TX0211_2008_ACM_Reinspection_Report.pdf

GENERAL SERVICES ADMINISTRATION, REGION 7

FORT WORTH REGIONAL OFFICE

Technical Services Branch (7PMS)

Fort Worth, TX

Asbestos Building Re-Inspection

Bob Casey Federal Building and Courthouse

(TX0211)

515 Rusk

Houston, Texas

CONTRACT NO. GS-07P-08-HHD-0048

ORDER NO. GS-P-07-08-UR-5238

PREPARED AND REVIEWED by:

LOFLIN ENVIRONMENTAL SERVICES, INC.

James Murray, CIH, CSP

Part of the Q2 Team

Submitted: November 30, 2008

Asbestos Audit – TX0211

1 November 2008

TABLE OF CONTENTS

I. INTRODUCTION Page 2

II. FACILITY DESCRIPTIO N Page 2

III. SUMMARY OF ACM FINDINGS Page 3

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 5

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 7

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 Laboratory Accreditation

D. OPERATIONS AND MAINTENANCE PLAN

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I. INTRODUCTION

An Asbestos Building Audit Survey (ABAS) Re-inspection was conducted at the Bob Casey Federal Building and Courthouse in Houston, Texas (TX0211). The purpose of the Re-inspection was to assess the condition of asbestos-containing materials (ACM) previously identified in the ABAS conducted in September 1994 and re-inspection performed in April 2003. 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 Re-inspection.

This Re-inspection utilized information from the previous asbestos survey prepared by Loflin Environmental Services, Inc. in 1994 and updated in April 2003. The original survey of 1994 identified the following asbestos containing materials:

Domestic water system insulation Mechanical system insulation Steam system insulation Boiler and boiler flue insulation Chiller insulation Tank insulation Pump insulation Air handler insulation Duct insulation Spray applied acoustical texture Spray-applied fireproofing Vinyl floor tile and mastic Asphalt floor tile and mastic Duct insulation sealant

Numerous minor building renovations have been performed since the 1994 and 2003 surveys.

All spray-applied acoustical texture and fireproofing were abated from the building in the 1990’s.

Various tenant build outs have included abatement of floor tile and mastic duct insulation sealant.

A few small projects have included glove bag abatement of pipe insulation. A project completed in 2004 involved patching and repair of air handler and duct insulation in the mechanical rooms.

Ongoing construction projects have abatement of floor tile and mastic planned.

II. FACILITY DESCRIPTION

The Bob Casey Federal Building and Courthouse (TX0211ZZ) located at 515 Rusk Street in Houston, Texas is a twelve-story structure built in 1960 with a basement and a mechanical penthouse area on the roof. It contains approximately 512,318 square feet of usable space and is of concrete pier and beam construction. A cooling tower also exists on the roof.

The cooling and heating is provided by a forced air system which originates from mechanical areas in the basement and feeds mechanical/air handler rooms on each floor one through twelve.

A boiler and chiller room, as well as several air handler units, are located in the basement.

Larger insulated ducts in each air handler room are fed by high velocity risers and service each floor by smaller flex ducts which run above the ceiling throughout the floor. Hot and chilled water pipes rise from the boiler room and feed each floor’s mechanical area. Domestic water pipes can be found above the ceiling throughout the building, in east and west bathroom chases on each floor, and in all the mechanical areas of the building.

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Interior finishes in the offices include plaster as well as sheetrock ceilings and walls, acoustical tile glued-on and drop ceilings, and various types of vinyl floor tile and mastic. In many cases, the vinyl floor tile is overlain by carpet.

III. SUMMARY OF ACM FINDINGS

Findings below are based on results from the Building Audit Survey conducted in 1994, the re-inspection performed in 2003 and from additional sampling performed as part of this assessment.

A total of 14 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, 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____

Mechanical System Fitting Bsmt.- 12 th Floor N/A Mechanical; Chases;

Insulation Above Ceilings (12%-45% Chrys.)

Domestic Water Fitting Ins. Bsmt.- Mechanical N/A Mechanical; Chases;

(3%-5% Chrys.) Penthouse Above Ceilings Restrooms

Steam System Fitting Ins. B-002A 19 each Mechanical Insulation (20%-50% Chrys.)

Soft Water Fitting Ins. B-002A 16 each Mechanical (3%-5% Chrys.)

Tank Insulation B-002A 300 sq. ft. Mechanical (20%-25% Chrys.)

Boiler Flue Insulation B-202A 1,300 sq. ft. Mechanical (7%-25% Chrys./ 7%-10% Amosite)

Chilled Expansion Mech. Penthouse 225 sq. ft. Mechanical Tank Insulation (20%-25% Chrys.)

Material Type Location Quantity Functional Space____

Hot Water Exchange Room 1202 100 sq. ft. Mechanical

(65%-70% Chrys.)

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Duct Insulation Bsmt. – Mechanical N/A Mechanical; Chases;

(20%-45% Chrys.) Penthouse Above Ceilings

In mechanical rooms including large air handler rooms in the basement, many of the mechanical system fittings have been replaced. Newer pvc fittings can be considered non-asbestos containing.

Miscellaneous ACM Materials

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

Material Type Location Quantity Functional Space____

Vinyl Floor Tile and/or Bsmt. – 12 th Floor 185,000 sq. ft. All

Black Mastic* (1%-5% Chrys.)

1’x2’ Floor Tile (Black) Rm. 1128/1210A 1350 sq. ft. Post Office Workroom, (3%-5% Chrys.) Storage

Stair Vinyl Flooring- Rm. B-417A 40 sq. ft. Stairwell Mastic Only (2%-3% Chrys.)

Duct Insulation Sealant (Black) Bsmt. – 12 th Floor N/A Above Ceilings

(3%-5% Chrys.)

Penetration Packing Rm. 1005 N/A Electrical Closet (3%-5% Chrys.)

* Black mastic underneath vinyl floor tile should be considered asbestos containing. In some areas, residual black mastic may be found under newer tile and yellow mastic.

NOTE: Vinyl floor tile may be overlain by carpet. Although every effort was made to accurately identify floor tile quantities in all areas, 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. Conversely, some carpeted areas may have floor tile that was not identified at the time of the survey. Should future renovation require abatement of large quantities of floor tile, the GSA may elect to reevaluate quantity estimates.

Non-ACM Materials

This category includes materials which were considered suspect and were sampled at the time of the original ABAS survey and were determined to be non-asbestos containing: acoustical ceiling tile, acoustical wall tile, cove base, wall mastic, wall plaster, finished plaster, window putty, sheetrock joint compound, sheetrock texture, mechanical system straight insulation and spray applied acoustical texture in the chiller room.

Bulk Sample Results

The original survey and re-inspection included analytical results for three hundred and two bulk samples. A total of fourteen 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.

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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 5 – High Concern Physical conditions represent FRIABLE asbestos-containing material types with DAMAGE and a LOW POTENTIAL for DISTURBANCE.

Duct Insulation

Basement Rm. B-425 Above Ceiling Plenum

Insulation on a duct located above a drop ceiling in this locker room has been cut into for the placement of a vent leaving the insulation damaged with exposed fibers.

Response Action 6 - Moderate Concern Physical conditions represent asbestos-containing materials with NO DAMAGE and a HIGH

POTENTIAL FOR DISTURBANCE.

Basement. Through Mechanical Various Areas Mechanical, Workroom Penthouse

Duct insulation is friable and although newly patched and repaired, it is in areas where physical contact is likely.

Response Action 7 - Moderate Concern Physical conditions represent asbestos-containing materials with NO DAMAGE and a

MODERATE POTENTIAL FOR DISTURBANCE.

Mechanical System Fitting Insulation

Basement Through Twelfth Floor Various Areas Above Ceiling, Chase, Penthouse Mechanical

Mechanical system fittings, including chilled and heating water elbows, are located throughout all of the mechanical areas of this facility. In several of the mechanical areas, especially in the basement, some of these fittings have been replaced, especially near and around the air handler units. Prior to renovation or removal, it is recommended that further testing be performed.

Domestic Water Fitting Insulation

Basement Through Mechanical Various Areas Above Ceiling, Chase, Penthouse Mechanical

Steam System Fitting Insulation

Basement Basement Rm. B-002A Mechanical

Soft Water Fitting Insulation Basement Rm. B-002A Mechanical

Basement Rm. B-002A Mechanical

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Boiler Flue Insulation Basement Rm. B-202A Mechanical

Chilled Exchange Tank Insulation

Roof area Mechanical Mechanical Penthouse

Hot Water Exchange Tank Insulation First Floor Rm. 1202 Mechanical

Response Action 8 - Low Concern These identified asbestos-containing materials were observed to be NON-FRIABLE, with NO DAMAGE, and minimal POTENTIAL FOR RELEASE OF ACM.

Vinyl Floor Tile and/or Mastic

Basement Through Twelfth Floor Various Areas Office, Corridor, Storage

1’x2’ Floor Tile (Black)

First Floor Rms. 1128, 1210A Post Office Workroom, Storage Stair Vinyl Flooring (Mastic Only) Basement Rm. B-417A Stairwell

Duct Exterior Sealant (Black) Basement Through Twelfth Floor Various Areas Above Ceiling

Penetration Packing First Floor Rm. 1005 Electrical Closet

V. ACTION PLAN PRIORITIES

The Re-inspection of the Bob Casey federal Building and Courthouse facility located in Houston has assessed the location and physical condition of ACM previously identified by an Asbestos Survey Report performed in 1994 and documented by the re-inspection performed in 2003. An additional fourteen 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 takes 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

7 November 2008 specific Decision Tree/Response Action Key recommendations for the types of materials identified:

Response Action Plan Action # Priority

5 HIGH

Removal Cost Estimates

Material Type Location Quantity Unit Price Cost Duct Insulation Rm. B-425 10 sq. ft. $50.00/ft. $500.00

Action Plan Description Continue O&M. Repair and schedule removal when practical and cost effective. Number indicates priority.

6 MODERATE

Material Type Location Quantity Unit Price Cost.

Duct Insulation Bsmt. through Mech. N/A $40.00/ft. N/A Penthouse

Action Plan Description Repair as needed, continue O&M. Number indicates priority, if all repairs cannot be done immediately.

7 LOW

Mech. System Fittings Bsmt.-12 th N/A $50.00/ea. N/A

Dom. Water Fittings Bsmt.-Mech. N/A $50.00/ea. N/A Penthouse

Steam System Fittings Rm. B-002A 19 each $50.00/ea. $950.00 Soft Water Fittings Rm. B-002A 16 each $50.00/ea $800.00 Tank Insulation Rm. B-002A 300 sq. ft. $30.00/ft. $9,000.00 Boiler Flue Insulation Rm. B-202A 1,300 sq. ft. $30.00/ft. $39,000.00 Chilled Exchange Mech. PH 225 sq. ft. $30.00/ft. $6,750.00

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Hot Water Exchange Rm. 1202 100 sq. ft. $30.00/ft. $300.00 Tank Insulation

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

8 LOW

Vinyl Floor Tile and/ Throughout 185,000 sq. ft. $3.00/ft. $555,000.00 or Mastic 1’x2’ Floor Tile (Black) Rms. 1128, 1,350 sq. ft. $2.00/ft. $2,700.00 1210A Stair Vinyl Flooring Rm. B-417A 45 sq. ft. $5.00/ft. $225.00 (Mastic Only) Duct Exterior Sealant Bsmt.-12 th N/A $4.00/lin. ft. N/A

(Black) Penetration Packing Rm.1005 N/A $95.00/ea. N/A

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. Clean up IMMEDIATELY all loose ACM debris

3. Patch and repair IMMEDIATELY any damaged ACM areas.

4. All identified damaged suspect asbestos-containing materials that could possibly be disturbed should be removed prior to any renovation/demolition/disturbance.

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

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

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The provided Building Audit Survey documentation will assist the Facility Asbestos Control Manager with the development of standardized EPA/AHERA Action Response Key References, for site-specific material conditions and their respective potentials for damage.

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.

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APPENDIX A

BUILDING FLOOR PLANS

ACM HOMOGENEOUS AREAS/FLOOR PLAN LOCATIONS

NOTE: Thermal system insulation drawings do not display inaccessible materials above ceilings and within chases.

Floor Type Page

Basement – East Thermal System Insulation 3 Flooring Materials 4

Basement – West Thermal System Insulation 5 Flooring Materials 6

First Floor - East Thermal System Insulation 7

Flooring Materials 8 First Floor - West Flooring Materials 9

Second Floor - East Thermal System Insulation 10

Flooring Materials 11 Second Floor - West Flooring Materials 12

Third Floor - East Thermal System Insulation 13

Flooring Materials 14 Third Floor - West Flooring Materials 15

Fourth Floor - East Thermal System Insulation 16

Flooring Materials 17 Fourth Floor - West Flooring Materials 18

Fifth Floor - East Thermal System Insulation 19

Flooring Materials 20 Fifth Floor - West Flooring Materials 21

Sixth Floor - East Thermal System Insulation 22

Flooring Materials 23 Sixth Floor - West Flooring Materials 24

Seventh Floor - East Thermal System Insulation 25

Flooring Materials 26 Seventh Floor - West Flooring Materials 27

Eighth Floor - East Thermal System Insulation 28

Flooring Materials 29 Eighth Floor - West Flooring Materials 30

A-2 November 2008

APPENDIX A

BUILDING FLOOR PLANS

ACM HOMOGENEOUS AREAS/FLOOR PLAN LOCATIONS

NOTE: Thermal system insulation drawings do not display inaccessible materials above ceilings and within chases.

Floor Type Page

Ninth Floor - East Flooring Materials 31 Ninth Floor - West Flooring Materials 32

Tenth Floor - East Thermal System Insulation 33

Flooring Materials 34 Tenth Floor - West Thermal System Insulation 35

Flooring Materials 36

Eleventh Floor - East Flooring Materials 37 Eleventh Floor - West Flooring Materials 38

Twelfth Floor - East Thermal System Insulation 39

Flooring Materials 40 Twelfth Floor - West Thermal System Insulation 41

Flooring Materials 42

Mechanical Penthouse Thermal System Insulation 43

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LOFLIN

Drawing Not to Scale

Bob Casey Federal Building and Courthouse

Elev ator Penthouse

Mechanical Penthouse

Thermal System Insulation

KEY

Chilled Exchange Tank Insulation

Domestic Water Fitting Insulation

Asbestos Audit Reinspection

November 2008

515 Rusk Street Houston, Texas

(TX0211ZZ)

Loflin Environmental Services

Project No. 881-08-01

B-1 November 2008

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 November 2008

PHOTOGRAPH INDEX

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

Photograph Homogeneous Material Number Location Area Description

1. Basement Floor Tile and Mastic Non-Friable

2. At Rm. 4000 Floor Tile Mastic Non-Friable

3. At Rm. 1122 Floor Tile Mastic Non-Friable

4. POWR Asphalt Plank Flooring Non-Friable

5. Room B202 Tank Insulation Friable-No Damage

6. Room 10014A Duct Insulation Sealant Non-Friable

7. Room 10300 Duct Insulation Friable-No Damage

8. Room B425 Duct Insulation Minor Damage

9. Room 4302 Mechanical System Fittings Some Replacement

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Photograph 1: Predominant type of asbestos containing floor tile and mastic found throughout the building

Photograph 2: Hallway outside Room 4000. Residual asbestos containing black mastic was found under newer tile and mastic at several locations.

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Photograph 3: Hallway outside Room 1122. Residual asbestos containing black mastic was found under newer tile and mastic at several locations.

Photograph 4: Asphalt plank flooring and mastic found in the Post Office areas.

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Photograph 5: Thermal system insulation in mechanical areas was found to be in undamaged condition with evidence of recent repairs.

Photograph 6: Asbestos containing tarry sealant is present on ducting throughout the building.

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Photograph 7: Asbestos containing duct insulation in all mechanical rooms has been repaired.

Photograph 8: Old damage to duct insulation above the suspended ceiling in Room B425.

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Photograph 9: Both asbestos and non-asbestos mechanical system insulation was found in mechanical rooms. Asbestos containing insulation was labeled.

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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

LABORATORY ACCREDITATION

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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.

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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. 12- 01B) with a corresponding laboratory identification number (i.e. L152321).

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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.

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BULK SAMPLE ACM INDEX/SUMMARY

Sample Material Location Result NESHAP Number Type Category

211--01 CHW Fitting Sealant Mechanical PH None Detected 2 211-02 Floor Tile 12300 Hallway None Detected 1 Mastic None Detected 2 211-03 Floor Tile 10204 Hallway None Detected 1 Mastic None Detected 2 211-04 Vibration Dampener MR 10300 None Detected 1 211-05 Ceiling Tile Room 9605 None Detected F Tile Glue None Detected 2 211-06 Floor Mastic Room 9602 None Detected 2 211-07 Floor Tile 7722 Hallway None Detected 1 Mastic None Detected 2 211-08 Floor Tile 6004 Hallway None Detected 1 Mastic None Detected 2 Mastic 3% Chrysotile 2 211-09 Floor Tile 4000 Hallway None Detected 1 Mastic None Detected 2 Mastic 3% Chrysotile 2 211-10 Floor Tile Main Lobby None Detected 1 Mastic None Detected 2 Mastic None Detected 2 211-11 Floor Tile Room 4403 2% Chrysotile 1 Mastic None Detected 2 Mastic 3% Chrysotile 2 211-12 Floor Tile Room 1010 None Detected 1 Mastic None Detected 2 211-13 Floor Tile 1122 Hallway None Detected 1 Mastic None Detected 2 Mastic 3% Chrysotile 2 211-14 Floor Tile Room B517 None Detected 1 Mastic None Detected 2

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BUILDING PLAN/BULK SAMPLE LOCATIONS

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

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LOFLIN

Drawing Not to Scale

Bob Casey Federal Building and Courthouse

Elev ator Penthouse

Mechanical Penthouse

Asbestos Audit Reinspection

November 2008

515 Rusk Street Houston, Texas

(TX0211ZZ)

Loflin Environmental Services

Project No. 881-08-01

Bulk Sample Locations

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LABORATORY ACCREDITATION

Evidence of Accreditation by the National Institute of Standards and Technology under the National Voluntary Laboratory Accreditation Program (NVLAP)

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QuickTime™ and a TIFF (LZW) decompressor are needed to see this picture.

APPENDIX D

OPERATIONS AND MAINTENANCE PLAN

Asbestos O&M – TX0211

D-2 October 2008

APPENDIX D

Operations and Maintenance Plan

1.0 INTRODUCTION

THE INTENT OF THE GENERAL SERVICES ADMINISTARION 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 CLASES 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 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 Bob Casey Federal Building and Courthouse located at 515 Rusk in Houston, Texas (TX0211) based on data collected during the Asbestos Re-inspection in October 2008. The data collected as pare of this survey is intended to ensure compliance with OSHA’s 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 Owner’s 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).

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

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

1.3 ASBESTOS INSPECTION REPORT

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

Asbestos Building Re-Inspection (TX0211ZZ) Bob Casey Federal Building and Courthouse 515 Rusk Houston, 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.

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.

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2.2 SITE-SPECIFIC ASBESTOS INFORMATION

Asbestos was identified in the following building materials:

Thermal System Insulation

Material Type Location Quantity Functional Space____

Mechanical System Fitting Bsmt.- 12 th Floor N/A Mechanical; Chases;

Insulation Above Ceilings (12%-45% Chrys.)

Domestic Water Fitting Ins. Bsmt.- Mechanical N/A Mechanical; Chases;

(3%-5% Chrys.) Penthouse Above Ceilings Restrooms

Steam System Fitting Ins. B-002A 19 each Mechanical Insulation (20%-50% Chrys.)

Soft Water Fitting Ins. B-002A 16 each Mechanical (3%-5% Chrys.)

Tank Insulation B-002A 300 sq. ft. Mechanical (20%-25% Chrys.)

Boiler Flue Insulation B-202A 1,300 sq. ft. Mechanical (7%-25% Chrys./ 7%-10% Amosite)

Chilled Expansion Mech. Penthouse 225 sq. ft. Mechanical Tank Insulation (20%-25% Chrys.)

Hot Water Exchange Room 1202 100 sq. ft. Mechanical Tank Insulation (65%-70% Chrys.)

Duct Insulation Bsmt. – Mechanical N/A Mechanical; Chases;

(20%-45% Chrys.) Penthouse Above Ceilings

Miscellaneous ACM Materials

Material Type Location Quantity Functional Space____

Vinyl Floor Tile and/or Bsmt. – 12 th Floor 185,000 sq. ft. All

Black Mastic

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(1%-5% Chrys.)

1’x2’ Floor Tile (Black) Rm. 1128/1210A 1350 sq. ft. Post Office Workroom, (3%-5% Chrys.) Storage

Stair Vinyl Flooring- Rm. B-417A 40 sq. ft. Stairwell Mastic Only (2%-3% Chrys.)

Duct Insulation Sealant (Black) Bsmt. – 12 th Floor N/A Above Ceilings

(3%-5% Chrys.)

Penetration Packing Rm. 1005 N/A Electrical Closet (3%-5% Chrys.)

Refer to Appendix A for the material location drawing(s) that identifies the location names listed above.

The purpose for collecting the above referenced asbestos data is to develop an asbestos hazard communication and operation and maintenance plan. All suspect roofing and exterior suspect materials should be assumed to be asbestos-containing unless sampling is performed and the suspect ACBM materials test negative for asbestos.

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, assesses, and documents of any changes in the ACM’s 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 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.

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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.

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, 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 and labels.

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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.

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 samples 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 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 building’s 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.

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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 contacted 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 OSHA’s permissible exposure limits. GSA employees cannot undertake any project that disturbs ACBM if that project is not consistent with District approved Class III work practices.

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

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

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

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

All of these activities should be carefully controlled by use of work controls and occupant notification as described. If minor damage takes place, approved cleaning practices may be authorized by the facility asbestos coordinator. Or the purposes of this O&M plan, minor damage is defined as damage to small amounts o 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 building’s 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 bad 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.

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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 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 worker’s breathing zone during performance of work involving asbestos exposures).

Objective data used to qualify for exemptions from OSHA’s 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 worker’s employment.

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

3.3.6 WORKER TRAINING

ASBESTOS AWARENESS TRAINING (2 HOURS)

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

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

Information on the health effects of exposure to asbestos.

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Location of ACBM in the facility where the employee works.

Recognition of deteriorating or damaged ACBM.

The identity of the person responsible for management of ACBM.

The regulations require that a refresher course be given annually.