Asbestos Management Plan Building 1 Final.pdf

ASBESTOS MANAGEMENT PLAN

Veterans Affairs (VA) Medical Center Building 1

300 West Veterans Boulevard Big Spring, Texas 79720

Prepared for:

Department of Veterans Affairs Contracts 00504

Engineering Services – Big Springs, Texas Location

7201 I‐40 West Suite 100

Amarillo TX 79106

Prepared by:

HGS Engineering, Inc. (HGS)

1121 Noble Street

Anniston, Alabama 36201

Trina Mullen Project Manager‐Management Planner‐Inspector TDSHS Individual Asbestos Consultant No. 105687

Reviewed by Tim Thompson:

November 2016

TABLE OF CONTENTS

Section Section Name

EXECUTIVE SUMMARY i

1 GENERAL INFORMATION 1

1.1 – Contact Information

1.2 – Glossary of Terms and Abbreviations

1.3 – Inventory of Building Materials

1.4 – Building Inspection

1.5 – Hazard Assessment

1.6 – Recommended Response Actions

2 RESPONSE ACTIONS AND HAZARD ASSESSMENT RANK 27

2A BUILDING 1 29

OPERATIONS AND MAINTENANCE PROGRAM

4 CONCLUSION AND REFERENCES 34

Appendices:

A – AHERA Limited Asbestos Survey Report (HGS 2016) B – ACBM Sample Locations and ACBM Locations (2016 Drawings)

C – Previous AHERA Limited Asbestos Survey Report (DSE 2011) D – Historical Drawings

Asbestos Management Plan Veterans Affairs Medical Center, Big Spring, Texas, Building 1

Page i

November 2016

EXECUTIVE SUMMARY

HGS Engineering, Inc. (HGS) was retained by Department of Veterans Affairs Contracts 00504 Engineering Services – Big Springs, Texas Location, to complete an Asbestos Management Plan (AMP) for the Veterans Affairs (VA) Medical Center Building 1 located at 300 West Veterans Boulevard, Big Spring, Texas 79720 (hereinafter referred to as the Site).

HGS recommends that the VA designate a contact person to oversee all asbestos activities at the VA Medical Center in Big Spring, Texas. This person is known as the Designated Person (DP) or the Operations & Maintenance Coordinator. The DP should work together with employees and building occupants to maintain compliance with federal, state and local asbestos regulations in order to prevent any uncontrolled releases of asbestos fibers which pose a threat to human health and the environment.

Any building containing or assumed to contain friable ACBM should implement an Operations and Management (O&M) Program as long as the ACM remains in the building. HGS has developed an O&M Program for this Site, which is included in this AMP.

SECTION 1

GENERAL INFORMATION

1.1 CONTACT INFORMATION

Table 1 below includes the DP and facility information. DPs should maintain a current Asbestos Management Plan (AMP), conduct or make available training for employees who may be exposed to asbestos fibers, be responsible for performance of building inspections, by licensed individuals, with sampling of suspect asbestos‐containing building materials (ACBM), and manage their asbestos properly.

The DP should consider providing yearly notification to occupants and employees about the contents of the AMP and any renovation or abatement activities involving asbestos‐containing materials (ACM) or assumed ACM.

Table 1. Contact and Property Information

DP: Telephone No.

Address: 300 West Veterans Boulevard, Big Spring, Texas 79720

Name of Facility:

Veterans Affairs Medical Center, Building 1 Telephone No.

Address: 300 West Veterans Boulevard, Big Spring, Texas 79720

The DP has the following general responsibilities:

Ensure that the activities of any persons’ who perform inspections, re‐inspections or periodic surveillance, develop and update management plans, develop and implement response actions;

and conduct operations and maintenance (O&M) activities in compliance with all of the federal, state, and local regulations.

- Inspections must be conducted by an accredited Building Inspector and licensed by the Texas Department of State Health Services (TDSHS). This involves visually inspecting buildings for friable and non‐friable ACBMs, sampling such materials unless they are assumed to be ACBM, and having samples analyzed by an accredited laboratory in accordance with the AHERA regulations.

- An accredited management planner should prepare the AMP based on the results of the inspection. In the AMP, the management planner recommends appropriate response actions, prepares cost estimates on the response actions, and schedules the response actions.

- Response actions should be selected by the DP based on the recommendations of the management planner. The DP should ensure the response actions are carried out in a timely manner and in compliance with applicable regulations.

- O&M Programs should be implemented by the DP whenever any friable ACBM is present or assumed ACM to be present in a building under its authority. Where materials identified as non‐friable ACBM or assumed non‐friable ACBM are about to become friable as a result of activities performed in the building, they must be treated as friable and thus should also be included in an O&M Program. EPA recommends that the DP also manage non‐friable ACBM in their buildings under an O&M Program.

Ensure that all custodial and maintenance workers are properly trained.

Ensure that workers and building occupants are notified about activities related to ACBM.

Ensure that short‐term workers who may come into contact with asbestos or assumed asbestos containing building materials are provided the locations of ACBM and suspected ACBM assumed to be ACM.

Ensure that warning labels are properly posted.

HGS recommends that the VA designate a contact person to oversee all asbestos activities at the VA Medical Center in Big Spring, Texas. This person is known as the Designated Person (DP) or the Operations & Maintenance Coordinator. The DP should work together with employees and building occupants to maintain compliance with federal, state and local asbestos regulations in order to prevent any uncontrolled releases of asbestos fibers which pose a threat to human health and the environment.

The DP position is most often held by a building engineer, superintendent, facilities manager or safety/health director. Regardless of who holds the position, the EPA stresses the need for the DP to be properly trained and qualified through training and experience and maintaining active involvement in all asbestos management activities. HGS recommends the DP should attend the 16‐hour Operations and Maintenance Training. The contact information and training records for the DP is included below in Table

2. This table should be kept up‐to‐date by the DP.

Table 2. Designated Person Information Veterans Affairs (VA) Medical Center, Big Spring, Texas 79720

Name of DP: Telephone No.

Address: 300 West Veterans Boulevard, Big Spring, Texas 79720

Training Location Training Course (Certificate ID) Date Earned Expiration Date

The DP should implement the AMP as contained in this report, which involves notifying all short‐term and outside contractors of the presence, location and quantity of ACBM in the building as well as all occupants in areas containing ACBM, regardless if the materials are assumed to be asbestos‐containing or sampled and confirmed to be ACBM. The DP should also maintain and manage the documented inventory of ACBM as provided in the AHERA Asbestos Survey Report. Work permit applications should be reviewed by the DP to determine if the work is to be done in areas with ACBM. The DP should also ensure that recordkeeping complies with relevant regulatory standards, including training records for custodial and maintenance staff.

1.2 GLOSSARY OF TERMS AND ABBREVIATIONS

Accessible – When referring to ACM, accessible means the material is subject to disturbance by building occupants, custodial or maintenance personnel in the course of their normal activities.

Accredited or Accreditation – Refers to a person, firm, or laboratory having met the requirements found in Section 206 of Title II of the AHERA Act.

Acoustical Material – Material that has been applied to ceilings or walls to dampen sound.

AHERA – The Asbestos Hazard Emergency Response Act of 1986 (40 CFR Part 763). Final rule as published in the Federal Register, Vol. 52, No. 210.

Air Plenums – A space above a ceiling used to circulate or condition air throughout the adjacent areas.

Air Samples – Samples of airborne fibers taken by drawing air through an appropriate filter media which traps the fibers. This sample is then analyzed by polarized light or electron microscopy.

Asbestos – The asbestiform varieties of: Chrysotile, crocidolite, amosite, anthophyllite, tremolite, and actinolite. Also may include other amphibole varieties.

Asbestos Containing Material (ACM) – When referring to a building, this means any material or product that contains greater than 1% asbestos fibers.

Asbestos Containing Building Materials (ACBM) – Surfacing ACM, thermal system insulation (TSI) ACM, or miscellaneous ACM that is found in or on building materials in interior portions of buildings.

Asbestos Fiber – Any fiber of chrysotile, actinolite, amosite, tremolite, anthophyllite, crocidolite at least 5 micrometers in length and with a length‐to‐width ratio (aspect) of greater than 3 to 1.

Asbestos Management Plan (AMP) – A document to assist in administering the asbestos program in a facility, which includes recommendations for response to ACM in the building, and also includes the O & M Program.

Bulk Samples – Physical samples of suspect asbestos containing material. These samples are then analyzed by Polarized Light Microscopy (PLM).

CFR – Code of Federal Regulations.

Competent Person – A person capable of identifying existing asbestos hazards in the workplace, and who has the authority to take prompt corrective measures.

Employee Exposure – Exposure to airborne asbestos that would occur if the employee were not wearing respiratory protection (the level of asbestos in the ambient air at a work site).

Encapsulation – The treatment of ACM/ACBM in place in a building with a liquid material that bridges or penetrates the asbestos fibers in an adhesive matrix to prevent the release of those fibers.

Bridging – Encapsulation technique that creates a membrane on the ACM surface.

Penetration – Encapsulation technique where the encapsulating mixture penetrates the ACM material and binds its components together.

Enclosure – An airtight, impermeable, permanent mechanical barrier around or over ACM/ACBM to prevent the release of asbestos into a functional space.

F/CC – Fibers per cubic centimeter. A measurement to express the level of fibers in the air.

Fiber Release Episode – Any uncontrolled or unintentional disturbance of ACM/ACBM that results in a visible emission.

Fireproofing ‐ Material sprayed or troweled onto facility components or structural members to prevent or retard their loss of strength during a fire.

Friable – Easily crumbled by hand pressure or material that has been made friable.

Functional Space – An area of specific use in a building.

Hazard – Any circumstance, mechanism, or event which has the potential to create injury or loss.

HEPA – High Efficiency Particulate Air. This prefix to the word “filter” defines a level of filter efficiency capable of trapping and retaining at least 99.97% of all mono‐dispersed particles of 0.3 micrometers in diameter.

Homogeneous Area (HA) – An area of building material that is determined to be uniform in color, texture, date of construction or general appearance.

Inspection – The process of identifying, locating and quantifying ACM, and determining its condition and potential for disturbance and reporting the results. This inspection is the basis of the management plan.

Mechanical Area – An area of a facility not normally accessed by the public; often contains HVAC equipment, boilers, heat exchangers, tanks, pipes, ducts and other mechanical equipment.

Medical Surveillance Program – A program to ensure that personnel are physically and psychologically able to wear respiratory protection equipment, and are able to perform asbestos related activities. It may also detect the presence of an asbestos related disease.

Mesothelioma – A cancer of the lining of the lung (pleural) or abdominal (peritoneal) cavity; a uniformly fatal asbestos specific disease, second only to lung cancer as a cause of early mortality from asbestos exposure.

Miscellaneous ACM – Any material containing greater than 1% asbestos that is not surfacing or TSI.

Miscellaneous Material – Building materials that are not thermal system insulation or surfacing material.

MSDS – Material Safety Data Sheet. A technical document or report that provides precautions, protective measures, chemical makeup (active ingredients), and steps to take after a release. A primary source of information concerning chemical hazards.

Non‐friable – That material in a building which when dry may not be crumbled, pulverized, or reduced to powder by hand pressure.

Operations and Maintenance Program (O & M) – A program aimed at maintaining ACM/ACBM in good condition through training, awareness, and standardized work practices. An outreach of a comprehensive

O & M program is the cleanup and repair of previously damaged ACM as well as the prevention of further damage.

OSHA – The Occupational Safety and Health Administration of the United States Department of Labor.

PCM – Phase Contrast Microscopy. A method used to analyze air samples for the presence of airborne fibers.

PEL – Permissible Exposure Limit. A level of airborne asbestos above which no unprotected employee shall be exposed. Currently the PEL (federal) is 0.1 f/cc of air as an 8 hour Time Weighted Average, and an Excursion Limit of 1.0 f/cc measured for 30 minutes. See 29 CFR 1926.1101(c).

Planned Renovation – Removal of threshold amounts of regulated asbestos containing material (RACM), which has been planned ahead; facility work such as remodel or tenant improvement.

PLM – Polarized Light Microscopy. A method used to analyze bulk samples for the presence of asbestos.

Potential for Disturbance – The potential for disturbance from contact, vibration or air erosion to ACM/ACBM, based on the presence of the material and the use or normal operation of a building.

Presumed Asbestos Containing Material (PACM) ‐ “Friable” surfacing or TSI found in buildings built before 1981. Under the OSHA construction standard for asbestos, this material must be treated as asbestos unless an accredited inspector collects bulk samples according to the AHERA protocol and these samples are proven not to contain greater than 1% asbestos by PLM analysis from a laboratory participating in a nationally recognized proficiency testing program.

Preventive Measures – As used in the AHERA regulation, a preventive measure is a response to non‐ friable ACM and/or small scale, short duration work on ACM. It is also used as a recommended remedy for friable or TSI in good condition, but about to become significantly damaged.

Regulated Areas – An area in which Class I, II or III asbestos work (any level of disturbance) is done. It must be posted with regulatory posting and administered by a competent person, with only authorized persons being allowed inside. O&M work may not be done in the presence of building occupants.

Re‐Inspection – A re‐assessment of the ACM's condition once every three years by an accredited inspector.

Removal – A response action where the asbestos is stripped or permanently removed.

Renovation – The modification of any existing structure or portion thereof where exposure to airborne asbestos may result. Under the asbestos National Emissions Standards for Hazardous Air Pollutants (NESHAP), a renovation would be the removal or disturbance of threshold amounts of RACM.

Repair – The restructuring, overhauling, rebuilding or reconditioning of structures or surfaces where asbestos is present. Repair is a response action under AHERA, requiring certified persons to design and conduct the work.

Respirator – A device worn over the mouth and nose to prevent the inhalation of noxious substances.

Respiratory Protection Program – A written program to provide the information, training, and equipment necessary for proper respiratory protection while working with ACM (required by OSHA at 29 CFR 1910.134(c)).

Response Action – Methods of controlling asbestos that include: Removal, Encapsulation, Enclosure, Repair, or O & M. Under AHERA, a response action is a response to friable material or TSI, bigger than maintenance, and inside the building.

Routine Maintenance Area – An area, such as a boiler room or mechanical room, not normally frequented by the public in which maintenance employees or contract workers regularly conduct maintenance activities.

Surfacing Material – That material which is sprayed on, troweled on, or otherwise applied as acoustical plaster, fireproofing, or as decorative finishes.

TAHPR – Texas Health Protection Rules. The TAHPR were approved and became effective on October 20, 1992. The purpose of the TAHPR is to establish the means of control and minimization of public exposure to airborne asbestos fibers by regulating asbestos disturbance activities in buildings that afford public access or occupancy. The TAHPR require that a person must be appropriately licensed or registered to engage in asbestos abatement or any asbestos‐related activity.

TDSHS – Texas Department of State Health Services. The agency charged with enforcing EPA AHERA and NESHAP, as well as TAHPR.

TEM – Transmission Electron Microscopy; currently the most definite analysis method for the determination of asbestos presence in air, water, or bulk samples.

Thermal System Insulation (TSI) – Material applied to pipes, fittings, boilers, interior mechanical structures, and ducts to prevent heat loss or gain, condensation or for other purposes. TSI is mechanical system insulation.

USEPA – United States Environmental Protection Agency. The agency charged with implementing AHERA and NESHAP.

Wet Cleaning – A cleaning technique where the material is kept wet with amended water, and/or towels or mops are used to reduce the potential of the material becoming airborne.

1.3 INVENTORY OF BUILDING MATERIALS

This management plan is specific to Building 1.

Building 1 – Veterans Affairs Big Spring

The general inventory of Building 1 is included in Table 3. This table lists the general inventory, including which areas contain friable or non‐friable ACM materials, assumed ACBM materials, and materials that were sampled and confirmed to not contain ACM.

Table 3: General Inventory

BUILDING 1

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Assumed

ACBM

Basement NOTE ‐ All of the TSI in the basement has been abated; however, ACBM

TSI may be located in the crawl space and in other areas that were inaccessible at that time.

Black sealant (1995 Survey)

X

Ceiling tile (1995 Survey)

Insulation sealant (1995 Survey)

Pipe insulation (1995 Survey)

Wall (1995 Survey)

Resilient Sheet Flooring and Backing (Former Morgue), with yellow mastic (2011 Survey)

Drywall with joint compound and new texture (2011 Survey)

Drywall with joint compound and old texture (2011

White mastic on TSI, old (2011 Survey)

White mastic on TSI, new (2011 Survey)

Red fire stop caulking (2016 Survey)

2' x 2' Acoustical ceiling tiles (2016 Survey)

HVAC mastic, white (2016 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Assumed

ACBM

Exterior window glazing (2016 Survey)

Black sealant on cloth/foam insulation (chill water line) in Main Corridor

TSI in crawlspaces

First Floor Northwest quadrant and Lobby abated in 2011. ACBM TSI is present in walls, ceilings and pipechases throughout the First Floor of the original building. . Asbestos‐containing cement asbestos board panels and black asbestos‐ containing mastic may be present behind steam radiators. Black asbestos‐containing waterproofing is present on the inside of perimeter walls.

Corrugated ceiling tile (1995 Survey)

Light brown tile (1995 Survey)

Dark brown tile (1995 Survey)

Ceiling tile, rough (1995 Survey)

Drywall with joint compound and texture, popcorn (2011 Survey)

Cove base mastic, yellow (2011 Survey)

12" x 12" Floor tile, white and green, with yellow mastic

Sink undercoating, cream (2011 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Drywall with joint compound and troweled texture

6" Ceramic floor grout and thinset (2011 Survey)

Joint compound and wallpaper (2011 Survey)

HVAC duct mastic, white (2011 Survey)

TSI on hot water supply, with white mastic in 125 corridor (2011 Survey)

HVAC duct mastic, red (2011 Survey)

HVAC duct mastic, cream (2011 Survey)

Drywall with joint compound and splatter texture (2011

Plaster and texture (2011 Survey)

Cove base mastic, tan (2011 Survey)

12" x 12" Floor tile, white with blue, with yellow mastic

2' x 2' Acoustical ceiling tiles (throughout) (2011 Survey)

TSI with white mastic on domestic water line (2011

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, TSI with black mastic on steam/hot water line (2011

4" Ceramic wall tile grout (2011 Survey)

12" x 12" Floor tile, pink and blue, with yellow mastic

White and tan plaster with leveling compound (2011

Drywall with joint compound and rippled texture (2011

Drywall (vinyl clad wall system) with joint compound and yellow mastic (2011 Survey)

Laminate flooring, wood grained pattern, clear mastic (2016 Survey)

12" x 12" laminate flooring, marble pattern, clear mastic

Covebase mastic, tan (2016 Survey)

Black mastic under new flooring (2016 Survey)

White floor tile with black mastic (1995 Survey)

TSI Pipe Insulation (1995 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Tan speckled floor tile with black mastic (1995 Survey)

12" x 12" Floor tile, tan spotted, with black mastic (2004 Survey)

Black sealant on pipe wrap over fiberglass (1st Floor Waiter Shaft)

Brown floor tile with black mastic (2007 Survey)

12" x 12" Floor tile, chocolate brown speckled, with black mastic (2008 Survey)

12" x 12" Floor tile, chocolate brown, with black mastic (2008 Survey)

9" x 9" Floor tile, beige streaked, with yellow mastic

Black floor tile mastic under blue carpet tile (2008

9" x 9" Floor tile, gold, with yellow mastic (2008

12" x 12" Floor tile, yellow tan speckled, with black mastic (2008 Survey)

TSI in pipechases

Black sealant behind radiators (2004 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Transite panels behind radiator

Second Floor Floor tile abated in: Dental clinic hallway and rooms 202 and 203; Rooms 245, 246, 248 and OP 233 area; Rooms 218 and 219; elevator lobby and west hallway. ACBM TSI insulation is present in walls, ceilings and pipechases throughout. Asbestos‐containing cement asbestos board panels and black asbestos‐containing mastic may be present behind steam radiators. Black asbestos‐containing waterproofing is present on the inside of perimeter walls.

Blue floor tile, no mastic (1995 Survey)

Ceiling tile, smooth (1995 Survey)

Wallboard and texture (1995 Survey)

Yellow pipe insulation with black mastic on wrap (1995

12" x 12" Floor tile, blur with gray streaks and smears, with yellow mastic (2008 Survey)

Beige cove base with yellow mastic (2008 Survey)

2' x 2' Ceiling tile, with white painted surface (2008

Yellow carpet mastic with white leveling compound

Gray cove base with white mastic (2008 Survey)

Sheet vinyl, brown, with yellow mastic (2008 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Sheet vinyl, red, with tan mastic (2008 Survey)

12" x 12" Floor tile, beige with turquoise, red, tan, and white, with yellow mastic (2008 Survey)

12" x 12" Floor tile, red with pink, white, blue, green streaks , with yellow mastic (2008 Survey)

12" x 12" Floor tile, turquoise with white and light green smears, with yellow mastic (2008 Survey)

Wall plaster (2008 Survey)

Domestic water pipe insulation (2008 Survey)

Chill water supply pipe insulation (2008 Survey)

Round HVAC duct insulation (2008 Survey)

Drywall with joint compound, chalky (2008 Survey)

HVAC pipe insulation tar (2008 Survey)

Duct insulation with white mastic (2008 Survey)

2' x 2' White acoustical ceiling tile, new (2011 Survey)

Drywall with joint compound, new (2011 Survey)

White seam sealant on TSI, new (2011 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, 2' x 2' White acoustical ceiling tile, old (2011 Survey)

Two part plaster system with paint and texture (2011

Brown window caulking compound (2011 Survey)

Wallpaper and glue (2016 Survey)

Pipe insulation near elevators (1995 Survey)

Vinyl sheet flooring, light brown tile, black mastic (1995 Survey)

White floor tile with black mastic (1995 Survey)

12" x 12" Floor tile, off‐white with brown and gray streaks, black mastic (2004 Survey)

Black sealant on pipe wrap in the waiter shaft (2004

Pipe insulation – TSI – elbows and runs above ceiling (Terracon Survey)

Cement asbestos board panels behind radiators (Terracon Survey)

Green floor tile, with black mastic (2008 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Sink soundproofing (pink) w/ some rusting brown

12" x 12" floor tile, white, with black mastic (2008

12" x 12" floor tile, white with gray streaks, with black

12" x 12" floor tile, rust with black streaks, with black

Steam pipe insulation – TSI (2008 Survey)

Vapor barrier, black, on perimeter of concrete wall

Sheet vinyl, white with pink, blue and gray specks, with black mastic

Third Floor TB Isolation Rooms TSI abated in Oct. 2005. East Wing totally abated between 1995 and 2004. West Wing VCT and black mastic reportedly abated prior to 1995 ENCON inspection. Most TSI reportedly abated in east and west wings; however, some asbestos‐containing TSI is present in walls, ceilings and pipechases that were inaccessible to abatement workers, primarily on the exterior walls. Asbestos‐containing Transite panels and black asbestos‐ containing mastic may remain behind steam radiators. Black asbestos‐containing waterproofing remains on the inside of perimeter walls.

White floor tile, no mastic (1995 Survey)

Brown floor tile, no mastic (1995 Survey)

Ceiling tile, smooth (1995 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, 12" x 12" Floor tile, white with brown and off‐white smears, with black mastic (2008 Survey)

Cove base mastic, brown (2008 Survey)

Drywall with joint compound and texture, semi‐rough

Duct mastic, grayish green (2008 Survey)

Fire stop caulk, red (2008 Survey)

Sink undercoating, gray (2008 Survey)

Pipe insulation, white (2008 Survey)

Drywall with joint compound and splattered texture

2' x 2' Acoustical ceiling tile, Pit/Dot (2011 Survey)

Drywall with joint compound and rippled texture (2011

2' x 2' Acoustical ceiling tile, deep textured (2011

2' x 2' Acoustical ceiling tile, fissured (2011 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Drywall with joint compound and texture (2011 Survey)

12" x 12" Floor tile, beige, with black mastic ‐ West side of Floor 3 (2016 Survey)

12 " x 12" Floor tile, white and blue, with yellow mastic

Green floor tile with black mastic (1995 Survey)

Beige floor tile with black mastic (1995 Survey)

Light brown floor tile with black mastic (1995 Survey)

Dark brown floor tile, no mastic (1995 Survey)

Floor tile, white speck, with black mastic (1995 Survey)

Pipe insulation TSI (1995 Survey)

12" x 12" Floor tile, brown with white‐gray‐tan streaks, and black mastic

12" x 12" Floor tile, green, and black mastic

Fourth Floor NOTE – Fourth Floor has been completely abated. TSI is present in walls, ceilings and pipechases that were inaccessible to abatement workers, primarily on the exterior walls. Cement asbestos board panels have been abated, however, asbestos‐containing black mastic behind radiators remains. Black asbestos‐containing waterproofing remains on the inside of perimeter walls.

Ceiling material (1995 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Drywall (1995 Survey)

Floor tile, white, no mastic (1995 Survey)

Grout (2005 Survey)

1" x 1" ceramic floor tile, grout and mortar (2011

Window caulking (2011 Survey)

Black mastics (waterproofing membrane) under quarry tiles, and felts (2011 Survey)

Pipe Insulation TSI and mastic, white in Room 4073

Pipe insulation TSI (2005 Survey)

Fifth Floor NOTE ‐ All TSI and VCT was abated in 2004; however, some asbestos‐containing TSI is present in walls, ceilings and pipechases that were inaccessible to abatement workers, primarily on the exterior walls. Black asbestos‐containing waterproofing remains on the inside of perimeter walls. Cement Asbestos Board panels and black asbestos‐ containing mastic may remain behind steam radiators.

Ceiling Tile, rough (1995 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Ceiling Tile, smooth (1995 Survey)

Drywall with joint compound and splatter texture (2011

2' x 2' Acoustical ceiling tile, beveled (2011 Survey)

12" x 12" Floor tile, blue, with yellow mastic (2011

Carpet mastic, gold (2016 Survey)

12" x 12" Floor tile, white, with yellow mastic (2016

Black sealant behind radiators (2004 Survey)

Sixth Floor HVAC duct insulation above suspended ceilings and TSI inside closets 607A and 607B at end of main hallway west wing was abated in September 2009. Asbestos‐containing VCT flooring and black mastic was abated in hallways and elevator lobby since the 2011 survey. Asbestos‐containing VCT and black mastic remain in most offices, as indicated on drawings and is covered with carpet or non‐ACBM VCT in several offices. ACBM TSI is present in walls, ceilings and pipechases throughout the 6th floor. Cement asbestos board panels and black asbestos‐containing mastic present behind steam radiators. Black asbestos‐containing waterproofing present on the inside of perimeter walls.

Roofing sealant, 5th Floor roof (1995 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Ceiling tile, rough texture (1995 Survey)

Closet walls (1995 Survey)

Textured paint on ceramic tile (2004 Survey)

2" pipe covering with black sealant (2004 Survey)

Texture/Plaster on concrete (2016 Survey)

Floor tile, green/red/brown/tan, with clear mastic and thinset (2016 Survey)

Green floor tile, no mastic (1995 Survey)

White floor tile, no mastic (1995 Survey)

Gray speckled floor tile, no mastic (1995 Survey)

Black floor tile mastic (2004 Survey)

12" x 12" Floor tile, marble with blue‐gray streaks (2004 Survey)

Pipe wrap insulation TSI (2004 Survey)

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Assumed

Seventh Floor Mechanical and Roof

Duct insulation (1995 Survey)

White seam sealant on TSI (1995 Survey)

Roof Field, BUR, roll‐on membrane with white foam to deck (2016 Survey)

Roof Field, Paver Roofs, black felt moisture barrier, foam, concrete to deck (2016 Survey)

Black mastic on flashing at parapet wall (2016 Survey)

White caulking (2016 Survey)

Equipment flashing, black (2016 Survey)

Roof field, BUR, tar and gravel (2016 Survey)

Roof field, asphaltic rolled on torched‐down (2016

White HVAC mastic on roof (2016 Survey)

Black mastic on roof top 11 (2016 Survey)

Drywall with joint compound at elevator machine room

Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Bldg No.

Brief Material Description (Throughout) Friable

ACM

Non‐ Friable

ACM

Sampled, NO ACBM

Not Sampled, Perimeter flashing on BURs, gray flashing with rubber seal (2016 Survey)

Pipe Insulation TSI on steam line (1995 Survey)

Cement asbestos boiler flue (Assumed)

Elevator brake shoes (Assumed)

The above listed suspect asbestos‐containing building materials were sampled and analyzed during investigations performed in 1995 by ENCON, in 2008 by DSE, in 2011 by DSE and in 2016 by HGS. Any material not previously sampled should be considered an asbestos‐containing material until such time the material is sampled and analyzed for the presence of asbestiform minerals. To be considered a valid asbestos survey, the report must include sample locations, sample descriptions, and laboratory data from an EPA Accredited Laboratory. HGS was provided data from the 2011 DSE survey. In order for the 1995 ENCON survey to be used as a valid asbestos survey, laboratory data should be produced, otherwise suspect asbestos‐containing building materials will need to be re‐sampled prior to renovation or demolition activities.

1.4 HAZARD ASSESSMENT

HGS determined the hazard ranking for each friable or TSI using the current condition of the material, the potential for disturbance, and the location of the material as indicated by the AHERA Building Inspector in the written assessments. If present, critical conditions were given special attention during development of response actions. The disturbance potential of ACM is determined by definitions given in AHERA. An ACM with Potential for Damage is in an area regularly used by building occupants, including maintenance personnel, in the course of their normal activities.

The hazard ranking is used to set abatement priorities and rank areas for response actions. The AHERA rankings for potential hazards range from 7 (most hazardous) to 1 (least hazardous). These rankings are also based on the potential for contact with the material, influence of vibration on the material, and potential for air erosion on the material. Table 4 of this report outlines the hazard ranking system used by the Management Planner to determine the response actions necessary at the Site.

Table 4: AHERA Hazard Ranking Classifications by Potential for Damage

Hazard Rank

ACBM

Condition

ACM Disturbance Potential

Response Actions Required by AHERA

Significantly Damaged

Any

Evacuate or restrict the area if needed.

Remove the ACBM (or enclose or encapsulate if it is sufficient to contain fibers). Repair TSI if feasible and safe.

Operations & Maintenance (O&M) required for all ACBM.

6 Damaged Potential for Significant

Damage

Evacuate or restrict area if needed. Remove, enclose, encapsulate, or repair to correct damage. Take steps to reduce potential for disturbance.

O&M required for all ACBM.

5 Damaged Potential for Damage

Remove, enclose, encapsulate, or repair to correct damage.

4 Damaged Low Potential for

Damage Same as Hazard Rank 5.

3 Good Potential for Significant

Damage

Evacuate or restrict area if needed. Take steps to reduce potential for disturbance.

2 Good Potential for Damage Take steps to reduce potential for damage.

1 Good Low Potential for

Damage

A “significantly damaged” material has at least 10% of the surface with evenly distributed damage over a functional space or at least 25% of the surface with localized damage over a functional space. A “damaged” material has less than 10% of the surface with evenly distributed damage, or less than 25% of the surface with localized damage over a functional space. Materials that are significantly damaged or damaged require abatement by a certified asbestos abatement contractor. A “good” material has no visible damage or deterioration. “Good” materials can be classified as having a potential for significant damage, a potential for damage, or a low potential for damage.

A material with potential for significant damage is located in a public area (hallway, corridor, auditorium), is easily accessible to building occupants, and can also be exposed to easily sensed vibrations, loud noise or high velocities of air movement. A material with potential for damage is located in a room or office and is easily accessible to occupants, with service workers performing work in the vicinity of the material once a week to once a month, and is subject to occasional loud sounds or vibrations, with noticeable movement of airflow. A material with low potential for damage may be in a closet or may be visible to building occupants but not within reach, with no measurable influence of sounds, vibrations, or airflow.

1.5 RECOMMENDED RESPONSE ACTIONS

A response action can be understood as containing three elements:

1) it is a response to friable ACM,

2) it is a project that is bigger than a maintenance‐level job, and

3) it is a project that occurs inside the building.

VA employees’ nor contractors can remove, damage or repair any materials not made of glass metal or wood. All materials in this MP that needs attention requires specifications from an AHERA‐accredited Project Designer, with the response action work conducted by EPA‐certified Contractor/Supervisors overseeing certified workers, including final clearance via air sampling before the area can be cleared for re‐occupancy.

If a DP has friable, damaged non‐friable or TSI ACBM present in a building, a response action should be implemented. Response actions fall into five categories:

O&M Program – this is a proactive program of training, cleaning, work practices, and periodic surveillance to maintain friable ACM in good condition, ensure cleanup of asbestos fibers that may have been released previously and prevent further release of asbestos fibers through minimizing disturbance activities of the friable ACM.

Repair

Encapsulation

Enclosure

Removal

As long as friable ACM (assumed or sampled) remains in the building, an O&M program should be implemented. An O&M Program is not appropriate as an initial response action for any damaged or significantly damaged material. A more comprehensive, industry standard approach, is to include all ACBM (assumed or sampled) in the O&M program, whether it is friable or not and whether it is located inside or outside the building. The purpose of an O&M program is to prevent exposure to asbestos, wherever it is located in the building. HGS developed an O&M program for all building materials sampled and determined to be asbestos. This O&M program is included in this AMP.

The following is a summary of the recommended response actions. All friable and TSI ABCM were classified in a physical assessment as good, damaged, or significantly damaged by the AHERA Building Inspector. The priority rank or schedule serves to rank the assumed ACBM homogenous materials for response action, using an evaluation process called a hazard assessment. When assigning the priority rank or schedule for repeating hazard ranks, the design of the facility’s HVAC system, total amount of assumed ACBM, and sizes of potentially exposed populations in the functional spaces are taken into account first.

A hazard assessment combines the level of potential disturbance with the current condition of the ACBM to indicate the overall hazard potential as shown in the following tables of this report. Hazard assessment produces seven hazard ranks. These seven ranks are different from and should not be confused with the seven AHERA physical assessment categories of damage and potential for damage.

The abatement or response action priority rank or schedule suggests the relative timing for abatement or implementation of a response action from a hazards perspective; however, the final decision rests with the VA and depends on a detailed analysis of effectiveness and costs. The listed response actions are based on the AHERA requirements for each physical assessment of friable, the hazard ranking system, the technical suitability, and the costs of the actions.

The priority of work considerations are based on the occupant population, occupant activity patterns, the remaining life of the building, and any planned renovation and maintenance in the building. Sometimes it is more economically feasible to combine planned renovation and maintenance activities with asbestos abatement activities. However, NESHAP will require removal of all ACBM from the building before full demolition can occur.

As detailed in the following sections of the report (each building has its own section), the response action selected by the management planner for all friable and non‐friable ACBM remaining in the building (materials assumed to be asbestos) was to manage the suspect ACBM in an Operations and Maintenance (O&M) program. There were no critical situations (areas with damaged or significantly damaged friable or TSI materials) noted by the Building Inspector in the report.

The O&M Program should begin immediately upon the identification of any friable ACBM present or assumed to be present in the building. The start date for the O&M Program will be considered to be November 3, 2016, which is the date that the AMP was delivered to the Veterans Affairs Medical Center, Big Spring, Texas.

A detailed written description of the ACBM (sampled or assumed) that will remain in the building is provided in the following tables. The descriptions should be updated as needed during the periodic surveillance.

SECTION 2

RESPONSE ACTIONS AND HAZARD ASSESSMENT RANK

Asbestos Management Plan Veterans Affairs Medical Center, Big Spring, Texas, Building 1

The tables below provides a detailed description of the recommended preventative measures and response actions with hazard rank to be taken in Building 1, including methods to be used for any friable ACBM, and the locations where measures and actions will be taken. Per this AMP, all interior building materials were properly tested and analyzed in accordance with AHERA and Texas Department of State Health Services (TDSHS) Texas Asbestos Health Protection Rules (TAHPR) and Occupational Safety and Health Administration (OSHA). In addition, prior to any non‐emergency renovations or demolition, suspect materials, not identified and encountered that have not been sampled should be sampled and analyzed prior to disturbance, in accordance with TAHPR and OSHA, to determine if the untested materials needs to be treated as ACBM.

It is a requirement by federal and state asbestos regulations to have ACBMs removed by a TDSHS‐Licensed Abatement Contractor prior to disturbance.

This may include planned renovations, accidental material damage, wall penetrations, installing telephone or computer lines, etc. Abatement specifications must be prepared by a TDSHS‐Licensed Asbestos Consultant prior to the commencement of the abatement project. Also, third party air sampling and project monitoring must be performed during abatement activities.

Asbestos Management Plan Veterans Affairs Medical Center, Big Spring, Texas, Building 1

Asbestos Management Plan Veterans Affairs Medical Center, Big Spring, Texas, Building 1

Recommended Response Actions and Hazard Assessment Rank

Veterans Affairs (VA) Medical Center located at 300 West Veterans Boulevard, Big Spring, Texas 79720

HA No. Homogeneous Material Location of Material by

Functional Space Response Action and Reasoning Schedule

Hazard Rank

Preventative Measures

Black sealant on cloth/foam insulation

(chill water line) in Main Corridor

Basement

O&M This sealant material is classified as non‐friable with low potential for significant damage. The material is not in public areas and is not accessible to building occupants. This material has been sampled and determined to be ACBM.

1– Since this material is an ACBM, it should be included in the O&M Program until such time as it is removed.

This non‐friable material is in good condition.

Maintain in place and periodically inspect.

TSI in crawlspaces

Basement

This TSI material is classified as friable with low potential for significant damage. The material is not in public areas and is not accessible to building occupants. This material has been assumed (not sampled) to be ACBM.

1– Since this material is an assumed ACBM, it must be included in the

O&M Program until such time as it is removed or bulk asbestos sampling proves it does not contain asbestos.

This friable material is in good condition.

Floor tile and Associated

Black Mastic

Refer to Drawings

This floor material is classified as non‐friable with low potential for significant damage. The material is in public areas and is accessible to building occupants. This material has been sampled and determined to be ACBM.

Program until such time as it is removed.

TSI Pipe Insulation

Walls, ceilings and pipechases

This TSI material is classified as friable with low potential for significant damage. The material is not in public areas and is not accessible to building occupants. This material has been

Program until such time as it is removed.

This friable material is in good condition.

Black sealant on pipe wrap over fiberglass

1st Floor Waiter Shaft

This sealant material is classified as non‐friable with low potential for significant damage. The material is not in public

Program until such time as it is removed.

Asbestos Management Plan Veterans Affairs Medical Center, Big Spring, Texas, Building 1

Veterans Affairs (VA) Medical Center located at 300 West Veterans Boulevard, Big Spring, Texas 79720

HA No. Homogeneous Material Location of Material by

Functional Space Response Action and Reasoning Schedule

Hazard Rank

Preventative Measures

Black sealant behind radiators Throughout where noted

This sealant material is classified as non‐friable with low potential for significant damage. The material is not in public

Program until such time as it is removed.

Transite panels behind radiators

Throughout where noted

This panel material is classified as non‐friable with low potential for significant damage. The material is not in public areas and is not accessible to building occupants. This material has been

Program until such time as it is removed.

Sink soundproofing (pink) w/ some rusting brown

2nd Floor

This sink coating material is classified as non‐friable with low potential for significant damage. The material is not in public

Program until such time as it is removed.

Vinyl Sheet Flooring

2nd Floor

This flooring material is classified as non‐friable with low potential for significant damage. The material is not in public

Program until such time as it is removed.

Perimeter flashing on

BURs, gray flashing with rubber seal

Roof

This roofing material is classified as non‐friable with low potential for significant damage. The material is not in public

Program until such time as it is removed.

These non‐friable materials are in good condition.

Asbestos Management Plan Veterans Affairs Medical Center, Big Spring, Texas, Building 1

Veterans Affairs (VA) Medical Center located at 300 West Veterans Boulevard, Big Spring, Texas 79720

HA No. Homogeneous Material Location of Material by

Functional Space Response Action and Reasoning Schedule

Hazard Rank

Preventative Measures

Cement asbestos boiler flue

7th Floor Mechanical

This flue material is classified as non‐friable with low potential for significant damage. The material is not in public areas and is not accessible to building occupants. This material has been assumed (not sampled) to be ACBM.

Program until such time as it is removed.

These non‐friable

Elevator brake shoes

7th Floor Elevator Machine Room

O&M This brake shoe material is classified as non‐friable with low potential for significant damage. The material is not in public has been assumed (not sampled) to be ACBM.

Program until such time as it is removed.

These non‐friable

Asbestos Management Plan Veterans Affairs Medical Center, Big Spring, Texas, Building 1

SECTION 3

OPERATIONS AND MAINTENANCE (O&M) PROGRAM SPECIFICS

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Asbestos Awareness

1.2 Summary of O&M Plan

2.0 PARTICIPATION AND ROLE DEFINITION

2.1 Building Management

2.1.1 DP Designate (O&M Plan Coordinator)

2.1.2 Head Maintenance

2.1.3 Maintenance Personnel

2.1.4 Custodial Staff Supervisor

2.1.5 Custodial Staff Members

2.2 Contractors

2.3 Asbestos Abatement Contractor

2.4 Asbestos Consultant

3.0 ASBESTOS IDENTIFICATION

3.1 Known Asbestos‐Containing Materials

4.0 TRAINING

5.0 WORKER PROTECTION

5.1 Medical Surveillance (Medical Monitoring)

5.2 Respiratory Protection

5.3 Personal Protective Clothing and Equipment

5.4 Exposure Monitoring (Air Monitoring)

6.0 OPERATIONS AND MAINTENANCE PROCEDURES

6.1 Evaluation of Existing Material Conditions

6.2 Notification and Labeling

6.3 Addressing Low Hazards

6.4 Addressing Moderate Hazards

6.5 Addressing High and Immediate Hazards

6.6 Normal Maintenance

6.7 Work by Outside Contractors

6.8 Minor Fiber Release Episodes

6.9 Major Fiber Release Episodes

6.10 Disposal Procedures

6.11 Re‐evaluation of Asbestos‐Containing Materials

7.0 INTERIM CONTROL PLAN FOR ASBESTOS‐RELATED ACTIVITIES

7.1 Work Procedures

7.2 Work Practices

7.3 Classification of Asbestos Work

7.3.1 Class I Work

7.3.2 Class II Work

7.3.3 Class III Work

7.3.4 Class IV Work

7.4 Repair Protocol

8.0 RECORD KEEPING

APPENDICES

Appendix A ‐ Previously Performed Limited Asbestos Survey

Appendix B ‐ O & M Training Forms Form 1 ‐ 2‐Hour Awareness Seminar Attendance Sheets Form 2 ‐ 14‐Hour Training Attendance Sheets Form 3 ‐ Worker Acknowledgment and Understanding of…