Code of Colorado Regulations
1000 - Department of Public Health and Environment
1007 - Hazardous Materials and Waste Management Division
6 CCR 1007-2 - SOLID WASTE SITES AND FACILITIES
Part 1 - SOLID WASTE SITES AND FACILITIES
Part B - REQUIREMENTS AND INFORMATION CONCERNING ALL SOLID WASTE DISPOSAL SITES AND FACILITIES IN THE STATE OF COLORADO
Section 5 - ASBESTOS WASTE MANAGEMENT
Appendix 6 CCR 1007-2-5A - SAMPLE COLLECTION PROTOCOLS AND ANALYTICAL METHODOLOGIES

Current through Register Vol. 48, No. 6, March 25, 2025

1.0 Purpose

(A) The purpose of this appendix is to establish standard sample collection requirements and analytical methods and procedures for use in identifying and quantifying asbestos fibers in air, bulk material, and environmental media such as soil or ash.

2.0 Sample Collection Requirements

(A) The following sample collection requirements shall be followed when collecting samples for the purpose of determining the applicability of Section 5.5, and when collecting samples necessary to comply with the requirements of Section 5.5. Remediation plans submitted in accordance with Section 5.5.6 shall include a site specific sampling and analysis plan that incorporates the sample collection methodologies and analytical procedures in this Appendix, or proposes alternatives, and include site specific clearance criteria.

2.1 Bulk Samples

(A) Bulk samples shall be collected, in a manner sufficient to determine whether the material is asbestos-containing material (ACM) or not ACM, from each type of suspect ACM. Bulk samples shall be collected by a State of Colorado certified Asbestos Building Inspector (CABI). In the absence of bulk sample collection, any suspect ACMs must be assumed to be ACMs.

(B) Bulk samples shall be collected by homogenous type based on color, pattern, texture, thickness, associated materials, or by other identifying characteristics. Additionally, the quantity and location of a suspect material shall be used to determine the number of bulk samples required to characterize the asbestos content of each homogeneous suspect material. For the purpose of determining that a homogeneous suspect material does not contain asbestos, a minimum of three (3) bulk samples shall be collected from the homogeneous material unless there is insufficient material to constitute three (3) samples. If one of the collected samples of a homogeneous bulk material is determined to be ACM, then the homogeneous material shall be considered ACM.

2.2 Soil Samples

(A) Samples collected to determine asbestos content in soil shall be ten (10) point aliquot composite samples collected from a maximum area of 1,250 square feet (representing 0-6 inches beyond the exposed surface) or a maximum volume of forty (40) cubic yards. Individual aliquots shall be approximately 1/10 of the entire sample volume. At each aliquot location approximately one (1) tablespoon of soil shall be collected. The total volume of the ten (10) aliquots should equal roughly a half cup. The total collected sample volume should be greater than one quarter (%) cup, but should not exceed one cup. Aliquot locations shall be randomly selected but shall be representative of the entire sample area or volume (to be inclusive of the interior of soil piles in addition to the surface). However, aliquots shall be co-located with any areas where friable ACM was formerly present. All samples collected to determine asbestos content shall be collected by a CABI.

(B) Sampling for clearance purposes of any exposed horizontal or vertical surface shall have the following additional requirements:

1) The aliquots of a clearance sample shall not be collected until after the RACS, and the required amount of associated material, has been removed.

2) A visual inspection shall be performed and passed (i.e., no visible ACM present) by a CABI prior to the collection of soil samples. Visual inspections shall include the following:

a) The area to be cleared shall be designated before the visual inspection; and

b) Former locations of friable materials shall be designated; and

c) The surface being inspected shall be dry enough to allow identification of suspect ACM; and

d) The visual inspection shall be conducted in adequate lighting; and

e) The area to be cleared shall be free of visual impediments (e.g. snow cover, plastic sheeting, standing water, etc.); and

f) At a minimum, the area to be cleared shall be inspected in at least two (2) perpendicular directions; and

g) Single or multiple inspectors may be used to perform a visual inspection and clearance. However, a single inspector shall not visually inspect more than a five (5) foot width with each pass [i.e. for a clearance area that is 25' x 50' a single inspector would be required to make at least five (5) passes in one direction (25' length) and at least ten (10) passes in the other direction (50' length)]; and

h) Detailed close examination of the area being cleared is required. The inspector(s) should use limited invasive inspection techniques, such as periodically sifting the surface being cleared and closely inspecting the disturbed area.

3) If sidewalls with six (6) inches or greater of vertical height are present, independent ten (10) point aliquot composite samples shall be collected from each of the sidewalls and the floor of the excavation.

2.3 Ash Samples

(A) Ash that contains, or is comingled with, suspect ACM and/or construction and demolition debris shall be considered to be RACS unless the ash is sampled, and analysis demonstrates that the ash is not RACS. Representative samples of each type of ash materials shall be sampled and analyzed in the same manner as soil (including area/volumetric limitations of sampling). Ash samples shall be collected by homogenous strata, location, content of other surrounding material, or other observations indicating heterogeneity of the ash present. All samples collected to determine asbestos content shall be collected by a CABI. In the absence of suspect ACM or construction and demolition debris, and in the absence of documented evidence of non-visible asbestos, ash material may be treated as non-RACS.

2.4 Cross Contamination Prevention

(A) All sample collection equipment shall be decontaminated in a manner sufficient to prevent cross contamination between individual samples or individual composite samples. Decontamination is not required between the collection of aliquots comprising a single composite sample.

2.5 Air Samples for Standard RACS Management

(A) Air samples shall be collected by drawing air through 0.8-micron (urn), 25-millimeter (mm), mixed cellulose ester (MCE) filters, using an open-faced cowl extension oriented face down at an angle of 45°. Sample flow rate shall be between 0.5-10 liters per minute depending on the anticipated duration of sampling and the specified detection sensitivity. The air sampling equipment shall be run until the minimum volume required is collected for each sample. However, if the minimum air volume required by the method, and/or to reach the required analytical sensitivity, being utilized cannot be met, the State of Colorado trained and certified Air Monitoring Specialist (AMS) shall request that the laboratory prepare the sample using an indirect preparation method, for TEM presence/absence analysis. Air samples shall be collected at a height that is representative of the disturbance activity taking place. However, air samples shall be located at a height between three (3) feet above the ground surface but not to exceed twenty (20) feet above the ground surface. Air samples shall be collected by an AMS.

2.6 Air Samples for Risk-Based Air Threshold Monitoring

(A) Air samples shall be collected by an AMS. Air monitoring shall be conducted during each partial or full day of soil management activities using fixed and mobile monitors as follows:

1) A minimum of four (4) samples shall be collected for each regulated work area (RWA).

2) For the purpose of determining the number of samples necessary, each RWA shall be divided into four (4) equal quadrants. A minimum of one (1) sample shall be collected for each quadrant with an adjacent receptor zone.

3) If an RWA is greater than one (1) acre, one (1) additional sample for each quadrant with an adjacent receptor zone shall be collected and analyzed for each additional one quarter (%) acre in RWA surface area.

4) Samples shall be located along the RWA perimeter, between the RWA and each adjacent receptor zone. Samples shall be placed between the RWA and any fixed adjacent receptor(s). In the absence of fixed adjacent receptors, sample placement shall be at the AMS's discretion.

5) The sample volume shall be the minimum necessary to meet analytical sensitivity.

6) Samples shall be collected by drawing air through 0.8-micron (urn), 0.25-millimeter (mm), mixed cellulose ester (MCE) filters, using an open-faced cowl extension oriented face down at an angle of 45°.

3.0 Analytical Requirements

(A) The following analytical methods shall be used to evaluate the presence of asbestos and/or to determine asbestos content when analyzing samples for the purpose of determining the applicability of Section 5.5, and when analyzing samples collected in accordance with Section 5.5:

3.1 Bulk Samples

(A) Samples of suspect ACM shall be analyzed by polarized light microscopy (PLM), according to United States Environmental Protection Agency (USEPA) Method EPA/600/R-93/116 or equivalent method, to determine if any asbestos fibers are present. If the asbestos content of a sample is estimated to be 1% asbestos or less, but greater than 0%, by a method other than point counting (such as visual estimation), the determination shall be repeated using the point counting technique with PLM. Alternatively, the material may be assumed to be ACM. Analysis shall be conducted by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory.

3.2 Soil Samples and Ash Samples

(A) Prior to preparation of a soil or ash sample, bulk materials shall be separated from the soil or ash sample for independent analysis. Any bulk materials identified in a soil or ash sample that contain any amount of asbestos shall be reported as independent layers of the whole sample. The samples shall be adequately prepared (crushed and dried) to facilitate stereo microscopic analysis by the laboratory. The goal of the preparation process should be to produce dried conglomerates of approximately one eighth inch (1/8") to one quarter inch (1/4") size. Rock and/or stone material does not need to be crushed (this process is not intended to be homogenization). Soil and ash samples shall be analyzed by PLM according to USEPA Method EPA/600/R-93/116 to determine if any asbestos fibers are present. Analysis shall be conducted by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory. During the stereo microscopic analysis (10X- 50X) of the soil/ash sample the analyst shall sift through the sample at a rate of approximately one (1) tablespoon per minute. At the end of the stereo microscopic analysis the sample shall be agitated or shaken as a final check for asbestos prior to the preparation of PLM grab mounts. At no time during the stereo microscopic analysis shall a sub sample be collected. The entire sample shall be analyzed and the results reported. If no asbestos was identified by PLM after the initial stereo microscopic examination, then three (3) random grab mount preparations shall be analyzed by PLM to determine if the sample is none detected for asbestos content. If any asbestos is found by the laboratory it shall be reported even in the absence of a second detection (i.e. there does not need to be a second detection to qualify a trace level of asbestos in the sample). Quantification of asbestos content shall be based on the entire sample volume, and be reported as such.

3.3 Air Samples for Standard RACS Management

(A) Air samples submitted for Phase Contrast Microscopy (PCM) shall be analyzed according to NIOSH Method 7400 by a laboratory showing successful participation in the American Industrial Hygiene Association (AIHA) Proficiency Analytical Testing (PAT) Program or individual(s) certified through the AIHA Asbestos Analysts Registry (AAR) Program.

(B) Air samples submitted for Transmission Electron Microscopy (TEM), for which quantification of asbestos is desired, shall be prepared and analyzed according to the standard Asbestos Hazard Emergency Response Act (AHERA) method (AHERA; 40 CFR Part 763, Subpart E, Appendix A). All TEM analysis shall be performed by a NVLAP accredited laboratory. If a presence/absence analysis is desired, the analysis shall be performed using the AHERA method modified in the following manner:

1) A minimum of two (2) preparations shall be prepared and utilized for each sample.

2) Analysis shall be conducted on a minimum of four (4) grid openings or until three (3) or more structures are identified, whichever comes first.

3) Any structure (adhering to the AHERA counting rules) identified during analysis shall be reported.

a) Identification of less than three (3) structures shall be reported as present.

b) Identification of three (3) or greater structures shall be reported as detected.

(C) Any air sample analysis that results in a "cannot be read (CBR)" determination from the analyst, or a "not analyzed (NA) or rejected" due to loose debris or uneven loading, shall be evaluated by the AMS to determine if a cause of the CBR or NA can be ascertained. If it is determined that the CBR is a result of overloading from airborne emissions, then the AMS shall request that the laboratory prepare the sample, using an indirect preparation method, for TEM presence/absence analysis.

3.4 Risk-Based Air Threshold Samples

(A) Air samples collected for TEM analysis shall be submitted to a NVLAP accredited laboratory. Samples shall be analyzed by TEM according to ISO Method 10312 with the following modifications for PCM equivalent (PCMe) structures:

1) An aspect ratio of 3:1 shall be used when counting structures greater than 5 urn in length, rather than the 5:1 ratio specified in the method.

2) A width range of 0.25 to 3 urn will be used when counting PCMe structures, rather than the 0.2 to 3 urn specified in the method.

3) A minimum often grid openings will be counted, rather than the minimum of four (4) grid openings specified in the method.

4) Calculations shall be made based on total fibers rather than primary fibers.

(B) The maximum number of grid openings (GOs) to be counted to achieve the specified analytical sensitivity shall be estimated as follows:

Number of GOs = EFA ÷ (AGO x V x S x CF)

where:

EFA = effective filter area (385 for a 25-mm filter)

AGO = area of a grid opening (approximately 0.01 mm2; actual value to be provided by the analytical laboratory)

V = volume of air sampled (in liters [L])

S = analytical sensitivity (structures per cubic centimeter [s/cc])

CF = conversion factor (1000 cc/L)

(C) Any air sample analysis that results in a "cannot be read (CBR)" determination from the analyst, or a "not analyzed (NA) or rejected" due to loose debris or uneven loading, shall be prepared by the laboratory, using an indirect preparation method, forTEM presence/absence analysis.

3.5 Data Evaluation for Risk-Based Air Threshold Samples

(A) General requirements:

1) Samples collected for comparison to risk-based air thresholds shall be evaluated based on the average (mean) concentration over the exposure duration.

2) All valid data shall be used to calculate daily and ten (10) day rolling averages.

3) For all projects a minimum of three (3) samples per day must have quantifiable data (not CBR or rejected). If less than three (3) quantifiable analytical results are available then the daily average is invalid.

(B) Project days 1-9:

1) The results of the daily samples must be averaged to calculate a daily average for use in comparing to the risk based air threshold for days 1-9 of monitoring.

2) A ten (10) day average shall be calculated for days 1-9. The ten (10) day average shall be comprised of at least eight (8) valid daily average results. However, all valid data shall be used to calculate the ten (10) day average.

3) If the ten (10) day average exceeds the risk-based air threshold, engineering controls shall be adjusted to reduce the daily average.

4) The Department shall be notified within 24 hours if the calculations in paragraphs 1 and 2 above cannot be completed due to invalid data.

(C) Project days 10 and greater:

1) Starting on day 10, a ten (10) day rolling average shall be calculated and compared to the risk-based threshold.

2) If average concentration trends indicate the risk-based air threshold will be exceeded before project completion, engineering controls shall be adjusted to reduce the daily asbestos emissions.

3) If subsequent evaluation of average concentration trends indicates that the risk-based air threshold will still be exceeded before project completion, additional adjustments to engineering controls shall be made.

4) If changes in engineering controls are not effective in reducing airborne concentration trends such that the risk-based air thresholds can be met, consultation with the Department is required.

5) The Department shall be notified within five (5) working days if the averaged airborne asbestos concentration for the entire project exceeds the risk-based air threshold.

4.0 Documentation

(A) All of the following sampling and analytical documentation shall be maintained during a project and available for Department review upon request. This documentation need not be submitted to CDPHE unless requested or as required in a project specific plan.

1) Documentation of bulk, soil, and ash samples shall include:

a. A description of the material being sampled including friability.

i. For samples collected for characterization purposes also include an estimate of the quantity of visible suspected RACS present.

ii. For samples of ash, also include a brief description of the ash layer, and any associated identifiable debris.

b. Name of person collecting the sample(s).

c. Date and time of sample collection.

d. Location of sample collection (a map, drawing, or diagram showing sample locations in relation to the work area and surrounding area).

e. The boundary/limits that are represented by the collected sample.

f. Chain of custody documentation.

g. Laboratory analysis reports.

h. Log of characterized homogeneous bulk materials including material descriptions, photographic documentation, and asbestos content.

2) Documentation of air samples shall include:

a. Name of person collecting the sample(s).

b. Date and time(s) of sample collection.

c. Locations of air sample collection.

d. Any relocation of air samples.

e. A map, drawing, or diagram showing air sample locations (initial and relocations) in relation to the work area and the surrounding area.

f. Chain of custody documentation.

g. Laboratory analysis reports.

h. Explanation of any air sample malfunctions and any voided air samples.

i. Risk based air threshold concentration calculations.

j. Air sample data (flow rates, time of sampling, volumes, calibration method, etc.).

k. Wind speed measurements.

I. Prevailing wind directions.

m. Wind shut down events.

n. Observations of visible emissions and responses.

5.0 Deviations from Sampling and Analysis Procedures

(A) Deviation from this sampling and analysis appendix shall only be allowed upon consultation with, review by, and approval from, the Department.

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