CHY VA - Asbestos Reinspection Report - November 2018.pdf

ASBESTOS REINSPECTION REPORT

LOCATION:

CHEYENNE VA MEDICAL CENTER

2360 E PERSHING BLVD.

CHEYENNE, WY 82001

CONTRACT NO.: 36C25918C0329

PROJECT: 442-18-007S

INSPECTION DATES:

NOVEMBER 5-7, 2018

PRIME CONTRACTOR:

CASTLE HILL ASSOCIATES, LLC

218-A MECHANIC ST.

WATERVILLE, OH 43566

567-952-0212

CHEYENNE VA MEDICAL CENTER - CHEYENNE, VA

NOVEMBER 2018

TABLE OF CONTENTS

1.0 ASBESTOS INSPECTION REPORT

• Table 1 – List of Acronyms

• Table 2 - Removal Priority Protocols

2.0 APPENDICES

Appendix A – Asbestos Sampling Data

Appendix B – Asbestos Quantities, Assessments, & Remediation Cost Estimate

Appendix C – Photographs of Newly Identified Asbestos Materials

Appendix D – Asbestos Laboratory Reports

Appendix E - Inspector Certifications

Appendix F - Lab Certifications

Appendix G – Asbestos Locations and Sample Location Drawings

Appendix H – Photographs of Sample Locations

Appendix I – O&M Plan (Operations & Maintenance)

ASBESTOS REINSPECTION REPORT

NOVEMBER 2018

1.0 EXECUTIVE SUMMARY

On November 5-7, 2018, Castle Hill Associates, LLC was contracted by the US Department of Veterans Affairs (VA) to perform asbestos re-inspections of 15 buildings on the site of the Cheyenne VA Medical Center in Cheyenne, VA. The survey was performed as part of the VA Contract Number 36C25918C0329.

The buildings that were surveyed as part of this project included:

Building Number

Building Name/Description

ASBESTOS

PRESENT?

1 Main Hospital Yes

1-CA Main Hospital – Clinical Addition No

1-CX Main Hospital – Physical Therapy No

4 Offices – Fiscal and AM&M Yes

5 Office – Human Resources Yes

6 Former Quarters/Offices Yes

7 Former Quarters/Offices Yes

8 Offices Yes

11 Engineering & Shops Yes

12 Supply Warehouse No

13 Boiler Plant Yes

18 Garage No

19 Storage-Grounds Yes

20 Storage Garages Yes

23 Grounds Shop No

25 Garage Yes

26 Garage Yes

The inspection was conducted by Brett Brumbaugh and Sam Ansara. The project manager was Mr.

Brumbaugh who has been conducting asbestos surveys, sampling, and consulting work since 1987. Sam Ansara has been conducting asbestos surveys, sampling, and consulting work since 1989. There was a previous asbestos reinspection and sampling conducted at the facility in 2013 and that report/drawings were reviewed by Castle Hill prior to this inspection. There were no limitations or exceptions to the PWS for the surveys conducted.

All accessible functional areas in the facilities were surveyed. All previous asbestos survey information and sampling conducted at the facilities were evaluated and incorporated into this survey. All confirmed asbestos-containing materials were verified. This report can be incorporated into the facility’s management plan for asbestos-containing materials.

2.0 STATE AND LOCAL REGULATIONS

The State of Wyoming asbestos licensing regulations are similar to the Federal regulations. State asbestos regulations include requirements for licensing and certification of personnel who will perform asbestos-related work activities. All personnel who engage in asbestos-related activities must comply with the state licensing/certification requirements as well as with all Federal requirements.

NOVEMBER 2018

3.0 ANALYTICAL METHODS AND LIMITATIONS

3.1 Asbestos Sampling Protocol

EPA and OSHA define an ACBM as any material which contains greater than 1 percent asbestos. The ACBM inspection and bulk sampling were performed in accordance with the methods outlined in the EPA guidance document titled Guidance for Controlling Asbestos-Containing Materials in Buildings (Document No. 560/5- 85/024). In addition, bulk sampling of asbestos was performed in accordance with 40 CFR Part 763, AHERA requirements for number of samples and types of ACBM to be sampled. According to these requirements, materials are classified as either surfacing (e.g., decorative plaster, spray-applied fireproofing), thermal system insulation (e.g., pipe insulation, pipe fitting insulation, boiler insulation), or miscellaneous materials (e.g., floor tile, ceiling tile, plaster, wallboard, mastics).

The number of samples collected from each material varies based on the classification of the material and increases as the potential for a non-uniform mixture of asbestos in the material increases. Typically, regulations require a minimum number of samples to be collected from the different classifications of suspect

ACBM.

All bulk samples were analyzed utilizing current EPA methods for PLM (Polarized Light Microscopy) by EMLab P&K in Marlton, NJ. EMLab is accredited by the NIST, NVLAP program (National Institute of Standards and Technology, National Voluntary Laboratory Accreditation Program) and also an American Industrial Hygiene Association (AIHA) accredited laboratory.

All soil samples were analyzed utilizing the CARB 435 methods for PLM Point Counting for soils by EMLab P&K in Arvada, CO. EMLab is accredited by the NIST, NVLAP program (National Institute of Standards and Technology, National Voluntary Laboratory Accreditation Program) and also an American Industrial Hygiene Association (AIHA) accredited laboratory.

4.0 SUMMARY OF FINDINGS

4.1 Asbestos-Containing Building Materials

The following is a summary of the asbestos containing materials, locations, quantities of materials in each inspected building for this project:

Building 1 – Main Hospital

Asbestos Containing Materials Locations Quantity

Contaminated soil from pipe insulation debris Crawl Spaces 40,700 sf

Pipe insulation CL-02C hallway, pipe chases by CL-04 and CL-17, C1-102, D1-36 closet, 60 lf

Hard ceiling plaster C1-92 Entry 1,440 sf 9” floor tile D1-36 closet, D1-15 storage 80 sf Ebony cement countertops & shelves D1-53 Dental Lab 90 sf Drywall joint compound Attic 4-OL & 4-OK divider wall 628 sf

Building 1-CA Clinical Addition

• No asbestos containing materials identified in building.

Building 1-CX Physical Therapy Addition

Building 4 – Offices (Fiscal and AM&M)

Contaminated soil under concrete cap Crawl Spaces 2,860 sf Pipe insulation Basement Storage Rooms B1, B2, and B4 415 lf Skim coating on concrete walls Basement rooms B1, B1A, B2, B3, B4 and 108 1,440 sf

Hard ceiling & wall plaster 1st & 2nd floor rooms 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 114, 115, S1F1, 200, 201, 203, S1F2

11,220 sf

Building 5 – Offices (Human Resources)

Transite cement sheets Basement furnace room B1 16 sf

Drywall joint compound First floor rooms 101, 102, 103, 104, 105, 106, 107, 108, C1, C2, S1F1

4,160 sf

Building 6 – Offices (former quarters)

Contaminated soil under concrete cap 2 Crawl Spaces 776 sf Pipe insulation Basement Storage Room 001 20 lf

Building 7 – Offices (former quarters)

Hard ceiling & wall plaster Basement, 1st & 2nd floor rooms B01, B02, 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, S1F2, 201

3,430 sf

Linoleum sheet flooring Kitchen 104 168 sf

Building 8 – Offices (former quarters)

9” floor tile Basement Storage B01 80 sf Drywall joint compound 1st floor entry 100 846 sf

Building 11 – Engineering and Shops

Pipe insulation (remaining stubs in sleeves) Elect. shop 103 (S.W. corner) 2 lf Hard ceiling plaster Paint shops 105, 106, 107, and closet 214 770 sf Glue pods for non-ACM 12” ceiling tiles (above 2x4 lay-in ceiling tile)

2nd floor offices 212 and 212A 384 sf

Building 12 – Supply Warehouse

Building 13 – Boiler Plant

Pipe insulation Tunnel under driveway to Building 11 90 lf Skim coating on concrete walls Basement Room B-107 320 sf

Building 18 – Garage

Building 19 – Storage/Grounds

Window Glazing/Putty Windows 4 windows

Building 20 – Storage Garages

Window Caulking Windows 10 windows

Building 23 – Grounds Shop

Building 25 –Garage

Window Caulking Window 1 window

Building 26 –Garage

Window Caulking Window 2 windows

Building 42 – Storage Building

Building 45 – VBA Veterans Benefits

5.0 Explanation of Assessment of Asbestos Containing Materials

Re-inspection protocol is based on the Asbestos Hazard Emergency Response Act (AHERA), Environmental Protection Act’s (EPA’s) revised Asbestos Model Accreditation Plan (MAP) mandated by the Asbestos School Hazard Abatement Reauthorization Act (ASHARA), and the Department of Veterans Affairs (VA) Directive 7700. The tabular listing included in this report contains Building Number, Floor, Room Number, Material Category (i.e., TSI, SM or MM), Material Type, quantity, a numerical priority ranking, condition, potential for damage, potential for human exposure, drawing number, hazard ranking, recommended response action and associated cost estimate for implementation of those response actions.

The material assessment categories of the ACM identified in the building is formatted in the following order for the summary tables enclosed in this report:

• Material Category - Surfacing Material (SUR); Thermal System Insulation (TSI); Miscellaneous (MM)

• Material Type - Friable (F); Non-Fable (NF)

• Condition of Material - Good; Fair; Poor

• Potential for Damage - Low; Medium; High

• Physical Assessment - Low; Medium; High

• Recommended Response Action - 1 through 7

Material category is the type of material such as surfacing material (SUR), thermal system insulation (TSI), and miscellaneous (MM)

• Surfacing Material (SUR) - Surfacing ACM means surfacing material that is ACM. Surfacing material means material in a school building that is sprayed-on, troweled-on, or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes.

• Thermal System Insulation (TSI) - Thermal system insulation ACM means thermal system insulation that is ACM. Thermal system insulation means material in a school building applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes.

• Miscellaneous (MM) - Miscellaneous ACM means miscellaneous material that is ACM Miscellaneous material means interior building material on structural components, structural members or fixtures, such as floor and ceiling tiles, and does not include surfacing material or thermal system insulation.

Material type refers to the hardness of a material to be crumbled, pulverized, or reduced to powder by hand pressure as friable (F), and includes previously non-friable (NF) material after such previously non-friable material becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure.

• Condition of Material - Good; Fair; Poor

• Potential for Damage - Low; Medium; High

• Physical Assessment - Low; Medium; High

Seven Categories define in the AHERA regulation one of which must be assigned to each friable surfacing and miscellaneous ACBM and each asbestos-containing TSI during the inspection/re-inspection.

1. Damaged or significantly damaged TSI ACBM - Damaged or significantly damaged thermal system insulation ACM means thermal system insulation ACM on pipes, boilers, tanks, ducts, and other thermal system insulation equipment where the insulation has lost its structural integrity, or its covering, in whole or in part, is crushed, water-stained, gouged, punctured, missing, or not intact such that it is not able to contain fibers. Damage may be further illustrated by occasional punctures, gouges or other signs of physical injury to ACM; occasional water damage on the protective coverings/jackets; or exposed ACM ends or joints. Asbestos debris originating from the ACBM in question may also indicate damage.

2. Damaged friable surfacing ACBM - Damaged friable surfacing ACM means friable surfacing ACM which has deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or which has delaminated such that its bond to the substrate (adhesion) is inadequate, or which, for any other reason, lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM surface; water damage; significant or repeated water stains, scrapes, gouges, mars or other signs of physical injury on the ACM. Asbestos debris originating from the ACBM in question may also indicate damage.

3. Significantly damaged friable surfacing ACBM - Significantly damaged friable surfacing ACM means damaged friable surfacing ACM in a functional space where the damage is extensive and severe.

4. Damaged or significantly damaged friable miscellaneous ACBM - Damaged friable miscellaneous ACM means friable miscellaneous ACM which has deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or, if applicable, which has delaminated such that its bond to the substrate (adhesion) is inadequate or which for any other reason lacks fiber cohesion or adhesion qualities.

Such damage or deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM surface; water damage; significant or repeated water stains, scrapes, gouges, mars or other signs of physical injury on the ACM. Asbestos debris originating from the ACBM in question may also indicate damage.

5. ACBM with Potential for Damage - Potential damage means circumstances in which:

(1) Friable ACBM is in an area regularly used by building occupants, including maintenance personnel, in the course of their normal activities.

(2) There are indications that there is a reasonable likelihood that the material or its covering will become damaged, deteriorated, or delaminated due to factors such as changes in building use, changes in operations and maintenance practices, changes in occupancy, or recurrent damage.

6. ACBM with potential for significant damaged - Potential significant damage means circumstances in which:

(1) Friable ACBM is in an area regularly used by building occupants, including maintenance personnel, in the course of their normal activities.

(2) There are indications that there is a reasonable likelihood that the material or its covering will become significantly damaged, deteriorated, or delaminated due to factors such as changes in building use, changes in operations and maintenance practices, changes in occupancy, or recurrent damage.

7. Any remaining friable ACBM or Friable Suspected ACBM

6.0 EXPLANATION OF REMEDIATION COST ESTIMATES

All remediation cost (removal and repair) estimates are based upon RS Means data. Since RS Means does not account for work in VA Medical Centers, all cost estimates are adjusted to reflect the VA specific requirments for abatement. In addition, the cost estimates reflect the quantity and location of the asbestos materials. For example, abatement work in crawl spaces is expected to be much more costly than work in more accessible areas of building. Also, the costs for each material in each building are intended to be for “stand alone” projects and the combination of areas for removal will reduce the costs due to an economy of scale.

7.0 CONCLUSION/RECOMMENDATIONS

An operations and maintenance (O&M) program has been developed by the VAMC specifically for the positively identified ACBM in the facilities. Any renovation/demolition work which may impact these positive materials should be conducted in accordance with the O&M program and all applicable Federal, state, and local regulations by appropriately trained and VA-approved personnel and contractors. Since demolition was not performed as part of the inspection work at the facilities, certain areas such as pipe chases and areas above fixed permanent ceilings, fire-door interiors, and vault/safe wall and door linings were not inspected or tested. Prior to renovation and alteration work which could impact these areas, Castle Hill recommends that exploratory demolition be performed and a qualified inspector be utilized to examine the areas and collect samples as needed. Castle Hill recommends sampling of roofing materials and electrical components (not specifically examined as part of this survey) if renovation activities are planned which may disturb these materials.

Respectfully Submitted:

Brett L. Brumbaugh, REPA, CESCO Project Manager

TABLE 1

LIST OF ACRONYMS

ACBM Asbestos Containing Building Material ACM Asbestos Containing Material AHERA Asbestos Hazard Emergency Response Act AIHA American Industrial Hygiene Association CAA Clean Air Act CFR Code of Federal Regulations EPA United States Environmental Protection Agency HazCom Hazard Communication HEPA High Efficiency Particulate Air Filter HVAC Heating, Ventilation, and Air Conditioning MISC Miscellaneous Asbestos Containing Material NESHAP National Emission Standards for Hazardous Air Pollutants NIOSH National Institute for Occupational Safety and Health NIST National Institute of Standards and Technology NOB Non-friable Organically Bound NVLAP National Voluntary Laboratory Accreditation Program OSHA Occupational Safety and Health Administration PAT AIHA Proficiency Analytical Testing Program PCM Phase Contrast Microscopy PEL Permissible Exposure Limit PLM Polarized Light Microscopy TEM Transmission Electron Microscopy TSCA Toxic Substances Control Act TSI Thermal Systems Insulation Castle Hill Castle Hill Associates, LLC VA United States Department of Veterans Affairs VAMC VA Medical Center XRD X-Ray Diffraction

TABLE 2

ASBESTOS REMOVAL PRIORITY PROTOCOLS

HAZARD

RANK

REMOVAL

PRIORITY

AHERA

CATEGORY

RESPONSE ACTION

RECOMMENDATION

7 1 Significantly Damaged

Evacuate or isolate the area.

Remove or repair if feasible.

O&M for all friable ACM.

6 2 Damaged with potential for significant damage

Evacuate or isolate the area.

Remove, encapsulate, or repair if feasible. O&M for all friable

ACM.

5 3 Damaged with potential for damage

Remove, encapsulate, or repair. O&M for all friable ACM.

4 4 Damaged Remove, encapsulate, or repair. O&M for all friable ACM.

3 5 Potential for significant damage

Take steps to reduce potential for damage. O&M for all friable

ACM.

2 6 Potential for damage O&M for all friable ACM.

1 7 No problem O&M for all friable ACM.

APPENDIX A

ASBESTOS BULK SAMPLING DATA

ASBESTOS BULK SAMPLING INFORMATION

Facility: Cheyenne VA Medical Center – Cheyenne, VA Building: 1 Sampling Date: November 5, 2018 Analysis Date: November 12, 2018 Laboratory: EMLab P&K – Marlton, NJ Accreditation: NVLAP Asbestos Bulk Accredited Laboratory # 200844-0 Sampler: Brett Brumbaugh Certification: EPA Accredited Asbestos Inspector/Management Planner

PLM Laboratory Analysis Result

SAMPLE

NUMBER

MATERIAL SAMPLE LOCATION

LABORATORY ANALYSIS

RESULT

1 Asphalt tar paper under slate shingle Attic No asbestos detected

2a 9” tan vinyl floor tile D2-38 mechanical room No asbestos detected

2b Black tar paper under tile “” No asbestos detected 2c Yellow mastic under tar paper “” No asbestos detected 3a 9” green floor tile D1-36 conf. room closet 4% Chrysotile Asbestos 3b Black mastic “” No asbestos detected 4a 9” tan floor tile D1-15 food storage room 6% Chrysotile Asbestos 4b Black mastic “” No asbestos detected

C3 Pipe insulation debris in soil Crawl space 45% Chrysotile Asbestos C4 Pipe insulation debris in soil Crawl space 40% Chrysotile Asbestos C6 Pipe insulation debris in soil Crawl space 30% Chrysotile Asbestos C7 Pipe insulation debris in soil Crawl space 45% Chrysotile Asbestos C8 Pipe insulation debris in soil Crawl space 40% Chrysotile Asbestos

EPA Definition of an asbestos containing material: Greater than 1% asbestos

ASBESTOS BULK SAMPLING INFORMATION

Facility: Cheyenne VA Medical Center – Cheyenne, VA Building: 1 Sampling Date: November 5, 2018 Analysis Date: November 21, 2018 Laboratory: EMLab P&K – Arvada, CO Accreditation: NVLAP Asbestos Bulk Accredited Laboratory # 500053-0 Sampler: Brett Brumbaugh Certification: EPA Accredited Asbestos Inspector/Management Planner

PLM Point Count Laboratory Analysis Result (CARB 435)

SAMPLE

NUMBER

MATERIAL SAMPLE LOCATION

LABORATORY ANALYSIS

RESULT

C1 Loose soil in crawl space Crawl space 1-A No Asbestos Detected C2 Loose soil in crawl space Crawl space 1 <0.25% Chrysotile Asbestos C5 Loose soil in crawl space Crawl space 1-B No Asbestos Detected

EPA Definition of an asbestos containing material: Greater than 1% asbestos

APPENDIX B

Asbestos Quantities, Assessments, & Remediation Cost Estimates

Cheyenne VAMC - Cheyenne, WY

Building 1

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal Cost

Estimate

Contaminated soil from pipe insulation debris Crawl Spaces 40,700 sf TSI Friable 7

Isolate crawl spaces and place signs at all entrances. Require PPE for entrance to crawl. Encapsulate soil or remove.

1 $220,000 $550,000

Pipe insulation CL-02C hallway, pipe chases by CL-04 and CL-

17, C1-102, D1-36 closet, 60 lf TSI Friable 2 O&M; Remove at renovation or demolition 6 No damage $3,300

Hard ceiling plaster C1-92 Entry 1,440 sf SURFACING Non-friable 2 O&M; Remove at renovation or demolition 6 No damage $72,000

9” floor tile D1-36 closet, D1-15 storage 80 sf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $4,000

Ebony cement countertops & shelves D1-53 Dental Lab 90 sf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $3,000

Drywall joint compound Attic 4-OL & 4-OK divider wall 628 sf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $7,000

Building 4

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal Cost

Estimate

Contaminated soil under concrete cap Crawl Spaces 2,860 sf TSI Non-friable 1 O&M; Remove at demolition 7 No damage $60,000

Pipe insulation Basement Storage Rooms B1, B2, and B4 415 lf TSI Friable 2 O&M; Remove at renovation or demolition 6 No damage $18,000

Skim coating on concrete walls Basement rooms B1, B1A, B2, B3, B4 and

1,440 sf SURFACING Non-friable 1

O&M; Remove at renovation or demolition 7 No damage $21,000

Hard ceiling & wall plaster

1st & 2nd floor rooms 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 114, 115, S1F1, 200, 201, 203, S1F2

11,220 sf SURFACING Non-friable 2 O&M; Remove at renovation or demolition 6 No damage $80,000

Building 5

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal Cost

Estimate

Transite cement sheets Basement furnace room B1 16 sf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $2,000

Drywall joint compound First floor rooms 101, 102, 103, 104, 105, 106, 107, 108, C1, C2, S1F1 4,160 sf MISC Non-friable 2

O&M; Remove at renovation

6 No damage $22,000

Building 6

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal Cost

Estimate

Contaminated soil under concrete cap 2 Crawl Spaces 776 sf TSI Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $36,500

Pipe insulation Basement Storage Room 001 20 lf TSI Friable 4 O&M; Remove at renovation

4 No damage $3,000

Building 7

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal Cost

Estimate

Hard ceiling & wall plaster

Basement, 1st & 2nd floor rooms B01, B02, 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, S1F2, 201

3,430 sf SURFACING Non-friable 2 O&M; Remove at renovation or demolition 6 No Damage $51,000

Linoleum sheet flooring Kitchen 104 168 sf MISC Non-friable 1 O&M; Remove at renovation

7 No Damage $2,500

Building 8

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

9” floor tile Basement Storage B01 80 sf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $1,200

Drywall joint compound 1st floor entry 100 846 sf MISC Non-friable 2 O&M; Remove at renovation or demolition 6 No damage $7,000

Building 11

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Pipe insulation (remaining stubs in sleeves) Elect. shop 103 (S.W. corner) 2 lf TSI Friable 1 O&M; Remove at renovation or demolition 7 No damage $1,500

Hard ceiling plaster Paint shops 105, 106, 107, and closet 214 770 sf SURFACING Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $8,500

Glue pods for non-ACM 12” ceiling tiles (above 2x4 lay-in ceiling tile) 2nd floor offices 212 and 212A 384 sf MISC Non-friable 1

O&M; Remove at renovation or

7 No damage $4,000

Building 13

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Pipe insulation Tunnel under driveway to Building

90 lf TSI Friable 2

Restrict access to tunnel with proper

PPE; O&M until removal at renovation or demolition

6 No damage $11,000

Skim coating on concrete walls Basement Room B-107 320 sf SURFACING Non-friable 2 O&M; Remove at renovation or

6 No damage $4,800

Building 19

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Window Glazing/Putty Windows 4 windows MISC Non-friable 1 O&M; Remove at renovation or

7 No damage $800

Building 20

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Window caulking Windows 10 windows MISC Non-friable 1 O&M; Remove at renovation or

7 No damage $1,800

Building 25

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Window caulking Windows 1 window MISC Non-friable 1 O&M; Remove at renovation or

7 No damage $500

Building 26

Asbestos Assessments and Cost Estimates

November 2018

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Window caulking Windows 2 windows MISC Non-friable 1 O&M; Remove at renovation or

7 No damage $600

APPENDIX C

PHOTOGRAPHS OF NEWLY IDENTIFIED ASBESTOS MATERIALS

BUILDING 1

Photo 1 Pipe insulation debris in crawl space on loose soil

Photo 2

Photo 3

Photo 4

Photo 5 Ebony cement lab table tops and shelves in Dental Lab D1-

Photo 6 9” tan floor tile in Canteen storage room D1-15

Photo 7 9” green floor tile in conference room closet D1-36

BUILDING 4

Photo 8 Pipe insulation in basement storage rooms

BUILDING 5

Photo 9 Transite cement sheets above furnace in basement storage room B1

BUILDING 6

Photo 10 Pipe insulation in basement storage room 001

BUILDING 7

Photo 11 Linoleum sheet flooring in kitchen/break room

BUILDING 13

Photo 12 Steam pipe insulation in tunnel from basement to

Building 11 under driveway

APPENDIX D

ASBESTOS LABORATORY REPORTS

Approved by:

Approved Signatory Balu Krishnan

Report for:

Mr. Brett Brumbaugh, REPA Castle Hill Associates PO Box 283 Waterville, OH 43566

Regarding: Project: Cheyenne VAMC - Cheyenne, WY; Asbestos Reinspection

EML ID: 2038295

All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. The results relate only to the items tested. The results include an inherent uncertainty of measurement associated with estimating percentages by polarized light microscopy. Measurement uncertainty data for sample results with >1% asbestos concentration can be provided when requested.

EMLab P&K ("the Company") shall have no liability to the client or the client's customer with respect to decisions or recommendations made, actions taken or courses of conduct implemented by either the client or the client's customer as a result of or based upon the Test Results. In no event shall the Company be liable to the client with respect to the Test Results except for the Company's own willful misconduct or gross negligence nor shall the Company be liable for incidental or consequential damages or lost profits or revenues to the fullest extent such liability may be disclaimed by law, even if the Company has been advised of the possibility of such damages, lost profits or lost revenues. In no event shall the Company's liability with respect to the Test Results exceed the amount paid to the Company by the client therefor.

Dates of Analysis:

Asbestos PLM: 11-12-2018

Service SOPs: Asbestos PLM (EPA 40CFR App E to Sub E of Part 763 & EPA METHOD 600/R-93-116, SOP EM-AS-S-1267)

EMLab ID: 2038295, Page 1 of 4EMLab P&K, LLC

EMLab P&K 3000 Lincoln Drive East, Suite A, Marlton, NJ 08053

(866) 871-1984 Fax (856) 334-1040 www.emlab.com Client: Castle Hill Associates C/O: Mr. Brett Brumbaugh, REPA Re: Cheyenne VAMC - Cheyenne, WY; Asbestos Reinspection

Date of Sampling: 11-06-2018 Date of Receipt: 11-07-2018 Date of Report: 11-12-2018

ASBESTOS PLM REPORT

Total Samples Submitted: 9 Total Samples Analyzed: 9

Total Samples with Layer Asbestos Content > 1%: 7

Location: 1, Roofing Felt Lab ID-Version‡: 9619113-1

Sample Layers Asbestos Content Black Roofing Felt ND

Composite Non-Asbestos Content: 50% Cellulose Sample Composite Homogeneity: Good

Location: 2, Floor Tile & Mastic Lab ID-Version‡: 9619114-1

Sample Layers Asbestos Content Tan Floor Tile ND

Brown/Black Felt Padding ND Yellow Mastic ND

Composite Non-Asbestos Content: 70% Cellulose Sample Composite Homogeneity: Good

Location: 3, Floor Tile Lab ID-Version‡: 9619115-1

Sample Layers Asbestos Content Green Floor Tile 4% Chrysotile

Black Mastic ND Composite Non-Asbestos Content: 2% Cellulose Sample Composite Homogeneity: Good

EMLab ID: 2038295, Page 2 of 4EMLab P&K, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is reflected by the value of "x".

(866) 871-1984 Fax (856) 334-1040 www.emlab.com Client: Castle Hill Associates C/O: Mr. Brett Brumbaugh, REPA Re: Cheyenne VAMC - Cheyenne, WY; Asbestos Reinspection

Date of Sampling: 11-06-2018 Date of Receipt: 11-07-2018 Date of Report: 11-12-2018

ASBESTOS PLM REPORT

Location: 4, Floor Tile Lab ID-Version‡: 9619116-1

Sample Layers Asbestos Content Cream Floor Tile 6% Chrysotile

Black Mastic ND Sample Composite Homogeneity: Good

Location: C3, Debris in Crawl Lab ID-Version‡: 9619117-1

Sample Layers Asbestos Content White Insulation 45% Chrysotile

Peach Rock & Stick ND Composite Non-Asbestos Content: 25% Cellulose

20% Mineral Wool Sample Composite Homogeneity: Good

Location: C4, Debris in Crawl Lab ID-Version‡: 9619118-1

Sample Layers Asbestos Content Off-White Fibrous Material 40% Chrysotile

Composite Non-Asbestos Content: 50% Mineral Wool 2% Cellulose

Sample Composite Homogeneity: Good

EMLab ID: 2038295, Page 3 of 4EMLab P&K, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 871-1984 Fax (856) 334-1040 www.emlab.com Client: Castle Hill Associates C/O: Mr. Brett Brumbaugh, REPA Re: Cheyenne VAMC - Cheyenne, WY; Asbestos Reinspection

Date of Sampling: 11-06-2018 Date of Receipt: 11-07-2018 Date of Report: 11-12-2018

ASBESTOS PLM REPORT

Location: C6, Debris in Crawl Lab ID-Version‡: 9619119-1

Sample Layers Asbestos Content Beige Wrap Insulation 30% Chrysotile

Composite Non-Asbestos Content: 5% Cellulose Sample Composite Homogeneity: Good

Location: C7, Debris in Crawl Lab ID-Version‡: 9619120-1

Sample Layers Asbestos Content Off-White Fibrous Material 45% Chrysotile

Composite Non-Asbestos Content: 40% Mineral Wool 2% Cellulose

Sample Composite Homogeneity: Good

Location: C8, Debris in Crawl Lab ID-Version‡: 9619121-1

Sample Layers Asbestos Content White Insulation 40% Chrysotile

Composite Non-Asbestos Content: 50% Mineral Wool 3% Cellulose

Sample Composite Homogeneity: Good

EMLab ID: 2038295, Page 4 of 4EMLab P&K, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

Approved by:

Technical Manager Noah Lazarte

Report for:

Mr. Brett Brumbaugh, REPA Castle Hill Associates PO Box 283 Waterville, OH 43566

Regarding: Project: Cheyenne VAMC- Cheyenne, WY; Asbestos Reinspection

EML ID: 2041579

All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. Due to the nature of the analyses performed, field blank correction of results is not applied. The results relate only to the items tested.

EMLab P&K ("the Company") shall have no liability to the client or the client's customer with respect to decisions or recommendations made, actions taken or courses of conduct implemented by either the client or the client's customer as a result of or based upon the Test Results. In no event shall the Company be liable to the client with respect to the Test Results except for the Company's own willful misconduct or gross negligence nor shall the Company be liable for incidental or consequential damages or lost profits or revenues to the fullest extent such liability may be disclaimed by law, even if the Company has been advised of the possibility of such damages, lost profits or lost revenues. In no event shall the Company's liability with respect to the Test Results exceed the amount paid to the Company by the client therefor.

Dates of Analysis:

Asbestos-CARB 435: 11-16-2018

Service SOPs: Asbestos-CARB 435 (EM-AS-S-1265)

EMLab ID: 2041579, Page 1 of 2EMLab P&K, LLC

4955 Yarrow Street , Arvada, CO 80002

(800) 651-4802 Fax (623) 780-7695 www.emlab.com Client: Castle Hill Associates C/O: Mr. Brett Brumbaugh, REPA Re: Cheyenne VAMC- Cheyenne, WY; Asbestos Reinspection

Date of Sampling: 11-05-2018 Date of Receipt: 11-12-2018 Date of Report: 11-21-2018

ASBESTOS POINT COUNT REPORT: CARB METHOD 435

Location: C1 Bldg 1 Crawl Space Soil

Total Points Counted: 0

Lab ID-Version‡: 9636442-1

Sample Layers Asbestos Type Asbestos Points Counted

Asbestos Concentration (%)

Gray Soil - - ND Layer Totals: - -

Comments:No asbestos was detected and no points were counted.

Location: C2 Bldg 1 Crawl Space Soil

Total Points Counted: 400

Lab ID-Version‡: 9636443-1

Sample Layers Asbestos Type Asbestos Points Counted

Asbestos Concentration (%)

Gray Soil Chrysotile 0 < 0.25 Layer Totals: 0 NA

Comments:Asbestos was detected, but no points counted.

Location: C5 Bldg 1 Crawl Space Soil

Total Points Counted: 0

Lab ID-Version‡: 9636444-1

Sample Layers Asbestos Type Asbestos Points Counted

Asbestos Concentration (%)

Gray Soil - - ND Layer Totals: - -

Comments:No asbestos was detected and no points were counted.

EMLab ID: 2041579, Page 2 of 2EMLab P&K, LLC

The analytical sensitivity is 1 asbestos point. The limit of detection is 1 asbestos point divided by the total number of points counted and multiplied by 100.

The results relate only to the items tested. Interpretation is left to the company and/or persons who conducted the field work. The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government.

All samples were received in acceptable condition unless otherwise noted. EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

APPENDIX E

INSPECTOR AND LAB CERTIFICATIONS

New Record

Asbestos Building Inspector Refresher

Toledo

Course LocationTraining Manager

10/24/19

Expiration Date

10/24/18

Examination Date

10/24/18

Date(s) of Course

74633

XXX-XX-6789

Certificate This is to certify

33150 Lakeland Blvd.

Cleveland, OH 44095 www.TSItraining.com ir

, OH

has attended and successfully completed the Asbestos Hazard Emergency Response Act mandatory course for the Asbestos Building Inspector Refresher and has passed an examination in that course with a minimum score of 70% or better. Training was in accordance with 40 CFR Part 763 (AHERA). The above student received the requisite training for asbestos accreditation under Title II of the Toxic Substances Control Act and State of Indiana requirements under 326 IAC 18-2 and Chapter 3745-22 Ohio Administrative Code.

18 TSI

Brett Brumbaugh

Course Certificate No.

New Record

Asbestos Management Planner Refresher

Toledo

Course LocationTraining Manager

10/24/19

Expiration Date

10/24/18

Examination Date

10/24/18

Date(s) of Course

74646

XXX-XX-6789

Certificate This is to certify

33150 Lakeland Blvd.

Cleveland, OH 44095 www.TSItraining.com mpr

, OH

has attended and successfully completed the Asbestos Hazard Emergency Response Act mandatory course for the Asbestos Management Planner Refresher and has passed an examination in that course with a minimum score of 70% or better. Training was in accordance with 40 CFR Part 763 (AHERA). The above student received the requisite training for asbestos accreditation under Title II of the Toxic Substances Control Act and State of Indiana requirements under 326 IAC 18-2 and Chapter 3745-22 Ohio Administrative Code.

18 TSI

Brett Brumbaugh

Course Certificate No.

APPENDIX F

LAB CERTIFICATIONS

United States Department of Commerce

National Institute of Standards and Technology

Certificate of Accreditation to ISO/IEC 17025:2005

NVLAP LAB CODE: 500053-0

EMLab P&K, LLC Arvada, CO is accredited by the National Voluntary Laboratory Accreditation Program for specific services, listed on the Scope of Accreditation, for:

Asbestos Fiber Analysis

2018-07-01 through 2019-06-30 Effective Dates For the National Voluntary Laboratory Accreditation Program

This laboratory is accredited in accordance with the recognized International Standard ISO/IEC 17025:2005.

This accreditation demonstrates technical competence for a defined scope and the operation of a laboratory quality management system (refer to joint ISO-ILAC-IAF Communique dated January 2009).

National Voluntary Laboratory Accreditation Program

SCOPE OF ACCREDITATION TO ISO/IEC 17025:2005

For the National Voluntary Laboratory Accreditation Program

Effective 2018-07-01 through 2019-06-30

EMLab P&K, LLC 4955 Yarrow Street Arvada, CO 80002

Mr. Dan Shelby Phone: 623-298-1015 Fax: 623-445-6217

Email: dshelby@emlabpk.com http://www.emlabpk.com

ASBESTOS FIBER ANALYSIS NVLAP LAB CODE 500053-0

Bulk Asbestos Analysis

Code Description 18/A01 EPA -- 40 CFR Appendix E to Subpart E of Part 763, Interim Method of the Determination of

Asbestos in Bulk Insulation Samples

18/A03 EPA 600/R-93/116: Method for the Determination of Asbestos in Bulk Building Materials

APPENDIX G

ASBESTOS LOCATIONS & SAMPLE LOCATION DRAWINGS

APPENDIX H

PHOTOGRAPHS OF SAMPLE LOCATIONS

Sample 1 Asphalt tar paper under former slate roofing shingles in attic

No asbestos detected

Sample 2 9” tan vinyl floor tile, mastic, and tar paper on floor of mechanical room D2-38

No asbestos detected in any layer

Sample 3

9” green vinyl floor tile and mastic in storage closet D1-36

Tile = 4% Asbestos

Mastic, No asbestos detected

Sample 4 9” tan vinyl floor tile and mastic in food storage room D1-15

Tile = 6% Asbestos

Mastic, No asbestos detected

Sample C1 Loose soil in crawl space 1-A

Sample C2

Loose soil in crawl space 1

<0.25% Asbestos

Sample C3

Pipe insulation debris on dirt floor of crawl space in

45% chrysotile asbestos

Sample C4

30% chrysotile asbestos

Sample C5 Loose soil in crawl space 1-B

Sample C6

Building 1-B

30% chrysotile asbestos

Sample C7

Pipe insulation debris on electrical cable tray in crawl space in Building 1-B

45% chrysotile asbestos

Sample C8

40% chrysotile asbestos

APPENDIX I

O&M PLAN

(OPERATIONS & MAINTENANCE)

CHEYENNE VA MEDICAL CENTER

ASBESTOS OPERATIONS AND MAINTENANCE PLAN

FY2018

NOVEMBER 28, 2018

US DEPARTMENT OF VETERAN AFFAIRS

CHEYENNE VA MEDICAL CENTER

2360 EAST PERSHING BLVD.

CHEYENNE, WY 82001

STANDARD OPERATING PROCEDURE

PREPARED BY:

CASTLE HILL ASSOCIATES, LLC

218-A MECHANIC ST.

WATERVILLE, OH 43566

Cheyenne VA Medical Center November 28, 2018

Table of Contents

1.0 Introduction

1.1 Regulatory History of Asbestos Bans

2.0 Purpose

2.1 Scope and Objectives

3.0 Roles and Responsibilities

4.0 Communication

4.1 Communication with Patients, Visitors, and Employees

4.2 Outside Contractor Communication

4.3 Employee Communication

4.4 Notification to Agencies

4.4.1 Notification Requirements

4.5 Warning Signs and Labels

4.5.1 Warning Signs

4.5.2 Warning Labels

5.0 Locations of ACM/ACBM

6.0 Training

6.1 Asbestos Program Manager and Industrial Hygienist

6.2 Maintenance Staff (working with ACM/ACBM)

6.3 Other Building Employees

6.4 Abatement Contractors

7.0 Worker Protection

7.1 Program Administrator

7.2 Recordkeeping

7.3 Medical Surveillance

7.3.1 Who Should Receive Medical Surveillance

7.3.2 Frequency of the Medical Examination

7.3.3 Information Building Management Will Provide to Physician

7.3.4 Content of Examination

7.4 Respiratory Protection Program

7.5 Protective Clothing

8.0 Emergency Response

8.1 Minor Fiber Release Episode

8.1.1 Procedures for control

8.2 Major Fiber Release Episode

8.2.1 Procedures for Control

9.0 Procedures for Planned Activities

9.1 Routine Maintenance in Which Disturbance to ACM/ACBM is Unlikely

9.2 Routine Maintenance in Which Disturbance to ACM/ACBM is Likely

9.3 Quality Assurance

9.4 Routine Cleaning

9.5 Ceiling Tiles

10.0 Equipment and Materials

10.1 Equipment

10.2 Materials

11.0 ACM/ACBM Disposal Procedures

11.1 General Disposal Procedures

12.0 Periodic Surveillance

12.1 Physical Inspection

12.2 Area Air Monitoring

13.0 Periodic Evaluation to O&M Plan

14.0 Recordkeeping

14.1 General Provisions

14.2 Building Managements’ Employee Files

14.3 Operations and Maintenance Activities Files

Attachment A: References

Attachment B: Contacts

1.0 Introduction

Asbestos is a common building material used in the United States from the early 1900’s to present.

Asbestos is completely safe when maintained in “good” condition, but becomes a potential hazard if the microscopic fibers are released into the air. This occurs when the material containing the asbestos becomes damaged and is friable-meaning when it is dry, it can be crumbled in your hand. If the dust containing the asbestos fibers is inhaled, these fibers can become trapped within the body and may eventually lead to asbestosis, mesothelioma, and lung cancer. If ingested, it may lead to many other types of cancer.

1.1 Regulatory History of Asbestos Bans

• In 1973, EPA banned spray-applied surfacing asbestos-containing material for fireproofing/insulating purposes. See National Emission Standards for Hazardous Air Pollutants (NESHAP) at 40 CFR Part 61, Subpart M.

• In 1975, EPA banned installation of asbestos pipe insulation and asbestos block insulation on facility components, such as boilers and hot water tanks, if the materials are either pre-formed (molded) and friable or wet-applied and friable after drying. See National Emission Standards for Hazardous Air Pollutants (NESHAP) at 40 CFR Part 61, Subpart M.

• In 1978, EPA banned spray-applied surfacing materials for purposes not already banned.

See National Emission Standards for Hazardous Air Pollutants (NESHAP) at 40 CFR Part 61, Subpart M.

• In 1977, the Consumer Product Safety Commission (CPSC) banned the use of asbestos in artificial fireplace embers and wall patching compounds. (16 CFR Part 1305 and 16 CFR 1304).

• In 1989, the EPA issued a final rule under Section 6 of Toxic Substances Control Act (TSCA) banning most asbestos-containing products. However, in 1991, this rule was vacated and remanded by the Fifth Circuit Court of Appeals. As a result, most of the original ban on the manufacture, importation, processing, or distribution in commerce for the majority of the asbestos-containing products originally covered in the 1989 final rule was overturned. See 40 CFR 763 Subpart I.

2.0 Purpose

The purpose of the Asbestos Operations and Maintenance (O&M) Plan is to address the existing Asbestos Containing Materials (ACM)/Asbestos Containing Building Materials (ACBM) within the Cheyenne VA Medical Center facility and how to prevent/minimize the potential for asbestos fiber exposure to building occupants, visitors, residents, employees, etc. This plan will identify procedures to maintain any existing ACM/ACBM in ‘good’ condition until all ACM/ACBM is ultimately abated. This plan will include the updated details of routine surveys and inspections and the procedures for handling ACM/ACBM that may become ‘damaged’ or ‘significantly damaged’.

The following definitions are the different conditions for all ACM/ACBM and how to identify what condition the ACM/ACBM is in:

1. Good: <1% overall damage and any damage does not appear to be a significant hazard.

2. Damaged: <10% localized damage or <25% total damage throughout homogeneous area.

http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol8/xml/CFR-2011-title40-vol8-part61.xml http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol8/xml/CFR-2011-title40-vol8-part61.xml http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol8/xml/CFR-2011-title40-vol8-part61.xml http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol8/xml/CFR-2011-title40-vol8-part61.xml http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol8/xml/CFR-2011-title40-vol8-part61.xml http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol8/xml/CFR-2011-title40-vol8-part61.xml http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol8/xml/CFR-2011-title40-vol8-part61.xml http://cpsc.gov/ http://www.gpo.gov/fdsys/pkg/CFR-2011-title16-vol2/pdf/CFR-2011-title16-vol2-part1305.pdf http://www.gpo.gov/fdsys/pkg/CFR-2011-title16-vol2/pdf/CFR-2011-title16-vol2-part1304.pdf http://www.gpo.gov/fdsys/pkg/CFR-2011-title16-vol2/pdf/CFR-2011-title16-vol2-part1304.pdf http://www.gpo.gov/fdsys/pkg/CFR-2011-title16-vol2/pdf/CFR-2011-title16-vol2-part1304.pdf http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol31/pdf/CFR-2011-title40-vol31-part763-subpartI.pdf

3. Significantly Damaged: >10% localized damage or >25% total damage throughout homogeneous area.

Anytime a condition other than ‘good’ is identified, it shall be reported to the Asbestos Program Manager immediately.

The following OSHA asbestos regulations are applicable and must be followed where appropriate:

1. 29 CFR 1910.1001 General Industry:

a. Employees must not be exposed to asbestos fibers at or above the permissible exposure level (PEL) as per 29 CFR 1910.1001(c).

b. Employees must be notified of ACM/ACBM in the area as per 29 CFR 1910.1001(j).

c. If exposure limit reaches the PEL, proper procedures must be followed as per 29CFR 1910.1001(e) and (f).

d. If entry into this area is required, then 29 CFR 1910.1001(g), (h), (i), and (l) must be followed.

2. 29 CFR 1926.1101 Construction:

a. Pertains to construction projects, repair operations, etc. as defined in 29 CFR 1910.12(b). Also includes housekeeping during and right after construction.

b. There are different procedures according to the class of asbestos work as defined in 29 CFR 1926.1101 ‘ASBESTOS’; Class I, II, III, and IV which must be followed. See below.

c. If work is class I, II, or III, then the area must be regulated as per 29 CFR 1926.1101(e).

d.…