S05-Mountain Home TN - VA Asbestos O AND M Plan January 2010 -1.pdf

ASBESTOS

OPERATIONS AND MAINTENANCE

PROGRAM

For:

James H. Quillen (Mountain Home) Veterans Administration Medical Center The Corner of Lamont and Veterans Way

Mountain Home, Tennessee 37684

Prepared for:

The Department of Veterans Affairs Acquisition Service Center VISN 9 (90C) 1639 Medical Center Parkway, Suite 400

Murfreesboro, TN 37129

Prepared by:

EFI Global, Inc.

8100 Professional Place, Suite 113

Landover, MD 20785 Phone: 240/764-1785 FAX: 240/764-1792

January 2010

Prepared by: Reviewed by:

Thomas J. Doxey Jonathan M. Schatz, MS, CES, CEI Senior Project Manager Senior Project Manager

Asbestos O&M Program James H. Quillen VA Medical Center, Mountain Home, TN

Table of Contents

TABLE OF CONTENTS

PAGE

1.0 INTRODUCTION.................................................................................................... 1 – 1

2.0 ASBESTOS CHARACTERISTICS AND HEALTH EFFECTS ............................... 2 – 1

2.1 Background.................................................................................................. 2 – 1

2.2 Health Effects .............................................................................................. 2 – 2

2.3 Regulatory Requirements ............................................................................ 2 – 2

3.0 PROGRAM RESPONSIBILITIES........................................................................... 3 – 1

3.1 Asbestos Program Coordinator.................................................................... 3 – 1

3.2 Building Occupant Responsibilities .............................................................. 3 – 2

4.0 MANDATORY PROGRAM REQUIREMENTS....................................................... 4 – 1

4.1 Caution Labels............................................................................................. 4 – 1

4.2 Training Requirements................................................................................. 4 – 2

4.3 Fiber Release Episodes............................................................................... 4 – 2

4.4 Periodic Surveillance Activities .................................................................... 4 – 3

4.5 Periodic Air Monitoring................................................................................. 4 – 4

4.6 Waste Disposal............................................................................................ 4 – 4

4.7 Recordkeeping............................................................................................. 4 – 5

4.8 Contractor Notification ................................................................................. 4 – 6

4.9 Tenant Notification....................................................................................... 4 – 7

5.0 INVENTORY OF ACBM ON THE PROPERTY...................................................... 5 – 1

5.1 Material Type, Friability, Locations, Preventive Measures, and Recommendations for ACBM ...................................................................... 5 – 1

6.0 LIMITATIONS......................................................................................................... 6 – 1

APPENDIX A USEFUL REFERENCES

APPENDIX B CLEANING PROCEDURES

APPENDIX C RECORDKEEPING SYSTEM

APPENDIX D FIBER RELEASE MANAGEMENT

APPENDIX E PROJECT MONITORING FIRMS

APPENDIX F ORGANIZATIONS OFFERING SMOKING CESSATION PROGRAMS

APPENDIX G SAMPLE NOTIFICATION LETTERS

APPENDIX H WORK PRACTICES

APPENDIX I GLOSSARY

APPENDIX J PLAN PREPARER’S CERTIFICATIONS

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1.0 INTRODUCTION

This update of the existing Operations and Maintenance (O&M) Program establishes the policy for managing potential exposures to asbestos-containing building materials (ACBM) present at the James H. Quillen Veterans Administration Medical Center (Mountain Home VA Medical Center), which encompasses twenty-one individual buildings situated in Mountain Home, Tennessee. The individual buildings/building areas discussed in this Program include:

Building 2 (basement only) Building 8 Building 13 Building 15 Building 17 Building 19 Building 20 Building 34 Building 36 Building 37 Building 39

Building 40 Building 41 Building 42 Building 43 Building 44 Building 45 Building 46 Building 47 Building 69 Building 77

An ACBM is one that contains greater than one percent (1%) asbestos by weight.

The specific intent of this Program is to protect the health of property occupants (this includes the building residents), visitors, contractors, custodial, and maintenance personnel while they are on the property. This Program is designed to: (1) ensure that asbestos fibers are not released into occupied areas by minimizing disturbance or damage to asbestos-containing materials; (2) repair or remove any ACBM which is identified as damaged; and (3) monitor the condition of all ACBM on the property. This Program will be in effect until all asbestos-containing materials have been removed from the Site.

This O&M Program is based on the assumption that The Department of Veterans Affairs’ policy precludes employees from disturbing ACBM.

This Program shall go into effect immediately.

The presence of asbestos on the property does not necessarily mean that the health of property occupants (maintenance personnel, custodial personnel, contractors, visitors and residents) is endangered. Asbestos fibers present a serious health hazard only when they become airborne after being released from the material in which they are bound.

Therefore, both on-site management, visitors, contractors and each occupant (including building residents) share the responsibility for not only protecting their own health, but also the health of other persons on the property by not allowing asbestos-containing materials to be disturbed during their normal activities. Asbestos-containing materials are most likely to be disturbed during maintenance, repair, or renovation activities. By complying with all provisions of the O&M Program, management and occupants alike will be assuring a safe environment.

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The locations and information pertaining to the asbestos-containing materials identified in this Operations and Maintenance Program are based upon a review of the following documents:

Asbestos-Containing Materials Inspection Report, dated November 24, 2009, prepared by EFI Global, Inc.

Asbestos Sampling Report, Buildings 8, 13, 15, 17, 19, 20, 34, 35, 36, 37, 44, 45, 46, 47, 69 and 77, dated December 2005, prepared by Alley and Associates, Inc.

Section 5 of this manual identifies both known and presumed asbestos-containing materials. All other materials suspected of containing asbestos on the property should either be assumed to contain asbestos or be tested by polarized light microscopy (PLM) to confirm the asbestos content.

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2.0 ASBESTOS CHARACTERISTICS AND HEALTH EFFECTS

2.1 Background

Asbestos is the generic term for a group of naturally occurring minerals that separate into fibers when crushed or processed. Since the turn of the century, asbestos has been used in a wide variety of construction materials and other building products. Its popularity stems from the fact that it has high resistance to heat, chemical attack, and the flow of electricity, and its fibers serve to reinforce otherwise brittle or weak materials.

There are two general types of asbestos rock: serpentine and amphibole. Chrysotile asbestos is derived from serpentine rock. Chrysotile, sometimes called white asbestos, has very thin fibers that are soft and flexible. Approximately 95 percent of the asbestos used in the United States are the chrysotile type, and its primary applications are in textile, high-strength cement products, and insulating materials.

Amphibole asbestos, which has thicker, harder fibers than chrysotile asbestos, includes several subcategories: amosite, crocidolite, anthophyllite, actinolite, and tremolite. Amosite asbestos, sometimes called brown asbestos, is used widely in insulating materials, plastics, textiles, and construction products. It has the longest fibers of all types of asbestos, and its resistance to acid and heat is particularly high.

For that reason, amosite is often found in buildings as insulation on high-temperature heating equipment such as boilers and exhaust stacks. Crocidolite or “blue” asbestos is also very resistant to acid and to the effects of outdoor exposure.

It is used in textiles and high-strength cementitious products. Anthophyllite, actinolite, and tremolite asbestos have brittle fibers and, therefore, limited applications.

As a rule, the degree of asbestos hazard that exists in a particular property depends on a number of factors; the most important of which may be the nature of the asbestos products present. Asbestos-bearing materials such as asbestos-cement pipe and shingles, roofing felts, vinyl floor tiles, and mastics in which the asbestos fibers are firmly bonded or encased in another material, generally pose very little hazard after installation; however, sanding, grinding, drilling, abrading, or cutting these materials may release asbestos fibers.

Asbestos fibers are more readily released from friable materials like sprayed-on insulation. A material is considered friable if it can be easily crumbled, pulverized, or reduced to powder by hand pressure when dry. Such friable materials can represent a serious potential health hazard in buildings. This does not mean, however, that all friable materials containing asbestos pose a hazard serious enough to warrant immediate corrective action. Textile products and preformed thermal insulation that contain asbestos are less of a hazard than friable materials, but they are somewhat more hazardous than those products in which the asbestos is encased or tightly bonded.

2.2 Health Effects

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Three diseases have been clearly linked to exposure to airborne asbestos fibers:

asbestosis, lung cancer, and mesothelioma. Asbestosis (pulmonary fibrosis) is a chronic lung disease caused by permanent changes in lung tissue due to asbestos exposure. Lung cancer is a malignant and invasive growth or tumor in the lungs.

Cigarette smoking significantly increases the risk of lung cancer for persons exposed to asbestos. Mesothelioma is an extremely rare cancer in the general population, but is not uncommon among asbestos workers or workers exposed to friable asbestos, such as shipyard employees. Some believe that it may develop even with very low levels of asbestos exposure. Mesothelioma affects the membrane (mesothelium) lining the chest or abdominal cavities.

The health hazard from asbestos exposure was initially considered to be related to a dose-response relationship. As more medical data has become available, it has been found that even persons exposed to low concentrations of airborne asbestos;

e.g., families of asbestos workers have developed asbestos-related diseases.

However, the data is difficult to evaluate because there usually is a long delay between exposure and the detection of disease. This is called the latency period, and for asbestos diseases it is approximately 10-40 years. One hypothesis is that “an inverse relationship exists between dose rates and the latency period; as the dose rate becomes progressively lower; the latency period may approach the life span of exposed individuals” (Lory and Coin, 1981).

Because of a lack of specific health based information and a lack of understanding of the precise mechanism that contributes to the development of asbestos-related diseases, it has not been possible to establish permissible levels of exposure to asbestos that will ensure absolute safety. Nonetheless, Government regulators have established exposure limits below which they believe the risk is very low. It is now generally agreed that all unnecessary exposures to asbestos should be avoided, and that proper precautions should be taken to minimize risks if exposures are unavoidable.

2.3 Regulatory Requirements

Effective October 1, 1995, the Occupational Safety and Health Administration (OSHA) tightened its existing asbestos regulations in several areas. A summary of the new regulations follows.

First, a set of regulations was promulgated for general industry and a second, nearly identical set, for the construction industry. For purposes of property management, the general industry regulations apply primarily to purely custodial work, the construction industry regulations, to all other types of activities. Hence, work done by a custodial staff to clean asbestos-containing floor materials would fall under the general industry standard, while work by the on-site engineering staff in mechanical areas containing ACBM would fall under the construction industry rule.

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Of the two rules, only the construction industry rule distinguishes different types of asbestos work based on OSHA’s perception of the risk to employees doing the work. Thus, Class I work represents the highest potential for employee exposure because it pertains to removal of friable asbestos-containing surfacing materials and thermal system insulation. Class II, considered a lower risk than Class I, involves removal of significant amounts of other types of asbestos-containing materials. For example, this includes, but is not limited to, removal of asbestos-containing wallboard, floor tile and sheeting, gaskets, joint compounds, roofing felts, roofing, and siding shingles.

Removal of small amounts of Class II materials (i.e., an amount that would fit into a glovebag) may be classified as a Class III job. Also, the actual or potential disturbance of asbestos materials during the course of performing maintenance or repair work is considered Class III work. OSHA defines disturbance as an activity that disrupts the matrix of ACBM or presumed ACBM, crumbles or pulverizes ACBM or presumed ACBM, or generates visible debris from ACBM or presumed ACBM.

Class IV work involves contact with asbestos materials and activities to cleanup waste and debris containing asbestos. This O&M Manual concerns itself only with Class IV work.

Under a settlement agreement with the roofing industry, removal of intact roofing cements, coatings, mastics, and flashings is not considered Class II work. Rather, OSHA has stipulated that certain minimal precautions be followed during their removal, provided such materials remain intact throughout the removal process.

The OSHA rule also requires Building Owners to presume as containing asbestos those suspect surfacing materials, thermal system insulation, and vinyl flooring materials installed in buildings built before 1981. To prove otherwise, OSHA says, requires the services of EPA-certified asbestos inspectors who would visually inspect such suspect materials and collect bulk samples for microscopic analysis.

The requirement by OSHA to presume the presence of asbestos in certain suspect materials installed in pre-1981 buildings applies to the four classes of work mentioned above. An example is suspect asbestos-containing insulation covering a leaky water valve in a pre-1981 property. Workers sent to repair the problem would need to have specific training in asbestos work, and must establish controls to assure they weren’t exposed to the suspect material unless a determination was first made by a certified inspector that the insulation did not contain asbestos. Likewise, vinyl floor tiles in pre-1981 properties would have to be cleaned using specified controls unless sampling demonstrated the absence of asbestos.

The new standard also requires that asbestos containing or presumed asbestos-containing materials be identified by means of warning labels. Exceptions are granted where labeling is not feasible, such as marking floor coverings or ceiling tiles. Employees engaged in any of the four classes of work must also be given

2 – 4 training and annual refresher training. Training for custodial workers is required under the general industry standard.

OSHA also has added notification requirements to the new regulation. Employees and contractors who might come in contact with asbestos-containing or presumed asbestos-containing materials must be notified by the Building Owner or Manager of their presence, location, and quantity. So must commercial tenants if work that disturbs asbestos or presumed asbestos materials is performed in their space.

Other notification requirements are also a part of the regulations. However, a blanket notification requirement to inform all tenants in a property that asbestos is there is definitely not a requirement of the new regulations.

The new standard defines basic work procedures that must be followed when working with or coming in contact with asbestos or presumed asbestos materials.

These include working wet to minimize dust generation unless doing so is not feasible; using a special device called a HEPA vacuum cleaner to cleanup debris;

and promptly cleaning up and bagging asbestos or presumed asbestos-containing debris. Custodial employees stripping asbestos or presumed asbestos-containing floor coverings must work wet using low abrasion pads mounted on machines operating at speeds under 300 rpm. Burnishing or dry buffing is only to be done on flooring with a minimum of three layers of overlying wax.

A competent person is to be available to guide employees who perform Class I-IV work. This is a person with special training in asbestos work that also has the authority to ensure worker safety and health on the job.

The OSHA asbestos standards are detailed and complex, and should be examined in their entirety to fully grasp all requirements. In addition, State and local asbestos regulations must be taken into account as well.

Except for public and private schools, grades K through 12, there currently is no legal requirement for property Owners or Managers to develop comprehensive asbestos Operations and Maintenance Program.

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3.0 PROGRAM RESPONSIBILITIES

3.1 Asbestos Program Coordinator

The Asbestos Program Coordinator for James H. Quillen Veterans Administration Medical Center located in Mountain Home, Tennessee is Ms. Miriam Trivette, Health and Safety Coordinator for the James H. Quillen Veterans Administration Medical Center. The Asbestos Program Coordinator can be reached at 423-926-1171 x 7905. Responsibilities of the Asbestos Program Coordinator include but are not limited to the following:

(1) Respond to tenant and Contractor inquiries regarding the presence of asbestos-containing materials on the property.

(2) Maintain records associated with the Program. These may include, but are not limited to, air sampling data, asbestos maintenance closure forms, and periodic condition and label inspection data.

(3) Coordinate air monitoring, as necessary and periodic inspection activities.

(4) Coordinate asbestos removal, repair, and maintenance operations as required.

(5) Assure that all necessary signs and warning labels required by the Program are posted and remain in place.

(6) Coordinate all engineering and maintenance staff asbestos awareness training.

(7) Assure that no additional asbestos-containing materials are brought onto the property, and that stored asbestos, if any, is disposed of properly and not applied to existing materials.

(8) Arrange for EFI Global, Inc. to perform testing of suspect asbestos-containing materials not previously identified. Since all asbestos materials may not have been identified in the previous inspections, the Coordinator should not assume all locations of asbestos materials are known.

(9) Assure contractors are notified of the presence of asbestos-containing materials before they begin work that might disturb these materials.

(10) Assure commercial tenants are notified in advance of work in their space that will disturb or is likely to disturb asbestos.

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3.2 Building Occupant Responsibilities

Building occupants (this includes residents, custodial personnel, maintenance personnel, contractors, and visitors) are also responsible for complying with the provisions of this O&M Program. Major responsibilities of building occupants are to assure they do not disturb ACBM or presumed ACBM, and that they notify their contractors and/or visitors that an O&M Program is in place.

In the event, residents, custodial personnel, maintenance personnel, contractors or visitors encounter any material they suspect may contain asbestos and will be disturbed, they must immediately stop their activity and notify the Asbestos Coordinator or designee. The Asbestos Coordinator or designee will be responsible for determining whether or not the suspect material is asbestos-containing, and what further actions are required before work can continue.

Building occupants are also expected to notify the Asbestos Coordinator if they observe damage or deterioration to ACBM or presumed ACBM, and they themselves are expected to do nothing to cause damage to such materials

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4.0 MANDATORY PROGRAM REQUIREMENTS

4.1 Caution Labels

Caution labels shall be affixed to or near all ACBM on the property where feasible.

The labels shall be prominently displayed and will remain posted until the ACBM is removed. The caution labels should read, in print that is readily visible due to its large size or bright color, as follows:

CAUTION:

ASBESTOS – HAZARDOUS

DO NOT DISTURB WITHOUT PROPER

TRAINING AND EQUIPMENT

– Or –

CAUTION:

ASBESTOS MATERIALS PRESENT

INQUIRE AT MANAGEMENT OFFICE

BEFORE DISTURBING ASBESTOS

Caution labels shall be written in other languages as needed.

Revisions to the OSHA Asbestos Standard specifically call for placement of signs at the entrance to mechanical rooms/areas in which employees reasonably can be expected to enter and which contain asbestos-containing or presumed asbestos-containing thermal system insulation and/or surfacing materials. OSHA also permits placement of signs inside mechanical areas, as opposed to outside them, as long as the sign is clearly visible to those entering the space. The signs must identify the material present, its location, and appropriate work practices to assure that the material is not disturbed.

It is generally not feasible to put labels on walls or floors. In such instances, explore alternatives. For example, if asbestos-containing floors are being serviced by employees who operate from a common equipment room day after day, then post the sign or label in the equipment room.

At periodic intervals, not to exceed semi-annually, the Asbestos Program Coordinator will inspect and ensure all caution labels and signs are in place and well maintained. The Asbestos Program Coordinator may obtain all necessary caution labels and signs through EFI Global, Inc. Each such inspection shall be documented; a form to document these inspections is provided in Appendix C. See Section 5 for labeling requirements.

4.2 Training Requirements

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The Asbestos Program Coordinator and all members of the property’s Management, Maintenance, and Engineering staffs shall receive two hours of asbestos awareness training initially, and annual refresher training. The duration of refresher training sessions is discretionary. The Maintenance and Engineering staff must receive this training regardless of whether or not their work activities will involve actual direct contact with, or disturbance of, ACBM. New Maintenance and Engineering staff employees must receive the required training within 30 days of hire or transfer or before they come in contact with ACBM or presumed ACBM, whichever is earlier.

The awareness training will address the specific subjects listed below:

Asbestos uses and types.

Health effects, including the relationship between smoking and asbestos in producing lung cancer.

Names, addresses, and phone numbers of public health organizations that provide information on smoking cessation programs. A list of such organizations is provided in Appendix F.

All known ACBM locations on the property.

Locations of flooring materials suspected of containing asbestos, if any.

Recognition of ACBM damage, deterioration, and delaminating.

Review of the Company’s Asbestos Management Program and the property’s Operations and Maintenance Program.

Provisions of 29 CFR 1910.1001 and 1926.1101, the OSHA Asbestos Standard for General Industry and the Construction Industry, respectively, dated August 10, 1994, as amended June 29, 1995.

Employee responsibilities under the O&M Program.

A form to document training can be found in Appendix C. To enhance the credibility of the documentation, each employee should sign his/her own name in the appropriate space, as opposed to having someone else write in the participant’s name.

4.3 Fiber Release Episodes

A fiber release episode may result from accidental damage or deterioration of ACBM. If one occurs, immediate action must be taken to prevent occupants and employees from being exposed to airborne asbestos fibers. The Asbestos Program Coordinator must be contacted immediately. See Section 3.1 for how to contact the

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Asbestos Program Coordinator. The Asbestos Coordinator, in conjunction with the Environmental Specialist, will be responsible for implementing the response actions listed below as necessary.

Evacuate the affected area, post signs, and lock all entrances to prevent access.

Temporarily shut off or modifies the air-handling system serving the affected area of the property and limits all other sources of air movement.

Document the incident using the Asbestos Maintenance Closure Form in

Appendix C.

The Asbestos Coordinator, in conjunction with EFI Global, Inc., will then jointly agree on subsequent remedial steps. These will include the following:

Evaluate the need for the services of specialized asbestos services company listed in Appendix D.

Evaluate the need for the services of a project-monitoring firm listed in

Appendix E to oversee the abatement contractor’s work.

In all such instances, the Asbestos Coordinator will document the incident using the Asbestos Maintenance Closure Form in Appendix C.

Further, the Environmental Specialist may investigate the incident. A written report shall be prepared and a copy of the report shall be filed in the “James H. Quillen Veterans Administration Medical Center” file at the property. Copies will also be sent to the Property Manager and/or Operations Manager. The investigation undertaken by the Environmental Specialist will be aimed at trying to determine why the incident occurred, whether or not the incident represented a breakdown in the O&M Program and recommendations to prevent a recurrence.

Additional procedures for fiber release management are listed in Appendix D.

4.4 Periodic Surveillance Activities

The Asbestos Program Coordinator or designee will inspect all known friable asbestos-containing materials to identify any damage or deterioration that has occurred from maintenance activities. This will be done semi-annually. See Section 5 for the locations of all known friable ACBM. The Asbestos Program Coordinator or designee will also inspect labels at six-month intervals and will document the results of these inspections in the asbestos program files. Periodic inspection results for asbestos-containing materials and verification of caution labels shall be documented using the Periodic Surveillance Summary Sheet shown in Appendix C. A sample Periodic Surveillance Summary Sheet form has been completed as an aid in helping complete the blank form correctly and is provided there also.

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Periodic inspection of non-friable asbestos-containing materials is not an O&M Program requirement. The reason is that non-friable applications generally represent a very low risk of releasing asbestos fibers into the air. Non-friable materials are those that cannot be crushed, pulverized, or reduced to powder under hand pressure when dry, and include, but are not limited to floor tile, sheet flooring, mastics, transite panels, and roof flashing. To answer questions as to the friability of known asbestos-containing materials on the property, see Section 5.

Although periodic inspections of non-friable forms of asbestos-containing materials are not required, the Asbestos Coordinator still must assure non-friable forms do not become friable. The Coordinator should also arrange for repair of non-friable forms if they become friable or if the potential for them to become friable increases. For example, broken floor tiles represent an increased risk of fiber release as well as a tripping hazard, and should be repaired or replaced not only because the O&M Program requires it, but also as part of routine activities under the property’s ongoing maintenance program. Even for nonfriable forms of asbestos materials, special controls to minimize the possibility of fiber release are generally necessary during repair and removal.

4.5 Periodic Air Monitoring

In special circumstances, ambient air sampling may be performed periodically by an industrial hygienist to document a safe building environment. The need and requirements for air monitoring will be based upon periodic surveillance information concerning the location and condition of ACBM. The frequency and location of air monitoring will be determined by the Asbestos Program Coordinator in consultation with the Environmental Specialist. This sampling should coincide with the periodic inspections. The results of air sampling shall be included in the O&M Program files for the James H. Quillen Veterans Administration Medical Center, with copies forwarded to the Environmental Specialist.

4.6 Waste Disposal

Asbestos laws require that an abatement contractor handle, transport, and dispose of all asbestos-contaminated waste materials in a manner that prevents all visible emissions and that do not expose individuals to asbestos fibers in air above specified levels. Along with the actual asbestos-containing material removed during O&M activities, other materials usually must be disposed of as contaminated waste as well.

All asbestos wastes must be carefully placed in 6-mil polyethylene bags that have pre-printed asbestos warning labels affixed to the bags. The bag shall be sealed airtight with duct tape or a metal twist band, and placed inside another clean-labeled 6-mil waste bag, which is then sealed in the same way.

Asbestos waste products will be disposed of in accordance with all federal, State of Tennessee, and local regulations. Waste material will be transported in accordance

4 – 5 with all applicable regulations of the U.S. Department of Transportation. Disposal must occur at an authorized disposal site in accordance with regulatory requirements of NESHAP and applicable regulations of the state and locality where the disposal site is located. As a general rule, asbestos waste is disposed of at a licensed landfill specified for asbestos waste disposal (sometimes called a monofill).

4.7 Recordkeeping

The Asbestos Program Coordinator is responsible for assuring all records and documentation required in this O&M Program is maintained at the property.

Documentation includes, but is not limited to:

Periodic surveillance activity reports and documentation, to include photographs and air sampling results, as applicable.

Bulk-sampling data generated from routine or special surveys.

Records of personnel receiving asbestos awareness training.

Asbestos Maintenance Closure Forms. At the completion of any asbestos abatement work (removal, enclosure, encapsulation, or repair) or after a fiber release episode, the asbestos abatement company supervisor or industrial hygienist overseeing the work must complete an Asbestos Maintenance Closure Form (see Appendix C). The purpose of the form is to provide documentation of abatement activities.

Periodic Surveillance Summary Sheets. See Section 4.4 for periodic surveillance requirements and Appendix C for a copy of the blank Periodic Surveillance Summary Sheet and an example of a properly completed Summary Sheet.

All tenant inquiries and responses thereto.

This O&M Program and updates thereto.

Documentation of all inquiries about locations of ACBM within the property or other aspects of the O&M Program on a log book form. The log book form is designed to record pertinent information about persons who inquire about the O&M Program. Only persons with a need to know; e.g., tenants, contractors, and visitors, will be permitted to examine the O&M Program documentation.

A representative of Management must be present at all times while the documentation is being examined. Under no circumstances will persons be permitted to take documents or make copies of the O&M Program documents. The Company representative will record on the logbook forms all documents the requester has inspected.

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Company memoranda and correspondence that pertain to the O&M Program.

A recordkeeping system has been developed and its contents are listed in Appendix C. To assure uniformity, this system alone must be used to organize records required by the O&M Program.

All asbestos records shall be retained indefinitely. Although current legal mandates do not require that all asbestos records be retained indefinitely, long-term retention is nonetheless required by this policy. Existing law does require that communications by the Building Owner and receipt by the Owner of information regarding the identification, location, and quantity of known or presumed asbestos-containing materials, as well as written records of such notifications and their content, be maintained for the duration of ownership of the property, and shall be transferred to successive owners.

4.8 Contractor Notification

All contract work, including that done for commercial tenants, is cleared through the Asbestos Coordinator before work begins. Having all contract work funneled through this person assures that appropriate notification is accomplished of the locations of asbestos-containing materials, thereby avoiding accidental disturbance of asbestos.

Despite this safeguard, possibilities still exists that a contractor who has not been briefed on the location of asbestos on the property could gain access to asbestos materials, and therefore, potentially disturb them. This is most likely to happen with contractors who have been operating on the property for years and thus are considered as an extension of property staff.

Further, it might occur if the Asbestos Coordinator merely limits the briefing about the whereabouts of asbestos to locations where the contractor is expected to work, as opposed to throughout the entire property. Briefing the contractor on asbestos throughout the property is crucial, since contractor duties often take them out of their immediate work zones unexpectedly.

Contractors shall be informed by the Asbestos Coordinator of the locations of asbestos on the property by means of the “Contractor Notification Letter” in Appendix G. The letter itself does not specify where asbestos is located. The Asbestos Coordinator may accomplish this in one of two ways: (1) allow the contractor to review the asbestos survey report and this O&M Manual, or (2) distribute to the contractor a copy of Section 5 of this Manual. As a reminder, if asbestos documentation is reviewed as in (1) above, O&M procedures require that the contractor sign the log book form.

The correspondence requires a signature from an authorized representative of the contractor. The contractor then is to return the letter to the Asbestos Coordinator for filing in the “James H. Quillen Veterans Administration Medical Center” O&M files.

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Some contractors may not return the signed form or, worse, may decline to do so. A reasonable effort should be made to obtain the proper signature. If that effort fails, consideration should be given to discontinuing use of that contractor for any future work on the property.

All verbal briefings given to contractors about asbestos must also be documented to include who performed the briefing, what was said, who received the briefing, that person’s or those persons’ job title/s, and the date the briefing was held. An authorized representative of the contractor must sign the documentation verifying that he/she received this information.

4.9 Tenant Notification

Federal law requires tenant notification if work is done in commercial tenant space that will disturb asbestos. Notification may be accomplished with a specially crafted letter or by means of the “Tenant Work Notification Letter” shown in Appendix G. If the Tenant Work Notification Letter is used, the appropriate portion of Section 5 of this O&M Manual must be attached.

Current law confers no obligation on the part of Property Owners or Managers to notify residential tenants of the location of all asbestos-containing materials or presumed asbestos-containing materials on the property. However, should Management choose to do that, a sample “Blanket Tenant Notification Letter” is provided for the purpose in Appendix G.

This letter does not ask for a signature from the tenant verifying that the tenant has received information on where ACM/PACM is located on the property. You may wish to change the letter to request a signature, for when a tenant returns a signed copy of the letter for inclusion in the “James H. Quillen Veterans Administration Medical Center” O&M file. Some tenants may not return the letter. If you think obtaining such a signature may be difficult, you may wish instead to send the Blanket Tenant Notification Letter by registered mail to the official contact person for each commercial tenant. The return receipt then becomes your proof that the letter was sent.

All tenant correspondence must be documented and retained in the on-site O&M file. Management may wish to retain copies of individual tenant correspondence in the individual tenant’s general file as well.

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5.0 INVENTORY OF ACBM ON THE PROPERTY

A number of materials on the property contain asbestos. Section 5.1 identifies locations of the materials, describes their friability, and provides direction on periodic surveillance and labeling. The preventive measures and response actions detail procedures to prevent the disturbance of ACBM.

The locations and information pertaining to the asbestos-containing materials identified in this Operations and Maintenance Program are based upon a review of the following documents:

Asbestos-Containing Materials Inspection Report, dated November 24, 2009, prepared by EFI Global, Inc.

EFI has not verified the findings of this report (by confirmatory bulk sampling of existing building materials) and therefore EFI is not responsible for the validity of previous information or this O&M Plan which has been based upon prior documentation.

Appendix B outlines procedures for cleaning if friable asbestos-containing materials are damaged. Specific O&M procedures for the repair and maintenance of additional types of ACBM are found in Appendix H. A more complete list of O&M Work Practices can be found in a publication from the National Institute of Building Sciences called Guidance Manual:

Asbestos Operations and Maintenance Work Practices, September 1992.

The procedures outlined in Appendix B and Appendix H have been developed only to provide guidance to the Asbestos Program Coordinator and Engineering Staff when consulting with asbestos abatement personnel, who would perform all work on ACBM within the property. The Department of Veterans Affairs policy prohibits employees from performing these procedures. In rare instances, waivers to this policy may be obtained.

Consult EFI Global, Inc. for details.

5.1 Material Type, Friability, Locations, Preventive Measures, and

Recommendations for ACBM

MATERIAL TYPE: Surfacing Materials

FRIABLE OR NONFRIABLE: Friable DESCRIPTION: Wall and ceiling plaster.

LOCATION: Building 45 – throughout building.

FRIABLE OR NONFRIABLE: Non-friable

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DESCRIPTION: Joint compound and associated sheetrock. The sheetrock should be considered inseparable from the asbestos-containing joint compound and therefore treated as ACM.

LOCATION: Building 47 - throughout building.

RECOMMENDATIONS AND PREVENTIVE MEASURES:

Repair or removal of this material must be performed by qualified personnel. This material might be present elsewhere in the facility.

PERIODIC SURVEILLANCE: See Section 4.4 LABELING: See Section 4.1 RESTRICTED ACTIVITIES: Engineering staff must avoid activities that will damage material.

Do NOT cut, saw, sand, abrade, or drill through the material.

Do NOT damage intact material.

Do NOT use an ordinary vacuum or dry sweeper to clean up debris.

Do NOT cause or create excessive air movement.

MATERIAL TYPE: Thermal System Insulation

DESCRIPTION: White pipe insulation.

LOCATION: Building 8 – limited quantities were observed in

Room 23, Men’s Locker Room, Medical Library, Room 230, 3rd Floor Women’s Restroom, Room 321, Room 003, and near Room 129.

DESCRIPTION: Brown pipe insulation.

LOCATION: Building 8 - Men’s Locker Room.

FRIABLE OR NONFRIABLE: Friable DESCRIPTION: Pipe insulation (December 2005 sampling report.)

LOCATION: Building 17 - Attic.

FRIABLE OR NONFRIABLE: Friable DESCRIPTION: Pipe insulation.

LOCATION: Building 20 – Basement and exterior of the building.

5 – 3

DESCRIPTION: Fibrous insulation.

LOCATION: Building 36 – inside Main Basement Area wall chase.

FRIABLE OR NONFRIABLE: Friable DESCRIPTION: Pipe insulation.

LOCATION: Building 37 – within the building in various pipe chases and in very small quantities at dividing walls.

DESCRIPTION: Pipe insulation.

LOCATION: Building 69 – throughout Basement and Attic.

RECOMMENDATIONS AND PREVENTIVE MEASURES:

Repair or removal of these materials must be performed by qualified personnel.

These materials may be present elsewhere in the facility. If the materials are presumed to contain asbestos, sampling to confirm the asbestos content should take place by EPA certified asbestos inspectors before the material is disturbed.

The analysis should be performed by an accredited laboratory using Polarized Light Microscopy.

PERIODIC SURVEILLANCE: See Section 4.4 LABELING: See Section 4.1 RESTRICTED ACTIVITIES: Engineering staff must avoid activities that will damage Thermal System Insulation.

Do NOT use an ordinary vacuum or dry sweeper to clean up debris.

Do NOT cause or create excessive air movement.

MATERIAL TYPE: Miscellaneous

DESCRIPTION: Gray/green 9”x9” vinyl floor tile.

LOCATION: Building 2 - throughout Basement.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Brown 9”x9” vinyl floor tile.

LOCATION: Building 13 – rooms off of the Chapel.

5 – 4

DESCRIPTION: Gray/green vinyl floor tile.

LOCATION: Building 13 – rooms off of the Chapel.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: White, green, white, and gray vinyl floor tiles.

LOCATION: Building 20 – throughout the 1st and 2nd Floors.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: White vinyl floor tile.

LOCATION: Building 34 – Museum.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Brown vinyl floor tile.

LOCATION: Building 34 – Basement in the S-corridor and

HVAC storage.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Red vinyl floor tile.

LOCATION: Building 34 – Basement in HVAC storage and the Tin Shop.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Grey vinyl floor tile.

LOCATION: Building 34 – HVAC Shop Storage.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Beige vinyl floor tile.

LOCATION: Building 34 – Basement Canteen and Food

Storage.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Blue vinyl floor tile.

LOCATION: Building 36 – 1st Floor Storage Room.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: 12”x12” off-white vinyl floor tile.

LOCATION: Building 39 – Left Kitchen.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: 9’x9” green vinyl floor tile.

LOCATION: Building 39 – Left Kitchen and Left Porch (below

12”x12” off-white vinyl floor tile.)

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Grey vinyl floor tile.

LOCATION: Building 40 – Left Kitchen.

5 – 5

DESCRIPTION: Vinyl floor tile (presumed.)

LOCATION: Building 40 – Right Kitchen.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: 12”x12” beige with brown vinyl floor tile.

LOCATION: Building 41 – Left Kitchen.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Grey vinyl floor tile.

LOCATION: Building 41 – Right Kitchen.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: 12”x12” light beige vinyl floor tile and associated mastic.

LOCATION: Building 42 – Right Kitchen.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: 12”x12” grey/green vinyl floor tile and associated mastic.

LOCATION: Building 42 – Right Rear Porch.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: 9”x9” green vinyl floor tile.

LOCATION: Building 43 – Left Kitchen.

DESCRIPTION: Tan vinyl floor tile.

LOCATION: Building 44 – Basement Bathroom.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Green vinyl floor tile.

LOCATION: Building 45 – Bathroom and Kitchen.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Green vinyl floor tile and associated mastic.

LOCATION: Building 46 – Kitchen (bottom layer.)

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Grey/green vinyl floor tile.

LOCATION: Building 46 – 2nd Floor Bathroom.

DESCRIPTION: Green vinyl floor tile and associated mastic.

LOCATION: Building 47 – 1st and 2nd Floor Bathrooms.

5 – 6

DESCRIPTION: Tan vinyl floor tile.

LOCATION: Building 69 – throughout building.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Green vinyl floor tile.

LOCATION: Building 69 – Basement.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Beige vinyl floor tile.

LOCATION: Building 69 – Rooms H114, H115b and 117.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Grey vinyl floor tile.

LOCATION: Building 69 – Room H102A and 2nd Floor Lobby.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Tan vinyl floor tile.

LOCATION: Building 77 – throughout building.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Beige vinyl floor tile.

LOCATION: Building 77 – throughout building.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Brown vinyl floor tile.

LOCATION: Building 77 – throughout building.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Stair cover mastic.

LOCATION: Building 13 – Chapel.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Brown vinyl flooring.

LOCATION: Building 15 – Laundry Room, Bathroom, Kitchen, and North Bathroom.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Green sheet flooring.

LOCATION: Building 40 – Left Porch.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Sheet flooring (presumed.)

LOCATION: Building 40 – Right Porch.

5 – 7

DESCRIPTION: Tan sheet flooring.

LOCATION: Building 42 – Left Kitchen.

DESCRIPTION: Tan/orange sheet flooring.

LOCATION: Building 43 – Right Kitchen (3rd layer of sheet flooring.)

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Tan sheet flooring.

LOCATION: Building 44 – Upper Bathroom.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Brown sheet flooring and associated mastic.

LOCATION: Building 45 – Bathroom.

DESCRIPTION: Beige sheet flooring.

LOCATION: Building 45 – Breakfast Room.

DESCRIPTION: Tan granular flooring.

LOCATION: Building 77 – throughout building.

DESCRIPTION: Black flooring mastic.

LOCATION: Building 77 – throughout building.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Exterior window caulking.

LOCATION: Building 8 - throughout building exterior.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Exterior window glazing.

LOCATION: Building 15 - throughout building exterior.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Exterior building caulking.

LOCATION: Building 17 – front of building exterior.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Exterior window glazing.

LOCATION: Building 39 – throughout building exterior.

5 – 8

DESCRIPTION: Exterior window glazing.

LOCATION: Building 41 – throughout building exterior.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: HVAC duct cloth.

LOCATION: Building 8 - Room 003A and Room 321.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: HVAC duct cloth.

LOCATION: Building 19 – Basement Storage Area.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: HVAC duct paper.

LOCATION: Building 44 – Basement Stairwell.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: HVAC duct cloth.

LOCATION: Building 45 – Basement.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: HVAC duct cloth.

LOCATION: Building 46 – Basement.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: HVAC duct cloth.

LOCATION: Building 47 – Basement.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Pipe insulation mastic.

LOCATION: Building 8 - Room 21.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Electrical box partitions.

LOCATION: Building 17 - Hall outside the Men’s Room.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Textured wall paint applied to plaster walls.

LOCATION: Building 20 – throughout building.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Sink undercoating/mastic.

LOCATION: Building 39 - Kitchens.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Sink undercoating/mastic.

LOCATION: Building 40 - Left kitchen.

5 – 9

DESCRIPTION: Sink undercoating/mastic (presumed.)

LOCATION: Building 40 - Right Kitchen.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Sink undercoating/mastic.

LOCATION: Building 41 - Kitchens.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Sink undercoating/mastic.

LOCATION: Building 42 - Kitchens.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Sink undercoating/mastic.

LOCATION: Building 43 - Kitchens.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Silver porch roofing material.

LOCATION: Building 46 – Porch.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Roofing materials (presumed.)

LOCATION: Buildings 2, 8, 13, 15, 17, 19, 20, 34, 36, 37, 39, 40, 41, 42, 43, 44, 45, 46, 69, 69, and 77 – Roofs.

DESCRIPTION: Fire doors (presumed.)

LOCATION: Buildings 8, 34, 36, 69, and 77 - throughout.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Elevator Doors (presumed.)

LOCATION: Buildings 8, 34, 36, 37, 69, and 77 - throughout.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Elevator brake shoes.

LOCATION: Building 36 – elevators throughout building.

FRIABLE OR NONFRIABLE: Non-friable DESCRIPTION: Mechanical gaskets (presumed.)

LOCATION: Buildings 2 (basement only), 8, 34, 37, 69, and

77 - HVAC equipment (including piping, valves, and duct work) and other building equipment throughout the buildings.

RECOMMENDATIONS AND PREVENTIVE MEASURES:

5 – 10

These materials may be present elsewhere in the facility, especially under carpeting (as applicable for floor tile and related…