Documenting Naturally Occurring Asbestos and Erionite in Import Material from Non-Nevada Department of Transportation

STATE OF NEVADA DEPARTMENT OF TRANSPORTATION ENVIRONMENTAL SERVICES DIVISION

DOCUMENTING NATURALLY OCCURRING ASBESTOS AND ERIONITE IN IMPORT MATERIAL FROM NON-NEVADA DEPARTMENT OF TRANSPORTATION

SOURCES FOR PROJECTS

FEBRUARY 2019

Version 2.0 Final 2/11/19

TABLE OF CONTENTS

A: Geological Evaluation ...... 2 B. Source Sampling ...... 2 C. Product Sampling (Surge Piles, Stockpiles, Belt Sampling or Recycled material) ...... 4 D. ANALYTICAL PROTOCOL ...... 7 E. Annual Review ...... 7 References: ...... 8

Appendix A Solid-Matrix Sample Preparation and Analysis for NOA and Erionite Appendix B Definitions

DOCUMENTING NATURALLY OCCURRING ASBESTOS AND ERIONITE IN IMPORT MATERIAL FROM NON-NEVADA DEPARTMENT OF TRANSPORTATION SOURCES FOR PROJECTS

Source of Supply and Quality Requirements. Rock, soil, and other mineral material (Materials) obtained or produced to construct Nevada Department of Transportation projects shall not have levels of Naturally Occurring Asbestos (NOA) or erionite (E) of 0.25% or above. Landscape mulch or rock that will not be subjected to regular vehicular traffic after placement and is less than 1,000 tons or 800 cubic yards for the entire project and boulders that will be placed unaltered at the project site are exempt from this evaluation. The health risk of NOA and E are not well defined at this time. EPA and other agencies continue to fund research into these subjects. As the science progresses Nevada Department of Transportation will continue to revise and update the levels of NOA and E that will be allowed. This document was developed for Nevada Department of Transportation’s use only to evaluate potential NOA and E effects on their projects. Anyone relying on this information for other uses does so at their own risk.

Such Materials include, but are not limited to, borrow embankment, selected borrow embankment, decorative rock, decorative boulders, granular backfill, drain rock, base aggregates, shouldering material, aggregates for bituminous mixtures, aggregates for Portland cement products, rip rap, rip rap bedding, and any other similar type of rock, soil, or mineral material required to construct the project.

The Nevada Department of Transportation, Environmental Services Division, NOA/Erionite Branch (NDOT) has set the following Material screening criteria. Materials will not be allowed on the project until the screening has been completed and the following information submitted. The flow chart can be used to identify required information needed for the submittal. The submittal shall be technically and legally defendable. The information should be compiled by the supplier and given to NDOT or the contractor and included in submittals for material acceptance.

FLOW CHART TO EVALUATE A RESOURCE FOR NATURALLY OCCURRING ASBESTOS AND ERIONITE

GEOLOGICAL EVALUATION BY PROFESSIONAL GEOLOGIST NO (IS RESOURCE LOCATED IN AN AREA WHERE NOA OR ERIONITE YES WOULD BE EXPECTED TO BE FOUND?) *

SAMPLING REQUIRED SUBMIT GEOLOGICAL (PICK ONE: SOURCE OR PRODUCT, EVALUATION TO NDOT FOR NOT REQUIRED TO DO BOTH) CONCURRENCE

SOURCE SAMPLING CONCUR PRODUCT SAMPLING

DEVELOP SAMPLING PLAN (CEM MATERIAL FROM THE REQUIRED) DEVELOP SAMPLING PLAN GEOGRAPHIC AREA IDENTIFIED IN THE GEOLOGICAL EVALUATION IS ACCEPTABLE CONDUCT FIELD SAMPLING FOR USE ON THE PROJECT CONDUCT FIELD SAMPLING

REEVALUATE ANNUALLY (ARE SUBMIT INFORMATION TO NDOT SUBMIT INFORMATION TO CONCLUSIONS CONSISTENT FOR REVIEW AND NDOT FOR REVIEW AND

WITH INFORMATION CONCURRENCE PRESENTED IN ORIGINAL GEOLOGICAL EVALUATION?) NO REVIEW ANNUALLY (IS ADDITIONAL SAMPLING REQUIRED?) YES YES NO SUBMIT INFORMATION TO NDOT FOR REVIEW AND SUBMIT INFORMATION TO NDOT FOR CONCURRENCE REVIEW AND CONCURRENCE

* If the material is coming from a one-time source(s) (i.e., excess material from another construction site) and not a commercial quarry, move directly to product sampling for each source and it will not be necessary to conduct a Geological Evaluation. Documenting NOA and Erionite in Import Material for NDOT Projects

A: GEOLOGICAL EVALUATION

The evaluation shall be conducted by a Professional Geologist (PG) meeting the standards set in Nevada Revised Statue (NRS) 514.005. The evaluation should include literature review as well as a site reconnaissance. The report shall include the following information:

1. Company (Owner/Operator of the site or source area)

2. Date

3. Site Description a. Location/Name a. Address (City, State, County) b. Coordinates obtained by a GPS unit that is accurate to 3 meters c. Study Area (size) d. Map of Study Area (Latitude/Longitude Coordinates for Area Boundary corners)

4. Geologic Setting a. Age b. Bedrock/Soil Unit c. Alluvium d. Other

5. Evaluation and Supporting Rationale from PG as to potential for the Study Area to contain NOA or Erionite

6. Qualifications of the PG preforming the Study

7. Appendices a. Photograph Documentation b. Supporting Geologic Mapping c. Field Reconnaissance Notes d. Other

The Geological Evaluation should be reviewed annually to verify if there have been changes at the facility that would change the recommendations included in the original evaluation. The annual review does not need to duplicate the information from the original Geologic Evaluation; however, it needs to evaluate any changes in the site geology and verify that the original recommendations have not changed. If there are no changes a letter, sent to NDOT, attesting to this by the Geologist will be enough to satisfy this requirement.

B. SOURCE SAMPLING

Resource area sampling shall use an unbiased sampling scheme unless there are non- homogeneous areas identified such as outcrops or depositional features. The non-homogeneous areas will require targeted sampling.

Personnel shall have field experience with soil and solid matrix sampling, composite sampling, and decontamination of field equipment. The resource sampling team shall include a PG per NRS 514.005; and, a Certified Environmental Manager (CEM) per NRS 459.485 and 459.500; and, Nevada Administrative Code (NAC) 459.9704, 459.972, and 459.9724.

Documenting NOA and Erionite in Import Material for NDOT Projects

The following is intended as a guideline for developing a Field Sampling Plan. It is the responsibility of the PG and CEM to develop a Field Sampling Plan that fully characterizes the source both vertically and horizontally. The Field Sampling Plan must be reviewed and approved by NDOT, Environmental Services Division, NOA/Erionite Branch before implementation.

1. Field Sampling Plan

The Field Sampling Plan shall contain the following information:

a. Site Description b. Sampling Rational c. Sample Locations (Include Map) d. Sampling Equipment e. Type and Amount of Samples to be Collected f. Analytical Methods g. Quality Control Methods h. Decontamination Procedures i. Personnel (qualifications and/or certifications) j. Signature of Responsible Professionals and CEM jurat

2. Hard Rock Quarries

a. The number and location of samples should be determined by the PG as adequate to characterize the resource being mined. Surface and subsurface samples can be collected as deemed appropriate. If evidence of intrusion of other rock types, thermal alteration, or other differences in mineral composition is observed, additional samples shall be obtained of the different materials.

b. Between 5 and 30 aliquots shall be collected from across the sample area. The aliquot samples can be collected from boreholes or excavated pits. Aliquots must adequately represent the vertical and horizontal extent of the areas being evaluated.

c. Each sample shall weigh approximately 2 kilograms (4.4 pounds). 1 kilogram for the laboratory and 1 kilogram to be delivered to NDOT for possible Quality Assurance (QA) analysis. See Section D of this guidance for alternatives to supplying a split sample to NDOT.

d. Samples will be delivered to the laboratory under chain-of-custody documentation as outline in ASTM D4840 (latest version).

3. Sand & Gravel Alluvium (Unconsolidated Material)

a. The number and location of samples should be determined by the PG as adequate to characterize the resource being mined. Surface and subsurface samples can be collected as deemed appropriate.

b. A minimum of 5 locations shall be identified for each composite sample. The locations can be boreholes or excavated pits. Aliquots must adequately represent the vertical and horizontal extent of the areas being evaluated.

c. Each sample shall weigh approximately 2 kilograms (4.4 pounds). 1 kilogram for the laboratory and 1 kilogram to be delivered to NDOT for possible QA analysis. See Section D of this guidance for alternatives to supplying a split sample to NDOT.

d. Samples will be delivered to the laboratory under chain-of-custody documentation as outline in ASTM D4840 (latest version).

Documenting NOA and Erionite in Import Material for NDOT Projects

4. Reporting for Resource Sampling

After sampling and analysis is completed, prepare a report to be submitted to NDOT for review and concurrence. The report shall include the following information:

a. Copy of Geological Evaluation b. Copy of Sampling Plan c. Analytical Procedures and Tabular Summary of Results (Include Latitude and Longitude Coordinate for each Location Sampled) d. Discussion of Results e. Review of Quality Control Measures f. Personnel (qualifications and/or certifications) g. Signature of Responsible Professionals and CEM jurat h. Related Figures i. Appendices Chain-of-Custody Documents Laboratory Results Additional Photographs

C. PRODUCT SAMPLING (SURGE PILES, STOCKPILES, BELT SAMPLING OR RECYCLED MATERIAL)

As an alternative to resource sampling the supplier may choose to sample the Product. A Field Sampling Plan shall be developed to assure the samples collected are representative of the material that will be delivered to the project site (Field Sampling Plans prepared for product sampling does not require a PG or CEM if the information gathered will not be used to request a waiver at a later date). The following guide lines shall be followed when developing and implementing the Field Sampling Plan.

1. Field Sampling Plan

The Field Sampling Plan shall contain the following information. The Field Sampling Plan must be reviewed and approved by NDOT, before implementation.

a. Site Description b. Product Type that is being evaluated c. Diagram of Facility d. Sampling Rational e. Sample locations (Identify Area, i.e., Storage Pile #) f. Sampling Equipment g. Type and Amount of Samples to be Collected h. Analytical Methods i. Quality Control Methods j. Decontamination Procedures k. Personnel (qualifications and/or certifications) l. Signature of Responsible Professionals and CEM jurat

2. Stockpiles and Surge Piles:

a. Random aliquots shall be chosen from all accessible areas of the stockpile. For every 15,000 cubic yards (CY) of aggregate, 1 composite sample shall be collected for analysis and shall be composed of not less than 5 randomly selected aliquots. The aliquots shall be combined into one composite sample for analysis. Each sample shall weigh approximately 2 kilograms (4.4 pounds). 1 kilogram for the laboratory and 1 kilogram to be delivered to

4 Documenting NOA and Erionite in Import Material for NDOT Projects

NDOT for possible QA analysis. See Section D of this guidance for alternatives to supplying a split sample to NDOT.

b. Samples can be collected from stockpiles or surge piles as outlined in ASTM D75/D75M (latest edition). As an alternative, an insertion tube or hand/machine-operated auger can be used to collect samples from the stockpiles. Insertions tube (outside diameter of 2 to 5 inches) or auger will be inserted at least 1 foot into the pile.

c. Each aliquot of material collected shall be placed in an appropriate-sized container (5- gallon bucket or bowl) for combining with the remaining aliquots. After all aliquots are collected, the composite samples will be transferred to an appropriate sample container for delivery to the laboratory and NDOT. Proper chain-of-custody documentation is required as outline in ASTM D4840 (latest version).

d. Sampling frequency shall be 1 sample per 15,000 CY for the first 75,000 CY for a total of 5 samples. If these samples are less than 0.25% NOA/E, then 1 sample per 50,000 CY for the next 100,000 CY will be collected. If all samples collected indicate less than 0.25% NOA/E the supplier may request that no additional sampling will be required for this product. NDOT will evaluate these requests on a case-by-case-basis.

e. After sampling and analysis is completed, prepare a report to be submitted to NDOT for review and concurrence. The report shall include the following information:

i. Copy of Geological Evaluation ii. Copy of Sampling Plan iii. Description of Product Sampled iv. Analytical Procedures and Tabular Summary of Results v. Discussion of Results vi. Personnel (qualifications and/or certifications) vii. Signature of Responsible Professionals and CEM jurat viii. Appendices Chain-of-Custody Documents Laboratory Results Photographs

3. Belt Samples:

a. Belt Samples can be collected as outline in ASTM D75/D75M. A minimum of 5 randomly selected aliquots shall be collected. The collection shall take place over a minimum of two days of operation. The aliquots shall be of equal size. Aliquots shall be stored in a secure area to avoid contamination or tampering before blending. The aliquots shall be combined into one composite sample for analysis. Each sample shall weigh approximately 2 kilograms (4.4 pounds). One kilogram for the laboratory and 1 kilogram to be delivered to NDOT for possible QA analysis. See Section D of this guidance for alternatives to supplying a split sample to NDOT. Proper chain-of-custody documentation is required as outline in ASTM D4840 (latest version).

b. Sampling frequency shall be 1 sample per 15,000 CY for the first 75,000 CY for a total of 5 samples. If these samples are less than 0.25% NOA/E, then 1 sample per 50,000 CY for the next 100,000 CY will be collected. If all samples collected indicate less than 0.25% NOA/E the supplier may request that no additional sampling will be required for this product. NDOT will evaluate these requests on a case-by-case basis.

5 Documenting NOA and Erionite in Import Material for NDOT Projects

c. After sampling and analysis is completed prepare a report to be submitted to NDOT for review and concurrence. The report shall include the following information:

4. Recycled Materials

a. Sampling of crushed concrete shall be conducted in accordance with the methodology described for Stockpiles above. One sample shall be collected for every 25,000 CY. Since recycled materials are not homogenous, testing at this rate is required for all material supplied to the project. The Geological Evaluation and CEM requirement to develop a Field Sampling Plan maybe waved for samples that are for recycled concrete. The waiver requires that the operator prepares a Field Sampling Plan. The Fields Sampling Plan must be submitted to NDOT for approval before samples are collected.

If the supplier of the recycled concrete knows the source of the material and an AHERA (Asbestos Hazardous Emergency Response Act) demolition survey was performed before demolition on the concrete, results from this survey can be used in place of sampling the recycled concrete.

b. Recycled Asphalt is oil coated and has a low probability of releasing fibers into the air and therefore it will be exempt from testing.

c. Other Recycled Material: Due to the variability of the materials that may be in recycled materials, the required sampling frequency and methodology will be determined on a case- by-case basis. A request for acceptance shall be submitted to NDOT prior to sampling and testing.

d. After sampling and analysis is completed, prepare a report to be submitted to NDOT for review and concurrence. The report shall include the following information:

i. Copy of Sampling Plan ii. Description of Product Sampled iii. Analytical Procedures and Tabular Summary of Results iv. Discussion of Results v. Review of Quality Control Measures vi. Personnel (qualifications and/or certifications) vii. Signature of Responsible Professionals and CEM jurat viii. Appendices Chain-of-Custody Documents Laboratory Results Additional Photographs

6 Documenting NOA and Erionite in Import Material for NDOT Projects

D. ANALYTICAL PROTOCOL

All samples that will be analyzed for NOA/E should be prepared and analyzed as outlined in Appendix A. A 1-kilogram split sample must be supplied to NDOT for possible QA analysis as NDOT reserves the right to conduct an independent analysis of all submitted samples. If your sample(s) are selected for QA sampling, allow for an additional 45 calendar days before report approval is granted. As an alternative to supplying a split sample for QA analysis, the operator may contact NDOT for alternate laboratory protocols.

E. ANNUAL REVIEW

This document will be reviewed annually by NDOT to evaluate its effectiveness. The evaluation will include the review of new scientific information and regulatory direction as it relates to risk, and health and safety, and material management. Also, laboratory protocols will be reviewed, and any new proven procedures will be incorporated into the document as necessary. Notice of the updated document will be posted in the Contractor’s Bulletin. If substantial changes are required comments will be solicited from effected parties

Documenting NOA and Erionite in Import Material for NDOT Projects

REFERENCES:

1991. David L. Bish and Steve J. Chipera, Diction of Trace Amounts or Erionite Using X-Ray Powder Diffraction: Erionite in Tuff of Yucca Mountain, Nevada, and Central Turkey, Clays and Clay Minerals, Volume 39, No. 4, 437-445 http://www.clays.org/journal/archive/volume%2039/39-4-437.pdf 1993. EPA 600/R-93/116. Method for the Determination of Asbestos in Bulk Building Materials.

1995. ISO 10312:1995. Ambient Air –Determination of asbestos fibers – Direct transfer transmission electron microscopy method.

1997. Coombs, D.S., A. Alberti, T. Armbruster, G. Artioli, C. Colella, E. Galli, J.D. Grice, F. Liebau, J.A. Mandarino, H. Minato, E.H. Nickel, E. Passaglia, D.R. Peacor, S. Quartieri, R. Rinaldi, M. Ross, R.A. Sheppard, E. Tillmans & G. Vezzalini (1997) Recommended nomenclature for zeolite minerals: Report of the Subcommittee on Zeolites of the International Mineralogical Association, Commission on New Minerals and Mineral Names. Canadian Mineralogist 35, 1571-1606. http://www.mineralogicalassociation.ca/doc/abstracts/ima98/ima98(13).pdf

2012. Hawthorne, F.C., Oberti, R., Harlow, G.E., Maresch, W.V., Martin, R.F., Schumacher, J.C., Welch, M.D. (2012) Nomenclature of the amphibole supergroup. American Mineralogist: 97: 2031-2048. http://www.minsocam.org/msa/ammin/toc/Abstracts/2012_Abstracts/ND12_Abstracts/Hawthorne_p2031_ 12.pdf

2014. ISO 22262-2:2014. Air Quality – Bulk Materials – Part 2: Quantitative Determination of asbestos by gravimetric and microscopical methods

2015. Kristina P. Pourtabib and Mickey E. Gunter, University of Idaho, Analytical Approach for Identification of the Zeolite Erionite, The Microscope, Volume 63:4, pp 175-185,

2017. ARB Monitoring and Laboratory Division, Quality Management Branch, Quality Management Section Implementation Guidance Document, Air Resources Board Test Method 435, Determination of Asbestos Content, of Serpentine Aggregate, Field Sampling and Laboratory Practices .

8 Appendix A Solid-Matrix Sample Preparation and Analysis For NOA and Erionite

February 11, 2019 Documenting NOA and Erionite in Import Material for NDOT Projects

Solid-Matrix Sample Preparation and Analysis For NOA and Erionite February 11,2019

The procedures below outline the steps to be applied to solid matrix samples such as soil and rock for the determination of the presence and quantity of natural occurrences of asbestos (NOA).

1. Sampling 1.1 Samples submitted to the laboratory should be approximately 1 kilogram (2.2 lbs.) in size. 1.2 Wide mouth plastic or glass containers with screw top lids or heavy duty ziplock bags (if double bagged) are acceptable.

2. Initial Lab Preparation 2.1 Samples submitted wet need to be dried in a drying oven at 90 degrees Centigrade prior to subsequent steps. 2.2 If more than 1 kilogram (approximately a quart) of soil is submitted to the laboratory the samples should be homogenized prior to any further prep and analysis. 2.3 Riffle splitting, Turbula Mixing and/or hand mixing may all be acceptable homogenization techniques depending on the sample.

3. Initial Visual and Stereomicroscopic Inspection 3.1 Complete a low-magnification examination of the entire sample submitted (up to approximately 1kilogram) by viewing multiple fields of view with a stereomicroscope. 3.2 The sample should be probed by turning over pieces and breaking apart larger clumps. 3.3 Record all observations such as overall homogeneity, color, and friability of components. 3.4 If any suspect fibers are observed, attempt to identify them with PLM by making slide mounts in appropriate oils. Record the identity and approximate percentage of fibers identified in the sample.

4. Sample Preparation for NOA Analyses 4.1 The entire sample should be homogenized prior to obtaining a representative sub-sample to be milled. 4.2 Depending on the sample this homogenization may require some initial crushing to reduce the size of any rock/aggregate present (maximum size of individual particles prior to milling should be ½ inch). 4.3 The sub-sample obtained should be milled to a nominal 250 micrometer (um) particle size.

5. Analysis samples as outlined in Implementation Guidance Document Air Resources Board Test Method 435 Determination of Asbestos Content of Serpentine Aggregate, Section V Laboratory Sample Analysis Procedures (CARB 435), dated April 2017.

6. Submit results to NDOT for review.

7. NDOT will select a certain percentage of samples to be reanalyzed for Quality Assurance (QA) purposes. If samples are selected for this purpose, approval of the material can be delayed by as much as 45 days. For alternative to QA analysis by NDOT refer to Section D of this guidance.

A-1 Documenting NOA and Erionite in Import Material for NDOT Projects

Appendix B Definition

Documenting NOA and Erionite in Import Material for NDOT Projects

DEFINITIONS

Aliquot: A number of equal subsamples that make up a whole.

CARB: California Air Resources Board

CEM: Certified Environmental Manager, a person meeting the requirements of NRS 459.485 and 459.500; and, Nevada Administrative Code 459.9704, 459.972, and 459.9724.

EPA: The United States Environmental Protection Agency

Erionite: Erionite is a naturally occurring fibrous mineral that belongs to a group of minerals called zeolites. It usually is found in volcanic ash that has been altered by weathering and ground water. Erionite forms brittle, wool-like fibrous masses in the hollows of rock formations. Erionite has been classified as a Group 1 Carcinogen by the International Agency for Research on Cancer a subgroup of the World Health Organization.

Import Material: Rock, soil, and other mineral materials obtained or produced to construct Nevada Department of Transportation projects that are not contained within the project site or included in the contract Special Provisions. In other words, materials that are imported onto any project-related area and do not come from a project-identified Nevada Department of Transportation material source described in Subsection 106.02 of the Special Provisions.

Materials: Rock, soil, and other mineral products.

LAA: Libby Amphibole Asbestos a complex mixture of amphibole fibers―both mineralogically and morphologically. The mixture primarily includes winchite, richterite, and tremolite fibers with trace amounts of magnesio-riebeckite, edenite, and magnesio-arfvedsonite. These fibers exhibit a complete range of morphologies from prismatic crystals to asbestiform fibers (Meeker et al., 2003) (EPA, Toxicologic Review of Libby Amphibole Asbestos 2014)

NAC: Nevada Administrative Code

NDOT: Nevada Department of Transportation, Environmental Services Division, NOA/Erionite Branch

NOA: Naturally Occurring Asbestos. a term used to describe asbestos minerals as natural components of soil or rock. Asbestos has been classified as a Group 1 Carcinogen by the International Agency for Research on Cancer a subgroup of the World Health Organization.

NRS: Nevada Revised Statute

PG: Professional Geologist, a person meeting the requirements of Nevada Revised Statue 514.005.

PLM: Polarized light microscopy, is a microscopy technique in which a polarized light source is used. TEM: Transmission electron microscopy, is a microscopy technique in which a beam of electrons is transmitted through a specimen to form an image.

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