S02 - W Roxbury - Volume 1 - FINAL.pdf

VOLUME I

GENERAL ASBESTOS/LEAD CONTAINING

PAINT SUMMARY REPORT

VISN 1

West Roxbury VA Medical Center

1400 VFW Parkway West Roxbury, Massachusetts

Project No. 2009023.002

May 28, 2010

5 Alfred Circle Bedford, MA 01730-2318

Telephone: (781) 275-6050 Toll Free: (800) 877-6050 Facsimile: (781) 275-5651 info@mabbett.com www.mabbett.com

© 2010, Mabbett & Associates, Inc.

©2010, Mabbett & Associates, Inc. i W Roxbury - Volume 1 - FINAL 5-28-10.doc

ACKNOWLEDGMENT

This Asbestos Containing Materials (ACM) and Lead Containing Paint (LCP) Survey Report was prepared for the Veterans Affairs (VA) New England Healthcare System (VISN1) in accordance with an established scope of work as defined in Contract Number VA241-P-1653. The information presented herein is based on the facts and information conveyed to or received by Mabbett & Associates, Inc. (M&A) during the preparation of this report. If any of the information provided to M&A that was used in preparing this report is incorrect, incomplete, or subject to change, M&A would wish to alter its opinion(s) accordingly. In addition, the professional opinions and information contained in this report are based solely on the requirements of the applicable regulations and technical data as of the date of this report and considered applicable to this report.

This report was prepared by the following Mabbett & Associates, Inc. personnel:

MABBETT & ASSOCIATES, INC.

BY:

Michael F. Delaney Project Manager Massachusetts Asbestos Inspector AI031436 Massachusetts Management Planner AP000048

This report has been reviewed and approved by:

Robert K. McKinley, MPH, CIH, LIH Director of Industrial Hygiene Services Massachusetts Asbestos Inspector AI000314

©2010, Mabbett & Associates, Inc. ii W Roxbury - Volume 1 - FINAL 5-28-10.doc

TABLE OF CONTENTS

Volume I - General

Chapter 1 - Introduction and Executive Summary Chapter 2 - Asbestos Operations & Maintenance (O&M) Manual Chapter 3 - Asbestos Containing Materials (ACM) Survey Tables Chapter 4 - Lead Containing Paint Screening Survey Tables

Volume II – Individual Building Reports

Individual Building Reports Chapters including:

• Cover page with building number

• Building narrative summary

• Floor plans

• Relevant asbestos findings for the building

• Relevant lead containing paint findings for the building

• Relevant photos

Volume III – Appendices and Supporting Data

Appendix A - Asbestos Laboratory Analysis Reports and Laboratory Certifications Appendix B - Inspector Field Data Sheets/Chains-of-Custody Appendix C - Personnel Certifications & Licenses Appendix D - XRF Performance Characteristics/Calibration Records Appendix E - Lead Laboratory Analysis Reports and Laboratory Certifications (if applicable)

Volume IV – HUD Residential LBP Reports (If Applicable)

©2010, Mabbett & Associates, Inc. iii W Roxbury - Volume 1 - FINAL 5-28-10.doc

VOLUME I – CHAPTER 1

Description Page

INTRODUCTION & EXECUTIVE SUMMARY

Executive Summary Scope Previous Report Summary Asbestos Survey Summary Lead Containing Paint Screening Survey Summary

LIST OF TABLES

Table 1 List of Screened/Survey Buildings Table 2 List of Building not Screened/Surveyed’ Table 3 List of Leased Buildings not Surveyed Table 4 Previous Report Summary Table 5 Summary of Duplicate Bulk Sample Results Table 6 Buildings Surveyed Where ACM was Not Identified Table 7 Buildings Surveyed Where ACM was Identified Table 8 Summary of Damaged Asbestos Containing Materials Table 9 Summary of ACM Quantities for Liability Report Table 10 Buildings Screened Where LCP in Concentrations Greater than the VISN 1

Threshold of 0.1 mg/cm2 was not Identified Table 11 Buildings Screened Where LCP in Concentrations Greater than the VISN 1

Threshold of 0.1 mg/cm2 was Identified

ATTACHMENTS

Attachment A Supporting Documentation

CHAPTER 1

INTRODUCTION & EXECUTIVE SUMMARY

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 1 of 8 W Roxbury - Volume 1 - FINAL 5-28-10.doc

INTRODUCTION & EXECUTIVE SUMMARY

Executive Summary

Mabbett and Associates, Inc. (M&A) with Covino Environmental Associates, Inc. (Covino) and EnviroMed Services, Inc. (EnviroMed) as sub-contractors (i.e. the M&A Team) performed an asbestos containing materials (ACM) and lead containing paint (LCP) screening inspection survey of the VA Medical Center (VAMC) located at 1400 VFW Parkway, West Roxbury, Massachusetts under contract VA241-P-1653. Site survey work was performed during January and February 2010 by appropriately credentialed personnel. No US Housing and Urban Development (HUD) residential LCP Surveys were performed. During the course of the survey phase, 972 of the 1,086 bulk samples collected were analyzed for asbestos content. Materials consisting of multiple layers were analyzed separately. 1,457 lead readings including calibration readings were collected from the buildings surveyed during the LCP screening survey.

This report, including individual Building Reports (Volume II), is the product of the M&A Team’s effort.

The Report consists of three volumes: Volume I – General, which is the main Project Report, containing the complete set of analytical findings tables for the ACM and LCP screening surveys, and the Asbestos Operations and Maintenance (O&M) Manual. Volume II - Individual Building Reports, containing floor plans indicating ACM sample locations and findings information, detailed analytical findings for the specific surveyed building, and relevant photos; and Volume III – Appendices/Back-up Data, including laboratory results and field data sheets.

Scope

The following VAMC buildings listed in the table below were included in this scope of work for ACM and LCP screening surveys:

Table 1 - List of Screened/Surveyed Buildings West Roxbury VA Medical Center

Bldg. No. Function Title Year Built

Year Renovation

No. of Floors

Total

GSF

Hospital/Clinic & Admin and

Flagpole 1943 1988 7 195,458

2 SCI/Med/ Surgery 1978 NA 6 150,800

3 Outpatient 1989 NA 4 149,300 5 Engineering/FMS 1977 NA 1 5,100 7 Warehouse 1945 NA 2 8,620 8 Boiler House 1943 1989 1 5,594

10 Garage 1945 NA 1 1,932

16 Incinerator (Abandoned) NA NA NA NA

17 Shops 1945 NA 1 1,800 20 Research 1950 1989 1 5,218 22 Research 1960 1996 1 1,474 30 Research 1960 1995 1 1,540

GSF – Gross Square Feet

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 2 of 8

The following buildings listed in the table below were not included in this survey for the reasons indicated:

Table 2 - List of Buildings not Screened/Surveyed

Bldg.

No. Function Title Year Built Leased Total GSF Reason for not screening or surveying

70 Switchgear Bldg. 2006 No 1,196 Removed from scope by VISN 1 **

Office Trailers (C&B Custom

Module) 2005 No 10,669 Removed from scope by VISN 1 **

96 Fisher House 2009 No 14,587 Removed from scope by VISN 1 **

X1

Child Care Trailer

(C&B Custom Module)

2009 No 2,749 Removed from scope by VISN 1 **

Key:

GSF – Gross Square Feet **Supporting documentation is provided in Attachment A.

The following leased facilities were visually screened for ACM, but no samples were collected.

Certification from the building owners attesting that no ACM is present were provided and are included in Attachment A. LCP surveys of leased facilities were not included in the scope of services of this contract. These facilities listed in the table below will be surveyed for ACM when and if authorization is received from VISN 1 and the building owner(s):

Table 3 - List of Leased Buildings not Surveyed

Bldg.

No. Function Title Year Built Leased Total GSF

126V Worcester Vet Center NA Yes 3,900

L1 Worcester OPC 1992 Yes 27,567

NA – Not Applicable

Supporting documentation from the building owners is provided in Attachment A.

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 3 of 8

Previous Report Summary

The VA provided previous Asbestos Survey Reports that have been listed in the table below. No LCP or ACM O&M Plans were made available. It should be noted, that it was not the intent of M&A to confirm the accuracy of the provided reports, but rather to use the provided reports as a guide while conducting the asbestos survey.

Table 4 - Previous Report Summary

Date Firm Title

June, 1995 Universal Engineering Corporation

Final Report for the Asbestos Update Survey:

Brockton Buildings, Jamaica Plain Buildings, and

West Roxbury Buildings September, 2004 Kendall Taylor & Company, Inc. 2004 Consolidated Asbestos Survey, West Roxbury, MA 02132

Asbestos Survey Summary

To determine the locations of suspect building materials, a visual inspection was conducted by Massachusetts Licensed Asbestos Inspectors in buildings listed in Table 1.

Only areas that were accessible during the field work phase were sampled. Areas which were inaccessible were indentified in the individual building reports. Suspect ACM material that may be present within the walls, above inaccessible hard ceilings, or in other inaccessible locations, that was not sampled should be assumed to contain asbestos if discovered during any renovation process or until otherwise verified. To avoid impacting any existing roof warranties, no destructive sampling of roofing materials was included in this survey, and suspect roofing material should be assumed to be ACM until sample results prove otherwise.

Sampling and inspections were performed in general accordance with US Environmental Protection Agency (EPA) Asbestos Hazard and Emergency Response Act (AHERA) protocols.

The Polarized Light Microscopy (PLM) analytical protocol requires each layer of the sample to be analyzed separately. The quantity of analyses will vary based on the number of layers in a sample and whether a "positive stop" is employed. A positive stop is used when one sample of a homogeneous area is positive, the remainder of the samples were not be analyzed because the entire homogeneous area is considered positive as indicated on the results tables and drawings.

The bulk asbestos samples collected were submitted under chain of custody procedures to ProScience Analytical Services, Inc. (ProScience) of Woburn, MA for polarized light microscopy (PLM) analysis of bulk materials via EPA 600/R-93/116 Method. ProScience is accredited by the American Industrial Hygiene Association (AIHA) and participates in the National Voluntary Laboratory Accreditation Program (NVLAP Lab Code 200090-0). Duplicate bulk samples were submitted to Covino Environmental Associates, Inc. (Covino). Covino is accredited by the American Industrial Hygiene Association (AIHA) and participates in the National Voluntary Laboratory Accreditation Program (NVLAP Lab Code 101781-0). Copies of the laboratory analysis

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 4 of 8 reports and accreditations are included in Appendix A, Volume III of the Comprehensive VAMC Lead and Asbestos Survey Report. A summary of the duplicate bulk sample results is provided in the table below:

Table 5 - Summary of Duplicate Bulk Sample Results

Building No.

Sample No. Description of Material

Percent and Type of Asbestos reported by

ProScience

Percent and Type of Asbestos reported by Covino

28 Gray Caulking at Double Doors NAD NAD

59C Small Diameter Pipe Insulation

Laboratory did not analyze sample due to a positive stop on sample 59A. Results of sample 59A revealed:

10% Chrysotile 40% Amosite

35% Amosite

82A 12”x12” Dark Purple Mottled Vinyl Floor Tile NAD NAD

83A 12”x12” Dark Purple Mottled Vinyl Floor Tile Mastic NAD NAD

100A Old Metal Window Glazing Trace 2% Chrysotile

23C 2’x2’ Ceiling Tile with Pin Dots NAD NAD

29G Joint Compound NAD NAD

7 24C Window Glazing NAD NAD

8 5A 12”x12” Light Brown Floor Tile NAD NAD

10 12A Window Glazing NAD NAD NAD – No Asbestos Detected All results considered acceptable per the SOP.

Of the 12 buildings surveyed for ACM, the following buildings had no ACM identified based on the results of the surveys of accessible locations and analytical results for sample collected which were all reported by the laboratory as “No Asbestos Detected” (NAD) for these buildings. See individual building reports for specific sample locations, building drawings, and results:

Table 6 - Buildings Surveyed Where ACM was Not Identified

Building 3

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 5 of 8

The following buildings had ACM identified during the survey based on the analytical results provided by the laboratory. See individual building reports for specific sample locations, building drawings, and results:

Table 7 - Buildings Surveyed Where ACM was Identified

West Roxbury VA Medical Center Building 1 Building 2 Building 5 Building 7 Building 8 Building 10

Building 16 Building 17 Building 20 Building 22 Building 30

The Asbestos O&M manual prepared by a Massachusetts Licensed Asbestos Management Planner found in Volume I - Chapter 2 of the Project Report satisfies the Occupational Safety and Health Administration (OSHA) compliance requirements for employee safety and for management of asbestos identified at the facility. This O&M manual contains the asbestos survey results, background information on asbestos, an introduction to the O&M program, information on implementing the O&M program, O&M work practices, O&M incident and emergency work practices and O&M surveillance and documentation practices. It is M&A’s understanding that asbestos removal and replacement procedures will be performed by asbestos abatement contractors rather than training in-house personnel to perform these tasks. The O&M manual reflects this understanding.

During preparation of renovation activities, the VAMC should review the Asbestos O&M Manual and specific building reports to determine if asbestos-containing materials will be disturbed by the proposed renovations. The VAMC should also assume materials not previously sampled due to accessibility, etc. which will be impacted by renovation activities to be asbestos-containing materials unless otherwise determined. If asbestos containing materials must be disturbed as a part of the renovations, ACMs must be removed by a Massachusetts Licensed Asbestos Abatement Contractor and proper notification to the Massachusetts Department of Environmental Protection be made as required. In the event of the disturbance of an asbestos containing material, the facility Asbestos Program Manager shall decide if the disturbance is considered an incident or an emergency and shall follow the guidelines of the attached Operations and Maintenance Manual, listed in Chapter 2, Section 8.0.

Continuous monitoring shall be performed by the facility Asbestos Program Manager or qualified representative during renovation activities and on a semi-annual basis as described in Section 9.0 of the attached Operations and Maintenance Manual. At a minimum, the continuous monitoring shall include a visual inspection and documentation of the asbestos containing materials to assess if the materials have become friable and/or damaged. Additionally, prior to commencing renovations, all contractors involved with the renovations should be made aware of the location and quantity of ACMs within the building in which they will be working.

If any asbestos containing material is damaged or becomes damaged it should be repaired, if possible, or removed entirely. Materials classified with a high potential for disturbance as identified in the tables should be removed or repaired immediately upon discovering damage to the material especially when located in occupied areas.

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 6 of 8

The VISN 1 AHERA hazard assessment scale 1 – 4 is a relative indicator of the risk and need for response/remediation. (1) represents the highest priority (e.g. removal or encapsulation) where as a (4) represents the lowest priority (monitor as part of 6 month O&M program). The rating assigned by an Asbestos Management Planner, takes into account: condition, friable vs. non-friable, accessibility, occupancy (e.g. continuous, intermittent or occasional and patients/staff/visitors), potential for air erosion, potential for vibration damage, potential for disturbance / damage (e.g. exposed and in an accessible location), and potential for water damage.

Based on the visual observations of this survey, the items listed in Table 8 below were identified as having a VISN 1 AHERA Risk Hazard Category rating of 1 (damaged condition):

Table 8 - Summary of Damaged Asbestos Containing Materials

Bldg No.

Sample No.

ACM

Location

ACM

Description

Laboratory Results Condition Estimated

Quantity

VISN 1

RISK

AHERA

Hazard

Category 1-4*

1 59 A

Staff Elevator Lobbies, in

Chase Above Drop Ceiling

Exposed Ends of Small

Diameter Pipe

Insulation

10% Chrysotile

40%

Amosite

Damaged 10 LF 1

7 22 Room 7

Debris Inside

Basement Trench

50% Chrysotile

Significantly Damaged 6 CF 1

8 19 B

Debris on Electrical

Conduit Near Mezzanine

Level Doorway to Chemical

Mixing Room

Debris 2% Chrysotile

Significantly Damaged 2 SF 1

LF – Linear Feet CF – Cubic Feet SF – Square Feet

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 7 of 8

The VAMC must submit a quarterly ACM liability report. At the time of the survey the following quantities of ACM were identified and should be included in the liability report until removed from the building.

Table 9 – Summary of ACM Quantities for Liability Report

General Description of Material Estimated Quantity

Flooring Tile and/or Mastic 91,035 SF

Terazzo Flooring 50 SF

Sheet Flooring and/or Mastic 1,860 SF

Pipe Insulation 381 LF

TSI Debris 9 SF

Window Caulking 10,230 LF

Window Glazing 400 LF

Door Caulking 450 LF

Building Caulking 300 LF

Duct Sealant 1,000 LF

Foam Panel Patch 525 SF

Wall Insulation Panel Adhesive 5,250 SF

Lab Counter 40 SF

Transite Panel at Radiators 300 SF

SF – Square Feet LF – Linear Feet

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 1 – Page 8 of 8

Lead Containing Paint Screening Survey Summary

M&A performed the LCP screening using lead screeners as identified in the VISN 1 approved Standard Operating Procedure (SOP). The purpose of the screening was to identify patterns of LCP and to not identify all LCP building components. LCP screening consisted of walking through each building to observe accessible areas for the presence of suspect painted surfaces that may include LCP, then selecting painted surfaces representative of major building components in each building to be tested including but not limited to windows, doors, walks, floors, etc. Lead containing paint screenings were performed in the buildings listed in Table 1 of this document.

Buildings where LCP screenings were not performed are listed in Table 2 and Table 3 of this document.

1,457 representative X-Ray Fluorescence (XRF) readings, from different painted surfaces in the listed buildings, were taken during the screening including calibration checks. Per VISN 1 non-painted structural elements such as glazed tile, glazed block, stained glass, and painted equipment, furniture, etc., were not included in the screening surveys although those items may have lead present. Because the OSHA standard for lead exposure in construction is applicable for lead present in paint at any level, for the purposes of this inspection a painted or coated substrate that contains greater than 0.1 mg/cm2 is classified as LCP. A summary of LCP results reported by building are located in each Building Report (Volume II). Tables containing XRF readings collected by building are located in Volume I - Chapter 4 of the Project Report.

Table 10 - Buildings Screened where LCP in Concentrations Greater than the VISN 1 Threshold of 0.1 mg/cm2 was not Identified

Building 22

The following buildings had LCP identified in accessible locations during the survey based on the analytical results provided by the XRF. See individual building reports for specific sample locations, building drawings, and results:

Table 11 - Buildings Screened where LCP in Concentrations Greater than the VISN 1

Threshold of 0.1 mg/cm2 was Identified West Roxbury VA Medical Center Building 1 Building 2 Building 3 Building 5 Building 7 Building 8

Building 10 Building 16 Building 17 Building 20 Building 30

ATTACHMENT A

SUPPORTING DOCUMENTATION

CHAPTER 2

ASBESTOS OPERATIONS & MAINTENANCE (O&M) MANUAL

ASBESTOS CONTAINING MATERIALS (ACM)

OPERATIONS AND MAINTENANCE (O&M) MANUAL

VETERANS AFFAIRS MEDICAL CENTER

1400 VFW PARKWAY

WEST ROXBURY, MASSACHUSETTS

VISN1

West Roxbury VA Medical Center

1400 VFW Parkway West Roxbury, Massachusetts 02132

PROJECT NO. 2009023.002

May 28, 2010

PREPARED BY:

5 Alfred Circle Bedford, MA 01730-2318

Telephone: (781) 275-6050 Toll Free: (800) 877-6050 Facsimile: (781) 275-5651 info@mabbett.com www.mabbett.com

© 2010, Mabbett & Associates, Inc.

©2010, Mabbett & Associates, Inc. i W Roxbury - Volume 1 - FINAL 5-28-10.doc

ACKNOWLEDGMENT

This Asbestos Containing Materials (ACM) Operations & Maintenance (O&M) Manual was prepared for the U.S. Department of Veterans Affairs, VISN1, Veterans Affairs Medical Center (VAMC) located in West Roxbury, MA in accordance with an established scope of work as defined in Contract Number VA241-P-1653. The information presented herein is based on the facts and information conveyed to or received by Mabbett & Associates, Inc. (M&A) during the preparation of this manual. If any of the information provided to M&A that was used in preparing this manual is incorrect, incomplete, or subject to change, M&A would wish to alter its opinion(s) accordingly. In addition, the professional opinions and information contained in this report are based solely on the requirements of the applicable regulations and technical data as known to M&A as of the date of this manual and considered applicable to this manual.

This O&M Manual was prepared by the following Mabbett & Associates, Inc. personnel:

MABBETT & ASSOCIATES, INC.

BY:

Michael Delaney, Project Manager Massachusetts Asbestos Management Planner

#AP000048

This O&M Manual has been reviewed and approved by:

Robert K. McKinley, MPH, CIH, LIH Director of Industrial Hygiene Services

©2010, Mabbett & Associates, Inc. ii W Roxbury - Volume 1 - FINAL 5-28-10.doc

Description Page

O&M DIRECTORY

1.0 INTRODUCTION

2.0 PROJECT INFORMATION

3.0 ASBESTOS BACKGROUND

4.0 INTRODUCTION TO THE OPERATIONS AND MAINTENANCE

PROGRAM

5.0 IMPLEMENTING THE OPERATIONS AND MAINTENANCE PROGRAM 6

6.0 OPERATIONS AND MAINTENANCE WORK PRACTICES

7.0 NOTIFICATIONS

8.0 INCIDENT AND EMERGENCY WORK PRACTICES

9.0 O&M SURVEILLANCE AND DOCUMENTATION

10.0 OPERATIONS AND MAINTENANCE PROCEDURES FOR VARIOUS

ASBESTOS-CONTAINING MATERIALS

11.0 FUTURE O&M WORK PRACTICES

12.0 QUALIFICATIONS STATEMENT

Appendix A:

ACM Labeling/Signage Procedures Form 1 - Employee Notification Form Form 2 - Employee Awareness Form Form 3 - Contractor Notification Form Form 4 - Asbestos Training Documentation Form 5 - Building Inspection Form Form 6 - Building Re-inspection Form

Attachments:

Building ACM Summary Tables OSHA Occupational Exposure to Asbestos standard, 29 CFR 1910,1001

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 2 – Page 1 of 19

O&M DIRECTORY

The following is a directory of the personnel involved in the facility's ACM Operations and Maintenance Program. The names are listed in the order in which notifications in the event of an incident or emergency involving ACM should take place.

Title Personnel

1. Asbestos Program Manager Bryan Soltysik

(617) 839-6705

2. Building Asbestos Coordinator(s) Bryan Soltysik

(617) 839-6705

3. Asbestos Program Consultants Mabbett & Associates, Inc.

(800) 877-6050

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 2 – Page 2 of 19

1.0 INTRODUCTION

This site-specific O&M Manual is exclusively for the VA, VISN 1, VAMC, West Roxbury, MA.

This manual is limited to the following buildings:

• Building 1 – Hospital/Clinic

• Building 2 – SCI/Med/Surgery

• Building 5 – Engineering/FMS

• Building 7 – Warehouse

• Building 8 – Boiler House

• Building 10 – Garage

• Building 16 – Incinerator Building

• Building 17 – Shops

• Building 20 – Research

• Building 22 – Research

• Building 30 – Research

The manual includes an O&M directory, project information, a list of the identified ACM and future O&M work practices. A properly conducted O&M Program can be an important asbestos control strategy. However, it is important that everyone involved in the program be committed to implementing it properly.

In addition, this site-specific manual includes background information on asbestos, an introduction to the O&M program, information on implementing the O&M program, O&M work practices, O&M incident and emergency work practices, and O&M surveillance and documentation practices.

Where no VA West Roxbury specific ACM program O&M procedures, forms, etc. were made available, Occupational Safety & Health Administration (OSHA) guidance and sample documents and templates have been included for the VA’s use and consideration.

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 2 – Page 3 of 19

2.0 PROJECT INFORMATION

The O&M plan is part of the VAVISN1 ACM and Lead-Based Paint (LBP) Building Surveys.

The scope of work as defined under contract number VA241-P-1653, included asbestos inspections of the above listed buildings (see Section 1.0). The information provided in this O&M plan is reliant upon the findings of those inspections. Inspection building reports containing drawings, narrative, and results are on file in the Safety Office. Tables containing lists of building materials found to contain ACM, locations and present conditions are attached to this manual. This O&M Plan focuses specifically on the ACMs listed on these tables.

If any ACM is damaged or becomes damaged it should be repaired, if possible, or removed entirely. Materials with a high potential for disturbance should be removed or repaired immediately upon discovering damage to the material especially when located in occupied areas.

All identified ACM must be removed prior to any planned renovation, maintenance, or demolition activities (if the asbestos will be disturbed) in compliance with all federal, state and local asbestos regulations. The procedures set forth are standard O&M procedures.

3.0 ASBESTOS BACKGROUND

3.1 What is Asbestos?

Asbestos is a term used to describe a group of six naturally occurring fibrous minerals (chrysotile, amosite, crocidolite, anthophyllite, tremolite, and actinolite) found in certain types of rock formations. Of that general group, the minerals chrysotile and amosite are commonly found in building products.

3.2 Asbestos Uses in Buildings

Asbestos has been used extensively in buildings throughout the world as a component in fireproofing, insulation materials, decorative and acoustical texture, floor coverings, roofing materials and as reinforcement for plaster binders in building products. Asbestos became a popular commercial product because of its strength, fire and corrosion resistance, and insulating qualities. In The United States, its commercial use began in the early 1900s.

3.3 Health Effects

Asbestos fibers can cause serious health problems if inhaled. Three specific diseases --asbestosis (a fibrous scarring of the lungs), lung cancer, and mesothelioma (a cancer of the lining of the chest or abdominal cavity) have been linked to asbestos exposure. These diseases do not develop immediately after inhalation of asbestos fibers; it may be 20 to 40 years or more before symptoms appear.

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 2 – Page 4 of 19

3.4 Federal Regulations

Since the early 1970s, awareness of the potential health hazards associated with inhalation of airborne asbestos fibers has increased. In 1973, the Environmental Protection Agency (EPA) enacted the National Emission Standards for Hazardous Air Pollutants (NESHAPs) which banned the spray application of asbestos-containing materials, such as fireproofing, insulation and acoustical surfacing materials. Also enacted was a no visible emissions standard for building renovation and demolition.

Because of its carcinogenic nature and because of its common use in public buildings, EPA mandated in the May 27, 1982 Federal Register that all public and private schools (kindergarten through grade 12) be inspected for the presence of asbestos-containing materials. This was the first legal mandate requiring any type of action concerning asbestos in buildings.

On October 22, 1986, Congress passed the Asbestos Hazard Emergency Response Act (AHERA) that, among other provisions, required EPA to develop final asbestos rules by October 17, 1987. It included inspection, testing, establishment of an O&M Program, and in some cases, removal of asbestos.

The Occupational Safety and Health Administration (OSHA) has regulations for occupational exposure to asbestos. The West Roxbury VA Medical Center is required to follow OSHA regulations in 29 CFR 1910.1001 and 1926.1101 - Occupational Exposure to Asbestos standards, to protect employees and maintenance workers. Among other things, these standards require that building owners do the following:

• Identify and label asbestos containing materials;

• Notify affected parties;

• Maintain records of notifications;

• Train housekeeping staff about the location of ACM and anyone who may be exposed to levels of asbestos above the permissible exposure limit; and,

• Designate a competent person to oversee asbestos activities.

If asbestos-containing materials are found during an inspection, there is no requirement that they be addressed in a manner similar to that which Congress mandated for schools. There is an EPA requirement to remove most asbestos-containing materials, with the possible exception of roofing materials, vinyl asbestos floor tiles and linoleum, from a building prior to demolition. In addition, there is no federal law requiring removal of asbestos currently in place in buildings.

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 2 – Page 5 of 19

4.0 INTRODUCTION TO THE OPERATIONS AND MAINTENANCE PROGRAM

4.1 Objective of the Operations and Maintenance Program

The principal objective of an O&M Program is to minimize exposure of building occupants to asbestos fibers. To accomplish this objective, an O&M Program includes work practices to:

(1) Maintain ACM in good condition,

(2) Ensure proper cleanup of asbestos fibers previously released, if necessary,

(3) Prevent further release of asbestos fibers, and

(4) Monitor the condition of ACM.

4.2 Types of Asbestos-Containing Materials

For the purpose of the Operations and Maintenance Program, asbestos-containing materials are placed into three major categories:

(1) Surfacing Material: Surfacing material is ACM that is sprayed or troweled onto surfaces, such as plaster, sprayed finishes, acoustical surfaces, or fireproofing.

(2) Thermal System Insulation (TSI): TSI is insulation applied to pipes, boilers, tanks, and ducts to prevent heat loss, heat gain, or condensation.

(3) Miscellaneous ACM: Miscellaneous ACM is other asbestos-containing materials such as ceiling or floor tiles, floor coverings, asbestos-cement panels, asbestos siding, and roofing materials.

4.3 Types of Operations and Maintenance Projects

Generally, the O&M Program is comprised of three types of projects:

No Contact with ACM Expected

Those projects that are unlikely to involve any direct contact with ACM -- for instance, floor tile in a facility. The custodial and maintenance staff can generally handle these projects.

Potential for Contact with ACM

Those projects which may cause accidental disturbance of ACM; for instance, maintenance work that may expose workers to TSI identified at the facility or removing and replacing damaged flooring material or miscellaneous materials.

Since the West Roxbury VA Medical Center will not be training an asbestos response team, these projects will require the involvement of an asbestos removal contractor. If the West Roxbury VA Medical Center plans to train an internal asbestos response team that will handle or disturb ACM, then appropriate training, medical surveillance, asbestos approved respirators (and a written respiratory protection program), personal protective equipment, environmental control equipment such as HEPA vacuums, etc. must be provided by the West Roxbury VA Medical Center to employees who perform these projects. Attached to this

© 2010, Mabbett & Associates, Inc. Vol I, Chapter 2 – Page 6 of 19 document are the OSHA Occupational Exposure to Asbestos standards that provide specific details pertaining to the above-mentioned items.

Contact with ACM

Those projects which involve relatively small disturbances of ACM -- for instance, maintenance work such as mechanical work that may come into contact with the TSI identified at the facility or removing and replacing damaged flooring material or other miscellaneous materials. Placing carpet, new sheet vinyl flooring or floor tile over asbestos-containing flooring (without removing the existing flooring) can be performed by maintenance personnel provided that they are aware of the location of ACM and are instructed not to disturb the material. However, if these materials are to be removed, these projects will require the involvement of an asbestos removal contractor. If the West Roxbury VA Medical Center plans to train an internal asbestos response team that will handle or disturb ACM, then appropriate training, medical surveillance, asbestos approved respirators (and a written respiratory protection program), personal protective equipment, environmental control equipment such as HEPA vacuums, etc. must be provided by the West Roxbury VA Medical Center to employees who perform these projects. Attached to this document are the OSHA Occupational Exposure to Asbestos standards that provide specific details pertaining to the above-mentioned items.

Larger, more complex projects for the intentional removal of ACM are beyond the scope of an O&M Program and are considered asbestos abatement projects. Abatement projects require state licensed abatement contractors. Contact the Asbestos Program Consultant for requirements.

Prior to finalizing plans for renovation activities, the VAMC should review the ACM O&M Manual to determine if ACM will be disturbed by the proposed renovations. The VAMC should also assume materials not previously sampled due to accessibility, etc. which will be impacted by renovation activities to be asbestos-containing materials unless proved otherwise. If ACM must be disturbed as a part of the renovations, all ACMs must be removed by a Commonwealth of Massachusetts licensed asbestos abatement contractor. If proposed renovations will not disturb ACM, continuous monitoring of ACMs should be conducted throughout renovation activities to ensure the ACMs remain in an intact condition. Additionally, prior to commencing renovations, all contractors involved with the renovations should be made aware of the location and quantity of ACMs within the buildings in which they will be working.

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5.0 IMPLEMENTING THE OPERATIONS AND MAINTENANCE PROGRAM

5.1 The Asbestos Program Manager

An Asbestos Program Manager, who will be responsible for maintaining the O&M Program, should be appointed. The Asbestos Program Manager's responsibilities are numerous and the Asbestos Program Manager will act as the decision-maker on all routine, as well as emergency, asbestos-related matters. The Asbestos Program Manager will have authority to oversee the custodial and maintenance staffs, contractors and outside service vendors with regard to all asbestos-related activities. The Asbestos Program Manager will arrange for training of on-site personnel in O&M techniques. The Asbestos Program Manager may delegate various responsibilities including documentation and record keeping to an Asbestos Program Consultant.

5.2 The Building Asbestos Coordinator

A Building Asbestos Coordinator (BAC), such as the maintenance managers associated with each building, should be appointed. BACs are responsible for notifying the Asbestos Program Manager of building operations that could disturb ACM or emergency, asbestos-related matters. The BAC can provide asbestos awareness training on behalf of the Asbestos Program Manager (if properly trained). The BAC or Asbestos Program Manager will develop a list of key contacts within the West Roxbury VAMC consisting of maintenance staff, custodial staff, office managers, general employees and vendors.

A well-developed O&M Program is ineffective unless the BAC is committed to implementing it properly. The BAC should convey this commitment to key personnel involved in the building's management and operations.

5.3 Cleaning

The Asbestos Program Manager should make a determination for the frequency of routine cleaning. Non-routine cleaning will be necessary if ACM is inadvertently disturbed. If an area needs to be cleaned due to the inadvertent disturbance of ACM, an asbestos removal contractor should be contacted for cleaning.

In areas where damage or debris was observed in the initial asbestos survey, dry brooms, mops, dust cloths, and standard vacuum cleaners simply re-suspend asbestos fibers into the air and, therefore, should not be used.

5.4 Notification

The Asbestos Program Manager and/or the BAC will inform maintenance employees, tenants and contractors about the location and physical condition of the ACM that may be disturbed, and stress the need to avoid disturbing the material. Informed building occupants are less likely to unknowingly disturb ACM and release fibers into the air. Notification will include an explanation of the asbestos labeling system. (See Appendix A.)

The BAC will inform building occupants about the presence of ACM by holding awareness or information sessions and posting signs in a common area at the West Roxbury VAMC where affected occupants can see them. The following methods will be used by the BAC to complete these notifications:

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Awareness Meetings

Selected personnel shall attend an awareness/information session. This session will inform them of the presence of asbestos in their facility and the procedures the management of the West Roxbury VAMC is taking to control it.

Employee Letter

Mail or post the employee/tenant notification letters for the West Roxbury VAMC Medical Center employees, tenants and contractors working at the facility. It is a simple method of conveying the needed information concerning the ACM within the facility (Form 1 in Appendix A is a sample template to be tailored by the BAC for use).

Employee Asbestos Awareness Form

All employees who are likely to contact ACM should sign the employee awareness form (sample Form 2 in Appendix A) including the asbestos program managers, each building manager, and maintenance or custodial/housekeeping employee of the West Roxbury VAMC or anyone else who may contact ACM during maintenance or renovation.

All other personnel whose work may involve disturbing ACM should also sign the awareness form. This form is an example and may be modified to meet the BAC’s needs. The Asbestos Program Manager will retain these forms on file for no less than 30 years as a critical document to support the owner in legal proceedings.

Through the use of this acknowledgment form, the management of the West Roxbury VAMC is showing its intent to abide not only by EPA and OSHA regulations but also by EPA and OSHA recommendations.

Contractor Notification Form

All affected outside contractors, vendors, and others sign the contractor notification form (sample Form 3 in Appendix A) to notify them of the presence of ACM within your facility. This form may also be modified depending on the intended outside agents. This form is signed by the contractor's superintendent or project manager and ensures that all of the contractor's workers have been informed of the presence of ACM.

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Warning Signs and Restricted Areas

To minimize the chance for accidental entry into areas with a high risk of exposure, such as areas undergoing maintenance activities, warning signs should be posted and access restricted to authorized personnel only. This is necessary to prevent personnel, both employees and agents, who are unaware of the presence of asbestos and its potential hazards from inadvertently disturbing any ACM. See Appendix A for a detailed explanation of the labeling system.

5.5 Employee Medical Surveillance Program

It is our understanding that the West Roxbury VAMC will hire an asbestos abatement contractor to perform removal where ACM will be disturbed. A Medical Surveillance Program for West Roxbury VAMC personnel will not be necessary under these conditions.

If the West Roxbury VAMC plans to train an asbestos response team and those employees will come in direct contact with ACM (other than placing new tile or other flooring over asbestos containing tile), then medical surveillance must be provided to each employee who is part of the asbestos response team. The details of the medical surveillance are included in part M of the OSHA Occupational Exposure to Asbestos standard attached to this O&M plan.

5.6 Employee Training

The Asbestos Program Manager will be required to attend formal training programs on the presence of asbestos-containing materials within the facility. Verbal notice with an acceptance signature will apply to contractors used by the West Roxbury VAMC prior to conducting work that will disturb the ACM. Each training program is for a certain group of employees depending on their exposure to the ACM in the building.

A. Asbestos Awareness Training Program

The Asbestos Awareness Training should be attended by employees that are not in day-to-day contact with ACM. These employees include but are not limited to:

* Administrative staff

* Maintenance staff/FMS staff

* Housekeeping/EMS staff

* Clerical Staff

* Other employees with minimal contact with ACM on a regular basis

The program presents general awareness training for the West Roxbury VA Medical Center employees, and would include:

* Administrative staff responsibilities

* An overview of the ACM in the facility

* Health concerns associated with ACM

* The building owner's response to the ACM

* The role of the building employees in a successful O&M Program

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The asbestos awareness program is vital to the dissemination of information to employees and tenants that have minimal contact with ACM on a day-to-day basis. This program should be well documented, and a record of each person in attendance should be kept on file. In addition, the employee should sign Form 2 indicating that he understood the material presented. Form 4 is to be completed by the trainer. Training records are maintained by the BAC and reviewed annually for completeness by the asbestos program manager.

6.0 OPERATIONS AND MAINTENANCE WORK PRACTICES

It is our understanding that the West Roxbury VA Medical Center will hire an asbestos abatement contractor to remove ACM, instead of training in-house personnel to perform these tasks. If the West Roxbury VAMC plans to train an asbestos response team and those employees will come in direct contact with asbestos (other than placing new tile or linoleum over asbestos containing tile), then medical surveillance must be provided to each employee who is part of the asbestos response team. The details of Class III and Class IV asbestos work are included in the OSHA Occupational Exposure to Asbestos standard that is attached to this O&M plan.

7.0 NOTIFICATIONS

7.1 EPA Notification Plan

A. Effective October 1, 1997, except as noted below, EPA no longer requires facility owners/operators to provide written Notification of Demolition and Renovation to the EPA, pursuant to 40 CFR subsection 61.145(b), as long as such notifications are delivered to the Commonwealth of Massachusetts Department of Occupational Safety (DOS) on forms jointly prescribed by the Massachusetts Department of Environmental Protection (DEP) and DOS.

The EPA will view notification to the DEP and DOS as having satisfied the federal notification requirement and conversely, will consider those who fail to notify the DEP and DOS as being in violation of the federal notification.

The EPA has published a notice in the October 2, 1997 Federal Register which details this information to the regulated community and the general public.

B. Written notices must be submitted to the DEP and DOS in accordance with the requirements of 310 CMR 7.00, 7.09, 7.15, and 453 CMR 6.12. Notice must be made on the Asbestos Abatement Notification Form prescribed by the DEP and DOS.

C. The exception to the transfer of notification receipt procedures will apply to regulated facilities, as defined by the asbestos NESHAP regulation 40 CFR Subsection 61.141, where a demolition is to occur but where asbestos is present below the DOS notification threshold amounts. This exception applies to those demolitions involving less than or equal to three (3) linear feet of asbestos-containing material or less than or equal to three (3) square feet of asbestos-containing material. This exception would also apply to those demolitions believed to involve zero asbestos. Notices subject to this exception must be submitted to EPA directly as presently required.

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D. Such notices shall be mailed to: EPA Region 1

Demolition/Renovation Clerk (APC 2811)

JFK Federal Building Boston, Massachusetts 02203

E. This notification shall be submitted by the abatement contractor on behalf of the owner and reviewed by the Asbestos Consultant.

7.2 Commonwealth of Massachusetts DEP and DOS Notifications

A. MA DOS will be notified before engaging in any asbestos abatement project or asbestos associated project which involves more than three (3) linear feet of asbestos on pipes or ducts, or more than three (3) square feet of asbestos surface other than pipes or ducts. Notification must be made on the Asbestos Abatement Notification Form prescribed by DOS and the DEP, and shall be postmarked or hand delivered at least ten (10) days before the asbestos abatement start date. For emergency asbestos abatement projects, notification shall be postmarked or hand delivered within one (1) working day after the start of asbestos abatement.

B. This notification may be submitted by the abatement contractor on behalf of the owner.

8.0 INCIDENT AND EMERGENCY WORK PRACTICES

8.1 Introduction

Special operating practices are needed in the event of a situation that may cause an immediate release of airborne asbestos fibers. These operating procedures are intended to limit, as much as possible, contamination of the building environment and thus reduce the potential for building occupant exposure to airborne asbestos fibers. Situations of this type are an incident or an emergency. An incident involves the disturbance of ACM in a small, localized area, while an emergency involves the sudden disturbance of large amounts of ACM. It is the responsibility of the Asbestos Program Manager to decide whether an incident is an emergency. Personnel must notify the BAC and the Asbestos Program Manager of all disturbances of ACM.

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8.2 Incident Procedures

In the event of an incident, the first priority will be the safety of the occupants of the area.

Notify the BAC and the Asbestos Program Manager immediately, and initiate the following procedures with appropriately trained personnel:

• Evacuate and isolate the area,

• Isolate and/or shut down the HVAC units to the area, and

• Await instructions from the Program Manager or BAC.

The Asbestos Program Manager will contact the asbestos abatement contractor to initiate the following procedures:

• If feasible or necessary, stop the cause of the disturbance,

• Clean-up the disturbed material in the affected area, and

• Provide for air sampling of the affected area (Asbestos Program Consultant).

8.3 Emergency Situations

Some typical situations that might represent an emergency include:

• Fire,

• Extensive water damage from roof leaks, pipe breaks, or other means,

• Improperly executed renovation or remodeling activities, or

• Earthquake, structural failure or other catastrophic events.

8.4 Emergency Procedures

The first priority in an emergency is the safety of the employees and contractors. Initiate the following procedures immediately:

• If feasible, stop the cause of the contamination (renovation work, coring, jack-hammering, etc.),

• Evacuate the area or building, if necessary,

• If possible, isolate or shut off power to the HVAC system, isolate the affected area by closing all doors leading to the area, and Immediately notify the BAC and the Asbestos Program Manager and other appropriate authorities (fire department, etc.), and inform authorities of the presence of asbestos.

The Asbestos Program Manager and/or the BAC will then contact the asbestos abatement contractor and implement the following procedures.

• Isolate the area,

• Ensure all personnel are evacuated. If someone must enter the area, only properly trained and protected personnel (required respiratory protection, protective clothing, including head covering, etc.) will be allowed to enter the area,

• Assure the isolation of the HVAC system,

• Wait for asbestos abatement/clean-up contractor to arrive and correct the

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• If necessary, the asbestos abatement contractor, under the authority of the

Asbestos Program Manager, will hire the Asbestos Program Consultant to conduct air monitoring inside and outside the contaminated area to evaluate airborne fiber concentrations. The air handling system in the affected area will remain off until airborne fiber concentrations are determined. No employee will enter the area until the contaminated area has been checked and air monitoring results indicate that the airborne fiber concentration is below a level acceptable to the building owner.

9.0 O&M SURVEILLANCE AND DOCUMENTATION

9.1 Periodic Surveillance

A regularly scheduled inspection plan for all areas where ACM is identified shall be implemented. The inspections shall be performed every six months so that knowledge of the condition of ACM…