R5_Asbestos_Pre-Alteration_Assessment_Guidance.pdf
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This document provides guidance on conducting asbestos pre-alteration assessments for federal construction projects. Asbestos pre-alteration assessments are required under the National Emission Standards for Hazardous Air Pollutants to determine if asbestos-containing materials may be impacted by demolition or renovation work. The guidance specifies that pre-alteration assessments must be performed before any project or maintenance tasks that could disturb asbestos-containing materials. Assessments involve reviewing asbestos surveys and inventory documents, inspecting project sites, and potentially collecting bulk samples for testing. Only individuals trained in asbestos inspection or project design and licensed in the applicable state can perform pre-alteration assessments. The guidance establishes best practices for conducting assessments and determining responsibility for associated costs. It also defines key terms relating to asbestos and provides additional resources on applicable regulations.
The related federal contract opportunity is a solicitation for a Construction Manager as Constructor contract for the FDA Forensic Chemistry Center Project. The General Services Administration intends to award a guaranteed maximum price contract to modernize building systems and expand laboratory spaces at facilities in Cincinnati, Ohio for the FDA. Interested offerors should review the solicitation and attachments for full details on response requirements, evaluation criteria, and other contractual terms.
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Asbestos Pre-Alteration Assessment GSA Region 5 Facilities Management & Services Programs Division
August, 2014
ABSTRACT
This document is designed to establish guidance on asbestos pre-alteration assessments as defined in the PBS Asbestos Policy and 40 CFR 61 National Emission Standards for Hazardous Air Pollutants.
Table of Contents
What is a pre-alteration assessment?
Why is a pre-alteration assessment required?
When is a pre-alteration assessment required?
When is a pre-alteration assessment not required?
If an asbestos building survey was recently completed, is a pre-alteration assessment still required for my project?
What if the area has already been “abated”?
If I choose to treat all suspect material as ACM, is a pre-alteration assessment required?
Who is qualified to do a pre-alteration assessment?
How should a pre-alteration assessment be performed?
How is funding responsibility for the pre-alteration assessment determined? 4
What is the cost of a pre-alteration assessment?
How long does a pre-alteration assessment take?
What are friable, category I nonfriable, category II nonfriable, and RACM?
How are demolition and renovation defined?
Where can I find additional resources?
Asbestos Pre-Alteration Assessment 1
What is a pre-alteration assessment?
A pre-alteration assessment determines the potential for disturbance of asbestos and establishes the appropriate control methods for work activities based on the scope of the project. A pre-alteration assessment can be as complex as a full asbestos building survey using destructive sampling or as simple as matching asbestos inventory information to a project scope. It should be viewed as an element of project planning and design on all projects [2].
Why is a pre-alteration assessment required?
The EPA requires that a pre-alteration assessment be conducted under the National Emission Standards for Hazardous Air Pollutants (NESHAP). Subpart M of NESHAP deals with asbestos. To determine if the NESHAP reporting requirements or asbestos emission controls are needed, a pre-alteration assessment shall be performed for every demolition and renovation project that could potentially impact any asbestos-containing materials (ACM) including Category I and Category II nonfriable ACM [1]. The pre-alteration assessment is also a requirement of the PBS Asbestos Policy [2].
40 CFR 61 Subpart M NESHAP for Asbestos §61.145 Standard for demolition and renovation
(a) Applicability. To determine which requirements of paragraphs (a), (b), and
(c) of this section apply to the owner or operator of a demolition or renovation activity and prior to the commencement of the demolition or renovation, thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation will occur for the presence of asbestos, including Category I and Category II nonfriable ACM.
(b) Notification Requirements.
(c) Procedures for asbestos emission control.
40 CFR 61 Subpart M NESHAP for Asbestos can be found here.
PBS Asbestos Policy X. Renovation and Demolition
a. Before conducting any work in the vicinity of ACM, an assessment must be performed to determine the potential to disturb such ACM and sufficient controls must be designed into the project. This pre-alteration assessment must be conducted for all facility projects regardless of the age of the facility http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=ad48891992f4fbe5cfe5fa0d058188ca&h=L&r=SUBPART&n=40y9.0.1.1.1.13#40:9.0.1.1.1.13.1.2
Asbestos Pre-Alteration Assessment 2 and must address both accessible and inaccessible ACM. Destructive sampling must be conducted where necessary to address inaccessible ACM.
Firms performing such assessments must use personnel accredited as both "asbestos inspector" and "asbestos project designer" [2].
The full text of the PBS Asbestos Policy can be found here.
When is a pre-alteration assessment required?
A pre-alteration assessment shall be performed before every project (regardless of size) and Operations & Maintenance (O&M) tasks that may likely disturb asbestos [2].
When is a pre-alteration assessment not required?
There are certain cases that will not require you to perform a pre-alteration assessment.
1. If a building asbestos survey incorporating destructive sampling methods concluded no ACM is present; a pre-alteration assessment is not required.
Additionally, the accompanying Asbestos Confirmation Statement must be approved and on file.
2. If an entire area or floor in a building has been verified to have no ACM, a pre-alteration assessment will not be required. Verification will require adequate documentation that clearly delineates the area of interest. An individual who has completed an EPA course in asbestos inspection or project design and is licensed in the applicable state must have developed the documentation. The individual’s license information must also be included in the documentation.
If an asbestos building survey was recently completed, is a pre-alteration assessment still required for my project?
Asbestos surveys are useful in the preparation of pre-alteration assessments but typically cannot substitute for such assessments. Asbestos surveys often do not include destructive sampling and are not project specific [2].
If a building asbestos survey incorporating destructive sampling methods concluded no ACM is present; a pre-alteration assessment is not required. Additionally, the accompanying Asbestos Confirmation Statement must be approved and on file.
https://docs.google.com/a/gsa.gov/file/d/0B5eCmZX0Mf39TkZEY1MtendXd3M/edit
Asbestos Pre-Alteration Assessment 3
What if the area has already been “abated”?
40 CFR 61 Subpart M NESHAP for Asbestos and the PBS Asbestos Policy requires that a pre-alteration assessment be performed for every demolition and renovation project that could potentially impact any ACM including Category I and Category II nonfriable ACM [1,2].
Often times, projects will remove ACM in certain areas of a building based on a specific scope of work (SOW). When the project is complete, people may use the term “abated” to describe the finished area, because everything specifically defined in the SOW was removed. This should not be interpreted as the entire space is free of asbestos and subsequent pre-alteration assessments are not required. Pre-alteration assessments will be required for each subsequent project, unless a full asbestos survey using destructive sampling methods has been conducted to scientifically prove no ACM is present in that space.
If there is evidence the scope of the new project is determined to be fully and completely overlaid with previous asbestos removal work, this documentation can be used as the pre-alteration assessment. An individual who has completed an EPA course in asbestos inspection or project design and is licensed in the applicable state must have developed the documentation. The individual’s license information must also be included in the documentation.
If I choose to treat all suspect material as ACM, is a pre-alteration assessment required?
Project Managers may elect to forgo bulk testing and treat the presumed (assumed) materials as asbestos throughout the project. This may be an acceptable trade-off in rare circumstances, after careful consideration is given to the impact this will have on cost.
Who is qualified to do a pre-alteration assessment?
Those who have completed an EPA course in asbestos inspection or project design and are licensed in the applicable state can perform the pre-alteration assessment.
Bulk testing of building materials for asbestos should only be performed by an individual trained in asbestos bulk sampling. The persons best suited to perform a pre-alteration assessment are typically those who gather planning and scoping information for space projects [2].
Asbestos Pre-Alteration Assessment 4
How should a pre-alteration assessment be performed?
The pre-alteration assessment should always begin with a review of the most current asbestos survey, inventory, or management plan. The asbestos materials and locations identified in these documents should be overlaid with the affected materials and locations of the project. Where there is an obvious overlay of building areas and features (finishes and assets) to what is known in the asbestos report, no further action is needed. Where there are uncertainties about the location of asbestos or whether the project might impact the asbestos, further assessment is needed to clarify the uncertainties. This usually involves a visit to the project site and possible collection of bulk material(s) for subsequent asbestos laboratory testing. Asbestos materials that are confirmed or are believed to be impacted by a project are then incorporated into the design [2].
How is funding responsibility for the pre-alteration assessment determined?
The potential impact of ACM must be considered and included in the cost of Reimbursable Work Authorizations (RWAs) and programmed into proposed projects [2].
What is the cost of a pre-alteration assessment?
The cost of a pre-alteration assessment will vary by project based on the number of bulk samples required, the area being sampled, and the method used to analyze the bulk samples. Not all assessments will require sampling. In most cases, the cost of a pre-alteration assessment represents a negligible percentage of the total project cost.
How long does a pre-alteration assessment take?
The time required to perform a pre-alteration assessment will vary based on the project scope, whether bulk samples are required, the area being sampled, and the method used to analyze the bulk samples. Not all assessments will require sampling.
In most cases where sampling is required, the collection of data and bulk samples will require one day or less, with a final report issued within five business days.
Asbestos Pre-Alteration Assessment 5
What are friable, category I nonfriable, category II nonfriable, and
RACM?
Friable asbestos material means any material containing more than 1 percent asbestos as determined using the method of Polarized Light Microscopy (PLM) that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure [1].
Category I nonfriable ACM means asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products containing more than 1 percent asbestos as determined using the method of PLM [1].
Category II nonfriable ACM means any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos as determined using the method of PLM that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure [1].
Regulated asbestos-containing material (RACM) means (a) Friable asbestos material,
(b) Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or
(d) Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations [1].
How are demolition and renovation defined?
Demolition means the wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations or the intentional burning of any facility [1].
Renovation means altering a facility or one or more facility components in any way, including the stripping or removal of RACM from a facility component. Operations in which load-supporting structural members are wrecked or taken out are demolitions [1].
Where can I find additional resources?
40 CFR 61 Subpart M NESHAP for Asbestos:
http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=ad48891992f4fbe5cfe5fa0d058188ca&h=L&n=40y9.
0.1.1.1&r=PART&ty=HTML - 40:9.0.1.1.1.13
PBS Asbestos Policy:
http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=ad48891992f4fbe5cfe5fa0d058188ca&h=L&n=40y9.0.1.1.1&r=PART&ty=HTML#40:9.0.1.1.1.13 http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=ad48891992f4fbe5cfe5fa0d058188ca&h=L&n=40y9.0.1.1.1&r=PART&ty=HTML#40:9.0.1.1.1.13 http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=ad48891992f4fbe5cfe5fa0d058188ca&h=L&n=40y9.0.1.1.1&r=PART&ty=HTML#40:9.0.1.1.1.13
Asbestos Pre-Alteration Assessment 6 https://docs.google.com/a/gsa.gov/file/d/0B5eCmZX0Mf39TkZEY1MtendXd3M/e dit
Common Questions on the Asbestos NESHAP:
http://yosemite.epa.gov/r5/r5ard.nsf/2f86cbca09880b61862565fe00588192/f28 9826963fc6c6486256fc7006c5550!OpenDocument http://yosemite.epa.gov/r5/r5ard.nsf/2f86cbca09880b61862565fe00588192/f289826963fc6c6486256fc7006c5550!OpenDocument http://yosemite.epa.gov/r5/r5ard.nsf/2f86cbca09880b61862565fe00588192/f289826963fc6c6486256fc7006c5550!OpenDocument
Works Cited
[1] "ECFR — Code of Federal Regulations." ECFR — Code of Federal Regulations 40
CFR 61. Environmental Protection Agency. Web. 30 July 2014.
[2] United States. General Services Administration. PBS. Public Buildings Service
Asbestos Policy. Print.
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