Procedure 5 Work Plan.pdf

Terracon Consul tants, Inc. 1421 Edinger Avenue, Sui te C Tust in , Cal iforn ia 92780 P (949) 864-2051 F (949) 261-6110 terracon.com

December 9, 2020

South Coast Air Quality Management District 21865 East Copley Drive Diamond Bar, California 91765

RE: SCAQMD Rule 1403 Procedure 5 Work Plan Riverside National Cemetery – Abandoned Wastewater Treatment Plant 22495 Van Buren Boulevard Riverside, Riverside County, California

To whom it may concern:

Please find the following procedures that will be utilized in accordance with South Coast Air Quality Management District’s (SCAQMD) Procedure 5 (Approved Alternative). The asbestos containing materials (ACMs) identified in this Procedure 5 were identified in Terracon’s Pre-Demolition Hazardous Materials Survey report, dated September 30, 2020 for the abandoned wastewater treatment plant located within the Riverside National Cemetery. The Procedure 5 plan is being prepared at the request of Vali Cooper International, LLC.

1.0 BACKGROUD INFORMATION

The abandoned wastewater treatment plant is located on the southwest end of the Riverside National Cemetery near the intersection of Nandina Avenue and Village West Drive. The property was vacant at the time of Terracon’s survey and it is Terracon’s understanding that the site is frequently inhabited by the homeless population.

The scope of the construction work at the waste water treatment plant includes: asbestos abatement of all identified asbestos containing-construction materials (ACCM) and asbestos containing materials (ACM), and the demolition/disposal of all equipment and building materials, with the exception of the concrete slab/foundation and underground utilities.

From August 25-28, 2020, Terracon performed a Pre-Demolition Hazardous Materials Survey of the subject property. The asbestos survey was performed by Mr. Mike Jarboe, a California Division of Occupational Safety and Health (DOSH) Certified Site Surveillance Technician (CSST). Various suspect ACMs were determined to be in damaged or significantly damaged conditions. Visible debris was observed in the basins of the waste water treatment plant.

Samples of suspect ACMs were submitted to EMLab P&K in Irvine, California. Upon review of the results, the materials listed below in Table I were determined to contain asbestos. Materials reported to contain <1% asbestos by polarized light microscopy (PLM) were further analyzed by 400-point count method to confirm asbestos content below >1% ACM threshold concentration.

SCAQMD Procedure 5 Work Plan 22495 Van Buren Boulevard ■ Riverside, California December 9, 2020

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The sampled materials, condition, asbestos type, estimated quantity and specific locations are listed in Table I below:

TABLE I: ASBESTOS CONTAINING MATERIALS

HA

No. Description Material

Location Percent/Type

Asbestos

NESHAP

Classification Condition Estimated Quantity*

Water Treatment Plant

1* Window Putty Main

Building Windows

0.25% CH NA Significantly Damaged

26 Windows

26 SF

(Approximately 10 SF Damaged)

*This material was confirmed as <1%, therefore is not classified as an ACM. It will still be removed as ACCM as part of this project

4 Filler Top of Roof Access

Main Building at Roof Hatch

2% CH Cat. II Good 12 SF

7* Stucco Debris Basins <0.25% CH NA Significantly Damaged

900 SF

(Approximately

400 SF Damaged) *This material was confirmed as <1%, therefore is not classified as an ACM. It will still be removed as ACCM as part of this project

4' Cement/Transite

Pipe Debris in Southwest Basin (4'' pipe, pipe in pieces)

Southwest Basin

15% CH

3% CR Cat. II Significantly

Damaged

15 LF, 5 SF

(Approximately 5

SF Damaged)

Wall Seam Mastic at Base of Exterior Wall and Concrete Floor

Main Building - Exterior Walls /

Concrete Slab

2% CH Cat. II Good 225 LF or 100 SF

*Quantities listed are approximate for the structures. Total quantities of materials to be abated will be confirmed by the contractor. CH=Chrysotile, RACM – Regulated Asbestos Containing Material, Cat. I – Category I Non-friable Asbestos Containing Material, Cat. II – Category II Non-friable Asbestos Containing Material, SF = Square Feet

2.0 ABATEMENT WORK PRACTICES AND RESPONSE ACTIONS

Prior to the start of abatement, a standard fourteen-day notification period to the SCAQMD is required for the asbestos abatement activities. An expedited notification is not necessary for this project.

Please note, wet-methods will be used when disturbing and removing all ACM, damaged ACM, ACM debris, ACCM and asbestos-contaminated materials. Amended water will be used as the wetting agent.

Abatement of Disturbed ACM: 4’ Cement/Transite Pipe Debris in the Southwest Basin

1) A DOSH licensed abatement contractor shall be retained and all work to be performed in accordance with California Occupational Safety and Health Administration (Cal/OSHA) California Code of Regulations (CCR) Title 8, Section 1529.

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2) All personnel involved in the asbestos abatement activities shall, at a minimum, wear full-body, disposal suits and half-face HEPA filtered air purifying respirators when inside the contaminated areas or directly handling ACMs. Dual language Asbestos warning signs and demarcation tape will be posted at all points of egress/ingress to the containment area.

3) The basin/settling pond is approximately a 5’x5’ exterior basin located within the ground.

Six-mil polyethylene (poly) sheeting shall be placed on the floor of the basins, approximately six feet out in each direction from the basin walls.

4) A decontamination area will be placed at the entry to the regulated area.

5) Appropriate signs are to be posted at the entry and perimeter of the work area while work is in progress and until final visual clearance has been achieved

6) The entire floor of the basin will be sprayed with amended water to help saturate the damaged transite pipe pieces. All visible debris pieces shall be picked up by hand or with a HEPA vacuum and placed in a properly labeled asbestos waste bag.

7) Once all debris is removed, the remaining intact pieces of pipe is to be removed in intact and wrapped in two layers of poly sheeting and removed from the basin and placed in an appropriately labeled waste container

8) Following completion of the transite pipe and debris removal, the area will be decontaminated and prepared for final visual clearance by a Certified Asbestos Consultant. Decontamination and/or any ACM abatement will be performed using state of the art techniques including wet methods with amended water, and HEPA vacuum methods. HEPA vacuum and wet-wiping shall be performed on all horizontal surfaces .

Dry removal is not permitted.

9) All ACM waste and debris shall be double bagged in properly labeled bags that are legible to read and contain all information required in SCAQMD’s Rule 1403.

10) All waste shall be disposed in an approved landfill with a hazardous waste manifest.

Abatement of Disturbed ACCM: Stucco and Window Putty

Stucco

1) A DOSH licensed abatement contractor shall be retained and all work to be performed in accordance with California Occupational Safety and Health Administration (Cal/OSHA) CCR Title 8, Section 1529.

2) All personnel involved in the asbestos abatement activities shall, at a minimum, wear full-body suits and half-face HEPA filtered air purifying respirators when inside the asbestos regulated work areas or directly handling materials with asbestos content. Dual language Asbestos warning signs and demarcation tape will be posted at all points of egress/ingress to the containment area.

3) Stucco debris was observed on ground at the perimeter of the water treatment plant (at-grade) and debris was observed to have fallen into the adjacent basins. A regulated area should be established around the basins and the ground level. 6-mil poly should be placed on the ground level, directly adjacent to all stucco. Appropriate signs are to be posted at

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4) A decontamination area will be placed at the entry to the regulated area.

5) The stucco at the ground level should be removed using hand tools and amended water shall be used to keep the material wet to reduce airborne fibers. All waste generated shall be double-bagged and properly labeled.

6) The stucco debris within the basins shall be removed by using wet methods and a HEPA vacuum. The basin shall be cleaned until no visible stucco debris is present.

7) Decontamination and/or any ACM abatement will be performed using state of the art techniques including wet methods with amended water and HEPA vacuum methods.

HEPA vacuum and wet-wiping shall be performed on all horizontal surfaces. Dry removal is not permitted.

8) All asbestos waste and debris shall be double bagged and properly labeled. The asbestos concentration of this material is confirmed as less than 1%, therefore the waste can be disposed of as construction debris.

Window Putty

1) A DOSH licensed abatement contractor shall be retained and all work to be performed in accordance with California Occupational Safety and Health Administration (Cal/OSHA) CCR Title 8, Section 1529.

2) All personnel involved in the asbestos abatement activities shall, at a minimum, wear full-body suits and half-face HEPA filtered air purifying respirators when inside the asbestos regulated work areas or directly handling materials with asbestos content. Dual language Asbestos warning signs and demarcation tape will be posted at all points of egress/ingress to the containment area.

3) A regulated area shall be established at the exterior perimeter of the structure at the window locations. 6-mil poly sheeting shall, be placed on the floor directly underneath the exterior windows. Appropriate signs are to be posted at the entry and perimeter of the work area while work is in progress and until final visual clearance has been achieved.

Window can be removed to either the interior or exterior of the structure. Regulated area to be established on both sides of the windows.

4) The entire window shall be removed intact onto the poly sheeting to minimize disturbance of window putty. Decontamination and/or any ACM abatement will be performed using state of the art techniques including wet methods with amended water and HEPA vacuum methods.

5) All ACM waste and debris shall be double bagged and properly labeled. The asbestos concentration of these materials is confirmed as less than 1%, therefore the waste can be disposed of as construction debris.

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Abatement of ACMs and Materials with Asbestos Content in ‘Good Condition’

1) A DOSH licensed abatement contractor shall be retained for complete removal of all ACMs. All work to be performed in accordance with California Occupational Safety and Health Administration (Cal/OSHA) CCR Title 8, Section 1529 and SCAQMD Rule 1403.

General Conditions

1. Each work area should be observed by Terracon (or a similarly licensed professional) prior to, during, and at the completion of removal activities.

2. The Contractor shall maintain Safety Data Sheets (SDS) on-site for all equipment and materials, as appropriate.

3. All manifests (hazardous and non-hazardous) shall be signed by the owner or owner representative.

4. All hazardous waste manifests or non-hazardous materials data forms shall be delivered to Terracon. Record keeping format shall utilize a chain of custody form which includes the names and addresses of the Generator (Owner), Contractor, Waste Hauler, pickup site, disposal site, the estimated quantity of the asbestos waste and the type of containers used. The form shall be signed by the Generator, Contractor, Waste Hauler and the Disposal Site Operator, as the responsibility for the material changing hands.

Air Monitoring and Clearance Inspection n During the abatement activities, daily perimeter air samples should be collected by a third-party air monitoring firm certified by the State of California for asbestos consulting services. Perimeter samples shall not exceed the established ambient background level or the EPA’s recommended level of 0.01 fibers per cubic centimeter (f/cc) as determined by Phase Contrast Microscopy (PCM). All samples shall be analyzed onsite by a Terracon CAC or CSST in accordance with the National Institute for Occupational Safety Health (NIOSH) Method 7400.

n At the completion of all abatement activities, a final visual clearance shall occur to confirm removal of all ACM, damaged ACM and ACCM. The clearance should be conducted by a third-party air monitoring firm certified by the State of California for asbestos consulting services. Following the visual clearance, the consultant will notify the Contractor and Owner or Owner’s designated representative in writing. The abatement contractor shall then remove all remaining containment barriers and equipment.

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If you have any questions regarding this Procedure 5, please contact Danish Mansoor at (949) 383- 1976.

Sincerely, Terracon Consultants, Inc.

Danish Mansoor, CIH, CSP, CAC #18-6175 For Kenneth Pilgrim, CAC 03-3503 Group Manager Department Manager