Supplemental_Language_Environmental_Specification.pdf

FY18 Update July 23, 2018

Supplemental language for Specification Section 015950 - Safety and Health

This supplement is intended to be used for all construction contracts and service contracts at the Federal Center, 4300 Goodfellow, St. Louis, MO. This supplement applies to all projects where contractors are working in the following areas:

● Penthouses

● Mechanical spaces

● Above ceilings

● Basements/Basement tunnels/crawl spaces

● Exterior Grounds

● Substations and electrical vaults

The following requirements are in addition to the requirements of section 015950. [This contract language can be incorporated into specification section 015950 by copy and pasting into the appropriate sections of the specification OR the Project Manager can use this as a stand alone specification if the project does not warrant the use of masterspec section 015950. These requirements shall also be incorporated into Professional Services contracts such as A/E, CM, etc]

Part 1 - Summary of Goodfellow Federal Complex Environmental Conditions

Many of the facilities and grounds on the Goodfellow Federal Complex, St. Louis, Missouri have been reported to be environmentally contaminated with varying concentrations of hazardous chemicals/materials. The following list of reported environmental contaminants that have the potential to affect worker safety and health is extracted from the 2013 Tetra Tech, Inc. (Tetra Tech) Occupational Exposure

Evaluation Report.

ASBESTOS

Amosite – trace amounts up to 6%

Chrysotile – trace amounts up to 10%

Crocidolite – trace amounts

Total Asbestos – trace amounts up to 15% (2016 OSHA sampling results discovered up to 35% friable asbestos)

TOXIC METALS

Antimony

Arsenic

Barium

Beryllium

Cadmium

Chromium

Copper

Lead

Mercury

Selenium

Silver

Polychlorinated Biphenyls (PCBs)

Decachlorobiphenyls

Dichlorobiphenyls

Heptachlorobiphenyls

Hexachlorobiphenyls

Monochlorobiphenyls

Nonachlorobiphenyls

Octachlorobiphenyls

Pentachlorobiphenyls

Tetrachlorobiphenyls

Trichlorobiphenyls

Total PCBs

Total Petroleum Hydrocarbons (TPHs)

Diesel Range Organics

Gasoline Range Organics

Oil Range Organics

Volatile Organic Compounds (VOCs)

Acetone

Carbon disulfide

Dichloroethylene, 1,2-cis-

Methyl Ethyl Ketone

Trichloroethene

Xylenes, m

Xylenes, p

Total Xylenes

Semi-Volatile Organic Compounds (SVOCs)

Acenaphthene

Acenaphthylene

Acetophenone

Anthracene

Benzaldehyde

Benz(a)Anthracene

Benzo(a)Pyrene

Benzo(b)Flouranthene

Benzo(g,h,i)Perylene

Benzo(k)Fluoranthene

Bis(2-Ethyl Hexyl) Phthalate

Biphenyl, 1,1´-

Butyl Benzyl Phthalate

Caprolactam

Carbazole

Carbon disulfide

Chlorophenyl Phenyl Ether, 4-

Chrysene

Dibenzo(a,h)Anthracene

Dibenzofuran

Dichlorophenol, 2,4-

Diethyl Phthalate

Dimethylphenol, 2,4-

Di-n-Butyl Phthalate

Di-n-Octylphthalate

Fluoranthene

Fluorene

Hexachlorocyclohexane, beta

Indeno(1,2,3-cd)Pyrene

Methylnaphthalene, 2-

Methylphenol, 2-, 3-, 4- (Cresols)

Naphthalene

Nitroaniline, 3-

Nitrophenol, 4-

Nitrosodiphenylamine, n-

Pentachlorophenols

Phenanthrene

Phenol

Pyrene

POISON

Cyanide

EXPLOSIVE COMPOUNDS AND PHOSPHORUS

2,4-Dinitrotoluene

2,6-Dinitrotoluene

2-Amino-4, 6-Dinitrotoluene

4-Nitrotoluene

Nitrobenzene

Phosphorus

Approximately 83 total contaminants that have the potential to affect worker safety and health were reported by Tetra Tech on site (Cyanide was reported by SCS Engineers

2008 Combined Preliminary Assessment/Site Inspection Report (starting on page 4-19) and is provided as part of this list of contaminants). The added totals of each variation of the asbestos contaminants, the xylene contaminants, and the polychlorinated biphenyls contaminants may make them a potential safety and health hazard as well.

A list of contaminants and their locations can be found in Appendix B, Tables 1 through

14 of the 2013 Tetra Tech Occupational Exposure Evaluation Report. The 2013 Tetra

Tech report does not constitute a complete list of potential contaminants. Additional reports assessing various aspects of the contamination on the Goodfellow Federal

Complex are available in the online reading room

(http://www.gsa.gov/portal/content/212361). Safety Data Fact Sheets are provided for each contaminant. All these reports were compiled to assess the contamination from an environmental perspective. Environmental action thresholds do not necessarily correlate into OSHA permissible exposure limits (PELs) because they were the result of testing/sampling in a static environment. OSHA requirements involve sampling/testing using an 8-hour time weighted average/30-minute excursion limit while each job specific activity is in progress.

Contractors whose employees are engaged in work that could potentially put them into contact with, or disturb any and/or all of the environmental contaminants present in such a manner as to make them airborne, shall perform the appropriate hazard assessment and testing to protect their employees according to OSHA 29 CFR 1910 and 1926 regulations. The hazard assessment shall include industrial hygiene sampling/testing as necessary. Contractors shall take the appropriate protective measures to ensure their actions do not place other federal complex personnel at risk

(i.e. post warning signs, install engineering controls, create barriers, erect containment, control access to work areas, etc.). Contractors will also ensure their employees decontaminate as required prior to leaving work areas and/or the job site so they do not cross contaminate non-contaminated areas/spaces.

Multiple building interiors (first and second floors) are reported to contain varying amounts of particulate lead and other heavy metals that could affect worker safety and health. These areas include, but are not limited to, the space above the ceiling tiles, mechanical rooms, penthouses, HVAC systems, substations, and electrical vaults.

Asbestos containing materials are also present in some of these spaces and are currently being managed in place. Work in areas that have the potential to disturb asbestos containing materials requires an asbestos work permit to be issued from the

GSA Building Manager prior to the start of work. Construction projects that may affect asbestos containing materials require a pre-alteration assessment to be accomplished and coordination through the GSA Region 6 Asbestos Program Manager prior to the start of work. The asbestos pre-alteration assessment for construction projects is typically performed by GSA.

Multiple building interiors (basement/basement crawl spaces/utility tunnels) are reported to contain a variety of environmental contaminants that could affect worker safety and health. Contamination includes friable asbestos in the soil, different toxic metals on building surfaces and in the soil, different explosive compounds and phosphorus in the sump water and soil, and different organic compounds in the sump water and soil.

Asbestos containing materials are also present in some of these spaces and are currently being managed in place. Work in areas that has the potential to disturb asbestos containing materials requires an asbestos work permit to be issued from the

GSA Building Manager prior to the start of work. Construction projects that may affect asbestos containing materials require a pre-alteration assessment to be accomplished and coordination through the GSA Region 6 Asbestos Program Manager prior to the start of work. The asbestos pre-alteration assessment for construction projects is typically performed by GSA.

Multiple building interiors (building electrical spaces, including electrical vaults, and interior/exterior ground soil and groundwater) are reported to contain a variety of polychlorinated biphenyl (PCB) contamination. Building interior contamination includes

PCBs in the concrete where PCB oil filled transformers used to be. The crawlspace soil of Building 108B is also reported to have PCB contamination. Exterior building ground soil and groundwater is also contaminated with PCB contamination that could affect worker safety and health. Maintenance and construction projects that could disturb

PCB laden concrete, interior/exterior ground soil or groundwater must be coordinated through the GSA Region 6 Environmental Program Manager prior to the start of work.

Multiple federal complex exterior areas are reported to be contaminated with a variety of environmental contaminants in the ground soil and groundwater that could affect worker safety and health. Maintenance and construction projects that could disturb federal complex grounds/ground water must be coordinated through the GSA Region 6

Environmental Program Manager prior to the start of work.

GSA Region 6 Public Building Services has attached the 2013 Tetra Tech Occupational

Exposure Evaluation Report and the SCS Engineers 2008 Combined Preliminary

Assessment/Site Inspection Report with Addendum 1(Interim Lead Wipe Sampling and

Assessment Report) to this contract. GSA Region 6 Public Building Services made these reports and multiple additional reports available on the GSA Website at:

http://www.gsa.gov/portal/content/212361. Additional reports are uploaded periodically as more information becomes available.

Reports incorporated by reference – 2008 SCS Engineers Combined Preliminary

Assessment/Site Inspection Report with Addendum 1(Interim Lead Wipe Sampling and

Assessment Report, 2013 Tetra Tech Occupational Exposure Evaluation Report, and

2016 OCCU-TECH Asbestos Air, Lead Air, and Lead Dust Investigation report. These reports can be obtained from the Contracting Officer or they can be reviewed on the

GSA website.

NOTE: In regard to work under the scope of this contract: Whenever cleanup of lead is required to accomplish the scope of work, it is the goal of the government to clean down to the lowest possible level as reasonably achievable not to exceed 40 ug/ft2 (HUD guidelines).

SUBMITTALS

Prior to beginning any work (after contract award and prior to Notice to Proceed), the contractor shall prepare and submit to the GSA Contracting Officer for review, a site specific work/safety plan describing the protective measures they will use. Additionally, prior to a subcontractor beginning any work, the contractor shall (1) obtain a statement from each subcontractor verifying the sufficiency of the contractor’s site specific work/safety plan or (2) obtain a subcontractor site specific work/safety plan from each subcontractor describing the protective measures they will use. Upon the contractor's review and approval of each (1) subcontractor statement verifying the sufficiency or (2) subcontractor site specific work/safety plan, the contractor shall submit the approved (1) subcontractor’s statement or (2) subcontractor site specific work/safety plan to the GSA

Contracting Officer for review. The contractor shall remain fully responsible and liable to assure his staff and all subcontractor staff comply with the contractor and subcontractor site specific work/safety plan(s). A copy of the accepted site specific safety plan must be available onsite while work is being performed.

http://www.gsa.gov/portal/content/212361

Contractors shall provide any sampling/testing results as part of the safety plan. The site specific work/safety plan(s) shall include but not be limited to the following (cover the who, what, when, where, why, and how):

Goodfellow SSSP Plan Review Checklist

This is a guide to what a Goodfellow Site Specific Safety Plan (SSSP) should contain.

Upon review, these are the items we are looking for in an SSSP that will allow us to determine if the contractor submitting the plan understands the safety and health requirements of the job they are performing as they relate to the contaminants they may be exposed to. Most importantly we have to do our due diligence to ensure the work contractors are performing does not jeopardize the safety and health of our GSA employees, the tenants, or other contractor employees on site. Generally, a SSSP should contain the following:

1) Title of Document:

● Document title should include “Site-Specific Safety Plan” as part of description.

2) Date of Plan:

● Include the date of when the plan was written. If revisions are made to the initial plan, the new revision date can be used or the original date with the revision number can be used, i.e., October 12,2017, Revision 1.

3) Introduction:

● Brief acknowledgement that there is an understanding that the site is contaminated.

4) Location and Description of Work:

● Describe the work you intend to perform and all the contaminated spaces you intend to perform it in.

● Currently, GSA has identified the following areas as contaminated: all spaces above suspended ceilings on the first and second floor of every building, all building HVAC air handlers, VAV’s, and ductwork, Bldg 104

VA Records Center first floor occupied space, all penthouses, all mechanical rooms, all substations/electrical vaults (PCBs embedded into concrete floors, and lead and heavy metal dust on surfaces ), all utility tunnels, all building basements (concrete floors), all building basement crawl spaces (in addition to other contaminants, dirt floor is also contaminated with up to 35% friable asbestos), all sump pump/groundwater and exterior grounds. This is not an all-inclusive list. If you identify a space not listed, please notify GSA immediately.

5) Hazard Assessment

● Assessment

○ Your evaluation of the hazards (contaminants) in the contaminated spaces you intend to perform your work in.

● Personal Protective Equipment (PPE) Required o PPE you are requiring your employees to use while working in the contaminated space(s).

● Responsibilities

○ Describe who is responsible for the plan and who is going to ensure it is complied with.

○ Signature of person responsible for the plan.

6) Operating Procedures

● Must include the work practices and procedures you plan on using to keep your workers safe, i.e. steps employees must take to enter the space, work safely in the space, and what they need to do after exiting the space.

● Must include disposal and clearance procedures for contaminated materials/PPE.

● Must include requirement to post signage and/or controls your employees will use so other complex personnel don’t accidentally enter the space while your employees are performing work.

● Must include requirement to coordinate and communicate all contractor activities through the GSA St. Louis West Field Office.

● Must include how you plan on “clearing the space” if your activities stir up/make contaminants airborne before releasing the space back to GSA/tenants.

● Must include requirement that all work will be performed after business hours/when tenants are not present.

● Must include how you intend to close off/isolate the air plenum in the space above the suspended ceiling between the space you are working in and other spaces so contamination made airborne by your work activities is not spread.

● Negative Exposure Assessments – If you chose to perform a negative exposure assessment (optional), you must include a sampling plan and statement that

GSA will be provided and accept all negative exposure assessments (including supporting documentation and sampling data) before you are allowed to implement it.

● Must include how you intend to close off/isolate spaces that open to the exterior so contamination made airborne by your work activities is not spread. Also, plan must include methods to prevent tracking of contaminants from the space into the exterior.

5) Emergency Procedures

● Must include your emergency contacts, emergency/accident procedures (hospital location, first aid, etc.