Asbestos Report.pdf

REPORT OF ASBESTOS CONTAINING MATERIALS

SURVEY AND MANAGEMENT PLAN

BARRACKS BUILDING

BUILDING 650

SACRAMENTO, CALIFORNIA

Survey also includes a limited PCB Label Inspection of transformers

PREPARED FOR:

63D Regional Support Command

AFRC-CCA-ENV

4235 Yorktown Ave., Bldg. 7 Los Alamitos, California 90720-5002

PREPARED BY:

ITI OF SOUTH FLORIDA, INC.

100 2nd Ave. South, Suite 200-S

St. Petersburg, FL 33701 727 898 0802 727 581 0764 (fax) itisf@aol.com

ADECCO / TAD TASK ORDER DA7-000001559

Gil Bakshi Certified Asbestos Consultant #99-2650 20 February 2001

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TABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY

2.0 BACKGROUND INFORMATION

3.0 DESCRIPTION OF FACILITIES

4.0 PREVIOUS INSPECTIONS

5.0 SAMPLING AND ANALYTICAL PROCEDURES

6.0 ASSESSMENT METHODOLOGY

7.0 RESPONSE ACTIONS

8.0 ASBESTOS CONTAINING MATERIALS

9.0 SUSPECT ASBESTOS CONTAINING MATERIALS

10.0 NON ASBESTOS CONTAINING MATERIALS

11.0 PREVIOUS ABATEMENT RECORDS

12.0 BULK SAMPLE ANALYSIS SUMMARY

13.0 PCB LABELS ON TRANSFORMERS

14.0 CONCLUSIONS AND RECOMMENDATIONS

15.0 COST ESTIMATION

APPENDICES

APPENDIX A PLM LABORATORY RESULTS (BULK SAMPLES)

APPENDIX B DETAILS AND DESCRIPTIONS FOR POTENTIAL FOR DAMAGE

APPENDIX C DETAILS FOR CLASSIFICATION SCHEME FLOW CHART

APPENDIX D DETAILS ON RESPONSE ACTION SCHEME BASED ON HAZARD RANK

APPENDIX E HAZARD RANKING ASSESSMENT FORMS / LOCATION OF SAMPLES

APPENDIX F ASBESTOS BUILDING INSPECTOR CERTIFICATION

APPENDIX G LABORATORY CERTIFICATIONS

APPENDIX H REGULATION SUMMARY

APPENDIX I PREVIOUS INSPECTIONS

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1.0 EXECUTIVE SUMMARY

INTRODUCTION

ITI of South Florida, Inc. (ITI) has completed a survey for asbestos-containing materials (ACM) and PCB Transformer Labels located at the Barracks Building, Sacramento, California for Building 650.

The scope of this work included the review of available records and an on-site investigative survey of facilities including bulk sample collection and analysis of suspect asbestos containing materials. Destructive survey techniques were not used. Accessible suspect asbestos containing building materials, including thermal system insulation and roofing materials, were evaluated. Representative material samples, including core samples, were collected from each homogeneous area of suspect ACM.

WARRANTY

The field and laboratory results reported herein (only if bulk samples are collected) are considered sufficient in detail and scope to determine the presence of accessible and/or exposed suspect asbestos containing building materials in the facility. ITI warrants that the finings contained herein have been prepared in general accordance with accepted professional practices at the time of its preparation as applied by similar professionals in the community. Changes in the state of the art or in applicable regulations cannot be anticipated and have not been addressed into this report.

The survey and analytical methods have been used to provide the client with information regarding the presence of accessible and/or exposed suspect asbestos containing building materials existing in the facility at the time of the inspection. Test results are valid only for material tested. There is a distinct possibility that conditions may exist which could not be identified within the scope of the study or which were not apparent during the site visit. This inspection covered only suspect accessible materials with no destructive survey techniques. The study is also limited to the information available from the client at the time it was conducted.

2.0 BACKGROUND INFORMATION

Based on the review of a previous asbestos survey prepared in April 1994 by CAL Environmental (CAL) and ITI’s survey of the building, ITI has concluded that the following materials contain asbestos:

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Ø TSI Fitting Insulation Ø Resilient Floor Tile and Mastic (9” x 9”) Grey with white streaks Ø Resilient Floor Tile and Mastic (9” x 9”) Beige with white streaks Ø Resilient Floor Tile and Mastic (9” x 9”) Dark Green with white streaks Ø Resilient Floor Tile and Mastic (9” x 9”) Lite Green Ø Wall Felt – Felt paper covering fibrous insulating wrap Ø Cement Asbestos Product – Cementitous panels inside generator shed Ø Cement Asbestos Product – 2’ x 4’ Ceiling Panels, White Cementitous Ø Resilient Floor Tile and Mastic (9” x 9”) Chocolate with red and white streaks Ø Resilient Floor Tile and Mastic (9” x 9”) Chocolate and white streaks Ø Cement Asbestos Product, White transite wall panels Ø Paint (Silver Paint)

In addition to the previous survey, one (1) bulk sample of suspect ACM was collected by ITI from a location in the facility. The sample was found to be negative when analyzed by Polarized Light Microscopy (PLM) analysis protocol recommended by the U.S.

Environmental Protection Agency (EPA) (40 CFR 763).

The material tested by ITI that was found not to contain asbestos was:

Ø Cove Mastic (2nd Floor Hallway)

ITI performed the scope of this work under the direction of Gil Bakshi, Certified Asbestos Consultant. Every reasonable effort was made to access all pertinent data required to identify ACBM within the facility.

The following materials were not tested but assumed to contain asbestos:

Ø Fire Door Insulation Ø Electrical wiring insulation Ø Electrical panel backings

Any items that are not listed in this survey that may be disturbed during renovation or demolition activities must be assumed positive or tested.

3.0 DESCRIPTION OF FACILITIES

Building 650, which was built in 1957, has a total of four floors including a basement level, comprising approximately 39,429 square feet of floor space. The building is currently being utilized as office space, dorm rooms and a kitchen. The floors, walls, and ceilings are all constructed of pored in place concrete. The roof is composed of hot mopped tar. Steam heating is supplied from boiler equipment located in the basement.

Air conditioning is supplied by air handling units situated on the roof which distribute air via above-ceiling space ducts on the first, second and third floors. Some building

63D RSC (Barracks Building - 650) ITI of South Florida, Inc. 5 additions and renovations have been made to the east and west wings to the main building as well as partial Thermal System Insulation (TSI) abatement, roof replacement and boiler room.

4.0 PREVIOUS INSPECTIONS

The 63D RSC provided ITI with one previous survey performed by CAL Environmental in April 1994. ITI reviewed the survey report prior to visiting the site and referenced it to confirm findings of the initial visual surveys performed by ITI. These surveys are presented in Appendix I.

5.0 SAMPLING AND ANALYTICAL PROCEDURES

During this survey, ITI accredited inspector, Mr. Tim Caughey performed a walk-through of the subject building. This was performed in order to identify and delineate locations of homogeneous materials suspected of containing asbestos. A homogeneous material is defined as material that presents similar distinguishing features such as contents. Once homogeneous materials were identified, bulk samples were collected by ITI accredited inspector from materials in order to confirm the presence or absence of asbestos in suspect materials. Samples were collected in accordance with U.S. Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA).

BULK SAMPLES

The sample numbering scheme was as follows:

SAC-650-01

SAC = Facility 650 = Building 01 = Sample number

During the Inspection, sampling locations were recorded on floor plans.

Bulk samples were sent to LA Labs, Inc. for laboratory analysis. This independent laboratory successfully participates in the National Voluntary Laboratory Accreditation Program (NVLAP) for bulk asbestos sample analysis. The samples were analyzed using Polarized Light Microscopy (PLM) analysis methodology coupled with dispersion staining solutions to distinguish the unique optical properties of mineral forms.

Employing this method of analysis allows asbestos fiber characteristics to colonize, which enables the microscopist to verify the presence or absence, quantity and type of asbestos in the samples. Any product that contains more than one percent asbestos is considered to be ACM by EPA & OSHA. Any product that contains one tenth of one percent is considered Asbestos Containing Construction Materials (ACCM) by Title 8, Section 1529 of the California Code of Regulations (CCR). ITI performed QA/QC

63D RSC (Barracks Building - 650) ITI of South Florida, Inc. 6 sampling for the total collected bulk samples (minimum of 10%). The PLM results are provided in Appendix A to this report.

6.0 ASSESSMENT METHODOLOGY

All Asbestos Containing Building Materials (ACBM) were classified into the following three types of suspect materials:

1. Surfacing Materials

2. Thermal System Insulation (TSI)

3. Miscellaneous Materials

ACM identified during the building survey was assessed according to the protocol described in 40 CR 763. The protocol evaluates the risk of exposure to airborne asbestos fibers by assessing the condition of each ACM and potential for that ACM to be disturbed and generate fibers. ACM was assessed according to each of the following factors:

(1) Damaged or significantly damaged thermal system insulation ACM.

(2) Damaged friable surfacing ACM.

(3) Significantly damaged friable surfacing ACM.

(4) Damaged or significantly damaged friable miscellaneous ACM.

(5) ACBM with potential for damage.

(6) ACBM with potential for significant damage.

(7) Any remaining friable ACBM or friable suspected ACBM.

ASSESSING CONDITION AND FRIABILITY

The ability of an ACM to be crushed, or reduced to powder by hand pressure is described in 40 CFR Part 61, Subpart M (NATIONAL EMISSIONS FOR HAZARD AIR

POLLUTANTS):

Ø Friable (F): ACM that can be crumbled, crushed, or reduced to powder by hand pressure.

Ø Nonfriable Category 1(NF1): Asbestos containing packing, gaskets, resilient floor coverings, asphalt roofing products, caulks, and mastics. These bituminous materials are assumed to remain nonfriable if demolition is performed using “normal” methods, but will become friable if severely weathered, sanded, or abraded.

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Ø Nonfriable Category 2 (NF2): ACM excluding Category 1 nonfriable ACM, that, when dry and in its present form, cannot be crumbled, pulverized or reduced to powder by hand pressure; however, these materials may become friable during demolition activities. These products include Transite board and asbestos cement products.

The condition of ACM including severity and extent of damage is classified into one of the following categories:

Ø Significantly Damaged: ACM that is crumbled, blistered, gouged, marred, delaminated, or otherwise damaged either uniformly or locally over a substantial portion of its surface area.

Ø Damaged: ACM that is crumbled, blistered, gouged, marred, delaminated, or otherwise damaged either uniformly or locally overall a small portion of its surface area.

Ø Good: ACM with very little or no damage.

Ø Potential for Disturbance: The potential for disturbance of each ACM was evaluated with respect to the types and frequency of occupancy, whether the ACM was accessible to area occupants, including vibration and air erosion.

See Appendix B for details and description of Potential for Disturbance Factors.

HAZARD RANKING ASSESSMENT METHODOLOGY

This hazard assessment combines the level of potential disturbance with the current condition of the ACM to indicate overall hazard potential. After the current conditions from the inspection report is determined, the ACBM will be classified as “significantly damaged”, “damaged” or “good” (40 CFR 763). The rankings of potential hazard range from 1 – most hazardous , to 7 – least hazardous. The highest rank is reserved for ACBM which is “significantly damaged”.

See Appendix C for details and Classification Scheme Flowchart.

See Appendix D for details on Response Action Schemes based on Hazard Rankings.

7.0 RESPONSE ACTIONS

ITI’s Response Actions (RA) and abatement priority for each ACM were based on the results of the assessment. Prioritization also has seven classifications: Priority (1) indicated that an ACM represents an immediate hazard and should be isolated and removed as soon as possible. Priority (7) indicated that an ACM represents little risk of exposure and should be managed in place. RA’s include one or more of the following:

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Ø Operations and Maintenance (O & M) Program: Managing all ACM in accordance with a properly designed and implemented O & M Program. An O & M Program has three components:

1. Identification, training, and notification requirements designed to prevent inadvertent disturbance of ACM.

2. Periodic surveillance of ACM to monitor its condition and modify the response actions or the program, as necessary.

3. Procedures to repair damaged ACM, clean up debris, and respond to fiber releases in the event that ACM is damaged or dislodged.

Ø Repair: Returning all damaged ACM to an undamaged or intact state through limited replacement and patching.

Ø Encapsulation: Treating ACM with a liquid that, after proper application, surrounds or embeds asbestos fibers in an adhesive matrix designed to prevent fiber release.

Ø Enclosure: Installing airtight barriers surrounds the ACM to prevent further damage and exposure to occupants.

Ø Removal: Stripping ACM from its substrate within regulated area using trained abatement workers; properly containerizing and disposal of the waste in a landfill.

8.0 ASBESTOS CONTAINING MATERIALS

Ø TSI Fitting Insulation (2” White Pipe Fitting / 4” Pipe Fitting Insulation)

According to the CAL survey, this material contains 15 % Chrysotile and 60% Amosite asbestos. This material is located in the basement, 2nd floor, boiler room, office and storage janitor’s room. There are a total of 74 fittings as identified in the CAL survey. Most visible and accessible fittings have been removed.

Although a removal of TSI was conducted in this building, it was not complete.

There is evidence of TSI in the laundry area and janitors closets. It is also anticipated that TSI is present in the attic / pipe chase (inaccessible) areas. The TSI observed by ITI appeared to have distributed damage and was significantly damaged in a few areas. Therefore, ITI has assigned the TSI a hazard ranking of 1 and an RA of 1 in accessible areas and a hazard ranking of 3 and an RA of 3 in inaccessible areas.

Ø TSI Pipe Insulation (1” White pipe run – 3” Insulation)

According to the CAL survey, this material contains 25% Chrysotile and 50% Amosite asbestos. ITI identified most of this material to be fiberglass in the basement. Although a removal of TSI was conducted in this building, it was not complete. There is evidence of TSI in the laundry area and janitors closets. It is also anticipated that TSI is present in the attic / pipe chase (inaccessible) areas.

The TSI observed by ITI appeared to have distributed damage and was significantly damaged in a few areas. Therefore, ITI has assigned the TSI a hazard ranking of 1 and an RA of 1 in accessible areas and a hazard ranking of 3 and an RA of 3 in inaccessible areas.

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Ø TSI Pipe Insulation (7” Pipe Insulation) According to the CAL survey, this material contains 2% Chrysotile and 30% Amosite asbestos. ITI identified this material to be fiberglass in the boiler room.

Should any material besides fiberglass be found, this should be treated as ACM.

Ø TSI Pipe Insulation (10” Pipe Insulation)

According to the CAL survey, this material contains 2% Chrysotile and 2%

Ø TSI Fitting Insulation (1” Pipe fittings / 3” Insulation) According to the CAL survey, this material contains 2% Chrysotile, 2% Amosite and 2% Crocidolite asbestos. ITI identified most of this material to be fiberglass in the basement, hallway 1st floor and boiler room. Although a removal of TSI was conducted in this building, it was not complete. There is evidence of TSI in the laundry area and janitors closets. It is also anticipated that TSI is present in the attic / pipe chase (inaccessible) areas. The TSI observed by ITI appeared to have distributed damage and was significantly damaged in a few areas.

Therefore, ITI has assigned the TSI a hazard ranking of 1 and an RA of 1 in accessible areas and a hazard ranking of 3 and an RA of 3 in inaccessible areas.

Ø TSI Fitting Insulation (7” Pipe Fitting)

According to the CAL survey, this material contains 2% Chrysotile and 8%

Ø TSI Pipe Insulation (4” white Pipe Run / 6” Insulation)

According to the CAL survey, this material contains 20% Chrysotile and 60% Amosite asbestos. ITI identified most of this material to be fiberglass in the basement, hallway 1st floor and boiler room. Although a removal of TSI was conducted in this building, it was not complete. There is evidence of TSI in the laundry area and janitors closets. It is also anticipated that TSI is present in the attic / pipe chase (inaccessible) areas. The TSI observed by ITI appeared to have distributed damage and was significantly damaged in a few areas. Therefore, ITI has assigned the TSI a hazard ranking of 1 and an RA of 1 in accessible areas and a hazard ranking of 3 and an RA of 3 in inaccessible areas.

Ø Resilient Floor Tile and Mastic (9” x 9” grey with white streaks)

According to the CAL survey, this material contains 5% Chrysotile asbestos in the tile and 10% Chrysotile in the mastic. This material is nonfriable and is in good condition. There is approximately 3,505 square feet located throughout the building. This material is assigned a hazard ranking of 7 and an RA of 7.

63D RSC (Barracks Building - 650) ITI of South Florida, Inc. 10

Ø Resilient Floor Tile and Mastic (9” x 9” beige with white streaks)

According to the CAL survey, this material contains 10% Chrysotile asbestos in the tile and mastic. This material is nonfriable and is in good condition. There is approximately 3,505 square feet located throughout the building. This material is assigned a hazard ranking of 7 and an RA of 7.

Ø Resilient Floor Tile and Mastic (9” x 9” dark green with white streaks) the tile and mastic. This material is nonfriable and is in good condition. There is approximately 2,819 square feet located throughout the building. This material is

Ø Resilient Floor Tile and Mastic (9” x 9” lite green) the tile and mastic. This material is nonfriable and is in good condition. There is approximately 2,819 square feet located throughout the building. This material is

Ø Cement Asbestos Product – Cementitous panels inside generator shed

According to the CAL survey, this material contains 70% Chrysotile asbestos.

This material is nonfriable and is in good condition. There is approximately 84 square feet of this material located in the generator shed. This material is

Ø Cement Asbestos Product – 2’ x 4’ Ceiling Panels – White Cementitous According to the CAL survey, this material contains 70% Chrysotile asbestos.

This material is nonfriable and is in good condition. There is approximately 1,425 square feet of this material located on the 1st, 2nd and 3rd floors. This material is assigned a hazard ranking of 7 and an RA of 7.

Ø Resilient Floor Tile and Mastic (9” x 9” Chocolate with red and white streaks) According to the CAL survey, this material contains 10% Chrysotile in the tile and 15% Chrysotile asbestos in the mastic. This material is nonfriable and is in good condition. There is approximately 1,368 square feet of this material located in the sleeping bay. This material is assigned a hazard ranking of 7 and an RA of 7.

Ø Resilient Floor Tile and Mastic (9” x 9” Beige with Chocolate and white streaks)

According to the CAL survey, this material contains 15% Chrysotile in the tile and 15% Chrysotile asbestos in the mastic. This material is nonfriable and is in good condition. There is approximately 1,368 square feet of this material located in the sleeping bay. This material is assigned a hazard ranking of 7 and an RA of 7.

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Ø Cement Asbestos Product – White transite wall panels

According to the CAL survey, this material contains 40% Chrysotile asbestos.

This material is nonfriable and is in good condition. There is approximately 600 square feet of this material located in the sleeping bay. This material is assigned a hazard ranking of 7 and an RA of 7.

Ø Paint (Silver Paint) According to the CAL survey, this material contains <1% Chrysotile asbestos.

This material is nonfriable and is in good condition. There is approximately 300 square feet of this material located in the boiler room. This material is assigned a hazard ranking of 7 and an RA of 7.

Ø Roof Tar / Sealant / Wall Felt

According to the CAL survey, these materials contain 5 - 10% Chrysotile asbestos. These materials are nonfriable and are in good condition. According to records provided by Paul Salinas, Facility Manager, these materials were abated.

9.0 SUSPECT ASBESTOS CONTAINING MATERIAL

Ø Electrical Wire Covering Ø Fire Door Insulation Ø Electrical Panel Backings

10.0 NON ASBESTOS CONTAINING MATERIAL

Asbestos was not detected in samples of the following materials collected by

CAL:

Ø TSI Gasket – Pale yellow rope gasket Inside door of southernmost boiler

Ø Acoustical Tile (1’ x 1’) white with small irregular holes Dining facility

Ø Resilient floor tile and mastic (12” x 12”) red Exit way and dining facility

Ø Resilient floor tile and mastic (12” x 12”) white with beige variations Exit way and dining facility

Ø Ceramic Tile (6” x 6”) rust Exit way, office, restroom, storage/janitor’s room and freezer

Ø Plaster and Lath Ø Wallboard / Joints / Texture (Gypsum Wallboard – Smooth) Ø TSI Duct Wrap – Fibrous Insulating Wrap Ø Linoleum and mastic (6” x 6”) beige squares Ø Acoustical Tile (2’ x 4’) white with small round holes and larger irregular holes Ø Ceramic Tile (Brown)

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Ø Wallboard / Joints / Texture – Gypsum Wallboard Ø Resilient Floor tile and mastic (12” x 12”) beige with white and brown variations Ø Cove base adhesive (4” Orange cove base adhesive) Ø Cove base adhesive (4” Dark brown cove base adhesive) Ø Cove base adhesive (4” light brown cove base adhesive) Ø Ceramic Tile (5” x 12”) beige ceramic tile and grout Ø Ceramic Tile (4” x 4”) brown ceramic tile and grout Ø Ceramic Tile (3 ½” x 3 ½”) grey ceramic tile Ø Ceramic Tile (5” x 5”) white ceramic tile Ø Carpet Mastic – Brown with yellow carpet mastic Ø Carpet Mastic – Green carpet mastic Ø Carpet Mastic – Brown carpet mastic Ø Miscellaneous TSI - Black pipe wrap tar Ø Miscellaneous freezer insulation Ø Vibration dampers Ø Paint – yellow paint Ø Window putty Ø Concrete

Asbestos was not detected in samples of the following materials collected by ITI:

Ø Cove mastic (2nd floor hallway)

11.0 PREVIOUS ABATEMENT RECORDS

Since the CAL survey, most of the TSI has been replaced by fiberglass. There is still TSI that contains asbestos in the laundry area and janitor’s closets that is visible and accessible. It is assumed that the TSI piping in the attic and chases also contain asbestos. Mr. Paul Salinas indicated that the boiler was replaced in 1998. In addition, according to Mr. Paul Salinas, the roof of the building was abated

The following materials have been partially abated:

Ø TSI Pipe Insulation (ONLY PARTIAL REMOVAL) 2” White pipe run / 4” Insulation Asbestos TSI is still in laundry area, janitor’s closets and assumed to be in chases and inaccessible areas.

Ø TSI Fitting Insulation (ONLY PARTIAL REMOVAL) (2” White Pipe Fitting / 4” Pipe Fitting Insulation)

63D RSC (Barracks Building - 650) ITI of South Florida, Inc. 13

(1” White pipe run – 3” Insulation)

(7” Pipe Insulation)

(10” Pipe Insulation)

Ø TSI Fitting Insulation (ONLY PARTIAL REMOVAL) (1” Pipe fittings / 3” Insulation)

(4” white Pipe Run / 6” Insulation) Asbestos TSI is still in laundry area, janitor’s closets and assumed to be in chases and inaccessible areas.

Ø TSI Fitting Insulation (ONLY PARTIAL REMOVAL)

12.0 BULK SAMPLE ANALYSIS SUMMARY

Sample Number Location Asbestos Content

SAC-650-01 Cove Mastic None SAC-650-01 QA None

13.0 PCB

The following list provides information on Transformers observed by ITI at 6270 Midway St., Sacramento, California.

Building 652 Pad mounted transformer number 1KMP2

Building 650 Pad mounted transformer number 1KMP3 Pad mounted transformer with no number on opposite side of the 1KMP3

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Building 640 Pad mounted transformer number 2KMP1

Building 655 Pad mounted transformer number 3KMP1

Parking Lot 3 Pole mounted transformers with number 15 on each

Mr. Tim Caughey, CIH, met with Rodney Turner from SMUD at the site to discuss electrical wiring that was assumed to contain asbestos. They are rewiring lights through the CCC. The transformers are owned by SMUD. The environmental contact is Fred Kellie (916-452-3211).

14.0 CONCLUSIONS AND RECOMMENDATIONS

Based on the findings above, ITI recommends the following:

Ø Observations for detected asbestos was based on visible and accessible materials;

therefore, asbestos containing materials may be present in inaccessible areas such as ceiling plenums, crawl spaces, attics, etc.

Ø An imminent asbestos hazard was present at the facility during the site visit.

- TSI in the laundry area

• Pipe Insulation is significantly damaged Ø This report is not intended to be an asbestos abatement design document and should not be used for the purpose of obtaining quotes.

Based on the asbestos present in the building, ITI recommends the following:

Ø Develop and implement an O & M Plan for all known and suspect ACM

There are three primary objectives of the O & M program: (1) clean up existing contamination (2) minimize further fiber release by controlling access to ACM, and (3) maintain ACM until it is eventually removed. Properly prepared and implemented, this plan will document the building owner’s prudence in dealing with asbestos in the building.

Ø Elements of the O & M Program o Notification and Labeling o A visual record of the type and location of known or assumed ACM within the building o Training o Employee protection and medical surveillance programs o Specialized cleaning procedures o Maintenance / Renovation work permit system o Special work practices for maintenance activities o Special work practices for renovation o Emergency response products o Periodic ACM surveillance: and o Record keeping

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Ø General awareness training must be presented to maintenance and custodial workers whose work responsibilities may require contact with ACM or suspect

ACM.

Training and periodic surveillance: Training shall include, but not be limited to:

(i) Information regarding asbestos and its various uses and forms.

(ii) Information on the health effects associated with asbestos exposure.

(iii) Locations of ACBM identified throughout each building

(iv) Recognition of damage, deterioration, and delaminating of ACBM.

(v) Descriptions of the proper methods of handling ACBM.

(vi) Information on the use of respiratory protection as contained in the

EPA/NIOSH Guide to Respiratory Protection for the Asbestos Abatement Industry, September 1986 (EPA 560/OPPTS-86-001), available from the Director, Environmental Assistance Division (7408), Office of Pollution Prevention and Toxics, U.S. Environmental Protection Agency, Room E- 543B, 401 M St., SW., Washington, DC, 20460.

(vii) Provisions of this section and Sec. 763.91, Appendices A, B, C, D of this subpart E of this part, EPA regulations contained in 40 CFR part 763, subpart G, and in 40 CFR part 61, subpart M, and OSHA regulations contained in 29 CFR 1926.1101.

(viii) Hands-on training in the use of respiratory protection, other personal protection measures, and good work practices.

Periodic surveillance: At least once every 6 months after a management plan is in effect, the Owner should conduct periodic surveillance in each building that contains ACBM or is assumed to contain ACBM.

Each person performing periodic surveillance shall: Visually inspect all areas that are identified in the management plan as ACBM or assumed ACBM and record the date of the surveillance, his or her name, and any changes in the condition of the materials.

Ø Training Requirements of the DOSH Asbestos Standard.

The DOSH asbestos standard (8 CCR § 1529) includes training requirements that are triggered by exposures exceeding the Permissible Exposure Limit (PEL).

Unless employees receive an appropriate level of training, those employees who work in buildings that contain ACM run the risk of disturbing the materials.

Pursuant to 29 CFR 1926.1101, employers must provide “Class IV” training to all employees who engage in activities during which they may contact known or suspect ACM or who engage in activities to clean up ACM debris. DOSH defines Asbestos Containing Construction Material as containing greater than 0.1 percent

63D RSC (Barracks Building - 650) ITI of South Florida, Inc. 16 asbestos. These employees include custodial or maintenance employees employed by or contracted on behalf of the USARC.

Ø Conduct periodic surveillance of all areas that contain known or suspect ACM.

Periodic review of the O & M program is essential to insure that the program objectives are being met. A key feature of the review is re-inspection of all ACM in the building. Combined with ongoing report of changes in the condition of the ACM made by service workers, the re-inspection will insure that any damage or deterioration of the ACM will be detected and corrective action taken. Re-inspection should be conducted at least annually; more frequently if necessary.

AHERA required surveillance every six months and re-inspection every three years by an accredited Building Inspector.

Ø Health and Safety Code §25915 et seq.

Also known as the Connelly Bill, these sections of the California Health and Safety Code require that all employees, outside contractors, and co-owners, including building occupants, be notified in writing regarding:

- Existence, location, accessibility, conclusions, and contents of asbestos survey reports and the asbestos management plans.

- Specific locations of ACM.

- General procedures and handling restrictions to prevent or minimize disturbance, release, or exposure.

- Bulk and air sampling results, including the sampling and analytical procedures used.

- Potential health risks or impacts that might result from exposure.

All occupants, employees, and owners must receive the above notification within 15 days following receipt of a survey report by the owner and annually thereafter.

New occupants, employees, and owners must receive the above notification within 15 days from the start of the relationship. All contractors should be notified regarding ACM onsite.

Ø Health and Safety Code §25249

The Safe Drinking Water and Toxic Substances Enforcement Act of 1986 (Proposition 65) applies to businesses of 10 or more employees and requires a warning of the risk of exposure to asbestos in buildings unless that exposure can be shown to be below the “no significant risk” (NSR) level or equal to background levels.

A clear and reasonable “environmental exposure” warning sign must also be posted at least in each area where damaged ACM is present.

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Signs typically read:

“WARNING: This area contains a chemical known to the State of California to cause cancer” OR “WARNING: This facility contains asbestos, a substance known to the State of California to cause cancer”.

Ø Title 29 CFR 1926.1101 (OSHA)

The Occupational Safety and Health Administration requires notification prior to and immediately following the performance of any work covered by the standard.

The building operator must notify in writing the following persons who will occupy or perform work in areas containing known or suspected ACM of the presence, location, and quantity of known and suspected ACM:

- Prospective employers applying or bidding for work in or adjacent to areas containing known or suspected ACM

- Employees of the owner who will work in or adjacent to areas containing known or suspected ACM

- On multi employer worksites, all employees who will perform work in or adjacent to areas containing known or suspected ACM

- Tenants who will occupy areas containing known or suspected ACM

Refer to 29 CFR 1926.1101 and 8 CCR § 1529 for complete owner notification requirements.

If building demolition or renovation activities will disturb ACM, such activities must be preceded by removal of the affected ACM as required by Federal, State and Local Regulations.

- ACM removal must be performed by a licensed and registered asbestos abatement contractor, in accordance with 8 CCR § 1529.

- Friable asbestos waste and debris containing greater than 1 percent asbestos must be transported by a qualified hazardous waste hauler and disposed of in manner consistent with applicable regulations at a landfill with operating permits and waste discharge requirements that allow it to accept asbestos containing waste.

- If ACM removal is performed, an asbestos abatement project design should be prepared. This project design may consist of technical specifications and drawing or a detailed work plan. The asbestos abatement project design must be prepared by a project designer accredited pursuant to AHERA.

63D RSC (Barracks Building - 650) ITI of South Florida, Inc. 18

- Asbestos abatement project design, management and monitoring should be conducted by a DOSH Certified Asbestos Consultant (CAC) and / or certified site surveillance technician (CSST).

Important Values / Definitions from Title 8 CCR § 1529, US EPA & OSHA

Asbestos Containing Material

"Asbestos-containing material (ACM)", means any material containing more than one percent asbestos.

Asbestos Containing Construction Material

"Asbestos-containing construction material" means any manufactured construction material which contains more than one tenth of 1 percent asbestos by weight.

"Asbestos-related work" means any activity which by disturbing asbestos-containing construction materials may release asbestos fibers into the air and which is not related to its manufacture, the mining or excavation of asbestos-bearing ore or materials, or the installation or repair of automotive materials containing asbestos. Asbestos-related work does not include the installation, repair, maintenance, or nondestructive removal of asbestos cement pipe used outside of buildings if the work operations do not result in employee exposures to asbestos in excess of 0.1 fibers per cubic centimeter of air (f/cc) as an 8-hour time-weighted average and the employees and supervisors involved in the work operations are trained and certified by an asbestos cement pipe training program which is approved by the Division.

Permissible Exposure Limits (PELS)

(1) Time-weighted average limit (TWA). The employer shall ensure that no employee is exposed to an airborne concentration of asbestos in excess of 0.1 fiber per cubic centimeter of air as an eight (8) hour time-weighted average (TWA).

(2) Excursion limit. The employer shall ensure that no employee is exposed to an airborne concentration of asbestos in excess of 1.0 fiber per cubic centimeter of air (1 f/cc) as averaged over a sampling period of thirty (30) minutes.

Notification

The following is a summary of the major asbestos notification and information requirements in 8 CCR 1529, 5203, 341.6-341.14 and the California Health & Safety Code. See the codes for the complete requirements. Note: Employers also have additional informational duties towards their employees under 8 CCR 1529, 1509 or 3203 (the Injury and Illness Prevention Program requirements for construction and general industry), 3204 (Access to Employee Exposure and Medical Records), as well as other Title 8 regulations.

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Employers performing work subject to 8 CCR § 1529:

• If less than 100 sq. ft. of asbestos-containing construction materials and therefore not subject to the asbestos registration rules, file a Report of Use with the Chief of DOSH (Cal/OSHA)

• Determine the location and quantity of asbestos-containing material (ACM) and/or presumed ACM (PACM) based on the criteria in 1529(k)(1); {ref.

1529(k)(3)(A)}

• If at a temporary worksite, notify the nearest Cal/OSHA District Enforcement Office 24 hours prior to work (ref. 1529(r) & 5203)

• Any incident resulting in an employee exposure in excess of the PEL and/or excursion limit by reporting in writing to the Chief of DOSH within 15 days. (ref.

1529(r) & 5203)

• Through meetings or other methods, inform employees, building owner and other employers on site, prior to work, about the location and quantity of ACM and/or PACM, the nature of their work, requirements pertaining to regulated areas, as well as the means to prevent asbestos air contamination; and {ref. 1529(d)(1) & (k)(3)(B)}

• Post a warning sign outside the regulated area that is understandable to employees working in and contiguous to the area {ref. 1529(e)(2) and (k)(7)}

• As soon as possible, notify affected employees regarding the results of personal air monitoring {ref. 1529(f)(5)}

• Within 10 days of completing the work, regarding the location and quantity of remaining asbestos, as well as any final monitoring results {ref. 1529(k)(3)(C)}

See 8 CCR 1529 for the exact requirements. There are additional notification duties to the local air quality district or the U.S. EPA.

Notification Under Title 40, Part 61, Subpart M (NESHAPS) – US EPA

• Notifications for renovations are required for the following activities which involve greater than 160 square feet, 260 linear feet or 35 cubic feet, cumulative per facility over one year.

• Notifications for demolitions are required for all demolitions of facilities.

• Please note that State Regulations may be more stringent than EPA Federal

Regulations.

15.0 COST ESTIMATION

ITI’s asbestos abatement cost estimates are listed below for each type of material found to be positive / confirmed asbestos containing in this report. Square

63D RSC (Barracks Building - 650) ITI of South Florida, Inc. 20 footage costs were prepared on the basis of historical units costs and information contained in the “Means Building Construction Cost Data” Manual (Unit Costs).

ITI’s estimated costs listed below may be may be higher than unit costs to help compensate for the many variables involved in the asbestos abatement industry.

It is always recommended to have an asbestos abatement contractor quote the project to get current and valid cost estimates at the time the USARC will perform the abatement.

Please note that conditions such as separating the work in small projects vs. one large project will greatly increase the cost. In addition, conditions such as weather and time of year will also impact the cost. All unit costs estimates listed below do not include estimated costs for project designs, air monitoring and consulting fees. Estimates are provided if all ACM is assumed to be removed at the same time and does not include the demolition of construction debris to access the ACM.

Estimated Project Designer Fees: $2,000 – 5,000 Estimated Air Monitoring Fees: $400 – 500 / day Estimated Consulting Fees: $50 – 70 / hour

Ø TSI Pipe Insulation $18.00 per linear foot 2” White pipe run / 4” Insulation

Ø TSI Fitting Insulation $150.00 each (2” White Pipe Fitting / 4” Pipe Fitting Insulation)

Ø TSI Pipe Insulation (1” White pipe run – 3” Insulation) $18.00 per linear foot

Ø TSI Pipe Insulation (7” Pipe Insulation) $18.00 per linear foot

Ø TSI Pipe Insulation (10” Pipe Insulation) $18.00 per linear foot

Ø TSI Fitting Insulation (1” Pipe fittings / 3” Insulation) $150.00 each

Ø TSI Fitting Insulation (7” Pipe Fitting) $150.00 each

Ø TSI Pipe Insulation (4” white Pipe Run / 6” Insulation) $18.00 per linear foot

Ø Resilient Floor Tile and Mastic $10,515.00

9” x 9” grey with white streaks 3,505 square feet located throughout the building ($3.00 per sq. ft.)

Ø Resilient Floor Tile and Mastic $10,515.00

9” x 9” beige with white streaks

63D RSC (Barracks Building - 650) ITI of South Florida, Inc. 21

3,505 square feet located throughout the building

Ø Resilient Floor Tile and Mastic $8,457.00

9” x 9” dark green with white streaks 2,819 square feet located throughout the building

Ø Resilient Floor Tile and Mastic $8,457.00 9” x 9” lite green 2,819 square feet located throughout the building

Ø Cement Asbestos Product $420.00 84 square feet of this material located in the generator shed ($5.00 per sq. ft.)

Ø Cement Asbestos Product – 2’ x 4’ Ceiling Panels $7,125.00 1,425 square feet ($5.00 per sq. ft.)

Ø Resilient Floor Tile and Mastic $4,104.00

9” x 9” Chocolate with red and white streaks 1,368 square feet of this material located in the sleeping bay

Ø Resilient Floor Tile and Mastic $4,104.00 9” x 9” Beige with Chocolate and white streaks 1,368 square feet of this material located in the sleeping bay

Ø Cement Asbestos Product – White transite wall panels $3,000.00 600 square feet of this material located in the sleeping bay ($5.00 per sq. ft.)

Ø Paint (Silver Paint) $600.00

300 square feet of this material located in the boiler room ($2.00 per sq. ft.)

NOTE: IT IS UNKNOWN THE ACTUAL QUANTITY OF ACM LOCATED

IN THIS BUILDING. IT IS ASSUMED THAT TSI IS IN THE

ATTIC SPACES, CRAWLSPACE AND INACCESSIBLE AREAS.

ACM IS VISIBLE AND ACCESSIBLE IN THE LAUNDRY AREA

AND JANITORS CLOSETS.