Amphibole Asbestos in Vermiculite

Amphibole Asbestos in Vermiculite
Matthew S. Sanchez, PhD
October 29, 2014
Webinar Agenda
• We appreciate your interest and time in joining this
webinar.
• Recent guidance by the NY DOH (letters dated June
and August 2012, July 2013, and July 2014)
• Of particular focus is the use of vermiculite in
thermal insulation systems (SOF-V) and why the
concern
• Compare LAB.055.1 with 198.8
RJ Lee Group
2
NYS DOH Guidance Letter History
• June 22, 2012, “If vermiculite is calculated to be 10% or
more (>) of the material, the material must be reported
as ACM.”
Taken from: NY DOH State Department of Health June 22, 2012 FAQ #10 Additional
Vermiculite guidance.
RJ Lee Group
3
June 22, 2012 Letter Expanded
• “However, because vermiculite’s asbestos
contamination typically ranges from 1% to 5%,
vermiculite’ s contribution to asbestos content of
vermiculite materials used for thermal systems
insulation, surfacing materials and other
miscellaneous ACM…“*
• Assumption here from the EPA is the vermiculite is
sourced to the mine near Libby, Montana.
• Amphibole asbestos from Libby is predominantly
winchite asbestos a non-regulated mineral.
*Taken from: NY DOH State Department of Health June 22, 2012 FAQ #10 Additional
Vermiculite guidance.
RJ Lee Group
4
Regulated Asbestos
Regulated asbestos types are:
• Serpentine Group
⁻ Chrysotile
• Amphibole Group
⁻
⁻
⁻
⁻
⁻
Amosite
Crocidolite
Anthophyllite asbestos
Tremolite asbestos
Actinolite asbestos
RJ Lee Group
5
Guidance Letter History
• August 27, 2012, allows avoidance of the
analytical testing if documentation exists
certifying the vermiculite as non-ACM (in other
words, not from Libby)
• RJ Lee Involvement (January 2013)
– Validation data packages delivered:
• April 2013
• June 2013
• July 2013
• January 2014
• February 2014
RJ Lee Group
6
Guidance Letter History
• July 9, 2013, permitted the use of 198.6 with the
disclaimer “This method does not remove vermiculite
and may underestimate the level of asbestos present in
a sample containing greater than 10% vermiculite.”
RJ Lee Group
7
Guidance Letter History (cont.)
• July 22, 2014, “…announces the imminent
availability of two new NYS DOH ELAP-approved
methods for the detection and quantitation of
asbestos content in spray-on fireproofing that
contains vermiculite (SOF-V).”
• RJ Lee Group developed one of the two methods
available. Dr. Chatfield with REPNY support worked
with the DOH to develop the 2nd method 198.8
• Effective October 31st one of the two methods must
be used on SOF-V.
RJ Lee Group
8
Guidance Letter History (cont.)
• RJ Lee Group Method LAB.055.1 was granted
accreditation on July 25th, 2014.
RJ Lee Group
9
July 2014 Guidance (additional)
Industry Implications: The approval of these new methods for the identification and quantitation of
asbestos in SOF-V will have the following implications during the demolition, renovation, remodeling
and/or repair of buildings that fall under the authority of NYS Industrial Code Rule 56.
•
•
•
•
•
For future projects that have no associated survey: MUST use one of the new methods and
current NYS guidance.
For projects that have an existing survey, but no project plan: MUST re-sample and resurvey and
use one of the new methods and current NYS guidance prior to starting any new project.
For projects with an existing survey, and project yet to be done (Phase 1A): MUST resample and
resurvey and use one of the new methods and current NYS guidance.
For projects in progress using an old survey, and work underway (Phase 2A-2D): resampling and
use one of the new methods is RECOMMENDED, but NOT REQUIRED UNLESS there is a change to
the project design requiring a change order. If a change order is required, then re-sampling and
analysis by one of the new methods and current NYS guidance is REQUIRED on the new area.
For completed projects that were conducted under an old survey: there is no requirement to go
back and re-sample. However, if there is a need to disturb a material in the future - MUST use one
of the new methods and current NYS guidance.
Taken from: NY DOH State Department of Health July 22, 2014 “Testing
Requirements for Sprayed-on Fireproofing Containing Vermiculite (SOF-V)”
RJ Lee Group
10
The Two Methods
RJLG LAB.055.1
NY DOH 198.8
• Dissolves the vermiculite
matrix (similar to NOB)
• Uses both PLM and
scanning electron
microscopy (SEM)
• Allows EDS to identify the
amphibole type(s)
• Can specifically discriminate
regulated with nonregulated species of
amphibole.
• Utilized density separation
techniques to isolate
amphibole type asbestos
• Uses PLM
• Cannot discriminate
amphiboles with similar
refractive indices, e.g.
regulated tremolite
asbestos from nonregulated winchite asbestos
RJ Lee Group
11
The Two Methods (cont.)
RJLG LAB.055.1
• Validation
– All six regulated types of
asbestos
NY DOH 198.8
• Validation
– One type of asbestos
• Labs seeking accreditation
have to provide a DOC
– Minimum four samples, can
be repeat analyses of same
sample.
RJ Lee Group
12
RJLG Validation Expanded
• Four analysts performed triplicate analysis for over 1000
tests completed
• Several hundred commercial tests performed for clients
• Spiked 5.0-gram samples of vermiculite fireproofing
– 5, 2, 0.5, 0.1, and 0.02 percent of each regulated
amphibole type and chrysotile
• Direct comparison of NY DOH 198.6 methods with
LAB.055.1
RJ Lee Group
Vermiculite Briefing Presentation
13
RJ Lee Group
14
0.1 Percent Amphibole
~0.5 gram starting weight
~98 percent weight loss
RJ Lee Group
15
1.0 Percent Amphibole
RJ Lee Group
16
PLM Residue
Amphibole Asbestos Bundle
in residue
RJ Lee Group
PLM image
1.620 oil
17
SEM Residue
winchite amphibole
RJ Lee Group
18
NY 198.8
• NY DOH validation of 198.8 is to be published
• Two analytical problems,
– PLM unable to differentiate winchite from
tremolite/actinolite
– Amphibole asbestos can become trapped in the
vermiculite float
RJ Lee Group
19
Optical Properties
• Refractive indices of tremolite – actinolite asbestos
overlap with winchite asbestos from Libby source
vermiculite
• Take home you cannot differentiate these two
minerals with PLM
Table adapted from Millete and Bandli 2005, Asbestos Identification Using
Available Standard Methods. Microscope, Vol 53:4 P.179-185 Table 1.
RJ Lee Group
20
Amphibole in the Float
• Float fraction is discarded by 198.8
• Theoretically amphibole will not be trapped based
on density
• However, it can be trapped with the lighter
fractions.
Amphibole asbestos observed in discarded float fraction
from RJLG DOC samples
RJ Lee Group
21
Summary
• One year ago you had to assume a sample was
ACM.
• Today there are two methods, LAB.055.1 and
DOH 198.8
• LAB.055.1 discriminates the type of amphibole
(where observed).
• LAB.055.1 reduces laboratory error.
RJ Lee Group
22
The RJ Lee Group Method LAB.055.1 is a
good example of industry and regulatory
body cooperation.
RJ Lee Group
23
For more information on LAB.055.1 or 198.8,
please contact RJ Lee Group:
Vermiculine: 724.387.1972
or
http://go.rjlg.com/vermiculite
RJ Lee Group
24