40 CFR 763 THREE-YEAR AHERA ASBESTOS RE-INSPECTION SUMMARY REPORT INDIAN HEAD ELEMENTARY SCHOOL

Transcription

1 69 Bridge Street Dedham, MA Phone Fax CFR 763 THREE-YEAR AHERA ASBESTOS RE-INSPECTION SUMMARY REPORT for INDIAN HEAD ELEMENTARY SCHOOL 726 Indian Head Street Hanson, MA Initial Re-Inspection Performed By: On November 21, 2011 Richard K. Bowen Mass DLS Asbestos Inspector #AI Revised Re-Inspection Performed By: On August 27, 2012 Paul Matuszko Mass DLS Asbestos Inspector # AI Management Planner Review By: and Report Date on Richard K. Bowen Massachusetts DLS Asbestos Management Planner # AP Prepared for: Mr. Ernest E. Sandland Facilities Director Whitman-Hanson Regional School District 600 Franklin Street Whitman, Massachusetts Prepared By: FLI Environmental, Inc. 69 Bridge Street Dedham, Massachusetts 02026

2 69 Bridge Street Dedham, MA Phone Fax TABLE OF CONTENTS Section Title Page Number 1.0 Introduction Summary of Initial Inspections EPA Required Assessment Codes Summary of Response Actions Required Under AHERA Additional AHERA Requirements Massachusetts Asbestos Regulations Current Re-Inspection Findings Notes/Comments Recommended Response Actions 5 Attachments: Asbestos Management Plan 7 Supplemental Operations & Maintenance Program Summary Annotated Floor Plan 8

3 69 Bridge Street Dedham, MA Phone Fax CFR 763 THREE YEAR AHERA ASBESTOS RE-INSPECTION SUMMARY REPORT For INDIAN HEAD ELEMENTARY SCHOOL 60 Regal Street Whitman, MA Report Revision Date: 1.0 Introduction: A. As required by the US Environmental Protection Agency's AHERA regulations, FLI Environmental, Inc. (FLI) has completed a survey and reassessment of asbestos containing materials in the Whitman Hanson Regional School District s Louse A. Conley Elementary School. This report summarizes the locations and conditions of materials remaining in the schools and reviews the ongoing responsibilities of the Local Education Agency (LEA). B. The initial re-inspection was performed on November 21, 2011 by Richard K. Bowen, Mass DLS Asbestos Inspector #AI A subsequent re-inspection to verify information in accordance with Massachusetts Department of Labor Standards (DLS) requirements was performed on August 27, 2012, by Paul Matuszko, Massachusetts Asbestos Inspector # AI The Management Plan review and report was prepared by Richard K. Bowen, Mass DLS Mass DLS Licensed Management Planner #AP in December, 2011 and revised on. C. This latest survey report should be incorporated into the files that the LEA maintains, pertaining to response actions, operations & maintenance activities, six-month re-inspection, training, air sampling and major asbestos activities. 2.0 Summary of Initial Inspection: A. During the initial inspection of the Whitman Hanson Regional School District, the consultant identified homogeneous areas of Asbestos Containing Building Materials (ACBM) and assessed their conditions as indicated in the original Management Plan. The FLI inspector identified the same homogeneous areas of ACBM as were identified in the initial inspection reports. Some of those materials have been abated. 3.0 EPA Required Assessment Codes: #1 Damaged or significantly damaged thermal systems insulation ACBM. #2 Damaged friable surfacing ACBM.

4 Page 2 #3 Significantly damaged friable surfacing ACBM. #4 Damaged or significantly damaged friable miscellaneous ACBM. #5 ACBM with potential for damage. #6 ACBM with potential for significant damage. #7 Any remaining friable Asbestos Containing Building Materials (ACBM) or friable suspected ACBM. 4.0 Summary of Response Actions Required Under AHERA: A. EPA Assessment Code #1: If damaged or significant damage thermal insulation ACBM is present, (EPA Code #1), the LEA must: Repair the damaged or remove the damaged material if not feasible to repair. Maintain all undamaged thermal system insulation in good condition. B. EPA Assessment Codes #2 and #4: If damaged friable surfacing ACBM or damaged friable miscellaneous ACBM, (EPA Codes #2 and #4), the LEA must either: Remove. Enclose. Encapsulate or repair the material in question. C. EPA Assessment Codes #3 and #4: If significant damage friable surfacing ACBM or friable miscellaneous ACBM is present, (EPA Codes #3 and #4), the LEA must: Immediately isolate and restrict access, unless isolation is not necessary. Remove the ACBM from the functional space, unless encapsulation or enclosure is sufficient. D. EPA Assessment Code #5: If ACBM has potential for damage (EPA Code #5), the LEA must: Institute an O&M program. E. EPA Assessment codes #6 and #7: If any ACBM has potential for significant damage (EPA Codes #6 and #7), the LEA must either: Implement an O&M program and institute preventative measures to eliminate likelihood that the ACBM or its cover will become significantly damaged. Remove the material expeditiously, if preventative measures are not possible, isolate and restrict access if necessary to prevent an imminent and substantial endangerment. 5.0 Additional AHERA Requirements: A. In addition to the above actions, AHERA regulations require the LEA to take the following actions: 1. Ensure that all 6-month periodic surveillance, inspections and re-inspections are carried out by trained and accredited personal.

5 Page 3 2. Ensure that all custodial and maintenance personal are properly trained in asbestos hazards (2 hour awareness). (Note: A two hour awareness training session was held on June 27, 2012). 3. Notify workers, building occupants and parents of students of AHERA activities. 4. Notify outside contractors of asbestos in the buildings that where any work may be done. 5. Post Asbestos warning labels in routine maintenance areas. (Note: completed during the August 27, 2012 re-inspection). 6. Notify building occupants that inspection reports and management plans are available for inspection. 7. Designate a person to ensure AHERA requirements are implemented and provide for adequate training to that person. 6.0 Massachusetts Asbestos Regulations: A. Stringent laws govern asbestos abatement activities in the Commonwealth of Massachusetts. The laws include the following: 1. Massachusetts State Law (453 CMR 6.00) requires certification of all persons involved in asbestos abatement activities. 2. Any employee whose work may require the disturbance of ACBM (i.e. plumbers, maintenance workers, etc.) should receive proper training in asbestos work techniques. Massachusetts State Law requires two-day mandatory training for affected individuals. 7.0 Current Re-Inspection Findings: A. During the required three-year re-inspection by this FLI, the inspector visually examined all accessible areas of the. Complete inspection found that asbestoscontaining materials are located in the following areas. I. Summary of Asbestos-Containing Building Materials (ACBMs) present: ACBM Type #* (Confirmed/Assumed) General Location ACBM Class Friable (F)/ Non-Friable (NF) AHERA Assessment Category Estimated Quantity (#1) Pipe insulation Crawl Space #1 (off boiler room) TSI F Good, #5 500 LF (#1) Pipe insulation Crawl Space #1 Entrance (off boiler room) TSI F Damaged, #1 ~ 8-10 LF (#2) Pipe insulation Crawl Space #2 (off Electrical transformer room) #* = Homogeneous area # SF = square feet LF = linear feet TSI F Good, #5 500 LF

6 Page 4 II. Summary of Previous Abatement Response Actions: A. FLI was not informed of or identified any abatement response actions that have been conducted since III. Summary of Findings and ACBM Classification (AHERA Category #): A. Damaged or Significantly Damaged Thermal System Insulation ACM (Cat. # 1.): 1. Pipe Insulation crawl space #1 entrance off boiler room (homogeneous area #1) Estimated Quantity: Previous Assessment: Current Assessment: ACBM Type: 8-10 LF Good condition Damaged condition Confirmed, friable thermal system insulation Damaged, asbestos-containing pipe insulation is present at the entrance to Crawl Space # 1 off the boiler room. The entrance area is up high near the ceiling along the back wall of the boiler room. The pipe insulation contains damaged frayed ends and minor contact and spot damage along the first two to three linear feet at the opening to the crawl space. B. Damaged Friable Surfacing ACM (Cat. # 2.): None Identified - not applicable C. Significantly Damaged Friable Surfacing ACM (Cat. # 3.): None Identified - not applicable D. Damaged or Significantly Damaged Friable Miscellaneous ACM (Cat. # 4.): None Identified not applicable E. ACBM with Potential for Damage (Good Condition - Cat. #5.): 2. Pipe Insulation crawl space #1 off boiler room (homogeneous area #1) Estimated Quantity: Previous Assessment: Current Assessment: ACBM Type: 500 LF Good condition Good condition Confirmed, friable thermal system insulation Asbestos-containing pipe insulation is present in generally good condition in the crawl space off the boiler room. The material has no change in its condition. 3. Pipe Insulation crawl space #2 off boiler room (homogeneous area #2) Estimated Quantity: 500 LF Previous Assessment: Good condition Current Assessment: Good condition ACBM Type: Confirmed, friable thermal system insulation Asbestos-containing pipe insulation is present in generally good condition in the crawl space off the boiler room. The material has no change in its condition.

7 Page 5 F. ACBM with Potential for Significant Damage (Cat. #6): None Identified - not applicable G. Any Remaining Friable ACBM of Friable Suspected ACBM (Cat. #7): None Identified - not applicable 8.0 Notes/Comments: A. Pipe insulation may be present in wall chases and above plaster ceilings. B. Include all ACBMs that are in good condition as well as any newly identified ACBM into the school s Management Plan and operations and maintenance (O & M) program (see attachment A for an update). The ACBMs listed herein should not be damaged or impacted in any manner. C. Removal of asbestos materials should be performed by a licensed Abatement Contractor prior to renovation or maintenance work that may impact the ACBMs. D. Bulk samples (when and if collected) will be collected in a statistically random manner in accordance with OSHA and AHERA 40 CFR 763 regulations. E. Additional Cleaning: Additional cleaning using HEPA-vacuuming and wet-wiping is NOT recommended at this time. ACBMs should be monitored for potential debris during six-month periodic surveillance inspections. Remedial cleaning should be performed by properly asbestos trained personnel whenever ACBM debris is present or when a fiber release episode occurs. F. Recommended Response Actions (RRAs) provided herein so that they are the least burdensome to the school system. G. Estimate of Resources: Estimated resources are provided using current abatement industry standard pricing. Annual O&M Program costs are provided for miscellaneous training, equipment, supplies (signs, labels, etc.) inspection, bulk sampling and respiratory protection. 9.0 Recommended Response Actions: A. The ACBMs listed in good condition do not require any response actions at this time. B. Should any newly identified suspect asbestos materials by identified during routine maintenance and renovation projects they should be sampled and analyzed for asbestos content prior to disturbing the material. C. Any previously presumed (assumed) ACBM should be sampled and analyzed to confirm the presence of asbestos. Presumed ACBM that is found not to contain asbestos may be removed from ACBM list for that school.. D. The following table outlines the RRAs and estimated resources costs:

8 Page 6 ACBM Type (Homogeneous area) (#1) Pipe Insulation Crawl Space #1 (off boiler room) (#1) Pipe insulation (#2) Pipe Insulation Location RRA 1 Estimated Quantity Crawl Space #1 Entrance (off boiler room) Crawl Space #2 (off Air Handling Room) Estimated Resources Cost* Estimated RRA completion date O&M 500 LF $ On-going Remove and repair ends 8-10 LF $1, April, 2013 O&M 500 LF $ On-going Good: Fair: Poor: RRA: O & M: ACBM DATA TABLES LEGEND No damage to the material, present in good condition. Minor damage to the material, present in fair condition. Less than 10% damaged throughout the material and coverings. Significant damage throughout the asbestos material. Greater than 10% damage. Recommended Response Action Maintain in Operations and Maintenance (O&M) Program Carpet O & M: Material is present under carpet. Maintain in O&M Program Repair: Remove: Assume: NA: Surf. TSI Misc. Repair Material Remove Material Assume material as an ACBM Not applicable; not previously listed or identified/ not present Surfacing Material Thermal System Insulation Miscellaneous Material

9 Page General Policy: Asbestos Management Plan Supplemental Operations & Maintenance Program Summary A. It is the intent and policy of the LEA (school system) that their employees shall not disturb, remove, repair or handle ACBMs in any manner during their work activities. Employees shall not perform minor clean-up or small-scale abatement activities of ACMs and asbestos debris. B. Employees shall not disturb or damage any identified confirmed or suspect ACM. Work may be conducted safely in and around areas containing properly maintained ACMs. C. Employees are not to engage in OSHA Class I, Class II, or Class III asbestos repair or removal activities, but instead utilizes licensed and certified outside contractors for these services. Ensure that all outside contractors working in the building are aware of the presence, location and type of ACBMs in areas that they will be expected to work near. D. Employees should inform their immediate supervisor of any suspect asbestos building materials that are disturbed or damaged or have the potential to be damaged during planned activities. If an unexpected suspect or confirmed asbestos-containing material is discovered during renovation or maintenance work, do not disturb the material, contact the Designated Person for a review of building inspection reports or required bulk sample analysis for asbestos content. E. Any activity that releases asbestos fibers into general workspace will require the services of an abatement contractor. Work shall cease unless emergency conditions exist (i.e. water leaks, broken pipes). The scope of work that may impact the ACMs will be decided by the Owner. F. Whenever possible, asbestos related work shall be performed in occupied areas on evenings when the building is not occupied. The HVAC system affecting the area will be shut down or modified during the activity. 2.0 Prohibited Activities: A. These are routine maintenance activities that are prohibited when ACBM is involved: 1. Do not drill holes in asbestos containing materials (walls, ceilings, floors, etc.). 2. Do not hang plants or pictures on structures that contain or are covered with ACBM. 3. Do not sand or drill VAT flooring and linoleum flooring materials. 4. Do not damage ACBM while moving furniture or equipment. 5. Do not install drapes, curtains or dividers in such a way that they damage ACBM. 6. Do not dust, floors ceilings, moldings or other surfaces in asbestos contaminated environments with a dry brush, cloth or broom. 7. Do not use an ordinary vacuum to clean up asbestos containing debris. Only HEPA filtered vacuums shall be used. 8. Do not remove ceiling tiles below ACBM without wearing the proper respiratory protection, clearing the area of other people, and observing asbestos removal waste disposal procedures. Page 1 of 1

10