Asbestos Report.pdf

LIMITED

ASBESTOS INVESTIGATION REPORT

for

Veterans Healthcare Systems of the Ozarks Central Boiler Plant Building 10

1100 N. College Avenue Fayetteville, Arkansas 72703

PROJECT NO. 18-0111-076

Prepared for:

Mr. Bill Holden Miller-Remick, LLC 1010 Kings Highway South Cherry Hill, New Jersey 08034

August 15, 2018

Prepared for

Mr. Bill Holden Miller-Remick, LLC

1010 Kings Highway South Cherry Hill, New Jersey 08034

The following pages of this Limited Asbestos Investigation report have been prepared for the exclusive use of Miller-Remick, LLC at the request of Mr. Bill Holden. The property surveyed is described as Veterans Healthcare Systems of the Ozarks Central Boiler Plant Building located at 1100 N. College Avenue in Fayetteville, Arkansas.

Performed by:

8/15/18 Mr. Bob E. Smith (ADEQ #011927) Environmental Professional/Asbestos Inspector Environmental Enterprise Group, Inc. (EEG)

Date

Senior Review:

8/15/18 Mr. Bob E. Smith Vice President/Senior Project Manager Environmental Enterprise Group, Inc. (EEG)

Date

TABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY

1.1 INTRODUCTION

1.2 BUILDING DESCRIPTION

1.3 FINDINGS

2.0 MATERIAL ASSESSMENT & RECOMMENDATIONS

2.1 ASBESTOS CONTAINING MATERIALS

3.0 ESTIMATED COST FOR REMOVAL

3.1 ASSUMED ASBESTOS CONTAINING MATERIALS

3.2 MATERIALS SAMPLED, ANALYZED AND FOUND TO BE NON-ASBESTOS CONTAINING MATERIALS

3.3 BUILDINGS/AREAS ASSESSED BUT WITH NO SUSPECT MATERIALS

3.4 MATERIALS CONSIDERED TO BE NON-SUSPECT BY USEPA

4.0 METHODOLOGY

4.1 HOMOGENEOUS AREAS

4.2 INSPECTION AND SAMPLING

4.2.1 Inspection Methods

4.2.2 Sampling Strategies

4.2.3 Sampling Procedures

4.2.4 Chain of Custody Procedures

4.3 ASSESSMENT LOGIC

4.3.1 Priority Level Determination

4.3.2 Priority Level Interpretation

APPENDICES

Photographs

Analytical Results

Asbestos Background Information

Decision Logic Flow Chart for Hazard Assessments

Laboratory QA/QC Procedures for Bulk Analysis

Inspector Certificates

LTD. ASBESTOS INVESTIGATION VA - CENTRAL BOILER PLANT BUILDING FAYETTEVILLE, AR

EEG PROJECT #18-0111-076

E n v i r o n m e n t a l E n t e r p r i s e G r o u p , I n c .

1.0 EXECUTIVE SUMMARY

1.1 INTRODUCTION

ENVIRONMENTAL ENTERPRISE GROUP, INC. (EEG) (Arkansas Department of Environmental Quality (ADEQ) Asbestos Abatement Consultant Certification No. 000234) was retained by Miller- Remick, LLC to conduct a limited inspection for suspect asbestos-containing materials (ACM) at the above-referenced property located in Fayetteville, Arkansas. The inspection included the assessment of suspect friable and non-friable ACM.

The purpose of this limited survey was to locate, identify, sample and assess the condition of accessible materials found throughout the interior of the Central Boiler Plant Building 10 at the Veterans Healthcare Systems of the Ozarks facility at 1100 N. College Avenue located in Fayetteville, Arkansas, that were suspected of containing more than one percent (1%) asbestos. The investigation took place at the request of Mr. Bill Holden of Miller-Remick, LLC and was conducted by Bob E. Smith, Environmental Professional/Asbestos Inspector, Certification No. 011927, on July 11, 2018. The inspection was limited as no roofing was inspected at the request of the client.

In order to ensure a safe and healthy work environment, Federal, State and local regulations require that ACM be identified and controlled. This asbestos investigation report provides the basis for an Operations and Maintenance (O&M) Plan.

1.2 BUILDING DESCRIPTION

The VA Central Boiler Plant Building, built in 1934-35, contains approximately 2,774 square feet and is constructed of masonry with brick exterior walls. The interior walls are concrete, block and brick. The building sits on a concrete foundation.

1.3 FINDINGS

As suspect ACM was identified, they were classified as either friable or non-friable. Friable materials are more hazardous than non-friable materials because they are more likely to release fibers into the air. In assessing the fiber release potential, the current condition of all ACM was noted. Evidence of deterioration, physical or water damage and the potential for future disturbance were taken into consideration. The potential of erosion of the ACM due to air disturbance, high vibration or contact was also noted. Please see photos of asbestos-containing materials in the appendix.

The following materials were found to be asbestos containing and were present at the facility in the listed quantities and locations:

Sample Group *HA Material Description Sample Location Friable/

Non-Friable Quantity Condition **Category 1/2

VA10-9G 9 Wall Penetration Pump Room, Lower Level, NW Exterior

Wall

Friable 1 Good NA

VA10-6G 6 Ceiling Penetrations Pump Room, Lower Level, East Side

Friable 4 Good NA

NA NA Remnant Flooring Mastic under Non-ACM

Floor Tile

NA Non-Friable 630 ft2 Good 1

Assumed NA Inaccessible Interior Components

Inside Incinerator Unknown 50 CY Good NA

*HA = Homogeneous Area ** Category 1 Non-Friable ACM: Asbestos-containing packings, gaskets, resilient floor covering and asphalt roofing products containing more than one percent asbestos as determined using the method specified in Appendix E, Subpart E, 40 CRF Part 763, Section 1, Polarized Light Microscopy.

Category 2 Non-Friable ACM: Any material, excluding Category 1non-friable ACM, containing more than one percent asbestos as determined using the methods specified in Appendix E, Subpart E, 40 CRF Part 763, Section 1, Polarized Light Microscopy that, when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure.

EEG recommends that the ACM identified in good condition should be placed in an O&M plan that specifies preventative measures to avoid disturbance and potential for damage. ACM in damaged condition should be removed or repaired in accordance with local, state and federal regulations. In the event of renovation or demolition of any ACM materials, removal shall be in accordance with local, state and federal regulations.

It is important to note that non-friable materials may become friable when being removed or demolished. The condition of these materials must be monitored when they are being disturbed. In the event that non-friable asbestos containing materials become friable during removal or demolition, there may be regulatory issues that must be addressed.

2.0 MATERIAL ASSESSMENT & RECOMMENDATIONS

2.1 ASBESTOS CONTAINING MATERIALS

As a result of the inspection conducted by EEG, the following materials were classified as asbestos-containing. EEG has made recommendations regarding each positive material in accordance with the AHERA guidelines (see Section 4.3).

HA: 9 Material Description: Wall Penetration

Material is located on the northwest exterior wall of the lower level of the pump room.

The material is a friable, TSI material and is in good condition.

EEG recommends that the material be identified in an O&M Plan that specifies preventative measures to avoid disturbance and potential for damage. In the event of repair, removal or demolition of systems that contain asbestos-containing materials, removal shall be in accordance with local, state and federal regulations.

HA: 6 Material Description: Ceiling Penetrations

Material is located on the east side of the lower level of the pump room.

The material is a friable, TSI material and is in good condition.

EEG recommends that the material be identified in an O&M Plan that specifies preventative measures to avoid disturbance and potential for damage. In the event of repair, removal or

HA: NA Material Description: Remnant Flooring Mastic under Non-

ACM Floor Tile

Material is located under non-ACM floor tile on the mezzanine level of the pump room.

The material is a non-friable, miscellaneous material and is in good condition.

EEG recommends that the material be identified in an O&M Plan that specifies preventative measures to avoid disturbance and potential for damage. In the event of repair, removal or

HA: NA Material Description: Inaccessible Interior Components

Material is located inside the incinerator.

The material is a TSI material and is in good condition. Friability is unknown.

EEG recommends that the material be identified in an O&M Plan that specifies preventative measures to avoid disturbance and potential for damage. In the event of repair, removal or

3.0 ESTIMATED COST FOR REMOVAL

Sample Group *HA Material Location Quantity Estimated

Removal Cost

VA10-9G 9 Wall Penetration Pump Room, Lower Level, NW Exterior Wall

1 $ 3,500.00

VA10-6G 6 Ceiling Penetrations Pump Room, Lower Level, East Side

4 $ 5,500.00

NA NA Remnant Flooring Mastic under Non-ACM Floor Tile

Pump Room, Mezzanine Level 630 ft2 $15,000.00

Assumed NA Inaccessible Interior Components

Inside Incinerator 50 CY $ 30,000.00

**Estimated Removal Cost $54,000.00

*HA = Homogeneous Area **Total Estimated Removal Cost is based on all asbestos-containing materials being removed at the same time.

Estimated Total Removal Cost does not include project management and air monitoring consultant fees.

It is important to note that non-friable materials may become friable when being removed or demolished.

The condition of these materials must be monitored when they are being disturbed. In the event that non-friable asbestos containing materials become friable during removal or demolition, there may be regulatory issues that must be addressed.

3.1 ASSUMED ASBESTOS CONTAINING MATERIALS

All suspect materials identified were sampled with the exception of materials inside the incinerator.

Any suspect materials located inside the incinerator should be assumed to be asbestos containing until proven otherwise by analysis via Polarized Light Microscopy (PLM) method.

3.2 MATERIALS SAMPLED, ANALYZED AND FOUND TO BE NON-ASBESTOS CONTAINING

MATERIALS

The following samples, found in the Veterans Healthcare Systems of the Ozarks Central Boiler Plant Building, were suspected of being asbestos-containing, but sampling and analytical testing showed asbestos concentrations of less than or equal to one percent (1%). These materials are:

MATERIAL SAMPLE LOCATION

Pipe Mastic on Fiberglass Pump Room & Boiler Room

Window Glazing Interior of Exterior Window

Wall Paint (Off White, Blue & Gray) Boiler Room – Level 1 & Pump Room – Level 1

Wall Paint (Gray, Tan, Blue & White) Stairs to Mezzanine & Mezzanine

3.3 BUILDINGS/AREAS ASSESSED BUT WITH NO SUSPECT MATERIALS

All areas of the Veterans Healthcare Systems of the Ozarks Central Boiler Plant Building were assessed for suspect asbestos-containing materials.

3.4 MATERIALS CONSIDERED TO BE NON-SUSPECT BY USEPA

Concrete Slab Walls and Concrete Roofing Brick on Walls and Floors Wood Structures and Beams Ceramic Tiles on Floors and Walls Fiberglass Bat Insulation Panels Carpet Fiberglass Pipe Insulation Wood Paneling Fiberglass Tank Insulation Epoxy Flooring Material Fiberglass Wall Insulation Synthetic Glass Block Pipe Insulation Cinder Block Walls Fiberglass and Metal HVAC Ductwork Non-Insulated Piping Steel and Sheet Metal Storage Buildings Sheet Metal Ceilings and Walls Steel and Sheet Metal Storage Tanks

4.0 METHODOLOGY

Asbestos is a naturally occurring fibrous mineral that has many beneficial properties. It is resistant to acids and heat and does not conduct electricity or heat well. It is because of these features that it was widely used in buildings constructed prior to 1975. Asbestos was used in over 3,000 types of construction materials.

The Asbestos Hazard and Emergency Response Act (AHERA) is a Federal law that describes standard methods for asbestos inspections. The AHERA addresses the hazard of asbestos in schools and grants no jurisdictional powers to any branch of government for the regulation of asbestos in any facility other than a school. This asbestos investigation satisfies the inspection requirements outlined in the Occupational Safety and Health Administration (OSHA) 29 CFR 1910.1001 and 1926.1101. An Operations and Maintenance (O&M) Plan will be implemented from this asbestos investigation. This asbestos investigation also satisfies requirements specified under the Environmental Protection Agency (EPA) National Emission Standards for Hazardous Air Pollutants (NESHAPS) 40 CFR Part 61 that states a survey must be performed identifying friable and non-friable ACM in a building prior to renovation or demolition. However, you may elect to collect and analyze additional samples of affected materials at the time of renovation or demolition.

4.1 HOMOGENEOUS AREAS

The site was inspected for the presence of materials that may contain asbestos. These materials were then described and categorized by homogeneous area (HA). The AHERA defines "homogeneous area" as an area of surfacing material, thermal system insulation material or miscellaneous material that is uniform in color, texture and date of material application. During the building inspection, the inspector classifies all materials by "homogeneous area." Homogeneous area might be better understood as a homogeneous material, since there is no requirement that a homogeneous area be contiguous or continuous. An example of this might be a building that has a single type of floor tile.

All floor tile in the building would be considered a single "homogeneous area" regardless of where it is located because it is uniform in color, texture and date of material application.

4.2 INSPECTION AND SAMPLING

4.2.1 Inspection Methods

The building inspection was performed as follows:

1. A visual determination of the quantity and condition of suspect materials in the facility.

2. A physical "hand pressure" test for determining the condition of suspect materials.

3. Sampling and documentation of observable suspect materials according to EPA guidelines.

4. Measurement of all observable material sampled to determine the quantity existing within the facility. The quantity is determined by a visual inspection and/or by blueprint examination.

4.2.2 Sampling Strategies

1. As much as possible, sampling was conducted in unoccupied areas such as mechanical rooms, pipe chases and closets.

2. Samples of each material were collected according to material type, color and texture. If a suspect material such as corrugated pipe covering was found in an unoccupied area on a floor, those samples were used to represent the material throughout the building as long as the appearance did not change.

3. In a general assessment, pipe covering and mudded joint packings are sampled and measured as homogeneous material unless otherwise noted. Each homogeneous material was randomly sampled three times. When different suspect asbestos-containing thermal insulation was identified, three additional random samples of the homogeneous material were collected.

4. In this assessment, three composite samples were collected of all non-homogeneous materials or materials where asbestos was not easily identifiable such as:

mudded joint fittings, especially those on fiberglass-insulated lines mudded packings on boilers, tanks, breechings, or ducts

5. Sampling was generally the last thing performed in each area after pressure testing, measuring, assigning sample numbers and evaluating the priority level.

6. All cementitious and miscellaneous suspect materials were sampled and noted as to location and quantity.

4.2.3 Sampling Procedures

The bulk samples were obtained with a stainless steel coring tool or knife designed to make clean cores of friable material to avoid creating excessive dust. The area was pre-wetted to reduce fiber generation during the sampling process. The coring tool or knife was used rather than scratching a sample from the surface of the suspect material in an effort to obtain a sample that was representative of all layers of the material.

Samples of materials such as ceiling tile, wallboard, floor tile, etc., are generally obtained with a utility knife. Frequently, a small, broken piece of these materials can be found and used as a sample.

4.2.4 Chain of Custody Procedures

A copy of the chain of custody that accompanied the samples is supplied in the Analytical Results Appendix. The inspector filled out the chain of custody form after all samples were collected and before the samples were shipped to the laboratory. When the laboratory received the samples, the chain of custody was transferred to the laboratory.

4.3 ASSESSMENT LOGIC

4.3.1 Priority Level Determination

As a result of the inspection and laboratory analysis of the bulk samples collected, EEG has generated a priority level for ACM that follows AHERA guidelines. The AHERA guidelines recognize seven levels of hazard associated with asbestos based on six primary variables:

material condition; water damage; exposed surface area; accessibility; activity/movement;

and air plenum/direct air stream.

Material condition refers to the condition of the material at the time of the inspection.

Factors included are the quality of installation, adhesion of the material to the underlying substrate, deterioration of the outer covering, de-lamination, contact damage and material disintegration.

Water damage relates to the potential for water to dislodge, delaminate and disturb materials.

Water damage weakens the binding matrix of the material and can carry fibers in a slurry to other areas of the building where they can become airborne.

The exposed surface area of friable material has an effect on potential fiber fallout levels and the possibility for contact and damage. A useful criterion in determining exposed surface areas is visibility of the friable asbestos material. Materials usually fall into one of the following categories: out in the open (fully exposed); above or behind a semi-permanent enclosure such as a wall, ceiling, or floor; and above or behind a permanent enclosure. Areas with louvers, grids or other open ceiling systems are considered exposed.

Accessibility of the material is a function of proximity. If the material can be reached, it is accessible and subject to accidental or intentional contact damage.

In the variable of activity and movement, occupancy and mechanical vibrations are two important factors to consider. High-occupancy areas are subject to more vibration from noise and physical movement; therefore, a greater ambient fiber release can be expected.

This variable also plays an important role in determining abatement priority. Mechanical vibrations, especially in boiler mechanical rooms, not only create ongoing ambient fiber release, but when the system is turned on or off there is a sudden burst of mechanical and air movement that creates a brief peak exposure.

The category of air plenum/direct air stream refers to potential or existing air movement.

A direct air stream moving across the material erodes the material, thereby releasing fibers into the air. If the area in question forms a supply air plenum, there is usually increased exposure to building occupants since the contaminated air is blown directly into rooms of the building. Return air plenums do not create quite as high an exposure potential as supply air plenums, but do contribute to the exposure of maintenance and mechanical workers accessing these areas. A value is given to this variable if there is a real or potential air stream at the time of the inspection. A fan, present but not in use at the time of the survey, is an example of a potential air stream.

Two sub-variables are asbestos content and friability. Friability is the ease with which material can be crumbled, pulverized or reduced to powder when dry, by hand pressure.

The more friable the material, the greater the potential is for fiber release and contamination.

The asbestos content is factored based on the analytical results of samples from a homogeneous sampling area. Materials with a high percentage of asbestos contain more fibers for potential release and contamination of the building.

The Decision Logic Flow Chart for Hazard Assessments, located in the appendix section of this report, shows the decision logic used to classify ACM by AHERA guidelines.

4.3.2 Priority Level Interpretation

High Priority materials are generally those that have been severely damaged. Removal is the corrective action suggested for most High Priority materials. Removal is the only permanent solution to asbestos-related problems.

Moderate Priority materials have a lower exposure potential than High Priority materials.

However, they still represent a significant exposure potential. EEG recommends implementing a corrective action plan to reduce the high exposure potentials that exist in these areas. Depending on the funds available, the corrective action plan may involve complete removal, or selective removal in conjunction with the cleaning up of debris that may exist and the repair of any damaged areas. Removal also eliminates future exposure incidents that may cause the building owners to incur additional liability. Any past liability the building owner has incurred as a result of an occupant's exposure to ACM will not be altered.

Low Priority materials either have a low friability or are located in inaccessible areas and are not expected to create a serious or immediate exposure potential. However, as materials deteriorate with time, a corrective action plan should be devised to minimize future asbestos exposure potential. The most effective means of reducing deterioration and accidental disturbance of ACM is the development of an Operations and Maintenance (O&M) Program. This is an interim control measure designed to train custodial and maintenance personnel, establish emergency abatement and control procedures, develop a periodic program to re-inspect the materials, and to provide the necessary supplies and equipment to perform these tasks.

Non-friable building materials do not create the potential for asbestos exposure unless they are sawed, broken, ripped or pulverized. However, even materials that are well wrapped and technically non-friable at the time of inspection have the potential to become friable very readily by accidental tearing or other disturbance (e.g., water damage, grinding, drilling, sawing, etc.). This report addresses friable and potentially friable materials.

The Decision Logic Flow Chart for Hazard Assessments, located in the appendix section of this report, shows the priority level associated with each hazard level using AHERA guidelines. The chart also shows the action recommended for each hazard level.

APPENDICES

Photographs

Building 10

ACM Wall Penetration

VETERANS HEALTHCARE SYSTEM

OF THE OZARKS

CENTRAL BOILER PLANT BUILDING

FAYETTEVILLE, ARKANSAS

EEG Project #18-0111-076 www.eegonline.com

ACM Ceiling Penetrations

ACM Black Mastic under Non-ACM Floor Tile

Assumed ACM Inaccessible Interior Incinerator Components

Analytical Results

Asbestos Background Information

Background Information

ASBESTOS

The Asbestos Issue

Asbestos fibers can cause serious health problems. If inhaled, they can cause diseases that disrupt the normal functioning of the lungs. Three specific diseases-asbestosis (a fibrous scarring of the lungs), lung cancer, and mesothelioma (a cancer of the lining of the chest or abdominal cavity) have been linked to asbestos exposure. These diseases do not develop immediately after inhalation of asbestos fibers; it may be 20 years or more before symptoms appear.

In general, as with cigarette smoking and the inhalation of tobacco smoke, the more asbestos fibers a person inhales, the greater the risk of developing an asbestos-related disease. Most of the cases of severe health problems resulting from asbestos exposure have been experienced by workers who held jobs in industries such as shipbuilding, mining, milling, and fabricating, where they were exposed to very high levels of asbestos in the air, without benefit of the worker protections now afforded by law. Many of these same workers were also smokers. These employees worked directly with asbestos materials on a regular basis and, generally, for long periods of time as part of their jobs. Additionally, there is an increasing concern for the health and safety of construction, renovation, and building maintenance personnel, because of possible periodic exposure to elevated levels of asbestos fibers while performing their jobs.

Whenever we discuss the risk posed by asbestos, we must keep in mind that asbestos fibers can be found nearly everywhere in our environment (usually at very low levels). There is, at this time, insufficient information concerning health effects resulting from low-level asbestos exposure, either from exposures in buildings or from our environment. This makes it difficult to accurately assess the magnitude of cancer risk for building occupants, tenants, and building maintenance and custodial workers.

Although in general the risk is likely to be negligible for occupants, health concerns remain, particularly for the building’s custodial and maintenance workers. Their jobs are likely to bring them into close proximity to ACM, and may sometimes require them to disturb the ACM in the performance of maintenance activities.

For these workers in particular, a complete and effective O&M program can greatly reduce asbestos exposure. This kind of O&M program can also minimize asbestos exposures for other building occupants as well.

What is Asbestos?

The term "asbestos" describes six naturally occurring fibrous minerals found in certain types of rock formations. Of that general group, the minerals chrysotile, amosite, and crocidolite have been most commonly used in building products. When mined and processed, asbestos is typically separated into very thin fibers. When these fibers are present in the air, they are normally invisible to the naked eye.

Asbestos fibers are commonly mixed during processing with a material that binds them together so that they can be used in many different products. Because these fibers are so small and light, they may remain in the air for many hours if they are released from ACM in a building. When fibers are released into the air, people in the building may inhale them.

Asbestos became a popular commercial product because it is strong, won’t burn, resists corrosion, and insulates well. In the United States, its commercial use began in the early 1900s and peaked in the period from World War II into the 1970s. Under the Clean Air Act of 1970 the EPA has been regulating many asbestos-containing materials, which by EPA definition, are materials with more than one percent asbestos. The Occupational Safety and Health Administration (OSHA) asbestos construction standard in Section K, "Communication of hazards to employees," specifies labeling many materials containing asbestos. In the mid- 1970s several major kinds of asbestos materials, such as spray-applied insulation, fireproofing, and acoustical surfacing material, were banned by EPA because of growing concern about health effects, particularly cancer, associated with exposures to such materials.

Where is Asbestos Likely to be Found in Buildings?

In February 1988, the EPA released a report titled EPA Study of Asbestos- Containing Materials in Public Buildings: A Report to Congress. EPA found that "friable" (easily crumbled) ACM can be found in an estimated 700,000 public and commercial buildings. About 500,000 of those buildings are believed to contain at least some damaged asbestos, and some areas of significantly damaged ACM can be found in over half of them.

According to the EPA study, significantly damaged ACM is found primarily in building areas not generally accessible to the public, such as boiler and machinery rooms where asbestos exposures generally would be limited to service and maintenance workers. Friable ACM, if present in air plenums, can lead to distribution of the material throughout the building, thereby possibly exposing building occupants. ACM can also be found in other building locations.

Asbestos in buildings has been commonly used for thermal insulation, fireproofing, and in various building materials, such as floor coverings and ceiling tile, cement pipe and sheeting, granular and corrugated paper pipe wrap, and acoustical and decorative treatment for ceilings and walls.

Typically, it is found in pipe and boiler insulation and in spray-applied uses such as fireproofing or sound-deadening applications.

The amount of asbestos in these products varies widely (from approximately 1 percent to nearly 100 percent). The precise amount of asbestos in a product cannot always be accurately determined from labels or by asking the manufacturer. Nor can positive identification of asbestos be ascertained merely by visual examination.

Instead, a qualified laboratory must analyze representative samples of the suspect material.

When is Asbestos a Problem?

Intact and undisturbed asbestos materials do not pose a health risk. The mere presence of asbestos in a building does not mean that the health of building occupants is endangered. ACM that is in good condition, and is not somehow damaged or disturbed, is not likely to release asbestos fibers into the air. When ACM is properly managed, release of asbestos fibers into the air is prevented or minimized, and the risk of asbestos-related disease can be reduced to a negligible level.

However, asbestos materials can become hazardous when, due to damage, disturbance, or deterioration over time, they release fibers into building air. Under these conditions, when ACM is damaged or disturbed-for example, by maintenance repairs conducted without proper controls, elevated airborne asbestos concentrations can create a potential hazard for workers and other building occupants.

Decision Logic Flow Chart for Hazard Assessments

Poor Condition and Any Other Reasons

Damaged or Significantly

Damaged Miscellaneous

ACM

Significantly Damaged Surfacing ACM

Good Condition

Fair Condition and Any Other Reasons

Poor Condition and Any Other Reasons

DE CIS IO N LO G IC F LO WCH ARTDE CIS IO N LO G IC F LO WCH ART

Moderate/High

Slight

Moderate

High

Repair and Operations and Maintenance (O&M) Plan

(Rarely Enclose or Encapsulate)

Repair and O&M or Remove (Rarely Enclose or Encapsulate)

Remove (Always) High

Remove (Always)

Low

Moderate

High

ACM with Potential for Damage Good Condition None/Slight O&M Low

ACM with Potential for Significant Damage Good Condition LowO&MModerate/High

Remaining

ACM

Constant Air Flow

Contaminated Soil

Good Condition

High

High

High

Enclosure

Isolate

Gross Removal

High

High

High

Damage CodesDamage Codes Reasons for DamageReasons for Damage Potential forPotential for DisturbanceDisturbance Response ActionResponse Action

Priority LevelPriority Level InterpretationInterpretation ffor H azard Assessmentsor H azard Assessments

Laboratory QA/QC Procedures for Bulk Analysis

LABORATORY QA/QC PROCEDURES

for Bulk Analysis

Quality Control Checks

Quality control checks are performed on a routine basis to verify the analysis and ensure the quality of the data. The Bulk Quality Control Program represents at least ten percent of all samples analyzed.

Quality control checks include the following:

METHOD

Repeat analysis of the same sample preparation by a different analyst.

METHOD

Re-preparation of the same sample and reanalysis by the same analyst.

METHOD

Re-preparation of the same sample and reanalysis by a different analyst.

Selection of Samples for Reanalysis

There are several ways to select samples for Quality Control reanalysis. The following is a list of resample procedures:

1. Samples received by the client in amounts less than 25 samples or small projects are reserved for a blind reanalysis. Ten percent of these samples are reanalyzed. This reanalysis may include sample Method 2 or 3 depending on who did the original analysis and who is doing the Quality Control Analysis. These samples are selected by the Laboratory Manager or Analyst in a semi-random fashion by selecting every tenth sample in the batch to be reanalyzed.

2. Special projects of samples in amounts greater than 25 samples will be analyzed by repeat analysis (Method 1) and/or reanalysis of the same sample by re-preparation (Method 2).

a. Repeat analysis of the same sample preparation by a different analyst (Method 1) is conducted at the completion of the analysis of the set. Reanalysis of these samples is selected by choosing every tenth slide (which is labeled by a sample number) or choosing a sample that is suspected of containing asbestos but no asbestos was detected. This quality control check is recorded on the original bulk analysis form by dating and initialing the original form in the proper location.

This procedure encourages interaction between analyst;

and any discrepancies are resolved immediately. A copy of the bulk analysis form in which the control check was made is filed in the Quality Control book in the lab.

b. Re-preparation and reanalysis by the same analyst (Method 2). Samples are selected by the original analyst after the analysis is completed from a sample group or project. The original analyst does not have the results of the original analysis. Samples may be selected by choosing every tenth sample in that group or project. The results are reported on a separate bulk analysis form and compared to the original analysis by the Laboratory Manager and tabulated on the QA Sample Analysis log. Any discrepancies are noted and resolved.

Samples that are in the one percent range or samples that are in question by the original analyst are reanalyzed by a second analyst without the knowledge of the first results (Method 3) or by the original analyst (Method 2). The second results are compared to the original results and any discrepancies are resolved.

This Quality Control check is noted on the original bulk analysis form. This method is conducted at the request of the original analyst. If the two analyses are still not completely resolved, the sample is sent to another lab for comparison or sent to the McCrone Research Institute for additional instruction and identification.

Traceable Standards

1. NIST traceable standards are analyzed during the NVLAP testing rounds. Each analyst individually analyzes the samples.

Results of the sample analysis is tabulated on the Monthly QA Bulk Summary Sheet and filed in the laboratory QA files.

2. NIST Standard Reference Material 1866 and 1867A are available in the laboratory as a calibration and training tool.

3. Generated Standard Generated Standards are analyzed periodically by each analyst as a means to calibrate the analysts. These standards are preparations of material with known volume/weight relationship.

Recording QC Results

The Quality Control results are tabulated and reviewed by the Laboratory Manager and filed in the laboratory files and analyst files.

Discrepancies are noted and corrective measures are taken as soon as possible. Any corrective measures that are taken are placed in the lab files and analyst files.

Discrepancies found in the ten percent reanalysis which involve false negatives or false positive will be corrected, and any similar sample in the sample group or project will also be reanalyzed as part of the Quality Control.

If any corrections are needed for the clients report, they shall be made immediately. If the report has been sent to the client, a phone call shall be made pertaining to the change and a corrected report shall be sent to replace the original. All analytical correction or change to a report is noted on the report by the comment “Corrected Report” in the footnote section of the report.

Contamination Control

To assure a contamination free environment, the following procedures are strictly adhered to:

1. The hood is turned on before analysis begins.

2. Only one sample is placed in the working area of the hood at a time.

3. After each analysis, all tools and surfaces are cleaned with a damp wipe.

4. Slides, cover slips, and mounting medium kept outside the hood are to prevent contamination of airborne fibers in the hood.

5. After each day’s analysis, the lab bench and working surfaces are cleaned with a damp wipe.

6. Contamination is checked each month or as needed by analyzing blanks.

Inspector Certificates