T02 DB SOW Attachment 3 Asbestos Management Plan 2021 07 27.pdf

ASBESTOS MANAGEMENT PROGRAM

OPERATIONS AND MAINTENANCE PLAN

FACILITY LOCATION:

Paul Rodgers Federal Building

701 Clematis Street West Palm Beach, Florida

GSA Building Number: FL0066AC

DATE: July 27, 2021

CONDUCTED FOR:

GENERAL SERVICES ADMINSTRATION

CONDUCTED BY:

FEDERAL OCCUPATIONAL HEALTH

TABLE OF CONTENTS

OBJECTIVE

1.0 INTRODUCTION

1.1 Purpose of the Plan

1.2 Scope of Plan

1.3 Limits of the O&M Plan

1.4 Applicability

1.5 Location and Availability of the Asbestos O&M Plan

1.6 References

2.0 OPERATION AND MAINTENANCE PLAN PROGRAM ELEMENTS

2.1 O&M Plan Objectives

3.0 DEFINITIONS

4.0 ADMINISTRATIVE RESPONSIBILITIES AND EXECUTION OF THE O&M PLAN

4.1 Administrative Responsibilities

4.2 Management Controls and procedures

4.3 Scope of Work - Building Maintenance and Repair

4.4 Restriction on Use of Maintenance Employees

5.0 GENERAL REQUIREMENTS

5.1 Notifications

5.2 Use of Asbestos Materials and Products (Restrictions)

5.3 Sampling and Analysis of Suspect ACBM

5.4 Environmental and Personal Air Monitoring for Airborne Asbestos Fibers

5.5 Disposal of Asbestos Waste and Materials

6.0 LOCATION AND AMOUNTS OF ASBESTOS MATERIALS

6.1 Observations

6.2 Soil Sampling

6.3 Bulk Debris Sampling

6.4 TEM Air Sampling

7.0 NOTIFICATION AND LABELING

7.1 Notification and Labeling

7.2 Awareness Training

7.3 Warning Signs and Labels

8.0 MAINTENANCE/RENOVATION PERMIT SYSTEM

9.0 WORK PRACTICES

9.1 Work Specifications (Outside Contractor for O&M)

9.4 Surveillance of Maintenance Activities

9.5 Initial Cleaning

9.6 Maintenance and Repair Activities

10.0 EMERGENCY ACTIVITIES (FIBER RELEASE EPISODES)

11.0 TRAINING

11.1 Maintenance Personnel - Worker Qualifications

12.0 PERSONAL PROTECTION AND MEDICAL SURVEILLANCE

12.1 Personal Protection Equipment

12.2 Medical surveillance

13.0 PERIODIC SURVEILLANCE

13.1 Inspection and Repair

14.0 RECORD KEEPING AND DOCUMENTATION

15.0 PERSONNEL AND APPROVED CONSULTANT FOR O&M ACTIVITIES

16.0 APPENDICES

ATTACHMENTS

ATTACHMENT 1.0.......................................................... ASBESTOS SOIL, AIR AND BULK SAMPLING REPORT ATTACHMENT 2.0.......................................................................................... CERTIFICATIONS ANS LICENSES ATTACHMENT 3.0.................................................................................................... ASBESTOS CONTACT LIST

OBJECTIVE

To define activities to be performed and methods to be employed in the management and control of asbestos containing building materials during initial clean-up, routine maintenance, permitted repairs, emergency situations, remodeling and renovation and demolition to minimize the release of asbestos fibers to the environment. This will include procedures for implementing area specific NESPHAP asbestos surveys in compliance with the Palm Beach County Health Department requirements.

The overall goal of the Asbestos Operations and Maintenance Plan (O&M Plan) is to maintain the complex environment free of asbestos contamination. The specific O&M Plan objectives are to: (1) remove asbestos fibers that may have been released from ACBM (Note: based on the June 2021 site visit and annual air monitoring, there is no existing airborne exposure issues.) and, (2) minimize future release and fiber disturbance by controlling activities that might disturb the asbestos-containing materials (ACBM).

The O&M Plan focuses on the activities of custodial and maintenance workers, service contractors, tenants and qualified asbestos abatement contractors. Special procedures for routine cleaning by accredited personnel are designed to achieve the first program objective (i.e. collecting previously released fibers). In order to achieve the second program objective (i.e. minimizing fiber release), special work practices are tailored to four types of activity (1) those which are unlikely to involve any contact with ACBM; and (2) those which may cause accidental disturbance of ACBM, (3) those which involve small scale or short duration manipulation or removal of ACBM and (4) those which involve large scale manipulation or removal of ACBM. Response actions for fiber release episodes are also specified in the O&M Plan.

1.0 INTRODUCTION

1.1 Purpose of the Plan

The Asbestos Operations and Maintenance (O&M) Plan has been developed to ensure Building employees, tenants and visitors are protected from asbestos expose through adherence to proper procedures for managing routine maintenance activities, emergency situations, remodeling and renovation projects involving ACBM. The O&M Plan has been prepared to comply with Federal and state regulatory requirements.

1.2 Scope of Plan

The Plan covers the ACBM in the complex as identified in Section 6.0. The scope of the Asbestos O&M Plan encompasses the following activities:

• Initial and periodic cleaning.

• Routine maintenance and repair activities.

• Emergency, small scale/short duration repair activities.

• Planned removal activities.

1.3 Limits of the O&M Plan

This Plan is limited to the proper handling and disposal of small amounts of asbestos containing materials usually in the amounts of 3 square feet or less and 3 linear feet or less.

Any amounts of ACBM disturbance or removal greater than 3 square feet and/or 3 linear feet shall be conducted by Florida Licensed Asbestos Abatement Contractor or an Asbestos Supervisor and Worker who has obtained and is working under the direction of a Florida Licensed Asbestos Abatement Contractor.

1.4 Applicability

Management controls and procedures outlined in the Asbestos O&M Plan are applicable to maintenance and/or repair work performed by trained personnel and/or qualified contractors.

1.5 Location and Availability of the Asbestos O&M Plan

The Asbestos O&M Plan is located in the property manager’s office and facility engineering office at The Complex and the Asbestos Management consultant's office.

1.6 References

OSHA Asbestos Standard - 29 CFR 1926.58. (Revised 29 CFR 1926.1101) OSHA Asbestos Standard - 29 CFR 1910.1001.

OSHA Respiratory Standard - 29 CFR 1910.131.

USEPA National Emission Standard for Asbestos (NESHAPS 40 CFR, SUBPART M, SECTION 61.125 to 61.156).

Florida Statute Local City, County and State regulations that apply.

2.0 OPERATION AND MAINTENANCE PLAN PROGRAM ELEMENTS

2.1 O&M Plan Objectives

To achieve the O&M Plan's objectives, the following elements are an integral part of the Plan:

• Plan administration, responsibilities and execution.

• General requirements

• Location and condition of asbestos materials.

• Notification and labeling procedures to warn occupants and contractors about ACBM.

• Initial cleaning and periodic cleaning.

• Maintenance/renovation permit system to provide control over potential disturbance of the

ACBM.

• Work practices for cleaning the complex and minimizing ACBM disturbance during maintenance and renovation.

• Procedures for cleaning up asbestos fibers after a fiber release episode.

• A training program for maintenance and service workers and requirements for outside contractors.

• Personal protection-Medical surveillance, respirators and protective clothing.

• Periodic surveillance of the ACBM.

• Record keeping.

Execution of the abatement work, when necessary, will be conducted by a Florida Licensed Asbestos Abatement firm licensed by the State to conduct work in the state. This firm will be used for emergency clean up involving fiber release episodes, initial cleaning and small scale, short duration projects involving

ACBM.

3.0 DEFINITIONS

"Asbestos Abatement Workers” means a person who has completed at least four days of training under an EPA accredited program and works under the direction of a State of Florida Asbestos Contractor. This four-day course should include hands on training and the individual must pass a final exam. One day of annual refresher training is required.

"Asbestos Abatement Supervisor" means a person who has completed at least five days of training under an EPA accredited program and works under the direction of a State of Florida Licensed Asbestos Abatement Contractor. This five-day course should include hands on training and the individual must pass a final exam. One day of annual refresher training is required.

"Asbestos Inspectors" means a person who has completed at least three days of training under an EPA licensed program and works under the direction of a State of Florida Asbestos Consultant. This three-day course shall include hands on training and individual must pass a final exam. One half day of annual refresher training is required.

"Asbestos Management Consultants" means an individual with experience and training in building inspection, hazard assessment, asbestos management planning and response actions who can provide expertise in the asbestos field. This person shall be a professional such as a Certified Industrial Hygienist, Professional Engineer or Architect and be licensed by the State of Florida.

"Asbestos" means the asbestos varieties of: Chrysotile (serpentine); Crocidolite (riebeckite); Amosite (cummingtonite-grunerite); and Actinolite.

"Asbestos-containing material" (ACM) means any material or product which contains more than 1 percent asbestos.

"Asbestos-containing building material" (ACBM) means surfacing ACBM, thermal system insulation ACM, or miscellaneous ACM that is found in or on interior structural members or other parts of Buildings.

"Asbestos debris" means pieces of ACBM that can be identified by color, texture, or composition, or means dust, if the dust is determined by a licensed inspector to be ACM.

"Complex" means the buildings located on the Paul Rodgers Federal Building in West Palm Beach, Florida.

"Certified Industrial Hygienist (CIH)" means an individual certified in the comprehensive practice of industrial hygiene by the American Board of Industrial Hygiene and is current with the Board for use of the designation C.I.H.

"Competent Person" means a person who has been trained at an approved USEPA Asbestos Abatement Supervision course and meets the requirements provided in 29 CFR 1926.58 (e)(6)(Revised 20 CFR 1926.1101).

"Contractor" means a person or entity licensed to perform asbestos abatement work in the State of Florida.

"Emergency Maintenance" means corrective action that is essential to enable continued facility operations in an environmentally safe manner. If the emergency maintenance were not performed, then partial or complete shutdown of operations would be required to ensure protection of staff and public from potential health hazards.

"Facility Manager" means the individual representing The Complex who is charged with the day to day management of the complex and its operation.

"Friable Material" means any material applied onto ceilings, walls, structural members, piping, ductwork or any other part of the complex structure which, when dry, may be crumbled, pulverized or reduced to powder by hand pressure.

"Asbestos Awareness Class" means person who has received information and training on asbestos uses and forms, damage recognition, uses of asbestos, health effects, proper work practices, and proper disposal.

"Renovation, Remodeling or Modification" means any operation on which employees or contractors are engaged in the alteration of complex structure or relocation of equipment (including new equipment installation) in which asbestos materials are involved. The removal or demolition of pipes, structures or equipment covered (i.e. spray applied materials) or insulated with asbestos, fall into the category of plant renovation or modification. This work is to be performed by a licensed contractor with specifications developed by a consultant.

"Maintenance and Renovation Work" is a descriptive phrase indicating work that is (a) essential for the continued safe and efficient operation of the complex's equipment in which less than 160 linear feet or 260 square feet of asbestos-containing materials are involved.

Maintenance, staff and outside contractors will be notified of the location, type and condition of asbestos in the complex. Outside contractors need only to know of ACBM located in their immediate work area. If ACBM is going to be disturbed, then all necessary precautions to minimize ACBM disturbance and/or prevent fiber release to the environment, must be taken.

4.0 ADMINISTRATIVE RESPONSIBILITIES AND EXECUTION OF THE O&M PLAN

4.1 Administrative Responsibilities

The responsibility for the implementation of the Asbestos O&M Plan is with the Building Owner or his designated representative.

The Facility Manager is responsible for:

• Informing complex occupants and outside contractors of the location of ACBM and potential hazard of manipulating or removing ACBM. The Asbestos Management Consultant will assist in providing technical and other information concerning asbestos management.

• Ensuring that Building personnel fully understand their responsibilities related to implementation of the Asbestos O&M Plan.

• Notifying the Asbestos Consultant immediately of impending, planned disturbance of ACBM or accidental disturbances of ACM.

• Notifying the Asbestos Management Consultant immediately of any changes to the condition of the ACBM.

• Informing contractors and others who may disturb the ACBM as to the location and condition of the ACBM.

• Issuing a work permit for outside contractors to start work in areas where ACBM may be disturbed. A work permit form is in the Appendix.

• Authorizing the use of a qualified contractor to perform emergency maintenance and repair work involving ACBM. The building's owner's consultant may be used for suggesting the names of qualified contractors or reviewing the credentials of a qualified contractor.

The Asbestos Management Consultant is responsible for:

• Periodically surveying materials and operations to ensure adherence to the Asbestos O&M Plan and resolving potential management and/or technical issues before they have an opportunity to adversely affect operations.

• Updating and revising the O&M Plan.

• Ensuring that ACBM not be used in building materials when such materials are to be replaced in the building.

• Interpreting new regulations as they pertain to O&M Plans.

• Ensuring that all Federal, State and local regulations are complied with before, during and after any planned removal or accidental fiber release episodes.

• Overseeing the air monitoring and comparing the laboratory results within the Buildings at the complex to ensure that the potential for asbestos fiber release is below the EPA recommended threshold of 0.01 f/cc.

4.2 Management Controls and procedures

Management controls and procedures are designed to prevent unnecessary exposure of complex occupants and contractor personnel to airborne concentrations of asbestos fibers, to protect the environment from improper handling and disposal of asbestos waste, and to ensure compliance with regulatory requirements.

4.3 Scope of Work - Building Maintenance and Repair

The scope of maintenance and repair activities involving asbestos materials includes the following:

• Initial and periodic cleaning of areas containing friable ACBM.

• Decontamination of an area after a fiber release episode.

• Repair or replacement of damaged asbestos floor tiles and sinks.

• Repair or replacement of damaged popcorn ceiling material, textured plaster, and/or drywall partitions and ceilings.

4.4 Restriction on Use of Maintenance Employees

Only maintenance personnel with Operations & Maintenance training and medical examination as per 29 CFR 1926.58 (Revised 29 CFR 1926.1101) or Florida Licensed Asbestos Abatement Contractor, are permitted to perform work involving asbestos-containing materials involving small scale/short duration activities.

5.0 GENERAL REQUIREMENTS

5.1 Notifications

Federal and state regulations require written notification of intent to renovate or modify Building or equipment involving asbestos containing materials. Federal regulations governing asbestos are in the EPA National Standard for Asbestos and require notification at either ten (10) days or twenty (20) days before renovation or modification, work begins depending on the amount of material removed.

The Complex is in the regulatory enforcement area of the Palm Beach County Health Department (Roberto.Armas@flhealth.gov).

The qualified asbestos abatement Contractor shall be responsible for providing written notification to regulatory authorities and obtaining all necessary permits for work involving asbestos materials before commencement any asbestos abatement. All notifications must be reviewed by the Florida Licensed Asbestos Management Consultant before a notice to proceed is issued. It is the responsibility of the Asbestos Management consultant to ensure that the contractor obtains all of the required permits before work commences.

5.2 Use of Asbestos Materials and Products (Restrictions)

The purchase and use of asbestos-containing materials as replacement parts for existing equipment are prohibited except where substitute materials are not available or economically not feasible. Similarly, the use of asbestos-containing material is prohibited in Building renovation and modification work.

During facility maintenance and renovation work involving asbestos-containing materials that are removed from the building structure or equipment shall not be reinstalled but disposed of in accordance with applicable regulatory requirements.

5.3 Sampling and Analysis of Suspect ACBM

Sampling of materials suspected of containing asbestos shall only be performed by a Florida licensed Asbestos consulting business.

Analysis of bulk materials suspected of containing asbestos shall only be done by an Asbestos NVLAP-accredited laboratory.

5.4 Environmental and Personal Air Monitoring for Airborne Asbestos Fibers

Environmental monitoring of airborne concentrations of asbestos fibers following a response action or general air monitoring shall be done in accordance with NIOSH Method 7400. Building personnel involved with asbestos should be monitored periodically to ensure compliance with OSHA regulations. The Licensed Asbestos Abatement Contractor shall monitor his employees any time asbestos fibers are released to the work environment and there is a risk of employee/personnel exposure. Personnel monitoring shall be in accordance with 29 CFR 1926.58 (Revised 29 CFR 1926.1101) to include Appendices A and B.

All airborne asbestos monitoring shall be done under the direction of a licensed asbestos consulting business. Affected employees or their representative shall be given a reasonable opportunity to observe any environmental and personal monitoring.

Records of environmental and personal monitoring shall be retained for a period of at least 30 years.

Fiber levels inside the building shall not exceed 0.01 f/cc as determined by either phase contrast microscopy or (0.01 f/cc) by transmission electron microscopy for asbestos structures.

5.5 Disposal of Asbestos Waste and Materials

Asbestos waste, scrap, debris, bags, containers, equipment and asbestos contaminated clothing shall be collected or disposed of in sealed, impermeable containers. During maintenance or repair activities, or Building renovations or modification work, asbestos waste shall be closely monitored and controlled, stored in acceptable temporary storage areas, protected, and labeled to ensure asbestos fibers are not inadvertently released into the environment or improperly disposed of.

No asbestos waste shall be disposed of without completing a shipping manifest and other required documentation.

Maintain a record or log where the final disposal of ACBM waste is located. A chain of custody form shall be used to keep track of all ACBM removed from the complex.

6.0 LOCATION AND AMOUNTS OF ASBESTOS MATERIALS

6.1 Observations

The following observations from the site reconnaissance conducted on March 29, 2021, detail the condition at the time of the first visit to the site:

• There were nine entrances into the building; two main entrances, two entrances from the garage, one service entrance, three emergency exits and the marshal’s elevator.

• The fresh air intake is located on the roof.

• There was quartz debris observed on the exterior mezzanine around the building. The quartz is delaminating off the building.

• There was ongoing road construction on the north and east of the building.

• The building is currently occupied by 89-100 people during the day.

• The building was slightly negatively pressurized.

At the time of the second inspection, the following observations were noted:

• The debris on the exterior mezzanine around the building was still present. The debris is due to the siding material of the building delaminating and falling onto the surface below.

• The road construction north and east of the building is still ongoing.

• No excessive dust was observed on horizontal surfaces in the interior areas of the building where TEM air sampling was conducted.

• Delaminated pieces of debris were observed scattered in the surface layer of the soil in the area around the dripline of the mezzanine.

6.2 Soil Sampling

On June 17, 2021, soil samples were collected at two depths: surface depth and six-inch depth. Samples were collected at the drip edge of the mezzanine, and at 25 feet away from the building, every 50 feet, where possible. Some locations were amended at the time of the inspection to work around obstructions.

For sampling locations please refer to the soil sample location diagram in Attachment A.

A total of 64 soil samples from 32 locations around the building were collected and submitted under chain of custody protocol to EMSL Analytical, Inc. (EMSL) of Cinnaminson, New Jersey. EMSL is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for bulk asbestos fiber analysis which is administered by the National Institute of Standards and Testing (NIST). The soil samples were analyzed using polarized light microscopy (PLM - Qualitative) with dispersion staining via EPA's "Method for the Determination of Asbestos in Bulk Building Materials" (EPA/600/R-93/116) with Milling Prep Level A (400 Point Count, reporting limit to <0.25%).

6.3 Bulk Debris Sampling

Bulk debris samples were collected from the mezzanine level around the building on June 17, 2021. A total of twelve (12) bulk debris samples were collected and submitted under chain of custody protocol to EMSL Analytical, Inc. (EMSL) of Cinnaminson, New Jersey. EMSL is accredited by the National Voluntary

Laboratory Accreditation Program (NVLAP) for bulk asbestos fiber analysis which is administered by the National Institute of Standards and Testing (NIST). The bulk debris samples were analyzed using polarized light microscopy (PLM - Qualitative) with dispersion staining via EPA's "Method for the Determination of Asbestos in Bulk Building Materials" (EPA/600/R-93/116).

6.4 TEM Air Sampling

On June 17, 2021, 10 TEM air samples with 3 blanks were collected. The samples were submitted under chain of custody protocol to EMSL Analytical, Inc. (EMSL) of Cinnaminson, New Jersey. EMSL is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for bulk asbestos fiber analysis which is administered by the National Institute of Standards and Testing (NIST). The air samples were analyzed using Transmission Electron Microscopy (TEM) and the EPA 40 CFR Part 763, Appendix A to Subpart E.

The present O&M Program is specifically prepared to cover such contingencies, and the requirements and documentation specified in this O&M Program must be followed in all future activities involving ACMs in this building. This includes conducting area specific NESPHAP asbestos surveys in compliance with the Palm Beach County Health Department requirements prior to planned renovation/demolition activities. A l s o , w h e n future abatement activities are performed on-site, documentation and records of such activities should be maintained in the attachment section of this manual.

7.0 NOTIFICATION AND LABELING

7.1 Notification and Labeling

The facility manager shall inform building occupants and outside contractors who may come into contact with the ACBM the location of ACBM and need for not disturbing the material. Information can be provided in any one or combination of the following:

• Written notices. These can be prepared by a consultant if necessary.

• Posting of signs.

• Awareness information sessions.

The building owner is obligated to conform with any community "right-to-know" regulations. Information provided should contain the following:

• Health hazards associated with inhalation of asbestos.

• Types and location of building materials that contain asbestos.

• Condition of the materials.

• Need for not disturbing the material.

• Reporting evidence of material disturbance.

• Special precautions to prevent the disturbance of the asbestos.

• Inspection of the complex periodically for evidence of damage.

• Long range management plans.

• Air monitoring results (specifically annual TEM monitoring results)

7.2 Awareness Training

Awareness training should be approximately four hours.

7.3 Warning Signs and Labels

The purpose of warning signs and labels are to:

• Alert affected parties to potential hazard.

• Provide basic information on avoiding the hazard.

Warning signs and labels shall be provided and displayed at each location where airborne concentrations of asbestos fibers may be in excess of the specified limits prescribed by law (0.0l f/cc) or where asbestos removal activities are in progress. Posting of signs and sign specifications (sign, legend, and layout) shall comply with OSHA Asbestos Standard (29 CFR 1926.58) (Revised 29 CFR 1926.1101).

Warning labels shall be affixed to all raw materials, scrap, waste, debris, and other materials containing asbestos fiber, or to their containers. Label specifications shall comply with USEPA, NESHAPS, and OSHA Asbestos Standards.

8.0 MAINTENANCE/RENOVATION PERMIT SYSTEM

Objective: To minimize the inadvertent disruption of ACBM during maintenance and renovation activities.

All work orders or work requests shall be transmitted to the Asbestos Management Consultant or his designee to determine if ACBM will be disturbed or has the potential of disturbance. An inspection of the area may be required to determine if the conditions of the material has changed since the last inspection.

If ACBM will be disturbed by actions taken in the work order/request, then a permit must be issued in order for the work to proceed. A determination should be made of the estimated amount of disturbance in order to execute the proper response. Responses could involve in house maintenance personnel for small amounts or a qualified contractor for large amounts.

All permits shall be signed and kept as part of the records for the facility.

9.0 WORK PRACTICES

Maintenance and repair activities involving asbestos are to be performed when the complex or area in which the work is being done is unoccupied. The ventilation system shall be off during any procedures that will require the removal of ACBM.

9.1 Work Specifications (Outside Contractor for O&M)

When qualified contractors are used for routine maintenance or repair work involving asbestos materials, work procedures contained in this plan shall be used.

When the Complex maintenance personnel are to be used for O&M repair or minor removal, they shall have been trained on proper work practices, respirator use personal protection, barricades, disposal and be incorporated into a medical surveillance program.

9.4 Surveillance of Maintenance Activities

Surveillance of all maintenance and repair activities involving asbestos materials shall be accomplished and documented whether the work is routine or extensive. The following guidelines shall apply:

• Observation of work practices at the work site shall be maintained throughout the project.

• The Asbestos Management Consultant or his Management Planner shall be responsible for the surveillance of work activities of qualified contractors or in-house O&M personnel.

• The Asbestos Management Consultant or his Management Planner shall stop all maintenance and repair activities whenever conditions dictate that the fiber release would cause air fiber levels to exceed 0.01 f/cc (PCM or TEM) or if good work practices are deficient.

• Surveillance of work practices shall be documented, using an Asbestos Abatement check list.

9.5 Initial Cleaning

All areas with friable ACBM shall be cleaned by properly trained O&M personnel using a HEPA vacuum or wet methods. The areas to be decontaminated are carpets, floors, furniture and horizontal surfaces where asbestos debris may have accumulated. Employees shall wear respirators and protective clothing while performing the initial cleaning. All debris, filters, mop heads, and clothes are to be disposed of by sealing in leak proof containers that are properly labeled. Areas will be cleaned as part of an ongoing asbestos removal project.

9.6 Maintenance and Repair Activities

Area Preparation and Personnel Protection Requirements:

• Persons performing maintenance activities in the area shall wear respirators and protective clothing.

• Work area is to be isolated/barricaded by signs, barricade tape and locking doors, where feasible, entering work area.

• OSHA warning signs, per 29 CFR 1926.58 (Revised 29 CFR 1926.1101), are to be prominently displayed on all approaches to the work area, to prevent entry by unprotected individuals. All immovable objects, i.e. furniture, etc., are to be removed from the work area.

• Follow procedures contained in Appendix G of 1926.58 (Revised 29 CFR 1926.1101).

• Bag the ACBM by carefully placing it in a labeled asbestos disposal bag and adding amended water. After placing all cleanup and covering materials, i.e. rags, mop heads, poly, etc., into bag, vacuum out all excess air with HEPA vacuum and seal tip of bag with a HEPA vacuum. Place double bagged material in a labeled container for transportation to the landfill.

• Contact the landfill and arrange for disposal of the asbestos.

• Maintain copies of disposal forms.

• Maintain copies of air sampling data and observations during maintenance work. Log in the project date, time, personnel, and respirator protective devices utilized.

10.0 EMERGENCY ACTIVITIES (FIBER RELEASE EPISODES)

Maintenance personnel shall follow these procedures for the following fiber release episodes:

• Minor Fiber Release - Dislodging of less than 3 square feet or 3 linear feet of friable ACBM:

o Immediately notify the Asbestos Management Consultant and barricade the area/room or hallway to prevent access until the material can be cleaned up and the area decontaminated.

o Thoroughly saturate the debris using wet methods and then clean the area using a HEPA vacuum and wet wipe any surfaces that were contaminated.

o Place debris in leak tight and labeled containers and dispose as per Section 55.

o Repair the area of damaged ACBM with materials such as asbestos free spackling, plastic, cement or seal with latex paint or encapsulant or implement an appropriate response action.

• Major Fiber Release - Dislodging of 3 or more square feet or 3 linear feet of friable ACBM:

o Immediately notify the Asbestos Management Consultant and barricade the area/room or hallway to prevent access until the material can be cleaned up and the area decontaminated.

o Immediately shutdown air handling system (HVAC) supplying the contaminated area where the fiber release has occurred.

o Use the trained personnel or Florida Licensed Asbestos Abatement/Supervisor to cleanup debris and decontaminate the area. Minor encapsulation may be required to prevent further fiber release. If a major problem exists with more than 3 SF or 3 linear ft., contract with a licensed abatement contractor to remedy the situation.

11.0 TRAINING

11.1 Maintenance Personnel - Worker Qualifications

All maintenance staff shall receive a Training Awareness to include the following information: asbestos uses and forms, health effects, location of ACBM and recognition of damage, deterioration and/or delamination, and the name and address of the Asbestos Management Consultant and the availability and location of the O&M Plan.

The individual who is appointed to oversee abatement will need to take a 5 day "Asbestos Supervisor's Course" in order to have the proper training to handle emergency maintenance activities involving ACBM within the buildings on-site.

Employees designated for emergency maintenance involving asbestos shall be qualified for asbestos work by taking a 16 hour "Asbestos Maintenance Course" before performing any task involving ACBM.

Training in asbestos hazards, control procedures and work practices, respiratory protection and hands on training O&M training.

Properly trained in the use of and fitted with respiratory protection, and capable of working extended periods while wearing respiratory protection.

Determined as medically qualified for such work by a physician.

12.0 PERSONAL PROTECTION AND MEDICAL SURVEILLANCE

12.1 Personal Protection Equipment

The following personal protective equipment shall be provided, and their use required and enforced for any employee or worker exposed to airborne concentration or asbestos fibers:

Respiratory Protection (establishes a respiratory program in accordance with OSHA Asbestos Standard (29 CFR 1926.58) (Revised 29 CFR 1926.1101) and the OSHA Respirator Standard (29 CFR 1910.134).

Minimum acceptable respirators for O&M procedures is a permanent half face air purifying type respirator with high efficiency particulate cartridges (identified by the magenta or red color of the cartridges). It if recommended that Powered Air Purifying Respirators (PAPR) of the full face or hood type equipped with high efficiency particulate cartridges be used to afford the highest reasonable protection.

Special Clothing (includes clothing such as coveralls or whole-body clothing, head coverings, gloves, and foot coverings).

12.2 Medical surveillance

All personnel who will wear a respirator and be exposed to asbestos fibers during routine or repair work involving ACBM shall have received a medical examination. Periodic examinations shall be performed by licensed physicians to follow the maintenance worker's health status. A medical questionnaire is mandatory and physical examination of the cardiovascular and pulmonary systems shall be performed by a licensed physician. Pulmonary function testing should include forced vital capacity (FVC) and forced expiratory volume in one second (FEV).

For compliance purposes, 29 CFR 1926.58 (Revised 29 CFR 1926.1101) shall be used for exposures in excess of the 0.1 f/cc (OSHA Action Level).

13.0 PERIODIC SURVEILLANCE

13.1 Inspection and Repair

Asbestos Management Consultant or his Management Planner shall review the location and condition of all identified asbestos-containing materials in the complex. Any damage noticed shall be reported immediately. Periodic inspection of friable materials shall be conducted every six months and non-friable annually. Repair work should be undertaken as soon as possible. This work shall only be performed by individuals who have received O&M training for asbestos work or by a qualified contractor.

Surveillance shall be conducted to assess the continued integrity of asbestos containing materials in the complex, at least every three months for friable and every six months for non friable. This will involve visiting all areas of the complex where such materials are located and removing obstructions to vision, if necessary. A corrective action report is to be submitted and kept as part of the record keeping process.

A periodic surveillance form is included in the Appendix.

Repairs of defective or damaged asbestos containing material in which asbestos is exposed, shall be performed according to the procedures defined in Section 8. Surveillance is to be performed by the Building Owner's Consultant. Written notes of the surveillance are to be taken and maintained with the signature of the person conducting the survey. This surveillance shall be conducted by a Florida Licensed Asbestos Inspector who has participated in a three-day training program licensed by the EPA and completed under the direction of a Florida licensed Asbestos Consultant.

14.0 RECORD KEEPING AND DOCUMENTATION

Comprehensive records shall be maintained of all maintenance and repair activities and renovation or modification work involving asbestos materials. Records shall be retained for a period of at least 30 years.

The following records shall be maintained by the Asbestos Management Consultant and kept on file at a convenient location:

• Fiber release episodes

• Response actions to fiber releases

• Air monitoring

• Medical Surveillance

• Periodic inspections

• Training data: attendees and trainer

• Disposal site for removal of ACBM

• Maintenance activities involving ACBM

Documentation

• Environmental and Personnel Monitoring Exposure Records

• Asbestos Abatement Plan Specification

• Asbestos Operation and Maintenance Plan

• Emergency Maintenance and Repairs Involving Asbestos Materials

• Shipping Manifest - Asbestos Waste

• Bid Specifications on Asbestos Removal Projects Conducted by a Licensed Asbestos Abatement Contractor.

• Results of periodic surveillance, reinspection and responses to fiber release episodes.

15.0 PERSONNEL AND APPROVED CONSULTANT FOR O&M ACTIVITIES

NAME/TITLE TELEPHONE NO.

J. Michael Bradshaw, PE 813-295-3595 EA No. 0000066

EFI Global See Individuals Below Florida Asbestos Business License No. ZA0000364

Matthew Berry, Florida Asbestos Inspector 407-793-1303 No. 190412-7504

Christina M. Haworth, Florida Asbestos Inspector 202-768-1886 No. 220085-1398

Diversified Management & Construction, Inc.

Asbestos Business License #ZA0000231

16.0 APPENDICES

• Work Permit and NESHAP Asbestos Survey Request Form

• Periodic Reinspection Form

• Fiber Release Episode Form

• ACBM Damage Report Form

• Request for Area-Specific NESHAP Asbestos Survey Prior to Renovation/Demolition

Sincerely, Reviewed by, Christina M. Haworth J. Michael Bradshaw, PE Project Manager Senior Engineer Florida Asbestos Inspector Florida Asbestos Consultant No. 190412-7515 No. EA0000066 Florida Asbestos Business License

ZA364

WORK PERMIT AND NESHAP ASBESTOS SURVEY REQUEST FORM

DATE:

LOCATION OF AREA WHERE RENOVATION/DEMOLITION TO BE PERFORMED:

ASBESTOS CONSULTING TESTING COMPANY NAME AND ADDRESS:

ACBM IDENTIFIED IN THE SPECIFIC AREA- OVER 3 SF OR 3 L.F.? IF YES, NEED SPECIALLY TRAINED

PERSONNEL (ASBESTOS ABATEMENT CONTRACTOR)

ASBESTOS ABATEMENT CONTRACTOR NAME (IF NECESSARY):

GENERAL CONTRACTOR NAME OR FACILITY PERSONNEL NAME:

APPROVAL TO PROCEED: TITLE: ....................... DATE:

PERIODIC INSPECTION FORM

DATE: INSPECTOR:

HOMOGENEOUS AREA COMMON COMMENTS

SIGNED: DATE:

COMMENTS:

FIBER RELEASE EPISODE FORM

DATE AND TIME OF NOTIFICATION:

LOCATION:

AMOUNT:

UNDER 3 SF OR 3 L.F.:

NOTIFY ASBESTOS PROGRAM MANAGER DATE/TIME

BARRICADED AREA DATE/TIME

NOTIFIED O&M PERSONNEL DATE/TIME

NOTIFIED CONTRACTOR DATE/TIME

AREA DECONTAMINATED DATE/TIME

WASTE DISPOSED DATE/TIME

AREA REOCCUPIED DATE/TIME

IF OVER 3 SF OR 3 L.F.:

NOTIFY ASBESTOS PROGRAM MANAGER DATE/TIME

BARRICADEDAREA DATE/TIME

TURNED OFF HVAC DATE/TIME

RESPONSE ACTION DATE/TIME

RESPONSE ACTION COMPLETED DATE/TIME

AREA REOCCUPIED DATE/TIME

SIGNED: TITLE: DATE:

ACBM DAMAGE REPORT FORM

TO: FACILITIES MANAGER

DATE:

LOCATION:

TYPE OF DAMAGE:

FOLLOW-UP ACTION:

SIGNED: DATE:

ATTACHMENTS

ATTACHMENT 1.0

ASBESTOS SOIL, AIR AND BULK SAMPLING REPORT

Asbestos Soil, Air, and Bulk Sampling

Completed for General Services Administration

Survey location:

701 Clematis Street

GSA Building Number: FL0066AC

Survey Date: June 17, 2021 Report Date: July 21, 2021

1.0 INTRODUCTION

On June 17, 2021, Mr. Matthew Berry (Certification No. 210370-8386), Ms. Christina Haworth (Certification No. 220085-1395), Mr. Jesus Cardenas (Certification No. HLZ7VCYV3EZGE), and Mr. Errol Gard (Certification nos. RTS1608658919618 and RTS10162020SR-04) representing the Program Support Center/Federal Occupational Health (PSC/FOH), working under Florida-Licensed Asbestos Business No.:

ZA0000364 performed soil, air, and bulk asbestos sampling at the Paul Rodgers Federal Building (GSA Building No.: FL0066AC), located at 701 Clematis Street in West Palm Beach, Florida (Site). This work was conducted under the Interagency Agreement between the FOH Program and the General Services Administration (GSA) Region 4. This survey was conducted in response to asbestos paneling on the exterior of the Paul Rodgers Federal Building that has been deteriorating for an extended period of time.

GSA requested an asbestos impact study to include soil sampling and determine the impact to the soil and air supply to the building.

As requested by the GSA, the FOH inspection team followed a sampling protocol pursuant to results from a site investigation performed on March 29, 2021. The purpose of sampling was to determine the impact to the soil around the building, as well as impact to the indoor air quality of the building in order to support the development of a Building Operations and Maintenance Program (OMP).

2.0 OBSERVATIONS

The following observations from the site reconnaissance conducted on March 29, 2021, detail the condition at the time of EFI’s first visit to the site:

• There were nine entrances into the building; two main entrances, two entrances from the garage, one service entrance, three emergency exits and the marshal’s elevator.

• The fresh air intake is located on the roof.

• There was quartz debris observed on the exterior mezzanine around the building. The quartz is delaminating off the building.

• There was ongoing road construction on the north and east of the building.

• The building is currently occupied by 89-100 people during the day.

• The building was slightly negatively pressurized.

At the time of EFI’s second inspection, the following observations were noted:

• The debris on the exterior mezzanine around the building was still present. The debris is due to the siding material of the building delaminating and falling onto the surface below.

• The road construction north and east of the building is still ongoing.

• No excessive dust was observed on horizontal surfaces in the interior areas of the building where TEM air sampling was conducted.

• Delaminated pieces of debris were observed scattered in the surface layer of the soil in the area around the dripline of the mezzanine.

3.0 SURVEY PROCEDURES

The survey and sampling were conducted in accordance with Florida Department of Environmental Protection (DEP) asbestos regulations and complied with other federal standards and regulations, including those of the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA).

3.1 SOIL SAMPLING

On June 17, 2021, EFI collected soil samples at two depths: surface depth and six-inch depth. Samples were collected at the drip edge of the mezzanine, and at 25 feet away from the building, every 50 feet, where possible. Some locations were amended at the time of the inspection to work around obstructions.

For sampling locations please refer to the soil sample location diagram in Attachment A.

A total of 64 soil samples from 32 locations around the building were collected and submitted under chain of custody protocol to EMSL Analytical, Inc. (EMSL) of Cinnaminson, New Jersey. EMSL is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for bulk asbestos fiber analysis which is administered by the National Institute of Standards and Testing (NIST). The soil samples were analyzed using polarized light microscopy (PLM - Qualitative) with dispersion staining via EPA's "Method for the Determination of Asbestos in Bulk Building Materials" (EPA/600/R-93/116) with Milling Prep Level A (400 Point Count, reporting limit to <0.25%).

3.2 BULK DEBRIS SAMPLING

EFI collected bulk debris samples from the mezzanine level around the building on June 17, 2021. A total of 12 bulk debris samples were collected and submitted under chain of custody protocol to EMSL Analytical, Inc. (EMSL) of Cinnaminson, New Jersey. EMSL is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for bulk asbestos fiber analysis which is administered by the National Institute of Standards and Testing (NIST). The bulk debris samples were analyzed using polarized light microscopy (PLM - Qualitative) with dispersion staining via EPA's "Method for the Determination of Asbestos in Bulk Building Materials" (EPA/600/R-93/116).

3.3 TEM AIR SAMPLING

On June 17, 2021, EFI collected 10 TEM air samples with 3 blanks. The samples were submitted under chain of custody protocol to EMSL Analytical, Inc. (EMSL) of Cinnaminson, New Jersey. EMSL is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for bulk asbestos fiber analysis which is administered by the National Institute of Standards and Testing (NIST). The air samples were analyzed using Transmission Electron Microscopy (TEM) and the EPA 40 CFR Part 763, Appendix A to Subpart E.

4.0 ANALYTICAL SAMPLE RESULTS

All samples were submitted to EMSL of Cinnaminson, New Jersey for their appropriate analyses as detailed in Section 3.0, Survey Procedures. The analytical results for the three different material types sampled are explained below.

4.1 SOIL RESULTS

Of the 64 samples collected, 13 were positive for asbestos. Those sample locations were consistently against the building, at the mezzanine dripline. Those samples were also consistently positive for asbestos at surface and six-inch depth, with the exception of sample location 15, in which only the six- inch depth sample was positive for asbestos. Based on the consistency in the results and conditions observed at the site, EFI opines that the asbestos present in the soil is a direct result of delaminating asbestos-containing cladding material falling off into the soil. For soil sample laboratory results, please refer to Attachment B.

4.2 BULK DEBRIS RESULTS

All 12 bulk debris samples collected came back positive for asbestos. As the samples were collected from the ground of the mezzanine level, the source of the debris is the asbestos-containing cladding of the building. For the bulk debris sample laboratory results, please refer to Attachment C.

4.3 TEM AIR RESULTS

All 10 air samples submitted for TEM analysis showed no asbestos structures detected. While the exterior of the building is delaminating, it has not yet begun to affect the indoor air quality of the building. This does not mean that action should not be taken to abate the asbestos hazard on the exterior; conditions that exist today will not remain unchanged indefinitely. For the TEM air sampling laboratory results, please refer to Attachment D.

DISCUSSION AND RECOMMENDATIONS

Upon review of current site conditions and laboratory results by Mr. J. Michael Bradshaw P. E. (Florida Asbestos Consultant No.: EA0000066) the following recommendations are made:

1. Asbestos remains present on the exterior of the building. Until abatement action is taken, cleaning of delaminated cladding material on the mezzanine should be conducted by a Florida-licensed asbestos abatement contractor as soon as feasible. Additionally, the Florida-licensed asbestos abatement contractor should conduct a periodic cleaning of the debris on the mezzanine and adjacent areas quarterly or as needed based on site conditions.

2. Due to the soils against the building containing consistent levels of asbestos, the soils should be remediated at the time the building is abated, six feet out around the building to a depth of six inches. To prevent disturbance of the debris in the soil, prior to any digging or trenching in the adjacent area an OMP work permit should be completed.

3. TEM air sampling indicates that the indoor air quality of the building remains unaffected by asbestos contamination.

4. Finally, until the exterior stucco can be abated, it is recommended that the OMP for the exterior of the building is followed, which includes cleaning protocols as well as schedules and techniques to prevent disturbances.

SUPPORTING DOCUMENTS

The following supporting documents are attached to the report:

• Attachment A – Soil Sampling Diagram

• Attachment B – Laboratory Analytical Results: Soil

• Attachment C – Laboratory Analytical Results: Bulk Debris

• Attachment D – Laboratory Analytical Results: Air

Sincerely, Reviewed by, Christina M. Haworth J. Michael Bradshaw, PE

Project Manager Senior Engineer

Florida Asbestos Inspector Florida Asbestos Consultant

No. 220085-1395 No. EA0000066

Florida Asbestos Business License

ZA364

ATTACHMENT A

SOIL SAMPLING DIAGRAM

Esri Community Maps Contributors, FDEP, Esri, HERE, Garmin, SafeGraph, INCREMENT P, METI/NASA, USGS, EPA, NPS, US Census Bureau, USDA

Paul G Rogers FB

Locations of soil samples collected at the Paul Rogers Federal Courthouse Building. Red indicates asbestos-containing samples at surface depth and 6" depth. Orange indicates asbestos-containing samples at 6" depth. Black indicates no asbestos detected.

100ft

ATTACHMENT B

LABORATORY ANALYTICAL REPORT: SOIL

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

Phone/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

EMSL Order: 042114798

Customer ID: EAFI66A

Customer PO:

Project ID:

Attention: Program Support Center Phone: (978) 688-3736

USPHS/Federal Occupational Health Fax:

JFK Federal Building, Government Center Received: 06/18/2021 9:20 AM

Room E-110 Analysis Date: 06/23/2021 - 06/25/2021

Boston, MA 02203 Collected: 06/17/2021

Project: 020.01543 / Paul G Rogers CH / 701 Clemantis St., West Palm Beach, FL 33401

Test Report: Asbestos Analysis of Soils via EPA 600/R-93/116 Method using PLM and

Milling Prep. Quantitation using 400 Point Count Procedure

Sample Description Appearance % Fibrous % Non-Fibrous % Type

Non-Asbestos Asbestos

Brown

Non-Fibrous

Homogeneous

N Side - 50 ft W of NE

Corner - 18 ft N of

Building

01-0

042114798-0001

None DetectedNon-fibrous (Other)100.0%

Brown

Non-Fibrous

Homogeneous

N Side - 50 ft W of NE

Corner - 18 ft N of

Building

01-6

042114798-0002

None DetectedNon-fibrous (Other)100.0%

Brown

Non-Fibrous

Homogeneous

N Side - 50 ft W of NE

Corner - At Building

02-0

042114798-0003

None DetectedNon-fibrous (Other)100.0%

Brown

Non-Fibrous

Homogeneous

N Side - 50 ft W of NE

Corne…