Amend 0003 TX0182 Tyler Asbestos Reinspection 2014-REV 12.22.14.pdf

GENERAL SERVICES ADMINISTRATION, REGION 7

FORT WORTH REGIONAL OFFICE

Technical Services Branch (7PMS)

Fort Worth, TX

Asbestos Building Re-Inspection U.S. Federal Building and Courthouse

Tyler, TX

(TX0182)

February 2014

PREPARED and REVIEWED by:

Federal Occupational Health a component of the U.S. Public Health Service

Department of Health and Human Services

Asbestos Audit – TX0182

1 February 2014

TABLE OF CONTENTS

I. INTRODUCTION Page 2

II. FACILITY DESCRIPTIO N Page 2

III. SUMMARY OF ACM FINDINGS Page 2

Summary of the location and quantities of all identified asbestos containing materials according to EPA/AHERA categories for Thermal System Insulation and Miscellaneous Materials

IV. PHYSICAL ASSESSMENT OF ACM CONDITIONS Page 4

Physical assessment of the ACM including the EPA/AHERA Decision Tree/Response Action Keys for prioritizing required administrative actions and identifying any damage and potential for future disturbance or release of ACM fibers.

V. ACTION PLAN PRIORITIES Page 5

Specific action plan description and estimated removal costs of identified ACM together with General Recommendations

APPENDICES

A. ACM FLOOR PLAN LOCATIONS

Floor Plans showing locations of the asbestos containing materials found in this facility.

B. PHOTOGRAPHS

C. SAMPLING AND LABORATORY ANALYSIS PROTOCOLS

Asbestos Laboratory Chain of Custody Form Bulk Sample Laboratory Results Bulk Sample ACM Index Building Plan/Bulk Sample Locations

D. OPERATIONS AND MAINTENANCE PLAN

2 February 2014

I. INTRODUCTION

An Asbestos Building Audit Survey (ABAS) Re-inspection was conducted at the U.S. Federal Building and Courthouse located at 221 West Ferguson in Tyler, Texas (TX0182). The purpose of the Reinspection was to assess the condition of asbestos-containing materials (ACM) previously identified in the ABAS conducted in March 1993 and updated in 2007. Additionally, any suspect materials not previously observed were sampled and documented as to condition and specific building location. Floor plans for room area locations and asbestos containing materials have also been updated to reflect the information available at the time of the Reinspection.

This Re-inspection utilized information from the previous asbestos survey prepared by USPHS - FOH in 1993 and updated in 2007. That survey identified the following asbestos containing materials:

Domestic water system insulation Mechanical system insulation Vinyl floor tile and mastic

Few building renovations have been performed since that survey. Dedicated asbestos removal projects included abatement of floor tile and mastic from the third floor and pipe insulation from isolated areas.

II. FACILITY DESCRIPTION

The Federal Building and U. S. Courthouse at 221 West Ferguson, is a three story structure with a basement and mechanical attic. The steel and concrete structure rests on a reinforced concrete pier and slab foundation. Built in 1934 as a post office and courthouse, it was renovated the late 1980s and has approximately 59,885 square feet of usable floor space. At the time of this audit, it housed three courts and associated offices.

Heating is provided mainly by a forced air system with two low pressure boilers in the basement supplying several air handling units in a mechanical mezzanine and attic. Supplemental heating is provided by low pressure steam radiators distributed across the building's west outer wall. Air handling units are supplied with chilled water from two chillers in the basement and one in the attic. Condenser water is fed to and from a cooling tower located on the roof next door.

Interior finishes include painted sheetrock walls, painted plaster and lath walls and ceilings, glue-on acoustical tiles, acoustical tile drop ceilings, and various types of vinyl floor tile occasionally overlain by carpet.

III. SUMMARY OF ACM FINDINGS

Findings below are based on results from the Building Audit Survey conducted in 1993, updated in 2007 and from additional sampling performed as part of this assessment. A total of 10 samples were collected and analyzed in an effort to update available records. Samples were also collected to confirm or refute earlier findings.

Quantities listed below are rough estimates and should be confirmed prior to project estimating, 3 February 2014

Thermal System Insulation

This category includes all types and shapes of INSULATION MATERIALS (PIPE LAGGING/ FITTINGS/BOILER BREECHING) used for temperature or condensation control and identified in the following locations:

Material Type Location Quantity Functional Space

Domestic Water Insulation* Basement 84 lin. ft. Mechanical, chases Domestic Water Insulation First Floor 141 lin. ft. Plenums, chases Domestic Water Insulation Third Floor 175 lin. ft. Chases Domestic Water Insulation Fourth Floor 130 lin. ft. Chases

Heating Water Insulation** Various 47 lin. ft. Mechanical, chases

NOTE: Chilled water fitting insulation was found to be asbestos containing by the 1993 survey report. No old chilled water fittings were observed during this reinspection. Any old hard fittings encountered during renovations or maintenance to the facility should be assumed to be asbestos containing. Enclosed chases may harbor asbestos containing chilled water fitting insulation.

* This includes straight pipe insulation, elbows, valves, and tees on both the domestic hot and cold systems. These pipes are accessible in most basement and attic areas. In floors 1, 3, and 4, the pipes are often enclosed above a drop ceiling and within vertical chases. Chase quantities are estimated. The presence of domestic water insulation behind plaster walls and chases should be verified prior to wall and ceiling demolition.

** Both asbestos containing and non asbestos containing heating water pipe insulation exist in this facility. Non ACM insulation can be clearly recognized as fiberglass with a paper wrap. ACM insulation, whether straights or fittings, is hard to the touch and usually has canvas wrapping.

Some of the heating water (steam) pipe insulation was observed existing in building perimeter enclosed chases. These pipes feed passive radiators found in certain areas of the facility. For the most part this material would be considered inaccessible and unlikely to be disturbed unless during structural demolition. Quantities are estimated. If block wall demolition is scheduled, the presence of heating water insulation should be investigated using destructive techniques prior to general demolition.

Surfacing ACM Materials

This category includes all the SPRAY-APPLIED and TROWELED-ON COATINGS.

There were no surfacing materials identified as containing asbestos.

4 February 2014

Miscellaneous ACM Materials

This category includes primarily FLOOR TILE, CEILING TILE AND SEALANTS.

Material Type Location Quantity Functional Space

9x9 Floor Tile and Mastic Basement 300 sq. ft. Office, Storage 9x9 Floor Tile and Mastic Fourth Floor 850 sq. ft. Office, Storage

12x12 Floor Tile and Mastic Basement 2475 sq. ft. Corridor, Storage 12x12 Floor Tile and Mastic Third Floor 1510 sq. ft. Office, Storage

12x12 Floor Tile B-13 150 sq. ft. Storage

12x12 Floor Tile Mastic First Floor 500 sq. ft. Office, Storage

Asbestos Board Room 332 25 sq. ft. Office

All older flooring materials found under carpet or parquet should be assumed to be asbestos containing unless testing verifies otherwise. Although the survey intended to identify all areas with asbestos containing flooring materials, certain areas with limited accessibility may not be reflected accurately on the floor plan drawings.

Non-ACM Materials

This category includes materials that were considered suspect and were sampled during this re-inspection or at the time of the original survey and were not found to be asbestos containing:

Acoustical ceiling tile Sheetrock joint compound Wall plaster Black duct insulation mastic Vapor barrier on brick Parquet floor mastic Cove base and mastic Duct insulation sealants (white) Duct insulation sealants (black) Pipe insulation sealants

Bulk Sample Results

The original survey included analytical results for ninety-three bulk samples. A total ten bulk samples were collected and analyzed as part of this Re-inspection. A summary of sampling and analytical results can be found in Appendix C.

IV. PHYSICAL ASSESSMENT OF ACM CONDITIONS

As a result of the survey, the presence of asbestos was documented for several types of building materials. The physical assessments and the appropriate EPA/AHERA Decision Tree/Response Action Key for these materials are summarized below.

5 February 2014

Response Action 6 - Moderate Concern These identified Functional Spaces and Homogeneous Areas were positively identified to contain ACM Fibers. The physical assessments were all judged NO DAMAGE, with a MODERATE Potential for DAMAGE and pose a minimal health hazard, as long as they are properly maintained.

Thermal System Insulation Restroom Chases Throughout Domestic Water Insulation

Above Ceilings Storage, Corridor

Above Ceilings Throughout Heating Water Insulation

Storage, Corridor

Asbestos containing pipe insulation remains in isolated locations on all floors except the attic.

Most insulation is inaccessible within plaster chases. Exposed insulation, where observable, was not found to be damaged.

Response Action 8 - Low Concern These identified Functional Spaces and Homogeneous Areas were positively identified to contain ACM Fibers, but the physical assessments were all considered to be Non-Friable and/or of Low Accessibility, and as a result, pose minimal health hazard as long as they are properly maintained.

Miscellaneous ACM Storage, Office Various 9x9 Floor Tile and Mastic Kitchen Locations

Corridor, Office Various 12x12 Floor Tile and Mastic Storage Locations

Storage, Office Various 12x12 Floor Tile Mastic

Locations

Asbestos containing flooring materials may be obscured by carpet or parquet. All 9x9 tile and 12x12 tile with black mastic should be considered asbestos containing unless sampled by specific location and determined otherwise.

V. ACTION PLAN PRIORITIES

The Re-inspection of the Federal Building facility located in San Antonio has assessed the location and physical condition of ACM previously identified by an Asbestos Survey Report performed in 1993 and updated in 2007. An additional nine samples were collected and analyzed for further confirmation. The physical condition of all of these materials represent some level of concern and associated response action. It is imperative that an updated ACTION PLAN take into consideration the results of this Building Audit Survey Re-inspection documentation. This will

6 February 2014 assist in prioritizing required administrative actions, as well as preventing any additional damage or release of any suspect ACM from occurring in these identified materials.

Based on the observations documented and the physical assessment of conditions for future disturbance or degree of damage identified, EPA/AHERA criteria have standardized the following specific Decision Tree/Response Action Key recommendations for the types of materials identified:

Response Action Plan Action # Priority

6 Moderate

Thermal System Insulation

Material Type Location(s) Quantity Unit Price Cost

Dom. Water Insulation All Floors 530 lin. ft. $50.00/ft $26,500

Heating Water Ins. Various` 47 lin. ft. $50.00/ft $2,350

Action Plan Description Continue O&M, until major renovation or demolition requires removal under NESHAPS, or until hazard assessment factors change. Review building plans prior to renovations that would include wall or ceiling demolition or changes to mechanical systems.

Response Action Plan Action # Priority

8 Low

Miscellaneous ACM

Material Type Location(s) Quantity Unit Price Cost

9x9 Floor Tile/Mastic Basement, 4, 1,150 sq. ft. $5.00/ft. $5,750

12x12 Floor Tile/Mastic Basement, 3 3,985 sq. ft. $5.00/ft. $19,925

12x12 Floor Tile B-13 150 sq. ft. $5.00/ft. $750

Floor Tile Mastic Basement, 11 500 sq. ft. $5.00/ft. $2,500

Asbestos Board Room 332 25 sq. ft. $20.00/ft $500

Action Plan Description Continue O&M, until major renovation or demolition requires removal under NESHAPS, or until hazard assessment factors change.

NOTE: Estimates do not include costs for material replacement.

7 February 2014

General Recommendations

1. Additional sampling and physical inspections of all identified/suspect ACM materials prior to any scheduled renovation, demolition, or disturbance of the areas identified are recommended Classify all referenced suspect materials as asbestos-containing until laboratory tests prove otherwise.

2. Maintain all identified/suspect ACM in good condition until removed or replaced.

3. Annually, hereafter, verify contractor/building maintenance personnel with updated EPA/AHERA accredited asbestos training, to provide adequate administrative support in understanding the identified asbestos building conditions and the options available in maintaining and servicing these materials safely.

Another administrative consideration for the resulting Audit Survey documentation is background information for the establishment of frequencies for air monitoring surveys and visual inspections, when there are indications that material could become damaged by changes in building use, changes in operations and maintenance practices, or with changes in occupancy.

A review of this report should be performed prior to scheduling any renovation or demolition work within this building to assure that all suspect asbestos-containing material locations have been identified. Subsequent to this inspection, if a previously concealed or undetermined suspect building material is identified, it shall be treated as asbestos-containing, until laboratory analysis proves otherwise.

A-1 February 2014

APPENDIX A

BUILDING FLOOR PLANS

ACM HOMOGENEOUS AREAS/FLOOR PLAN LOCATIONS

This SUB-APPENDIX represents a basic set of floor plans outlining general locations of identified Asbestos Containing Materials.

Floor Type Page

Basement Thermal System 2 Miscellaneous ACM 3

First Floor Thermal System 4 Miscellaneous ACM 5

Third Floor Thermal System 6

Miscellaneous ACM 7

Fourth Floor Thermal System 8 Miscellaneous ACM 9

A-2 February 2014

Drawing Not to Scale

CRAWLSPACE

B-12B

B-15

B-12A B-12

B-11

B-11A

B-21 B-20

B-10

B-08C

B-05 B-03B

B-03

B-02A

B-14A

B-01

B-01B

B-04B-06

B-07

B-14

B-14B

CBB

CBA

B-08

B-13

B-02

CBA

B-09

B-16

Heating Water Insulation

Domestic Water Insulation

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Basement Thermal System Insulation

Asbestos Reinspection

TX0182

A-3 February 2014

Drawing Not to Scale

CRAWLSPACE

B-12B

B-15

B-12A B-12

B-11

B-11A

B-21 B-20

B-10

B-08C

B-05 B-03B

B-03

B-02A

B-14A

B-01

B-01B

B-04B-06

B-07

B-14

CBB

CBA

B-08 B-02

CBA

B-16

12x12 Floor Tile and Mastic

9x9 Floor Tile and Mastic

B-14B

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Basement Miscellaneous ACM

Asbestos Reinspection February 2014

B-13

A-4 February 2014

Drawing Not to Scale

RE 129 127

C1B

124128

COURTROOM

C1A

MAIN LOBBY

101A 107C

107A

CELL

Heating Water Insulation

Domestic Water Insulation Suspected Domestic Water Insulation

119B

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

First Floor Thermal System Insulation

Asbestos Reinspection

A-5 February 2014

Drawing Not to Scale

RE 129 127

C1B

124128

COURTROOM

C1A

MAIN LOBBY

101A 107C

107A

CELL

Residual Black Mastic

119B

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

First Floor Miscellaneous ACM

Asbestos Reinspection

A-6 February 2014

Drawing Not to Scale

COURTROOM

332C

332B

332A

C3B

336 337 330-13

C3A

329A

341A

C3C

339B 339C

Suspected Domestic Water Insulation

341A

Heating Water Insulation

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Third Floor Thermal System Insulation

Asbestos Reinspection February 2014

TX0182

330-7

330-10 330-8

330-9

330-11 A

330-6A

330-12

A-7 February 2014

COURTROOM

332C

332B

332A

C3B

336 337

335A

C3A

329A

341A

C3C

339B 339C

12X12 Floor Tile and Mastic

339C339B

341A

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Third Floor Miscellaneous ACM

Asbestos Reinspection

A-8 February 2014

UPPER COURTROOM

C4B

C4A

ROOF

410 C4D

C4C

413415C415B

415A

C4E

402 403 401A

404A

404B 404D

405B

405A

406A

Suspected Domestic Water InsulationDomestic Water Insulation

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Fourth Floor Thermal System Insulation

Asbestos Reinspection

A-9 February 2014

C4B

C4A

ROOF

C4C

413415C415B

415A

C4E

402 403 401A

404A

404B 404D

405B

405A

406A

9X9 Floor Tile and Mastic

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Fourth Floor Miscellaneous ACM

Asbestos Reinspection

B-1 February 2014

APPENDIX B

PHOTOGRAPHS

PHOTOGRAPH INDEX

PHOTOGRAPHS

This APPENDIX provides an Indexed Listing of the attached photographs; the Location pictured; the Homogeneous Area and/or Functional Space represented; as well as the respective Material Description associated with the photograph. Copies of actual photographs are also included.

B-2 February 2014

PHOTOGRAPH INDEX

This SUB-APPENDIX provides an Indexed Listing of the attached photographs; the Location pictured; the Homogeneous Area and/or Functional Space represented; as well as the respective Material Description associated with the photograph.

Photograph Homogeneous Material Number Location Area Description

1. Basement 12x12 Floor Tile and Mastic Non Friable

2. Crawlspace Heating Water Insulation Friable

3. Crawlspace Vapor Barrier Non ACM

4. Basement Pipe Insulation Sealant Non ACM

5. 4th Plenum Black Duct Ins. Mastic Non ACM

6. Mezzanine Texture/Plaster Non ACM

B-3 February 2014

Photograph 1: Asbestos containing 12x12 floor tile in the basement.

Asbestos floor tile may be present under parquet or wood flooring.

B-4 February 2014

Photograph 2: Typical heating water insulation as seen in the basement crawlspace.

Insulation is assumed to be present in chases.

B-5 February 2014

Photograph 3: Black tarry vapor barrier tar tested in the crawlspace was not found to contain asbestos.

B-6 February 2014

Photograph 4: White sealant on insulated fittings was not found to contain asbestos.

B-7 February 2014

Photograph 5: Black sealant on duct insulation above the fourth floor ceiling was sampled and not found to contain asbestos.

B-8 February 2014

Photograph 6: Plaster texture sampled from the mechanical mezzanine was not found to contain asbestos.

C-1 February 2014

APPENDIX C

SAMPLING AND LABORATORY ANALYSIS PROTOCOLS

ASBESTOS LABORATORY CHAIN OF CUSTODY FORMS

BULK SAMPLE LABORATORY RESULTS

BULK SAMPLE ACM INDEX

BUILDING PLAN/BULK SAMPLE LOCATIONS

C-2 February 2014

ASBESTOS LABORATORY CHAIN OF CUSTODY FORMS

This SUB-APPENDIX represents copies of the Chain of Custody Documentation submitted by the Building Audit Inspection Team requesting analysis of the collected Bulk Samples.

C-5 February 2014

BULK SAMPLE LABORATORY RESULTS

This SUB-APPENDIX represents the ASBESTOS LABORATORY ANALYTICAL REPORT for the ASBESTOS ANALYSIS of the collected bulk samples submitted by the Building Audit Inspection Team. The laboratory provides comments related to the "Analysis of Bulk Samples for Asbestos" and analytical technique utilized. The Analytical Laboratory has correlated the original sample collection numbers (i.e. 80- 01B) with a corresponding laboratory identification number (i.e. L21296).

C-8 February 2014

BULK SAMPLE ACM INDEX/SUMMARY

This SUB-APPENDIX identifies the site-specific locations where suspect asbestos-containing building materials were collected, and the asbestos laboratory analytical results reported for each respective location. The notation "ND" referenced for ASBESTOS CONTENT information, represents that after each sample was separated according to homogeneity, layering and principal fibrous/non-fibrous components; the fibrous components were then immersed into a liquid media of a known refractive index and analyzed by Polarized Light Microscopy (PLM); this determination identified that "NO ASBESTOS FIBERS" were observed within the limits of the polarizing technique utilized or the limits of the microscope objective/eyepiece magnifications used. The column titled NESHAP Category refers to the classification of material type based on 40 CFR Part 61 Subpart M, November 20, 1990. F stands for Friable ACM. The number 1 means Category 1 Non-Friable ACM, 1* means Category 1 Non-Friable ACM which has become friable, 1** means Category 1 Non-Friable that has or will be subjected to grinding sanding or abrading, and 2 means Category 2 Non-Friable ACM.

C-9 February 2014

Sample Material Location Result NESHAP Number Type Category

B182-01 HW Pipe Sealant B14-B None Detected 2 B182-02 Vinyl Floor Tile (Gr.) B-14B 2% Chrysotile 1 B182-03 Vinyl Floor Tile (Wh.) B-13 2% Chrysotile 1 B182-04 Vapor Barrier Crawlspace None Detected 2 B182-05 White Pipe Sealant Crawlspace None Detected 2 B182-06 White Pipe Sealant Crawlspace None Detected 2 B182-07 White Duct Sealant Crawlspace None Detected 2 B182-08 Parquet Mastic 1st Fr. Elev. None Detected 1 B182-09 C. Texture/Plaster Mech. Mezz. None Detected 2 B182-10 Duct Ins. Mastic 4th Plenum None Detected 2

C-10 February 2014

BUILDING PLAN/BULK SAMPLE LOCATIONS

This SUB-APPENDIX represents the BULKS SAMPLING LOCATIONS for the additional sampling performed as part of this Re-Inspection.

C-11 February 2014

CRAWLSPACE

B-12B

B-15

B-12A B-12

B-11

B-11A

B-21 B-20

B-10

B-08C

B-05 B-03B

B-03

B-02A

B-14A

B-01

B-01B

B-04B-06

B-07

B-14

B-14B

CBB

CBA

B-08

B-13

B-02

CBA

B-09

B-16

HW Pipe Insulation Sealant (neg.)

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Basement Bulk Sample Locations

Asbestos Reinspection February 2014

TX0182

1 8 2 - 0 1

1 8 2 - 0 2 Green 12x12

FT (pos.)

1 8 2 - 0 3White 12x12

FT (pos.)

Tarry Vapor Barrier (neg.)

1 8 2 - 0 4

White Pipe Sealant (neg.)1 8 2 - 0 5 1 8 2 - 0 6 1 8 2 - 0 7

White Pipe Sealant (neg.)

White Duct Sealant (neg.)

C-12 February 2014

Drawing Not to Scale

RE 129 127

C1B

124128

COURTROOM

C1A

MAIN LOBBY

101A 107C

107A

CELL

119B

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

First Floor Bulk Sample Locations

Asbestos Reinspection February 2014

TX0182

1 8 2 - 0 8 Parquet Floor Mastic (neg.)

1 8 2 - 0 9 Ceiling Texture/Plaster (neg.)

Collected in mezzanine mechanical room

C-13 February 2014

C4B

C4A

ROOF

410 C4D

C4C

413415C415B

415A

C4E

402 403 401A

404A

404B 404D

405B

405A

406A

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Fourth Floor

Asbestos Reinspection February 2014

TX0182 Bulk Sample Locations

1 8 2 - 1 0 Black Duct Insulation

Mastic in Plenum (neg.)

Asbestos O&M – TX0182

D-1 February 2014

APPENDIX D

Operations and Maintenance Plan

1.0 INTRODUCTION

THE INTENT OF THE GENERAL SERVICES ADMINISTRATION IS TO IMPLEMENT THIS

PROGRAM WITHOUT INVOLVING GSA EMPLOYEES IN REMOVAL, ENCAPSULATION, OR

ANY OTHER ACTIVITY THAT DISTURBS FRIABLE OR NON-FRIABLE ASBESTOS-

CONTAINING BUILDING MATERIAL EXCEPT FOR GSA APPROVED CLASS III ASBESTOS

WORK PRACTICES. GSA APPROVED ASBESTOS CONTRACTORS SHALL BE RETAINED

IN ALL OTHER CASES WHERE ACBM IS DISTURBED INTENTIONALLY.

This O&M program has been established to fulfill the requirements of the General Service Administration under the Asbestos Hazard Emergency Response Act (AHERA), as specified by:

US Environmental Protection Agency (EPA) Regulations in 40 Code of Federal Regulations (CFR), Part 763; OSHA Regulations in 29 CFR Parts 1910 and 1926.

The primary purpose of an O&M program is to prevent the release of asbestos fibers by minimizing ACBM (Asbestos Containing Building Material) disturbance and/or damage. The O&M program shall continue until all ACBM is removed from the facility. As part of the O&M plan, workers and building occupants will be alerted to the location of ACBM. The O&M plan will establish a process that ensures ACBM is not disturbed during building repairs and renovations, maintain a current inventory of all ACBM in the facility, provide training for the proper management of ACBM, and periodically visually re-inspect areas which contain ACBM.

The procedure incorporated into this O&M program address only that portion of custodial and maintenance work which involves potential disturbances of ACBM.

1.1 SCOPE

THIS O&M PROGRAM HAS BEEN DESIGNED TO MAKE GSA EMPLOYEES AWARE OF

POTENTIAL ASBESTOS HAZARDS AND HOW TO AVOID THE DISTURBANCE OF ACBM IN

THE COURSE OF THEIR DAILY ACTIVITIES.

The General Services Administration has endeavored to develop and implement a site-specific asbestos O&M plan for the U. S. Federal Building and Courthouse located in Tyler, TX (TX0182) based on data collected during the Asbestos Building Audit Survey Reinspection in February 2014. The data collected as part of this survey is intended to ensure compliance with OSHAʼs hazard communication requirements. This O&M program applies only to ACBM; it does not pertain to any other work-related hazards.

Maintenance and custodial personnel should follow standard industrial safety practices as well as GSA safe work practices during any work conducted near ACBM.

1.2 RELATED DOCUMENTS

This plan is intended to be used in conjunction with several guidance documents including but not limited to the following:

• Managing Asbestos in Place – A building Ownerʼs Guide to Operations and Maintenance Programs for Asbestos-Containing Materials (“Green Book”) (EPA publication 20T-2003)

• Guidance for Controlling Asbestos-Containing Materials in Buildings (“Purple Book”) (EPA publication 560/5-85-024).

D-2 February 2014

• Guidance Manual Asbestos Operations & Maintenance Work Practices, the National Institute of Building Sciences.

All other applicable Federal, state, and local regulations must be complied with as well as any approved GSA work practices.

1.3 ASBESTOS INSPECTION REPORT

The O&M plan is based on the inspection report listed below.

• Asbestos Building Audit Survey Reinspection (TX0182) U. S. Federal Building and Courthouse 221 West Ferguson Tyler, TX

2.0 SITE BACKGROUND INFORMATION

2.1 GENERAL

Asbestos is a mineral that is mined predominantly in Canada, South Africa, and Russia. It forms long, thin fibers that may be only 0.33 microns wide (1 micron = 1 millionth of a meter), which are not visible to the human eye. Because they are so small, asbestos fibers can remain airborne for long periods of time. Three forms of asbestos are commonly used commercially: chrysotile, crocidolite, and amosite (often known as white, blue, and brown, respectively). While some countries regulate these minerals separately, US regulatory agencies consider them equally hazardous and group them together within the regulations. Three forms of asbestos less commonly used commercially are tremolite, actinolite, and anthophyllite.

Much of what is known about asbestos-related diseases comes from studying workers in the various asbestos industries. Exposure to levels of airborne asbestos typical of the asbestos work place prior to 1972 has been related to a significantly higher incidence of asbestosis, a debilitating lung disease; mesothelioma, a rare cancer of the chest and abdominal lining; and cancers of the lung, esophagus, stomach, colon, and other organs. The potential for disease appears to be related to the physical and chemical characteristics of asbestos fibers and to the concentration of fibers in the air.

Asbestos may be found in cement products, acoustical plaster, fireproofing textiles, wallboard, ceiling tiles, vinyl floor tiles, floor tile mastic, thermal insulation, and other materials.

ACBM is grouped into three categories:

• Surfacing Material: Material that is sprayed-on, trowelled-on, or otherwise applied to surfaces, for acoustical, fireproofing, or other purposes.

• Thermal System Insulation (TSI): Material applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain, or water condensation.

• Miscellaneous Material: Interior building material on structural components, structural members or fixtures, such as floor and ceiling tiles, not including surfacing material or thermal system insulation.

D-3 February 2014

ACBM in the first two categories generally can be made readily friable (if the material has not been encapsulated); it can be crumbled, pulverized, or reduced to powder by hand pressure.

ACBM in the third category are described as being non-friable.

2.2 SITE-SPECIFIC ASBESTOS INFORMATION

Asbestos was identified in the following building materials:

Thermal System Insulation

This category includes all types and shapes of INSULATION MATERIALS (PIPE LAGGING/ FITTINGS/BOILER BREECHING) used for temperature or condensation control and identified in the following locations:

Material Type Location Quantity Functional Space

Domestic Water Insulation* Basement 100 lin. ft. Mechanical, chases Domestic Water Insulation First Floor 130 lin. ft. Plenums, chases Domestic Water Insulation Third Floor 90 lin. ft. Chases Domestic Water Insulation Fourth Floor 75 lin. ft. Chases

Heating Water Insulation** Basement 125 lin. ft. Mechanical, crawlspace Heating Water Insulation First Floor 55 lin. ft. Chases Heating Water Insulation Third Floor 20 lin. ft. Chases

NOTE: Chilled water fitting insulation was found to be asbestos containing by the 1993 survey report. No old chilled water fittings were observed during this reinspection. Any old hard fittings encountered during renovations or maintenance to the facility should be assumed to be asbestos containing. Enclosed chases may harbor asbestos containing chilled water fitting insulation.

* This includes straight pipe insulation, elbows, valves, and tees on both the domestic hot and cold systems. These pipes are accessible in most basement and attic areas. In floors 1, 3, and 4, the pipes are often enclosed above a drop ceiling and within vertical chases. Chase quantities are estimated. The presence of domestic water insulation behind plaster walls and chases should be verified prior to wall and ceiling demolition.

** Both asbestos containing and non asbestos containing heating water pipe insulation exist in this facility. Non ACM insulation can be clearly recognized as fiberglass with a paper wrap. ACM insulation, whether straights or fittings, is hard to the touch and usually has canvas wrapping.

Some of the heating water (steam) pipe insulation was observed existing in building perimeter enclosed chases. These pipes feed passive radiators found in certain areas of the facility. For the most part this material would be considered inaccessible and unlikely to be disturbed unless during structural demolition. Quantities are estimated. If block wall demolition is scheduled, the presence of heating water insulation should be investigated using destructive techniques prior to general demolition.

Surfacing ACM Materials

This category includes all the SPRAY-APPLIED and TROWELED-ON COATINGS.

There were no surfacing materials identified as containing asbestos.

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Miscellaneous ACM Materials

This category includes primarily FLOOR TILE, CEILING TILE AND SEALANTS.

Material Type Location Quantity Functional Space

9x9 Floor Tile and Mastic Basement 300 sq. ft. Office, Storage 9x9 Floor Tile and Mastic Fourth Floor 340 sq. ft. Office, Storage

12x12 Floor Tile and Mastic Basement 1250 sq. ft. Office, Storage 12x12 Floor Tile and Mastic Third Floor 950 sq. ft. Office, Storage

12x12 Floor Tile Mastic First Floor 380 sq. ft. Office, Storage

3.0 OPERATIONS AND MAINTENANCE PLAN

A successful O&M plan should address the following seven elements:

• Notification- program to tell workers, tenants, and building occupants where ACM is located, why occupants should avoid disturbing the ACM, and how to avoid disturbing the ACM. All persons affected should be properly informed.

• Surveillance- regular surveillance of the ACM to note, assess, and document any changes in the ACMʼs condition.

• Controls- work control and permit system to control activities that might disturb ACM.

• Work practices- O&M work practices to avoid or minimize fiber release during activities affecting ACM.

• Worker protection- medical and respiratory protection programs, as applicable (this is combined with work practices above.)

• Recordkeeping- documentation of O&M activities.

• Training- training of asbestos program manager (i.e., FAC) and custodial and maintenance staff.

Properly trained and authorized GSA maintenance workers may not disturb ACBM unless they are trained on using approved Class III asbestos work practices and the activity is approved by GSA Headquarters. Both GSA contractors and maintenance workers must utilize proper personal protective equipment and ensure the safety of the facility personnel during the course of any project that disturbs ACBM.

3.1 O&M PERSONNEL

The GSA Asbestos Program Coordinator (APC) is responsible for the overall coordination of asbestos-related issues in his/her particular building site. Each facility manager shall designate a Facility Asbestos Coordinator (FAC) if asbestos survey results indicate the need to establish an asbestos O&M Plan. The FAC will be responsible for all facility-specific asbestos issues.

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The name of the FAC must be submitted to the APC within 30 days of the receipt of the final O&M Plan.

The FAC will be responsible for the following tasks:

• Maintaining the appropriate asbestos notification, awareness and associated worker training records.

• Periodic visual re-inspections of ACBM.

• Permanent record keeping.

• Maintaining responsibility for issuance of work authorizations for facility specific asbestos work.

• Work controls.

The above tasks are described in detail in the sections below.

3.2 O&M PLAN OBECTIVES

The principal objective of this asbestos O&M program/plan is to detail facility specific ACBM management strategies and procedures, which will minimize exposure of building occupants and workers to asbestos fibers. To accomplish this objective, the O&M program includes work practices to maintain ACBM in good condition, ensure proper cleanup of asbestos fibers if released, prevent release of asbestos fibers, and monitor the condition of the ACBM, The O&M program also includes training of custodial and maintenance staff who may contact ACBM.

3.3 O&M PLAN MANAGEMENT

Management of the O&M plan will include the following elements: occupant and worker notification, building surveillance and re-inspection, work controls, specific O&M work practices for limiting asbestos fiber release, record keeping procedures, and O&M personnel training.

3.3.1 OCCUPANT & WORKER KNOWLEDGE

Notification The FAC will properly inform all affected building occupants of the presence and location of ACBM and PACM (Presumed Asbestos Containing Material), as well as, any actions that are planned to disturb ACBM or PACM and the results of all air monitoring or clearance sampling related to those actions. The FAC is also responsible for posting appropriate warning signs.

Awareness An awareness training session specific to each building will also be provided to the appropriate building occupants. This awareness training will include background information, health effects, regulatory review, site-specific information, standard work procedures, and proper response to asbestos fiber release. The awareness training session will identify when activities and operations should be restricted. These activities may include:

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RESTRICTED ACTIVITIES

1) All drilling, hammering, or any other construction or renovation activity that would disturb the asbestos-containing material at the facility. (Unless approved by a Competent Person)

2) All other activities that would disturb the positively identified ACBM including dust and loose debris where ACBM may be present.

3.3.2 BUILDING SURVEILLANCE

A visual re-inspection of all ACBM will be conducted every six months by a properly trained FAC as part of this O&M plan. This re-inspection will evaluate and record the current condition of known ACBM and alert the APC to any changes in conditions. Maintaining a set of photographs, which document the condition of the ACBM is recommended. The findings of these re-inspections must be recorded on electronic database and maintained in the permanent ACBM files.

If during the re-inspections there is reason to believe that damage has occurred to the ACBM or to the partition barrier (e.g., behind walls or above ceiling), the dust or debris should be tested to confirm if asbestos is present in this dust or debris. The suspect ACBM must be sampled by a qualified asbestos consultant/inspector. If friable ACBM is found, cleanup must be performed by a GSA approved asbestos contractor. In addition, if there is reason to believe that damage has occurred to the ACBM or to any partition barrier, air monitoring should be conducted. The design and performance of the air monitoring should be performed by a qualified asbestos consultant.

3.3.3 WORK CONTROLS

This O&M plan institutes a program to control work activities that could damage the buildingʼs ACBM. This program requires the person requesting the work to submit a job request to the FAC before beginning any maintenance work. The request gives the time and location of the requested work, the type of maintenance needed, and available information about any ACBM in the vicinity of the requested work. The contractor or other person authorized to perform the work is identified on the work request. The form serves as a chronological record of work events that occur in areas where ACBM may be disturbed. Follow the instructions on the form to ensure that it accurately documents any work performed in areas that contain ACBM.

GSA employees will not engage in any Class I or Class II work as defined by OSHA. In addition, no Class III asbestos work (as defined by OSHA) will be performed by GSA employees that require the use of respiratory protection or airtight enclosures for regulated areas.

3.3.4 WORK PRACTICES

GSA POLICIES AND REGULATIONS PROHIBIT GSA EMPLOYEES FROM ABATING ACBM

DURING THEIR NORMAL MAINTENANCE OPERATIONS. ONLY QUALIFIED, ACCREDITED

PERSONNEL SHALL CARRY OUT RESPONSE ACTIONS OR PERFORM MAINTENANCE

OPERATIONS WHICH DISTURB ACBM.

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All O&M procedures, which involve renovation, or emergency responses beyond the basic procedures outlined below will be contracted to GSA approved asbestos consulting firms and/or contractors. For this reason, a respiratory protection program will not be required as part of this O&M plan.

GSA custodial employees are limited to performing Class IV asbestos-related work as defined by OSHA. In addition, properly trained GSA maintenance employees may undertake Class III work practices that involves limited disturbance of non-friable asbestos containing materials. Such Class III work may be initiated when, 1) a Class III program has been authorized by district management, 2) the work is supervised by a district designated competent person and 3) the work is supported by negative exposure assessment (NEA) that confirms asbestos levels are below OSHAʼs permissible exposure limits. GSA employees cannot undertake any project that disturbs ACBM if that project is not consistent with District approved Class III work practices.

Several Class IV asbestos related work practices have been adopted for General Services Administration use nationwide. These work practices include general custodial work practices and care of asbestos containing floor material.

Other approved asbestos-related work practices may be available in your area. Coordinate with the APC for a complete listing of approved work practices.

As mentioned under the worker notification section of this O&M plan, certain activities within the building should be restricted. These activities include anything that would be likely to release fibers from the ACBM. For instance, fiber release can occur when workers drill, cut, break, or saw walls, ceilings, or floors.

Other activities may occur in the vicinity of the ACBM, which can cause damage to ACBM and may result in fiber release. For example, maintenance and custodial staff may damage ACBM barriers and/or ACBM accidentally with ladders while performing routine tasks. Such accidental damage may also result from building occupants during routine work activities within the facility.

All of these activities should be carefully controlled by use of work controls and occupant notification as described. If minor damage takes place, approved cleaning practices may be authorized by the facility asbestos coordinator. For the purposes of this O&M plan, minor damage is defined as damage to small amounts of intact non-friable materials such as floor tile.

O&M approved cleaning practices include the use of wet-wipe cleaning of surfaces such as floors and other horizontal surfaces. For example, proper O&M cleaning will involve the use of wet-cleaning (mopping) practices to pick up dust or debris. Dry sweeping or dusting can result in asbestos fibers being re-suspended into the buildingʼs air and therefore should not be used. Wet cloths, rags, or mops that have been used to pick up suspect asbestos fibers or debris should not be allowed to dry but placed inside a plastic bag and sealed. The facility asbestos coordinator must be consulted on proper disposal methods for each task or instance where asbestos disposal is necessary.

In all but the most minor of incidents, a GSA approved asbestos consultant should be retained to evaluate and make recommendations. In the event of an accidental release, the area of the release should be immediately isolated by closing doors or by evacuation of the building.

Signs should immediately be posted outside the fiber release site to prevent persons not involved in the cleanup operation from inadvertently entering the area.

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If asbestos fibers could enter the heating, ventilation, and air conditioning (HVAC) system, that system should be shut down and sealed off. The cleanup of such a release should be performed only by a GSA approved asbestos contractor.

3.3.5 RECORDKEEPING

All of the asbestos management documents discussed in this O&M plan, including: the plan itself;

inspection and assessment reports; work practices and procedures; fiber release reports;

maintenance work applications and approved forms; evaluations of work affecting ACBM; and surveillance reports of ACBM should be stored in permanent files.

These plans and reports and any other appropriate asbestos-related documents are designated as accountable records. The FAC maintains the original records at the facility and must transfer them to any subsequent owner of the facility. When the ACBM has been removed from the facility, all asbestos O&M program files and abatement case files are forwarded to the Federal Records Center and retained for 30 years.

In addition, for employees engaged in asbestos-related work, federal regulations require that employers retain the following records:

• Personal air sampling records, for at least 30 years (personal air samples are those collected in the workerʼs breathing zone during performance of work involving asbestos exposures).

• Objective data used to qualify for exemptions from OSHAʼs initial monitoring requirements for the duration of the exemption.

• Medical records for each employee, subject to duration of his or her employment plus 30 years.

• All employee-training records for 1 year beyond the last date of each workerʼs employment.

The EPA recommends that all written elements of the O&M program be made available to the O&M staff as well as to tenants and other building occupants. As a matter or policy, the GSA will make a written copy of the O&M plan available to all tenants.

3.3.6 WORKER TRAINING

ASBESTOS AWARENESS TRAINING (2 HOURS)

The training course is applicable for custodial personnel, maintenance and custodial personnel performing Class IV asbestos work, facility managers, and the FAC. On-site contractor personnel who perform similar work must have proof of equivalent training. The training course must include the following elements:

• Information on the various forms and uses of asbestos in the facility.

• Information on the health effects of exposure to asbestos.

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• Location of ACBM in the facility where the employee works.

• Recognition of deteriorating or damaged ACBM.

• The identity of the person responsible for management of ACBM.

• The regulations require that a refresher course be given annually.