JEB Little Creek – Building 3126 1250 Gator Blvd., Virginia Beach, VA 23460

Presented by

1818 New York Ave., Suite 231 Washington, DC 20002 www.salutinc.com info@salutinc.com

(301) 595-3783 January 4, 2021 mailto:info@salutinc.com

NAVFAC JEB Little Creek — Building 3126 Hazardous Material Investigation Report 1

TABLE OF CONTENTS

1. Asbestos Survey

1.1 Survey Methodology

1.1.1 Laboratory Analyses

1.2 Survey Findings

Table 1: Asbestos Inspection Summary

Table 2: Quantities of Suspect ACM

1.3 Asbestos Conclusions and Recommendations

2. Survey Limitations and Disclaimer

3. Operations & Maintenance Plan

3.1 Personnel Training Requirements

3.1.1 Maintenance Worker Training

3.1.2 Contractor Training

3.1.3 Medical Surveillance Requirements

3.1.4 Respiratory Protection Requirements

3.1.5 Protective Clothing Requirements

3.1.6 Abatement Program Establishment

3.1.7 Abatement of Asbestos Hazards

3.1.8 Procedures for Interim Control Measures

3.1.9 Fiber Release Episodes

3.1.10 Equipment and Supply Requirements

3.1.11 Notification/Right-to-Know/Labeling

3.1.12 Control of Work

3.1.13 Periodic Surveillance and Reinspection

3.1.14 Recordkeeping

APPENDIX A: ACM Laboratory Results ............................................................................ A-1

APPENDIX B: Photo Catalog ............................................................................................. B-1

APPENDIX C: Inspector Credentials ................................................................................. C-1

APPENDIX D: Laboratory Accreditations .......................................................................... D-1

APPENDIX E: Floor Plans with Sample Points .................................................................. E-1

Hazardous Material Investigation Report 2

Hazardous Material Investigation Report 3

1. Asbestos Survey On October 24th, 2020, Soil and Land Use Technology Inc., (SaLUT) performed a hazardous materials investigation at the NAVFAC Joint Expeditionary Base (JEB) Little Creek premises located at 1250 Gator Boulevard, Virginia Beach, VA 23460. This investigation included inspection and testing for asbestos-containing materials as requested by NAVFAC, in order to ascertain the presence of hazardous materials located in the NAVFAC JEB Little Creek property.

The results of this survey are presented in Section 1.2, Survey Findings. The asbestos survey was conducted by EPA-certified Asbestos Inspector, Mr. Wualter Hernandez (see Appendix C for credentials).

1.1 Survey Methodology

The sampling was conducted in accordance with EPA Standard 40 CFR 763 Subpart E, Asbestos Hazard Emergency Response Act (AHERA), OSHA Standard 29 CFR

1926.1101 Inspection Protocol and ASTM Standard E2356 Standard Practice for Comprehensive Building Asbestos Surveys. SaLUT representatives collected three hundred and forty-nine (349) bulk samples from one hundred and thirty-one (131) homogeneous materials. The number of samples collected complies with the minimum number of samples per material classification as specified under AHERA sampling protocols. AHERA specifies that surfacing materials require three samples for materials with less than 1,000 square feet, five samples for materials present in quantities ranging from 1,000 to 5,000 square feet, and seven samples for materials covering greater than 5,000 square feet. A minimum of three bulk samples were collected of each homogeneous miscellaneous material.

Suspect materials that were homogeneous in nature (i.e., uniform in color and texture) were identified, touched to determine friability, and sampled by removing a small piece. This small sample was placed into a labeled container. Extreme care was taken to avoid fiber liberation during the inspection/sampling process. Before sample collection, a fine mist of water was typically applied to the sample site.

Samples were collected using sharpened core samplers and/or razor knives, where necessary, and immediately placed in labeled containers and sealed.

1.1.1 Laboratory Analyses

Collected samples of suspect ACMs were submitted for analysis under strict chain-of-custody procedures to EMSL Analytical, Inc., and AMA Analytical Services National Voluntary Laboratory Accreditation Program (NVLAP)-accredited laboratory located in Maryland (Appendix D). The bulk samples were analyzed under polarized light microscopy/dispersion staining (PLM/DS)

Hazardous Material Investigation Report 4 techniques. All vermiculite samples were analyzed via PLM EPA 600/R- 93/116 with milling prep method.

1.2 Survey Findings

Out of one hundred and thirty-one (131) homogeneous areas where samples were collected from, nineteen (19) were determined to contain asbestos by laboratory analysis (Appendix A). Photographs of these materials are included in Appendix B.

Sample collection sites for identified suspect ACMs and locations of ACMs are indicated in Appendix B. The Asbestos Inspection Summary (Table 1) provides a listing of all identified suspect ACMs within the facility. For each suspect material, a description of the material, general locations in the building, and sample numbers are indicated, as well as whether the material was determined to be ACM or not, and a summary of the laboratory results.

Hazardous Material Investigation Report 5

Table1: Asbestos Inspection Summary

HOMOGENOUS

MATERIAL

MATERIAL LOCATION

SAMPLE

NUMBER

CONDI-

TION

FRIABLE

(Y/N)

% ASBESTOS

FLOOR ROOM

Samples Collected on October 24, 2020

Blue 12"X12" Floor Tiles with Navy/Beige Specks 1 1088 AS-00624

Good No No-Detected

Tan 12"X12" Floor Tiles 1 1088 AS-00625 Fair Good 3% Chrysotile

Black Floor Tile Mastic 1 1088 AS-00626 Fair Good 4% Chrysotile

Black 4" Rubberized Baseboard 1 1088 AS-00627

Good No None-Detected

Brown Baseboard With Mastic 1 1088 AS-00628

Good No None-Detected

White, 2'X 4' Ceiling Tile with Pinholes and Fissures 1 1088 AS-00629

Good No None-Detected

White, 2'X 4' Ceiling Tile with Pinholes and

Gouches 1 1088 AS-00630 Good No None-Detected

Beige Pipe Wrap associated with Fiberglass

Insulation 1 1088 AS-00631 Good No None-Detected

Gray Door Caulking associated with Metal

Door 1 1088 AS-00632 Fair No 6% Chrysotile

Beige/Brown 12"X12" Floor Tiles with Marble

Pattern 1 1087 AS-00633 Fair No 3% Chrysotile

Brown Floor Tile Mastic associated with 12’x12’

Floor Tiles 1 1087 AS-00634 Fair No 6% Chrysotile

Beige 12"X12" Floor Tiles with Small Speckles 1 1129 AS-00635

Good No None-Detected

Yellow/Gray Floor Tile Mastic associated with

12”x12” Floor Tiles 1 1129 AS-00636 Good No None-Detected

Dark Gray Speckled 12"X12" Floor Tiles 1 1129 AS-00637

Good No None-Detected

Black Floor Tile Mastic associated with 12”x12”

Floor Tiles 1 1129 AS-00638 Fair No 4% Chrysotile

Gray Tile Grout associated with Ceramic Floor Tiles 1 1129 AS-00639

Fair No None-Detected

Orange 12"X12" Floor Tiles with Beige Streaks 1 1092 AS-00640

Fair No 3% Chrysotile

Brown/Yellow Floor Tile 1 1092 AS-00641 Fair No None-Detected

Hazardous Material Investigation Report 6

HOMOGENOUS

MATERIAL

MATERIAL LOCATION

SAMPLE

NUMBER

CONDI-

TION

FRIABLE

(Y/N)

% ASBESTOS

FLOOR ROOM

Mastic associated with 12”x12” Floor Tiles

Beige/Brown Carpet Mastic associated with

Gray Carpeting 2 2001 AS-00642 Fair No None-Detected

Beige/Brown 12"X12" Floor Tiles associated with

Floor Carpet 2 2001 AS-00643 Fair No 3% Chrysotile

Black Floor Tile Mastic 2 2001 AS-00644 Fair No 5% Chrysotile

White Cementitious Drywall Joint Compound 2 2001 AS-00645

Fair No 2% Chrysotile

White Drywall 2 2001 AS-00646 Fair No None-Detected

Beige Duct Insulation Wrap 2 2nd fl storage AS-00647

Fair No None-Detected

Beige Pipe Wrap associated with 1”-3” OD

Fiberglass Pipe 2 2nd fl storage AS-00648 Fair No None-Detected

Beige Pipe Wrap associated with Pipe

Elbow 2 2nd fl storage AS-00649 Fair No None-Detected

White Rubberized Exterior Door Caulking associated with Metal Door 1 Warehouse loading dock AS-00650 Fair No None-Detected

White 2'X2' Ceiling Tiles with Pinholes and Gouges 1 1129 AS-00651

Fair No None-Detected

Gray Rubberized 4" Baseboard 1 1129 AS-00652

Fair No None-Detected

White Baseboard Mastic 1 1129 AS-00653 Fair No None-Detected

Green Carpet Mastic 1 1129 AS-00654 Fair No None-Detected

Beige Rubberized 4" Baseboard 1 1129 AS-00655

Fair No None-Detected

Beige/Brown Baseboard Mastic 1 1129 AS-00656

Fair No None-Detected

Beige 12"X12" Floor Tiles with Mutli-Color Streaks 1 1129 AS-00657

Fair No None-Detected

Black/Gray Mastic 1 1129 AS-00658 Fair No None-Detected

Beige Terrazzo Floor with Cementitious Dark Specks 1 1129 AS-00659

Fair No None-Detected

Green 12"X12" Floor Tiles with Beige Streaks 1 1129 AS-00660

Fair No None-Detected

Brown Mastic associated with Green Floor Tiles 1 1129 AS-00661

Fair No None-Detected

Hazardous Material Investigation Report 7

HOMOGENOUS

MATERIAL

MATERIAL LOCATION

SAMPLE

NUMBER

CONDI-

TION

FRIABLE

(Y/N)

% ASBESTOS

FLOOR ROOM

Brown 12"X12" Floor Tiles under Speckled Mutli-

Color Carpeting 1 1129 AS-00665 Fair No None-Detected

Brown Mastic 1 1129 AS-00667 Fair No None-Detected

Beige Pipe Seam Sealant 1 1097 AS-00669 Fair No None-Detected

Beige Pipe Seam Sealant 1 1097 AS-00670 Fair No None-Detected

Beige Sealant associated with 6” Pipe Insulation 1 1096 AS-00671

Fair No None-Detected

Beige/Brown Floor Mastic 1 1096 AS-00672 Fair No None-Detected

Black Mastic 1 1096 AS-00673 Fair No None-Detected

Beige Duct Sealant associated with Fiberglass

Insulation and Duct Wrapping 1 1096 AS-00674

Fair No None-Detected

White Tile Grout associated with 4”x4”

Ceramic Wall Tiles 1

Men’s RR by

NEXCOM HQ

OIA/HB/ admin.

area AS-00675

Fair No None-Detected

White Tile Grout associated with 12”x12”

Ceramic Floor Tiles 1

Men’s RR by

NEXCOM HQ

OIA/HB/ admin.

area AS-00676

Fair No None-Detected

Beige 12"X12" Floor Tiles with Orange and Gray

Specks 1

NW entry foyer by NEXCOM HQ OIA/HB/ admin.

area AS-00677

Fair No None-Detected

Brown Mastic 1

NW entry foyer by NEXCOM HQ OIA/HB/ admin.

area AS-00678

Fair No None-Detected

White Duct Seam Sealant 1

NW entry foyer by NEXCOM HQ OIA/HB/ admin.

area AS-00679

Fair No None-Detected

Beige/Brown 12"X12" Floor Tiles with Marble

Pattern 1 Electrical RM in EEO Office area AS-00680

Fair No 2% Chrysotile

Black Floor Mastic associated with HA-680 1

Electrical RM in EEO Office area AS-00681

Fair No 5% Chrysotile

Gray Tile Grout associated with Hexagonal Floor Tiles 1

1063-Staff kitchen AS-00685

Fair No None-Detected

Gray 12"X12" Floor Tiles with Dark and Beige

Specks 1 HQ OIA Server room AS-00720

Hazardous Material Investigation Report 8

HOMOGENOUS

MATERIAL

MATERIAL LOCATION

SAMPLE

NUMBER

CONDI-

TION

FRIABLE

(Y/N)

% ASBESTOS

FLOOR ROOM

Black/Brown Floor Mastic associated with Square

Carpeting 1 HQ OIA Admin.

suite AS-00721 Fair No <1% Chrysotile

Beige 12"X12" Floor Tiles with Light Brown and Light

Gray Streaks 1 Cubicle in HQ

OIA admin. area AS-00722 Fair No None-Detected

Yellow Carpet Mastic 2

Conference room in call center AS-00723 Fair No None-Detected

Beige 12"X12" Floor Tiles with Gray and Green

Specks 2

Conference room in call center AS-00724 Fair No 2% Chrysotile

Black Floor Tile Mastic 2

Conference room in call center AS-00725 Fair No 5% Chrysotile

Brown 12"X12" Floor Tiles underneath Carpet 2

Call center hallway AS-00726

Fair No 4% Chrysotile

Black Mastic on Wood Flooring 2

Call center hallway AS-00727

Fair No 5% Chrysotile

Yellow Carpet Mastic associated with 2’x2’ Mutli-

Colored Carpet Square 2 Call center hallway AS-00728 Fair No None-Detected

Gray Rubberized Window Caulking 2

Handicap Elevator lobby to call center AS-00729

Fair No None-Detected

Brown White Surface Particle Type Boards 2

Call center-server room AS-00730

Fair No None-Detected

Brown Roll-Out Paper associated with Pink

Insulation 2 Call center server room AS-00731 Fair No Non-Detected

Beige Tile Grout associated with 2’x2’ Ceramic Floor Tiles 2

Men’s RR in call center AS-00732

Fair No None-Detected

Black/Gray Grainy Roof Flashing Roof Section A AS-00733

Fair No None-Detected

Black Roof Seam Sealant associated with Roof

Flashing Roof Section A AS-00734 Fair No None-Detected

Black Roof Tar Pitch Pocket Sealant Roof Section A AS-00735

Fair No None-Detected

Gray Duct Sealant Roof Section A AS-00736 Fair No None-Detected

Gray Duct Sealant Roof Section A AS-00738 Fair No None-Detected

Black Roof Flashing Roof Section B AS-00770 Fair No None-Detected

Hazardous Material Investigation Report 9

HOMOGENOUS

MATERIAL

MATERIAL LOCATION

SAMPLE

NUMBER

CONDI-

TION

FRIABLE

(Y/N)

% ASBESTOS

FLOOR ROOM

Black Tar associated Roof Seam Sealant Roof Section B AS-00771

Fair No None-Detected

Gray Caulking associated with Metal Flashing Roof Section B AS-00772

Fair No None-Detected

Black Roof Flashing Roof Section B AS-00773 Fair No None-Detected

Beige Hard Compound Stucco Roof Section E AS-00774

Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section A, eastern side-north eastern side AS-00775

Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section A, eastern side at center AS-00776 Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section A, eastern side-southwest area AS-00777 Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section A, western side-north central area AS-00778

Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section A, western side-at the center AS-00779 Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section A, western side-south central area AS-00781

Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section B, eastern side-north eastern area AS-00782

Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section B, eastern side-north western area AS-00783

Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section B, eastern side-south central area AS-00784

Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section B, western side-south central area AS-00785

Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section B, western side- AS-00786

Hazardous Material Investigation Report 10

HOMOGENOUS

MATERIAL

MATERIAL LOCATION

SAMPLE

NUMBER

CONDI-

TION

FRIABLE

(Y/N)

% ASBESTOS

FLOOR ROOM

western area

Black/Brown Membrane Roof Core Roof

Section B, western side-northwestern area AS-00787

Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section C, northeastern area AS-00788 Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section C, northcentral area AS-00789 Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section C, northwestern area AS-00790 Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section C, southeastern area AS-00791 Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section C, southcentral area AS-00792 Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section C, southwestern area AS-00793 Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section E, eastern area AS-00794

Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section E, central area AS-00795

Fair No None-Detected

Black/Brown Membrane Roof Core Roof

Section E, western area AS-00796

Fair No None-Detected

Beige Rubberized Caulking Roof Section E AS-00797 Fair No None-Detected

Gray Tile Grout associated with 4”x8” Brown Floor

Tiles 1 1126-main lobby AS-00798 Fair No None-Detected

Beige 12"X12" Floor Tiles with Light Beige Specks 1 1010 Storage AS-00799

Fair No None-Detected

Black Floor Mastic associated with Sample

799 1 1010 Storage AS-00800 Fair No None-Detected

Beige/Brown 16”x16” Floor Tile 1 1011 AS-00801

Fair No None-Detected

Black Floor Mastic 1 mechanical room AS-00803 Fair No 4% Chrysotile

Brown Tile Grout 1 1023, 1132 AS-00804 Fair No None-Detected

Hazardous Material Investigation Report 11

HOMOGENOUS

MATERIAL

MATERIAL LOCATION

SAMPLE

NUMBER

CONDI-

TION

FRIABLE

(Y/N)

% ASBESTOS

FLOOR ROOM

associated with 6”x6” Red and Brown Floor Tiles

Beige 16”x16” Floor Tile with White and Black

Specks 1 1056 AS-00807 Fair No None-Detected

Black Floor Tile Mastic associated with sample

807 1 1056 AS-00808

Fair No None-Detected

Black/Gray Tile Grout associated with 1’x1’ Gray and Beige Ceramic Tiles 1 1054 AS-00810

Fair No None-Detected

Gray Tile Grout associated with 4”x4” Gray Ceramic

Wall Tiles 1 1054 AS-00813 Fair No None-Detected

Beige Seam Sealant associated with Fiberglass

Insulated Duct 1 Mechanical Room 1053 AS-00834

Fair No None-Detected

White End Cap Sealant 1 Mechanical Room 1053 AS-00835

Fair No None-Detected

Beige 16”x16” Floor Tile 1

Barbershop AS-00837 Fair No None-Detected

Yellow Mastic associated with Sample 837 1

Barbershop AS-00838

Fair No None-Detected

Black Tile Grout associated with Black 2”x2”

Ceramic Floor Tile 1 1043 RR AS-00839 Fair No None-Detected

Beige Tile Grout associated with Beige and Yellow 4”x4” Ceramic Wall

Tiles 1 1017, 1040 AS-00841

Fair No None-Detected

White Particle Type Boards with Peg Holes 1 1040 AS-00842

Fair No None-Detected

White Ceiling Plaster 1 1022 hallway AS-00843 Fair No None-Detected

Rough Plaster Brown Coat 1 1022 hallway AS-00844 Fair No None-Detected

White Smooth 2'X2' Drywall Type Ceiling Tiles 1 1021 AS-00845

Fair No None-Detected

Light Gray Smooth Window Caulking associated with old 8’x4’ window 1

Exterior Navy Exchange

Tenant office AS-00864

Fair No None-Detected

White Smooth Window Glazing associated with old 8’x4’ window 1

Exterior Navy Exchange

Tenant office AS-00865

Beige Door Caulking 1 Exit adjacent AS-00866 Fair No None-Detected

Hazardous Material Investigation Report 12

HOMOGENOUS

MATERIAL

MATERIAL LOCATION

SAMPLE

NUMBER

CONDI-

TION

FRIABLE

(Y/N)

% ASBESTOS

FLOOR ROOM

associated with Exterior Metal Double and Single

Door

NEXCOM IT field office

Beige/Brown Mastic underneath Black Stair

Thread 1 1114 Stairs AS-00867 Fair No None-Detected

Black Tar Paper associated with Wood Floor 1

Mechanical Room within Rm

1057 AS-00868

Fair No None-Detected

White 2'X2' Ceiling Tiles with Tiny Gouches 1 1126 AS-00869

Fair No None-Detected

Beige Duct Insulation Wrap 1

Adjacent to room 1002 AS-00870

Fair No None-Detected

Beige Rubberized Window Caulking 1 1004 AS-00871

Fair No 12% Chrysotile

Gray Textured Waterproofing 1 1030 AS-00872

Fair No 5% Chrysotile

White 2'X4' Ceiling Tiles Rough Fiberglass Type 1 1004 AS-00873

Fair No None-Detected

Yellow Carpet Mastic 1 1003 AS-00874 Fair No None-Detected

Brown Dry and Flaky Vermiculite 1 warehouse AS-01022

Fair Yes None-Detected

Hazardous Material Investigation Report 13

Table 2: Quantities of Suspect ACM

MATERIAL DESCRIPTION ESTIMATED QUANTITIES

Tan 12"X12" Floor Tiles 145 SF

Black Floor Tile Mastic 145 SF

Gray Door Caulking associated with Metal Door 18 LF

Beige/Brown 12"X12" Floor Tiles with Marble Pattern 145 SF

Brown Floor Tile Mastic associated with 12’x12’ Floor Tiles 145 SF

Black Floor Tile Mastic associated with 12”x12” Floor Tiles 920 SF

Orange 12"X12" Floor Tiles with Beige Streaks 62SF

Beige/Brown 12"X12" Floor Tiles associated with Floor Carpet 155 SF

Black Floor Tile Mastic 155 SF

White Cementitious Drywall Joint Compound 1,200 SF

Beige/Brown 12"X12" Floor Tiles with Marble Pattern 200 SF

Black Floor Mastic associated with HA-680 200 SF

Beige 12"X12" Floor Tiles with Gray and Green Specks 1,440 sf

Black Floor Tile Mastic 1,440 SF

Brown 12"X12" Floor Tiles underneath Carpet 825 sf

Black Mastic on Wood Flooring 825 SF

Black Floor Mastic 75 SF

Beige Rubberized Window Caulking 828 LF

Gray Textured Waterproofing 130 SF

1.3 Asbestos Conclusions and Recommendations

Evaluating the laboratory results, out of the one hundred and thirty-one (131) homogeneous areas, black mastic associated with 9x9 floor tiles and roof flashing contained asbestos.

We recommend monitoring for concealed suspected materials that may be ACM during the demolition phase. If concealed materials are identified, we recommend they be sampled and a determination of asbestos content be made. Standard construction practices, safety and health procedures normally employed during construction activity may be used for the removal, demolition, and disposal of these materials.

There are no additional recommendations at this time.

Hazardous Material Investigation Report 14

2. Survey Limitations and Disclaimer Information in this inspection report relating to asbestos, although believed to be inclusive and accurate, was based on visual observations and field sampling of accessible areas.

Limiting conditions included limited destructive sampling and inaccessible areas such as between walls and floors of the structures, and limited subsurface assessment of the property. Reasonable efforts are made to extrapolate where possible such as where insulated pipe runs into and through a wall. SaLUT, Inc. reserves the right to revise any recommendations and conclusions, and does not guarantee or accept any liability that encompasses this survey of all hazardous or regulated materials located within this building.

Hazardous Material Investigation Report 15

3. Operations & Maintenance Plan The O&M procedures contained in the Hazardous Material Investigation Report are provided only as an overview. Routine maintenance activities will incorporate procedures such as those found in the National Institute of Building Sciences (NIBS) Guidance Manual for Asbestos Operations and Maintenance Work Practices, or the EPA's Green Book entitled "Managing Asbestos in Place" or equivalent publication, for working with and around ACBM.

The purpose of O&M procedures is to minimize the exposure of building occupants and visitors to airborne asbestos fibers by cleaning potentially friable asbestos fibers already released; to prevent further releases by minimizing ACBM disturbance; and to monitor the condition of the ACBM. To accomplish this goal, O&M procedures must be implemented to manage ACBM in-place until abatement is necessary or the building is demolished. There are six major categories associated with O&M procedures:

1. Review of renovation or demolition projects for the presence and condition of ACBM

2. Notifying parents, teachers, and employees of the presence and condition of ACBM

3. Training of custodial and maintenance workers in proper procedures for cleaning and maintaining areas with ACBM

4. Implementing a program to periodically inspect and clean areas where there is a potential for release of ACBM

5. Coordinating with maintenance workers or contractors to notify them of asbestos hazards prior to repair, renovation, or building demolition (through a work order system)

6. Developing a schedule for periodic reinspection of ACBM

3.1 Personnel Training Requirements

Personnel who perform activities related to asbestos control or management must be qualified and trained. Such personnel will be trained in accordance with applicable federal and Virginia regulations. These personnel include the NAVFAC Asbestos Team; maintenance workers; and contractors.

The greatest social factor is the health risk perception ACBM has on individuals who work in areas with ACBM present. A hazard communication program should be implemented to inform those individuals of the potential dangers of friable ACBM as well as to reassure individuals that proper asbestos abatement will significantly reduce the risk of asbestos fiber exposure.

Hazardous Material Investigation Report 16

3.1.1 Maintenance Worker Training

In accordance with 40 CFR Part 763.92, members of the maintenance and custodial staff who work in a building that contains ACBM shall receive at least two hours of awareness training, whether or not they are required to work with ACBM. New employees must be trained within 60 days of hire.

For maintenance workers who conduct activities that result in ACBM disturbance, 16 hours of course training is required prior to performing activities that will disturb ACBM. Some of the course topics include:

• Background information on asbestos (types of asbestos, appearance, etc.)

• Potential health effects related to asbestos

• Worker protection (respiratory and PPE)

• Location of ACBM in buildings

• Recognition of ACBM damage and deterioration

• O&M program for the building

• Proper methods of handling and disposing of ACBM

• Training in work practices and engineering controls

• Name and telephone number of Designated Person

NAVFAC employees involved in O&M activities shall be required to complete O&M training. Maintenance workers must be properly trained to identify, clean, and maintain ACBM areas. OSHA defines ACBM as any material containing more than 1 percent asbestos (29 CFR Part 1926.1101). OSHA further defines several types of materials that may be considered ACBM if they contain more than 1 percent asbestos. These materials are:

• Surfacing Material (SM) such as sprayed-on or troweled-on materials (i.e., acoustical plaster on ceilings, fireproofing materials on structural steel)

• Thermal System Insulation (TSI) such as pipe, boiler, tank insulation or other interior structural components to prevent heat loss or gain or water condensation

• Presumed Asbestos Containing Material (PACM) such as TSI and SM found in buildings constructed no later than 1980

Hazardous Material Investigation Report 17

The EPA defines Miscellaneous Material (MM) ACBM as interior building materials on structural members, such as floor tiles, ceiling tiles, and wall materials that contain more than one percent asbestos.

OSHA defines asbestos work (29 CFR Park 1926.1101) into four distinct classes listed below:

Class I: Activities involving the removal of TSI and surfacing ACBM and

PACM.

Class II: Activities involving the removal of ACBM that is not TSI or SM. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile, roofing and siding shingles, and construction mastics.

Class III: Repair and maintenance operations where ACBM, including TSI and surfacing ACM and PACM, may be disturbed.

Class IV: Maintenance and custodial activities during which maintenance staff contact but do not disturb ACBM or PACM; and activities to clean up dust, waste, and debris resulting from Class I, II, and III activities.

Most of the cleaning and maintenance activities at NAVFAC may be classified as Class IV asbestos work. For O&M activities involving ACBM, the air-handling system as well as other sources of air movement must be temporarily shut-off or modified. For ACBM cleaning, a high-efficiency particulate air (HEPA) filtered vacuum cleaner must be made available to the custodial crew.

According to OSHA regulations (29 CFR Parts 1910.1001 and 1926.1101), the employer (NAVFAC) shall institute a training program for employees who are exposed to airborne concentrations of asbestos fibers above the PEL or excursion limit. The PEL for asbestos is currently set at an airborne concentration of 0.1 fibers per cubic centimeter (f/cc) of air calculated as an 8-hour time weighted average (TWA). The excursion limit is currently established as an airborne concentration of 1.0 flee of air as averaged over a sampling period of 30 minutes.

Basic components of training shall include:

• Health effects associated with asbestos exposure

• The quantity, location, manner of use, release, and storage of asbestos, and the specific nature of operations that could result in asbestos exposure

• Engineering controls, work practices, and PPE used to protect employee exposure to asbestos

• Purpose, proper use, and limitations of respirators and protective clothing

Hazardous Material Investigation Report 18

• Purpose and description of the medical surveillance program

• Requirements for posting signs, affixing labels on ACBM, and employee right to-know information on asbestos

3.1.2 Contractor Training

It is the responsibility of the NAVFAC Asbestos Team to ensure that outside contractors submit copies of current asbestos supervisor and worker certifications for employees working on asbestos-related projects at the facility.

Contractors with the potential to disturb ACBM will be required to sign a statement that they have reviewed the Hazardous Material Investigation Report and are familiar with the locations of known ACBM in the area in which they will be working and have been apprised of what to do if ACBM is accidentally disturbed or unknown ACBM is uncovered. NAVFAC will retain these records.

3.1.3 Medical Surveillance Requirements

NAVFAC will institute a medical surveillance program for employees who are or may be exposed to asbestos at or above the OSHA PEL of 0.1 flee, for 30 or more days per year, or the excursion limit of 1 flee for any length of time.

The medical surveillance program is also required for employees who are assigned to wear a negative pressure respirator (i.e., inspectors who take bulk asbestos samples and who monitor abatement contractor asbestos abatement activities). The examinations and procedures must be performed by or under the direct supervision of a licensed occupational physician. The examinations must, at a minimum, include the following:

• Medical and work histories with special emphasis directed to symptoms of the respiratory system, cardiovascular system, and respiratory tract

• Completion of a respiratory disease questionnaire

• A complete physical examination including a chest roentgenogram and pulmonary function test that includes measurement of the employee's forced vital capacity (FVC) and forced expiratory volume at one second

(FEV1)

• Any laboratory or other test that the examining physician deems to be necessary, in accordance with sound medical practice

These medical tests must be conducted initially upon hire, at least annually thereafter, and upon termination to those employees covered. The examining

Hazardous Material Investigation Report 19 physician will be provided with the following information prior to the examination: a copy of the applicable OSHA asbestos regulation; a description of the employee's duties as they relate to asbestos exposure; the employee's representative exposure to asbestos; a description of personal protective equipment used by the employee; and information from previous medical examinations of the affected employee that is not otherwise available to the examining physician.

NAVFAC will obtain a written opinion from the examining physician containing the results of the physical examination. The physician's opinion should include whether the employee has any detected medical conditions that would place the individual at an increased risk of exposure to related disease, and recommended limitations on the individual or on the use of personal protective equipment. A statement verifying that the individual has been informed by the physician of the results of the medical examination and of medical conditions related to asbestos that require further explanation or treatment is also required.

If an employee who is not in a medical surveillance program becomes exposed to friable asbestos at a level greater than the OSHA PEL for 30 or more days per year, or is exposed to levels of airborne asbestos at or greater than the excursion limit, or is assigned to wear a negative pressure respirator, NAVFAC shall ensure that the employee receives a medical examination.

NAVFAC shall maintain the records of the exposure incident and medical exam indefinitely.

3.1.4 Respiratory Protection Requirements

Respiratory protection training must be provided to NAVFAC Asbestos Team personnel and maintenance workers who come into contact and disturb ACBM. Respirator training must be in accordance with federal (OSHA, EPA) and Virginia regulations. Training must be conducted prior to the time when respirator use is required (i.e., O&M activities, asbestos abatement) and annually thereafter. The components of respirator training shall include:

• Proper fitting, adjusting, handling, cleaning, and storing of respirator

• Test of facepiece-to-face seal

• Health effects from exposure to asbestos

• Hazards associated with improper wearing of respirator

• Proper respirator selection based on airborne concentrations of asbestos fibers (Table 2-1)

Hazardous Material Investigation Report 20

• Limitation of respirators

The respirator training must conform with current OSHA standards for respirator selection in Table 2-1 below.

Table 2-1: Respirator Required

Airborne Concentration of Asbestos

Respirator Required

Less than 1 flee (10 x PEL) Half-mask air purifying respirator equipped with HEPA filters

1 flee - 5 flee (50 x PEL) Full-facepiece air purifying respirator equipped with HEPA filters

5 flee - 10 flee (100 x PEL) Any powered air purifying respirator equipped with HEPA filters or any supplied-air respirator operated in the continuous flow mode

10 flee - 100 flee (1,000 x

PEL)

Full-facepiece supplied-air respirator operated in the pressure demand mode

Greater than 100 flee (>1,000 x PEL)

Full-facepiece supplied-air respirator operated in the pressure demand mode equipped with an auxiliary positive pressure self-contained breathing apparatus

NAVFAC will ensure that respirators are available to employees and ensure that they are used when working with friable ACBM (work practices conducted at NAVFAC involving friable ACBM may include bulk sampling, inspecting asbestos abatement projects, and conducting small-scale ACBM abatement). At a minimum, half-mask air purifying respirators equipped with HEPA cartridges will be provided to employees involved in these work practices. Respirators used will be among those approved by the National Institute for Occupational Safety and Health (NIOSH) under the provisions of 30 CFR Part 11.

NAVFAC will institute a respiratory protection program prior to respirators being used. NAVFAC will institute a respiratory protection program satisfying, at a minimum 29 CFR Part 1910.134/1926.103, including the following:

• Each employee who uses an air purifying respirator will be permitted to change the filtering medium whenever an increase in breathing resistance is noted

• Employees will be permitted to leave work areas to wash their faces and respirator facepieces whenever necessary to prevent skin irritation associated with respirator use

Hazardous Material Investigation Report 21

• Each employee will be informed of the availability and provided a powered air purifying respirator (PAPR) if they request a PAPR, as long as the PAPR provides adequate protection

• No employee will be required to wear a respirator if, based on an examination by a licensed physician, the employee has been deemed to be unfit to work while wearing the appropriate respiratory protection

• NAVFAC Asbestos Team or Asbestos Team Leader will perform either qualitative or quantitative fit testing for those employees who are assigned respirators at the time of initial fitting and at least every six months thereafter as required by OSHA

3.1.5 Protective Clothing Requirements

Employees who are involved in sampling friable ACBM, inspecting asbestos abatement project areas, areas isolated following fiber release episodes, and small-scale ACBM abatement activities, will be provided with gloves and disposable full-body, including head and foot, disposable protective clothing (Tyvek or equivalent).

3.1.6 Abatement Program Establishment

While protection of students, personnel, visitors, and contractors is the primary objective of a comprehensive program, the selection of the optimum abatement action will include cost analysis of the various methods. Of the several remediation measures, proper removal and disposal of ACBM is the only one which eliminates potential exposure to the occupants, but it is also potentially the most expensive. Removal will be done at opportune times during construction and repairs, and when safety considerations are paramount. Encapsulation or enclosure may temporarily alleviate the problem but are not permanent solutions and may make future removal more expensive. The remaining ACBM requires inclusion in this Hazardous Material Investigation Report in order to routinely address the asbestos hazard at NAVFAC. Training maintenance personnel in asbestos hazard awareness/hazard communication, in conjunction with periodic inspections, will ensure that control measures will be taken early to reduce the potential hazard and will continue to offer adequate protection.

If samples indicate asbestos is present, 29 CFR Part 1910.1001 (General Industry Standard for Asbestos) will govern the proper control procedures. In general, this standard requires semi annual personal sampling of building occupants exposed to the OSHA action level of 0.1 flee, and employee training, medical examinations, and notification. The actual abatement shall

Hazardous Material Investigation Report 22 be conducted by a Virginia licensed asbestos abatement contractor according to 1926.1101.

3.1.7 Abatement of Asbestos Hazards

ACBM will not be allowed to deteriorate, become damaged, or be disturbed by workers or building occupants unless appropriate measures have been taken to prevent human exposure to airborne asbestos fibers.

To prevent asbestos fibers from becoming airborne, five major response actions are available to NAVFAC. These response actions and their advantages and disadvantages are presented in Table 2-2. ACBM will be removed when it poses a threat to release airborne asbestos fibers, and it cannot be reliably repaired or isolated.

The following list defines the five major response actions:

• Operations and Maintenance — Formulated program that includes identifying management structure (key personnel), notifying building occupants, determining priorities, implementing short- and long-term control programs, training, and maintaining comprehensive recordkeeping and report systems to maintain ACM in good condition.

• Repair and/or Operations and Maintenance — Measures taken to return damaged ACBM to an undamaged condition or to keep ACBM in an intact state to prevent the release of asbestos fibers.

• Encapsulation — Coating, binding, or resurfacing with materials that surround or embed asbestos fibers in an adhesive matrix to prevent fibers from becoming airborne.

• Enclosure — An airtight impermeable, permanent barrier or structure around the ACBM to prevent the release of asbestos fibers.

• Removal — Stripping of asbestos materials from any pipe, duct, thermal system unit, floors, or structural members by a licensed contractor or trained personnel. EPA only requires asbestos removal in order to prevent significant public exposure to airborne asbestos fibers during building demolition or renovation activities. Removal is also necessary when other response actions are not sufficient to protect human health and the environment or are not technically feasible.

Selection of appropriate response actions will be conducted in accordance with Table 2-2 below and in conjunction with budgetary limitations and other limiting factors.

Hazardous Material Investigation Report 23

Table 2-2: Alternative Response Action

Alternative Response Action Advantages Disadvantages

Repair and/or Operations and Maintenance

1. Usually lowest initial costs. 1. Asbestos source remains.

2. Good interim plan until funding becomes available for removal.

2. Surveillance (O&M Plan) is required.

3. May avoid need for removal until renovation or demolition.

3. Cost of training, operations and maintenance surveillance may be significant.

4. Allows asbestos removal to occur over a period of years, thus spreading expenditure.

4. Long-term life cycle cost may be greater than that of removal.

5. Can be implemented quickly. 5. May not be effective where control of worker/building occupant activities is difficult.

6. Can usually be done in-house. 6. If material must be repaired, source of damage must be identified and eliminated.

Encapsulation 1. May reduce asbestos fiber release from material.

1. Asbestos source remains and may have to be removed at a later date. Encapsulation may increase future removal cost.

2. Initial cost typically lower than removal or enclosure.

2. Inappropriate encapsulating agent may cause asbestos material to delaminate from substrate or may not prevent fiber release.

3. Fireproofing or insulating material may not need replacement.

3. O&M Plan needs to be kept active; potential for damage may still exist.

4. Is also a quick, temporary corrective action for damage to insulation material on piping and associated mechanical equipment.

4. Preparation activities for asbestos removal need to be implemented during encapsulation.

5. Allows opportunity for simultaneous improvement of architectural finishes on surfacing ACBM.

Enclosure 1. Reduces immediate exposure. 1. Asbestos source remains and may have to be removed at a later date. Enclosure will typically increase future removal cost.

2. Initial cost is typically lower than removal.

2. Maintenance to systems behind enclosure would require the removal of enclosure, thereby exposing

ACBM.

3. Fireproofing and insulation materials would not need replacement.

3. O&M Plan still needed unless enclosure (or encasement) is impact-proof and effectively isolates ACBM. Potential for damage may still exist.

4. Is also a quick, temporary corrective action for damage to insulation and associated mechanical equipment.

4. Fibers will be released during construction of enclosure (or spray application of encasement) and will, therefore, require the same preparation as that of removal and encapsulation.

5. Long-term life cycle cost may be greater than removal.

Hazardous Material Investigation Report 24

Alternative Response Action Advantages Disadvantages

Removal 1. Eliminates ACBM. 1. Refireproofing or reinsulation will be needed.

2. Eliminates continued need for O&M Plan.

2. Improper removal may increase airborne asbestos fiber concentration above prevalent levels.

3. Life cycle cost may be lowest of alternatives.

3. Initial cost is usually highest of all methods.

4. Eliminates application of regulations (if all ACBM is removed).

4. Building operations may have to be shut down temporarily during removal.

Should it not be practical to remove the friable asbestos, the material may be encapsulated or encased if the material retains its integrity and the substrate is undamaged; the material is not highly accessible; and the material is granular or cementitious rather than fibrous or fluffy.

If encapsulation is determined to be the most advantageous method, the recommended sealant used to encapsulate the material should be tested several days prior to widespread use to determine if delamination or deterioration of the ACBM substrate will occur. The contracted asbestos abatement contractor should perform the testing under the supervision of the NAVFAC Asbestos Team and/or Asbestos Team Leader. Appropriate protective measures (respiratory protection, isolation of the test area, protective clothing, etc.) should be established during the testing procedures in the event that delamination occurs. The sealant should be applied according to the manufacturer's instructions and should not be applied to material thicker than recommended, due to the possibility of delamination.

Large-scale (>3 square feet or 3 linear feet) ACBM removal at NAVFAC shall be conducted only by a Virginia-licensed asbestos abatement contractor.

Specifications for the removal project shall be prepared by the NAVFAC Asbestos Team and shall be checked by the Asbestos Team Leader prior to issuance. The Asbestos Team Leader shall ensure that the contractor is qualified to perform the required asbestos abatement work prior to an issuance of a Notice To Proceed by NAVFAC.

The NAVFAC Asbestos Team Leader is responsible for monitoring the contractor during the abatement project to ensure compliance with applicable regulations and worker/NAVFAC personnel safety requirements. The NAVFAC Asbestos Team Leader shall monitor the contractor's industrial hygienist's breathing zone sampling techniques and data. The NAVFAC Asbestos Team Leader shall immediately issue a Stop Work Order on any project that is an endangerment to human health. The Asbestos Team

Hazardous Material Investigation Report 25

Leader shall also have the authority to issue Stop Work Orders when violations of safety and health procedures are identified.

Friable ACBM shall be properly handled, transported, and disposed of at the specific direction of the NAVFAC Asbestos Team and Asbestos Team Leader, who shall ensure compliance by performing visual inspections of asbestos abatement project areas and by obtaining documentation of proper transport and disposal (waste shipment records and disposal manifests).

Handling, transportation, and disposal of ACBM shall be conducted in accordance with all federal and Virginia regulations.

3.1.8 Procedures for Interim Control Measures

When the building has not been cleaned using approved methods within the previous six months, areas with friable ACBM, damaged or significantly damaged thermal system insulation ACM, or friable suspected ACBM assumed to be ACM will be cleaned prior to the initiation of response actions other than O&M and repair. Additional or periodic cleaning is not recommended.

Surfacing Materials (SM) and Miscellaneous Friable Ceiling Tile Cleaning- ACBM that is sprayed-on or troweled-on surfaces is often the main source of airborne asbestos fibers in a building. If the material is friable, fibers are slowly released as the material ages. SM and miscellaneous ceiling tile are often most susceptible to damage during routine maintenance activities. The required practices for SM cleaning containing ACBM are as follows:

Initial Cleaning:

• Steam-clean carpets in affected areas throughout the building or vacuum carpets with a HEPA-filtered vacuum cleaner. Do not use vacuums without HEPA filters to clean ACBM surfaces.

• HEPA-vacuum curtains and books in affected areas.

• Mop or HEPA-vacuum non-carpeted floors and other horizontal surfaces in affected areas. Wipe shelves and horizontal surfaces with damp cloths. Use a mist spray bottle to keep cloths damp.

• Dispose of used rags, debris, cloths, mopheads, and vacuum filter bags as ACBM contaminated waste in sealed, leak-tight containers in accordance with EPA and OSHA regulations.

Periodic Cleaning (if recommended):

• Spray debris found near surfacing ACBM with amended water and place debris in plastic bags using a dust pan.

Hazardous Material Investigation Report 26

• Vacuum carpets with a HEPA-filtered vacuum cleaner. Do not use vacuums without HEPA filters to clean ACBM surfaces.

• Wet-mop non-carpeted floors and wipe shelves and horizontal surfaces with damp cloths.

• Dispose used rags, debris, cloths, mopheads, vacuum filter bags and debris as ACBM-contaminated waste in accordance with EPA and OSHA regulations.

Thermal System Insulation (TSI) Cleaning — Asbestos-containing pipe, boiler, and tank insulation is typically a less significant source of airborne asbestos fibers than surfacing materials. Protective jackets or coverings around the insulation will usually prevent fiber release. The required practices for cleaning TSI containing ACM are as follows:

Initial Cleaning:

• Steam-clean or HEPA-vacuum carpets in rooms containing heating, cooling, air handling, and similar equipment containing asbestos-containing insulation. Do not use vacuums without HEPA filters to clean asbestos-containing insulation.

• HEPA-vacuum curtains and books in rooms with asbestos-containing TSI.

• Wet-mop non-carpeted floors in rooms with asbestos-containing TSI.

Wipe shelves and horizontal surfaces with damp cloths. Use a mist spray bottle to keep cloths damp.

• Dispose used rags, debris, cloths, mopheads, and vacuum filter bags as ACBMcontaminated waste in accordance with EPA and OSHA regulations.

Periodic Cleaning (if recommended):

• Spray any debris found near asbestos-containing TSI with amended water and place debris in plastic bags.

• Vacuum carpets with a HEPA-filtered vacuum cleaner. Do not use vacuums without HEPA filters to clean TSI surfaces.

• Wet-mop non-carpeted floors and wipe shelves and horizontal surfaces with damp cloths.

• Dispose of used rags, debris, cloths, mopheads, vacuum filter bags and debris as ACBM-contaminated waste in accordance with EPA and OSHA regulations.

Hazardous Material Investigation Report 27

For routine repairs or insulation replacement, safety precautions and procedures must be implemented prior to repairs. The maintenance worker should avoid patching and repair work on TSI until the ACBM has been assessed by the NAVFAC Asbestos Team. During repairs or replacement of TSI, warning signs should be posted; containment barriers or bags should be positioned around work area; and workers should wear appropriate PPE, including respirators. TSI damaged during construction or maintenance activities should be repaired with non-asbestos mastic and replaced with non-asbestos TSI and new protective jackets.

Miscellaneous Material (MM) Cleaning — Most ACBM that is neither SM nor TSI is hard and non-friable. This type of ACBM releases asbestos fibers only when disturbed (i.e., cut, drilled, sawed) or damaged. Therefore, O&M activities should include alerting workers to the location of such ACBM and to avoid disturbance or damage to the ACBM. The NAVFAC Asbestos Team must ensure that safety precautions be followed before authorizing construction or maintenance work involving ACBM.

The OSHA guidelines for care of asbestos-containing floor coverings are described below:

• Sanding of flooring material is prohibited.

• Stripping of floor finishes shall be done as infrequently as possible (i.e., once or twice per year).

• Follow appropriate work practices, such as safe operation of machines, pads, and floor care products.

• Strip floors while wet. Burnishing or dry buffing may be performed only on flooring that has sufficient finish so that the pad cannot contact the flooring material.

• Stripping of finishes shall be conducted using low abrasion pads at speeds lower than 300 rpm. Prior to machine operation, use a mop and chemical stripper solution to soften the wax or finish coat. If the machine used to strip the wax or finish coat has variable speeds, it should be run at slow speed (i.e., 300 rpm) during floor stripping.

• Use the least abrasive pad possible to strip wax or finish coat from asbestos containing floors.

• Do not over strip floors. Over stripping can damage the surface and may release asbestos fibers. Do NOT operate a floor machine with an abrasive pad on unwaxed or unfinished floors.

Hazardous Material Investigation Report 28

Preventative Measures — Preventative measures applies to SM, TSI, and MM. The maintenance staff employees should be instructed:

• Not to drill holes in ACBM.

• Not to hang plants or pictures on structures covered with ACBM.

• Not to sand or use high-speed…