APPLYING LOCAL AND STATE AIR QUALITY REGULATIONS CONCERNING NATURALLY OCCURRING ASBESTOS (NOA) AT THE DISTRICT LEVEL IN EL DORADO COUNTY: AN AIR POLLUTION CONTROL OFFICERS PERSPECTIVE

El Dorado County's Air Quality Management District (AQMD) enforces local and state regulations promulgated to minimize NOA emissions during construction and/or surface mining soil disturbing activities. With the widespread occurrence of NOA in Western El Dorado County, often identified as Tremolite/Actinolite asbestos, significant resources have been expended to protect the public from NOA exposure. Public interest on the issue, especially concerns over potentially contaminated public school sites and parks, has been high, leading to extensive involvement by the USEPA and other State and Federal agencies, which included school site mitigation and extensive (yet unpublished) assessment of NOA exposure study, numerous public meetings and media scrutiny.

Several years ago, El Dorado County promulgated a local ordinance which put forth requirements to minimize construction and mining generated NOA fugitive dust, and for disclosure of NOA presence during real estate transactions. With building development activities at all time high and likely to increase in the future, El Dorado AQMD is responsible for assuring that earthwork conducted in NOA containing areas is conducted with minimal fugitive dust generation. The enforcement becomes complex, as there are issues with soil sampling and analytical procedures, required to determine the presence or absence of NOA. There are even more complex issues regarding sampling and interpretation of NOA air monitoring data. The El Dorado AQMD is working with local professional and public groups to deal with these issues and to promulgate new rules to eliminate some shortcomings of the currently utilized state and local regulations. Success in addressing the numerous issues NOA has been mixed with much work left to do.