GSA General Services Administration f/cc Fibers/cubic centimeter FSP Field Sampling Plan HSP Health and Safety Plan MHP Materials Handling Plan for the UIP NIST National Institute of Standards and Technology NLVAP National Voluntary Laboratory Accreditation Program PCM Phase Contrast Microscopy PLM Polarized Light Microscopy PPE Personal Protection Equipment QA/QC Quality Assurance/Quality Control SSHO Site Safety and Health Officer SOP Standard Operating Procedure TEM Transmission electron microscopy UIP Utilities Infrastructure Project

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1.0 PURPOSE AND SCOPE

This Standard Operating Procedure (SOP) provides technical guidance and methods that shall be used to identify and excavate both surface and subsurface soils when asbestos containing material (ACM) or asbestos containing soil (ACS) is suspected or discovered during excavation(s) for the Denver Federal Center (DFC) Utilities Infrastructure Project (UIP) and other construction excavations to install utilities, which may occur throughout the DFC. It is a “living document”, thus if there is a more suitable protocol to use that complies with CDPHE regulations, it can be proposed and reviewed by the GSA CABI, the EPG and CDPHE to determine if it can be implemented.

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

This SOP is for the benefit of the Contractor and the General Services Administration (GSA) Contracting Officer’s Designated Representative, who is referenced in this SOP as the GSA Colorado State Asbestos Building Inspector (CABI). The list below outlines the sections of this SOP that are pertinent to the Contractor or CABI or both:

Section 1.0 – Purpose and Scope Contractor/GSA CABI

Section 2.0 – Personnel Qualifications Contractor/ GSA CABI

Section 3.0 – Materials and Equipment Contractor/ GSA CABI

Section 4.0 – Procedures Contractor/ GSA CABI

Section 4.1 – Inspection Procedures for Surface Asbestos GSA CABI

Section 4.1.1 – Sampling of Suspect Asbestos Material GSA CABI

Section 4.1.2 – Inspection Only GSA CABI

Section 4.1.3 – Inspection and “Pick and Go” GSA CABI

Section 4.2 – Post Inspection Activities for Surface Asbestos Contractor

Section 4.3 – Trenching Approach - Asbestos Excavation for Prior Identified Surface ACM/ACS Expression (Planned Encounter)

Contractor/ GSA CABI

Section 4.4 – Trenching Approach – Asbestos Excavation with No Prior Surface ACM/ACS Expression

Contractor/ GSA CABI

Section 5.0 – Air Monitoring Procedures Contractor/ GSA CABI

Section 6.0 – Documentation GSA CABI

Section 7.0 – Vehicle Access and Decontamination Procedures Contractor/ GSA CABI

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2.0 PERSONNEL QUALIFICATIONS

Personnel overseeing, directing, inspecting and/or handling ACM or asbestos containing soil ACS (including suspect asbestos material) shall 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 (CABI) Certification with a minimum of six months of experience in asbestos-contaminated soil management (Inspectors only).

• All required certificates and licenses shall 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).

Ancillary personnel not directly performing fieldwork such as quality assurance/quality control (QA/QC) oversight staff, management, and GSA project staff are required to attend an asbestos awareness class prior to initial visit of the site. Training shall be tailored for soil projects.

All personnel working on the site shall 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 role shall 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 excavation of ACM 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.

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• Garden trowels 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.

• 10-mil polyethylene 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 liner, depending on the friability of the asbestos.

4.0 PROCEDURES

Upon initial discovery of any suspected asbestos, field personnel who are not CABIs shall immediately stop work and notify a supervisor. Field personnel shall 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 GSA CABI (see Section 2.0) shall handle activities beyond initial discovery including but not limited to the following:

• 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 who are 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

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If the asbestos contaminated soil is pervasive throughout the excavation area, wind fencing and other protective measures must be employed. The GSA’s CABI is allowed to make judgment calls on the initiation of additional protective measures and the amount of soil to be removed.

4.1 INSPECTION PROCEDURES FOR SURFACE ASBESTOS

This section describes the procedures for surface asbestos inspections, ACM collection, and clearance, which were developed in accordance with 6 CCR 1007-2, Part 1, Section 5.5 - Management of Asbestos-Contaminated Soil and the “Asbestos-Contaminated Soil Guidance Document” (April 2007).

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 excavation procedures within 100 feet 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. Hand held wind-measuring equipment shall be used to measure wind speed.

• Any wind gust reaches or exceeds 20 miles per hour (mph) 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.

Soil removal/disturbance operations may resume after all of the following four conditions have been met:

• All wind gust readings, for a period of 20 minutes, drop below 10 miles per hour as determined by hand-held instruments;

• Sustained wind speeds are below 12 miles per hour averaged over a period of 10 minutes;

• Winds are no longer producing visible emissions or creating movement of dust or debris in or near the removal/disturbance area; and

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• Winds are not impacting the ability of engineering controls to work as designed.

In general, one of two different inspection approaches shall be specified. These are as follows:

• The first approach, described in 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, described in 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 trench corridor shall be marked out.

The trench corridor is defined as a 50-foot wide swath inside of which all construction activities shall take place. A corridor grid is defined as a 50-foot wide and 25-foot long grid. Grid numbers shall be determined by the GSA CABI in conjunction with the GSA EPG. The inspection shall be conducted in accordance with the following procedures (Section 4.1.1 through 4.1.3):

4.1.1 Sampling of Suspect Surface Asbestos Material

A. If the GSA CABI encounters materials that are suspect of containing asbestos, the CABI shall collect representative samples of each type of the material(s) for analysis.

a. Adequately wet the suspect material to be sampled and the 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 GPS location (to sub meter accuracy), 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. For each ACM 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 GSA CABI shall make a determination as to whether the corridor inspected contains visible asbestos material. This information shall be documented in accordance with Section 5.0 of this SOP.

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4.1.2 Inspection Only (No Hand-Removal) – For Determination of the Presence of 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 feet meaning a minimum of five passes of the 25 foot side of the grid and 10 passes of the 50 foot side of the grid. 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 asbestos material 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 corridor 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.

4.1.3 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 feet meaning a minimum of 5 passes of the 25 foot side of the grid and 10 passes of the 50 foot 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 asbestos material 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 ACM discovered in the corridor grid. Log location with GPS unit (to submeter accuracy), if applicable. Obtain samples of suspect asbestos material for laboratory analysis per Section 4.1.1.

C. If clearance of the corridor grid is directed by the GSA CABI , 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 square foot may count as

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4.2. Corridor grid length shall not exceed 50 feet for the determination of the 25-piece rule. If the surface is cleared by this inspection and subsequent pickup, the area becomes suspect for asbestos at depth and an increase of protection shall be implemented when this section is excavated.

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.

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 corridor by repeating procedures A-E above until no more visible asbestos material is found in the corridor grid.

H. If no more visible asbestos material is discovered and GSA wishes to obtain final clearance for the corridor grid, the GSA CABI shall proceed with soil clearance by collecting a 10-point composite soil sample over the corridor grid. Aliquot locations shall be representative of the entire corridor grid; however, aliquots must be placed where any visible friable asbestos material was found. Sampling shall be performed by following these procedures:

a. Calculate the volume of sample material to be collected at each increment sample to ensure the necessary amount of composite sample shall be obtained. For a given composite sample, the volume of each incremental sample must be the same and must equal 1/n of the required composite sample volume, where n equals the number of incremental sample making up the composite sample.

b. At each increment sample location, clear an area approximately 12 inches in diameter of surface vegetation and debris.

c. Use a decontaminated stainless steel spoon to collect surface soil to a depth of 6 inches. A stainless steel pick may be used as needed to loosen the soil. To the extent possible, eliminate gravel-size or large particles and debris based on visual observation.

d. Decontaminate the sampling equipment in accordance with Attachment C, SOP 1.

e. Sampling personnel shall complete an Asbestos Surface Soil Sample Field Data Sheet (Form 26-A2) for each sample.

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f. Submit the material(s) for analysis using proper chain-of-custody protocol.

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

I. If no asbestos fibers are detected in the soil sample, the corridor 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 corridor grid is required to be remediated or stabilized. Go to Section 4.2. If the surface is cleared by this inspection and subsequent pickup, the area becomes suspect for asbestos at depth and an increase of protection shall be implemented when this section is excavated.

J. Dispose of waste in marked 6 mil bags with affixed generator labels. Waste shall be double-bagged if picked up during inspection. All waste must be disposed as defined in the Materials Handling Plan (MHP) for the UIP.

4.2 POST INSPECTION ACTIVITIES FOR SURFACE ASBESTOS

A. The following procedure applies to corridor grids with nonfriable asbestos material left on the corridor grid surface or soil sample from the corridor grid contains detectable asbestos (ACS) per PLM results:

a. The corridor grid surface is determined to be contaminated with asbestos and may be required to be stabilized or remediated by excavating the surface soil, resinspected and then resampled according to 4.1.3.H.

b. Delineate corridor 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. The following procedure applies to corridor grids with friable asbestos material left on the corridor grid surface or soil sample from the corridor grid contains detectable asbestos (ACS) per PLM results:

a. The corridor grid surface is determined to be contaminated with asbestos and is required to be stabilized or remediated by excavating the surface soil, reinspected and then resampled according to 4.1.3.H.

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.

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d. Unless remediation is scheduled to begin immediately, the location(s) of friable asbestos material shall be picked up without the underlying 3 cubic feet 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 shall not blow away) or 10-mil polyethylene sheeting. Polyethylene 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 shall 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.

4.3 TRENCHING APPROACH - ASBESTOS EXCAVATION FOR PRIOR IDENTIFIED

SURFACE ACM/ACS EXPRESSION (PLANNED ENCOUNTER)

This section applies to the scenario during construction of the UIP or other utility excavations, where corridor grids with surface asbestos have been identified by CABI prior to excavation in the area. Procedures for excavations using a ditch witch or other similar piece of equipment are noted under K.

Dust control measures shall be increased significantly during trenching through areas of known surface asbestos. Dust control during trenching shall be continually assessed and modified as needed to best accommodate changing site conditions. Visible dust emissions shall not be generated at any time during the trenching process.

Important: Unless specified in the Construction Documents and Contractor’s Health and Safety Plans (HSP), personnel shall not enter an excavation without the proper safety precautions. Substantial local, state, and federal regulations and site-specific health and safety requirements apply for entry into excavations. GSA and/or the Contractor’s Health and Safety Officer must be notified prior to any activity involving entry of personnel into excavations.

A. The air monitoring requirements specified under Section 5.0 shall be followed during this type of excavation.

B. The wind stoppage criteria under Section 4.1 shall be followed.

C. Trenches shall be excavated at the locations and to the total depths specified in the Construction Documents. 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. Use of both is size of excavation and condition (weather and/or asbestos potential) dependent.

D. Carefully excavate thin layers of soil, no more than 2 feet thick with each scoop of the backhoe. The GSA CABI shall conduct a subsurface visual inspection for asbestos

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E. The anticipated total depth of a trench is specified in the Construction Documents.

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. This is to ensure that in when the remainder of the area is remediated for asbestos, the utility corridor bedding shall not be disturbed.

F. For each trench through areas with surface ACM occurrence, the GSA CABI shall complete Form 26-B2, even if no visible asbestos material is observed in the trench. A geologist/engineer (provided by the GSA) shall 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.

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

a. The GSA CABI shall 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, after this material has been removed. The GSA CABI shall complete an Asbestos Subsurface (Trench) Soil Sample Field Data Sheet (Form 26-A3) for each sample.

b. The GSA CABI shall label and handle the sample containers using proper chain-of-custody protocol and decontaminate all non-disposable sampling equipment between samples in accordance with Attachment C, SOP 1.

c. All samples shall be analyzed using accepted PLM methodology for asbestos bulk samples by laboratories accredited according to the provisions set forth in Colorado Air Pollution Control Division Regulation No. 8. All samples will be homogenized by the laboratory prior to sample analysis.

H. Excavated ACM and ACS shall be placed in designated containers labeled for asbestos in accordance with the MHP except that the soil shall be loaded using all necessary

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I. The trenches shall be backfilled immediately after sampling results have been received, using clean fill material in accordance with the Contract Documents. Soil from the site cannot be used as backfill if soils come from areas determined to contain ACS or ACM, unless it has been representatively sampled for ACS, analyzed using PLM, and determined to be non-detection for asbestos. If 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.

J. All ACS that are stockpiled or placed in roll-offs shall be covered with 10-mil polyethylene sheeting and inspected daily to ensure sheeting is in tact.

K. If a ditch witch or other similar piece of equipment is used to install a utility, the air monitoring procedures under A and the wind stoppage criteria under B shall be followed.

The soil shall be wetted as noted under C. If an asbestos inspection has been completed prior to excavation by the GSA CABI and no asbestos has been identified, the excavated soil can be placed directly on the ground surface. If asbestos has been identified within a 10 foot buffer of the trench corridor and /or if asbestos has been identified in the trench corridor, the excavated soil shall be placed on a 10-mil polyethylene liner for inspection by the GSA CABI. The GSA CABI will follow the inspection, sampling and documentation procedures under D. The installation of a utility that is installed with a ditch witch or other similar piece of equipment typically does not require bedding nor is the trench available for visual inspection; therefore, the procedures under E, F and G do not apply. The procedures under HI and J shall be followed to backfill the trench as applicable.

4.4 TRENCHING APPROACH – ASBESTOS EXCAVATION WITH NO PRIOR

SURFACE ACM/ACS EXPRESSION

This section applies to the scenario during construction of the UIP or other utility excavation where asbestos has not been discovered by the GSA CABI prior to excavation of trenches wider than 6 inches and depth greater than 2 feet. The GSA CABI must be present during all intrusive activities for trenching and excavation. All excavated soils shall be placed on 10-mil polyethylene sheeting. Soils that are suitable for backfill are prescribed in the MHP. All water used in the following procedure shall be amended water. As advancing the excavation, the GSA

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CABI shall inspect the bucket for ACS as the soils are laid down on the 10-mil polyethylene sheeting on the side of the trench. Once the GSA CABI discovers asbestos the following procedure shall be followed.

A. The air monitoring requirements specified under Section 5.0 shall be followed during this type of excavation.

B. The wind stoppage criteria under Section 4.1 shall be followed.

C. If non-friable ACM is observed, the CABI shall pick up and bag the ACM along with some surrounding soils. The excavator shall start using the sprayer bar with amended water on the excavation face. Alternatively wetting may be conducted by personnel on the ground with spraying equipment. If in the excavation process, more than 10 linear feet of trench has more than 15 pieces of ACM, the excavated soils from this unit length shall be treated as described in Section 4.3. All excavated soils are required to be covered by 10-mil polyethylene sheeting. These activities can be stopped when 3 linear feet of trench does not contain observable ACS. These soils shall not be placed back into the excavation.

D. If friable ACM is observed, and not related to Steam lines or other facility components which are covered under Colorado Regulation No. 8 which must be followed, the friable ACM or visible ACS shall be segregated on 10-mil polyethylene sheeting, on the other side of the ditch/excavation. The segregation shall continue for 3 linear feet after the last occurrence of ACS. As soon as friable ACM is encountered, the spray bar on the excavator shall be activated. Extra wetting support may be required by ground based personnel on the working face, as necessary to ensure that there are no visible emissions. The excavator operator, the CABI, and personnel handling the spray on the working face shall don tyvex, respirator, and personal air pumps for air monitoring. The soils shall be placed on 10-mil polyethylene sheeting, and as soon as possible tightly covered with 10-mil polyethylene sheeting to prevent wind dispersion of the soils. The wetting, PPE, and air monitoring shall continue until 3 linear feet of clean material beyond the last occurrence of ACS. The bucket shall be decontaminated over the soil pile and standard excavation protocols may resume.

E. The contractor shall ship the friable ACS out for disposal, or place in double lined roll offs, no longer than 3 days after excavation. When loading soils with friable asbestos for disposal, the soils shall be loaded into double lined dump trucks, or a second liner can be added to a non-friable load which already has a single liner, manifested, and disposed at a landfill permitted to accept this material. In the case that a second liner has been added, the entire load will be considered friable asbestos. The excavator or front-end loader or equivalent, moving the soils into the haul truck/roll-off shall have the sprayer bar operating to wet the material being loaded. A ground based sprayer shall also spray/wet the bucket as it is unloaded into the truck. The truck shall be placed on 10-mil polyethylene sheeting while being loaded so that any over-spill can be picked up. The excavator operator, the person operating the spray unit, the CABI, and any other personnel in the area immediately helping

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5.0 AIR MONITORING REQUIREMENTS

A. Personal Air Monitoring

a. Shall be performed in accordance with all OSHA requirements during all excavation and loading of known and suspect friable asbestos in soils.

b. In addition to OSHA requirements, for all asbestos contaminated soil excavation activities, at least two (2) different workers or 25 percent of the workers, whichever is greater, and who are expected to have the worst-case exposure to asbestos during excavation, shall be monitored to assist in determining the adequacy of engineering and environmental controls employed at the site.

c. When ACM soil or ACS are loaded from covered stockpiles into trucks, the excavator operator, the personnel wetting the working surface of the pile, the personnel wetting the soil and bucket as it is being loaded into the truck shall be monitored to assist in determining the adequacy of engineering and environmental controls employed at the site.

d. The Contractor shall maintain a daily air-monitoring log for GSA CABI inspection.

e. Nominally, two of the cartridges with the highest loading shall be chosen for TEM analysis. TEM shall be used to determine composition of fibers.

f. Initially, all the air samples collected on the workers shall be submitted for transmission electron microscopy (TEM) analysis to a National Institute of Standards and Technology (NIST), National Voluntary Laboratory Accreditation Program (NLVAP) accredited laboratory on the day of excavation. Verbal results shall be made available to the Contractor and GSA CABI by the start of the next business day or as soon as practical after the start of the next business day, and written results shall be made available on-site within 24 hours from the time the verbal result is received.

g. If a detection (one fiber) occurs, engineering controls shall be reviewed and appropriately changed, air monitoring with daily TEM analysis shall continue to occur.

h. After one week of monitoring the same type of field operation, the frequency of TEM analysis can be reduced to a random twice a week, with the remaining samples being analyzed by phase contrast microscopy (PCM). The two highest loaded samples from the PCM analysis shall be analyzed by TEM to determine if asbestos is present. The GSA CABI shall choose the random days. However, any

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i. If site conditions/engineering controls change substantially, the initial air monitoring procedures shall be repeated for three additional days or until CDPHE is satisfied that the new or modified engineering controls are deemed adequate.

j. Positive TEM Results – the Contractor and GSA CABI shall review the TEM analysis of personnel air monitoring samples. CDPHE shall be immediately notified should any air sample show any concentration of airborne fibers. In the event asbestos fibers are detected, the following shall occur:

i. Excavation shall immediately cease,

ii. The source(s) of emissions identified, and

iii. A control plan shall be derived and submitted to the GSA CABI and the CDPHE for review.

iv. Soil removal shall not continue until CDPHE provides verbal and/or written authorization to proceed.

B. Perimeter Air Monitoring for Asbestos

a. Perimeter monitoring shall be performed during all excavation or movement of asbestos containing soils. This does not include movement of roll-offs with single or double lined roll-offs or trucks.

b. Downwind air monitoring shall be conducted during excavation of known or all suspect friable asbestos is soils within the vicinity (100 yards) of an occupied building or in areas of general use by employees.

c. Monitoring stations shall be placed at edge of exclusion area, in the down wind direction, and at 90-degrees to the prevailing wind directions. In addition, a monitoring station shall be placed at the air intake(s) of any downwind building.

d. All samples shall be submitted for PCM analysis with results reported by 8 AM the next day to the GSA CABI. The air cartridge with the highest loading shall be sent in for TEM analysis. However, any sample with fiber concentration greater than 0.01 fibers per cubic centimeter (f/cc), detected by PCM analysis, shall be analyzed by TEM to determine if asbestos is present.

6.0 DOCUMENTATION

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

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

The GSA CABI shall 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, decontamination procedures, ACM and/or ACS handling, sample collection, and any other pertinent information not already contained on the inspection and Sampling Forms in this SOP.

7.0 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 and excavations contained in this SOP. It is not intended to be used for other soil disturbing activities that may require more extensive procedures.

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

CORRIDORS 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 excavations (such as backhoes) access is subject to the following conditions:

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

2. Under Subsection 4.1, the GSA CABI may do a limited clearance of a corridor to allow vehicle crossing. For corridors containing friable asbestos, the corridor 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 shall be used to the maximum extent feasible.

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

6. The GSA CABI must be in front of the vehicle to guide the vehicle from driving across any visible asbestos material. Should the GSA CABI observe any suspect or known asbestos materials, the operator/driver shall alter course to avoid them.

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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 shall be thoroughly rinsed as each vehicle exits the area determined to have asbestos present on the surface. The driver shall then drive onto a polyethylene tarp and re-rinse the wheels. A 60-mil or greater liner may be used multiple times, or 10-mil polyethylene sheeting may be used for a single decontamination event. If 10-mil polyethylene 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 area. The water must not run-off an asbestos corridor onto a non-contaminated corridor or toward any surface water feature. The 60-ml or greater liners may be decontaminated for reuse and one-time use 10-mil polyethylene sheeting shall be disposed as asbestos waste.

9. Decontamination: The excavator/front end loader or equivalent shall operate on clean areas. 10-mil polyethylene sheeting or liner material can be used to drive onto contaminated areas. When moving from one location to another, the bucket that came into contact with the ACM/ACS shall be wrapped in 10-mil polyethylene sheeting to prevent spreading fibers to non-contaminated areas. When it is finished loading, the bucket shall be decontaminated over the last dump truck prior to closing the 10-mil polyethylene sheeting liner/burrito wrap.

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 polyethylene sheeting and be allowed to drive across the corridor.

Personnel and equipment performing work under this SOP shall be decontaminated in accordance with the procedures in Attachment C. All equipment must be decontaminated before use at the 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 Attachment C.

Sampling equipment, backhoe buckets, wheelbarrows, vehicles, and other equipment that comes in contact with soil known to contain, or potentially contain asbestos shall be decontaminated in accordance with Attachment C between each sample, hole, or excavation to avoid potential cross-contamination, and before leaving the site. The rinsate shall be managed as stated above (see 8).

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ATT…