Attachment 0004B -PDF Appendix A- BVAMC ASBESTOS OM PLAN 2018.pdf

DEPARTMENT OF VETERANS AFFAIRS MEDICAL CENTER

Birmingham, Alabama

APPENDIX A:

ASBESTOS OPERATIONS AND MAINTENANCE (O&M) PLAN

1.0 INTRODUCTION

In accordance with Veterans Health Administration Directive 7714, April 6, 2017 Asbestos Management Program, this Operations and Maintenance (O&M) Plan is required when an asbestos inspection reveals the presence of friable asbestos containing material (ACM) in a building, and the ACM is in good condition. Although the plan may be appropriate and sufficient for managing asbestos in place and assuring compliance with construction and exposure regulations, in some cases the Plan is not enough and abatement will be necessary.

2.0 PURPOSE AND OBJECTIVES

Per Veterans Health Administration Directive 7714, April 6, 2017, the primary objective of this O&M plan is to control building occupant and employee exposure to asbestos fibers.

In addition, the procedures in this O&M plan attempts to:

• Minimize any potential hazard posed by existing ACM/presumed ACM (PACM) during cleaning, maintenance, and general operation activities.

• Complying with applicable Environmental Protection Agency (USEPA) and Occupational Safety and Health Administration (OSHA) regulations.

• Describe the locations and approximate quantities of ACM, PACM, and Regulated

ACM (RACM).

This O&M plan applies to employees, building occupants, and contractors. Engineering Service and Environmental Management Services (EMS) personnel assigned asbestos-related tasks must complete training that addresses the written procedures; VHA polices, and complies with appropriate portions of the USEPA and OSHA regulations.

The procedures contained in this plan must be reviewed and updated periodically to ensure compliance with emerging requirements.

3.0 DEFINITIONS

▪ Asbestos. Includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these minerals that have been chemically treated or altered.

▪ Asbestos Containing Material (ACM). Any material or product that contains more than 1% asbestos.

▪ Category I Non-friable ACM. Material such as packing, gaskets, resilient floor covering, and asphalt roofing products containing more than 1% asbestos.

▪ Category II Non-friable ACM. Any material containing more than 1% asbestos that is not category I non-friable ACM, and that, when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure. Category II ACM includes, but is not limited to:

• Asbestos cement siding and shingles,

• Cementitious (Transite™) panel boards, and

• Asbestos cement pipe (asbestos cement pipe may not be limited to buildings).

▪ Friable ACM. Any material containing more than 1% asbestos that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure.

▪ High-Efficiency Particulate Air (HEPA) Filter. A filter capable of trapping and retaining at least 99.97% of monodispersed particles of 0.3 micrometers or larger in diameter.

▪ Presumed Asbestos Containing Material (PACM). Thermal System Insulation (TSI) and surfacing material found in buildings constructed before 1981 and floor tile installed in buildings through 1981 may contain asbestos. Although it is unlikely, some flooring installed after 1981 may contain asbestos. Until sampling demonstrates that the material has 1% or less asbestos, we consider these materials PACM.

▪ Regulated Asbestos Containing Material (RACM). RACM includes:

• Friable asbestos material;

• Category I non-friable ACM that has become friable, or has been subjected to sanding, grinding, cutting, or abrading; and

• Category II non-friable ACM that has a high probability of becoming crumbled, pulverized, or reduced to powder during demolition or renovation operations.

▪ Vinyl Asbestos Floor Tile. When vinyl floor tile, and in some cases its mastic, contains more than 1% asbestos, it must be handled as ACM.

4.0 ASBESTOS LOCATIONS

The Birmingham VA Medical Center is located at 700 South 19th Street, Birmingham, AL 35233. The facility consists of multiple buildings which include the following buildings with their associated square footage that were assessed in the 2017 Asbestos reinspection:

BIRMINGHAM VA MEDICAL CENTER

BUILDING LIST

Building Name Square Footage

1 Main 613,547

1 RD (Research Wing) 27,272

1Z Wing (Blind Rehabilitation) 68,959

K Wing Main 21,000

L Wing Main 21,000

Guntersville CBOC * 9,365

Shoals CBOC * 7,650

Building Name Square Footage

Gadsden CBOC * 10,255

Jasper CBOC * 9,255

Annex (Bagel Bldg.) * 26,894

Bessemer CBOC * 11,235

Callahan Eye Clinic * 13,545

Anniston CBOC * 9,195

Prosthetics CBOC * 6,755

Childersburg CBOC * 9,235

Birmingham VA Clinic * 63,565

Huntsville Clinic * 61,785

Pickwick Call Center * 9,835

Warehouse (25th Street) * 10,000

Total Square Footage: 1,010347

* Leased Spaces

In 2017, the BVAMC Safety office conducted an asbestos re-inspection of accessible areas of the Birmingham VA Medical Center. No roof samples were obtained. Therefore, roofing materials are considered PACM. This inspection will be used as the basis for this AMP and the Asbestos O&M Plan.

The 2017 Asbestos Reinspection indicated the following materials were found to contain asbestos in various locations throughout the facility:

• Vinyl floor tile & mastic

• Tar paper wrap on mineral wool pipe insulation

• Spray-on fire-proofing on beams & deck

• Perforated Transite wall panels

• Transite sheets in fume hood

• Transite sheets in recessed radiator units

• Layered paper pipe insulation

• Tar roofing

• Black tar on exterior brick walls

• Transite sheets on exterior siding

• Ebony Black Lab Counter Tops

Location Room/Area Asbestos-containing material

Hazard Rank

Current Condition/ Description

Disturbance Potential

Friability

Building 1 (Main Hospital)

B103B, G306B, G30, G512A, 1304, 2307. 3304, 4304, 5304, 6304, 7304, 7305, 8304, 8306, 9304A, 9309, closets on all floors by elevator #5

12” vinyl floor tile & mastic 3 Good

Potential for Significant Damage Non-Friable

Vertical pipe chase from 1st- 10th floor east of elevator 5, receipt

Tar paper wrap on mineral wool pipe insulation 2 Good Potential for

Damage Non-Friable

G406, G413 Spray-on fire-proofing on beams & deck 1 Good Low Friable

1607, 2604 Perforated Transite wall panels 3 Good Potential for

Significant Damage Non-Friable

2344, 3429, 3422 Transite sheets in fume hood 1 Good Low Non-Friable

All rooms and floors in original building Transite sheets in recessed radiator units 1 Good Low Non-Friable

8306 and in inaccessible wall and ceiling chases on all floors

Layered paper pipe insulation 1 Good Low Non-Friable

1st floor by elevator 15/16, 3rd floor by 3308 and 3309 Tar roofing 2 Good

Potential for Damage Non-Friable

Basement and 10th floor Black tar on exterior brick walls 1 Good Low Non-Friable

Auditorium 9211 exterior walls Transite sheets on exterior siding 1 Good Low Non-Friable

Building 1RD (Research Wing)

2701, 2702, 2705, 2714A, 3701, 3702, 3705, 4701, 4702, 4605 & 4706

12” vinyl floor tile & mastic 3 Good

Potential for Significant Damage Non-Friable

Auditorium 9211 exterior walls Transite sheets on exterior siding 1 Good Low Non-Friable

Building 1Z (Blind Rehabilitation)

2701, 2702, 2705, 2714A, 3701, 3702, 3705, 4701, 4702, 4605 & 4706

12” vinyl floor tile & mastic 3 Good

Potential for Significant Damage Non-Friable

G415 & G416 Spray-on fireproofing on beams and deck 1 Good Low Friable

Dental Laboratory 2610 Ebony Black Lab

Counter Tops 2 Good Potential for

Damage Non-Friable

*Maintenance must consult drawings for sheetrock walls constructed prior to 1981 before performing work on any joint compound.

**Always check with Industrial Hygiene before disturbing any floor tile or mastic on all floors.

A complete listing and more details of the asbestos containing materials is found in the 2017 Asbestos Re-Inspection Report, which can be found at Z: Drive »Safety »Asbestos & Lead. The materials found to contain asbestos will require that all employees and contractors follow the standard operating procedures outlined in this plan. Due to continual capital projects and subsequent ACM removal and O&M projects, this list will continually change and require updating on a regular basis. The FAC will assure these changes and updates are made. The 2017 Asbestos Re-Inspection should be reviewed to make these determinations.

5.0 AUTHORITY AND KEY REGULATORY REQUIREMENTS

The procedures contained in this Asbestos O&M Plan are based on numerous Federal and State laws, regulations, guidance and United States Department of Veterans Affairs specific policies, and guidance. The key regulatory requirements are noted in the list below. These documents should be kept current and readily available to personnel who are responsible for the Asbestos O&M Program.

Department of Veterans Affairs Directives

• Asbestos Management Program; VHA Directive 7714, April 6, 2017

Occupational Safety and Health Administration (OSHA) Regulations

• Occupational Exposure to Asbestos, Tremolite, Anthophyllite, and Actinolite;

Final Rules Title 29, Part 1910, Section 1001 and Part 1926, Section 1101 of the Code of Federal Regulations

• General Asbestos Regulations; Title 29, Part 1910, Section 1001 and Part 1926, Section 1101 of the Code of Federal Regulations

• Respiratory Protection; Title 29, Part 1910, Section 134 of the Code of Federal Regulations

• Asbestos in the Construction Industry; Title 29, Part 1926, of the Code of Federal Regulations

• Access to Employee Exposure and Medical Records; Title 29, Part 1910, Section 1020 of the Code of Federal Regulations

• Hazard Communication; Title 29, Part 1910, Section 1200 of the Code of Federal Regulations

• Specifications for Accident Prevention Signs and Tags; Title 29, Part 1910, Section 145 of the Code of Federal Regulations

Department of Transportation (DOT) Regulations

• U.S. DOT, including but not limited to: Hazardous Substances; Title 29, Part 171 and 172 of the Code of Federal Regulations

USEPA Regulations

• USEPA, including but not limited to: Asbestos Abatement Projects; Worker Protection Rule; Title 40 Part 763, Subpart G of the Code of Federal Regulations

• AHERA Regulation ACM in Schools Final Rule & Notice; Title 40, Part 763, Subpart E of the Code of Federal Regulations

• Training Requirements of AHERA Regulation ACM in Schools Final Rule & Notice; Title 40, Part 763, Subpart E, Appendix C of the Code of Federal Regulations

• National Emission Standards for Hazardous Air Pollutants (NESHAP) National Emission Standards for Asbestos; Title 40, Part 61, Subpart A, and Subpart M (Revised Subpart B) of the Code of Federal Regulations

6.0 EMPLOYEE TRAINING

Each EMS and Engineering Service employees, who perform custodial, maintenance, or utility tasks and other employees who may disturb asbestos during their normal job duties must complete a minimum of 2 hours of asbestos awareness training BEFORE they begin duties and annually thereafter. Asbestos awareness training should include such topics as:

• Background information on asbestos,

• Health effects of asbestos,

• Worker protection programs,

• Locations of ACM and PACM at the facility,

• Recognition of ACM and PACM damage and deterioration,

▪ The O&M plan for the facility, and

• Proper response to fiber release episodes.

Several online VA asbestos awareness training courses provide certificates of completion and meet the requirements of OSHA 29 CFR 1910.1001(j)(7)(iv).

7.0 NOTIFICATION

A notification program has been developed to inform employees, building occupants, visitors, and regulatory agencies of asbestos-related activities and hazards. Descriptions of the type and location of potentially friable ACM, and the means by which personnel will avoid disturbing the ACM, must be included in each notification.

The Industrial Hygienist will inform all workers, and building occupants of ACM within their respective facilities in a language that is understandable to the person receiving the notification. The notification will be issued at least annually or when there is a change in the condition of the ACM in the facility.

All contracts dealing with asbestos abatement shall be adequately worded to require the contractor to notify the proper regulatory agencies. Otherwise, the Industrial Hygienist is responsible for notifying the appropriate regulatory agencies.

8.0 PERIODIC SURVEILLANCE OF EXISTING ACM

The existing ACM is subject to deterioration with age, the effects of building occupancy, and accidental damage. To monitor the condition of accessible ACM, the Industrial Hygienist or a trained, designated individual or contractor shall visually inspect the material at regular intervals (at least two times per year), and immediately report any ACM damage or deterioration. The semi-annual visual assessment will be conducted on friable ACM, which is designated with the potential for damage or potential for significant damage. The assessment can be completed either by visual inspection on environment of care rounds, by a qualified person from the facility on six-month rotating schedule, or through a third-party contractor.

The Industrial Hygienist keeps a written record of these periodic inspections. The record must include:

• Date of inspection;

• Building number;

• Room (location);

• Type of ACM;

• Abatement status;

• Assessment;

• Recommended action(s);

• Signature of inspector.

The most recent inspection/risk assessment should be used as the basis for this survey.

9.0 RECORDKEEPING

In accordance with applicable USEPA and OSHA regulations and pertinent VA policies, the Industrial Hygienist must ensure that the Birmingham VA Medical Center staff retains facility asbestos management documents including:

• Copies of Asbestos Hazard Emergency Response Act (AHERA) inspection and assessment reports;

• Written O&M plan;

• Semiannual ACM/PACM visual inspection records;

• Awareness training records; and

• Changes to location, condition, or quantity of the ACM/PACM.

10.0 JOB SITE CONTROLS FOR WORK INVOLVING ACM

Whenever EMS and Engineering Service employees, who perform custodial, maintenance, or utility tasks and other employees perform work in areas where ACM or PACM is present, they shall consult the Industrial Hygienist prior to any anticipated activity that may impact known or suspect ACM. They must use appropriate work practices and protective measures to minimize the potential to disturb the ACM/PACM.

In other words, it is important to minimize the disturbance of ACM and the subsequent release of asbestos fibers. You can accomplish this by staying out of physical contact with materials that contain, or are presumed to contain, asbestos.

Birmingham VA Medical Center employees shall not purposefully disturb any known or suspect ACM or asbestos debris. Birmingham VA Medical Center employees shall not perform Class I, Class II, or Class III asbestos work. ACM O&M activities and asbestos clean-up activities (Class III and Class IV) shall be performed by accredited, experienced asbestos removal contractors.

11.0 SAFE WORK PRACTICES

Accredited, experienced asbestos removal contractors shall use appropriate work practices including:

• Avoidance of certain activities such as sawing, sanding, or drilling around

ACM/PACM;

• Area isolation, demarcation and warning signs;

• Use of negative pressure enclosures (NPEs) or glovebags;

• Use of wet methods (such as applying water to ACM with a low-pressure sprayer);

and

• Use of High Efficiency Particulate Air (HEPA) vacuum.

12.0 PROHIBITED ACTIVITIES

Prohibited work activities include:

• Use of compressed air to clean surfaces contaminated with asbestos dust or debris.

• Use of dry shoveling, dry sweeping or other dry methods to clean surfaces contaminated with asbestos dust or debris.

• Use of non-HEPA vacuum to clean surfaces contaminated with asbestos dust or debris.

• Sanding, sawing, drilling or otherwise abrading of ACM.

• Use of mechanical buffers at speeds greater than 300 rpm to strip finishes from asbestos-containing floor material.

• Burnishing or dry buffing of asbestos-containing flooring to the point the finish becomes deteriorated or otherwise stripping finishes from asbestos-containing floor material.

The Industrial Hygienist shall be informed immediately when ACM is disturbed, damaged, or when asbestos debris needs to be cleaned up. EMS and Engineering Service employees and other employees performing work in areas where ACM or PACM is present shall adhere to the 3-Rs when ACM is disturbed, damaged, or when asbestos debris needs to be cleaned up:

• Recognize the asbestos hazard.

• Restrict access to the hazardous area and isolate the HVAC system.

• Report the hazard to the Industrial Hygienist immediately.

13.0 WORKER PROTECTION

EMS and Engineering Service employees, who perform custodial, maintenance, or utility tasks must not participate in asbestos O&M and removal activities unless they are in full compliance with Federal and State regulations concerning training, accreditation, and medical surveillance standards and follow OSHA and EPA requirements.

Birmingham VA Medical Center employees shall not purposefully disturb any known or suspect ACM or asbestos debris. Birmingham VA Medical Center employees shall not perform Class I, Class II, Class III or Class IV asbestos work.

ACM O&M activities and asbestos clean-up activities (Class III and Class IV) shall be performed by accredited, experienced asbestos removal contractors.