United States National Risk Management

Environmental Protection Research Laboratory

Agency Cincinnati, OH 45268

Project Summary

Research and Development EPA/600/SR-97/063 July 1997

Abstract

The Asbestos Hazard Emergency Response Act (AHERA) required all

schools to develop and implement an

asbestos management plan (AMP). The

key component of the AMP is the operations and maintenance (O&M) program. A study was conducted to evaluate the implementation of O&M programs at ten sites representing eight

New Jersey schools. The evaluation included aspects required by AHERA as

well as those recommended in the Environmental Protection Agency’s (EPA)

guidance. Each school’s O&M program

and compliance with their program during past O&M activities were documented. In addition, ten ongoing O&M

activities were documented to determine the impact of the activities on

airborne asbestos levels and to determine compliance with the O&M program during these activities. Overall,

schools were not implementing all the

elements of the O&M program. Schools

performed more O&M program elements required by AHERA than those

recommended in EPA guidance. The

percentage of performance responses

given by the schools indicating that

the elements of the O&M programs were

performed (52%) was higher than those

provided by the worker or contractor

performing the activity (35% and 22%

respectively). Increases in area asbestos levels (by transmission electron

microscopy [TEM]) were observed during five of the ten O&M activities evaluated, however, none of the total fiber

levels (by phase contrast microscopy

[PCM]) exceeded the Occupational

Evaluation of the Implementation of

Operations and Maintenance

Programs in New Jersey Schools

John R. Kominsky, Ronald W. Freyberg Donald R. Gerber, Gary J. Centifonti

Safety and Health Administration

(OSHA) Permissible Exposure Limit

(PEL). This study underscores the importance of a thorough O&M program

and the effective communication and

implementation of all program elements.

This Project Summary was developed

by the National Risk Management Research Laboratory’s Sustainable Technologies Division, Cincinnati, OH, to

announce key findings of the research

project that is fully documented in a

separate report of the same title (see

Project Report ordering infomration at

back).

Introduction

The concern for asbestos-containing materials (ACM) in buildings started in the late

1970s in the U.S. In 1978 the EPA issued

a two-volume guidance document to schools

for identification and evaluation of in-place

asbestos. Subsequently, three additional

guidance documents were issued by the

EPA in 1983, 1985, and 1990.

Although removal was encouraged over

alternative approaches of asbestos management in the past, in-place management and O&M programs are currently

viewed by the EPA as the most appropriate overall strategy for management of

asbestos in buildings. In-place management involves the use of building O&M

work practices and control measures that

minimize the release of airborne fibers

from ACM, thereby reducing exposures

and associated risks to workers and other

building occupants.

Operations and maintenance programs

must be prepared and implemented when-
2

ever friable ACM is present or assumed

to be present in school buildings. An O&M

program is an administrative framework

that prescribes specific work practices and

training to maintain friable ACM in good

condition, ensure cleanup of asbestos fibers previously released, and prevent future release by minimizing and controlling

friable ACM disturbance during installation, repair, maintenance, and cleaning

activities. A well-developed O&M program

is ineffective unless it is implemented properly. The O&M program’s success is contingent upon the commitment of all personnel involved in developing, conscientiously implementing, and conducting O&M

activities.

Although these O&M programs have

been prepared for schools, no representative field studies have been conducted

to evaluate the implementation and effectiveness of these programs in controlling

the release of asbestos fibers into a building. The purpose of this study was to

evaluate the implementation of O&M programs in selected schools in New Jersey.

Objectives

The objectives of this study were to (1)

document and assess each school’s O&M

program and other related components in

the AMP; (2) document and assess each

school’s compliance with their O&M program during previously conducted O&M

activities; (3) observe and document the

conduct of selected O&M activities involving ACM or in the vicinity of ACM; and (4)

determine the impact of selected O&M

activities on airborne asbestos levels.

Site Selection

An “O&M Activities Survey Form” was

distributed to 26 candidate schools representing 14 different school districts that

planned to perform O&M activities involving ACM or activities in the vicinity of

ACM during the summer of 1994. This

form solicited information regarding three

types of O&M activities: (1) Operations

(custodial/service); (2) Maintenance (heating, ventilation, and air-conditioning, plumbing, electrical/communications, fire protection, and other building systems or components); (3) and Renovation (general

space modifications, ceiling tile replacement, carpet removal, and roofing repair).

Eight schools, representing ten distinct

O&M activities, were selected based on

the type of planned activity and the schedule for conducting the planned activity.

The results obtained from the different

schools studied were used to document

the implementation of the O&M programs

at these schools and to identify common

factors that may influence airborne asbestos levels during O&M activities on or near

ACM.

Evaluation of O&M Programs

A “Site Evaluation/Assessment Documentation Form” was used to standardize

the evaluation of each school’s O&M Program. To prevent any ambiguity regarding

the questions or recording of the responses, the form was administered by

an Environmental Health Services-New

Jersey Department of Health (EHSNJDOH) representative who was thoroughly instructed on the basis of each

question, as well as its application to the

various parts of the evaluation (i.e., Parts

1, 2, and 3 as described below). To ensure data consistency the same persons

completed the Site Evaluation/Assessment

Documentation Form.

Each school’s O&M program evaluation

included three primary parts. Part 1 involved a review of each school’s O&M

program and other related components in

the AMP on file with the NJDOH to determine the overall comprehensiveness of

the O&M program. Part 2 involved an onsite interview with the school’s AHERA

Designated Person to assess each

school’s compliance with their O&M program during previously conducted O&M

activities. Part 3 involved interviewing the

school’s AHERA Designated Person and

observing and interviewing the worker

(school employee or contractor) performing an actual O&M activity.

Part 1 - Each school’s AMP, which was

on file with the EHS-NJDOH, was evaluated by an EPA-accredited Inspector and

Management Planner prior to initiating the

planned activity. The Inspector/Management Planner completed the Site Assessment/Documentation Form during the review of the school’s O&M program. The

evaluation included the program elements

required by AHERA as well as those elements recommended by EPA in issued

guidance. Therefore, the evaluation was

based on three categories of program elements: those program elements required

by AHERA; those program elements recommended in EPA guidance documents;

and all of the program elements (i.e., those

required by AHERA and those recommended in EPA-issued guidance). A “Site

Evaluation/Assessment Documentation

Form” was used to standardize the evaluation of the respective O&M programs.

Each school’s O&M Program was evaluated regarding the following elements:

• Comprehensiveness: The program

should be developed by a qualified

Asbestos Management Planner and

implemented by a qualified Asbestos

Program Manager/Designated Person

following a comprehensive building

inspection to identify and assess the

condition of all ACM in the building.

The written O&M Program should be

site-specific and take into account

function and building design. The program should address specific activities and procedures related to use,

cleaning, maintenance, repairs, equipment service, and fiber release episodes.

• Administration/Awareness: The written AMP should be available at the

school and updated to keep it current

with ongoing O&M, periodic surveillance, inspection, reinspection, and

response action activities. Additionally, maintenance and custodial personnel must be made aware and have

reviewed the AMP and O&M Program

prior to conducting activities.

• Notification: AHERA requires that

workers (school employees and contract workers), tenants, and building

occupants be notified where ACM is

located, and how and why to avoid

disturbing the ACM. All persons affected should be properly informed.

• Surveillance: AHERA requires regular 6-month ACM surveillance and 3-

year reinspections to note, assess,

and document any changes in the

condition of the ACM.

• Controls: The program should include

a work control/permit system to control activities that might disturb ACM.

• Work Practices: The program should

describe O&M work practices to avoid

or minimize fiber release during activities affecting ACM.

• Recordkeeping: AHERA requires specific documentation of O&M activities.

• Worker Protection: AHERA requires

medical and respiratory protection programs, as applicable.

• Training: AHERA requires proper

training of custodial and maintenance

staff who may deal with activities involving ACM.

Part 2 - Information regarding previously conducted O&M activities at the

school was obtained by interviewing each

school’s designated person using the “Site

Evaluation/Assessment Documentation

Form.” This information included the type

and location of the O&M activity, the date

of the activity, whether key elements of

the O&M program were followed, etc. This

information was used to assess the

school’s perception of compliance with

their O&M program during previously conducted O&M activities.
3

Part 3 - Selected O&M activities involving ACM, or in the vicinity of ACM, were

observed and documented at each school

by using the Site Evaluation/Assessment

Documentation Form. The school’s

AHERA Designated Person was observed

and interviewed. In addition, the school

employee or contract worker performing

the O&M activity was also interviewed regarding use of the elements (e.g., work

practices and procedures) specified in the

school’s O&M program. This information

was used to determine the extent of actual compliance with their O&M program

during the activity.

Impact of O&M Activities on

Airborne Asbestos Levels

The impact of the selected O&M activities on the exposure of custodial workers,

maintenance workers, and/or building occupants was evaluated by air monitoring

for asbestos structures and total fibers.

Characterization of the ACM or source of

asbestos structures potentially involved in

the O&M activity or near the O&M activity

was determined by collecting bulk samples

of the material(s).

Sampling Methods

Fixed-Station Area Air Samples

The fixed-station area air samples were

collected on open-face, 25-mm diameter,

0.45-μm poresize, mixed cellulose ester

(MCE) filters with a 5-μm poresize MCE

diffusing filter and cellulose support pad

contained in a three-piece cassette. The

labeled filter cassettes were positioned on

tripods approximately 5 feet above the

floor with the filter face at a 45° angle

toward the floor. The filter assembly was

attached to an electric-powered (110 VAC)

1/6-horsepower vacuum pump operating

at a flowrate of approximately 9 liters per

minute (L/min).

Personal Breathing Zone

Samples

One personal breathing zone air sample

was collected on an open-face, 25-mm

diameter, 0.8-μm poresize MCE filter and

cellulose support pad contained in a threepiece cassette with a 50-mm conductive

extension cowl. This sample was collected

in accordance with NIOSH Method 7400

for analysis by PCM for comparison to the

OSHA PEL. Two additional personal

breathing zone air samples were collected

on open-faced, 25-mm-diameter, 0.45-μm

poresize MCE filters with a 5-μm poresize

MCE diffusing filter and a cellulose support pad contained in a three-piece cassette. These two samples were collected

for analysis by TEM. The three labeled

filter cassettes were positioned in the

breathing zone of the individual performing the O&M activity. Each filter was attached to approximately 50 feet of Tygon

tubing that was attached to an electricpowered (110 VAC) 1/6-horsepower

vacuum pump operating at a flowrate of

approximately 9 L/min. Traditional batterypowered, personal sampling pumps could

not be used because of their limited airflow rates (approximately 2 L/min with the

0.45-μm poresize MCE filter with a 5-μm

poresize MCE diffusing filter and a cellulose support pad contained in a threepiece cassette).

Analytical Methods

Area Air Samples

The MCE filters were prepared and analyzed in accordance with the nonmandatory

TEM method specified in the AHERA Final Rule (October 30, 1987; 52 CFR 4826).

In addition to the requirements of the

AHERA nonmandatory TEM method, the

specific length and width of each structure

were measured and recorded. A sufficient

number of grid openings were analyzed to

ensure a sensitivity (the concentration represented by the finding of a single structure) of no greater than 0.005 asbestos

structures per cubic centimeter of air

sampled, unless the degree of loading

made this impractical. On heavily loaded

samples, counting stopped after completion of the grid square in which the 100th

asbestos structure was found.

Personal Breathing Zone

Samples

The 0.8-μm poresize MCE filters were

analyzed by PCM. These samples were

prepared and analyzed according to the

NIOSH 7400 protocol (Revision 3, June 5,

1989, NIOSH Manual of Analytical Methods). All fibers > 5 μm in length and with

an aspect ratio of > 3:1 were counted

using the “A” counting rules. The analytical sensitivity was approximately 0.01 fiber per cubic centimeter of air sampled.

Bulk Samples

The type and percentage of asbestos in

bulk samples was determined by polarized light microscopy (PLM) and X-ray

diffraction (XRD) in accordance with the

“Interim Method for Determination of Asbestos in Bulk Samples” (EPA-600/M4-

82-020).

Statistical Methods

Airborne asbestos levels measured before and during each O&M activity were

characterized for each site by the use of

descriptive statistics. The descriptive statistics included the arithmetic mean, minimum and maximum concentrations, and

sample size. A one-factor analysis of variance (ANOVA) was used to examine overall differences between baseline concentrations, area air concentrations measured

during the O&M activity, and personal

breathing zone concentrations measured

during the activity. The transformation In(x

+ 0.002), where In is the natural logarithm

and x is the mean airborne asbestos concentration, was applied to each measurement before the ANOVA was performed.

The transformation was used to make variances more equal and to provide data

that are better approximated by a normal

distribution. The constant 0.002, a value

chosen to be smaller than the majority of

analytical sensitivities, was used because

some zero values were present (the natural logarithm of zero is undefined). The

transformation was used only for the

ANOVA analysis; it was not used for any

other part of the data analysis (e.g., plots

or descriptive statistics). The data were

transferred back to the original scale for

reporting purposes. The Tukey multiple

comparison procedure was used to distinguish pairwise differences between mean

concentrations. All statistical comparisons

were conducted at the 0.05 level of significance.

Quality Assurance

During the study, sample chain-of-custody procedures were an integral part of

both the sampling and analytical activities

and were followed for all air and bulk

samples collected. The field custody procedures documented each sample from

the time of its collection until its receipt by

the analytical laboratory. Internal laboratory records then documented the custody of the sample through its final disposition. Specific quality assurance procedures outlined in the AHERA rule were

used to ensure the precision of the collection and analysis of air samples, including

filter lot blanks, open and closed field

blanks, and repeated sample analyses.

Results and Discussion

Site Descriptions

Eight schools representing seven school

districts were surveyed during this study.

All eight of these schools have participated in past asbestos-related studies conducted cooperatively by EPA and EHSNJDOH. A total of ten O&M activities were

evaluated at these eight schools; two activities were evaluated at two of the schools

(Sites F and G) and one activity was evaluated at each of the other six schools. A

summary matrix of each study site and
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Table 1. Summary of O&M Activities Evaluated by SITE

Site O&M Category Description of O&M Activity

A Operationsa Wet-stripping of resilient floor tile.

B Maintenancea HEPA-vacuuming of boiler interior.

C Renovation Space modification (demolition of plaster walls/ceilings; pipes).

D Maintenancea HEPA-vacuuming of HVAC unit in classrooms.

E Renovation Removal of carpet over resilient floor tile.

F1 Maintenancea HEPA-vacuuming of interior air handling unit.

F2 Maintenance Wiring pulled above suspended ceiling for smoke detectors.

G1 Renovationa Removal/replacement of suspended ceiling panels.

G2 Maintenance Romex cable pulled above suspended ceiling.

H Maintenance Holes drilled in acoustical plaster to install smoke detectors.

a

Denotes that the work was performed by an employee of the school.

the O&M activity evaluated is presented

in Table 1.

Assessment of O&M Programs

The evaluation of the data for each

school’s O&M program was grouped into

three categories: AHERA Elements, including those program elements required

by AHERA; Guidance Elements, including

those program elements recommended in

EPA-issued guidance; and All Elements,

including all of the program elements (i.e.,

the first two categories combined). Each

school’s O&M program evaluation was also

divided into three primary parts: Part 1

(AMP), which included the information contained in the school’s AHERA AMP filed

with the EHS-NJDOH; Part 2 (previous

O&M activities), which included the previously conducted O&M activities information obtained by interviewing each school’s

AHERA Designated Person; and Part 3

(observed O&M activities), which included

the information obtained by direct observation of O&M activities.

Comparison By Category

Table 2 summarizes the individual performance responses for each site by part

and category. It also presents the overall

average percentage of performance response for all sites by part and category.

The responses to questions on the Site

Assessment/Documentation Form are

termed “performance responses” in this

report. A “yes” indicates an affirmative response to the respective question, as well

as indicates that the particular activity or

function had been accomplished.

AHERA Elements - Overall, the performance responses were highest for elements required by AHERA. The AMP performance responses ranged from 69.6%

to 95.7% with an average of 88.3%. At

seven of ten sites, the AMP’s indicated

greater than 90% performance response.

Only one site’s AMP had less than 70%

performance response. It should be noted

that for the evaluation of the information

required by AHERA in the AMP, it is possible to have less than 100% performance

for the purpose of this study. Some O&M

program elements could not be verified

because they would not be performed until a future date, i.e., a date beyond the

time when the AMP was reviewed by the

EHS-NJDOH inspector. In previous O&M

activities, performance responses in eight

of ten sites were less than those noted in

the AMP. In the observed O&M activities,

performance responses in all sites were

less than those documented in the AMP

and averaged 58.9%.

Guidance Elements - Overall, in all three

parts, the performance responses noted

in this category were the lowest. The AMP

performance responses ranged from 7.1%

to 71.4% with an average of 41.4%. At

eight of ten sites, the AMP indicated less

than 70% performance response. The

lower responses could be attributed to

some of the guidance information (particularly the “Green Book”) not being available when the AMP’s were prepared in

1987 to 1989. The performance responses

averaged only slightly higher in previous

O&M activities (54.1%) and during the observed O&M activities (44.0%).

Although all of the guidance was available for approximately five years prior to

this evaluation, the most recent EPA guidance (the “Green Book”) is not geared

specifically toward schools, but for buildings in general. Therefore, the schools

may not be aware of the guidance or may

choose not to implement the guidance

recommendations since it’s not a regulatory requirement. A comparison of the data

contained in the AMP, with the performance responses from previous O&M activities and a comparison with the observed

O&M activities and a comparison suggest

a trend in decreasing percentage of performance responses. The AMP’s documented an average performance response

of 70.6%, whereas the school stated that

it performed 57.6% of the O&M elements

during previous O&M activities, and performed 49.2% of the elements during the

observed O&M activity. In the observed

O&M activities, performance responses in

eight of ten sites were less than those

noted in the AMP.

Comparisons by Part

Table 2 summarizes the individual performance responses for each site by part

and category. It also presents the average percentage of performance response

for all sites by part and category.

Part 1 - At all sites, the individual percentage of AHERA element performance

responses was higher than those recommended in EPA Guidance elements. The

number of sites with performance responses less than 70% was only one of

ten for AHERA elements and eight of ten

for Guidance elements. The average performance response for AHERA elements

(88.3%) was 53.1% higher than the average performance response for Guidance

elements (41.4%).

Part 2 - The average performance response for Guidance elements (54.1%)

was 9.8% lower than the average performance response for AHERA elements

(60.0%). All three categories had six of

ten sites with performance responses less

than 70%.

Part 3 - The average performance response for Guidance elements (44.0%)

was 25.3% lower than the average performance response for AHERA elements

(58.9%). Both the AHERA elements and

Guidance elements categories had seven

of ten sites with performance responses

less than 70%.

Comparisons of School, Worker,

and Contractor Performance

Responses

Further evaluation was made to compare the performance responses of the

school officials to those of the persons

actually performing the observed O&M

activity. Both the school Designated Person and the school maintenance worker
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Table 2. Percentage of Performance Responses for Program Elements

Required by AHERA EPA Guidance All Elementsd

Study Site Part 1a Part 2b Part 3c Part 1 Part 2 Part 3 Part 1 Part 2 Part 3

A 95.7 58.3 66.7 50.0 47.1 46.7 78.4 53.7 54.2

B 91.3 50.0 22.2 35.7 41.2 6.7 70.3 46.3 12.5

C 78.3 95.8 77.8 50.0 100 80.0 67.6 97.6 83.3

D 91.3 54.2 77.8 71.4 23.5 20.0 83.8 41.5 33.3

E 69.6 95.8 66.7 7.1 76.5 66.7 45.9 87.8 66.7

F1 95.7 12.5 44.4 14.3 23.5 13.3 64.9 12.5 25.0

F2 95.7 16.7 44.4 14.3 23.5 13.3 64.9 19.5 25.0

G1 91.3 75.0 55.6 50.0 8.2 80.0 75.7 80.5 70.8

G2 91.3 75.0 55.6 50.0 88.2 73.3 75.7 80.5 66.7

H 82.6 66.7 77.8 71.4 29.4 40.0 78.4 51.2 54.2

Average 88.3 60.0 58.9 41.4 54.1 44.0 70.6 57.6 49.2

a

Part 1 involved a review of each school’s Asbestos Management Plan.

b

Part 2 involved an interview with the school’s AHERA Designated Person regarding previous O&M activities.

c

Part 3 involved information from the school’s AHERA Designated Person and the individual performing the observed O&M activity.

d

Includes the O&M program elements required by AHERA and those recommended in EPA-issued guidance.

or the outside contractor performing the

activity where asked specific questions regarding the observed O&M activities. Table

3 summarizes the responses for these

specific questions for the “All Elements”

and “AHERA Elements” categories. The

performance response for “All Elements”

indicated by the school Designated Person was 52.5%, whereas the performance

response indicated by the school maintenance worker was 35%. The outside contractor indicated that 22.5% of the O&M

elements were performed. Approximately

a 33.3% decrease in the performance response from the school Designated Person to the school maintenance worker was

also observed. Similarly, a 57.1% decrease

in the performance response from the

school Designated Person to the outside

contractor was observed. This also reflects a 35.7% decrease in performance

response from the school maintenance

worker to the outside contractor. The performance responses for “AHERA Elements” were very similar as was the trend

of decreasing performance responses from

the school Designated Person to the

school maintenance worker and the outside contractor.

Comparisons by Program

Elements

Table 4 presents the performance responses to the individual program elements for both the AHERA-required and

EPA-recommended elements by Parts 1,

2, and 3. Generally, decreases in performance responses for each element is

noted from the elements documented in

the AMP (Part 1), to previous O&M activities (Part 2), and to what was actually

observed during the O&M activity (Part 3).

Across all sites for each program element, an overall average was calculated.

When the AMP is evaluated according to

the “All Elements” category; surveillance,

recordkeeping, and training had the highest percentage of performance responses.

Other program elements scored less, with

all being less than 80%. Work practices

and work permit system program elements

scored the lowest with 57.5% and 38.9%,

respectively.

Impact of O&M Activities on

Airborne Asbestos Levels

TEM Air Monitoring Results

Airborne asbestos levels were measured

before and during each O&M activity at

each site. A one-way ANOVA was used

to compare airborne asbestos levels measured before each activity to area and

personal breathing zone levels measured

during the activity at each site. Table 5

summarizes the results of these comparisons for each O&M activity. Some O&M

activities were performed in the vicinity of

ACM without causing elevated airborne

asbestos levels. Five of ten activities (Sites

A, C, F1, F2, and H) showed significant

increases in airborne asbestos levels during the associated O&M activity when compared to baseline measurements. Additionally, when O&M activities disturbed

ACM in the vicinity or were conducted on

ACM, airborne asbestos levels were elevated at or above 0.02 s/cm3

 in four of

ten sites (A, C, F1, and H). The 0.02 s/cm3

criterion was derived from the AHERA

clearance criterion of 70 s/mm2 (40 CFR

763). Another study, conducted over a 4

year period, concluded that O&M activities that disturbed ACM (including thermal

system insulation and plaster, and resilient floor tile) may have contributed to

elevated airborne asbestos levels at several of the sites.

The airborne asbestos levels measured

during wet-stripping of the resilient floor

tile were three orders of magnitude higher

than the levels measured during the other

O&M activities. These elevated levels during wet-stripping of resilient floor tile are

consistent with those levels measured during other studies involving the same floor

care maintenance practice.

 Additionally, a study previously conducted on the spray-buffing of resilient

floor tile demonstrated that this common

maintenance procedure increased airborne

asbestos levels at the majority of the study

sites.
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Table 3. Percentage of Performance Responses for Part 3 with Individual School Designated Person,

Worker, and Contractor Responses

Percentage of Performance Responses

School

Elements Designated Person School Worker Contractor

All Elements 52.5 35.0 22.5

AHERA Elements 60.0 37.5 25.0

Table 4. Average Performance Responses for all SITES by Element and Part - All Elements Category

Parts

Program Elements 1a 2b 3c

Administration 72.3 66.4 68.0

Notification 76.7 30.0 35.0

Surveillance 100 75.0 -

Work Control/Permit System 38.9 45.6 38.9

Work Practices 57.5 44.0 33.3

Recordkeeping 97.5 70.0 75.0

Personal Protective Equipment 70.0 50.0 80.0

Training 90.0 65.0 45.0

Totals 70.6 57.6 49.2

a

Part 1 involved a review of each school’s Asbestos Management Plan.

b

Part 2 involved an interview with the school’s AHERA Designated Person regarding previous O&M

activities.

c

Part 3 involved information from the school’s AHERA Designated Person and the individual performing

the observed O&M activity.

Table 5. Summary of ANOVA Comparisons

ANOVA

Site-Activity p-value Tukey pairwise comparisonsa,b,c

Site A - Perform wet-stripping of resilient floor tile 0.0001 B(0.002) DP(3.29) DA(3.91)

Site B - Vacuum interior of boilers 0.3627 DP(0.002) B(0.003) DA(0.006)

Site C - Contact space modification 0.0102 B(0.003) DA(0.020)

Site D - Vacuum air-handling unit 0.4889 B(0.002) DA(0.003) DP(0.003)

Site F1 - Changer filter and vacuum air-handling unit 0.0254 B(0.003) DA(0.007) DP(0.042)

Site F2 - Install smoke detector wing 0.0059 DA(0.003) B(0.003) DP(0.009)

Site G1 - Remove/replace ceiling tile 0.5192 DA(0.004) DP(0.006) B(0.007)

Site G2 - Install flexible electrical conduit above 0.5650 B(0.004) DA(0.009) DP(0.008)

 suspended ceiling

Site H - Install fire alarm system 0.0001 B(0.003) DA(0.053) DP(0.120)

a

B = Baseline; DA = Area samples taken during the activity; DP = Personal samples taken during the

activity

b

Parenthetical entries are geometric average airborne asbestos concentrations (s/cm3). c

Average concentrations connected by a line are not significantly different.

In general, personal breathing zone levels tended to be slightly higher than area

levels during the activities. This difference,

however, was statistically significant during only one activity. The higher concentrations of asbestos measured by the personal breathing zone samples than the

concentrations measured by the fixed-station area samples at Site F2

 are most

likely attributable to differences in the proximity of the sampling cassettes to the

source of the asbestos release; i.e., the

O&M activity.

PCM Air Monitoring Results

None of the personal breathing zone

levels exceeded the OSHA PEL of 0.1 f/

cm3, 8-hour time weighted average (TWA).

The 8-hour TWA concentrations were calculated by assuming zero exposure both

before and beyond that which was measured during the activity.

Conclusions

The following are the principal conclusions reached during this study:

1. Overall, schools were not completely

implementing all the elements of the

O&M program within the AMP as

outlined in AHERA or in EPA guidance documents. The O&M programs ranged in overall comprehensiveness from 45.9% to 83.8% with

an average of 70.6%.

2. School Designated Persons may not

be aware of all program elements in

the AMP. The overall percentage of

performance responses given by the

school officials during the observed

O&M activities was 52.5%. The

school maintenance worker indicated

a performance response of only 35%,

while the outside contractor indicated

an even lower performance of 22.5%.

All elements were not implemented

and/or communicated by the school’s

designated person. Additionally, all

program elements were not performed by the workers/contractors

conducting the O&M activity.

3. Schools implemented more required

items in accordance with AHERA

than those additional program elements outlined in EPA guidance

documents. The percentage of performance responses was highest in

the management elements of

AHERA and EPA guidance. The elements indicating implementation

items such as notification to workers/contractors, work permit system,

and work practices for the O&M activities had the least percentage of

performance responses.
7

4. O&M activities were performed in

the vicinity of ACM without causing

elevated airborne asbestos levels.

When O&M activities disturbed or

were conducted on ACM, however,

airborne asbestos levels were significantly elevated and exceeded

0.02 asbestos structure/cm3 (School

Sites A, C, and H).

5. The estimated 8-hour TWA of total

fiber concentrations (0.005 f/cm3

maximum) in the breathing zone of

the individual performing the O&M

activities (as determined by phase

contrast microscopy) did not exceed

the OSHA Permissible Exposure

Limit of 0.1 f/cm3, 8-hour TWA.

The full report was submitted in partial

fulfillment of Contract No. 68-D2-0058 by

Environmental Quality Management, Inc.,

under subcontract to Pacific Environmental Services, Inc., under the sponsorship

of the U.S. Environmental Protection

Agency.
8

J.R. Kominsky and R.W. Freyberg are with Environmental Quality Management,

Inc., Cincinnati, OH 45240; D.R. Gerber and G.J. Centifonti are with the Environmental Health Services - New Jersey Department of Health, Trenton, NJ 08625.

Aaron R. Martin is the EPA Project Officer and Alva Edwards is the EPA Technical

Project Officer (see below).

The complete report, entitled “Evaluation of the Implementation of Operations and

Maintenance Programs in New Jersey Schools,” (Order No. PB97-181424; Cost:

$25.00, subject to change) will be available only from:

National Technical Information Service

5285 Port Royal Road

Springfield, VA 22161

Telephone: 703-487-4650

The EPA Technical Project Officer can be contacted at:

Sustainable Technology Division

National Risk Management Research Laboratory

U.S. Environmental Protection Agency

Cincinnati, OH 45268

• •

United States

Environmental Protection Agency

Center for Environmental Research Information

Cincinnati, OH 45268

EPA/600/SR-97/063

Official Business

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