Amend 0003 TX0262 Tyler Asbestos Reinspection-2014.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

(TX0262)

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 – TX0262

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 211 West Ferguson in Tyler, Texas (TX0262). 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 fitting sealant Roof drain fitting sealant Chilled/Heating water fitting sealant 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 corridors and large portions of floors 2 and 3.

II. FACILITY DESCRIPTION

The Federal Building and U.S. Courthouse at 211 West Ferguson, is a three story structure with a small mechanical penthouse. The steel and concrete structure rests on a reinforced concrete pier and slab foundation. Built in 1972, it has approximately 260,953 gross square feet. At the time of this audit, it housed three courtrooms and several federal agencies.

Heating and cooling is provided by a forced air system with chillers and a low pressure boiler in the basement of the building next door supplying air handling units on the first floor and penthouse. 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 often overlain by carpet.

III. SUMMARY OF ACM FINDINGS

Findings below are based on results from the Building Audit Surveys conducted in 1993 and 2007 and from additional sampling performed as part of this assessment. A total of 4 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

Dom. Water Fitting Sealant All Floors 800 lin. ft. Above Ceilings, Plenum, Chases

Roof Drain Fitting Sealant Third Floor 210 lin. ft. Above Ceilings

Domestic water fitting sealants were previously assessed per fittings. Since sealants are sometimes present on straights, the measurements have been changed to linear feet. Quantities reflect observable materials.

NOTE: Chilled/heating water fitting sealant was found to be asbestos containing by the 1993 survey report. These materials, previously identified in the mechanical room and penthouse have been replaced. Chilled/heating water fittings may still exist in enclosed chases.

For the most part these materials would be considered to have low accessibility and unlikely to be disturbed unless during demolition. Quantities are estimated.

Surfacing ACM Materials

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

There were no surfacing materials identified as containing asbestos.

Miscellaneous ACM Materials

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

Material Type Location Quantity Functional Space

12x12 Floor Tile and Mastic All Floors 9,750 sq. ft. Office, Storage Corridor

Residual Floor Tile Mastic All Floors 3,300 sq. ft. Office, Restroom Storage

Duct Insulation Mastic Mech. Room 104 NA Mechanical

Vinyl floor tile is overlain by carpet in many areas. Although every effort was made to accurately identify floor tile quantities in all areas, many areas were inaccessible and some rooms could not be verified without destructive investigation. Hence, a few areas were assumed to have floor tile under carpet without actual visual confirmation. Should future renovation require abatement of large quantities of floor tile, the GSA may elect to re-evaluate quantity estimates.

4 February 2014

In certain locations, residual black mastic remains under carpet tiles. In the kitchen 304, mastic is presumed to be present under new tile and mastic.

Duct insulation mastic (sealant) was sampled as part of the 2007 Reinspection and found to contain 2%-3% chrysotile asbestos. This light brown gummy non-friable material, painted white, was not identified by the original survey. It was unknown whether this material was present in 1993 or added after chilled/heating water system insulation was replaced. Asbestos containing mastic may be present in other areas of the building.

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 Cove base and mastic Spray-applied fireproofing Fiberglass thermal system insulating materials

Bulk Sample Results

The previous surveys included analytical results for sixty-nine bulk samples. A total four 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.

Response Action 7 - Low 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.

Restroom Chases Throughout Domestic Water Fitting Sealant

Above Ceilings

Above Ceilings Third Floor Roof Drain Fitting Sealant

Asbestos containing pipe fitting insulation sealants remains in isolated locations on all floors.

Most insulation is inaccessible within chases. No damage was observed.

5 February 2014

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

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

Restroom, Office Various Residual Tile Mastic Corridor Locations

Mechanical 104 Duct Insulation Mastic

Asbestos containing flooring materials may be obscured by carpet.

Duct mastic can be identified by its brown gummy texture. Itʼs presence was confirmed in room 104 only.

V. ACTION PLAN PRIORITIES

The Re-inspection of the U.S. Federal Building and Courthouse facility located in Tyler, TX 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 four 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 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

7 Low

6 February 2014

Material Type Location(s) Quantity Unit Price Cost

Dom. Fitting Sealants All Floors 800 lin. ft. $20.00/ft.. $16,000

Roof Drain Third Floor 210 lin. ft. $20.00/ea. $4,200 Fitting Sealants

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

12x12 Floor Tile/Mastic All Floors 9,750 sq. ft. $4.00/ft. $39,040

12x12 Floor Tile Mastic 109, 224, C2C 3,300 sq. ft. $4.00/ft. $13,200

Duct Insulation Mastic Mech. Room 104 NA NA NA

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.

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

7 February 2014 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.

Asbestos Audit – TX262

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

First Floor Thermal System 2 Miscellaneous ACM 3

Second Floor Thermal System 4

Miscellaneous ACM 5

Third Floor Thermal System 6 Miscellaneous ACM 7

A-2 February 2014

Drawing Not to Scale

9A

106B

106C

106F

9E

109F 110D 110C

110B

110A

106A

106D

109B109C109D

106E

C1A

Thermal System Insulation

Domestic Water Fitting Sealant

All domestic water fittings with sealants not represented on this drawing shoudl be assumed to be asbestos containing.

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

First Floor

Asbestos Reinspection

TX0262

A-3 February 2014

109A

106B

106C

106F

109E

109F

C1A

110D 110C

110B

110A

106A

106D

106E

109B109D

106E

110C110D

110B

110A

106A

106D

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

First Floor Miscellaneous ACM

Asbestos Reinspection February 2014

12x12 Floor Tile and Mastic

Floor Mastic Only

Duct Insulation Mastic

Brown gummy duct insulation mastic ideintified in Mech

104. The material may be present above ceilings.

A-4 February 2014

203A

211D

211A 211B

211C

208C 208D

208A 208B

204A 204B

204C

220A

220B

220C

220D

220E

220F

220G

216A

210A210B

210D

210E

1C2

C

Domestic Water Fitting Sealant

Thermal System Insulation

All domestic water fittings with sealants not represented on this drawing shoudl be assumed to be asbestos containing.

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Second Floor

Asbestos Reinspection

A-5 February 2014

203A

211D

211A 211B

211C

208C 208D

208A 208B

204A 204B

204C

220A

220B

220C

220D

220E

220F

220G

216A

210A210B

210D

210E

1C2

C

210A

210B

210D

217 210E

C2A

12x12 Floor Tile and Mastic

Floor Mastic Only

Miscellaneous ACM

Brown gummy duct insulation mastic ideintified in Mech

104. The material may be present above ceilings.

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Second Floor

Asbestos Reinspection

A-6 February 2014

C3B

C3C

319B

319A

318A

Domestic Water Fitting Sealant

Thermal System Insulation

308A308

314C

WR1

WR2

314D

314B

314A

305E

305C

C3A

Roof Drain Fitting Sealant All domestic water and roof drain fittings with sealants not represented on this drawing shoudl be assumed to be asbestos containing.

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Third Floor

Asbestos Reinspection

A-7 February 2014

C3C

319B

319A

318A

12x12 Floor Tile and Mastic

308A308

WR1

WR2

305E

305C

305D

C3A

Miscellaneous ACM

Brown gummy duct insulation mastic ideintified in Mech

104. The material may be present above ceilings.

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Third Floor

Asbestos Reinspection February 2014

TX0262

Floor Mastic Only

314C

314B

314A

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. First Floor 12x12 Floor Tile and Mastic Non Friable

2. Third Floor Residual Black Mastic Non Friable

3. Wall Chase Domestic Water Sealant Non Friable

B-3 February 2014

Photograph 1: Typical asbestos containing 12x12 floor tile and mastic found on all floors.

Photograph 2: Residual black floor tile mastic present under carpeting at various locations.

B-4 February 2014

Photograph 3: Typical asbestos containing domestic water system sealant found in chases and above ceilings.

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-4 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-6 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-7 February 2014

Sample Material Location Result NESHAP Number Type Category

01B Ceiling Tile 110 None Detected F 02B Joint Compound 211 None Detected 2 03B Fireproofing 204 None Detected F 04B Floor Tile 314 None Detected 1 Mastic None Detected 1

C-8 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-9 February 2014

109A

106B

106C

106F

109E

109F

C1A

110D 110C

110B

110A

106A

106D

109B109C109D

106E

Bulk Sample Locations

0 1 Ceiling Tile

(neg.)

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

First Floor

Asbestos Reinspection

C-10 February 2014

203A

211D

211A 211B

211C

208C 208D

208A 208B

204A 204B

204C

220A

220B

220C

220D

220E

220F

220G

216A

210A210B

210D

210E

1C2

C

Bulk Sample Locations

0 2 Joint Compound

(neg.)

0 3 Fireproofing

(neg.)

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

First Floor

Asbestos Reinspection

C-11 February 2014

C3C

319B

319A

318A

308A308

314C

WR1

WR2

314D

314B

314A

305E

305C

C3A

Federal Building and U.S. Courthouse

211 W. Ferguson Tyler, Texas

Third Floor

Asbestos Reinspection

TX0262 Bulk Sample Locations

Asbestos O&M – TX0262

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 (TX0262) 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 (TX0262) U. S. Federal Building and Courthouse 201 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

Dom. Water Fitting Sealant All Floors 800 lin. ft. Above Ceilings, Plenum, Chases Roof Drain Fitting Sealant Third Floor 210 lin. ft. Above Ceilings

Domestic water fitting sealants were previously assessed per fittings. Since sealants are sometimes present on straights, the measurements have been changed to linear feet. Quantities reflect observable materials.

NOTE: Chilled/heating water fitting sealant was found to be asbestos containing by the 1993 survey report. These materials, previously identified in the mechanical room and penthouse have been replaced. Chilled/heating water fittings may still exist in enclosed chases.

For the most part these materials would be considered to have low accessibility and unlikely to be disturbed unless during demolition. Quantities are estimated.

Surfacing ACM Materials

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

There were no surfacing materials identified as containing asbestos.

Miscellaneous ACM Materials

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

Material Type Location Quantity Functional Space

12x12 Floor Tile and Mastic All Floors 9,750 sq. ft. Office, Storage Corridor Residual Floor Tile Mastic All Floors 3,300 sq. ft. Office, Restroom Storage Duct Insulation Mastic Mech. Room 104 NA Mechanical

D-4 February 2014

Vinyl floor tile is overlain by carpet in many areas. Although every effort was made to accurately identify floor tile quantities in all areas, many areas were inaccessible and some rooms could not be verified without destructive investigation. Hence, a few areas were assumed to have floor tile under carpet without actual visual confirmation. Should future renovation require abatement of large quantities of floor tile, the GSA may elect to re-evaluate quantity estimates.

In certain locations, residual black mastic remains under carpet tiles. In the kitchen 304, mastic is presumed to be present under new tile and mastic.

Duct insulation mastic (sealant) was sampled as pert of the 2007 Reinspection and found to contain 2%-3% chrysotile asbestos. This light brown gummy non-friable material, painted white, was not identified by the original survey. It was unknown whether this material was present in 1993 or added after chilled/heating water system insulation was replaced. Asbestos containing mastic may be present in other areas of the building.

D-5 February 2014

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.

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.

D-6 February 2014

• 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:

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.

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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.

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.

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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.

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

D-9 February 2014 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.

• 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.