Building 14 Survey 7.rtf

2016 Asbestos Reassessment to 2012 and 2009 Asbestos Reinspection July 2016 file_0.jpg file_1.wmf

2016 ASBESTOS REASSESSMENT

to 2012 and 2009 ASBESTOS RE-INSPECTION REPORT Waco V.A. Medical Center 4800 Memorial Drive Waco, Texas

Building 14 file_2.emf file_3.wmf

Waco, Texas

2016 ASBESTOS REASSMENT REPORT CENTRAL TEXAS VETERANS HEALTH CARE SYSTEM WACO VA MEDICAL CENTER Executive Summary HGS Engineering, Inc. was awarded the contract to perform the periodic reassessment as described in 40 CFR Part 763.85. HGS Engineering attended a kick off meeting in Building 220 at the Temple Veterans Affairs Medical Center facility. Present at the meeting were Robin Reblin, contracting officer’s representative; Tim Thompson, Project Manager for HGS Engineering and Lonnie Lyro, senior Texas Asbestos Consultant. During the meeting Mr. Reblin gave HGS the opportunity to see the current reassessment for each building in the scope of work. Mr. Reblin also gave HGS the contact information for the Waco VA Medical Center facility point of contact; Aaron Smith. The schedule for facility inspections allowed for HGS to be able to reassess the Temple Facility from 11 April through 14 April 2016 Building 14 had piping elbows and debris noted near the boiler control panel. This debris was caused by the asbestos associate with the boiler and the HMA- 04. This area was supposed to be cleaned up and for that reason we suggest no changes to charts.

There are no changes required to the O&M Plan for this building.

SCOPE OF WORK

1. The owner requested that an AHERA style reassessment be completed using the 2009 asbestos report complete by ALTEC. All work will be done by a Texas license Asbestos Inspector and Management Planner.

2. This asbestos reassessment complies with the requirements of Asbestos Hazard Emergency Response Act (AHERA).

3. Each facility inspection was performed by an accredited inspector.

4. For each facility, the HGS completed the following tasks:

A. Visually re-inspect and reassess the condition of all friable known or assumed asbestos containing building materials (ACBM).

B. Visually inspect material previously considered non-friable ACBM, and physically touch the material to determine whether it has become friable since the last inspection.

C. Identify any homogenous areas with material that has become friable since the last inspection or re-inspection.

D. Collect bulk samples for analysis of newly friable material that is already assumed (not sampled) to be ACBM, or collect additional bulk samples to fully assess the suspect materials.

E. Visually inspect, sample, analyze, and assess the conditions of building materials that have been added to the facility since the last inspection or re-inspection.

F. Assess the condition of the newly friable material in areas where samples are collected and of newly friable material in areas assumed to ACBM.

G. Reassess the condition of friable known or assumed ACBM previously identified.

H. Record above information on inspection logs for each facility.

5. A management planner shall review the above information and complete the following required functions:

A. Review each management plan for compliance with AHERA and TDSHS regulations and ensure the plan reflects the current conditions.

D. Sign and date the review documents, include the accreditation number of inspectors and planners, and submit a copy to the designated person.

6. The following information shall be submitted to the designated person under AHERA and TDSHS, for inclusion in the management plan for each facility and optionally at a central office location:

A. The date of the inspection, the name and signature of the asbestos inspector(s) performing the inspection, state of accreditation number, and any changes in the condition of known or assumed ACBM.

B. The exact locations where samples are collected during the inspection, a description of the manner used to choose sampling locations, the name and signature of each asbestos inspector who collected the samples, state of accreditation, and accreditation number.

C. Any assessments or reassessments made of friable material, the name and signature of the asbestos inspector(s) performing the assessment, state of accreditation, and accreditation number.

SAMPLING PROTOCOL

HGS Engineering collected triplicate interior samples of the ACMs of concern and single samples from the exterior ACM of concern.

Bulk sampling was conducted in general accordance with procedures outlined in the Asbestos Hazard Emergency Response Act (40 CFR 763.86), Texas Department of State Health Services (TDSHS) Texas Asbestos Health Protection Rules (TAHPR) and the U.S. Environmental Protection Agency (EPA) guidance document entitled Guidance for Controlling Asbestos-Containing Materials in Buildings (Document No. 560/5-85/024). The asbestos inspections were performed by Mr. Lonnie Lyro of ATC (TDSHS Individual Asbestos Consultant License No. 105763) on April 11-14, 2016.

Bulk samples of suspect materials were analyzed by Steve Moody Laboratories (TDSHS Laboratory License No. 30-0084) in Farmers Branch, Texas using approved polarized light microscopy with dispersion staining (PLM/DS) methods. The PLM/DS analytical method is modeled after U.S. EPA Publication EPA/600/R-93/116: Test Method for the Determination of Asbestos in Bulk Materials, July 1993. If a material is identified as containing greater than 1% asbestos, it is considered to be an ACM.

Additional ACM may be present at the site in inaccessible or concealed spaces or not sample during the 2016 re-inspection nor sampled in the previous inspections and re-inspections. HGS recommends the Management Plan be reviewed by TDSHS accredited personnel prior to renovation or demolition activities or treated as ACM. These spaces include, but are not limited to, pipe chases, spaces between wall/ceiling/door/floor cavities, interior of mechanical components such as boiler cavities, interior ducts, beneath foundation pads, etc. If future maintenance/renovation/demolition activities make these areas accessible, HGS recommends that a thorough assessment of these spaces be conducted at that time to identify and confirm the presence or absence of additional ACMs. Until then, all such unidentified materials should be treated as assumed ACM in accordance with 40 CFR 76.

NOTE: Ceramic wall tiles, floor tiles, thin-set and grout was not sampled throughout the property in 2009, nor, 2012. Based on non-destructive sampling and aesthetics, sampling of these materials was not conducted in 2016 and should be sampled prior to renovation or demolition activities.

NOTE: Although materials sampled previous was point counted to below 1% asbestos, that material is still regulated by OSHA and proper precautions should be taken prior to removal or demolition activities.

MANAGEMENT PLAN RECOMMENDATIONS

The following general notes are for all facilities inspected during the Asbestos Re-inspection:

awareness training should be filed in the Management Plan.

Any new custodial, janitorial, or maintenance staff that have the potential to come in contact with asbestos-containing materials (ACM) are required to attend a two-hour awareness training class. Records of training for new employees should be filed in the Management Plan.

The Designated Person is required to inform workers and building occupants at least once a year about the Management Plan. This includes information about inspections, response actions, and post-response action activities that are planned or in progress.

Maintenance areas (boiler rooms, janitor closets, etc.) are required to have warning labels where ACM is located. Install warning labels in these areas as needed. Some older labels may have come loose and are no longer visible. Post the labels in a prominent location.

Review the enclosed 2016 Reinspection Condition and Removal Priority Table for maintenance actions that may be required and to establish priorities and budgets for future repair and abatement work.

Periodic “Surveillance Inspections” are required every six (6) months. This inspection should indicate the condition of the material and provide recommendations for repair or potential removal. Consistency of inspections is desired and, therefore, should be performed by the same individual(s) for all facilities. An accredited inspector is not required, but is recommended. Records of Surveillance Inspections should be filed in both the administrative and facility Management Plans.

“Re-inspections” are required every three (3) years. Updated information should be added to the Management Plan.

An accredited “Supervisor” should be on staff or available on a contract basis per

AHERA guidelines. Certification paperwork should be filed in the training section of the Management Plan.

ACM should only be removed by contractors licensed and accredited in the State of

Texas. Response actions related to abatement activity should be filed in the Management Plan. Removal of limited amounts of asbestos by the accredited Supervisor and trained individuals is within the scope of the Management Plan.

Notification should be provided to “outside contractors” about ACM within the facility.

This should include such trades or services as telephone, electrical, plumbing, air conditioning, and other construction work. A form should be created for this purpose and placed in the Management Plan.

New building construction and portable buildings added to a facility are required to be inspected and sampled for ACM. In lieu of this, a letter from the architect, engineer, or manufacturer can be obtained that states “no ACM were specified or used in the facility.”

A copy of this letter is to be filed with the Management Plan at the facility. This letter will cancel the requirement for sampling.

Abatement Costs were developed for each homogeneous area and per facility. The estimated abatement cost is for budget purposes only. The cost is based on the area of material and estimated abatement costs for this material. The cost is for abatement only and does not include abatement design, air monitoring, or project observation costs.

MANAGEMENT PLAN UPDATES

There were no changes to Building 14 during the 2016 reassessment.

CONDITION AND REMOVAL PRIORITY TABLE

This section contains a table with the material’s current condition, potential for disturbance, and removal priority for each homogeneous area.

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CERTIFICATIONS

This section contains certifications for all Inspectors, the Management Planner who reviewed this Management Plan, and the laboratory that performed the bulk sample analysis. J John Need Tim’s TX certifications.

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This 2016 Asbestos Re-inspection was provided by:

Contractor:

HGS Engineering Inc.

1121 Noble Street Anniston, AL 36201 Phone: 256-835-3800 Fax: 256-236-2979 www.hgsengineeringinc.com

Inspectors:

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Lonnie Lyro 105763 Asbestos Individual Consultant Accreditation Agency: Texas Department of Health Services which is a recognized EPA accreditation agency. J John Need assistance in completing.

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Timothy A. Thompson, CQM Project Manager