Attachment 5 Brockton - Volume 1 Rpt.pdf

VOLUME I

GENERAL ASBESTOS/LEAD CONTAINING

PAINT SUMMARY REPORT

VISN 1

Brockton VA Medical Center

940 Belmont Street Brockton, MA 02301

Project No. 2009023.003

June 21, 2010

5 Alfred Circle Bedford, MA 01730-2318

Telephone: (781) 275-6050 Toll Free: (800) 877-6050 Facsimile: (781) 275-5651 info@mabbett.com www.mabbett.com

© 2010, Mabbett & Associates, Inc.

©2010, Mabbett & Associates, Inc. i Brockton - Volume 1 Text FINAL 6-21-10.doc

ACKNOWLEDGMENT

This Asbestos Containing Materials (ACM) and Lead Containing Paint (LCP) Survey Report was prepared for the Veterans Affairs (VA) New England Healthcare System (VISN1) in accordance with an established scope of work as defined in Contract Number VA241-P-1653. The information presented herein is based on the facts and information conveyed to or received by Mabbett & Associates, Inc. (M&A) during the preparation of this report. If any of the information provided to M&A that was used in preparing this report is incorrect, incomplete, or subject to change, M&A would wish to alter its opinion(s) accordingly. In addition, the professional opinions and information contained in this report are based solely on the requirements of the applicable regulations and technical data as of the date of this report and considered applicable to this report.

This report was prepared by the following Mabbett & Associates, Inc. personnel:

MABBETT & ASSOCIATES, INC.

BY:

Michael F. Delaney Project Manager Massachusetts Asbestos Inspector AI031436 Massachusetts Management Planner AP000048

This report has been reviewed and approved by:

Robert K. McKinley, MPH, CIH, LIH Director of Industrial Hygiene Services Massachusetts Asbestos Inspector AI000314

©2010, Mabbett & Associates, Inc. ii Brockton - Volume 1 Text FINAL 6-21-10.doc

TABLE OF CONTENTS

Volume I - General

Chapter 1 - Introduction and Executive Summary Chapter 2 - Asbestos Operations & Maintenance (O&M) Manual Chapter 3 - Asbestos Containing Materials (ACM) Survey Tables Chapter 4 - Lead Containing Paint Screening Survey Tables

Volume II – Individual Building Reports

Individual Building Reports Chapters including:

• Cover page with building number

• Building narrative summary

• Floor plans

• Relevant asbestos findings for the building

• Relevant lead containing paint findings for the building

• Relevant photos

Volume III – Appendices and Supporting Data

Appendix A - Asbestos Laboratory Analysis Reports and Laboratory Certifications Appendix B - Inspector Field Data Sheets/Chains-of-Custody Appendix C - Personnel Certifications & Licenses Appendix D - XRF Performance Characteristics/Calibration Records Appendix E - Lead Laboratory Analysis Reports and Laboratory Certifications (if applicable)

Volume IV – HUD Residential LBP Reports (If Applicable)

©2010, Mabbett & Associates, Inc. iii Brockton - Volume 1 Text FINAL 6-21-10.doc

VOLUME I – CHAPTER 1

Description Page

INTRODUCTION & EXECUTIVE SUMMARY

Executive Summary Scope Previous Report Summary Asbestos Survey Summary Lead Containing Paint Screening Survey Summary

LIST OF TABLES

Table 1 List of Screened/Survey Buildings Table 2 List of Building not Screened/Surveyed Table 3 List of Buildings where No Samples were Collected Table 4 Previous Report Summary Table 5 Summary of Duplicate Bulk Sample Results Table 6 Buildings Surveyed Where ACM was Not Identified Table 7 Buildings Surveyed Where ACM was Identified Table 8 Summary of Damaged Asbestos Containing Materials Table 9 Summary of ACM Quantities for Liability Report Table 10 Buildings Screened Where LCP in Concentrations Greater than the VISN 1

Threshold of 0.1 mg/cm2 was not Identified Table 11 Buildings Screened Where LCP in Concentrations Greater than the VISN 1

Threshold of 0.1 mg/cm2 was Identified

ATTACHMENTS

Attachment A Supporting Documentation

CHAPTER 1

INTRODUCTION & EXECUTIVE SUMMARY

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 1 of 9 Brockton - Volume 1 Text FINAL 6-21-10.doc

INTRODUCTION & EXECUTIVE SUMMARY

Executive Summary

Mabbett and Associates, Inc. (M&A) with Covino Environmental Associates, Inc. (Covino) as sub-contractor (i.e. the M&A Team) performed an asbestos-containing materials (ACM) and lead containing paint (LCP) screening inspection survey of the VA Medical Center (VAMC) located at 940 Belmont Street in Brockton, Massachusetts under contract VA241-P-1653. Site survey work was performed during February and March, 2010 by appropriately credentialed personnel. No US Housing and Urban Development (HUD) residential LCP Surveys were performed. During the course of the survey phase, 1,962 of the 2,242 bulk samples collected were analyzed for asbestos content.

Materials consisting of multiple layers were analyzed separately. 2,874 lead readings including calibration readings were collected from the buildings surveyed during the LCP screening survey.

This report, including individual Building Reports (Volume II), is the product of the M&A Team’s effort.

The Report consists of three volumes: Volume I – General, which is the main Project Report, containing the complete set of analytical findings tables for the ACM and LCP screening surveys, and the Asbestos Operations and Maintenance (O&M) Manual. Volume II - Individual Building Reports, containing floor plans indicating ACM sample locations and findings information, detailed analytical findings for the specific surveyed building, and relevant photos; and Volume III – Appendices/Supporting Data, including laboratory results and field data sheets.

Scope

The following VAMC buildings listed in the table below were included in this scope of work for ACM and LCP screening surveys:

Table 1 - List of Screened/Surveyed Buildings – Brockton, VAMC

Bldg No. Function Title Year

Built Year of

Renovation Leased No. of Floors

Total Gross Square

Footage (ft2) 1 Administration 1955 - N 3 50,095

1CC Connecting Corridors 1955 - N 1 25,200 2 Inpatient Psychiatry 1955 1989 N 5 183,100 3 Outpatient 1955 - N 7 228,766 4 Nursing Home 1955 1997 N 3 117,608 5 Outpatient Psychiatry 1955 1998 N 3 81,489

7 Domiciliary/Out- Leased 1955 1986 N 3 113,504

8 Spinal Cord Injury 1955 1965 N 2 75,422 20 Kitchen / Warehouse 1955 - N 2 55,881 22 Recreation / Library 1955 - N 2 30,572 23 Gym / Pool 1955 - N 1 40,957 24 Chapel 1955 - N 2 15,720 25 CWT Storage 1955 - N 1 21,140 28 HazMat Storage* 1990 - N 1 160 40 Boiler Plant 1955 1997 N 1 4,500 43 Welding 1955 - N 1 400

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 2 of 9

Table 1 - List of Screened/Surveyed Buildings – Brockton, VAMC

Bldg No. Function Title Year

Built Year of

Renovation Leased No. of Floors

Total Gross Square

Footage (ft2) 44 Station Garage 1955 1990 N 1 7,140 45 VISN Laundry 1955 1990 N 2 22,639 46 Research 1955 1985 N 1 5,567 47 Water Pump House 1955 - N 1 200 50 Sewer Pump House 1955 - N 1 150 51 Storage 1960 - N 1 2,640

60 Substance Abuse Outlease 1920 1955 N 1 17,185

61 IRM 1955 - N 3 13,646

62 RISE Drug Treatment 1955 - N 1 6,784 64 Picnic Building 1955 - N 0 - 65 Vacant Greenhouse 1955 - N 1 2,348 67 Generator Building 1975 1984 N 1 704 68 Generator Building 1979 - N 1 360 69 Generator Building 1979 - N 1 360 70 Generator Building 1979 - N 1 360 71 Switchgear Building 1979 - N 1 200 72 Generator 1998 - N 1 400

*No suspect ACMs or painted surfaces were identified.

The following buildings listed in the table below were not included in this survey for the reasons indicated:

Table 2 - List of Buildings not Screened/Surveyed – Brockton, VAMC

Bldg.

No. Function Title Year Built Leased

Total Gross Square

Footage (ft2)

Reason for not screening or surveying

21 Theater 1955 No 39,736

Eliminated from survey by Bill Kulas (COTR) during pre-survey conference call on

February 3, 2010 since building poses a safety hazard and will be demolished. A full NESHAP survey will be done prior to demolition by another contractor per Peter Lopes.

63 Storage Garage 1955 No 1,632 Building no longer exists

The following leased facilities were visually screened for ACM, but no samples were collected.

Certification from the building owners attesting that no ACM is present were provided and are included in Attachment A. LCP surveys of leased facilities were not included in the scope of services

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 3 of 9 of this contract. The facility listed in the table below will be surveyed for ACM when and if authorization is received from VISN 1 and the building owner(s):

Table 3 - List of Buildings Visually Surveyed With No Samples Collected – Brockton, VAMC

Bldg.

No. Function Title Year Built Leased

Total Gross Square

Footage (ft2) Reason Not Sampled

104V Brockton Vet Center

Not Provided Y 3,270

Leased facility. M&A is waiting on signed agreement from owner prior to sample collection.

Any supporting documentation from the building owners is provided in Attachment A.

Previous Report Summary

The VA provided previous Asbestos Survey Reports that have been listed in the table below. No LCP or ACM O&M Plans were made available. It should be noted, that it was not the intent of M&A to confirm the accuracy of the provided reports, but rather to use the provided reports as a guide while conducting the asbestos survey.

Table 4 - Previous Report Summary – Brockton, VAMC

Date Firm Title

June, 1995 Universal Engineering Corporation

Final Report for the Asbestos Update Survey:

Brockton Buildings, Jamaica Plain Buildings, and

Brockton Buildings

September 6, 2004 Kendall Taylor & Company, Inc. 2004 Consolidated Asbestos Survey, Brockton, MA 02132

Asbestos Survey Summary

To determine the locations of suspect building materials, a visual inspection was conducted by Massachusetts Licensed Asbestos Inspectors in buildings listed in Table 1.

Only areas that were accessible during the field work phase were sampled. Areas which were inaccessible were indentified in the individual building reports. Suspect ACM material that may be present within the walls, above inaccessible hard ceilings, or in other inaccessible locations, that was not sampled should be assumed to contain asbestos if discovered during any renovation process or until otherwise verified. To avoid impacting any existing roof warranties, no destructive sampling of roofing materials was included in this survey, and suspect roofing material should be assumed to be ACM until sample results prove otherwise.

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 4 of 9

Sampling and inspections were performed in general accordance with US Environmental Protection Agency (EPA) Asbestos Hazard and Emergency Response Act (AHERA) protocols.

The Polarized Light Microscopy (PLM) analytical protocol requires each layer of the sample to be analyzed separately. The quantity of analyses will vary based on the number of layers in a sample and whether a "positive stop" is employed. A positive stop is used when one sample of a homogeneous area is positive, the remainder of the samples were not be analyzed because the entire homogeneous area is considered positive as indicated on the results tables and drawings.

The bulk asbestos samples collected were submitted under chain of custody procedures to ProScience Analytical Services, Inc. (ProScience) of Woburn, MA for polarized light microscopy (PLM) analysis of bulk materials via EPA 600/R-93/116 Method. ProScience is accredited by the American Industrial Hygiene Association (AIHA) and participates in the National Voluntary Laboratory Accreditation Program (NVLAP Lab Code 200090-0). Duplicate bulk samples were submitted to Covino Environmental Associates, Inc. (Covino). Covino is accredited by the American Industrial Hygiene Association (AIHA) and participates in the National Voluntary Laboratory Accreditation Program (NVLAP Lab Code 101781-0). Copies of the laboratory analysis reports and accreditations are included in Appendix A, Volume III of the Comprehensive VAMC Lead and Asbestos Survey Report.

Table 5 - Summary of Duplicate Bulk Sample Results

Building No.

Sample No. Description of Material

Percent and Type of Asbestos reported by

ProScience

Percent and Type of Asbestos reported by Covino 19A 12”x12” Tan Floor Tile 2% Chrysotile 8% Chrysotile

20A 12”x12” Tan Floor Tile Mastic 10% Chrysotile 10% Chrysotile

2 16A HVAC Flex Connectors NAD NAD

3 13A Transite Panel 30% Chrysotile 25% Chrysotile

14A 12”x12” Pink Floor Tile NAD NAD

15A 12”x12” Pink Floor Tile Mastic Trace 5% Chrysotile

7 29A Window Caulk NAD NAD

20 30A 1’x1’ Ceiling Tile Mastic NAD NAD

22 9A 2’x2’ Ceiling Tile (Large Fissured) NAD NAD

3A 9”x9” White Floor Tile 2% Chrysotile 8% Chrysotile

4A 9”x9” White Floor Tile Mastic 5% Chrysotile 5% Chrysotile

24 6A Carpet Mastic NAD NAD

43 1A Door Caulking 2% Chrysotile 4% Chrysotile

44 9A Interior Window Glazing NAD NAD

45 2A Tan Fire Stop NAD NAD

46 9A Tan Duct Sealant NAD NAD

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 5 of 9

Table 5 - Summary of Duplicate Bulk Sample Results Brockton VA Medical Center

Building No.

Sample No. Description of Material

Percent and Type of Asbestos reported by

ProScience

Percent and Type of Asbestos reported by Covino 50 1A Window Glazing NAD NAD

60 25A 4” Covebase Mastic NAD NAD

70 8A Sprayed-on Insulation NAD NAD

72 1A Tank Insulation NAD NAD NAD – No Asbestos Detected All results considered acceptable per the SOP.

Of the buildings surveyed for ACM, the following buildings had no ACM identified based on the results of the surveys of accessible locations and analytical results for sample collected which were all reported by the laboratory as “No Asbestos Detected” (NAD) for these buildings. See individual building reports for specific sample locations, building drawings, and results:

Table 6 - Buildings Surveyed Where ACM was Not Identified

Building 28 Building 64 Building 67 Building 68 Building 69 Building 71 Building 72

The following buildings had ACM identified during the survey based on the analytical results provided by the laboratory. See individual building reports for specific sample locations, building drawings, and results:

Table 7 - Buildings Surveyed Where ACM was Identified

Building 1 Building 1CC (Tunnels)

Building 2 Building 3 Building 4 Building 5 Building 7 Building 8

Building 20 Building 22 Building 23 Building 24 Building 25 Building 40 Building 43 Building 44 Building 45 Building 46 Building 47 Building 50 Building 51 Building 60 Building 61 Building 62 Building 65 Building 70

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 6 of 9

The Asbestos O&M manual prepared by a Massachusetts Licensed Asbestos Management Planner found in Volume I - Chapter 2 of the Project Report satisfies the Occupational Safety and Health Administration (OSHA) compliance requirements for employee safety and for management of asbestos identified at the facility. This O&M manual contains the asbestos survey results, background information on asbestos, an introduction to the O&M program, information on implementing the O&M program, O&M work practices, O&M incident and emergency work practices and O&M surveillance and documentation practices. It is M&A’s understanding that asbestos removal and replacement procedures will be performed by asbestos abatement contractors rather than training in-house personnel to perform these tasks. The O&M manual reflects this understanding.

During preparation of renovation activities, the VAMC should review the Asbestos O&M Manual and specific building reports to determine if asbestos-containing materials will be disturbed by the proposed renovations. The VAMC should also assume materials not previously sampled due to accessibility, etc. which will be impacted by renovation activities to be asbestos-containing materials unless otherwise determined. If asbestos containing materials must be disturbed as a part of the renovations, ACMs must be removed by a Massachusetts Licensed Asbestos Abatement Contractor and proper notification to the Massachusetts Department of Environmental Protection be made as required. In the event of the disturbance of an asbestos containing material, the facility Asbestos Program Manager shall decide if the disturbance is considered an incident or an emergency and shall follow the guidelines of the attached Operations and Maintenance Manual, listed in Chapter 2, Section 8.0.

Continuous monitoring shall be performed by the facility Asbestos Program Manager or qualified representative during renovation activities and on a semi-annual basis as described in Section 9.0 of the attached Operations and Maintenance Manual. At a minimum, the continuous monitoring shall include a visual inspection and documentation of the asbestos containing materials to assess if the materials have become friable and/or damaged. Additionally, prior to commencing renovations, all contractors involved with the renovations should be made aware of the location and quantity of ACMs within the building in which they will be working.

If any asbestos containing material is damaged or becomes damaged it should be repaired, if possible, or removed entirely. Materials classified with a high potential for disturbance as identified in the tables should be removed or repaired immediately upon discovering damage to the material especially when located in occupied areas.

The VISN 1 AHERA hazard assessment scale 1 – 4 is a relative indicator of the risk and need for response/remediation. (1) represents the highest priority (e.g. removal or encapsulation) where as a (4) represents the lowest priority (monitor as part of 6 month O&M program). The rating assigned by an Asbestos Management Planner, takes into account: condition, friable vs. non-friable, accessibility, occupancy (e.g. continuous, intermittent or occasional and patients/staff/visitors), potential for air erosion, potential for vibration damage, potential for disturbance / damage (e.g. exposed and in an accessible location), and potential for water damage.

Based on the visual observations of this survey, the items listed in Table 8 below were identified as having a VISN 1 AHERA Risk Hazard Category rating of 1 (damaged condition):

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 7 of 9

Table 8 - Summary of Damaged Asbestos Containing Materials

Bldg No.

Sample No.

ACM

Location

ACM

Description

Laboratory Results Condition Estimated

Quantity

VISN 1

RISK

AHERA

Hazard

Category No ACM was identified at the time of the survey with a risk rating of 1.

The VAMC must submit a quarterly ACM liability report. At the time of the survey the following quantities of ACM were identified and should be included in the liability report until removed from the building.

Table 9 – Summary of ACM Quantities for Liability Report

General Description of Material Estimated Quantity

Flooring Tile and/or Mastic 225,435 SF

Sheet Flooring and/or Mastic 9,635 SF

Pipe Insulation 4,171 LF

Window Caulking 28,208 LF

Window Glazing 5,308 LF

Door Caulking 1,500 LF

Building Caulking 1,761 LF

Transite Panel at Radiators 11,476 SF

Black Damp Proofing 115,000 SF

SF – Square Feet LF – Linear Feet

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 8 of 9

Lead Containing Paint Screening Survey Summary

M&A performed the LCP screening using lead screeners as identified in the VISN 1 approved Standard Operating Procedure (SOP). The purpose of the screening was to identify patterns of LCP and to not identify all LCP building components. LCP screening consisted of walking through each building to observe accessible areas for the presence of suspect painted surfaces that may include LCP, then selecting painted surfaces representative of major building components in each building to be tested including but not limited to windows, doors, walks, floors, etc. Lead containing paint screenings were performed in the buildings listed in Table 1 of this document.

Buildings where LCP screenings were not performed are listed in Table 2 and Table 3 of this document.

2,874 representative X-Ray Fluorescence (XRF) readings, from different painted surfaces in the listed buildings, were taken during the screening including calibration checks. Per VISN 1 non-painted structural elements such as glazed tile, glazed block, stained glass, and painted equipment, furniture, etc., were not included in the screening surveys although those items may have lead present. Because the OSHA standard for lead exposure in construction is applicable for lead present in paint at any level, for the purposes of this inspection a painted or coated substrate that contains greater than 0.1 mg/cm2 is classified as LCP. A summary of LCP results reported by building are located in each Building Report (Volume II). Tables containing XRF readings collected by building are located in Volume I - Chapter 4 of the Project Report.

Table 10 - Buildings Screened where LCP in Concentrations Greater than the VISN 1 Threshold of 0.1 mg/cm2 was not Identified Building 28* Building 67 Building 69 Building 72

*no painted surfaces identified

The following buildings had LCP identified in accessible locations during the survey based on the analytical results provided by the XRF. See individual building reports for specific sample locations, building drawings, and results:

Table 11 - Buildings Screened where LCP in Concentrations Greater than the VISN 1

Threshold of 0.1 mg/cm2 was Identified Building 1 Building 1CC (Tunnels) Building 2 Building 3 Building 4 Building 5 Building 7 Building 8

Building 20 Building 22 Building 23 Building 24

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 9 of 9

Table 11 - Buildings Screened where LCP in Concentrations Greater than the VISN 1

Threshold of 0.1 mg/cm2 was Identified Building 25 Building 40 Building 43 Building 44 Building 45 Building 46 Building 47 Building 50 Building 51 Building 60 Building 61 Building 62 Building 64 Building 65 Building 68 Building 70 Building 71

ATTACHMENT A

SUPPORTING DOCUMENTATION

(If Applicable)

DRAFT

2010, © Mabbett & Associates, Inc. Page 1 of 3 S:\STAFF\VISN1 Asbestos Lead\Facilities\Brockton\Final PDFs\Vol I\Draft Pre-Survey Checklist Brockton.doc

VISN 1 Lead Based Paint and Asbestos Pre-Survey Conference Checklist Facility: Brockton Date: 2/3/2010 Conference Attendees:

Peter Lopes, Kathy Luciani, Jennifer Burrill, Susan Smits, Mike Delaney, Bill K and Wes joined late

1. Points of Contact (POC) including Safety Manager, FMS, and identified escorts including phone numbers, cell phones, Bldg. and Room #, and e-mail:

Point of Contact: Safety Manager, Kathy Luciani – no pre-mtg required Main Phone Number: _ Room No. - Bldg 1, Cell Phone Number: 617-799-1237 E-mail Katherine.luciani@va.gov (may be more than one – use bhs address Kathy to get key from IRM – need someone to replace her on Monday

Point of Contact: Peter Lopes , FMS contact : Peter will sub out people if Brian & Salo can’t make a certain day Main Phone Number: 774-826-1145 Room: No.bldg 1 room 200 Cell Phone Number: 617-212-4956 E-mail

Point of Contact: GEMS Coordinator, Bryan Soltysik Main Phone Number: Stationed at W.Rox Room No.

Cell Phone Number: E-mail

Point of Contact, ESCORT: Brian Soltysik, HEM Main Phone Number: __________________ Room No.

Cell Phone Number: E-mail

Point of Contact, ESCORT : Salo Birman, BHS IH Main Phone Number: 857-364-5460 Room No. JP Cell Phone Number: 617-799-1509 E-mail

Point of Contact, ESCORT : Kathy Luciani see above

2. Site visit schedule:

• Survey weeks: start Feb 8 for 3 weeks, off on Pres Day

• Pre-survey site visit: Cindy Tibert (infection control)- completed

• Director/Management briefing required? No

3. Review escort requirements: PACU, SICU, MICU, Cardiac cath lab

• Psychiatric ward escort identified? Schedule requirements?

psych ward – bldg 2 had major asbestos project, will need to schedule in advance, will require escort from clinical staff

4. Will escorts have master keys available: Yes No If no then why?

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Except for IRM (bldg1 &3), pharmacy, psych wards – schedule in advance; 46 research, 44 garage attached to research some admin & ltd lab

5. No. of buildings included in the contract per SOW (Table 1) including Building #, date built, leased (Y/N), # floors, and total Sq. ft provided to M&A

Yes No If no then why?

6. Availability of current electronic CADD Plans: Yes No If no then why?

All but Brockton vet center – very close to campus

7. Current Campus map provided to M&A: being emailed to Mike

8. CADD plans provided to M&A: Yes No If no then why?

9. All previous inspection reports including CADD, photos, tables, reports, results, etc.

provided electronically to M&A: Yes No If no then why?

10. Availability of abatement records: Yes No If no then why?

Salo or Bryan

11. Normal work schedule:

Escorts from 7:30 – 4

12. Work hour restrictions for ORs, etc.:

13. Any restricted areas which Team will NOT be able to access i.e. BL3 labs, animal facilities, isolation areas, etc.:

15. Safety Briefing Requirements: Same as W. Rox

• Emergency evacuation signal & meeting place: Code Red, Code Green (psych Brockton), Code Grey

• Medical assistance number: 33333 Police number: 55911

16. Infection Control Meeting Required? Yes per Gavazzi No

a. Requirements

b. Who, when, where?

Cindy Tibert: already met with Cindy

17. Unique facility requirements etc.:

a. Any medical testing requirements in addition to TB tests? Yes No

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18. Unique survey requirements, hazards, etc. (special hazards or unique sampling requirements):

None; most bldgs been through abatements – asbestos primarily in chases above hard ceilings, etc. most friable removed

19. Badging requirements including where, how and what:

a. let Peter Lopes know if you need more or to renew

Availability/Restrictions on parking:

NONE ____________

20. Team workspace location with telephone and internet access:

Will provide – TBD

21. Ladders Provided: Yes No

a. Size & No.: 8 feet

22. List of available VA identified permit required confined spaces provided to M&A:

Crawl spaces, tunnels but no permit required

23. Has VA notified Labor Representatives of survey?: Yes No

General notice sent for BHS, Specific reminder will be sent for Brockton

24. Have the Director and Section Chiefs been notified of purpose of surveys? Yes No

a. Any schedule requirements?

b. Contact person for each Dept? Name, Dept, Bldg, Room # & phone reminder for Brockton to be sent

Misc Notes:

Site meeting Friday 2/5/10 @ 9:00 AM

Start with Bldg 60 – basically empty – will start there

Theatre bldg to be demolished #21 currently closed check to see if on list – Bill would be ok leaving it out if a full NESHAPS will be done prior to demo but there is some IRM storage area in lobby so people do occasionally go in and out of there – Peter thinks we don’t need to survey the bldg – Peter says a full NESHAPs will be done – to be noted in the report – potentially contains ACM but full NESHAPs will be done prior to demo – and is an approved project - go into table into the front and addtl documentation/notes later in report

Wes asked re popping ceiling tiles – Peter can think of only a few areas in Brockton , Brockton people and/or escort will take care of that

Peter has cert on Worcester lease – pg 163 or lease initialed at bottom , lease signed on first page , to be faxed to Susan

CHAPTER 2

ASBESTOS OPERATIONS & MAINTENANCE (O&M) MANUAL

ASBESTOS CONTAINING MATERIALS (ACM)

OPERATIONS AND MAINTENANCE (O&M) MANUAL

VETERANS AFFAIRS MEDICAL CENTER

for

VISN 1

940 Belmont Street Brockton, MA 02301

Project No. 2009023.003

June 21, 2010

PREPARED BY:

5 Alfred Circle Bedford, MA 01730-2318

Telephone: (781) 275-6050 Toll Free: (800) 877-6050 Facsimile: (781) 275-5651 info@mabbett.com www.mabbett.com

© 2010, Mabbett & Associates, Inc.

©2010, Mabbett & Associates, Inc. i Brockton - Volume 1 Text FINAL 6-21-10.doc

ACKNOWLEDGMENT

This Asbestos Containing Materials (ACM) Operations & Maintenance (O&M) Manual was prepared for the U.S. Department of Veterans Affairs, VISN1, Veterans Affairs Medical Center (VAMC) located in Brockton, MA in accordance with an established scope of work as defined in Contract Number VA241-P-1653. The information presented herein is based on the facts and information conveyed to or received by Mabbett & Associates, Inc. (M&A) during the preparation of this manual. If any of the information provided to M&A that was used in preparing this manual is incorrect, incomplete, or subject to change, M&A would wish to alter its opinion(s) accordingly. In addition, the professional opinions and information contained in this report are based solely on the requirements of the applicable regulations and technical data as known to M&A as of the date of this manual and considered applicable to this manual.

This O&M Manual was prepared by the following Mabbett & Associates, Inc. personnel:

MABBETT & ASSOCIATES, INC.

BY:

Michael Delaney Project Manager Massachusetts Asbestos Inspector AI031436 Massachusetts Management Planner AP000048

This O&M Manual has been reviewed and approved by:

Robert K. McKinley, MPH, CIH, LIH Director of Industrial Hygiene Services Massachusetts Asbestos Inspector AI000314

©2010, Mabbett & Associates, Inc. ii Brockton - Volume 1 Text FINAL 6-21-10.doc

Description Page

O&M DIRECTORY

1.0 INTRODUCTION

2.0 PROJECT INFORMATION

3.0 ASBESTOS BACKGROUND

4.0 INTRODUCTION TO THE OPERATIONS AND MAINTENANCE PROGRAM

5.0 IMPLEMENTING THE OPERATIONS AND MAINTENANCE PROGRAM

6.0 OPERATIONS AND MAINTENANCE WORK PRACTICES

7.0 NOTIFICATIONS

8.0 INCIDENT AND EMERGENCY WORK PRACTICES

9.0 O&M SURVEILLANCE AND DOCUMENTATION

10.0 O&M PROCEDURES FOR VARIOUS ASBESTOS-CONTAINING MATERIALS 1

11.0 FUTURE O&M WORK PRACTICES

12.0 QUALIFICATIONS STATEMENT

Appendix A:

ACM Labeling/Signage Procedures Form 1 - Employee Notification Form Form 2 - Employee Awareness Form Form 3 - Contractor Notification Form Form 4 - Asbestos Training Documentation Form 5 - Building Inspection Form Form 6 - Building Re-inspection Form

Attachments:

Building ACM Summary Tables OSHA Occupational Exposure to Asbestos Standard, 29 CFR 1910.1001

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 2 – Page 1 of 21

O&M DIRECTORY

The following is a directory of the personnel involved in the facility's ACM Operations and Maintenance Program. The names are listed in the order in which notifications in the event of an incident or emergency involving ACM should take place.

Title Personnel

1. Asbestos Program Manager Bryan Soltysik, HEM

2. Building Asbestos Coordinator(s) Bryan Soltysik, HEM

3. Asbestos Program Consultants Mabbett & Associates, Inc.

(800) 877-6050

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 2 – Page 2 of 21

1.0 INTRODUCTION

This site-specific O&M Manual is exclusively for the VA, VISN 1, VAMC, Brockton, MA. This manual is limited to the following buildings:

• Building 1 CC – Connecting Corridors

• Building 1 – Administration

• Building 2 – Impatient Psychiatry

• Building 3 – Outpatient

• Building 4 – Nursing Home

• Building 5 – Outpatient Psychiatry

• Building 7 – Domiciliary – Out-leased

• Building 8 – Spinal Cord Injury

• Building 20 – Kitchen/ Warehouse

• Building 22 – Recreation/ Library

• Building 23 – Gym/Pool

• Building 24 – Chapel

• Building 25 – CWT Storage

• Building 40 – Boiler Plant

• Building 43 – Welding

• Building 44 – Station garage

• Building 45 – VISN Laundry

• Building 46 – Research

• Building 47 – Water Pump House

• Building 50 – Sewer Pump House

• Building 51 – Storage

• Building 60 – Substance Abuse Out-lease

• Building 61 – IRM

• Building 62 – RISE Drug Treatment

• Building 65 – Vacant Greenhouse

• Building 70 – Generator Building

The manual includes an O&M directory, project information, a list of the identified ACM and future O&M work practices. A properly conducted O&M Program can be an important asbestos control strategy. However, it is important that everyone involved in the program be committed to implementing it properly.

In addition, this site-specific manual includes background information on asbestos, an introduction to the O&M program, information on implementing the O&M program, O&M work practices, O&M incident and emergency work practices, and O&M surveillance and documentation practices.

Where no VA Brockton specific ACM program O&M procedures, forms, etc. were made available, Occupational Safety & Health Administration (OSHA) guidance and

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 2 – Page 3 of 21 sample documents and templates have been included for the VA’s use and consideration.

2.0 PROJECT INFORMATION

The O&M plan is part of the VA VISN1 ACM and Lead Containing Paint (LCP) Building Surveys. The scope of work as defined under contract number VA241-P- 1653, included asbestos inspections of the above listed buildings (see Section 1.0).

The information provided in this O&M plan is reliant upon the findings of those inspections. Inspection building reports containing drawings, narrative, and results are on file in the Safety Office. Tables containing lists of building materials found to contain ACM, locations and present conditions are attached to this manual. This O&M Plan focuses specifically on the ACMs listed on these tables.

If any ACM is damaged or becomes damaged it should be repaired, if possible, or removed entirely. Materials with a high potential for disturbance should be removed or repaired immediately upon discovering damage to the material especially when located in occupied areas.

All identified ACM must be removed prior to any planned renovation, maintenance, or demolition activities (if the asbestos will be disturbed) in compliance with all federal, state and local asbestos regulations. The procedures set forth are standard O&M procedures.

3.0 ASBESTOS BACKGROUND

3.1 What is Asbestos?

Asbestos is a term used to describe a group of six naturally occurring fibrous minerals (chrysotile, amosite, crocidolite, anthophyllite, tremolite, and actinolite) found in certain types of rock formations. Of that general group, the minerals chrysotile and amosite are commonly found in building products.

3.2 Asbestos Uses in Buildings

Asbestos has been used extensively in buildings throughout the world as a component in fireproofing, insulation materials, decorative and acoustical texture, floor coverings, roofing materials and as reinforcement for plaster binders in building products. Asbestos became a popular commercial product because of its strength, fire and corrosion resistance, and insulating qualities. In The United States, its commercial use began in the early 1900s.

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3.3 Health Effects

Asbestos fibers can cause serious health problems if inhaled. 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 to 40 years or more before symptoms appear.

3.4 Federal Regulations

Since the early 1970s, awareness of the potential health hazards associated with inhalation of airborne asbestos fibers has increased. In 1973, the Environmental Protection Agency (EPA) enacted the National Emission Standards for Hazardous Air Pollutants (NESHAPs) which banned the spray application of asbestos-containing materials, such as fireproofing, insulation and acoustical surfacing materials. Also enacted was a no visible emissions standard for building renovation and demolition.

Because of its carcinogenic nature and because of its common use in public buildings, EPA mandated in the May 27, 1982 Federal Register that all public and private schools (kindergarten through grade 12) be inspected for the presence of asbestos-containing materials. This was the first legal mandate requiring any type of action concerning asbestos in buildings.

On October 22, 1986, Congress passed the Asbestos Hazard Emergency Response Act (AHERA) that, among other provisions, required EPA to develop final asbestos rules by October 17, 1987. It included inspection, testing, establishment of an O&M Program, and in some cases, removal of asbestos.

The Occupational Safety and Health Administration (OSHA) has regulations for occupational exposure to asbestos. The Brockton VA Medical Center is required to follow OSHA regulations in 29 CFR 1910.1001 and 1926.1101 - Occupational Exposure to Asbestos standards, to protect employees and maintenance workers.

Among other things, these standards require that building owners do the following:

• Identify and label asbestos containing materials;

• Notify affected parties;

• Maintain records of notifications;

• Train housekeeping staff about the location of ACM and anyone who may be exposed to levels of asbestos above the permissible exposure limit; and,

• Designate a competent person to oversee asbestos activities.

If asbestos-containing materials are found during an inspection, there is no requirement that they be addressed in a manner similar to that which Congress

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 2 – Page 5 of 21 mandated for schools. There is an EPA requirement to remove most asbestos-containing materials, with the possible exception of roofing materials, vinyl asbestos floor tiles and linoleum, from a building prior to demolition. In addition, there is no federal law requiring removal of asbestos currently in place in buildings.

4.0 INTRODUCTION TO THE OPERATIONS AND MAINTENANCE

PROGRAM

4.1 Objective of the Operations and Maintenance Program

The principal objective of an O&M Program is to minimize exposure of building occupants to asbestos fibers. To accomplish this objective, an O&M Program includes work practices to:

(1) Maintain ACM in good condition,

(2) Ensure proper cleanup of asbestos fibers previously released, if necessary,

(3) Prevent further release of asbestos fibers, and

(4) Monitor the condition of ACM.

4.2 Types of Asbestos-Containing Materials

For the purpose of the Operations and Maintenance Program, asbestos-containing materials are placed into three major categories:

(1) Surfacing Material: Surfacing material is ACM that is sprayed or troweled onto surfaces, such as plaster, sprayed finishes, acoustical surfaces, or fireproofing.

(2) Thermal System Insulation (TSI): TSI is insulation applied to pipes, boilers, tanks, and ducts to prevent heat loss, heat gain, or condensation.

(3) Miscellaneous ACM: Miscellaneous ACM is other asbestos-containing materials such as ceiling or floor tiles, floor coverings, asbestos-cement panels, asbestos siding, and roofing materials.

4.3 Types of Operations and Maintenance Projects

Generally, the O&M Program is comprised of three types of projects:

No Contact with ACM Expected

Those projects that are unlikely to involve any direct contact with ACM -- for instance, floor tile in a facility. The custodial and maintenance staff can generally handle these projects.

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Potential for Contact with ACM

Those projects which may cause accidental disturbance of ACM; for instance, maintenance work that may expose workers to TSI identified at the facility or removing and replacing damaged flooring material or miscellaneous materials. Since the Brockton VA Medical Center will not be training an asbestos response team, these projects will require the involvement of an asbestos removal contractor. If the Brockton VA Medical Center plans to train an internal asbestos response team that will handle or disturb ACM, then appropriate training, medical surveillance, asbestos approved respirators (and a written respiratory protection program), personal protective equipment, environmental control equipment such as HEPA vacuums, etc.

must be provided by the Brockton VA Medical Center to employees who perform these projects. Attached to this document are the OSHA Occupational Exposure to Asbestos standards that provide specific details pertaining to the above-mentioned items.

Contact with ACM

Those projects which involve relatively small disturbances of ACM -- for instance, maintenance work such as mechanical work that may come into contact with the TSI identified at the facility or removing and replacing damaged flooring material or other miscellaneous materials. Placing carpet, new sheet vinyl flooring or floor tile over asbestos-containing flooring (without removing the existing flooring) can be performed by maintenance personnel provided that they are aware of the location of ACM and are instructed not to disturb the material. However, if these materials are to be removed, these projects will require the involvement of an asbestos removal contractor. If the Brockton VA Medical Center plans to train an internal asbestos response team that will handle or disturb ACM, then appropriate training, medical surveillance, asbestos approved respirators (and a written respiratory protection program), personal protective equipment, environmental control equipment such as HEPA vacuums, etc. must be provided by the Brockton VA Medical Center to employees who perform these projects. Attached to this document are the OSHA Occupational Exposure to Asbestos standards that provide specific details pertaining to the above-mentioned items.

Larger, more complex projects for the intentional removal of ACM are beyond the scope of an O&M Program and are considered asbestos abatement projects.

Abatement projects require state licensed abatement contractors. Contact the Asbestos Program Consultant for requirements.

Prior to finalizing plans for renovation activities, the VAMC should review the ACM O&M Manual to determine if ACM will be disturbed by the proposed renovations.

The VAMC should also assume materials not previously sampled due to

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 2 – Page 7 of 21 accessibility, etc. which will be impacted by renovation activities to be asbestos-containing materials unless proved otherwise. If ACM must be disturbed as a part of the renovations, all ACMs must be removed by a Commonwealth of Massachusetts licensed asbestos abatement contractor. If proposed renovations will not disturb ACM, continuous monitoring of ACMs should be conducted throughout renovation activities to ensure the ACMs remain in an intact condition. Additionally, prior to commencing renovations, all contractors involved with the renovations should be made aware of the location and quantity of ACMs within the buildings in which they will be working.

5.0 IMPLEMENTING THE OPERATIONS AND MAINTENANCE PROGRAM

5.1 The Asbestos Program Manager

An Asbestos Program Manager, who will be responsible for maintaining the O&M Program, should be appointed. The Asbestos Program Manager's responsibilities are numerous and the Asbestos Program Manager will act as the decision-maker on all routine, as well as emergency, asbestos-related matters. The Asbestos Program Manager will have authority to oversee the custodial and maintenance staffs, contractors and outside service vendors with regard to all asbestos-related activities.

The Asbestos Program Manager will arrange for training of on-site personnel in O&M techniques. The Asbestos Program Manager may delegate various responsibilities including documentation and record keeping to an Asbestos Program Consultant.

5.2 The Building Asbestos Coordinator

A Building Asbestos Coordinator (BAC), such as the maintenance managers associated with each building, should be appointed. BACs are responsible for notifying the Asbestos Program Manager of building operations that could disturb ACM or emergency, asbestos-related matters. The BAC can provide asbestos awareness training on behalf of the Asbestos Program Manager (if properly trained).

The BAC or Asbestos Program Manager will develop a list of key contacts within the Brockton VAMC consisting of maintenance staff, custodial staff, office managers, general employees and vendors.

A well-developed O&M Program is ineffective unless the BAC is committed to implementing it properly. The BAC should convey this commitment to key personnel involved in the building's management and operations.

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5.3 Cleaning

The Asbestos Program Manager should make a determination for the frequency of routine cleaning. Non-routine cleaning will be necessary if ACM is inadvertently disturbed. If an area needs to be cleaned due to the inadvertent disturbance of ACM, an asbestos removal contractor should be contacted for cleaning.

In areas where damage or debris was observed in the initial asbestos survey, dry brooms, mops, dust cloths, and standard vacuum cleaners simply re-suspend asbestos fibers into the air and, therefore, should not be used.

5.4 Notification

The Asbestos Program Manager and/or the BAC will inform maintenance employees, tenants and contractors about the location and physical condition of the ACM that may be disturbed, and stress the need to avoid disturbing the material.

Informed building occupants are less likely to unknowingly disturb ACM and release fibers into the air. Notification will include an explanation of the asbestos labeling system (See Appendix A.)

The BAC will inform building occupants about the presence of ACM by holding awareness or information sessions and posting signs in a common area at the Brockton VAMC where affected occupants can see them. The following methods will be used by the BAC to complete these notifications:

Awareness Meetings

Selected personnel shall attend an awareness/information session. This session will inform them of the presence of asbestos in their facility and the procedures the management of the Brockton VAMC is taking to control it.

Employee Letter

Mail or post the employee/tenant notification letters for the Brockton VAMC Medical Center employees, tenants and contractors working at the facility. It is a simple method of conveying the needed information concerning the ACM within the facility (Form 1 in Appendix A is a sample template to be tailored by the BAC for use).

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Employee Asbestos Awareness Form

All employees who are likely to contact ACM should sign the employee awareness form (sample Form 2 in Appendix A) including the asbestos program managers, each building manager, and maintenance or custodial/housekeeping employee of the Brockton VAMC or anyone else who may contact ACM during maintenance or renovation.

All other personnel whose work may involve disturbing ACM should also sign the awareness form. This form is an example and may be modified to meet the BAC’s needs. The Asbestos Program Manager will retain these forms on file for no less than 30 years as a critical document to support the owner in legal proceedings. Through the use of this acknowledgment form, the management of the Brockton VAMC is showing its intent to abide not only by EPA and OSHA regulations but also by EPA and OSHA recommendations.

Contractor Notification Form

All affected outside contractors, vendors, and others sign the contractor notification form (sample Form 3 in Appendix A) to notify them of the presence of ACM within your facility. This form may also be modified depending on the intended outside agents. This form is signed by the contractor's superintendent or project manager and ensures that all of the contractor's workers have been informed of the presence of ACM.

Warning Signs and Restricted Areas

To minimize the chance for accidental entry into areas with a high risk of exposure, such as areas undergoing maintenance activities, warning signs should be posted and access restricted to authorized personnel only. This is necessary to prevent personnel, both employees and agents, who are unaware of the presence of asbestos and its potential hazards from inadvertently disturbing any ACM. See Appendix A for a detailed explanation of the labeling system.

5.5 Employee Medical Surveillance Program

It is our understanding that the Brockton VAMC will hire an asbestos abatement contractor to perform removal where ACM will be disturbed. A Medical Surveillance Program for Brockton VAMC personnel will not be necessary under these conditions. If the Brockton VAMC plans to train an asbestos response team and those employees will come in direct contact with ACM (other than placing new tile or other flooring over asbestos containing tile), then medical surveillance must be provided to each employee who is part of the asbestos response team. The details of the medical surveillance are included in part M of the OSHA Occupational Exposure to Asbestos standard attached to this O&M plan.

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5.6 Employee Training

The Asbestos Program Manager will be required to attend formal training programs on the presence of asbestos-containing materials within the facility. Verbal notice with an acceptance signature will apply to contractors used by the Brockton VAMC prior to conducting work that will disturb the ACM. Each training program is for a certain group of employees depending on their exposure to the ACM in the building.

A. Asbestos Awareness Training Program

The Asbestos Awareness Training should be attended by employees that are not in day-to-day contact with ACM. These employees include but are not limited to:

• Administrative staff

• Maintenance staff/FMS staff

• Housekeeping/EMS staff

• Clerical Staff

• Other employees with minimal contact with ACM on a regular basis

The program presents general awareness training for the Brockton VA Medical Center employees, and would include:

• Administrative staff responsibilities

• An overview of the ACM in the facility

• Health concerns associated with ACM

• The building owner's response to the ACM

• The role of the building employees in a successful O&M

Program

The asbestos awareness program is vital to the dissemination of information to employees and tenants that have minimal contact with ACM on a day-to-day basis.

This program should be well documented, and a record of each person in attendance should be kept on file.