Template and format for Environmental Building Surveys.docx

Template Environmental Building Survey Requirement and Format

References:

1) Floor Plans (Provided by the Government)

Attachments:

1) NAVFAC MID-LANT Portable Gauge Operations Planning Work Sheet (If radiological devices are planned for use by contractor).

The objective of this Template .is to provide the organizational framework necessary to obtain an Environmental Survey for a planned project at Building X, MCRC SomeCity, SomeState.

The Contractor shall provide the labor, equipment, and materials necessary to perform the required work while adhering to all applicable local, state, and federal regulations.

All work described herein shall be performed by the contractor and coordinated with the Naval Technical Representative (NTR).

SECTION 1 - DESCRIPTION OF WORK

Work Element 1: Site Inspection

1.1.1 Perform an inspection of the project site to determine the type and extent of environmental hazards that are present.

1.1.2 Inspect all impacted areas internal and external to the subject building renovation project including, but not limited to, ceilings, walls, floors, piping, tanks, mechanical equipment, crawl spaces, water closets, voids between walls, utility areas/vaults, lay down areas, all painted surfaces, sidings, roofing, flashing, etc. Collect information of the conditions, locations, and quantities of all environmentally regulated materials identified.

1.1.3 Examine all potential sources of polychlorinated biphenyls (PCBs) in light ballasts and electrical components; mercury in gauges, switches and electrical components; ozone depleting substances (ODS) and low-level radiation materials for labeling and manufacturer’s information. If there is no label stating the contents of the source, then contact the manufacturer for more information. If there is no label or manufacturer’s information, then document the description, location and quantity of the potential sources in the Environmental Survey Report.

1.1.4 Follow 40 CFR 763- Subpart E, Asbestos Hazard Emergency Response Act (AHERA) requirements for inspection of friable and non-friable asbestos containing materials.

1.1.5 Follow State Public Health Administrative Rules and U.S. Department of Housing and Urban Development (HUD) guidelines for inspection of lead based paint.

1.1.6 Photograph all representative areas (homogenous areas per 40 CFR 763) of environmentally regulated materials identified during the inspection. Take sufficient number of photos to adequately represent the material and its location.

1.1.7 The inspector shall be licensed by the State as an Asbestos Building Inspector and Lead Inspector. [NOTE: The Contractor shall provide a second person to accompany the inspector when conducting inspections in high risk safety areas such as roofs and confined air spaces. The second person is not required to be a licensed inspector].

1.1.8 RADIATION SAFETY REQUIREMENTS

If planned for use, the lead inspector shall show proof of factory training (or equivalent) on the specific XRF Analyzer(s) (if used) for the inspection and prepare NAVFAC MID-LANT Portable Gauge Operations Planning Work Sheet (Attachment 2) for submission to the Government Radiological Program Contractor Oversight Technician (Mr. Mark Schultz at mark.r.schultz@navy.mil). License Certificates, employee training records, and Leak Test Reports for radiation materials and equipment shall be submitted to the Contracting Officer and Contracting Oversight Technician (COT) for all specialized and licensed material and equipment proposed for use on the construction project. These records shall be maintained on-site whenever licensed radiological materials or ionizing equipment are on government property.

Workers shall be protected from radiation exposure in accordance with 10 CFR 20. Standards for Protection Against Radiation, ensuring any personnel exposures are maintained As Low As Reasonably Achievable.

Contractors shall submit a Radiography Operation Planning Work Sheet to Contracting Officer 14 days prior to commencement of operations involving radioactive materials or radiation generating devices. The Contracting Officer and COT will review this worksheet and submit questions and comments.

Contractors shall use primary dosimeters process by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory. Contractors shall coordinate site access and security requirements with the Contracting Officer and COT for all radiological materials and equipment containing ionizing radiation that are proposed for use on a government facility. The Navy COT or authorized representative will meet the contractor at a designated location, ensure safety of the materials being transported, and will escort the contractor to the job site and return upon completion of the work. Loss or release of radioactive materials, and unplanned personnel exposures shall be reported immediately to the Contracting Officer, COT, and Base Security Department Emergency Number.

Actual exposure of the radiographic film or unshielding the source shall not be initiated until after 5 p.m. on weekdays.

The Contractor shall provide a copy of all calibration records, and utilization records to the COT for radiological operations performed on the site.

The Contractor shall properly demark and barricade an area surrounding radiological operations to preclude personnel entrance, as per Navy Instruction, EM-385-1-1, Nuclear Regulatory Commission and Applicable State regulations and license requirements, and as per requirements established in the accepted Radiography Operation Planning Work Sheet.

The Contractor shall properly secure the radiological material and ionizing radiation equipment at all times, including keeping the devices in a properly marked and locked container, and secondarily locking the container to a secure point in the Contractor’s vehicle or other approved storage location during transportation and while not in use. While in use, The Contractor shall maintain a continuous visual observation on the radiological material and ionizing radiation equipment.

In instances where radiography is scheduled near or adjacent to buildings or areas having limited access or one-way doors, no assumptions shall be made as to building occupancy. Where necessary, the Contracting Officer will direct the Contractor to conduct an actual building entry, search, and alert. Where removal of personnel from such a building cannot be accomplished and it is otherwise safe to proceed with the radiography, a fully instructed employee shall be positioned inside such building or area to prevent exiting while external radiographic operations are in process. Transportation of Regulated Amounts of Radioactive Material will comply with 49 CFR, Subchapter C, Hazardous Material Regulations. Local Fire authorities and the site Radiation Safety officer (RSO) shall be notified of any Radioactive Material use.

Transmitter Requirements: The base policy concerning the use of transmitters such as radios, cell phones, etc., must be adhered to by all Contractor personnel. They must also obey Emissions control (EMCON) restrictions.

Work Element 2: Sampling and Testing

1.2.1 Collect and analyze bulk samples to determine, if any, the presence of asbestos containing materials (ACM). Follow 40 CFR 763- Subpart E, Asbestos Hazard Emergency Response Act (AHERA) requirements for sampling and testing of suspect ACM. The AHERA sampling protocol for Surfacing Materials (3/5/7) shall be used for sampling miscellaneous materials.

1.2.2 Test painted surfaces for the presence of lead, using an XRF Analyzer or take physical lead paint chip samples. Other paint constituents may be required to be sampled for certain locations, but will be ordered separately in addition to this survey service. Follow State Lead Administrative Rules and U.S. Department of Housing and Urban Development (HUD) guidelines for the screening and testing of painted surfaces. The collection of paint chips shall be used to confirm inconclusive XRF results and for a minimum of 10% of XRF sample locations tested. All test results regardless of test method shall be reported as milligrams per square centimeter, unless the surface area cannot be measured or if all paint cannot be removed from the measured surface area. The XRF Analyzer shall be calibrated per the following protocol unless these are less stringent than the manufacturer’s instructions: At the beginning and end of each inspection and at least every 4 hours during the inspection. Each calibration check shall consist of a minimum of three readings. Do not use an XRF Analyzer if the calibration check results are outside the Performance Characteristic Sheet (PCS) tolerance limits.

1.2.3 If any historical asbestos and lead survey reports are provided to the contractor, they shall be used “FOR REFERENCE ONLY”. Any material previously identified as containing asbestos or lead shall be re-sampled.

1.2.4 Perform destructive testing for each homogenous area, inaccessible to routine testing, that will be disturbed by the subject work. Destructive testing shall be performed in an orderly and professional manner. Destruction of structures shall be limited to what is required to obtain the samples. Patching of damaged areas shall be performed by the Contractor to the satisfaction of the NTR.

1.2.5 Flooring, roofing, walls, etc. shall be cored completely through for asbestos sample collection purposes. The profile of the material shall be inspected for multiple layers. For multi-layered materials (e.g. drywall, joint compound, tape), analyze both discrete samples (separate layers) and composite samples.

1.2.6 The actual number of samples collected shall be within plus or minus 10% of the number of samples included in the award at no additional cost to the government. If samples to be collected will exceed 10% of the number of samples included in the award due to unforeseeable circumstances, Contractor shall stop work, and notify Contracting Officer before proceeding.

1.2.7 The Contractor shall send samples to a third party accredited laboratory for analysis using appropriate U.S. Environmental Protection Agency (EPA) test methods.

1.2.8 Laboratories performing analysis for asbestos in bulk materials must be accredited by the National Institute of Standards and Technology/National Voluntary Laboratory Accreditation Program (NIST/NVLAP) and must be a successful participant and maintain proficiency in the NIST/NVLAP sponsored quality assurance program for asbestos identification.

1.2.9 Laboratories performing analysis for lead in paint chip, soil or wipe samples must be fully accredited by the EPA National Lead Laboratory Accreditation Program (NLLAP) and rated proficient in the NIOSH/EPA Environmental Lead Proficiency Analytical Testing Program (ELPAT). Paint chip samples shall be collected in accordance with ASTM E 1729, Standard Practice for Field Collection of Dried Paint Samples for Subsequent Lead Determination, or equivalent.

1.2.10 Retest all friable asbestos Thermal System Insulation (TSI) yielding Polarized Light Microscopy (PLM) results of less than 10% asbestos and above detectable limit using Point Count Method. Test till positive per analytical protocol.

1.2.11 Retest all non-friable materials yielding PLM results of greater than 1% but less than 5% using Point Count method. Test till positive per analytical protocol.

1.2.12 Retest all resilient floor covering materials including vinyl and asphalt floor tiles, sheet vinyl flooring, and floor adhesives and mastics with PLM results of 1% or less. Retest using Transmission Electron Microscopy (TEM). Test till positive per analytical protocol.

Work Element 3: Inventory of Hazardous Materials

1.3.1 The Contractor shall identify and inventory all hazardous materials remaining in the building in containers, drums, tanks, etc., and include a list in the report.

Work Element 4: Mold Survey

1.4.1 The Contractor shall conduct a survey of the existing building spaces and visually inspect for the presence of mold. If suspected areas of mold exist, the Contractor shall photograph these areas and collect samples to be tested. Representative background samples shall be taken from the existing building for comparison. Visual inspections shall identify suspected facility components impacted by moisture/mold for sampling, including sampling behind wall and ceiling surfaces for presence of mold.

1.4.2 Any physical sampling of suspected mold on building surfaces and confirmation of fungal/species type in accordance with EPA and ACGIH methods will be ordered separately in addition to this survey.

Work Element 5: Other Building Sampling

1.5.1 Visually inspect any existing floor drains and trench sumps for petroleum or other hazardous substances. Testing may be ordered in addition to this survey to characterize these substances..

Work Element 6: Environmental Report

1.6.1 Submit a draft copy of the Environmental Report to the NTR via the Contractual Representative for review and comment before finalizing the report.

1.6.2 The report shall be in a suitable format to issue to construction contractors for reference during the renovation project.

1.6.3 The report shall identify, locate, and quantify all environmentally regulated materials and wastes that will require abatement or waste manifesting. If no such materials or wastes were identified, then state this in the report.

1.6.4 If any materials are assumed to contain asbestos, then provide an explanation in the report as to why this assumption was made. Likewise, provide an explanation for any areas internal or external to the building that were not inspected.

1.6.5 The report shall include drawings showing the locations, quantities, and sample locations for homogenous areas of suspect ACM and testing combinations for paint. Samples that have tested positive for asbestos or lead based paint shall be annotated on the drawings.

1.6.6 The report shall provide approximate quantities for all suspect asbestos containing materials sampled regardless of test results.

1.6.7 The report shall include a table summarizing all identified suspect or assumed ACM. Results shall be tabulated. The table shall include as a minimum the following information:

· Homogenous Area (HA) Identification Number

· HA Location

· HA Description (include description of multiple layers as applicable; include diameters for piping)

· HA Type (surfacing material, thermal system insulation, or miscellaneous)

· Approx. Quantity

· Sample Identification Numbers

· Test Results (% and type of asbestos)

· Test Method (PLM, PC, TEM)

· Photo Identification Number

The table shall include the following additional information for any material containing more than 1% asbestos (ACM):

· Friability (friable or non-friable)

· Condition (good, damaged, severely damaged)

1.6.8 The report shall include a table summarizing all identified paint testing combinations and their classification (positive or negative). Testing combinations are not based on color, but on the following three elements: Room Equivalent, Component Type and Substrate. Classifications shall be determined from XRF and laboratory analyses results (to be provided as separate attachments). Testing combination information shall be tabulated. The table shall include as a minimum the following information:

· Room Equivalent

· Component Type

· Substrate

· Paint Color

· Classification (positive or negative)

· Approx. Quantity

· Condition

· Photo Identification Number

Additionally, the report shall include XRF calibration check results, XRF Performance Characteristic Sheet (PCS), and a copy of the non-medical radioactive material license issued by the State.

1.6.9 The report shall include a table summarizing all other identified environmentally regulated materials discovered at the project site (e.g. containers or equipment containing hazardous materials, mercury and PCB containing articles, low level radiation materials, ozone depleting substances, universal wastes, and special wastes). The table shall include as a minimum the following information:

· Description of material or waste

· Location

· Quantity

· Photo Identification Number

1.6.10 The report shall include appropriate number of photographs to adequately represent the environmentally regulated materials and wastes located at the project site. Report shall incorporate color photos into the finished survey. Photos shall be labeled with the date, material description, HA Identification Number (as applicable) and location. The label information shall be readable when viewed from the photograph.

1.6.11 The report shall include recommendations for disposal. This section shall include an exposure summary narrative (i.e. exposure pathways and how exposure will affect human health and welfare), an explanation of regulatory drivers for abatement, and a statement/narrative indicating how the particular regulated material (e.g. ACM or LBP) should be abated.

1.6.12 The report shall be prepared under the charge of a State Licensed Asbestos Project Designer.

1.6.13 The report format shall be organized as follows and include as a minimum the following information:

· Cover Page

· project title

· project location

· contract number

· contract company name and address

· printed name and signature of licensed inspectors

· inspector license numbers

· report date (including revision date as applicable)

· Table of Contents

· Executive Summary

· Introduction

· purpose of survey

· scope of services performed

· project area description

· inspection dates

· name(s) of inspectors and credentials

· areas not inspected due to inaccessibility

· Survey Methodology

· Summary of Findings

· Conclusions and Recommendations

· Abatement recommendations

· Statement of Limitations

· Tables (Appendix)

· Drawings of Homogenous Areas, Testing Combinations and Sample Locations (Appendix)

· scaled and dimensioned drawings

· floor plans or building sections showing location of each homogenous area and testing combination from which samples were collected

· specific location where each sample was obtained

· Inspector Certifications (Appendix)

· Chain of Custody Forms (Appendix)

· Laboratory Results (Appendix) The following data is anticipated to be present on the laboratory analytical data sheets:

· client sample identification number

· laboratory sample identification number

· analytical method used

· laboratory quality control procedures used

· physical description of sample, as received

· type(s) and estimated percentage of asbestos fibers

· type(s) and estimated percentage of non-asbestos fibers

· type (if known) and percentage of other components

· date of analysis

· name and signature of person performing analysis

· Laboratory Certifications (Appendix)

· XRF Analyzer Performance Characteristic Sheet (Appendix)

· Non-Medical Radioactive Material License (Appendix)

· Photographs (Appendix)

Additionally, each page of the main body of the report shall include the project title and date of report (including revision date as applicable).

Work Element 7: Abatement Cost Estimate

1.7.1 For each building, prepare a cost estimate for the abatement of asbestos containing materials and lead based paint, and disposal of all environmentally regulated materials and wastes discovered at the project site.

1.7.2 The cost estimate shall be itemized by material type, quantity, and unit cost.

1.7.3 The abatement cost estimate shall be detailed and include separate costs for mobilization and demobilization, preparation of containment area, material, labor, equipment, removal, disposal, decontamination, air monitoring, and clearance testing. The cost estimate shall be based on an assumed abatement method.

1.7.4 The abatement cost estimate shall be prepared under the charge of a State-Licensed Asbestos and Lead Project Designer.

Digital Photos

1.10.9 Provide two sets of CDs containing the digital photos.

Field Notes

1.10.10 Provide a copy of the filed notes on a CD.

Attachment (2) NAVFAC MID-LANT Portable Gauge Operations Planning Work Sheet

NAVFAC CONTRACTOR PORTABLE GAUGE / RADIOLOGICAL WORK OPERATIONS PLANNING SHEET

Project/Contract #: _______________________________ Site Location: ______________________________

C

Additional Site Restrictions or Requirements

Contractor’s Operator Name (Printed)

Signature

Date

Contracting Officer’s Representative Name (Printed)

Signature

Date

Contract Oversight Technician Name (Printed)

Signature

Date image1.jpeg