SOP_26B_Asbestos_Excavation_Proc_Post_Hole_Drilling-Digging_04-10.pdf

SOP NO. 26B

Standard Operating Procedure For

ASBESTOS EXCAVATION PROCEDURES

FOR POST HOLE DRILLING/DIGGING

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 2.0

Denver Federal Center SOPs Revision No. 2.0

April 2010 Page i of iii

SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

POST HOLE DRILLING/DIGGING

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

2.0 PERSONNEL QUALIFICATIONS ........................................................................ 26B-2

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

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

4.1 Inspection Procedures for Surface Asbestos.............................................................26B-4

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

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

Asbestos on the Surface .................................................................................. 26B-5

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

Surface ............................................................................................................ 26B-6

4.2 Post Inspection Activities for Surface Asbestos .......................................................26B-8

4.3 Post-Hole Drilling/Digging Approach – Asbestos Excavation for Prior Identified Surface ACM/ACS Expression (Planned Encounter) ..............................................26B-9

4.4 Post-Hole Drilling/Digging Approach – Asbestos Excavation with No Prior Surface ACM/ACS Expression............................................................................................26B-10

5.0 AIR MONITORING REQUIREMENTS.............................................................. 26B-12

6.0 DOCUMENTATION ............................................................................................ 26B-13

7.0 VEHICLE ACCESS AND DECONTAMINATION PROCEDURES ................. 26B-14

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

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

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

Subsurface Asbestos Post-hole Inspection Form – Form 26-B2

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SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

POST HOLE DRILLING/DIGGING

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REVISION LOG

Revision Number Description Date

0.0 Original SOP No. 26B (prepared by

PWT/CDPHE/GSA)

May 2000

2.0 SOP No. 26B (modified by

FOH/CDPHE/GSA)

April 2010

Regulator: Colleen Brisnehan CDPHE, Hazardous Material Division Phone: (303) 692-3057

Environmental Protection Specialist

April 2010 Page iii of iii

SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

POST HOLE DRILLING/DIGGING

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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 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

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SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

POST HOLE DRILLING/DIGGING

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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 properly manage both surface and subsurface soils when asbestos containing material (ACM) or asbestos containing soil (ACS) is suspected or discovered during post-hole digging/drilling at the Denver Federal Center (DFC). This plan will be implemented only under the circumstances or conditions in which the requirements of 6 CCR 1007-2, Part 1, Section 5.5 are activated. 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 - Control of Hazardous Air Pollutants, Part B - Asbestos Control).

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 – Post-Hole Drilling/Digging Approach – Asbestos Excavation for Prior Identified Surface ACM/ACS Expression (Planned Encounter)

Contractor/GSA CABI

Section 4.4 – Post-Hole Drilling/Digging 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

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SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

POST HOLE DRILLING/DIGGING

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

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 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.

• Garden trowels and/or rakes.

• Shovels, wheelbarrow.

• Garden sprayers.

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SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

POST HOLE DRILLING/DIGGING

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• 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 projects may require additional equipment such as a 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 asbestos and the associated 3 cubic feet of soil (amount of soil is dependent on the distribution of the friable ACM within the contaminated 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 PPE requirements may be required as determined by the Contractor's Health and

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SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

POST HOLE DRILLING/DIGGING

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Safety Officer. Refer to Section 7 of this SOP for personnel and equipment decontamination procedures.

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

• 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.

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SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

POST HOLE DRILLING/DIGGING

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• 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 work area shall be marked out. The work area is defined as the area inside of which all drilling/excavation activities shall take place.

Grids shall be established within the work area. The size of the grids shall depend on the dimensions of the work area, but shall not exceed 1,250 square feet in area. 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.

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

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SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

POST HOLE DRILLING/DIGGING

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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.

4.1.3 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 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 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 one), the GSA CABI shall follow the procedures 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. 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.

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SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

POST HOLE DRILLING/DIGGING

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

H. If no more visible asbestos material is discovered and GSA wishes to obtain final clearance for the grid, the GSA CABI shall proceed with soil clearance by collecting a 10-point composite soil sample over the grid. Aliquot locations shall be representative of the entire 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 SOP 1 - Personnel and Equipment Decontamination.

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

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 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

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SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

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(acceptable level is non-detect), the 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 grids with nonfriable asbestos material left on the grid surface or soil sample from the 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 by excavating the surface soil, resinspected and then resampled according to 4.1.3.H.

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

a. The 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.

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.

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SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

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4.3 POST-HOLE DRILLING/DIGGING APPROACH – ASBESTOS EXCAVATION FOR

PRIOR IDENTIFIED SURFACE ACM/ACS EXPRESSION (PLANNED

ENCOUNTER)

This section applies to the scenario during post-hole drilling/digging where grids with surface asbestos have been identified by CABI prior to excavation in the area. Post-holes shall be advanced using hand or auger methods. Hydrovac methods shall not be used due to the increased potential for emissions and additional equipment decontamination requirements. The GSA CABI must be present during all intrusive activities for post-hole drilling/digging. All water used in the following procedure shall be amended water.

Dust control measures shall be increased significantly during post-hole drilling/digging through areas of known surface and/or subsurface asbestos. Dust control during post-hole drilling/digging 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 drilling/digging process.

A. At a minimum, individuals conducting drilling/digging activities must wear disposable booties and rubber gloves. If friable ACM was observed during the surface inspection, or if it is encountered during drilling/digging, the driller, the CABI, and personnel handling the spray shall also don Tyvex® or equivalent coveralls, respirator, and personal air pumps for air monitoring.

B. The air monitoring requirements specified under Section 5.0 shall be followed during this type of drilling/digging.

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

D. Post-holes shall be installed at the locations and to the total depths specified in the project specific design documents. Prior to drilling/digging, the contractor shall adequately wet the surface soil to prevent visible emissions. During drilling/digging, the contractor shall use hand-operated misters/sprayers to ensure that the soil and any suspect asbestos material are adequately wet to prevent visible emissions.

E. Carefully drill/dig through the first 2 feet of soil to minimize the potential for emissions.

The GSA CABI shall conduct a visual inspection of the cuttings for asbestos material as drilling/digging proceeds and inspect the soil during removal/containerization. All generated soils not directly loaded for disposal shall be placed on 10-mil polyethylene sheeting or containerized. Any friable ACM encountered shall be containerized or tightly covered with 10-mil polyethylene sheeting as soon as possible to prevent wind dispersion.

F. For each post-hole drilled through areas with surface ACM occurrence, the GSA CABI shall complete Form 26-B2, even if no visible asbestos material is observed during post-hole drilling/digging. A geologist/engineer shall also log the post-hole cuttings and observe the lithology in the open post-hole intervals in accordance with DFC SOP

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SOP NUMBER 26B ASBESTOS EXCAVATION PROCEDURES FOR

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No. 16. The geologist shall document on the log whether the soil is fill/disturbed soil or native/undisturbed soil for each post-hole.

G. When the post-hole is complete, the if suspect ACM or ACS is left in place in the sidewalls of the post-hole, the sidewalls should be stabilized with a spray-on tactifier, magnesium chloride, or other equivalent stabilizer.

H. The post-holes shall be completed as soon as possible after installation. Soil from areas determined to contain ACS or ACM cannot be used as backfill unless it has been representatively sampled for ACS, analyzed using PLM, and determined to be non-detect for asbestos. If post-holes are to be left open overnight, access to the area must be restricted and any exposed portions of the post-hole or soil piles containing known or suspect visible asbestos or ACS must be covered or otherwise stabilized.

I. Any stockpiled ACS shall be covered with 10-mil polyethylene sheeting and inspected daily to ensure the sheeting is intact. For disposal, all ACM and ACS shall be placed in designated containers labeled for asbestos, and shall be loaded using all necessary procedures to prevent visible emissions. These include misting/wetting during the loading process, keeping the soil 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 shall be in accordance with Section 5.5.7 of the Colorado Solid Waste Regulations (e.g., leak tight container or burrito wrap, single or double liner). If trucks are used, non-friable ACM in soils shall be loaded in to single lined trucks, friable ACM or visible ACS shall be loaded into double lined trucks.

J. The drilling/digging equipment shall be decontaminated as discussed Section 7.0.

4.4 POST-HOLE DRILLING/DIGGING APPROACH – ASBESTOS EXCAVATION

WITH NO PRIOR SURFACE ACM/ACS EXPRESSION

This section applies to the scenario during post-hole drilling/digging where asbestos or suspect ACM have not been discovered by the GSA CABI prior to drilling/digging, but where asbestos is suspected to possibly exist (e.g., in grids adjacent to known asbestos-contaminated grids or in former building areas). Post-holes shall be advanced using hand or auger methods. Hydrovac methods shall not be used due to the increased potential for emissions and additional equipment decontamination requirements. The GSA CABI must be present during all intrusive activities for post-hole drilling/digging. All generated soils shall be placed on 10-mil polyethylene sheeting.

At the direction of GSA, some soils may be allowed to not be placed on 10-mil. All water used in the following procedure shall be amended water. Prior to drilling/digging, the contractor shall adequately wet the surface soil to prevent visible emissions. 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 drilling/digging.

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

C. If non-friable ACM is observed, he driller, the CABI and personnel handling the sprayer shall don booties and disposable gloves. The CABI shall pick up and bag the ACM along with some surrounding soils. During drilling/digging, the contractor shall use hand-operated misters/sprayers to ensure that the soil and any suspect asbestos material are adequately wet to prevent visible emissions. All generated soils are required to be containerized or covered by 10-mil polyethylene sheeting. These activities shall continue for to the total depth of the post-hole. The drilling/digging equipment shall be decontaminated as discussed Section 7.0, and standard drilling/digging protocols may resume at the next post-hole location.

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 in a container or on 10-mil polyethylene sheeting. Extra wetting may be required as necessary to ensure that there are no visible emissions. The driller, the CABI, and personnel handling the spray shall don booties, disposable gloves, Tyvex® or equivalent coveralls, respirator, and personal air pumps for air monitoring. The soils shall be containerized or 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 to the total depth of the post-hole. The drilling/digging equipment shall be decontaminated as discussed Section 7.0, and standard drilling/digging protocols may resume at the next post-hole location.

E. When the post-hole is complete, the if suspect ACM or ACS is left in place in the sidewalls of the post-hole, the sidewalls should be stabilized with a spray-on tactifier, magnesium chloride, or other equivalent stabilizer.

F. The post-holes shall be completed as soon as possible after installation. Soil from areas determined to contain ACS or ACM cannot be used as backfill unless it has been representatively sampled for ACS, analyzed using PLM, and determined to be non-detect for asbestos. If post-holes are to be left open overnight, access to the area must be restricted and any exposed portions of the post-hole of or soil piles containing known or suspect visible asbestos or ACS must be covered or otherwise stabilized.

G. Any ACS that is stockpiled shall be covered with 10-mil polyethylene sheeting and inspected daily to ensure the sheeting is intact. For disposal, all ACM and ACS shall be placed in designated containers labeled for asbestos, and shall be loaded using all necessary procedures to prevent visible emissions. These include misting/wetting during the loading process, keeping the soil 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 shall be in accordance with Section 5.5.7 of the Colorado Solid Waste Regulations (e.g., leak tight container or burrito wrap, single or

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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 drilling/digging and loading of known and suspect friable asbestos in soils.

b. In addition to OSHA requirements, for all drilling/digging activities conducted in areas with ACM/ACS, 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 drilling/digging, shall be monitored to assist in determining the adequacy of engineering and environmental controls employed at the site.

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

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

e. In areas were friable ACM has been observed, 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.

f. In areas where only non-friable ACM has been observed, samples will be analyzed by phase contrast microscopy (PCM). Any sample with fiber concentrations 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. In areas immediately adjacent to occupied buildings are near public access areas, at the discretion of GSA, in consultation with CDPHE, TEM analysis may be run on the two samples with the highest cartridge loading (fiber count), even if fiber concentrations are below 0.01 f/cc by PCM analysis.

g. 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:

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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. Drilling/digging activities shall not continue until CDPHE provides verbal and/or written authorization to proceed.

B. Perimeter Air Monitoring for Asbestos, if applicable

Perimeter air monitoring will not be performed unless drilling/digging activities are conducted in areas that are directly adjacent to occupied buildings or public access areas.

The decision to conduct perimeter air monitoring will be made by GSA in consultation with CDPHE. If conducted, the following procedures shall be used for perimeter air monitoring:

a. Perimeter monitoring shall be performed during all drilling/digging activities or movement of asbestos containing soils. This does not include movement of containers, lined roll-offs or lined trucks.

b. Downwind air monitoring shall be conducted during drilling/digging in areas with known or 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 (fiber count) 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.

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

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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 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 drilling/digging activities (such as drill rigs), 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, the GSA CABI may do a limited clearance of a grid to allow vehicle crossing. For grids containing friable asbestos, the grid must be confirmed clean by soil sampling prior to allowing access. As an alternative, ACM/ACS can be covered, as discussed below.

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.

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: For areas determined to have asbestos present on the surface, the wheels of vehicles that have come into contact with soil shall be thoroughly rinsed prior to exiting the area. The driver shall then drive onto a polyethylene tarp and the wheels shall be re-rinsed. A 60-mil or greater liner may be used multiple times, or 10-mil

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9. Decontamination: The drill rig 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 ACS location to another, the drilling/digging equipment that came into contact with ACM/ACS shall be wrapped in 10-mil polyethylene sheeting to prevent spreading fibers to non-contaminated areas. Prior to moving from one ACS area to an non-ACS area, or when drilling/digging activities are complete, all drilling/digging equipment that came in contact with ACM/ACS shall be decontaminated in accordance with SOP 1 within a container (i.e., tub or half drum), within a designated decontamination area designed to capture water, or over ACS that has been containerized for disposal.

10. All decontamination water must be collected, filtered with 5-micron filter, and then disposed in a sanitary sewer. Subject to GSA site-specific approval, the equipment decontamination water may be collected, filtered with a 5-micro filter, and placed on a known asbestos area, or added to ACS prior to disposal. As an alternative, equipment decontamination water may be filtered, sampled and analyzed for asbestos, and handled as non-asbestos contaminated if no asbestos is detected.

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 grid.

Personnel and equipment performing work under this SOP shall be decontaminated in accordance with the procedures in SOP 1. 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 and/or post-hole drilling/digging should wear booties, disposable gloves, and if friable asbestos is encountered, disposable outer protective suits (Tyveks), which should then be discarded as asbestos waste prior to exiting the site. Any nondisposable personnel items must be decontaminated in accordance with SOP 1.

Sampling equipment, drilling/digging equipment (augers), wheelbarrows, vehicles, and other equipment that comes in contact with soil known to contain, or potentially contain asbestos shall be decontaminated in accordance with SOP 1 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 10).

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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

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Form 26-A1: Asbestos Material Sample Field Data Sheet

Sample Identification No.

Project Information Area Name: Corridor 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:

Sa…