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Asbestos-Contaminated Soil Regulations in Colorado

Asbestos-Contaminated Soil Regulations in Colorado. Colleen Brisnehan Colorado Department of Public Health And Environment Hazardous Materials and Waste Management Division. Asbestos-contaminated soil

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Asbestos-Contaminated Soil Regulations in Colorado

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  1. Asbestos-Contaminated Soil Regulations in Colorado Colleen Brisnehan Colorado Department of Public Health And Environment Hazardous Materials and Waste Management Division

  2. Asbestos-contaminated soil Asbestos-contaminated soil has been identified at several sites in Colorado; it is also an emerging national issue Potential exposure risks when disturbed Proper management necessary to prevent exposure Background

  3. Background • Management previously conducted under: • Colorado Solid Waste Act and Regulations • Colorado Hazardous Waste Act • Air Quality Control Commission Regulation No. 8 • These regulations lacked specific requirements for management of asbestos-contaminated soil • Needed clear regulations that codified the risk-management approach already applied at sites in Colorado

  4. New Regulations • Amendment to the Colorado Solid Waste Regulations (6 CCR 1007-2, Part 1): • Section 1.2 - Definitions • Section 5.5 - Asbestos-Contaminated Soil • Adopted February 15, 2006 • Became Effective April 30, 2006

  5. Overview of Asbestos Exposure and Risk Issues • Asbestos is a generic term used to describe the fibrous varieties of six minerals which fall into two categories: serpentine and amphibole. • Asbestos is known to be persistent in the environment. • All types of asbestos are a known human carcinogen and can cause nonmalignant lung and pleural diseases. • The 1% threshold for asbestos in soil/debris may not be protective of human health and should not be used as the default action level (EPA, 2004). • Soil/debris containing significantly <1% of all types of asbestos can pose unreasonable risk to human health (EPA, 2004). • Asbestos fibers in soil/debris do not inherently pose a risk to human health if left undisturbed.

  6. Overview of Asbestos Exposure and Risk Issues (cont.) • Health risks from asbestos-contaminated soil/debris will depend on the potential for asbestos to become airborne and be inhaled. • EPA IRIS cancer risk-based acceptable (“safe”) level of asbestos in air = 0.000004 f/cc at a risk level of 1 in a million. • The concentration of asbestos in soil corresponding 0.000004 f/cc in air is not known at this time. • Asbestos health risk assessment is an evolving science and EPA is developing a risk assessment toolbox. • Current risk assessment methods can be used to: • Demonstrate complete exposure pathway(s); and • Estimate risk qualitatively/semiquantitatively

  7. Exposure Evaluation • Several studies using a variety of approaches to evaluate the release of asbestos fibers from significantly <1% asbestos in soil/debris demonstrated: • All types of asbestos fibers can be released into the air or breathing zone during soil disturbing activities resulting in unacceptable risk: • Significantly above acceptable cancer risk level of 1 in a million at 0.000004 f/cc (EPA IRIS) • Even above the OSHA limit of 0.1 f/cc, in some cases Irrespective of fiber type or soil type, as low as 0.001 % asbestos in soil can generate airborne respirable asbestos concentration of >0.1 f/cc (Addison et al., 1988)

  8. Exposure: Activity-Based Personal Monitoring • Libby studies (EPA, 2001 Weis Memo): • Rototilling of garden soil (<1% asbestos) • 0.066 f/cc in personal monitor (Cancer risk = 1 in 100,000) • 0.019 f/cc in stationary monitor • Soil bagging and sweeping floors (<1% to 6% asbestos) • >5.0 f/cc (above OSHA limit of 0.1 f/cc) • Oregon studies (EPA, 2004 Januch and McDermott): • Leaf blowing (soil <1% asbestos) • 0.045 f/cc for equipment operator • 0.033 f/cc for observer

  9. Exposure: Modified Elutriator MethodBerman and Kolk (2000) • Initial Health Risk Assessment at the Former Lowry Air Force Base, Colorado (Parsons, 2004): <1% chrysotile in surface soil resulted in excess potential cancer risks, for example: • Running and walking by residents = 1 or 4 in 100,000 • Construction worker = 2 in 10,000 Overall potential risks are underestimated due to major limitations of dust models used to predict airborne asbestos exposures

  10. Assessment Of Health Risks For Asbestos-Contaminated Soil/Debris • Potential Exposure Pathways: • Outdoor activities routinely performed by residents (child and adult), for example: • Gardening; rototilling; weeding; bagging and sweeping of excavated soils; children playing with soil/debris; • Transport from outdoor to indoor: • Wind through open doors and windows • Track-in of adhered fibers on clothing and shoes of children and adults, and through pet animals • Children physically carrying asbestos-contaminated soil/debris Outdoor and indoor asbestos sources act as a reservoir of fibers that could continue to be released to the air as a result of routine activities

  11. Current Issues In Risk Assessment of Asbestos-Contaminated Soil/Debris Examples of Major Issues/Limitations: • Improved methods are being developed for asbestos analyses and to determine asbestos release • Potential future indoor exposures as a result of outdoor-to-indoor transport are difficult to quantify • Exposure assessment provides a snap-shot in time • Cancer and noncancer toxicity is being re-evaluated • Better definition of asbestos fiber to relate to its toxic potential is needed Current methods for estimating asbestos exposure dose allow qualitative/semiquantitative screening risk assessment

  12. New Regulations - Our Goal • Take a pragmatic approach to regulation of asbestos-contaminated soil • Management of disturbed soils; not remediation • Triggers: • visible asbestos • reason to know asbestos is present in soil • Key Sections: Applicability/Exemptions • Put new asbestos-contaminated soil regulations into Solid Waste Regulations • HMWMD versus APCD (soil contamination; not abatement) • SW versus HW (asbestos is not a listed or characteristic hazardous waste)

  13. Changes to Solid Waste Regulations • Updates to existing language: • Section 1.2 – Definitions • Part 5 (Sections 5.1 though 5.4) – Asbestos Waste Disposal Sites • New Section 5.5 for asbestos-contaminated soil

  14. Requires proper management - ONLY when asbestos-contaminated soil is disturbed No requirement to ‘chase’ or remediate asbestos contamination Clarifies requirements for: Identification Onsite management Disposition Section 5.5 Asbestos-Contaminated Soil

  15. Applicability Owners or Operators of sites: With asbestos-contaminated soil based on: • visible observation • past sampling, or • knowledge/data of historical activities And, with current or planned soil-disturbing activities Removal of Asbestos-Containing Material • On a facility component And, on or in soil that will be disturbed And, below AQCC Regulation No. 8 trigger levels • Pieces that are not on a facility component And, on or in soil that will be disturbed

  16. Exemptions Does Not Apply to: • Removal of solely non-friable asbestos from soil • Abatement of facility components under AQCC Regulation No. 8 • Spill response under AQCC Regulation No. 8 • Naturally occurring asbestos • “Background” not associated with site activities • De Minimis Projects • Less than 1 cubic yard • And, using low-emission excavation methods • Projects by home owner on primary residence

  17. Key Definitions Asbestos-Contaminated Soil Soil containing any amount of asbestos. Soil-Disturbing Activities Excavation, grading, tilling, or any other mechanical activity. Facility Component Any part of a “facility” including equipment. “Facility” - as defined in AQCC Regulation No. 8

  18. Unplanned Asbestos Discovery • Immediate actions • Stop soil-disturbing activities • Control site access • Stabilize surface soil • 24-hour notification • Property and project information • Interim Actions • Take appropriate measures to control emissions • Submit a Soil Characterization and Management Plan, or implement approved standard procedures

  19. Planned Asbestos Management • Ten working day notification • Property and project information • Soil Characterization and Management Plan • Site Information • Any proposed characterization • The proposed soil-disturbing activities • Proposed exposure mitigation and asbestos fiber control measures • Site access control • Air monitoring plan • Emissions control plan • Exposure mitigation plan for asbestos left in place • Disposal plan

  20. Remediation If property owner chooses to remediate: • Submit an asbestos remediation plan that complies with Section 5.5 and includes: • Soil Characterization and Management Plan • Detailed description of planned remediation • Proposed use of the property and area of remediation • Any planned engineering controls to prevent exposure to any asbestos left in place

  21. Training and Certification • On-the-job asbestos-contaminated soil awareness training • Individuals conducting soil-disturbing activities • Asbestos awareness training, in accordance with OSHA requirements • Individuals conducting soil-disturbing activities in areas with asbestos • Training conducted by: • Asbestos Supervisor, Building Inspector or Project Designer certified in accordance with AQCC Regulation No. 8 • With 6 months of asbestos-contaminated soil experience

  22. Training and Certification (cont.) • Inspection and identification of asbestos • Asbestos Building Inspector certified in accordance with AQCC Regulation No. 8 • And, with 6 months of asbestos-contaminated soil experience • Soil Characterization and Management Plans • Prepared and signed by an Asbestos Project Designer certified in accordance with AQCC Regulation No. 8 • Air monitoring • By an Air Monitoring Specialist certified in accordance with AQCC Regulation No. 8

  23. Disposal Asbestos-Contaminated Soil with: • Visible friable asbestos • Transported and disposed in leak tight containers • Disposed of as friable asbestos waste • Only visible non-friable asbestos • Transported and disposed in leak tight containers • Disposed of as non-friable asbestos waste • No visible asbestos • Transported and disposed in leak tight containers • Disposed of in the same manner as non-friable asbestos waste Soil that is not asbestos-contaminated can be replaced into the disturbed area

  24. Fees • In accordance with Section 1.7.2 • Based on total documented costs • Review of Soil Characterization and Management Plan • Review of related documents • Department oversight activities • Paid by the owner, operator, or person conducting soil-disturbing activities

  25. Guidance Document • Broad overview of asbestos-contaminted soil • Solid Waste Regulations • Hazardous Waste Regulations • Voluntary Cleanup Program • Best management practices andexposure mitigation methods • Working draft - continue to solicit stakeholder input • Update as necessary based on feedback during implementation of the regulations

  26. Additional Information Solid Waste Regulations http://www.cdphe.state.co.us/regulations/solidwaste/ 100702disposalsites&facilities.pdf Draft Guidance Document http://www.cdphe.state.co.us/hm/asbestosinsoil.pdf Contact Information Colleen Brisnehan (303) 692-3357 colleen.brisnehan@state.co.us

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