Attachment 1 Appendix C - Hazardous Materials.docx

Appendix C: Hazardous Material

1. Asbestos

a. Design:

i. The Asbestos survey provided by the VA is for informational purpose only. It is the responsibility of the A/E to engage an Asbestos consultant, licensed in the State of Florida pursuant to FS Chapter 469, to perform verification of existing conditions and develop abatement specifications prior to any renovation or demolition activities. The AE shall perform destructive testing, as needed, in compliance with NESHAP 40 CFR Part 61 subpart M. The design team shall verify the exact location of RACM and approximate quantity of material to be abated.

ii. The design team shall use the VA master specification guidelines 02 82 11 for the preparation of the Asbestos abatement specification. Each specification must include CADD drawings indicating the location of RACM to be abated, haul-out route, special conditions, and ICRA compliance.

iii. The A/E shall secure the services a Certified Industrial Hygienist (CIH) to provide expertise in all aspects of identifying, assessing, and making recommendations concerning the management of asbestos and/or lead. Recommendations will be based on, but not limited to; field investigations, sampling, monitoring, laboratory analysis, review of specifications, drawings, etc. The CIH shall be a current member of the American Industrial Hygiene Association and maintain current certification on comprehensive practice. In addition, the CIH shall possess current licensure as asbestos / lead consultant as stipulated in Chapter 469 of Florida Statutes (See Appendix C, Section 2 for more details on lead). Results obtained from these findings will be used by the A/E and CIH to finalize / complete drawings, phasing schedules and specifications which will specify the location and proper procedures for the removal, storage, transportation, disposal, and/or safety precautions to be used when working with asbestos / lead substances (See Appendix C, Section 2 for more details on lead). The CIH will coordinate his/her work with the A/E. The CIH’s professional judgment and expertise will provide for a complete, thorough and safe construction contract.

Task D1: Visually inspect areas impacted by the project in order to identify ACM, PCB and/or lead. This will include the sampling of suspected ACM, PCB and/or lead in accordance with AHERA protocols for sampling and number of samples (See Appendix C, Section 2 and Section 3 for more details on lead and PCB). Conduct interviews with station personnel and review building records available (Drawings and Specification) to assist in identifying of asbestos / lead containing material.

Task D2: Based on the results of Task 1, Develop a sampling strategy to:

Sample suspect ACM / lead using AHERA sampling protocols (i.e., develop homogeneous areas) and analyze for potential ACM by approved identification methods at a laboratory participating in the EPA Asbestos Bulk Sample Quality Assurance Program (See Appendix C, Section 2 for more details on lead). Although asbestos fibers can be recognized through optical microscopy, precise identification of the type asbestos (e.g. –crocidolite, amosite and chrysotile) requires three additional methods of asbestos fiber identification, namely:

· Polarized Light Microscopy, as performed by a laboratory of recognized competence.

· X-ray Diffraction, if necessary, as a supplement to the polarized light microscopy.

· Electron Microscopy, if doubt persists following analysis by polarized light microscopy and x-ray diffraction.

A complete, written, signed and dated report of the results must be provided by the laboratory. The laboratory must report the following information for each sample submitted.

· Facility Identification

· Sample Identification

· Percentage of Asbestos Present

· Type of Asbestos Present

· Methods used to analyze the Sample

· Type of Other Fibrous Materials Present in the Sample

Analysis of samples will follow the AHERA requirements for analyzing samples of ACM / Lead from the same homogeneous area (See Appendix C, Section 2 for more details on lead).

Task D3: After reviewing the sampling test analyses for asbestos / lead determine the most appropriate approach (removal, transportation or disposal) for managing ACM / PCB / Lead identified (See Appendix C, Section 2 for more details on lead). If available data is not adequate, perform more sampling and testing and then proceed as above. The CIH will be required to provide professional judgment as to the number of additional samples required if any and this should be contained in the CIH’s proposal.

Task D4: Prepare an exposure report reflecting the results of Tasks 1, 2, and 3. Detail in a report which areas are deemed “hazardous” requiring full protective measures during abatement. For each location include information of specific abatement action, cost of abatement and schedule for completion. Submit this document certified, signed and dated with a cover statement that reflects your findings and recommendations on the project and is in accordance with VA policy and best abatement practice of asbestos abatement is required.

Concurrently with the completion of Task 4 the A/E shall submit a CIH furnished detailed cost proposal to do Tasks 5 through 10 below.

Task D5: Design and specify appropriate techniques and approaches for the execution of work. This submission shall be thorough enough to provide a contractor clear and specific instructions for locations, removing, transporting, disposing, phasing of work, work area preparation and insure maximum protection measures for himself/herself, visitors, patients, employees, or other personnel in or around the work site during the construction phase.

Determine for each typical case how the abatement will be accomplished including entry and exit facilities if required, toilet facilities and other measures that may be required. The CIH will ensure that the Federal Register, OSHA, EPA, State of Florida and VA Standards are complied with in the removal, storage, transportation and disposal of asbestos and that the strictest requirements take precedence. The VA will provide the CIH with existing VA Circulars and specifications on asbestos removal. The CIH shall use his/her professional judgment in applying that appropriate warnings and the asbestos locations are identified for A/E inclusion drawings and develop the necessary specifications and certify both.

b. Construction Period Services

i. During the construction phase, the A/E firm will be responsible for securing the services of an independent Industrial Hygienist and a Certified Industrial Hygienist, to act as the VA Professional Industrial Hygienist (VPIH) and the VA Certified Industrial Hygienist (VPCIH) in compliance with the VA specification section 2.2.1.B.

ii. The VPIH/CIH will perform the necessary monitoring, inspection, testing, and other support services to ensure that VA patients, employees, and visitors will not be adversely affected by the abatement work, that the abatement work proceeds in accordance with these specifications, and that the abated areas or abated buildings have been successfully decontaminated. The work of the VPIH/CIH consultant in no way relieves the Contractor from their responsibility to perform the work in accordance with contract/specification requirements, to perform continuous inspection, monitoring and testing for the safety of their employees, and to perform other such services as specified. The cost of the VPIH/CIH and their services will be borne by the VA except for any repeat of final inspection and testing that may be required due to unsatisfactory initial results. Any repeated final inspections and/or testing, if required, will be paid for by the Contractor.

iii. The VPIH/CIH shall be responsible for review and approval of the abatement contractor Asbestos hazard abatement plan.

iv. Scope of Services of the VPIH/CIH Consultant

a. The purpose of the work of the VPIH/CIH is to: assure quality; adhere to the specification; resolve problems; prevent the spread of contamination beyond the regulated area; and assure clearance at the end of the project. In addition, their work includes performing the final inspection and testing to determine whether the regulated area or building has been adequately decontaminated. All air monitoring is to be done utilizing PCM/TEM. The VPIH/CIH will perform the following tasks:

Task C1: Assist VA to evaluate qualifications of asbestos abatement contractor and personnel by establishing minimum qualifications requirements for specialized experience, key personnel, standard operating procedures, etc.

Task C2: Establish background levels before abatement begins by collecting background samples. Retain samples for possible TEM analysis.

Task C3: Perform continuous air monitoring, inspection, and testing outside the regulated area during actual abatement work to detect any faults in the regulated area isolation and any adverse impact on the surroundings from regulated area activities.

Task C4: Perform unannounced visits to spot check overall compliance of work with contract/specifications. These visits may include any inspection, monitoring, and testing inside and outside the regulated area and all aspects of the operation except personnel monitoring.

Task C5: Provide support, such as evaluation of submittals from the Contractor, resolution of conflicts, interpret data, etc., to the VA representative.

Task C6: Perform, in the presence of the VA representative, final inspection and testing of a decontaminated regulated area at the conclusion of the abatement to certify compliance with all regulations and VA requirements/specifications.

Task C7: The CIH is responsible for the preparation of all notification requests for the Department of Veterans Affairs by preparing same for the VA to submit officially e.g. 40 CFR part 61 sections 61.140, 61.141, 61.145, 61.146, 61.147 and 61.152. In addition, no later than 30 days prior to the beginning of asbestos / PCB / lead abatement, in the form titled “Notice of Asbestos / Lead Renovation or Demolition” shall be completed by the CIH or an agent working under his/her direction. The completed form shall be mailed to:

Florida Department of Environmental Protection Attn: Asbestos / Lead Contact 7825 Bay Meadows Way, Suite B-200 Jacksonville, FL 32256-7590

The notification form shall be completed and submitted in accordance with the provisions of Rule 62-257, Florida Administrative Court.

Task C8: Issue certificate of decontamination for each regulated area and project report.

b. All documentation, inspection results, and testing results generated by the VPIH/CIH will be available to the Contractor for information and consideration. The Contractor shall cooperate with and support the VPIH/CIH for efficient and smooth performance of their work.

c. The monitoring and inspection results of the VPIH/CIH will be used by the VA to issue any Stop Removal orders to the Contractor during abatement work and to accept or reject a regulated area or building as decontaminated.

2. Lead

a. Design:

The owner does not presently have a Lead Paint survey of the facility. It is the responsibility of the design team to engage an EPA-certified Lead Based Paint consultant, pursuant to 40 CFR 745.226, to perform verification of existing conditions to identify any Lead based paint and/or Lead containing paint and develop abatement specifications prior to any renovation or demolition activities. The design team shall perform Lead Based/Containing paint testing utilizing X-Ray Fluorescence (XRF) lead analyzer in accordance with its XRF Performance Characteristic Sheet issued by HUD to measure the level of lead in the paint. The requirements of ASTM E 2119, “Standard Practice for Quality Systems for Conducting In Situ Measurements of Lead Content in Paint or Other Coatings Using Field-Portable X-Ray Fluorescence (XRF) Devices,” or its HUD- approved equivalent, shall be used to measure the lead contend in the paint. Any test results which falls within the inconclusive range of the XRF or below 1 mg/cm2 must be confirmed by paint chip sampling. Paint chip samples must be analyzed by an NLLAP-certified lab.

The design team shall use the VA master specification guidelines 02 83 00 for the preparation of the Lead abatement specification. Each specification must include CADD drawings indicating the location of Lead Based paint and Lead containing paint. The specification must ensure compliance with EPA 40 CFR 745 and OSHA 1926.62.

b. Construction Period Services During the construction phase the A/E firm shall secure the services of a VPIH/CIH to oversee the Lead paint abatement activity to ensure compliance with the specification 02 83 00. The VPIH/CIH shall be responsible for the following:

· Certifying Training.

· Reviewing and approving lead-containing paint removal plan for conformance to the applicable referenced standards.

· Inspecting lead-containing paint removal work for conformance with the approved plan.

· Ensuring that the contractor is in compliance with 29 CFR 1910.134, 29 CFR 1910.1025, and 29 CFR 1926.62

· Direct monitoring.

· Ensuring work is always performed in strict accordance with specifications.

· Ensuring hazardous exposure to personnel and to the environment are always adequately controlled.

· Performing all required final visual inspections to ensure the work area has been properly decontaminated. The VPIH/CIH may also be required to perform wipe clearance testing as needed.

3. Polychlorinated Biphenols (PCB) & Mercury Lamps

[This project involves the elimination of all PCB containing materials from [lamps, ][equipment] [and] [electrical distribution systems]. Edit and submit [UFGS 02 84 16, Handling of Lighting Ballasts and Lamps Containing PCBs and Mercury.] [ UFGS 02 84 33, Removal and Disposal of Polychlorinated Biphenyls (PCBs).]

PCB oil-filled or running capacitors are predominantly, but not exclusively, found in air conditioners, fluorescent light ballasts, dehumidifiers, submersible pumps, mercury vapor lamps, copy machines and electrical control panels. It is the responsibility of the design team to verify if any PCB exists within their scope of work. Any capacitors that is not labelled as non-containing PCB must be assumed to contain PCB and be removed accordingly. Usually, capacitors manufactured after 1979 do not contain PCB oil, however, it is the responsibility of the design team to verify the content of these capacitors.

EPA regulations require the use of DOT-approved 55-gallon drums for disposal of PCB capacitors once they are removed. Drums should contain absorbent material (speedi-dry or kitty litter) at the bottom in case some of the capacitors are damaged or leaking. There should be a PCB ML label placed on each drum that contains PCB capacitors. Drums should be sealed and stored in a secure area that would minimize inadvertent damage or vandalism.

Leaking capacitors should be stored in a separate drum from intact capacitors. Intact capacitors can be stored until the drum is full while leaking capacitors must be disposed within 30 days.

In addition, caulking and expansion joints manufactured between 1950 and 1978 may contain PCB. It is the responsibility of the design team to test any caulking or expansion joints in any building constructed prior to 1978. If PCB containing materials are discovered, they must be properly abated and disposed of.

A permitted transporter must be contracted to haul PCB waste and dispose of drums filled with capacitors. Records must be maintained including the date of pick-up, the number of drums, names of transporters, and destination of the PCB waste for disposal.

4. Low Level Radioactive Material

Some building materials, such as exit signs and smoke detectors, may contain LLR sources. The design team shall be responsible for the identification of any sources of LLR within the scope of their work and the preparation of specification for the removal, transportation, and disposal of the waste. The Florida Department of Health regulates use, transportation, and disposal of radioactive waste in Florida under an agreement with Nuclear Regulatory Commission (NRC). The design team shall be responsible to ensure that the removal and disposal for LLR is in compliance with Florida Statutes Chapter 404 regulating radioactive materials.

5. Animal Droppings At this time, the owner is not aware of any animal infestations within their buildings. It is the responsibility of the design team to investigate any potential animal infestation within their scope of work area. Animal infestations in Florida mainly include bats and pigeons. It is important to note that some species of bats are protected. If any animal infestation is detected, the design team shall prepare exclusion techniques such as netting, baiting, or trapping and releasing. The design team shall also prepare anti-infestation measures to ensure prevention of re-infestation.

The design team shall also be responsible for the preparation of specification for clean-up and decontamination efforts of bat and pigeon guano.

6. Mold and Spores

The design team may encounter biological growth in areas scheduled for renovation. It will be the responsibility of the design team to engage a Florida-licensed mold assessor pursuant to FS 468.8411 to perform a microbial assessment survey to identify extent of contamination and sources of water-damaged material. The design team shall be responsible for identifying the location of mold growth on building materials and preparing specification and CADD drawings for mold remediation in accordance with VA Master Specification Section 02 85 00 “Mold Remediation”.

During the construction phase, the A/E team shall be responsible for securing the services of a Certified Mold Assessor firm to oversee all work performed by the abatement contractor to ensure compliance with the mold abatement specification.

The VPIH/CIH shall be responsible for reviewing and approving the contractor’s mold remediation plan, as well as continuous monitoring of the work area and pressure differential to ensure compliance with the specification.

The VPIH/CIH shall also be responsible for conducting a post-remediation visual inspection and clearance of the work area to ensure the area was properly cleaned and decontaminated. In some instances, the VPIH/CIH may also perform post-remediation air samples to verify that the environment within the work area is suitable for re-occupancy.

The VPIH/CIH shall submit a final report certifying the microbial remediation is complete

7. Radon

The design team must engage a licensed Radon measurement business to perform Radon testing as needed of any new structure or after any major renovations. The business must be licensed by the Florida Department of Health pursuant to Florida Administrative code 64E-5.1206.

Testing for Radon must follow all applicable Department of Health protocol for sampling as stated in the latest revisions to section FS 404.056(5). Facilities only located in counties with intermediate or elevated radon potential shown on the Department of Community Affairs “new construction and/or large buildings” radon protection maps will require testing. New construction, or buildings that have undergone significant structural changes, will require testing by July 1 following the date of occupancy or licensing. The design team shall fill out the required forms (DH form 1777) and submit directly to the DOH. If the design team discovers any elevated levels of Radon, they will be required to engage the services of a Radon mitigation business licensed in State of Florida pursuant to Florida Administrative Code 64E-5.1207, to mitigate the elevated levels.

8. Storage Tanks The design team shall be responsible for identifying any underground and/or above ground storage tanks (UST/AST) within their scope of work. The design team must ensure that these tanks are in compliance with Florida Department of Environmental Protection (FDEP) rules and regulations per Florida Administrative Codes (F.A.C.), Chapter 62-770 Petroleum Contamination Site Cleanup Criteria, Chapter 62-761 Petroleum Storage Systems and Chapter 62-777 Contaminant Cleanup Target Levels. Chapter 62-761 provides standards for underground storage tank systems having individual storage tank capacities greater than 110 gallons, and aboveground storage tank systems having individual storage tank capacities greater than 550 gallons. In addition to secondary containment standards, additional requirements need to be met for the registration, construction, installation, operation, maintenance, inspection, repair, closure, and disposal of storage tank systems. By December of 2009 all storage tank systems shall meet the performance standards of Rule 62-761.500, F.A.C., or be permanently closed in accordance with Rule 62-761.800(3), F.A.C.

9. Contaminated Soil and Ground Water

The owner is not aware of any soil or groundwater contamination at their facility. However, the owner does own several above ground storage tanks and has already removed several underground storage tanks in the past. If the design team suspects there is any potential for soil or groundwater contamination within their scope of work, then they will be responsible for ensuring compliance with RCRA 40 CFR Part 260. The design team may be required to perform subsurface investigation of soil and groundwater sampling and install monitoring wells as needed. In the case that any soil and/or groundwater contamination is discovered, the design firm shall be responsible for the preparation of a remedial action plan and coordination with the regulators for approval of the plan and oversight of any remedial action performed by a remediation contractor, as well as preparation of all closure documents and submittal to DEP for approval.