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Asbestos - Clearance Sampling

Q1:  Following an asbestos removal action, who can perform final clearance sampling?

A1:  In California, clearance air sampling must be performed under the direct supervision of a California-certified asbestos consultant, or "CAC."  Requirements vary in other states, but generally require a combination of training, experience, testing and licensure.

Q2:  I've hired a licensed abatement contractor to remove asbestos from my building.  Can't I just ask him to have the clearance sampling performed?

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SCAQMD, Notice to Comply, Procedure 5



                

The South Coast Air Quality Management District (SCAQMD) responds to complaints of possible asbestos disturbance lodged by building occupants, tenants and employees.  They can be reached at (909) 396-2000 or 800-CUT-SMOG (800-288-7664).

The SCAQMD is by far the most active environmental regulatory agency in California, responding to complaints 24 hours a day.  When investigating the possible disturbance of asbestos-containing materials, the AQMD inspector will first request a copy of an Asbestos Survey. By law, AQMD Rule 1403, an asbestos survey is required prior to any demolition or renovation effort).  If no survey report is produced, the agency will immediately issue a "Notice to Comply", or "NTC," requiring that a Certified Asbestos Consultant conduct an asbestos hazard assessment.  If asbestos is identified, that same CAC must prepare and submit a "Procedure 5" (P5) cleanup plan on behalf of the building owner.

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Certified Asbestos Consultant

"Certified Asbestos Consultant"

 Ellis was recently asked to respond to an asbestos-related emergency by a major southern California university.  As the first step in a large building renovation project, an abatement contractor had been hired to remove asbestos materials.  That contractor had been given a copy of the school's campus-wide asbestos survey performed by Ellis in 2007.  But for this project and for the first time, the university chose to manage the abatement project "in-house," i.e. without bid phase assistance or input from a California-certified asbestos consultant (CAC). 

With the project already underway, Ellis was finally called in . . . but only after the contractor had improperly removed eight thousand square feet of identified asbestos flooring and wallboard without proper engineering controls or notification.  When asked why they'd done it, the contractor admitted  they had received Ellis' original asbestos survey report, but had somehow "missed" the presence of these two asbestos materials.  The AQMD automatically investigated, cited the contractor, and mandated that a CAC direct all subsequent cleanup operations.  Ellis performed this service, administered remaining abatement, and the project was completed without further incident. 

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"Transite" Pipe and the AQMD

AC_Pipe.jpg

The proper name for it is "Asbestos-Cement", or simply "A-C" pipe, but it is also commonly called by its manufacturer JM's brand name - "Transite" pipe.

A-C pipe is present under most commercial and industrial sites.  Typically buried at a depth of 2 to 7 feet, A-C pipe was installed and used for a number of purposes:

Electrical and Telephone Conduit.  Typically 2"-6" O.D. (outer diameter), A-C conduit lines can typically be found embedded in large blocks of concrete, which can make excavation and disposal challenging.High Pressure Fresh Water Line.  Sizes will range from 12" O.D. (main lines) to 4" O.D. (service lines).  Tees and elbows are often embedded in concrete thrust blocks.Sewer Lines.  A-C pipe is a common way to move sewage from homes to the wastewater treatment plant, via 4" service lines connecting to a main line of 24" or more.

In southern California, the South Coast Air Quality Management District (AQMD) now requires that ALL A-C pipes must be excavated and removed in accordance with an approved "Procedure 5" (or simply "P5") application.  The P5 must be prepared by a California certified asbestos consultant (CAC) and must accurately describe a plan to excavate, expose, remove, wrap and dispose of A-C pipe wherever it is found.  Typically, this process will require approximately 3 weeks to complete, including the 2-week notification period to the AQMD.

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