11 DDWG J-0200000-06 Asbestos Final Report.pdf
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FINAL ASBESTOS SURVEY REPORT AND
MANAGEMENT PLAN
DDC FACILITY ASBESTOS SURVEY
DEFENSE LOGISTICS AGENCY
WARNER ROBINS, GEORGIA
(DDWG)
Defense Logistics Agency
MACTEC Engineering and Consulting, Inc.
Project No. 6141-06-3000
Air Force Center for Environmental Excellence Contract No.: F41624-03-D-8606
Task Order No.: 0116
20 June 2007
FINAL ASBESTOS SURVEY REPORT AND MANAGEMENT PLAN
DDC FACILITY ASBESTOS SURVEY
DEFENSE LOGISTICS AGENCY
WARNER ROBINS, GEORGIA
(DDWG)
Prepared for:
Air Force Center for Environmental Excellence
Contract No. F41624-03-D-8606
Task Order No. 0116
Prepared by:
MACTEC Engineering and Consulting, Inc.
396 Plasters Avenue
Atlanta, Georgia 30324
TABLE OF CONTENTS
LIST OF ACRONYMS AND ABBREVIATIONS
PREFACE
1.0 EXECUTIVE SUMMARY
1.1 Legacy Asbestos Data Evaluation
1.2 Asbestos Survey Findings
1.3 Conclusions
1.4 Recommendations
2.0 BACKGROUND INFORMATION
3.0 ASBESTOS SURVEY SCOPE
3.1 Pre-survey Activities
3.2 Visual Site Survey and Sample Collection
3.3 Sample Analysis, Data Management, and Reporting
4.0 ASBESTOS SURVEY FINDINGS
5.0 CONCLUSIONS AND RECOMMENDATIONS
5.1 Conclusions
5.2 Recommendations
6.0 ASBESTOS MANAGEMENT PLAN
6.1 Immediate Action Items
6.2 Phased Action Items
6.3 Asbestos Management Plan Funding Requirements
7.0 SUMMARY OF SURVEY INFORMATION BY FACILITY
7.1 Building 00333
7.2 Building 00334
7.3 Building 00340
7.4 Building 00341
7.5 Building 00351
7.6 Building 00368
7.7 Building 00376
7.8 Building 00380
7.9 Building 00385
7.10 Building 00393
7.11 Building 00395
7.12 Building 00396
7.13 Building 00602
7.14 Building 00606
7.15 Building 00641
7.16 Building 00660
Final Asbestos Survey Report and Management Plan – DDWG Contract No. F41624-03-D-8606-0116 MACTEC Project No. 6141-06-3000.03
20 June 2007 Revision 0
063000.01 i
7.17 Building 01611
7.18 Building 01612
7.19 Building 01613
7.20 Building 01614
8.0 SUMMARY OF SUSPECT ACM
8.1 Building 00333
8.2 Building 00334
8.3 Building 00340
8.4 Building 00341
8.5 Building 00351
8.6 Building 00368
8.7 Building 00376
8.7 Building 00376
8.8 Building 00380
8.9 Building 00385
8.10 Building 00393
8.11 Building 00395
8.12 Building 00396
8.13 Building 00602
8.14 Building 00606
8.15 Building 00641
8.16 Building 00660
9.0 SUMMARY OF IDENTIFIED ACM
9.1 Building 00333
9.2 Building 00340
9.3 Building 00341
9.4 Building 00351
9.5 Building 00368
9.6 Building 00376
9.7 Building 00380
9.8 Building 00385
9.9 Building 00393
9.10 Building 00395
9.11 Building 00396
9.12 Building 00602
9.13 Building 00606
9.14 Building 00641
9.15 Building 00660
10.0 INVENTORY OF SUSPECT ACM BY ROOM
Final Asbestos Survey Report and Management Plan – DDWG Contract No. F41624-03-D-8606-0116 MACTEC Project No. 6141-06-3000.03
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063000.01 ii
10.1 Building 00333
10.2 Building 00334
10.3 Building 00340
10.4 Building 00341
10.5 Building 00351
10.6 Building 00368
10.7 Building 00376
10.8 Building 00380
10.9 Building 00385
10.10 Building 00393
10.11 Building 00395
10.12 Building 00396
10.13 Building 00602
10.14 Building 00606
10.15 Building 00641
10.16 Building 00660
10.17 Building 01611
10.18 Building 01612
10.19 Building 01613
10.20 Building 01614
11.0 SUMMARY OF RECOMMENDED RESPONSE ACTIONS FOR ACM
11.1 Building 00333
11.3 Building 00340
11.4 Building 00341
11.5 Building 00351
11.6 Building 00368
11.6 Building 00368
11.6 Building 00368
11.6 Building 00368
11.7 Building 00376
11.7 Building 00376
11.7 Building 00376
11.7 Building 00376
11.8 Building 00380
11.8 Building 00380
11.8 Building 00380
11.9 Building 00385
11.9 Building 00385
11.9 Building 00385
Final Asbestos Survey Report and Management Plan – DDWG Contract No. F41624-03-D-8606-0116 MACTEC Project No. 6141-06-3000.03
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063000.01 iii
11.9 Building 00385
11.9 Building 00385
11.10 Building 00393
11.11 Building 00395
11.12 Building 00396
11.13 Building 00602
11.13 Building 00602
11.14 Building 00606
11.14 Building 00606
11.15 Building 00641
11.15 Building 00641
11.15 Building 00641
11.15 Building 00641
11.15 Building 00641
11.16 Building 00660
12.0 COMPLETED MILITARY CONSTRUCTION PROJECT DATA FORMS (DD FORM1391)
13.0 SUSPECT ACM DETAIL AND PHOTOGRAPHS
13.1 Building 00333 -Homogeneous Material M00333.001
13.2 Building 00333 -Homogeneous Material M00333.002
13.3 Building 00333 -Homogeneous Material M00333.003
13.4 Building 00334 -Homogeneous Material M00334.001
13.5 Building 00334 -Homogeneous Material M00334.002
13.6 Building 00334 -Homogeneous Material M00334.003
13.7 Building 00334 -Homogeneous Material M00334.004
13.8 Building 00340 -Homogeneous Material M00340.001
13.9 Building 00340 -Homogeneous Material M00340.002
13.10 Building 00340 -Homogeneous Material M00340.003
13.11 Building 00340 -Homogeneous Material M00340.004
13.12 Building 00340 -Homogeneous Material M00340.005
13.13 Building 00340 -Homogeneous Material M00340.006
13.14 Building 00340 -Homogeneous Material M00340.007
13.15 Building 00340 -Homogeneous Material M00340.009
13.16 Building 00340 -Homogeneous Material M00340.011
13.17 Building 00340 -Homogeneous Material M00340.012
13.18 Building 00340 -Homogeneous Material M00340.013
13.19 Building 00340 -Homogeneous Material M00340.014
13.20 Building 00340 -Homogeneous Material M00340.015
13.21 Building 00340 -Homogeneous Material M00340.016
13.22 Building 00340 -Homogeneous Material M00340.017
Final Asbestos Survey Report and Management Plan – DDWG Contract No. F41624-03-D-8606-0116 MACTEC Project No. 6141-06-3000.03
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063000.01 iv
13.23 Building 00340 -Homogeneous Material M00340.018
13.24 Building 00340 -Homogeneous Material M00340.019
13.25 Building 00340 -Homogeneous Material M00340.020
13.26 Building 00340 -Homogeneous Material M00340.021
13.27 Building 00341 -Homogeneous Material M00341.001
13.28 Building 00341 -Homogeneous Material M00341.002
13.29 Building 00341 -Homogeneous Material M00341.003
13.30 Building 00341 -Homogeneous Material M00341.004
13.31 Building 00351 -Homogeneous Material M00351.001
13.32 Building 00351 -Homogeneous Material M00351.002
13.33 Building 00351 -Homogeneous Material M00351.003
13.34 Building 00351 -Homogeneous Material M00351.004
13.35 Building 00351 -Homogeneous Material M00351.005
13.36 Building 00351 -Homogeneous Material M00351.006
13.37 Building 00351 -Homogeneous Material M00351.007
13.38 Building 00351 -Homogeneous Material M00351.008
13.39 Building 00351 -Homogeneous Material M00351.010
13.40 Building 00351 -Homogeneous Material M00351.011
13.41 Building 00351 -Homogeneous Material M00351.012
13.42 Building 00351 -Homogeneous Material M00351.013
13.43 Building 00351 -Homogeneous Material M00351.014
13.44 Building 00351 -Homogeneous Material M00351.015
13.45 Building 00351 -Homogeneous Material M00351.016
13.46 Building 00351 -Homogeneous Material M00351.017
13.47 Building 00351 -Homogeneous Material M00351.018
13.48 Building 00351 -Homogeneous Material M00351.019
13.49 Building 00351 -Homogeneous Material M00351.020
13.50 Building 00368 -Homogeneous Material M00368.001
13.51 Building 00368 -Homogeneous Material M00368.002
13.52 Building 00368 -Homogeneous Material M00368.003
13.53 Building 00368 -Homogeneous Material M00368.004
13.54 Building 00368 -Homogeneous Material M00368.005
13.55 Building 00368 -Homogeneous Material M00368.006
13.56 Building 00368 -Homogeneous Material M00368.007
13.57 Building 00368 -Homogeneous Material M00368.008
13.58 Building 00368 -Homogeneous Material M00368.009
13.59 Building 00368 -Homogeneous Material M00368.010
13.60 Building 00368 -Homogeneous Material M00368.011
13.61 Building 00368 -Homogeneous Material M00368.012
Final Asbestos Survey Report and Management Plan – DDWG Contract No. F41624-03-D-8606-0116 MACTEC Project No. 6141-06-3000.03
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063000.01 v
13.62 Building 00368 -Homogeneous Material M00368.013
13.63 Building 00368 -Homogeneous Material M00368.014
13.64 Building 00368 -Homogeneous Material M00368.015
13.65 Building 00368 -Homogeneous Material M00368.016
13.66 Building 00368 -Homogeneous Material M00368.017
13.67 Building 00368 -Homogeneous Material M00368.018
13.68 Building 00368 -Homogeneous Material M00368.019
13.69 Building 00368 -Homogeneous Material M00368.020
13.70 Building 00368 -Homogeneous Material M00368.021
13.71 Building 00368 -Homogeneous Material M00368.022
13.72 Building 00368 -Homogeneous Material M00368.023
13.73 Building 00368 -Homogeneous Material M00368.024
13.74 Building 00368 -Homogeneous Material M00368.025
13.75 Building 00368 -Homogeneous Material M00368.026
13.76 Building 00368 -Homogeneous Material M00368.027
13.77 Building 00368 -Homogeneous Material M00368.028
13.78 Building 00368 -Homogeneous Material M00368.029
13.79 Building 00368 -Homogeneous Material M00368.030
13.80 Building 00368 -Homogeneous Material M00368.031
13.81 Building 00376 -Homogeneous Material M00376.001
13.82 Building 00376 -Homogeneous Material M00376.002
13.83 Building 00376 -Homogeneous Material M00376.003
13.84 Building 00376 -Homogeneous Material M00376.004
13.86 Building 00376 -Homogeneous Material M00376.005
13.86 Building 00376 -Homogeneous Material M00376.006
13.87 Building 00376 -Homogeneous Material M00376.007
13.88 Building 00376 -Homogeneous Material M00376.008
13.89 Building 00376 -Homogeneous Material M00376.009
13.90 Building 00376 -Homogeneous Material M00376.010
13.91 Building 00376 -Homogeneous Material M00376.011
13.92 Building 00376 -Homogeneous Material M00376.012
13.93 Building 00376 -Homogeneous Material M00376.013
13.94 Building 00376 -Homogeneous Material M00376.014
13.95 Building 00376 -Homogeneous Material M00376.015
13.96 Building 00376 -Homogeneous Material M00376.016
13.97 Building 00376 -Homogeneous Material M00376.017
13.98 Building 00376 -Homogeneous Material M00376.018
13.99 Building 00376 -Homogeneous Material M00376.019
13.100 Building 00376 -Homogeneous Material M00376.020
Final Asbestos Survey Report and Management Plan – DDWG Contract No. F41624-03-D-8606-0116 MACTEC Project No. 6141-06-3000.03
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063000.01 vi
13.101 Building 00376 -Homogeneous Material M00376.021
13.102 Building 00376 -Homogeneous Material M00376.022
13.103 Building 00376 -Homogeneous Material M00376.023
13.104 Building 00376 -Homogeneous Material M00376.024
13.105 Building 00376 -Homogeneous Material M00376.025
13.106 Building 00380 -Homogeneous Material M00380.001
13.107 Building 00380 -Homogeneous Material M00380.002
13.108 Building 00380 -Homogeneous Material M00380.003
13.109 Building 00380 -Homogeneous Material M00380.004
13.110 Building 00380 -Homogeneous Material M00380.005
13.111 Building 00380 -Homogeneous Material M00380.006
13.112 Building 00380 -Homogeneous Material M00380.007
13.113 Building 00380 -Homogeneous Material M00380.008
13.114 Building 00380 -Homogeneous Material M00380.009
13.115 Building 00380 -Homogeneous Material M00380.010
13.116 Building 00380 -Homogeneous Material M00380.011
13.117 Building 00380 -Homogeneous Material M00380.012
13.118 Building 00380 -Homogeneous Material M00380.013
13.119 Building 00380 -Homogeneous Material M00380.014
13.120 Building 00380 -Homogeneous Material M00380.015
13.121 Building 00380 -Homogeneous Material M00380.016
13.122 Building 00380 -Homogeneous Material M00380.017
13.123 Building 00380 -Homogeneous Material M00380.018
13.124 Building 00380 -Homogeneous Material M00380.019
13.125 Building 00380 -Homogeneous Material M00380.020
13.126 Building 00380 -Homogeneous Material M00380.022
13.127 Building 00380 -Homogeneous Material M00380.023
13.128 Building 00385 -Homogeneous Material M00385.001
13.129 Building 00385 -Homogeneous Material M00385.002
13.130 Building 00385 -Homogeneous Material M00385.003
13.131 Building 00385 -Homogeneous Material M00385.004
13.132 Building 00385 -Homogeneous Material M00385.005
13.133 Building 00385 -Homogeneous Material M00385.006
13.134 Building 00385 -Homogeneous Material M00385.007
13.135 Building 00385 -Homogeneous Material M00385.008
13.136 Building 00385 -Homogeneous Material M00385.009
13.137 Building 00385 -Homogeneous Material M00385.010
13.138 Building 00385 -Homogeneous Material M00385.011
13.139 Building 00385 -Homogeneous Material M00385.012
Final Asbestos Survey Report and Management Plan – DDWG Contract No. F41624-03-D-8606-0116 MACTEC Project No. 6141-06-3000.03
20 June 2007
063000.01 vii
13.140 Building 00385 -Homogeneous Material M00385.013
13.141 Building 00385 -Homogeneous Material M00385.014
13.142 Building 00385 -Homogeneous Material M00385.015
13.143 Building 00385 -Homogeneous Material M00385.016
13.144 Building 00385 -Homogeneous Material M00385.017
13.145 Building 00385 -Homogeneous Material M00385.018
13.146 Building 00385 -Homogeneous Material M00385.019
13.147 Building 00385 -Homogeneous Material M00385.020
13.148 Building 00385 -Homogeneous Material M00385.021
13.149 Building 00385 -Homogeneous Material M00385.022
13.150 Building 00385 -Homogeneous Material M00385.023
13.151 Building 00385 -Homogeneous Material M00385.024
13.152 Building 00385 -Homogeneous Material M00385.025
13.153 Building 00385 -Homogeneous Material M00385.026
13.154 Building 00385 -Homogeneous Material M00385.027
13.155 Building 00385 -Homogeneous Material M00385.028
13.156 Building 00385 -Homogeneous Material M00385.029
13.157 Building 00385 -Homogeneous Material M00385.030
13.158 Building 00385 -Homogeneous Material M00385.031
13.159 Building 00385 -Homogeneous Material M00385.032
13.160 Building 00385 -Homogeneous Material M00385.033
13.161 Building 00385 -Homogeneous Material M00385.034
13.162 Building 00385 -Homogeneous Material M00385.035
13.163 Building 00385 -Homogeneous Material M00385.036
13.164 Building 00385 -Homogeneous Material M00385.037
13.165 Building 00385 -Homogeneous Material M00385.038
13.166 Building 00385 -Homogeneous Material M00385.039
13.167 Building 00393 -Homogeneous Material M00393.001
13.168 Building 00395 -Homogeneous Material M00395.001
13.169 Building 00395 -Homogeneous Material M00395.002
13.170 Building 00395 -Homogeneous Material M00395.003
13.171 Building 00395 -Homogeneous Material M00395.004
13.172 Building 00395 -Homogeneous Material M00395.005
13.173 Building 00395 -Homogeneous Material M00395.006
13.174 Building 00395 -Homogeneous Material M00395.007
13.175 Building 00395 -Homogeneous Material M00395.008
13.176 Building 00395 -Homogeneous Material M00395.009
13.177 Building 00395 -Homogeneous Material M00395.010
13.178 Building 00396 -Homogeneous Material M00396.001
Final Asbestos Survey Report and Management Plan – DDWG Contract No. F41624-03-D-8606-0116 MACTEC Project No. 6141-06-3000.03
20 June 2007
063000.01 viii
13.179 Building 00602 -Homogeneous Material M00602.001
13.180 Building 00602 -Homogeneous Material M00602.002
13.181 Building 00602 -Homogeneous Material M00602.003
13.182 Building 00602 -Homogeneous Material M00602.004
13.183 Building 00602 -Homogeneous Material M00602.005
13.184 Building 00602 -Homogeneous Material M00602.006
13.185 Building 00602 -Homogeneous Material M00602.007
13.186 Building 00602 -Homogeneous Material M00602.008
13.187 Building 00602 -Homogeneous Material M00602.009
13.188 Building 00606 -Homogeneous Material M00606.001
13.189 Building 00606 -Homogeneous Material M00606.002
13.190 Building 00606 -Homogeneous Material M00606.003
13.191 Building 00606 -Homogeneous Material M00606.004
13.192 Building 00606 -Homogeneous Material M00606.005
13.193 Building 00641 -Homogeneous Material M00641.001
13.194 Building 00641 -Homogeneous Material M00641.002
13.195 Building 00641 -Homogeneous Material M00641.003
13.196 Building 00641 -Homogeneous Material M00641.004
13.197 Building 00641 -Homogeneous Material M00641.005
13.198 Building 00641 -Homogeneous Material M00641.006
13.199 Building 00641 -Homogeneous Material M00641.007
13.200 Building 00641 -Homogeneous Material M00641.008
13.201 Building 00641 -Homogeneous Material M00641.009
13.202 Building 00641 -Homogeneous Material M00641.010
13.203 Building 00641 -Homogeneous Material M00641.011
13.204 Building 00641 -Homogeneous Material M00641.012
13.205 Building 00641 -Homogeneous Material M00641.013
13.206 Building 00641 -Homogeneous Material M00641.014
13.207 Building 00641 -Homogeneous Material M00641.015
13.208 Building 00641 -Homogeneous Material M00641.016
13.209 Building 00641 -Homogeneous Material M00641.017
13.210 Building 00641 -Homogeneous Material M00641.018
13.211 Building 00641 -Homogeneous Material M00641.019
13.212 Building 00641 -Homogeneous Material M00641.020
13.213 Building 00641 -Homogeneous Material M00641.021
13.214 Building 00641 -Homogeneous Material M00641.022
13.215 Building 00641 -Homogeneous Material M00641.023
13.216 Building 00641 -Homogeneous Material M00641.024
13.217 Building 00641 -Homogeneous Material M00641.025
Final Asbestos Survey Report and Management Plan – DDWG Contract No. F41624-03-D-8606-0116 MACTEC Project No. 6141-06-3000.03
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063000.01 ix
13.218 Building 00641 -Homogeneous Material M00641.026
13.219 Building 00641 -Homogeneous Material M00641.027
13.220 Building 00641 -Homogeneous Material M00641.028
13.221 Building 00641 -Homogeneous Material M00641.029
13.222 Building 00641 -Homogeneous Material M00641.030
13.223 Building 00641 -Homogeneous Material M00641.031
13.224 Building 00641 -Homogeneous Material M00641.032
13.225 Building 00641 -Homogeneous Material M00641.033
13.226 Building 00641 -Homogeneous Material M00641.034
13.227 Building 00641 -Homogeneous Material M00641.035
13.228 Building 00660 -Homogeneous Material M00660.001
13.229 Building 00660 -Homogeneous Material M00660.002
13.230 Building 00660 -Homogeneous Material M00660.003
13.231 Building 00660 -Homogeneous Material M00660.004
13.232 Building 00660 -Homogeneous Material M00660.005
13.233 Building 00660 -Homogeneous Material M00660.006
13.234 Building 00660 -Homogeneous Material M00660.007
13.235 Building 00660 -Homogeneous Material M00660.008
13.236 Building 00660 -Homogeneous Material M00660.009
13.237 Building 00660 -Homogeneous Material M00660.010
13.238 Building 00660 -Homogeneous Material M00660.011
13.239 Building 00660 -Homogeneous Material M00660.012
13.240 Building 00660 -Homogeneous Material M00660.013
13.241 Building 00660 -Homogeneous Material M00660.014
13.242 Building 00660 -Homogeneous Material M00660.015
14.0 GIS ASBESTOS SURVEY SITE DRAWING
Buildings 00333, 00334, 00340, 00341 & 00376
Buildings 00351, 00368, 00393, 00395 & 00396
Buildings 00380 & 00385
Buildings 00602, 00606 & 00641
Building 00660
Buildings 01611, 01612, 01613 & 01614
A PLM Summary Reports (Results of Bulk Samples – NVLAP LAB# 101066 [MACTEC-ATLANTA]) PDF file
B Summaries of Results of Analyses by TEM (TEM Confirmation of Select Bulk Samples – NVLAP LAB# 101235 [Materials Analytical Serices] PDF file
C Suspect ACM Inventory Detail Spreadsheet Spreadsheet file
D Survey Team Member Accreditations PDF file
E GIS Drawing with Associated Survey Data DWG/DWF files
ATTACHMENTS
Final Asbestos Survey Report and Management Plan – DDWG Contract No. F41624-03-D-8606-0116 MACTEC Project No. 6141-06-3000.03
20 June 2007
063000.01 x
Final Asbestos Survey Report and Management Plan – DDWG 20 June 2007 Contract No. F41624-03-D-8606-0116 Revision 0 MACTEC Project No. 6141-06-3000.03
063000.01 xi
Acronym Definition
AAPM Asbestos Abatement Program Management
ACBM Asbestos-containing Building Materials
ACM Asbestos-containing Materials
AHERA Asbestos Hazard Emergency Response Act
AMP Asbestos Management Plan
APM Asbestos Program Manager
ARDR Asbestos-related Document Review
BUR Built-up Roofing
CAB Cement Asbestos Board
CADD Computer-aided Design Drafting
CE Civil Engineering
CFR Code of Federal Regulations
CMU Concrete Masonry Unit
DDC Defense Distribution Center
DDWG Defense Distribution Center Warner Robins, Georgia
DLA Defense Logistics Agency
FY Fiscal Year
GIS Geographic Information System
ID Identification
MACTEC MACTEC Engineering and Consulting, Inc.
NESHAP National Emission Standards for Hazardous Air Pollutants
NOB Non-friable Organically Bound
NVLAP National Voluntary Laboratory Accreditation Program
OSHA Occupational Safety and Health Administration
O&M Operation and Maintenance
PACM Presumed Asbestos-containing Material
PLM Polarized Light Microscopy
QA Quality Assurance
QC Quality Control
RAFB Robins Air Force Base
063000.01 xii
(Continued)
Acronym Definition
TEM Transmission Electron Microscopy
TSI Thermal Systems Insulation
USEPA U.S. Environmental Protection Agency
063000.01 xiii
PREFACE
The attached Final Asbestos Survey Report and Management Plan, DDC Facility Asbestos Survey, Defense Logistics Agency, Warner Robins, Georgia, is distributed in the following formats:
• Printed hardcopy (Volume I – includes Sections 1.0 through 9.0)
• Electronic copy (PDF format on CD, Volumes I and II, Sections 1.0 through 14.0, including:
Laboratory PLM Summary Reports
Laboratory Summaries of Results of Analyses by TEM Report
Suspect ACM Inventory Detail Spreadsheet
Survey Team Member Accreditations
GIS Drawing with Associated Survey Data
063000.01 1-1
1.0 EXECUTIVE SUMMARY
MACTEC Engineering and Consulting, Inc., (MACTEC) performed an asbestos survey of buildings occupied by the Defense Logistics Agency (DLA) within the Defense Distribution Center (DDC) at
Robins Air Force Base (RAFB), Warner Robins, Georgia, (DDWG) from 11 through 22 December 2006.
At the time of MACTEC’s field survey, the DLA-occupied space comprised 20 buildings and encompassed approximately 3,079,227 square feet of plan area. The construction dates ranged from 1943 to 2000. The buildings were mostly single-story structures, with warehouse space the primary use in 16 of the 20 buildings. The remaining four buildings were the shipping/receiving building, the container recycling building, a small office building, and a break room/restroom building.
1.1 Legacy Asbestos Data Evaluation
The Asbestos Assessment Program Project Activities Work Plan developed to support DLA asbestos survey efforts included review and validation of legacy asbestos survey data and inspection and supplemental sampling of suspect asbestos-containing materials (ACM) to meet established protocol.
MACTEC’s document review of the legacy asbestos data revealed limited information regarding the extent and location of previously identified ACM within the buildings. It was not possible to verify portions of the legacy information due to incomplete material and/or sample location descriptions. To the extent information on previous bulk sampling was available, corresponding information was not available to delineate the extent of materials represented. MACTEC’s field verification of the legacy data revealed that the information was outdated. Portions of previously identified ACM were not observed during
MACTEC’s site activities. Materials installed after the previous surveys apparently concealed some previously identified ACM. When legacy bulk sampling results were correlated to suspect ACM in the field, there were multiple instances in which insufficient samples were collected to comply with
Occupational Safety and Health Administration (OSHA) asbestos regulations. When legacy information was available, MACTEC’s survey validated bulk sample analytical data, supplemented as appropriate, and assessed the current condition and friability of the ACM consistent with the survey program’s protocol.
063000.01 1-2
1.2 Asbestos Survey Findings
MACTEC identified 347 suspect homogeneous materials in the 20 buildings. MACTEC relied on validated analytical results of legacy asbestos survey data and performed supplemental bulk sampling of unsampled and under-sampled suspect materials as necessary to identify ACM. Supplemental bulk sampling of suspect asbestos-containing materials included the collection of 465 bulk material samples to determine which suspect materials contained asbestos. Consistent with established protocol, certain categories of suspect asbestos-containing materials such as roofing were assumed to contained asbestos rather than subject the materials to physical damage associated with their sampling and associated uncertainties with patching and repairs.
The U.S. Environmental Protection Agency (USEPA) and OSHA have published regulations, guidelines, and recommendations regarding inspection and sampling for installed ACM. MACTEC’s survey addressed the requirements of OSHA’s Asbestos Standard for Construction and USEPA’s Asbestos
Standard for Demolition and Renovation, which are contained in the National Emission Standards for
Hazardous Air Pollutants (NESHAP).
Current USEPA Asbestos Hazard Emergency Response Act (AHERA) regulations (40 Code of Federal
Regulations [CFR] Part 763] classify asbestos-containing building materials (ACBM) into three categories: Surfacing Materials, Thermal Systems Insulation (TSI), and Miscellaneous Materials.
Asbestos-containing applications of the following categories were identified at DDWG:
• Surfacing Materials in the form of a textured coating in Building 00641
• TSI in the form of preformed block insulation, pipe insulation, and pipe fitting insulation installed in various piping systems in Buildings 00351, 00368, 00376, 00380, 00385, and 00641
• Miscellaneous Materials in the form of resilient floor tiles and associated mastics;
ceiling tile adhesive; various mastics on ductwork; and insulation associated with piping, waterproof coatings, and cement asbestos board (CAB) in Buildings 00333, 00340, 00341, 00351, 00368, 00376, 00380, 00385, 00393, 00395, 00396, 00602, 00606, 00641, and 00660
The AHERA regulations do not require sampling of materials; rather, they allow designation of suspect materials as “asbestos-containing.” Similarly, rather than require sampling the OSHA regulations allow designation of “presumed asbestos-containing material (PACM)”. Select applications of suspect ACM were assumed to contain asbestos, rather than subject the materials to physical damage associated with
063000.01 1-3 sampling and associated uncertainties with patching and repairs. Additional applications of non-sampled suspect asbestos-containing Miscellaneous Materials were identified: fire doors, flange gaskets, roofing system materials, CAB, various mastics, and wiring insulation.
No ACM was identified in Buildings 00334, 01611, 01612, 01613, and 01614.
MACTEC’s asbestos survey protocol included documentation of the condition of suspect ACM identified during the field efforts. The identified ACM was generally in good condition. Limited damaged ACM in the form of floor tiles and associated mastics was identified in Buildings 00376, 00380, and 00385.
1.3 Conclusions
MACTEC’s survey either identified or confirmed ACM in 15 of the 20 DLA-occupied buildings. Most
ACM were in good condition and are candidates for ongoing, in-place management. Limited areas in three of the buildings were documented to include limited areas of damaged and/or significantly damaged
ACM that is not candidates for ongoing, in-place management and should be repaired or removed under strict, controlled procedures. Certain suspect ACM (e.g., vermiculite and selected roofing or concealed materials) was beyond the scope of the sampling protocol and were assumed ACM. The PACM should be managed in place as ACM until it is disturbed (or scheduled to be disturbed). At such time, bulk samples of the associated materials should be collected by an accredited asbestos building inspector and analyzed for asbestos content.
MACTEC’s previous review of asbestos-related documents revealed that while the host agency has an
Asbestos Operation and Maintenance (O&M) Program it maintains, verification of the implementation and effectiveness of the program is difficult to assess given the matrix of responsibilities and lack of centralized recordkeeping. For an Asbestos O&M Program to be effectively implemented, it must address and reflect an installation’s operational requirements and provide for centralized recordkeeping.
1.4 Recommendations
Based on the findings and conclusions in this report, MACTEC recommends that DLA/DDC implement the Asbestos Management Plan (AMP) provided in Section 6.0 for DLA-occupied buildings. The AMP should address and manage confirmed and assumed ACM identified by MACTEC, along with a site-specific Asbestos O&M Program for ACM that are candidates for ongoing, in-place management.
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MACTEC further recommends that the AMP provide Asbestos Abatement Program Management
(AAPM) guidance and support to facilitate the proper removal and disposal of identified ACM in a consistent, planned, cost-effective manner to meet established abatement protocol.
Based on MACTEC’s recommended AMP, DDWG should invest in the following (dollar amounts are rough order of magnitude):
• Removal of Damaged ACM Identified by the MACTEC Survey:
o Building 00376: MACTEC recommends budgeting $5,428 for this work in Fiscal Year (FY) 2007.
o Building 00380: MACTEC recommends budgeting $7,610 for this work in
FY 2007.
o Building 00385: MACTEC recommends budgeting approximately $5,195 for this work in FY 2007.
• Development of a Site-specific Asbestos O&M Program. MACTEC recommends budgeting $103,685 for this work in FY 2007. Additional ongoing funding will be required to support program management. Long-term costs will depend on the selected management approach and may include costs of equipment and supplies necessary for program activities and medical surveillance for employees.
• Training to Support Asbestos O&M Program Implementation. MACTEC recommends budgeting $23,927 for this work in FY 2007. This cost includes two awareness training sessions, two O&M worker training sessions, one Asbestos Program Manager (APM) training session, and associated training materials.
Additional ongoing funding will be required to support the training. Long-term costs will depend on the selected management approach and may include annual offerings of awareness training and O&M worker training courses.
• Development of AAPM Protocol. MACTEC recommends budgeting $31,017 for this work in FY 2007. No additional funding for development is anticipated, but additional ongoing funding will be required to support activities that are beyond the scope of the Asbestos O&M Program. These costs will depend on the ACM affected.
An associated Military Construction Project Data form (DD Form 1391) for each item detailed above is provided in Section 12.0.
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2.0 BACKGROUND INFORMATION
MACTEC conducted an assessment of the Defense Distribution Center (DDC) buildings in Warner
Robins, Georgia (DDWG) in November 2005 to provide an inventory and assessment of real property assets and an actionable list of facility repairs and upgrades. The assessment included an Asbestos-related
Document Review (ARDR), referred to as an “Environmental Document Review” in Final Report, Worldwide Facility Assessment, Warner Robins, Georgia, to assess the site’s compliance with applicable military, federal, and state asbestos regulations and to provide recommendations regarding resolution of identified deficiencies. In general, MACTEC’s recommendations associated with the ARDR findings included the following:
• Validate and supplement the existing asbestos-related legacy data to obtain a comprehensive asbestos survey of the DLA-occupied buildings and develop a corresponding AMP.
• Implement the AMP recommendations, including development and implementation of an Asbestos O&M Program to manage the installed ACBM.
• Implement written management procedures to guard against ACBM installation and prevent future asbestos-related considerations from being introduced to future facility operations, maintenance, construction, and/or renovation.
To support the ARDR-related recommendations in the Worldwide Facility Assessment, Property
Condition Assessment and Remediation, Contract No. F41624-03-D-8606, Task Order No. 0074, the Air
Force Center for Environmental Excellence retained MACTEC, under Contract No. F41624-03-D-8606, Task Order No. 0116, to perform asbestos surveys of selected DLA/DDC facilities.
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3.0 ASBESTOS SURVEY SCOPE
The purpose of MACTEC’s asbestos survey was to validate and supplement available asbestos-related legacy data to obtain a comprehensive asbestos survey of DLA-occupied buildings, and to support management of asbestos-related issues affecting facility operations. MACTEC located, quantified, and assessed ACBM according to the following tasks:
• Pre-survey activities
• Visual site survey and sample collection
• Sample analysis, data management, and reporting
3.1 Pre-survey Activities
Pre-survey activities consisted of site reconnaissance, including logistical support, legacy data evaluation, plotting of available Geographic Information System (GIS)/Computer-aided Design Drafting (CADD) drawings for use in the field survey, and project standardization field survey training.
3.1.1 Logistical Support
Logistical support included coordination of the following:
• A site reconnaissance meeting in advance of the full survey team
• Field efforts with on-site DDC personnel
• Project standardization field survey training in DLA survey protocols for primary field and technical support personnel
• Travel and lodging arrangements for pre-deployment site reconnaissance and the field survey
3.1.2 Site Reconnaissance
The site team leader performed site reconnaissance on 6 and 7 December 2006. The reconnaissance efforts included collection of available electronic drawings, coordination of field efforts with on-site DDC personnel, and a walk-through of buildings to be included in the visual site survey and sample collection.
The site team leader also interviewed Support Services Specialist Messers Robert Collins and Dan Matibe while on-site. Information gathered from the interview was incorporated into the applicable sections of this report. MACTEC previously collected available asbestos legacy data during the ARDR.
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Appropriate additional site personnel were interviewed to obtain information regarding current facility operations and planned modifications to the buildings included in MACTEC’s asbestos survey. In accordance with DLA survey protocol, more invasive sampling (selective demolition of identified areas) is required in buildings planned for demolition, renovation, or construction within 12 months of the survey, so that areas that may contain otherwise unreported ACM can be accessed.
Based on the interviews, renovations are planned for Building 00385 within the next 12 months for installation of an elevator in Bay A. No demolition, renovation, and/or construction are planned for any of the other buildings.
3.1.3 Legacy Data Evaluation
MACTEC’s previous assessment of DDC buildings included an ARDR to generally assess the site’s compliance with applicable military, federal, and state asbestos regulations. That assessment included initial collection of previous asbestos survey reports and documentation associated with sampling and analysis of suspect ACM. MACTEC’s review and evaluation of the available information related to the asbestos visual site survey and sample collection were performed concurrently with those efforts.
The available information underwent a preliminary “desktop” review to evaluate the scope of previous efforts and associated findings, and to determine whether the data were appropriate for on-site validation and potential incorporation into MACTEC’s asbestos survey. In general, MACTEC’s review of legacy data included an evaluation of the following:
• Purpose and Scope, to identify the intent of the previous survey.
• Usability of the Data. The following elements of previously collected data were evaluated. Data that failed to satisfy each criterion were excluded from the survey:
o Accreditation:
Determine whether the building inspector was properly accredited.
Determine whether the laboratory was accredited by the National Voluntary Laboratory Accreditation Program (NVLAP), as well as other possibly required local accreditations and/or certifications.
Verify that sample chain of custody was maintained and documented.
o Determine whether the documentation appeared to be sufficient such that data could be correlated to existing materials and conditions in the facility.
063000.01 3-3 o Assess the consistency of the data (e.g., correlation between bulk sampling data and laboratory data, logical sampling locations, or samples collected from areas where material was located).
• Sufficiency of the Data. Data that appeared to be valid and usable were further evaluated to assess their sufficiency and completeness to represent the materials sampled according to DLA survey protocol. Where “desktop” review identified that supplemental sampling and/or information was necessary, MACTEC:
o Determined whether the materials that were identified as non-ACM were adequately sampled.
o Determined whether some ACM classes or categories may not have been addressed during the survey based on the scope and limitations of previous work.
o Evaluated the classification and assessment system used during the survey (e.g., verify that materials were classified and assessed according to NESHAP1, OSHA, and/or other locally prevailing regulations).
o Evaluated sampling and analytical protocols used in previous survey efforts (e.g., floor tile samples collected and analyzed without floor tile mastic samples or results reported).
• Inclusion of Legacy Data into the Current Survey. Data that appeared to be valid and usable based on the “desktop” review were included for field validation by the survey teams.
MACTEC’s conclusions associated with the legacy asbestos data evaluation are summarized in
Section 5.1.
3.1.4 Plotting of Available CADD Drawings of Facility Buildings
Previous efforts associated with MACTEC’s Worldwide Facility Assessment resulted in development of
GIS drawings of the buildings that were occupied by DLA at that time. The GIS drawings simplistically indicate each building’s perimeter and are geospatially located on a base map plan. The drawings do not indicate detailed interior plan space.
MACTEC’s DLA survey protocol includes documentation of visual site survey and sample collection.
After MACTEC’s site team leader returned from the pre-deployment site reconnaissance, geo-based/CADD professionals produced hardcopies of the electronic floor plan drawings that were available for use and field verification by the survey team. MACTEC also used existing hardcopies available from
1 Subsequent references to USEPA’s NESHAP in this report are in the context of Subpart M, Section 61.145.
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DLA. When existing floor plan drawings were not available or were not current for the existing buildings and/or areas included in the survey, the survey team sketched a single-line plan of the existing areas. The single-line sketches were not prepared to scale, although efforts were made to maintain relative proportions.
3.2 Visual Site Survey and Sample Collection
MACTEC’s field survey team conducted the asbestos survey from 11 through 22 December 2006. The team consisted of a survey team leader, a site data manager, a site quality assurance (QA) manager, and three two-person survey teams consisting of leaders and surveyors. In addition, one person supplemented data entry for a subset of the visual site survey and sample collection. Each survey team member was a
USEPA AHERA-accredited building inspector. Copies of MACTEC personnel accreditations are included in Attachment D.
USEPA and OSHA have published regulations, guidelines, and recommendations regarding inspection and sampling for installed ACM. MACTEC’s survey addressed the requirements of OSHA’s Asbestos
Standard for Construction (29 CFR Part 1926.1101) and USEPA’s Asbestos Standard for Demolition and
Renovation (40 CFR Part 61.145), which is contained in the NESHAP regulations.
MACTEC conducted project standardization field survey training in DDC survey protocols for primary field and technical support personnel. The training:
• Described project-specific requirements and protocols related to consistency in the assessment of legacy data, supplemental sampling, and field data collection
• Established the required parameters in verification of existing information and determination of supplemental requirements to meet DDC survey protocol
• Provided orientation in project-specific field forms and related documentation requirements to gather information while supporting the efficient transition from field data input to project reporting
3.2.1 Methodology
Survey methodology in the referenced regulations requires sampling of suspect materials by
“homogeneous areas” and assessment of suspect materials by “functional space.” To support MACTEC’s survey, room designations were developed during a walk-through of each building, and each room was
063000.01 3-5 assigned a unique number consistent with the survey protocol. For survey purposes, a “room” is a discrete area in a building that may correspond to physical rooms (e.g., doors and walls), discrete space
(e.g., a mezzanine or roof), or other easily identifiable space (e.g., a column bay).
Rooms were then grouped into “functional spaces.” A functional space is an area that generally has similar activities and that contains suspect materials that have similar damage and potential for future damage or disturbance (e.g., warehouse or administrative space).
3.2.2 Visual Site Survey
The visual site survey consisted of a walk-through of DLA-occupied buildings (or portions thereof) to identify, inventory, and assess suspect ACM. The survey included accessible interior and exterior areas.
MACTEC did not use destructive means or disassemble equipment or finishes to access suspect materials.
The suspect materials were grouped based on material homogeneity. A homogeneous material is one that appears to be uniform in texture, color, and wear, and appears to have been applied or installed during the same general period.
3.2.3 Legacy Data Assessment
RAFB’s Civil Engineering (CE) office maintains asbestos documentation on-site. Asbestos-related information previously was scanned and archived as PDF documents. The documentation was organized by building number, varied by type and extent of information, and ranged from no asbestos information available to limited information that varied by building. Documentation associated with several buildings included a “Summary of Findings” from an apparently previous base-wide asbestos survey report, which was not provided in full for review. Bulk sampling documentation was limited to single incident or scope
(e.g., project-related or complaint), and was not included as a survey report. RAFB personnel performed bulk sampling.
Preliminary review of the legacy asbestos documentation revealed that a base-wide asbestos survey was performed in the mid-1980s. Additionally, supplemental sampling was performed in some buildings to support previous renovations or maintenance activities. Findings from the review are as follows:
• The asbestos information appeared outdated. Portions of previously identified ACM were not observed during MACTEC’s site activities.
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• Materials installed after the previous surveys concealed portions of previously identified ACM. No data regarding these materials were available for review.
• Portions of the legacy information could not be verified because of incomplete material and/or sampling location descriptions.
• Information regarding extent and location of identified ACM in the buildings is limited. Available information included locations of previously collected bulk samples and did not typically delineate the extent of the materials represented by the sampling.
• The number of samples collected of various suspect materials during previous bulk sampling was insufficient to comply with OSHA’s Asbestos Standard for Construction (29 CFR Part 1926.1101) and USEPA’s Asbestos Standard for Demolition and Renovation (40 CFR Part 61.145).
Available asbestos-related legacy information was validated to the extent possible and incorporated into the visual site survey and sample collection. Additional bulk samples from materials previously identified as ACM were not collected. The condition of these materials, which were verified to be in the surveyed areas, was assessed or re-assessed consistent with protocol. Data associated with materials previously documented as non-ACM were not relied upon because they did not include complete material descriptions, did not meet minimum sampling requirements, and/or lacked adequate documentation associated with accredited inspectors and laboratories.
3.2.4 Sample Collection
The sampling strategy was developed following the visual site survey. Representative bulk samples of previously unsampled suspect materials, as well as those previously sampled insufficiently according to the DLA survey protocol, were collected. These samples supplemented the validated legacy data and helped to provide comprehensive asbestos surveys of DLA-occupied buildings.
Suspect ACM was sampled as necessary to supplement existing asbestos survey information and to meet current NESHAP and applicable state and military bulk sampling requirements. Available legacy data were validated and used to reduce additional sampling. Supplemental sampling was performed where deficiencies were identified to meet DLA survey sampling protocols.
Following the facility walk-through and identification of suspect materials, sampling locations were selected and representative samples of suspect materials were collected. Unless otherwise instructed,
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MACTEC did not demolish or remove finishes or materials, or disassemble equipment to access the suspect materials.
Appropriately accredited personnel collected the samples. MACTEC documented the locations and field-estimated quantities of accessible suspect ACM in the buildings. Inaccessible areas that may contain unreported suspect ACM were noted.
The asbestos survey protocol included sampling of built-up materials on roofs that were estimated to have a remaining service life of three years or less, as determined by the Worldwide Facility Assessment.
Roofing materials on buildings scheduled to be demolished in the 12 months following MACTEC’s field survey also would be sampled. However, the Worldwide Facility Assessment did not identify such built-up roofing (BUR) systems. Furthermore, no buildings slated for demolition from December 2006 to
December 2007 were identified. Where suspect roofing materials were observed, they were documented and considered ACM.
3.3 Sample Analysis, Data Management, and Reporting
Following the visual site survey and sample collection, MACTEC submitted samples for laboratory analysis, compiled data collected during the site activities, and prepared this Final Asbestos Survey
Report and Management Plan.
3.3.1 Sample Analysis
The bulk samples were sealed in airtight containers; labeled; and delivered to MACTEC’s
NVLAP-accredited laboratory in Atlanta, Georgia, for analysis by polarized light microscopy (PLM), coupled with dispersion staining (USEPA/600/R-93/116). A PLM Summary Report was prepared for each building in which bulk samples were collected. In addition, samples of suspect ACM documented as damaged or significantly damaged in all affected buildings at the time of sample collection were consolidated. Expedited PLM analyses were performed on samples representing the damaged or significantly damaged suspect ACM. The results identifying asbestos in the samples were reported in
MACTEC’s Interim Report of Asbestos Survey dated 23 January 2007. The PLM Summary Reports are included in Attachment A.
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Consistent with industry practice, PLM analytical results of resilient floor tile or other non-friable organically bound (NOB) materials indicating less than 1 percent asbestos were confirmed with analysis by transmission electron microscopy (TEM). Bulk samples were submitted for supplemental analysis by
TEM according to the following criteria:
• One bulk sample of any NOB material that had no asbestos detected by PLM and that was categorized as damaged or significantly damaged
• One bulk sample of any NOB material representing those materials with a higher likelihood of asbestos (e.g., 9- by 9-inch floor tile)
• One bulk sample of any NOB material representing similar materials identified as asbestos in other buildings at the same site
• One bulk sample of any material specifically addressed by a DLA representative
• One bulk sample of any material in which no asbestos was observed by PLM but in which the analyst questioned the accuracy of the PLM results
• One bulk sample of any material in which point count analytical results were less than 1 percent (e.g., wallboard joint compound)
• One bulk sample of any generally unique material in which no asbestos was detected by PLM
The results of the supplemental TEM analyses were compared to the initial PLM laboratory reports. Any discrepancies were addressed before final bulk sampling results were reported. A Summary of Results of
Analyses by TEM was prepared for each building for which bulk samples were submitted for supplemental confirmation analysis. These summary reports are included in Attachment B.
MACTEC performed supplemental PLM analysis of approximately 10 percent of the total number of bulk samples for QA and quality control (QC). Bulk samples were duplicated or split, documented, and included with a chain of custody form. QC samples were submitted to the laboratory as blind samples
(the analyst was unaware of the building or original sample number). The QC sample results were compared to the original laboratory reports. Any discrepancies were addressed before final bulk sampling results were reported. The PLM Summary Report associated with the QC samples is included in
Attachment A.
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3.3.2 Data Management
Based on DLA survey protocol requirements, MACTEC determined the type and extent of asbestos survey-related information to be gathered. A database was developed to support management of asbestos survey-related data. Use of the database, which supported production of this Final Asbestos Survey
Report and Management Plan, was beneficial for consistent collection of field data and critical for their consistent evaluation.
Associated data were managed to support verification of legacy data and supplemental survey and sampling as necessary to comply with DLA survey protocol. The manner in which the field asbestos survey efforts were performed was structured such that information necessary to populate the database and support desired output was obtained (i.e.
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