ASBESTOS OPERATIONS AND MAINTENANCE PROGRAM. Prepared for: FALMOUTH PUBLIC SCHOOLS FALMOUTH, MASSACHUSETTS. Prepared by:

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1 ASBESTOS OPERATIONS AND MAINTENANCE PROGRAM Prepared for: FALMOUTH PUBLIC SCHOOLS FALMOUTH, MASSACHUSETTS Prepared by: American Environmental Consultants, Inc 841 Broad Street Weymouth, Massachusetts December 6, 2017 The asbestos, lead, mold and hazardous material professionals 814 Broad St. Weymouth, MA Fax:

2 ASBESTOS OPERATIONS AND MAINTENANCE PROGRAM Prepared for: FALMOUTH PUBLIC SCHOOLS FALMOUTH, MASSACHUSETTS Prepared by: American Environmental Consultants, Inc 841 Broad Street Weymouth, Massachusetts December 6, 2017 Prepared by: Michael McCaffrey (MA AP ) Principal The asbestos, lead, mold and hazardous material professionals 814 Broad St. Weymouth, MA Fax:

3 CHAPTER I: INTRODUCTION TABLE OF CONTENTS 1.0 INTRODUCTION TO THE OPERATIONS AND MAINTENANCE PROGRAM. 1-1 CHAPTER II: CLIENT O&M PROGRAM 1.0 CLIENT POLICY ORGANIZATION OF THE ASBESTOS MANAGEMENT TEAM GROUP COORDINATOR ("GS") APPROVED INDEPENDENT ASBESTOS CONSULTANT MAINTENANCE PERSONNEL CUSTODIAL STAFF OFFICE PERSONNEL AREAS CONTAINING ASBESTOS MATERIALS ASBESTOS-CONTAINING MATERIALS NOTIFICATIONS REGULATORY NOTIFICATIONS FOR PLANNED AND EMERGENCY ASBESTOS ABATEMENT PROGRAM FOR INFORMING BUILDING OCCUPANTS COMMON MAINTENANCE ACTIVITIES IMPACTING ACM SIGNS TRAINING REQUIREMENTS CUSTODIANS AND MAINTENANCE PERSONNEL ASBESTOS COORDINATOR DOCUMENTATION OF TRAINING CLEANING AREAS WITH FRIABLE ACM AREAS WITH NON-FRIABLE ACM SPECIAL WORK PRACTICES FOR MAINTENANCE ACTIVITIES SPECIAL WORK PRACTICES FOR PLANNED RENOVATION WORK EMERGENCY RESPONSE PROCEDURES FOR EPISODIC EVENTS PERIODIC ACM SURVEILLANCE INSPECTION ASBESTOS SAMPLING AND ANALYSIS Bulk Sampling Air Sampling i

4 TABLE OF CONTENTS (Continued) 12.0 RECORDKEEPING ASBESTOS-CONTAINING WASTE MATERIAL STORAGE AND TRANSPORTATION CHAPTER III: BACKGROUND INFORMATION 1.0 HISTORY OF ASBESTOS USES OCCURRENCE AND PROPERTIES USES OF ASBESTOS IN BUILDINGS EXPOSURE POTENTIAL POTENTIAL HEALTH CONCERNS AND EFFECTS THE RESPIRATORY SYSTEM ASBESTOSIS LUNG CANCER MESOTHELIOMA ASBESTOS REGULATIONS OSHA ASBESTOS STANDARDS NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) OTHER FEDERAL AGENCIES STATE AND LOCAL AGENCIES FIGURES List of Buildings Covered By This Program Floor Plans for Each School APPENDICES Appendix A Appendix B Appendix C GLOSSARY OF TERMS SIX MONTH INSPECTION FORMS FOR EACH SCHOOL ASBESTOS SAMPLE NOTIFICATION LETTER ii

5 CHAPTER I INTRODUCTION

6 1.0 INTRODUCTION TO THE OPERATIONS AND MAINTENANCE PROGRAM This Asbestos Operations and Maintenance (O&M) Program provides management and guidelines for conducting maintenance activities in areas of Falmouth Public School Buildings where asbestos-containing materials (ACM) are located. This program adopts guidelines from the United States Environmental Protection Agency (EPA) Managing Asbestos in Place - A Building Owner's Guide to an Operations and Maintenance Program for Asbestos Containing Materials, Occupational Safety and Health Administration (OSHA) regulations, and local regulatory agency requirements. This manual is intended to provide a basis for implementation of the O&M Program. The primary purpose of the O&M Program is the protection of the health and safety of building occupants and staff. The goals of this program include the monitoring of the condition of ACM over time, the minimization of fiber release episodes by minimizing disturbance of ACM, and abatement of asbestos when considered in a short-term actionable state. This program addresses those procedures and practices required to safely perform activities, such as: Monitoring of the condition of ACM; Performing emergency and scheduled asbestos abatement; and Overseeing asbestos waste disposal. This program is also designed to: Inform Falmouth Public Schools management and facility maintenance staff of the presence of asbestos and of precautions to be taken to prevent potential exposures, Provide proper training to Falmouth Public Schools Staff, Provide necessary equipment to Falmouth Public Schools staff, Provide proper notification to outside contractors on the presence and location of identified ACM, Establish schedules for periodic surveillance activities, Provide guidelines for response to potential fiber-release episodes, and

7 Organize the documentation of these activities in conformance with applicable regulations and guidelines. Suspect ACM has been identified in specific Buildings and Building locations at the Falmouth Public Schools in Falmouth, Massachusetts. A listing of materials that should be presumed to contain asbestos is found in Chapter III, Table 1. These materials should be presumed to be asbestos-containing until bulk sampling and laboratory analysis confirm that the material is non-acm. Falmouth Public Schools supports all activities associated with the implementation of the O&M Program. Mr. Kevin Pimental, whose office is located at the Teaticket School, is designated as the contact for the Asbestos Program. Mr. Pimental can be reached at Any asbestos questions, concerns, maintenance, and emergency situations for the Falmouth Public School buildings should be addressed to the Program Manager. Chapter II presents site-specific O&M practices and procedures. These procedures should be read and thoroughly understood by affected Falmouth Public Schools personnel; however, only independent licensed contractors shall perform them. Chapter III presents general information including history and uses of asbestos, health concerns, and effects, and summaries of Federal regulation pertaining to asbestos.

8 CHAPTER II CLIENT ASBESTOS O&M PROGRAM

9 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA 1.0 CLIENT POLICY INTRODUCTION Asbestos has been determined to be a naturally-occurring carcinogen once used in a wide variety of building products. Asbestos-containing materials (ACM) remain in commercial and industrial buildings and exist in certain facilities owned and operated by Falmouth Public Schools. The presence of ACM within a building does not, in and of itself, pose a hazard to human health. This policy is designed to control the possible health risks, which could be created if excessive asbestos fibers are released. This policy requires: Conducting surveys for ACM prior to purchasing or leasing new facilities, and removing or causing the removal of ACM prior to any planned disturbance and occupation by Falmouth Public Schools, in accordance with applicable federal, state, and local laws and regulations. Conducting surveys for ACM in currently-occupied facilities (for example, sprayedon or trawled-on surfacing material or thermal systems insulation). Confirming the existence of ACM by testing and removing or otherwise abating the existing ACM prior to any planned disturbance. Implementing operations and maintenance (O&M) programs in accordance with applicable laws, to manage and periodically assess the condition of ACM in Falmouth Public School facilities where ACM has been identified. Minimizing disturbance of ACM through awareness training and other management practices. Informing and training affected employees, in accordance with applicable federal, state, and local laws and regulations. ASBESTOS COORDINATION The Asbestos Program Manager directs the asbestos policy. Mr. Kevin Pimental, is the designated Asbestos Program Manager. He coordinates and implements Falmouth Public School s asbestos policy. Mr. Pimental and the entire facilities staff are responsible for minimizing the risks caused by the presence of ACM at the campus through proper execution of the O&M Program. All information regarding the identification of known or suspected ACM at each school building must be reported to the Program Manager who will maintain such records. 2-1

10 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA ASBESTOS CONSULTANT Falmouth Public Schools may retain a qualified and experienced asbestos consultant to assist the Program Manager as needed. The consultant is available to perform building surveys, assess conditions of ACM, test and monitor airborne fiber concentration levels, coordinate ACM emergency procedures, conduct asbestos awareness training, aid in the implementation of the O&M Program, and provide asbestos abatement design and monitoring services, as required. OCCUPIED PROPERTY Asbestos surveys are performed, as necessary; to assess the condition and potential hazards posed by ACM. Within the limits of operational factors, and as may otherwise be required by applicable law, ACM may be planned to be removed or otherwise abated, based upon the results of the surveys being conducted and arising out of and in conjunction with a planned alteration. Falmouth Public Schools strives to abate any ACM that is damaged, accessible, and friable to the extent it poses an immediate health threat in accordance with applicable laws and regulations. A qualified and licensed contractor (for example, pre-qualified by Falmouth Public Schools) performs abatement prior to or in conjunction with any renovation or demolition work, which could disturb ACM. ASBESTOS ABATEMENT Abatement and disposal of ACM is conducted in accordance with applicable laws and regulations and within generally accepted standards of the asbestos abatement industry. Falmouth Public Schools may employ the services of an experienced asbestos consultant to (1) design large abatement projects, (2) observe the work of abatement contractors, (3) inform applicable employees of the presence of ACM prior to the abatement work being performed, (4) conduct air monitoring before, during, and after abatement projects, as appropriate, and (5) prepare and submit final abatement project reports. Preparation of a specification or detailed scope of work may be necessary for major asbestos abatement activities. The specification shall be site-specific and detailed for a particular project or operation. Specifications / response action are required for all major work by abatement contractors, except for routine operations conducted under the guidance of the designated environmental consultant. Falmouth Public Schools only employs qualified and licensed asbestos abatement contractors for abatement projects, independent of the asbestos consultant and the licensed laboratory. 2-2

11 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA OPERATIONS AND MAINTENANCE PROGRAMS Falmouth Public Schools evaluates the Public Schools where friable ACM is located for purposes of developing and implementing appropriate operations and maintenance programs. The applicable and affected employees in an area in which ACM is found are notified of such presence, as required by law and, if the ACM is not required to be removed, appropriate employees are trained in awareness of asbestos to detect and report episodic incidents of damaged ACM to allow for the proper abatement. Falmouth Public Schools employees are directed not to engage in any activity which disturbs ACM. Only qualified and licensed asbestos abatement contractors shall conduct cleanup and maintenance of ACM. 1.1 THE ASBESTOS PROGRAM MANAGER The Asbestos Program Manager is Kevin Pimental. This information should be dated and kept current. 1.2 PROGRAM MANAGER (PM) The PM has implementation responsibility for the site-specific O&M Program. Any questions from Occupants regarding the program content or requirements should be directed to the PM who is responsible for program implementation and recordkeeping. The PM is the contact person and coordinator for all asbestos-related activities at each applicable facility. It is the PM s responsibility to coordinate all emergency response to asbestos fiber release episodes, scheduled asbestos abatement, and/or other operations and maintenance activities throughout each facility and communicates to affected parties. The PM is also responsible for providing access to all involved parties and security coverage to ensure smooth operation whenever any maintenance and operations activities disturb suspect ACM. The PM contacts the Asbestos Consultant and/or Abatement Contractor for the appropriate response plan. 1.3 APPROVED INDEPENDENT ASBESTOS CONSULTANT An Independent Asbestos Consultant, approved by Falmouth Public Schools, may be retained to perform visual inspections, air and/or bulk sampling, project oversight and provide recommendations, as necessary. The Approved Independent Asbestos Consultant works closely with PM to assist in determining appropriate response actions. 2-3

12 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA 1.4 MAINTENANCE PERSONNEL Maintenance personnel are required to stop any activities and notify their supervisor when their work potentially disturbs ACM. The supervisor then notifies the PM who determines the appropriate response actions. Figure 2 MAINTENANCE PERSONNEL PROGRAM MANAGER ASBESTOS CONSULTANT 1.5 CUSTODIAL STAFF Custodial personnel are required to notify the Program Manager when they encounter damaged suspect ACM. The Program Manager notifies the Asbestos Consultant to determine the appropriate response actions. Figure 3 MAINTENANCE PERSONNEL PROGRAM MANAGER ASBESTOS CONSULTANT 1.6 OFFICE PERSONNEL All office personnel are required to notify their Supervisor when they encounter damaged ACM. The Supervisor, along with the Industrial Hygiene Office determines the appropriate response to take. Figure 4 OFFICE PERSONNEL PROGRAM MANAGER ASBESTOS CONSULTANT 2-4

13 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA 2.0 AREAS CONTAINING ASBESTOS MATERIALS A summary of the areas where ACM are identified and their condition are presented as the inspections are completed. The bulk material assessment identified the materials that contain asbestos fibers. The assessments are limited to areas where readily accessible suspect ACM is located. Any additional suspect ACM uncovered during maintenance operations, renovation, and/or demolition activities not identified during the assessment is treated as an ACM until laboratory analysis proves otherwise. Records of assessments are kept by the Program Manager s Office. 2.1 ASBESTOS-CONTAINING MATERIALS In accordance with US EPA regulations, materials containing asbestos in concentrations1% or greater are considered to be asbestos-containing materials. All materials that contain less than 1% asbestos are considered to be an asbestos containing waste material. All suspect asbestoscontaining materials listed in Table 1, Chapter III are assumed to contain asbestos in concentrations greater than one percent until proven otherwise. 3.0 NOTIFICATIONS 3.1 REGULATORY NOTIFICATIONS FOR PLANNED AND EMERGENCY ASBESTOS ABATEMENT The USEPA, state, and local jurisdictional authorities must be notified in writing of each scheduled and emergency asbestos abatement project. Emergencies are notified by the Program Manager and or their designated Consultant. Notification waiver numbers are passed on to the contractor. The asbestos consultant or contractor ensures this notification is complete within the required notification period. 3.2 PROGRAM FOR INFORMING BUILDING OCCUPANTS Once the presence of ACM has been established in a facility, a notification program is initiated. The notification program serves two primary purposes: (1) it alerts affected parties of the presence of ACM in the facility, and (2) it provides basic information on avoiding the unnecessary disturbance of ACM. This notification program is based on USEPA and OSHA requirements. Notification of some building occupants, as necessary and/or required, and other affected individuals, including outside contractors, can be accomplished several ways. Four common methods are: Notify immediate area personnel either by or posting depending on project and area Distributing notices/letters either hard copy or via School web site 2-5

14 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA Holding awareness or informational seminars Shutdown list NOTE: The Program Manager is responsible to ensure that all outside contractors who may work in applicable facilities that are known to contain ACM, are properly informed in writing using the sample Contractor Notification letter, attached in Appendix C. 3.3 ASBESTOS AWARENESS TRAINING As required by OSHA, all in-house trade workers and custodial/maintenance housekeeping personnel who work in a facility that contains friable ACM are trained on awareness of asbestos. In addition, all outside contractors who work in the facility that contains friable ACM are notified, in writing, of ACM and made aware of their obligations to their employees. Awareness or informational seminars can be designed to enhance written notification. They serve to expand on relevant information while allowing attendees to raise questions. These seminars typically last no more than 30 minutes. The Program Manager provides notification to applicable employees and outside contractors regarding asbestos-related repair or abatement activities occurring within the building, as necessary and/or as required by applicable laws and regulations. 4.0 COMMON MAINTENANCE ACTIVITIES IMPACTING ACM Maintenance personnel may perform various general maintenance activities throughout a facility. Some examples of maintenance activities performed in specific locations, which may impact suspect or confirmed ACM, are listed below. This work must be performed by taking the proper care and precautions, so as not to disturb the ACM. Examples of Maintenance Activities Which Impact ACM Maintaining Thermal Pipeline System; Repairing Leaking Fittings Removal of Overlay Carpeting; Buffing, Sanding, or Drilling (coring) Floor Tiles Ceiling Tile Replacement Being Impacted Pipe Fitting Insulation Floor Tile and Mastic Materials or debris on top of ceiling tile Roof repair 2-6 Roofing materials

15 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA 5.0 SIGNS As required by applicable Federal, State and/or local laws and regulations, Program Manager informs occupants about the location and physical condition of ACM that may be disturbed. As required by the regulations, the Program Manager informs occupants about the presence of ACM by distributing written notices, by posting signs or labels in a central location where affected occupants can see them, or by holding awareness or information sessions. The Program Manager, when required by applicable laws or regulations, institutes a labeling system to identify ACM. These labels are prominently displayed and remain posted until ACM are removed. This labeling serves to alert and remind Maintenance Personnel, and possibly outside contractors, of the presence of the ACM and to avoid inadvertently disturbing the ACM. Warning signs are to be posted in areas where the airborne fiber concentrations can be reasonably expected to exceed the OSHA permissible exposure Client (PEL) of 0.1 fibers per cubic centimeter of air (f/cc). They serve to prevent unprotected individuals from entering those areas. The warning signs should read as follows: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA If during removal and repair operations airborne fiber concentrations are not reasonably expected to exceed the OSHA PEL, OSHA signs are not required. However, warning signs should be affixed to barriers to warn any bystanders of the potential danger in the area. During asbestos remediation performed by trained personnel, the Abatement Contractor shall be responsible for posting signs as required by OSHA regulations. The Program Manager is available to provide assistance with this task. 6.0 TRAINING REQUIREMENTS Employees of Falmouth Public Schools who perform routine maintenance or custodial activities are, at a minimum, trained in asbestos awareness. 2-7

16 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA 6.1 CUSTODIANS AND MAINTENANCE PERSONNEL Custodian, maintenance, and other trades personnel employed by Falmouth Public Schools receive the asbestos awareness training. The training consists of information regarding: Asbestos and its various uses and forms; Health effects associated with asbestos exposure; Locations of ACM identified within the building; Recognition of damage, deterioration, and delamination of ACM; The O&M Program; and Proper response to fiber release episodes. Custodial activities may be limited to cleaning and simple maintenance tasks where ACM may have the potential to be accidentally disturbed. Generally, employees do not directly contact friable ACM but must be directed to use the proper equipment when performing custodial maintenance (for example, cleaning asbestos-containing floor tile with nonabrasive brushes). 6.2 ASBESTOS PROGRAM MANAGER The Asbestos Program Manager is responsible for the implementation of the asbestos O&M Program. The Program Manager is trained on the management of asbestos. The training includes detailed information on the following: Asbestos Regulations They are made aware of relevant city, Commonwealth of State and Federal regulations, including those of OSHA and USEPA. Notification of Outside Contractors At times, Falmouth Public Schools may hire outside contractors for renovation work in the building. Not only must the Program Manager notify the contractor of the presence of asbestos, but he/she should also oversee the work practices to ensure that the renovation activities do not result in exposures of building occupants or employees. 6.3 DOCUMENTATION OF TRAINING Records or certificates for each employee trained must be kept on file with the Program Manager. The records should include the trainer, the date of training, and the content of the training provided. 2-8

17 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA 7.0 CLEANING Cleaning within specific areas of the facility is one of the primary objectives of the O&M Program. The Program Manager retains a licensed asbestos abatement contractor (i.e., prequalified by Falmouth Public Schools) to conduct initial cleaning in areas of the facility where damaged friable ACM are present before the initiation of any response action. In areas of the facility where damaged asbestos-containing thermal system insulation or surfacing material is present (i.e., an episodic event), the Program Manager retains a prequalified, licensed asbestos abatement contractor to clean all areas in the immediate vicinity. All cleaning activities are to be recorded and included in the O&M manual. Subsequent minor repair and routine maintenance is also conducted by a pre-qualified and licensed asbestos abatement contractor retained by the Program Manager. Initial Cleaning When damaged friable ACM is present, the asbestos abatement contractor must HEPA vacuum and, if possible, wet clean all areas in the immediate vicinity. This includes cleaning all surfaces, such as shelves, walls, light fixtures, equipment housing, exterior of ducts, with damp cloths or a HEPA vacuum. All mop heads, damp cloths, liquid wastes, debris, filters, or vacuum bags must be disposed as asbestos-contaminated waste. 7.1 AREAS WITH FRIABLE ACM Friable ACM (for example, thermal systems insulation on the pipes, elbows, and/or boiler and other vessels) should not be disturbed by anyone other than approved licensed abatement contractors. If any material dislodges because of accidental disturbance or water leak, the Program Manager should be contacted as soon as possible after the area is secured. The Program Manager contacts the approved Abatement Contractor to respond to the emergency. 7.2 AREAS WITH NON-FRIABLE ACM Non-friable ACM (for example, floor tile, mastic, and cementitious asbestos panels [Transite]) typically release fibers only when damaged or disturbed. Fiber releases can occur when workers drill, cut, abrade, break, or saw vinyl asbestos floor tile or any other non-friable material. General cleaning and maintenance, however, should not damage the material. USEPA and OSHA has instituted the following recommended guidelines when stripping wax or finish coat from asbestos-containing flooring which must be followed by the custodial staff. 2-9

18 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA Recommended Guidelines for Stripping Wax or Finish From Asbestos-Containing Flooring 1. AVOID STRIPPING FLOORS. Stripping of floors should be done as infrequently as possible, perhaps once or twice a year or less, depending on circumstances. The frequency should be carefully considered when floor maintenance schedules or contracts are written or renewed. 2. PROPERLY TRAIN STAFF. Custodial or maintenance staff that strips floors should be trained to operate the machines and pads and to use floor care chemicals properly and safely. 3. FOLLOW APPROPRIATE WORK PRACTICES. Custodial or maintenance staff that strip floors should follow appropriate work practices, such as those recommended here, under informed supervision. Directions from floor tile and floor wax product manufacturers on proper maintenance procedures should be consulted. 4. STRIP FLOORS WHILE WET. The floor should be kept adequately wet during the stripping operations. DO NOT perform dry stripping. Prior to machine operation, an emulsion of chemical stripper in water is commonly applied to the floor with a mop to soften the wax or finish coat. After stripping and before application of the new wax, the floor should be thoroughly cleaned while wet. 5. RUN MACHINE AT SLOW SPEED. If the machine used to remove the wax or finish coat has variable speeds, it should be run at slow speed (about rpm) during the stripping operations. 6. SELECT THE LEAST ABRASIVE PAD POSSIBLE. USEPA recommends that the machine be equipped with the least abrasive pad possible to strip wax or finish coat from asbestos-containing floors. 7. DO NOT STRIP FLOORS. Stop stripping when the old surface coat is removed. Over stripping can damage the floor and may cause the release of asbestos fibers. DO NOT operate a floor machine with an abrasive pad on unwaxed or unfinished floors. REMEMBER: Improperly removing asbestos-containing floor coverings could result in the release of high levels of asbestos fibers. USEPA recommends that you leave asbestoscontaining floor covering in place, provided the material is in good condition. However, proper maintenance procedures, such as those previously outlined, should always be followed. 2-10

19 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA 8.0 SPECIAL WORK PRACTICES FOR MAINTENANCE ACTIVITIES Before conducting any maintenance or repair work, which will damage or disturb ACM, the Program Manager or designated consultant shall inspect the area to determine appropriate action(s). Whenever the potential for release of asbestos fibers from ACM exists (for example, sanding floor tile or repairing a pipe leak), the Program Manager retains an outside asbestos abatement contractor to perform the work procedures in the aforementioned sections. Basic O&M procedures to minimize and/or contain asbestos fibers may include wet methods, use of mini-enclosures, use of portable power tools equipped with special local ventilation attachments, and avoidance of certain activities, such as sawing, sanding, and drilling ACM. NOTE: During O&M procedures, personal air monitoring must be performed by the Contractor. All asbestos waste (generated during these activities) must be handled in accordance with all local, state, and federal requirements. Maintenance activities can be divided into three categories with regard to their potential for disturbing ACM: Contact with ACM Unlikely - In-house Personnel Maintenance activities or repairs, which can be performed without contacting or disturbing the ACM, require little more than normal care and good workmanship and can be performed by inhouse personnel. These include, but are not to: Repairing non-acm insulated pipes or valves without disturbing other ACM. Routine cleaning activities All surfaces should be isolated to remove any settled fibers in the event that ACM are disturbed. An asbestos abatement contractor responds to the asbestos fiber release episode. Contact with ACM Not Likely but Possible - In-house Personnel Maintenance activities or repairs that may have the potential to cause accidental disturbance of ACM require some precautions. In-house associates may perform this work only if the proper precautions are instituted to minimize the potential ACM disturbance. For example, special cleaning, possibly area isolation and respiratory protection, may be needed if the chance of disturbance is likely. Activities that fall into this category include, but are not to: Routine cleaning activities Working on a fixture near thermal system ACM.; 2-11

20 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA Working on a fixture above suspended ceilings where asbestos-containing sprayed-on fireproofing or trawled-on acoustical material is present; Installation of telecommunication or electrical conduits above suspended ceiling; and Repairing of a pipe that is not insulated with ACM but disturbs ACM on nearby pipes. The Program Manager should review any scope of work and work area to determine whether the Asbestos Consultant should be contacted to discuss and/or determine cleanup, repair, or removal requirements prior to allowing maintenance activities to commence. Contact with ACM Likely or Intended - Only by Outside Asbestos Contractor Maintenance activities or repairs that involve intentional manipulation or disturbance of ACM require special work practices, as outlined in this O&M manual. A pre-qualified outside abatement contractor must remove ACM before in-house personnel perform their duties. Personal protective equipment, including respirators and Tyvek suits, and personal air monitoring are required when ACM is disturbed. Typical activities include, but are not to: Installing new building components over existing ACM floor tiles; Replacing or moving a ceiling tile with ACM above; Replacing or moving a ceiling tile that contain ACM; Replacing an old roof-mounted air-handling unit insulated with ACM; Replacing carpet with ACM floor tile beneath; Repair a leaking pipe insulated with ACM and; Repairing acoustic plaster ceilings containing ACM. Prior to performing any maintenance activities that disturb ACM, the Program Manager shall contact the Asbestos Consultant to provide area air monitoring before, during, and after the ACM disturbance, if necessary. NOTE: Under no circumstances will any in-house Falmouth Public Schools Personnel perform this type of work or any other abatement work. Failure to adhere to this policy will be subject to disciplinary actions, up to, and including, discharge. 2-12

21 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA 9.0 SPECIAL WORK PRACTICES FOR PLANNED RENOVATION WORK Future renovations may involve disturbing ACM or presumed ACM and may also uncover building materials previously hidden that may contain asbestos. Work, such as moving walls, adding wings, and replacing heating or air-conditioning systems may involve breaking, cutting, or otherwise disturbing ACM. When building renovations are scheduled, it is the responsibility of the Program Manager to notify the Asbestos Consultant of any planned alteration or renovation activity so that they can assist in identifying ACM that may be impacted by testing or reviewing previous survey reports. All parties must be aware of potential ACM disturbance early in the project planning stage to determine appropriate actions. Partial or full removal may be necessary before renovation. If partial or full removal is necessary, the Program Manager shall select an asbestos abatement contractor to perform the ACM removal work. The Asbestos Consultant shall provide an asbestos project designer, licensed in the State of Massachusetts, to develop guideline specifications or work plans in accordance with US EPA, OSHA, and Commonwealth of Massachusetts regulations, for use by the asbestos abatement contractor. The Asbestos Consultant shall ensure that the asbestos abatement contractor performs all work in compliance with applicable Federal, State, and local laws and regulations. The Program Manager shall maintain records of the asbestos removal work. These records shall include copies of the following documents: project notifications and waivers; specifications or work plans (response actions); asbestos workers medical records and licenses air sampling reports; closeout documentation provided by the independent consultant; and waste disposal per Client s and waste shipment records. A copy of these records shall remain at the facility with the Program Manager EMERGENCY RESPONSE PROCEDURES FOR EPISODIC EVENTS As long as ACM remain in the facility, a fiber release episode could occur if the ACM is inadvertently disturbed. Falmouth Public Schools personnel should immediately report to their supervisor and Industrial Hygiene Office the presence of suspect asbestos-containing debris on the floor, water or physical damage to the ACM, or any other evidence of a fiber release. 2-13

22 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA The Program Manager and/or Asbestos Consultant may then take the following steps, with assistance from the Maintenance Supervisor: Evaluate the extent of ACM damage; Demarcate contaminated areas to prevent entry by unauthorized personnel; Isolate the contaminated area by sealing doors and vents with polyethylene sheeting and duct tape and shutting off or modifying air handling systems or any other notification appropriate to restrict access or prevent exposure in other areas of the facility; Post a warning sign outside the contaminated area; and Fill out a Fiber Release Episode form, located in Appendix B, and submit and maintain at the main office and to the appropriate AHERA Plan. The Program Manager may then take the following steps: Contact the Asbestos Consultant; the Asbestos Consultant assesses the situation and recommend further courses of actions; Contact a pre-qualified asbestos abatement contractor; If significant damage or delamination of ACM has occurred, consider total removal of the ACM by a pre-approved abatement contractor in the affected areas and replacement with a non-asbestos containing substitute; and Keep all records associated with the fiber release episode, including asbestos abatement contractor submittals (medical information, waste shipment records, etc.), Asbestos Consultant reports (air sampling data), and a fiber release episode report (see Appendix B). NOTE: The Program Manager secures and maintains necessary documentation and records associated with the work (See Section 12.0). To respond to fiber release episodes, the following materials are available to trained Maintenance staff for the purpose of isolating areas of damaged ACM. 2-14

23 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA Minor Fiber Release Episodes A minor fiber release episode is one in which less than 3 square feet or 3 linear feet of friable asbestos containing material is dislodged. Minor fiber release episodes can be treated with standard wet cleaning and HEPA vacuum techniques by the building management in-house Associated Project Workers. Examples of minor fiber releases include: A small number of fallen or dislodged ceiling tiles. Three or less broken or dislodged floor tiles. Minor water leaks on unabated floors. Procedures for Control: 1. The occupant or worker discovering the fiber release should alert the Asbestos Coordinator or, if unavailable, the building management. 2. At least two Associated Project Workers will be assigned to proceed to the area to evaluate the problem. If the problem is not minor then the area should be isolated (See Section 8.2, Major Fiber Release Episode) and the Asbestos Coordinator contacted. 3. The Asbestos Coordinator or designee will require that unauthorized personnel temporarily evacuate the room or area. 4. While one worker stays at the location of the fiber release, the other worker should retrieve the following: a) Warning signs. b) Personal respirators and disposable suits for both workers. c) Airless water sprayer and amended water. d) HEPA vacuum. e) Clean rags. f) 6 mil plastic bags with asbestos waste labels. g) Any repair materials that may be necessary as a result of the fiber release. h) Personal air pump and filter cassette (if monitoring will be performed). i) Pen, paper, and appropriate forms (Sample Job Request Form [Form C-2] and Asbestos Repair/Removal Form [Form C-3]). 5. One worker, who will perform the cleaning, should don a protective suit and respirator, perform fit checks for the respirator, and put on the personal air pump and filter cassette (unless previous personal air sampling demonstrates exposure is below 0.1 f/cc). The other worker will prevent others from entering the area, retrieve any other needed supplies, and record any information; the protective suit and respirator are available if the second worker must come within the cleaning area to assist. 6. Thoroughly saturate the debris using the sprayer and amended water. Use caution in 2-15

24 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA areas where leaking may occur or finishes may be damaged. 7. Place the debris in the labeled 6 mil plastic bag for disposal. 8. HEPA vacuum all surrounding areas, including floors, fixtures, and other surfaces, at least 10 feet around the edges of the fallen debris. 9. Repeat HEPA vacuuming, as above. 10. For all hard surfaces, wipe the area with a wet rag; for all carpets or permeable surfaces, perform HEPA vacuuming a third time. 11. If the ACM or other area requires repair, perform the repair (See Section 9, Procedures For Planned Activities). 12. HEPA vacuum the disposable suit. 13. Carefully remove the disposable suit, turning inside out, and place the suit in an asbestos disposal bag. Remove the personal air pump if used, and record information. 14. Clean all tools and materials. Place all rags and permeable materials used in the asbestos waste bag. 15. Remove the respirator and clean with a damp cloth, placing the cloth in the asbestos disposal bag. 16. Double bag the disposal bag with another 6 mil plastic bag labeled as asbestos waste. Place the bag into a covered bin, and transport the waste to a designated area in building. 17. Call the Department Environmental Protection for an emergency waiver number. 18. Full documentation of the episode should be made, including reports from all involved parties, the amount of ACM disturbed, and all measures taken. (Minor Release Cover Letter [A-6], Sample Job Request Form [C-2] and Asbestos Repair/Removal Form [C-3]). Major Fiber Release Episode A major fiber release episode is one in which more than 3 square feet or 3 linear feet of friable asbestos containing material is dislodged. Major fiber release episodes can be serious events, and require that licensed and certified asbestos contractors be used for clean-up and decontamination. The Associated Project Workers and Asbestos Coordinator will be the first ones on site to minimize contamination and exposure to building occupants. Examples of a major fiber release episode include, but are not limited to: A section of ceiling collapses on an unabated floor. A major water leak occurs on an unabated floor. Procedures for Control: 1. The occupant or worker discovering the fiber release should immediately alert the Asbestos Coordinator or designated representative. 2-16

25 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA 2. At least two trained maintenance workers and the Asbestos Coordinator will proceed to the area to begin emergency procedures. 3. The Asbestos Coordinator or designee will require that all personnel evacuate the room or area. Personnel will not take any items out of the area that are contaminated or potentially contam 4. The area will be isolated as soon as possible. Doors will be locked from the inside (escape corridors must remain in operation) and signs posted to prevent unauthorized personnel from ente "DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA" 5. The area is considered contaminated, and only trained personnel wearing suits and respirators may enter. 6. An Asbestos Consultant should be notified immediately to assist in evaluating the extent of contamination and measures to be taken. 7. The air handling system to the contaminated area must be shut off or temporarily modified to prevent the distribution of fibers to other areas of the building. Further evaluation by the Asbestos Consultant may result in the ability to reactivate the HVAC system, however prudent measures should be taken until an evaluation is made. If necessary, doors, windows, and air registers should be sealed with 6 mil plastic sheets and duct tape. 8. The Asbestos Consultant(s) will determine the extent of contamination through visible inspection and air monitoring in the surrounding vicinity and throughout the building, as necessary. If there is any doubt as to whether the released debris is asbestoscontaining, bulk samples may be taken and analyzed. Attention should be paid to whether there is the possibility of future fiber release episodes from the same source. 9. All procedures for removing ACM or cleaning the area after a major fiber release episode must be conducted by a licensed and certified contractor. The Associated Project Workers may only enter the area initially to isolate the area or begin other emergency procedures and may not handle the asbestos containing material. Federal and states regulations specify this in order to prevent further release of fibers due to improper handling of lack of full containment procedures. There may be some cases where the workers will have to disturb small amounts of asbestos in order to prevent further contamination. 10. All procedures for removing the disturbed ACM and cleaning the area must be in accordance with federal, state, and local regulations for large scale asbestos abatement, including containment barriers, negative pressure ventilation, wet methods, personal respiratory protection and protective clothing, decontamination 2-17

26 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA facilities, waste disposal and air testing. This abatement should be done as soon as possible. 11. Based on inspection and air monitoring results, the Asbestos Coordinator, Asbestos Consultant will determine which additional areas need to be isolated, abated, cleaned, or repaired, if any, and set up a schedule with the licensed asbestos contractor to carry out all work. 12. Full documentation of the episode should be made, including reports from all involved parties, the amount of ACM disturbed, all measures taken, and all air monitoring results. (Major Release Cover Letter [Letter A-7], Hygienist Report, Contractor Report, Air Monitoring Report, all other pertinent reports). FIBER RELEASE EPISODE SUPPLIES Respirator (half-face) Barricade Tape (3 inches x 1,000 feet) Duct Tape (3 inch x 60 yard/roll) Polyethylene Sheet (6-mil) sheet (20 feet x 100 feet) Sign - DANGER (14 inches x 20 inches) Sign - KEEP OUT Surfactant Sprayer Any additional response action for fiber release episodes is determined by the Asbestos Consultant and conducted by a pre-qualified asbestos abatement contractor PERIODIC ACM SURVEILLANCE 11.1 INSPECTION Periodic review of the O&M Program is essential to see that the program objectives are being met. A key feature of the review is reinspection of all ACM in each of the school buildings. The, periodic surveillance combined with ongoing reports of changes in the condition of the ACM made by employees, ensure that any damage or deterioration of the ACM is detected and corrective action taken. Periodic surveillance should be conducted, at a minimum, annually; and more frequently where necessary, as determined by the Asbestos Consultant. Highly friable and deteriorated material, such as thermal ACM and highly accessible ACM, may require periodic surveillance every 6 months to determine any changes in conditions. Forms, which can be used to document the reassessment of materials previously determined to 2-18

27 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA contain asbestos, are provided in Appendix B. Completed forms should be retained in the asbestos building file located at the Program Manager s with other periodic surveillance materials ASBESTOS SAMPLING AND ANALYSIS Two types of asbestos measurements are required based on specific conditions as part of the O&M Program. Bulk samples to determine if asbestos is present; and Air monitoring to determine airborne fiber and asbestos fiber concentrations Bulk Sampling Bulk material sampling has been performed at the Teaticket School Building some sampling is listed at the Morse Pond all other Falmouth schools are scheduled to have bulk sampling conducted. All suspect ACM is presumed to be ACM. Additional assessments may be necessary to clarify, update, or identify ACM in the buildings. Before maintenance, renovation, or contractor work is performed in any area, the Program Manager must be notified to determine if ACM are present. If suspect ACM have not been analyzed for asbestos in a state certified laboratory, the Program Manager shall have the Commonwealth of Massachusetts Licensed Asbestos Inspector perform bulk sampling, if necessary. Results from the bulk material sampling assessment should be maintained by the Program Manager s Office and is distributed to appropriate personnel, as necessary and in accordance with applicable federal, state, and local regulations Air Sampling Air samples are defined by what is being measured and by the requirements of regulations. Prevalent (Background) Level Air Sampling Prevalent level air sampling is used to determine baseline levels of airborne fibers and/or asbestos fibers in the facilities. It should be used in areas where friable ACM are present. Baseline airborne fiber and/or asbestos concentrations should be established after the O&M Program is initiated. Periodic air sampling (perhaps conducted simultaneously with the periodic surveillance) would then be used to measure changes in airborne fiber concentrations with respect to the baseline. Prevalent air sampling is initially done by using phase contrast microscopy (PCM) and, when necessary, follow-up with transmission electron microscopy (TEM). 2-19

28 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA The air sampling should be performed by a Commonwealth of Massachusetts, Department of Labor Standards (MA DLS) Licensed Asbestos Inspector or Project Monitor and analyzed in a MA DLS certified laboratory. Copies of the air sampling results should be sent to the Program Manager. Clearance Sampling This sampling is used to determine if an area meets the Commonwealth of Massachusetts Department of Labor Standards (DLS) regulatory criteria for clearance after a Response Action, renovation, or remodeling has been completed. The Program Manager should be familiar with the different types of sampling and analyses RECORDKEEPING The Program Manager (PM) retains all records related to the O&M Program, such as: The written O&M Program itself, including work practices (PM and Consultant); data (location of ACM); Copies of notification (PM); Description of times, dates, attendees of training programs, and all outlines and written materials disseminated (PM); Copies of all documentation of maintenance, renovation, and emergency response actions performed (PM and Consultant); Periodic ACM surveillance records, including all air sampling data and photographs (PM and Consultant); Bulk and air sampling reports (PM and Consultant); Chain-of-custody forms for laboratory samples (PM and Consultant); Contractor insurance forms (PM); and Waste disposal and waste shipment records (PM). Falmouth Public Schools shall maintain all records associated with asbestos-related activities (for example, testing and medical records) for a period of at least 30 years ASBESTOS-CONTAINING WASTE MATERIAL STORAGE AND TRANSPORTATION Asbestos-containing waste materials generated during O&M procedures should be stored and transported as follows: In leak-tight containers with the following warning labels: 2-20

29 FALMOUTH PUBLIC SCHOOLS Asbestos Operations and Maintenance Program Falmouth, MA DANGER ASBESTOS MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS AUTHORIZED PERSONNEL ONLY 9-NA2212 -PG III Waste should also be labeled with Falmouth Public School name, the location of the school building where the waste was generated, and the initial accumulation date. Waste should not be stored in the facility longer than 90 days from initial accumulation. These containers should be temporarily stored on the premises in a secured container or storage area, for example, a trash can with a locking top or behind a locked cage or closet. All waste must be stored wet. All waste should be transported by a licensed asbestos waste hauler. The waste hauling vehicle should be enclosed to contain the transported waste. An ACM waste shipment record must accompany all waste materials transported to the USEPA-approved landfill. Falmouth Public Schools must receive the completed waste shipment record from the disposal site within 35 days of the date the waste was accepted by the initial waste hauler. If it is not received within this timeframe, the Program Manager must contact the transporter and/or the operator of the landfill to determine the status of the waste shipment record and report their findings to the Project Manager s Office. If the completed waste shipment record is not received within 45 days, a report must be submitted to the local USEPA Regional Office responsible for administering NESHAP regulations. 2-21