B08_Attachment_8_-_BICR_Abatement_Plan_Specifications_Report.pdf

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BICR 316236 - Rehabilitate Civil Rights Structures
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This document is a Report of Abatement Plan Specifications for the National Park Service (NPS) BICR project to rehabilitate the Gaston Motel in Birmingham, Alabama. The report, prepared by NOVA Engineering and Environmental, LLC on April 29, 2024, details comprehensive abatement specifications for asbestos and lead-based paint removal.

The abatement plan identifies three primary areas of hazardous material removal: black mastic containing 3% Chrysotile asbestos on concrete slabs, green/brown leveler with 3-5% Chrysotile asbestos in the front lobby and restroom, and black cement with 5% Chrysotile asbestos on wood beam framing. The specifications outline strict protocols for worker safety, including respiratory protection, personnel training, work area preparation, material handling, and disposal procedures. The document includes detailed requirements for personal protective equipment, air monitoring, waste containment, and compliance with federal regulations from EPA, OSHA, and Alabama environmental management agencies.

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REPORT OF ABATEMENT PLAN

SPECIFICATIONS

NPS BICR – Rehabilitate Gaston Motel Birmingham, Jefferson County, Alabama

PREPARED FOR:

Houser Walker Architecture

1819 Peachtree Road, NE

Suite 102

Atlanta, Georgia 30309

NOVA Project Number: 10102-3024037

April 29, 2024

P R O F E S S I O N A L | P R A C T I C A L | P R O V E N

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April 29, 2024

HOUSER WALKER ARCHITECTURE

1819 Peachtree Road, NE

Attention: Mr. Rick Bizot AIA, LEED AP

Project Manager

Subject: Report of Abatement Plan Specifications

NPS BICR – REHABILITATE GASTON MOTEL

NOVA Project Number 10102-3024037

Dear Mr. Bizot:

NOVA Engineering and Environmental, LLC (NOVA) has completed the Abatement Plan

Specifications for the National Park Service (NPS) BICR – Rehabilitate Gaston Motel located at

1510 5TH Avenue in Birmingham, Jefferson County, Alabama. We appreciate your selection of

NOVA and for the opportunity to be of service on this project. Please feel free to contact us if you have any questions or if we may be of further assistance.

Sincerely, NOVA Engineering and Environmental, LLC

Curtis Moses Nickolaus DaSantos

Staff Professional Business Unit Manager

Environmental Services Environmental Services

AHERA No. 19414 AHERA No. 19496

EPA Lead Inspector No. 2076 EPA Lead Inspector No. 2124

AL Inspector No. LIN0123610139 Project Designer No. 4663

TABLE OF CONTENTS

1.0 ASBESTOS ABATEMENT

1.1 SUMMARY OF WORK

1.2 DEFINITIONS FOR SECTION 1

1.3 CODES AND REGULATIONS

1.4 QUALIFICATIONS OF TESTING LABORATORY

1.5 PAYMENT FOR TESTING

1.6 RESULTS

1.7 TRAINING PROGRAM

1.8 PRE-CONSTRUCTION SUBMITTALS

1.9 POST-CONSTRUCTION SUBMITTALS

1.10 WORKSITE CONDITIONS

1.11 PERSONNEL PROTECTION

1.12 PRODUCTS

1.13 WORK AREA PREPARATION AND ABATEMENT

1.14 DISPOSAL OF ASBESTOS CONTAINING MATERIAL

2.0 LEAD PAINT ABATEMENT

2.1 SUMMARY OF WORK

2.2 DEFINITIONS

2.3 CODES AND REGULATIONS

2.4 PAYMENT AND TESTING

2.5 QUALIFICATIONS OF TESTING LABORATORY

2.6 TRAINING PROGRAM

2.7 PRE-CONSTRUCTION SUBMITTALS

2.8 POST-CONSTRUCTION SUBMITTALS

2.9 WORKSITE CONDITIONS

2.10 PERSONNEL PROTECTION

2.11 WORK AREA PREPARATION AND ABATEMENT

2.12 DISPOSAL OF WASTE

3.0 CLEAN-UP

4.0 FIELD QUALITY CONTROL

LIST OF APPENDICES

APPENDIX A – REPORT DOCUMENTS (NOVA ENGINEERING AND ENVIRONMENTAL, LLC – REPORT NUMBER

10102-3023033.1)

APPENDIX B – CERTIFICATE OF WORKERS ACKNOWLEDGEMENT

APPENDIX C – PERSONNEL QUALIFICATIONS

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

1.0 ASBESTOS ABATEMENT

Perform all planning, administrative, execution, and cleaning requirements necessary to safely remove asbestos-containing material identified in the environmental Services

Report prepared by NOVA Engineering and Environmental, LLC (NOVA Project Number

10102-3023033.1) dated July 18, 2023, (hereafter referred to as the Report). A copy of this report is included in Appendix A of these specifications.

NOTE: CONTRACTOR IS RESPONSIBLE FOR VERIFYING EXACT MATERIAL QUANTITIES.

1.1 SUMMARY OF WORK

Upon request, the Contractor must remove and dispose of the following Asbestos-

Containing Material (ACM) identified in the Report:

• Black Mastic – Black mastic associated with the concrete slab was identified to contain 3% Chrysotile asbestos.

• Green/Brown Leveler – Green/brown leveler associated with the concrete slab in the front lobby was identified to contain 3% - 5% Chrysotile asbestos.

• Black Cement – Black cement associated with the top of the wood beam framing was identified to contain 5% Chrysotile asbestos.

Determination of the actual quantities of ACM at all locations should be made by the abatement contractor during a site inspection prior to beginning abatement. The possibility exists that additional asbestos-containing material may be discovered during the course of renovations (i.e. pipe insulation concealed in block walls and pipe chases).

All work must be performed in accordance with the rules specified in Section 1.3 of this specification. Contractor to perform personnel air monitoring, including excursion limit sampling (EL), required for compliance with the applicable United States Occupational

Safety and Health Administration (OSHA) regulations throughout the course of abatement activities.

1.2 DEFINITIONS FOR SECTION 1

• Abatement – procedures to remove asbestos containing material. Includes encapsulation, enclosure and removal.

• Air Monitoring – the process of measuring the fiber content of a specific volume of air in a stated period of time.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

• Amended water – water to which a surfactant is added.

• Asbestos Containing Material (ACM) - any material which contains more than one percent (>1%) asbestos as determined by Polarized Light Microscopy.

• Category I Nonfriable Material - As defined by the United States Environmental

Protection Agency (EPA), asbestos-containing packings, gaskets, resilient floor covering, mastics and asphalt roof products (such as asphalt shingles, built-up roofing, and single-ply modified bitumen roofing) containing more than one percent asbestos as determined by Polarized Light Microscopy.

• Category II Nonfriable Material - As defined by the EPA, any material, excluding

Category I nonfriable asbestos-containing material (such as asbestos cement shingles, siding, fascia/parapet panels and cementitious stuccos) containing more than one percent asbestos as determined by Polarized Light Microscopy, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

• Class I Asbestos Work – activities involving the removal of thermal system insulation

(TSI), surfacing ACM and Presumed Asbestos Containing Material (PACM).

• Class II Asbestos Work - activities involving the removal of ACM flooring, mastics, roofing materials, wallboard, and other materials as defined in the OSHA regulations.

• Competent Person - As defined by OSHA, one who, in addition to the definition in 29

CFR 1926.32 (f), is capable of identifying existing asbestos hazards and selecting the appropriate control strategy for asbestos exposure, and who has the authority to take prompt corrective measures to eliminate them. In addition, the Competent

Person for asbestos work must complete specified training.

• Cutting - As defined in the EPA NESHAP, penetrating with a sharp edged instrument and includes sawing, but does not include shearing, slicing, or punching. The use of a Rotating Blade (RB) roof cutter or abrasive disk saw meets the definition of cutting when used on roofing materials.

• Encapsulation - the sealing of asbestos surfaces involving application of a material

(encapsulant/sealant) that will envelop or coat the fiber matrix and minimize fiber fallout and protect against contact damage.

• Enclosure - procedures necessary to completely enclose material containing asbestos behind airtight, impermeable, permanent barriers.

• EPA - United States Environmental Protection Agency.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

• Excursion Limit (EL) - Exposure to an airborne fiber concentration, measured by

Phase Contrast Microscopy (PCM), in the breathing zone of 1.0 fibers per cubic centimeter (f/cc) as a thirty-minute time weighted average (TWA).

• Friable - a material which can be crumbled or pulverized by hand pressure.

• Glove Bag - Provide commercially available glove bag assemblies constructed of a minimum of six-mil plastic sheeting and permanent, securely attached sleeves and gloves. For high temperature (greater than 120 degrees Fahrenheit) applications, provide glove bags constructed of suitable materials. Onsite modifications to glove bags or use contrary to manufacturer's instruction must be submitted in writing to the abatement design professional for review and approval prior to initiation of work.

• High Efficiency Particulate Air (HEPA) Filter - a HEPA filter capable of trapping and retaining 99.97 percent of asbestos thermally generated DOP particles 0.3 microns in diameter.

• HEPA Vacuum Equipment - High Efficiency Particulate Air filtered vacuuming equipment with a filter system capable of collecting and retaining asbestos fibers.

Filters should be 99.97 percent efficient for retaining thermally generated DOP particles 0.3 microns in diameter.

• Incidental asbestos-containing roofing material (ACRM) - As defined by OSHA, asbestos-containing roof coatings, mastics, cements, and flashings.

• Intact - As defined by OSHA, an ACM has not crumbled, been pulverized, or otherwise deteriorated so that it is no longer likely to be bound with its matrix.

• Negative Exposure Assessment (NEA) - A determination in accordance with the OSHA standards that employee exposures are, or that there is a high degree of certainty they will be, below the Permissible Exposure Limit (PEL) and EL.

• NIOSH - National Institute for Occupational Safety and Health.

• OSHA – United States Occupational Safety & Health Administration.

• Permissible Exposure Limit (PEL) - Exposure to an airborne fiber concentration, measured using Phase Contrast Microscopy (PCM), in the breathing zone of 0.1 fibers per cubic centimeter (f/cc) over an eight-hour time weighted average (TWA).

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

• Plastic Sheeting - plastic sheet material used for protection of walls, floors, etc. and used to seal openings into work areas. The thickness of the material shall be as specified.

• Rotating Blade (RB) Roof Cutter - An engine powered roof cutting machine with one or more rotating cutting blades, the edges of which are blunt. Equipment with sharp or tapered edge blades is not included in this definition.

• Regulated Area - An area established where OSHA Class I, II, or III asbestos work is conducted, and any adjoining area where debris and waste from such asbestos work accumulate; and a work area within which airborne concentrations of asbestos exceed, or there is reasonable possibility they may exceed the PEL and EL. A regulated area must be demarcated with barriers and signage to allow only access by authorized, trained persons.

• Regulated Asbestos-Containing Material (RACM) - As defined by the EPA, includes friable ACM; Category I non-friable ACM that has become friable; Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or, Category II non-friable ACM that has a high probability of becoming, or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations.

• Removal - the act of removing asbestos-containing or contaminated materials from a structure and depositing in a suitable disposal site.

• Scaffolding - self-supporting and load bearing temporary structure.

• Surfactant - a chemical wetting agent added to water to improve its penetrating ability and, thus reducing the quantity of water required to saturate asbestos-containing materials.

• Wet Cleaning - the process of eliminating asbestos contamination from building surfaces and objects by using cloths, mops, or other cleaning tools which have been dampened with amended water, and by afterwards disposing of these cleaning tools as asbestos- contaminated waste.

• Work area - area or areas of Project which undergo "abatement" or are contaminated.

See also regulated area.

• Working Day - Monday through Friday, excluding holidays which fall on Monday through Friday.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

1.3 CODES AND REGULATIONS

A. General Applicability of Codes and Regulations, Guidelines and Standards:

Except to the extent that more explicit or more stringent requirements are written directly into the contract documents, all applicable codes, regulations, guidelines and standards have the same force and effect (and are made a part of the contract documents by reference) as if copied directly into the contract documents, or as if published copies are bound herewith.

B. Contractor Responsibility: The Contractor shall assume full responsibility and liability for the compliance with all applicable federal, state, and local regulations pertaining to work practices, protection of workers, visitors to the site, and persons occupying areas adjacent to the site. The Contractor shall hold the Owner and Designer(s) of this specification harmless for failure to comply with any applicable work, packaging, salvaging, delivering, safety, health or other regulation on the part of himself, his employees, or his subcontractors.

C. Qualifications for Performance of Work:

1. Contractor (or subcontractor engaged to perform the work of this Section) shall:

a. Be a certified and licensed asbestos contractor in accordance with the

Alabama Asbestos Contractor Accreditation Program required by the

Alabama Department of Environmental Management (ADEM). Submit documentation confirming current licensure.

b. Utilize workers and supervisors who are trained in accordance with the ADEM for Class I and II activities. Submit documentation confirming current training.

D. Reference Standards:

1. The Contractor acknowledges, by the executing of the contract, awareness and familiarity with the contents and requirements of the following regulations, codes, and standards, and assumes responsibility for the performance of the work in strict compliance therewith and, for every instance of failure, to comply therewith.

2. The current issue of each document shall govern. Where conflict among requirements or with the contract documents exists, the more stringent requirements shall apply.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

a. U.S. Environmental Protection Agency (EPA) Regulations for

Asbestos (Code of Federal Regulations Title 40, Part 61, Subparts

A and B).

b. U.S. EPA National Emissions Standards for Hazardous Air

Pollutants (Code of Federal Regulations Title 40, Part 61, Subpart

M).

c. U.S. EPA National Emissions Standards for Hazardous Air

Pollutants (Code of Federal Regulations Title 40, Part 61, Appendix A to Subpart M).

d. U.S. EPA Asbestos Hazard Emergency Response Act (AHERA) regulations (Code of Federal Regulations Title 40 Part 763, Subpart E).

e. U.S. Occupational and Safety and Health Administration (OSHA)

Asbestos Regulations (Code of Federal Regulations Title 29, Part

1926, Section 1926.1101).

f. U.S. EPA Office of Pesticide and Toxic Substances Guidance

Document, "Guidance for Controlling Friable Asbestos-Containing

Materials in Buildings", EPA 56015-85-024, June, 1985.

g. U.S. Department of Transportation, Hazardous Substances: Final

Rule (Code of Federal Regulations Title 49 Parts 171 and 172), Federal Register November 21, 1986 and corrected February 17, 1987.

h. Alabama Department of Environmental Management Land

Division – Solid Waste Program, Division 13

i. State of Alabama Rules for Air Pollution Control.

j. Asbestos-containing materials require special care and handling.

Contact the Special Services Section, Air Division, ADEM, 334-

271-7879, for requirements for asbestos management.

Asbestos-containing material may be disposed of in any permitted landfill in Alabama with written approval from ADEM, following the special waste provisions found in ADEM regulations at ADEM Admin. Code 335-13-4-.26(2). The solid waste regulations are available on the ADEM Internet web site at www.adem.state.al.us/regulations/div13.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

k. All state, county, and city codes and ordinances as applicable.

Make available for review at the site one copy of EPA, OSHA, and applicable state, county, and city regulations governing the work.

1.4 QUALIFICATIONS OF TESTING LABORATORY

A. Testing Laboratory shall participate in the Proficiency Analytical Testing (PAT) program administered by the National Institute for Occupation Safety and Health

(NIOSH). Testing Laboratory shall have been proficient on all samples for the last two (2) consecutive rounds.

1.5 PAYMENT FOR TESTING

A. The Contractor will provide a testing laboratory for the duration of asbestos removal for the OSHA personnel air samples. Area and final clearance samples may be performed by the Owner’s Representative.

B. Contractor will pay for testing services for the OSHA personnel air samples.

C. Retesting: When initial final clearance air tests by Owner’s Representative, indicate non-compliance with the asbestos industry’s final clearance standard, subsequent retesting occasioned by the noncompliance shall be performed at the cost of the Contractor.

1.6 RESULTS

A. All OSHA personnel testing and analysis will be performed promptly and results issued expeditiously in order to minimize any possible delay in the progress of the work.

B. Test results will be available to Owner or Owner’s Representative as follows:

1. OSHA personnel air sample results (Phase Contrast Microscopy) - as quickly as possible and/or within five (5) working days following completion of test(s).

1.7 TRAINING PROGRAM

A. Training Requirements for Licensed Asbestos Contractors:

1. The following training requirements apply to state licensed asbestos abatement contractors who remove all categories of asbestos-containing material.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

a. Each worker shall complete a state approved, EPA accredited, Asbestos Worker course and annual refreshers.

b. Each Competent Person shall complete a state approved, EPA accredited, Asbestos Supervisor course and annual refreshers.

1.8 PRE-CONSTRUCTION SUBMITTALS

A. Submittals to Owner’s Representative Prior to Beginning Work

1. Submit a copy of the Alabama Project Notification Form for Asbestos

Renovation, Encapsulation, or Demolition to the State of Alabama

Department of Environmental Management. This notice shall be filed in accordance with the NESHAP standard not less than ten (10) working days before asbestos removal commences on the project.

2. Certificate of Worker Acknowledgment: Submit an original signed copy of the Certificate of Worker's Acknowledgment found at the end of this

Section, for each worker who is to be at the job site or enter the work area(s).

3. Respiratory Protection Schedule: Submit level of respiratory protection intended for each operation required by the project. Submit this information on the "Respiratory Protection Schedule" form included at the end of this Section. Include an OSHA compliant Negative Exposure

Assessment if no respiratory protection is proposed for use on this project.

4. Respirator Fitting Documentation: Submit documentation indicating successful fit check testing of respirators, if used, for the individuals working on this project in accordance with 29 CFR 1910.134. and 29 CFR

1926.1101.

5. Submit product data indicating compliance with the contract documents for products and equipment to be utilized on the project. Include manufacturer's instruction and Safety Data Sheets (SDS) sheets (as applicable).

1.9 POST-CONSTRUCTION SUBMITTALS

A. Submit copies of receipts from landfill operator which acknowledge the

Contractor's delivery(s) of asbestos-containing waste material. Receipts shall include date, quantity of material delivered, and signature of authorized representative of landfill. Include copy of the completed waste shipment record required by NESHAP. All receipts shall be forwarded digitally and in hard copy form to:

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

Mr. Rick Bizot

Project Manager

Houser Walker Architecture

1819 Peachtree Road, NE

Suite 102 rick@houserwalker.com

B. Submit copies of training documentation for additional workers and supervisors not previously submitted.

C. Submit evidence of compliance with the applicable OSHA regulation including, as a minimum, copies of employee air monitoring results.

1.10 WORKSITE CONDITIONS

A. Worker and Visitor Procedures: The Contractor is hereby advised that asbestos has been determined by the U.S. Government to be a CANCER-CAUSING AGENT and Contractor shall provide workers with respirators which as a minimum shall meet the requirements of OSHA 29 CFR 1926.1101, and protective clothing during preparation of system of enclosures, prior to commencing, during actual asbestos removal, and until final clean-up is completed. The Contractor shall provide visitors, limited to qualified third party abatement oversight, asbestos inspectors, and the abatement design professional, with protective clothing during preparation of system of enclosures, prior to commencing, during actual asbestos removal, and until final clean-up is completed.

1.11 PERSONNEL PROTECTION

A. Prior to commencement of work, all workers shall be instructed by the Contractor and shall be knowledgeable, in the appropriate procedures of personnel protection and asbestos removal.

B. Contractor acknowledges and agrees that he is solely responsible for enforcing worker protection requirements at least equal to those required by federal

C. Negative Exposure Assessment (NEA):

1. Provide a negative exposure assessment as described in 29 CFR

1926.1101 for each operation to justify the selection of the appropriate respiratory protection for each activity including work area preparation, removal of ACM, work area clean-up, and disposal at the landfill.

mailto:rick@houserwalker.com

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

2. Obtain PEL and excursion limit air sampling from either prior asbestos jobs within the last 12 months or initial exposure monitoring from this project to generate a negative exposure assessment.

3. Air sample data from previous asbestos jobs must include documentation that the data was obtained during operations which closely resemble the processes, type of ACM, control methods, work practices, and environmental conditions used and prevailing on this project. Include documentation that the training and experience of the workers on the prior asbestos jobs was no more extensive than that of the workers on this project.

Documentation shall be sufficient to determine that the conditions prevailing, and which will prevail on the current project, will, with a high degree of certainty, not result in employee exposures above the PEL or excursion limit. Previous documentation shall be obtained for projects wherein the exact same personnel utilized on the previous project will be utilized on this project.

4. Revise and resubmit the respiratory protection schedule, with attached supporting documentation, for the project, if initial exposure assessments result requires, or allowed change in respiratory protection for any of the work activities listed above.

D. Contractor shall provide workers with personally issued and marked respiratory equipment approved by NIOSH and OSHA and as a minimum suitable for the asbestos exposure level in the work areas.

1. Type of respiratory protection required:

a. Fibers: For purposes of this Section, fibers are defined as all fibers regardless of composition as counted using the OSHA Reference

Method (ORM) or NIOSH 7400 procedures, or asbestos fibers of any size as counted using a transmission electron microscope.

b. Provide Respiratory Protection as allowed by these specifications.

For the work of all sections, the level of respiratory protection that supplies an airborne fiber concentration inside the respirator below 0.01 fibers per cubic centimeters (f/cc) is the minimum level of protection allowed. Regardless of the anticipated fiber concentrations, half-face air purifying respirators shall be the minimum level of respiratory protection for removal and cleaning activities. Determine the proper level of protection by dividing the expected or actual airborne fiber concentration in the work area by the "Protection Factors" given below:

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

RESPIRATORY PROTECTION FACTOR:

Respirator Type Protection Factor

Air purifying:

Negative-pressure respirator, High efficiency filter, Half-face piece

Air purifying:

Negative-pressure respirator, High efficiency filter, Full-face piece

Powered air purifying (PAPR):

Positive-pressure respirator, High efficiency filter, Full-face piece

Type C supplied air:

Positive-pressure respirator, pressure-demand, Full-face piece

Type C supplied air:

Positive-pressure respirator, pressure-demand, Full-face piece, Equipped with an auxiliary positive-pressure Self-contained breathing apparatus (SCBA) over 1000

E. Where respirators with disposable filters are used, provide sufficient filters for replacement as necessary by the workers, or as required by applicable

F. Permit no visitors, except for governmental inspectors having jurisdiction, or qualified personnel in the work areas after commencement of asbestos disturbance or removal.

G. Provide workers with sufficient sets of protective disposable clothing, consisting of full-body coveralls, head covers, gloves, and foot covers; of sizes to properly fit individual workers in accordance with 29 CFR 1926.1101.

H. Provide authorized visitors with a set of suitable protective disposable clothing, headgear, eye protection, and footwear of sizes to properly fit visitors whenever they are required to enter the work area.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

1.12 PRODUCTS

1.12.1 MATERIAL

A. Impermeable containers - Shall be suitable to receive and retain asbestos-containing or contaminated materials until disposal at an approved site and shall be labeled in accordance with OSHA Regulation 29 CFR 1926.1101, and U.S. DOT 49 CFR 171 and 172, containers shall be both air and watertight.

Use a minimum of two types of impermeable containers: 1) two six mil plastic bags; 2) dumpster, dump truck, or trailer lined with two layers of six-mil plastic sheeting secured with tape.

B. Warning labels and signs - Shall be posted as required by OSHA regulation

29 CFR 1926.1101 (and U.S. DOT 49 CFR 171 and 172 for impermeable containers).

C. Plastic Sheeting - Provide flame resistant 6.0 mil thick polyethylene film that conforms to requirements set forth by the National Fire Protection Association

Standard 701, Small Scale Fire Test for Flame-resistant Textiles and Films.

Provide the largest size possible to minimize seams.

D. Duct Tape - glass fiber or other type capable of securing adjacent sheets of plastic and attachment of plastic sheeting to finished and unfinished surfaces of dissimilar materials under wet and dry conditions.

E. Other materials - Provide all other materials, such as lumber, nails and hardware, which may be required to construct and dismantle the decontamination area and the barriers that isolate the work area(s).

1.12.2 TOOLS AND EQUIPMENT

A. OSHA personnel air sampling pumps shall be battery powered, intended for collection of air samples.

B. Air sample cassettes shall be commercially available 25 millimeter, non-conductive cowl units with a 0.8 micron mixed cellulose ester filter and cellulose pad which comply with the requirements of NIOSH Method 7400.

C. Provide suitable tools for asbestos removal including but not limited to:

1. Sprayer - Utilize airless or other low-pressure sprayer for amended water application.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

2. Scaffolding and Ladders – that may be required to accomplish any of the specified work tasks shall meet all applicable safety regulations.

4. Transportation - As required for loading, temporary storage, transit, and unloading of contaminated waste without exposure to persons or property.

1.13 WORK AREA PREPARATION AND ABATEMENT

1.13.1 ASBESTOS-CONTAINING MASTIC AND/OR CEMENT

A. Coordinate with Owner for HVAC supplying work area(s) to remain off during abatement activities.

B. Isolate the work area(s) until completion of abatement activities, by completely sealing off all openings such as vents, nearby doorways, breaches in block walls, other penetrations of the work area(s) with a minimum of a single layer of 6-mil poly sheeting sealed with tape.

C. Ensure that all barriers and critical seals remain effectively sealed and taped for duration of asbestos removal and subsequent cleaning. Repair damaged barriers and remedy defects immediately upon discovery.

D. Access to the work area(s) shall be limited to authorized personnel only. The work area(s) shall be regulated utilizing barrier tape and warning signs posted at the approach to each work area in accordance with the EPA and OSHA requirements.

E. Provide temporary power, water, and lighting, utilizing ground fault protection devices as necessary.

F. Notify Owner’s Representative for observation of the preparation of jobsite prior to any removal of ACM.

G. Maintain for the duration of the Project from the first activity requiring disturbance of ACM, a sign in/out log in the immediate area of the change room(s). Log shall be utilized by every person and each time upon entering and leaving the work area(s). Submit copies of this log to Owner for permanent file upon completion of project.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

H. A decontamination wash station shall be available to workers upon exit of the work area. The wash station shall include, but not limited to, a properly labeled

6-mil poly disposal bag for disposal of protective suits and used towels. It is recommended all workers properly decontaminate in the wash station.

I. Thoroughly wet the asbestos-containing mastic. Wetting of the material shall be only sufficient to prevent the release of asbestos fibers and shall not create unsafe working conditions.

J. Remove the material by utilizing wet scraping and solvent techniques.

K. Waste should be bagged in 6-mill marked bags prior to leaving the work area.

L. Containerized waste shall be hand or cart carried to disposal container(s).

1.13.2 ASBESTOS-CONTAINING LEVELER

A. Coordinate with Owner for HVAC supplying work area(s) to remain off during abatement activities.

B. Isolate the work area(s) until completion of abatement activities, by completely sealing off all openings such as vents, nearby doorways, breaches in block walls, other penetrations of the work area(s) with a minimum of a single layer of 6-mil poly sheeting sealed with tape.

C. Ensure that all barriers and critical seals remain effectively sealed and taped for duration of asbestos removal and subsequent cleaning. Repair damaged barriers and remedy defects immediately upon discovery.

D. Access to the work area(s) shall be limited to authorized personnel only. The

E. Provide temporary power, water, and lighting, utilizing ground fault protection

F. Notify Owner’s Representative for observation of the preparation of jobsite prior to any removal of ACM.

G. Maintain for the duration of the Project from the first activity requiring disturbance of ACM, a sign in/out log in the immediate area of the change room(s). Log shall be utilized by every person and each time upon entering and leaving the work area(s). Submit copies of this log to Owner for permanent file upon completion of project.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

H. A decontamination wash station shall be available to workers upon exit of the work area. The wash station shall include, but not limited to, a properly labeled

6-mil poly disposal bag for disposal of protective suits and used towels. It is recommended all workers properly decontaminate in the wash station.

I. Thoroughly wet the asbestos-containing mastic. Wetting of the material shall be only sufficient to prevent the release of asbestos fibers and shall not create unsafe working conditions.

J. Remove the material by utilizing wet scraping and solvent techniques.

K. Waste should be bagged in 6-mill marked bags prior to leaving the work area.

L. Containerized waste shall be hand or cart carried to disposal container(s).

1.14 DISPOSAL OF ASBESTOS CONTAINING MATERIAL

A. Properly remove and dispose of the ACM in accordance with the methods and procedures outlined in the U.S. Department of Labor Occupational Safety and

Health Administration (OSHA) Asbestos Regulation (Code of Federal Regulations

Title 29, Part 1926, Section 1926.1101) or as more stringently specified herein.

1.14.1 DISPOSAL OF WASTE

A. Disposal of the waste will be at an authorized landfill for the waste.

B. Containerized and/or sealed asbestos material shall be immediately transferred to closed receptacle in such a manner as to preclude the dispersion of dust.

C. Seal asbestos waste in accordance with Title 29, Code of Federal Regulations, Section 1926.1101, and Title 49, Code of Federal Regulations, Sections 171 and 172.

D. Use only enclosed or covered trucks or dumpsters to haul ACM to approved landfill.

E. Submit to the Owner Representative, any waste manifests after completion of the project.

F. Following the last trip to dispose of contaminated waste, all plastic sheeting shall be removed from the walls and floor of the truck or dumpster and also be disposed of as contaminated waste.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

2.0 LEAD PAINT ABATEMENT

Perform all planning, administrative, execution, and cleaning requirements necessary to safely remove Lead Based Paint (LBP) identified in the environmental Services Report prepared by NOVA Engineering and Environmental, LLC (NOVA Project Number 10102-

3022211) dated March 30, 2023. A copy of this report is included in Appendix A of these specifications.

2.1 SUMMARY OF WORK

The Contractor must remove and dispose of the following Lead Based Paint (LBP) and

Lead Containing Paint (LCP) identified in the Report that will be impacted as part of the renovations:

Lead Based Paint

• Painted surfaces of metal structural beams, columns, and stairwell riser components located at the Subject Property.

Lead Containing Paint

• Painted surfaces of green concrete located at the Subject Property.

The possibility exists that additional LBP and/or LCP may be discovered during the course of renovations (i.e. material concealed behind existing walls, etc.).

Please note that OSHA does not define Lead Based Paint based on lead content. Any detectable lead in a paint or varnish makes it lead paint for purposes of complying with

OSHA regulations to determine worker exposure. Consequently, for purposes of this study, Lead Containing Paint is considered any detectable lead.

2.2 DEFINITIONS

• Abatement - procedures to remove lead-based paint material. Includes encapsulation, enclosure and removal.

• Action Level – employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 30 micrograms per meter cubed (ug/m^3) over an eight (8) hour time weighted average (TWA).

• Competent Person - As defined by OSHA, one who is capable of identifying existing lead-based paint hazards and selecting the appropriate control strategy for lead exposure, and who has the authority to take prompt corrective measures to eliminate them. In addition, the Competent Person for lead work must complete specified training.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

• Encapsulation - the sealing of lead-based paint surfaces involving application of a material (encapsulant/sealant) that will envelop or coat the matrix and minimize fallout and protect against contact damage.

• Enclosure - procedures necessary to completely enclose material containing lead behind airtight, impermeable, permanent barriers.

• EPA - United States Environmental Protection Agency.

• High Efficiency Particulate Air (HEPA) Filter - a HEPA filter capable of trapping and retaining 99.97 percent of thermally generated DOP particles 0.3 microns in diameter.

• HEPA Vacuum Equipment - High Efficiency Particulate Air filtered vacuuming equipment with a filter system capable of collecting and retaining airborne particles larger than 0.3 microns. HEPA Vacuum Filters should be 99.97 percent efficient.

• Intact - As defined by OSHA, LBP has not crumbled, been pulverized, or otherwise deteriorated so that it is no longer likely to be bound to its substrate.

• Lead Based Paint - paint or varnish containing lead at a concentration >0.5% by weight when determined by laboratory analysis, (1972, Lead Based Paint Poison

Prevention Act (LBPPPA)). LBP is also defined by HUD as 1.0 mg/cm2 when determined using an x-ray fluorescence (XRF) analyzer. These concentrations are applicable for housing and child-care facilities; however, these concentration levels are also frequently used as targets in commercial projects to allow flexibility in future area usage.

• Lead Containing Paint - paint or varnish containing lead at any concentration. OSHA does not define Lead Based Paint based on lead content. Any detectable lead in a paint or varnish classifies it as lead paint for purposes of complying with OSHA regulations to determine worker exposure.

• Negative Exposure Assessment (NEA) - A determination in accordance with the OSHA standards that employee exposures are, or that there is a high degree of certainty they will be, below the Permissible Exposure Limit (PEL) and Action Level.

• NIOSH - National Institute for Occupational Safety and Health.

• OSHA – United States Occupational Safety & Health Administration.

• Permissible Exposure Limit (PEL) - Exposure to an airborne lead concentration in the breathing zone of 50 micrograms per meter cubed (ug/m^3) over an eight-hour time weighted average (TWA).

• Plastic Sheeting - plastic sheet material used for protection of walls, floors, etc. and used to seal openings into work areas.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

• Regulated Area - An area established where lead-based paint work is conducted, and any adjoining area where debris and waste from such lead work accumulate; and a work area within which airborne concentrations of lead exceed, or there is reasonable possibility they may exceed the PEL and EL. A regulated area must demarcated with barriers and signage to allow only access by authorized, trained persons.

• Removal - the act of removing lead-based paint or contaminated materials from a structure and depositing in a suitable disposal site.

• RRP – Renovation, Repair and Painting

• Work area - area or areas of Project which undergo "abatement" or are contaminated.

See also regulated area.

2.3 CODES AND REGULATIONS

A. General Applicability of Codes and Regulations, Guidelines and Standards:

Except to the extent that more explicit or more stringent requirements are written directly into the contract documents, all applicable codes, regulations, guidelines and standards have the same force and effect (and are made a part of the contract documents by reference) as if copied directly into the contract documents, or as if published copies are bound herewith.

B. Contractor Responsibility: The Contractor shall assume full responsibility and liability for the compliance with all applicable federal, state, and local regulations pertaining to work practices, protection of workers, visitors to the site, and persons occupying areas adjacent to the site. The Contractor shall hold the Owner and Designer(s) of this specification harmless for failure to comply with any applicable work, packaging, salvaging, delivering, safety, health or other regulation on the part of himself, his employees, or his subcontractors.

C, Qualifications for Performance of Work:

1. Contractor (or subcontractor engaged to perform the work of this Section) shall:

a. Be a certified and licensed lead-based paint abatement or RRP contractor. Submit documentation confirming current licensure.

b. Utilize workers and supervisors who are trained in accordance with all

Alabama lead based paint abatement regulations. Submit documentation confirming current training.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

D. Reference Standards:

1. The Contractor acknowledges, by the executing of the contract, awareness and familiarity with the contents and requirements of the following regulations, codes, and standards, and assumes responsibility for the performance of the work in strict compliance therewith and, for every instance of failure, to comply therewith.

2. The current issue of each document shall govern. Where conflict among requirements or with the contract documents exists, the more stringent requirements shall apply.

E. All state, county, and city codes and ordinances as applicable. Make available for review at the site one copy of EPA, OSHA, and applicable state, county, and city regulations governing the work.

2.4 PAYMENT AND TESTING

A. The Contractor will provide a testing laboratory for the duration of lead-based paint removal for the OSHA personnel air samples. Area and final clearance samples may be performed by the Owner’s Representative.

B. Contractor will pay for testing services for the OSHA personnel air samples.

2.5 QUALIFICATIONS OF TESTING LABORATORY

A. Testing Laboratory shall participate in the National Voluntary Laboratory

Accreditation Program (NVLAP) program administered by the National Institute of

Standards and Technology. Testing Laboratory shall have been proficient on all samples for the last two (2) consecutive rounds.

2.6 TRAINING PROGRAM

A. Training Requirements for Licensed Lead Based Paint Abatement Contractors:

1. The following training requirements apply to state licensed lead-based paint abatement contractors.

a. Each worker shall complete a state approved, EPA accredited, lead

Worker course and annual refreshers.

b. Each Competent Person shall complete a state approved, EPA accredited, lead Supervisor course and annual refreshers.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

2.7 PRE-CONSTRUCTION SUBMITTALS

A. Submittals to Owner’s Representative Prior to Beginning Work

1. Certificate of Worker Acknowledgment: Submit an original signed copy of the Certificate of Worker's Acknowledgment found at the end of this

Section, for each worker who is to be at the job site or enter the work area(s).

2. Respiratory Protection Schedule: Submit level of respiratory protection intended for each operation required by the project. Submit this information on the "Respiratory Protection Schedule" form included at the end of this Section. Include an OSHA compliant Negative Exposure

Assessment if no respiratory protection is proposed for use on this project.

3. Respirator Fitting Documentation: Submit documentation indicating successful fit check testing of respirators, if used, for the individuals working on this project in accordance with 29 CFR 1910.134., 29 CFR

1926.1101., and 1926.62

B. Submit product data indicating compliance with the contract documents for products and equipment to be utilized on the project. Include manufacturer's instruction and Material Data Sheets (MDS) sheets (as applicable).

2.8 POST-CONSTRUCTION SUBMITTALS

A. Submit copies of receipts from landfill operator which acknowledge the

Contractor's delivery(s) of lead waste material. Receipts shall include date, quantity of material delivered, and signature of authorized representative of landfill. Include copy of the completed waste shipment record required by the

EPA. All receipts shall be forwarded to:

Mr. Rick Bizot

Houser Walker Architecture

1819 Peachtree Road, NE

Suite 102 rick@houserwalker.com

B. Submit copies of training documentation for additional workers and supervisors not previously submitted.

C. Submit evidence of compliance with the applicable OSHA regulation including, as a minimum, copies of employee air monitoring results.

mailto:rick@houserwalker.com

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

2.9 WORKSITE CONDITIONS

A. Worker and Visitor Procedures:

The Contractor is hereby advised that the Contractor shall provide workers with respirators which as a minimum shall meet the requirements of OSHA 29 CFR

1910.134, OSHA 29 CFR 1926.62 and protective clothing during preparation of system of enclosures, prior to commencing, during actual lead-based paint removal, and until final clean-up is completed. The Contractor shall provide visitors with protective clothing during preparation of system of enclosures, prior to commencing, during actual lead-based paint removal, and until final clean-up is completed.

2.10 PERSONNEL PROTECTION

A. Prior to commencement of work, all workers shall be instructed by the Contractor and shall be knowledgeable, in the appropriate procedures of personnel protection and lead removal.

B. Contractor acknowledges and agrees that he/she is solely responsible for enforcing worker protection requirements at least equal to those required by federal regulations.

C. Contractor shall provide workers with personally issued and marked respiratory equipment approved by NIOSH and OSHA and as a minimum suitable for the lead exposure level in the work areas.

1. Type of respiratory protection required:

Regardless of the anticipated lead concentrations, half-face air purifying respirators shall be the minimum level of respiratory protection for removal and cleaning activities.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

RESPIRATORY PROTECTION FACTOR:

Respirator Type Protection Factor

Air purifying:

Negative-pressure respirator, High efficiency filter, Half-facepiece

Air purifying:

Negative-pressure respirator, High efficiency filter, Full-facepiece

Powered air purifying (PAPR):

Positive-pressure respirator, High efficiency filter, Full-facepiece

Type C supplied air:

Positive-pressure respirator, pressure-demand, Full-facepiece

Type C supplied air:

Positive-pressure respirator, pressure-demand, Full-facepiece, Equipped with an auxiliary positive-pressure Self-contained breathing apparatus (SCBA) over 1000

D. Where respirators with disposable filters are used, provide sufficient filters for replacement as necessary by the workers, or as required by applicable

E. Permit no visitors, except for governmental inspectors having jurisdiction, or qualified personnel in the work areas after commencement of lead disturbance or removal.

F. Provide workers with sufficient sets of protective disposable clothing, consisting of full-body coveralls, head covers, gloves, and foot covers; of sizes to properly fit individual workers in accordance with 29 CFR 1910.1025 and 29 CFR 1926.62.

G. Provide authorized visitors with a set of suitable protective disposable clothing, headgear, eye protection, and footwear of sizes to properly fit visitors whenever they are required to enter the work area.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

2.11 WORK AREA PREPARATION AND ABATEMENT

2.11.1 LEAD BASED PAINT & LEAD CONTAINING PAINT

A. Isolate the work area(s) until completion of abatement activities, by completely sealing off all openings such as exhaust pipes, fans, and other penetrations of the work area(s) with a minimum of a single layer of 6-mil poly sheeting sealed with tape.

B. Ensure that all barriers and critical seals remain effectively sealed and taped for duration of lead-based paint removal and subsequent cleaning. Repair damaged barriers and remedy defects immediately upon discovery. Use smoke methods to test effectiveness of barriers when directed by Owner’s Representative.

C. Access to the work area(s) shall be limited to authorized personnel only. The

D. Provide temporary power, water, and lighting, utilizing ground fault protection

E. Notify Owner’s Representative for observation of the preparation of jobsite prior to any removal of lead.

F. Maintain for the duration of the Project from the first activity requiring disturbance of LBP and LCP, a sign in/out log in the immediate area of the change room(s). Log shall be utilized by every person and each time upon entering and leaving the work area(s). Submit copies of this log to Owner for permanent file upon completion of project.

G. Properly remove and dispose of the LBP and LCP in accordance with all applicable state and federal rules and regulations.

H. A remote decontamination wash station shall be available to workers upon exit of the work area. The wash station shall include, but not limited to, a properly labeled 6-mil poly disposal bag for disposal of protective suits and used towels.

It is recommended all workers properly decontaminate in the wash station.

I. Throughout the course of abatement, utilize wet scrapping methods and/or encapsulation to address lead paint on surfaces as required.

J. Removed LBP and LCP material shall be wrapped in 6-mil poly sheeting as removal occurs, not allowing materials to accumulate in the abatement area.

Abatement Plan Specifications April 29, 2024

Houser Walker Architecture NOVA Project Number 10102-3024037

2.12 DISPOSAL OF WASTE

A. Disposal of the waste will be at an authorized landfill for the waste.

B. Containerized and/or sealed lead paint material shall be immediately transferred to closed receptacle in such a manner as to preclude the dispersion of dust.

C. Use only enclosed or covered trucks or dumpsters to haul LBP and/or LCP to approved landfill.

D. Submit to the Owner Representative, any waste manifests after completion of the project.

E. Following the last trip to dispose of contaminated waste, all plastic sheeting shall be removed from the walls and floor of the truck or dumpster and also…

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