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Contract 36293 (2)
[ r r l I f l l l CITY SECRETAR'(3 l :£15 CONTRACT NO. Q Between CITY OF FORT WORTH and EAGLE CONSTRUCTION AND ENVIRONMENTAL SERVICES, L.P. For Alternative Asbestos Control Method (AACM) Oak Hollow Office Building 5901 Boca Raton Fort Worth, Texas Environmental Management Department December 2007 I • - 0 I I I STATE OF TEXAS § § § § KNOW ALL PERSONS BY THESE PRESENTS COUNTIES OF TARRANT§ DENTON AND WISE CONTRACT FOR THE DEMOLITION OF THE OAK HOLLOW APARTMENT OFFICE BUILDING LOCATED AT 5901 BOCA RATON BOULEVARD 1bis agreement is entered into by and between the City of Fort Worth, Texas, a home-rule municipal corporation situated in Tarrant, Denton and Wise Counties, Texas, hereinafter called "City," acting herein through Libby Watson, its duly authorized Assistant City Manager, and Fagle <hBt:nrtim & Ib.rirm1Blta1. Srvs,L.Jhereinafter called "Contractor," by and through Mm:: ti-JJUM?O , its duly authorized President/Vice President. In consideration of the mutual promises and benefits of this contract, the City and Contractor agree as follows: 1. DEFINITIONS In this contract, the following words and phrases shall be defined as follows: AACM shall mean Alternative Asbestos Control Method. Amended Water shall mean Kiddie Fire Foam as determined by the EPA. Asbestos shall mean the asbestiform varieties of chrysotile, amosite, crocidolite, tremolite, anthophyllite, and actinolite and all materials containing one percent or more of any of those substances. Asbestos Abatement shall mean the removal, the encapsulation or the enclosure of asbestos. Asbestos Abatement Activity shall mean asbestos abatement and any on-site preparations or clean up related to the abatement. Asbestos-Containing Material (ACM) shall mean materials or products that contain more than one percent (1.0%) of any kind or combination of asbestos, as determined by Environmental Protection Agency (EPA) recommended methods as listed in Section 40 of the Code of Federal Regulations, (CFR) Part 763, Subpart F and 40 CFR 763 Subpart E, Appendix A. 1bis means· any one material component of a structure. Demolition of 5901 Boca Raton Blvd. CRL l2.0S .07v3 Page I I I I I I I I I Asbestos Removal shall mean any action that dislodges, strips, or otherwise takes away asbestos containing material (ACM). City shall mean the City of Fort Worth, Texas. Contract Documents shall mean this document and all other exhibits as described in this contract and all ancillary documents. Contractor shall mean f;lgJe Qun:nrtim & fuiirammal .aervieee, L.P. DEM shall mean the Department of Environmental Management. Director shall mean the Director of the City of Fort Worth's Environmental Management Department. EPA shall mean the United States Environmental Protection Agency. NESHAP shall mean the United States Environmental Protection Agency National Emissions Standards for Haz.ardous Air Pollutants, as described in Title 40 CFR Part 61. Regulated Asbestos-Containing Material <RACM) shall mean (a) friable asbestos material, (b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by forces expected to act on the material in the course of demolition or renovation operations. DSHS shall mean the Texas Department of State Health Services. Structure shall mean the Oak Hollow Apartment office building located at 5901 Boca Raton Boulevard, Fort Worth, Texas. 2. TERM AND TIME TO COMPLETE This contract shall be effective from the date of its execution by both parties, until the completion of all Contractor services as provided in Section 3, or January 31, 2008, whichever date occurs first, notwithstanding the survival of the terms and rights in Section 7. Contractor agrees to begin demolition activities of the structure as instructed by the City. City shall use its best effort to provide Contractor with reasonable notice of the date of demolition, however, Contractor acknowledges and waives the right to object to the City decision to postpone or cancel the date of demolition. Contractor shall complete the demolition of the Structure within 24 hours of the commencement of the demolition activities. Demolition of5901 Boca Raton Blvd. CRL 12.05 .07v3 Pagc2 I I I I I 3. SCOPE OF CONTRACTOR'S SERVICES A. Contractor shall provide all the labor, materials, and equipment necessary for performing the demolition of the Structure at 5901 Boca Raton Boulevard, Fort Worth, Texas using the AACM in strict compliance with the Quality Assurance Project Plan (QAPP) attached as Exhibit A, as instructed by the City. B. C. Contractor understands and hereby acknowledges that the use of the AACM is done with the EPA and DSHS' discretion of enforcement to allow EPA and the City to evaluate the AACM. Contractor further understands and acknowledges that the EPA has issued a letter of No Action Assurance attached as Exhibit B, and DSHS has issued a letter of similar assurance attached as Exhibit C. Contractor understands and acknowledges that the discretion of enforcement from the EPA applies only to the NESHAP provisions in 40 CFR Part 61, Subpart M, §§61.145(c)(l) thru (6). Contractor agrees that Contractor shall comply with all other DSHS and NESHAP regulations in the performance of the demolition of the Structure. In compliance with the QAPP, Contractor agrees to the following specifications for the demolition of the Structure: 1. Wetting Process • Structure shall be thoroughly and adequately wetted, as defined by NESHAP, with Amended Water (surfactant addition) one-day prior to demolition, the morning prior to demolition, and during demolition activities, and during debris handling and loading. • Amended Water will be applied with a minimum of two (2) fire hoses. • Amended Water will be delivered in a manner that most effectively wets the demolition debris and controls airborne emissions. • Direct high-pressure impact of structure, structure components and resultant structure debris shall be prohibited at all times. • · Visible foaming must occur at impact of the spray mist and the structure. • Wetting process will occur in the aforementioned stages with the interior and the exterior portions of the structure addressed. • Interstitial wall spaces and cavity areas shall also be adequately wetted. 2. Wetting Schedule • One day prior to initiating demolition activities, access openings shall be made into attic spaces from the exterior. • Structure will be pre-wet from the interior and then from the exterior access opemngs. • Once the pre-wetting begins, access into the Structure shall be prohibited. • Structure shall be re-wet through exterior access openings on the day demolition activities are to begin, prior to demolition commencing. Demolition of5901 Boca Raton Blvd. CRL 12 .05 .07v3 Page 3 0 I I I I I I I • Wetting shall continue through demolition of the Structure and during the loading of debris. 3. Demolition • Contractor shall minimize breakage of ACM. • Demolition activities shall be conducted in a timely manner. • Debris generated shall be removed from the demolition site the same day that it is generated. 4. Visible Emissions • Demolition activities shall not generate visible emissions. • If a representative from the City or the EPA determines that visible emissions have occurred or are occurring, or if the Contractor has actual knowledge of such emissions, activities shall cease until the area of concern is adequately wetted. Once the area of concern is determined to be adequately wet, the demolition activities shall continue. 5. Weather Restrictions • Activities may be halted in the case of inclement weather by the determination of the City. • Visible dusting in the area of demolition shall warrant a stoppage in operations. 6. Monitoring Requirements • Contractor shall comply with all applicable OSHA requirements including but not limited to 29 CFR 1910 and 1926. • Contractor shall provide personal air monitoring for all workers within the bermed area including the heavy equipment operator. 7. Waste Handling • All waste geneg from the demoliti~n. site during the day shall be removed and disposed of at ,~,,.;-~ ~ -l.ew.isvilJ.e . . • Contractor shall transportand -dispose of all debris in accordance with all state and federal regulations • Waste transport containers shall be leak-proof. • The containers will be double-lined with at least 6-mil thick polyethylene sheeting and subsequently sealed along the top in order to prevent leakage from the trailer. • An application of expandable spray foam between the trailer and the end-gate shall be applied prior to installing the polyethylene liners in order to prevent leakage from the trailer during transport. • The transport vehicle and trailer will be decontaminated prior to leaving the controlled (bermed) area. Decontamination shall include but not be limited to the removing of all debris in the bermed area and the rinsing of the vehicle, trailer and undercarriage, including wheels and tires with the use of Amended Water. • All demolition debris shall be disposed of as RACM and no sorting of debris will be allowed for this project. Demolition of 5901 Boca Raton Blvd. CRL 12.05 .07v3 Page4 :i, I I I I I I I I I I I I I • All PPE shall be disposed of as RACM and non-disposable PPE shall be thoroughly decontaminated according to OSHA standard practices. 8. Applied Water Collection and Containment • No potentially contaminated water is permitted to leave the site during demolition activities. • All impervious surfaces remaining will be thoroughly washed with Amended Water prior to site closure. • Best Management Practices (BMPs) shall be utilized in order to prevent water runoff. • BMPs shall provide containment of excess amounts of applied water with collection station(s) strategically located to remove the runoff water from the bermedarea • Collected water shall be pumped into holding tanks of sufficient size for disposal as RACM or filtered with a series of filters in order to remove any fibers larger than five microns. If filtered, this water may be transported to the local POTW for disposal. • BMPs should extend at least 25' horizontally from the structure in order to allow for movement of demolition equipment and loading of waste trailers. • Applications of at least 6-mil polyethylene sheeting over bermed areas is required. • Polyethylene sheeting utilized will disposed of as RACM. 9. Potentially Contaminated Soils • Following the removal of all demolition debris, bare soils within the demolition bermed area will be excavated to a depth of at least 3" below ground surface and disposed of as RACM. 10. Additional Workplace Requirements • One layer of 6-mil polyethylene lining will be placed surrounding the immediate adjacent side of the apartment buildings located adjacent north and south of the project building. • A 75' long by 20' wall shall be constructed along the tree line located adjacent east of the project building. The wall shall be covered with at least one layer of 6- mil polyethylene and the wall will be anchored sufficiently to prevent toppling or falling . • Only the trailer of debris transport vehicles shall be allowed to enter the bermed area The tractor portion shall remain outside of the bermed area and the driver shall remain inside the tractor cab during loading operations and sealing of the polyethylene sheeting around the load. • Personnel access will be required for the adjacent roof-top areas in order to install air-monitoring devices and for hourly calibration and adjustments during the course of the project. • Portable toilet facilities shall be stationed at the project location in an area that is outside the Contamination Reduction Zone (CRZ). Demolition of5901 Boca Raton Blvd . CRL l2.0S .07v3 Page 5 D I I I I I I I I D. Contractor agrees that it shall maintain during the term of this contract, current and appropriate federal, state, and local licenses and permits to perform the services contained in this contract. E. F. A. B. A. B . Contractor agrees that it shall not assign, delegate, or subcontract any of the work described in this contract without first obtaining express written approval to do so from City. Contractor shall remain fully responsible for the satisfactory performance of such work and shall remain fully bound by the terms of this contract. City shall have the right to approve or reject all subcontractors retained by Contractor to perform services under this contract. Contractor shall attend Pre-Demolition Meeting(s) with the City to discuss all aspects of the Project. 4. CITY'S RESPONSIBILITIES City shall designate a City representative to provide timely direction to the Contractor and render City decisions. · City shall provide timely notice to Contractor of the start of the demolition project. 5. COMPENSATION In consideration for the work performed by Contractor under this contract, City shall pay Contractor a sum not to exceed twenty-four thousand nine hundred fifty dollars ($24,950.00). Payment shall be based on the unit price charges as set forth in exhibit D . Mobilization of equipment is for travel time from Contractor's place of business to 5901 Boca Raton Boulevard and from 5901 Boca Raton Boulevard to Contractor's place of business only. C. City shall only be billed for actual work performed. Idle time on the site shall not be billable. D. City shall make payment within thirty (30) days of receiving a correct invoice from Contractor. City is responsible for notifying Contractor of any questions concerning an invoice. In the event of a disputed or contested billing, only that portion so contested will be withheld from payment, and the undisputed portion will be paid. The City will exercise reasonableness in contesting any bill or portion thereof. No interest will accrue on any contested portion of the billing until mutually resolved. E. Contractor shall receive no compensation for delays or hindrances to the work, except when direct and unavoidable extra cost to Contractor was caused by City's failure to Demolition of 5901 Boca Raton Blvd . CRL l2.0S .07v3 Page 6 D I I I I provide information, if any, which it is required to do . When extra compensation is claimed, a written statement thereof shall be presented to the City. 6. INSURANCE Contractor agrees to furnish the following proof satisfactory to City, that it or it's subcontractor(s) has secured and paid for the following policies ofliability insurance for the term of this contract covering all risks related to the work of this project. A . Insurance coverage and limits: 1. Commercial General Liability Insurance o $1,000,000 each occurrence o $2,000,000 aggregate 2. Professional Liability Insurance -NOT APPLICABLE. 3. Automobile Liability Insurance - 4. 5. a Coverage on vehicles involved in the work performed under this contract: o $1,000,000 per accident on a combined single limit basis QI: o $500,000 bodily injury each person; $500,000 bodily injury each accident; and $250,000 property damage b. Uninsured/Underinsured Motorist: o $20,000 bodily injury each person; $40,000 bodily injury each accident; and$15,000 property damage each accident The named insured and employees of Contractor shall be covered under this policy. The City of Fort Worth shall be named an Additional insured on Endorsement TE 9901 or equivalent, as its interests may appear. Liability for damage occurring while loading, unloading and transporting materials collected under the Contract shall be included under this policy. Worker's Compensation - o Coverage A : statutory limits o Coverage B: $100,000 each accident $500,000 disease -policy limit $100,000 disease -each employee Environmental Impairment Liability (EIL) and/or Pollution Liability - $2,000,000 per occurrence. EIL coverage(s) must be included in policies listed in subsections 1 and 2 above; or, such insurance shall be provided under separate policy(s). Liability for damage occurring while loading, unloading and transporting materials collected under the contract shall be included under the Automobile Liability insurance or other policy(s). Demolition of S901 Boca Raton Blvd . CRL l2.0S .07v3 Page 7 D I I I I I 6. Asbestos Abatement Insurance -Sl,000,000 each occurrence with no ~ Sunset Clause(ir, !>e prov,JeJ f>; U,~.J q;J,os../o$ svbco,rlt-,,clr,r J. ~ B. Certificates of insurance evidencing that the Contractor has obtained all required insurance shall be delivered to the City prior to Contractor proceeding with the contract. 1. Applicable policies shall be endorsed to name the City an Additional Insured thereon, as its interests may appear. The term City shall include its employees, officers, officials, agents, and volunteers as respects the contracted services. 2. ' Certificate( s) of insurance shall document that insurance coverage specified according to items in section (a) above are provided under applicable policies documented thereon. 3. Any failure on part of the City to request required insurance documentation shall not constitute a waiver of the insurance requirements. 4. 5. 6. A minimum of thirty (30) days notice of cancellation or material change in coverage shall be provided to the City. A ten (10) days notice shall be acceptable in the event of non-payment of premium. Such terms shall be endorsed onto Contractor's insurance policies. Notice shall be sent to Brian Boemer, Director, Department of Environmental Management, City of Fort Worth, 1000 Throckmorton, Fort Worth, Texas 76102. Insurers for all policies must be authorized to do business in the state of Texas or be otherwise approved by the City; and, such insurers shall be acceptable to the City in terms of their financial strength and solvency. Deductible limits, or self-insured retentions, affecting insurance required herein shall be acceptable to the City in its sole discretion; and, in lieu of traditional insurance, any alternative coverage maintained through insurance pools or risk retention groups must be also approved. Dedicated financial resources or letters of credit may also be acceptable to the City. 7. Applicable policies shall each be endorsed with a waiver of subrogation in favor of the City as respects the contract. 8 . The City shall be entitled, upon its request and without incurring expense, to review the Contractor's insurance policies including endorsements thereto and, at the City's discretion, the Contractor may be required to provide proof of insurance premium payments. Demolition of 5901 Boca Raton Blvd . CRL l2.0S.07v3 Page 8 .3.z J 0 B I I I I I 9. The Commercial General Liability insurance policy shall have no exclusions by endorsements unless the City approves such exclusions. 10. The City shall not be responsible for the direct payment of any insurance premiums required by the contract. It is understood that insurance cost is an allowable component of Contractor's overhead. 11. All insurance required in section (a) above shall be written on an occurrence basis in order to be approved by the City. 12. Subcontractors to the Contractor shall be required by the Contractor to maintain the same or reasonably equivalent insurance coverage as required for the Contractor. When subcontractors maintain insurance coverage, Contractor shall provide City with documentation thereof on a certificate of insurance. Notwithstanding anything to the contrary contained herein, in the event a subcontractor's insurance coverage is canceled or terminated, such cancellation or termination shall not constitute a breach by Contractor of the contract. 7. INDEMNIFICATION A. For purposes of this contract, the phrases "Environmental Damages" and "Environmental Requirements" shall be defined as stated below: 1. Environmental Damages shall mean all claims, judgments, damages, losses, penalties, fines, liabilities (including strict liability), encumbrances, liens, costs, and expenses of investigation and defense of any claim, whether or not such claim is ultimately defeated, and of any good faith settlement or judgment, of whatever kind or nature, contingent or otherwise, matured or unmatured, foreseeable or unforeseeable, including without limitation reasonable attorney's fees and disbursements and consultant's fees, any of which are incurred as a result of handling, collection, transportation, storage, disposal, treatment, recovery, and/or reuse of waste pursuant to this contract, or the existence of a violation of environmental requirements pertaining to, and including without limitation: a. Damages for personal injury and death, or injury to property or natural resources; b. Fees incurred for the services of attorneys, consultants, contractors, experts, laboratories and all other costs in connection with the investigation or remediation of such wastes or violation of environmental requirements including, but not limited to, the preparation of any feasibility studies or reports of the performance of any cleanup, remediation, removal, response, abatement, containment, closure, restoration or monitoring work required by any federal, state or local Demolition of 5901 Boca Raton Blvd. CRL 12 .05 .07v3 Page9 I I I I I I I I I I I I B. 2. governmental agency or political subdivision, or otherwise expended in connection with the existence of such wastes or violations of environmental requirements, and including without limitation any attorney's fees, costs and expenses incurred in enforcing this contract or collecting any sums due hereunder; and c. Liability to any third person or governmental agency to indemnify such person or agency for costs expended in connection with this Agreement. Environmental requirements shall mean all applicable present and future statutes, regulations, rules, ordinances, codes, licenses, permits, orders, approvals, plans, authorizations, concessions, franchises, and similar items, of all governmental agencies, departments, commissions, boards, bureaus, or instrumentalities of the United States, states, and political subdivisions thereof and all applicable judicial, administrative, and regulatory decrees, judgments, and orders relating to the protection of human health or the environment, including without limitation: a. All requirements, including, but not limited to, those pertaining to reporting, licensing, permitting, investigation, and remediation of emissions, discharges, releases, or threatened releases of hazardous materials, pollutants, contaminants or hazardous or toxic substances, materials, or wastes whether solid, liquid, or gaseous in nature, into the air, surface water, groundwater, storm water, or land, or relating to the manufacture, processing, distribution, use, treatment, storage, disposal, transport, or handling of pollutants, contaminants, or hazardous or toxic substances, materials, or wastes, whether solid, liquid, or gaseous in nature; and b. All requirements pertaining to the protection of the health and safety of employees or the public. General Indemnification: CONTRACTOR DOES HEREBY RELEASE, INDEMNIFY, REIMBURSE, DEFEND, AND HOLD HARMLESS THE CITY, ITS OFFICERS, AGENTS, EMPLOYEES AND VOLUNTEERS, FROM AND AGAINST ANY AND ALL LIABILITY, CLAIMS, SUITS, DEMANDS, OR CAUSES OF ACTIONS WlllCH MAY ARISE DUE TO ANY LOSS OR DAMAGE TO PERSONAL PROPERTY, OR PERSONAL INJURY, AND/OR DEAm OCCURRING AS A CONSEQUENCE OF THE PERFORMANCE OF THIS CONTRACT, WHEN SUCH INJURIES, DEATH, OR DAMAGES ARE CAUSED BY THE SOLE NEGLIGENCE OF CONTRACTOR, ITS OFFICERS, AGENTS, OR EMPLOYEES, OR THE JOINT NEGLIGENCE OF CONTRACTOR, ITS OFFICERS, AGENTS, OR EMPLOYEES, AND ANY OTHER PERSON OR ENTITY. Demolition of 5901 Boca Raton Blvd. CRL 12 .05 .07v3 Page 10 I I I I I I I C. D. E. F. G . Environmental Indemnification: CONTRACTOR DOES HEREBY RELEASE, INDEMNIFY, DEFEND, REIMBURSE, AND HOLD HARMLESS THE CITY, ITS OFFICERS, AGENTS, EMPLOYEES AND VOLUNTEERS, AGAINST ANY AND ALL ENVIRONMENTAL DAMAGES AND THE VIOLATION OF ANY AND ALL ENVIRONMENTAL REQUIREMENTS RESULTING FROM THE HANDLING, COLLECTION, AND TRANSPORTATION, OF NON-CONTAMINATED CONSTRUCTION DEBRIS AND FRIABLE ASBESTOS-CONTAINING OR ASBESTOS-CONTAMINATED DEBRIS, AS A CONSEQUENCE OF THE PERFORMANCE OF nns CONTRACT, WHEN SUCH DAMAGES OR VIOLATIONS ARE CAUSED BY THE SOLE NEGLIGENCE OF CONTRACTOR, ITS OFFICERS, AGENTS, OR EMPLOYEES, OR THE JOINT NEGLIGENCE OF CONTRACTOR, ITS OFFICERS, AGENTS, OR EMPLOYEES, AND ANY OTHER PERSON OR ENTITY. No Action Assurance Contractor hereby acknowledges that the demolition of the Structure pursuant to the QAPP and through the use of the AACM is being done through the discretion of enforcement by EPA and DSHS as more particularly described in Section 3B. Contractor hereby accepts and assumes the risks associated with the demolition of the Structure using the AACM under such discretion. The obligations of the Contractor under this section shall include, but not be limited to, the burden and expense of defending all claims, suits and administrative proceedings (with counsel reasonably approved by City), even if such claims, suits or proceedings are groundless, false, or fraudulent, and conducting all negotiations of any description, and paying and discharging, when and as the same become due, any and all judgments, penalties or other sums due against such indemnified persons. Upon learning of a claim, lawsuit, or other liability that Contractor is required hereunder to indemnify City, City shall provide Contractor with reasonably timely notice of same. The obligations of the Contractor under this section shall survive the expiration of this Agreement and the discharge of all other obligations owed by the parties to each other hereunder. H. In all of its contracts with subcontractors for the performance of any work under this contract, Contractor shall require the subcontractors to indemnify the City in a manner consistent with this Section. I. In the event City receives a written claim for damages against the Contractor or its subcontractors prior to final payment, final payment shall not be made until Contractor either submits to City satisfactory evidence that the claim has been settled and/or a Demolition of 5901 Boca Raton Blvd . CRL 12 .05 .07v3 Page 11 I I I I I I release from the claimant involved, or provides City with a letter from Contractor's liability insurance carrier that the claim has been referred to the insurance carrier. 8. WARRANTY Contractor warrants that it understands the currently known hazards and suspected hazards that are present to persons, property and the environment by the performance of the demolition of the structure using the AACM pursuant to the QAPP; as well as all other known hazards and suspected hazards associated with the demolition of the Structure. Contractor further warrants that it will perform all services under this contract in a safe, efficient and in a manner using industry accepted practices, and in full compliance with all applicable state and federal laws governing its activities, except for those activities described in the QAPP. Contractor warrants that it will strictly adhere to the QAPP as it pertains the use of the AACM in the demolition of the Structure. Contractor also warrants that it is under no restraint or order that would prohibit performance of services under this contract. 9. TERMINATION A. City may terminate this contract, with or without cause, by giving five (5) days written notice to Contractor, provided that such termination shall be without prejudice to any other remedy the City may have. In the event of termination, any work in progress will continue to completion unless specified otherwise in the notice of termination. B. If the City terminates this contract under paragraph A of this section, City shall pay Contractor for all services performed prior to the termination notice. C. All completed or partially completed original documents prepared under this contract shall become the property of the City when the contract is terminated, and may be used by the City in any manner it desires; provided, however, that the Contractor shall not be liable for the use of such documents for any purpose other than as described when requested. D. In the event either party defaults in the performance of any of its obligations under this contract, misrepresents to the other a material fact, or fails to notify the other party of any material fact which would affect the party's performance of its obligations hereunder, the non-defaulting party shall have an immediate right to terminate this contract upon giving the defaulting party notice describing the breach or omission in reasonable detail. 10. DEFAULT A. Contractor shall not be deemed to be in default because of any failure to perform under this contract, if the failure arises from causes beyond the control and without the fault or negligence of Contractor. Such causes shall include acts of God, acts of the public Demolition of 5901 Boca Raton Blvd . CRL 12 .05.07v3 Page 12 I I I I B. C. A B. enemy, acts of Government, in either its sovereign or contractual capacity, fires, flood, epidemics, quarantine restrictions, strikes, freight embargoes, and unusually severe weather. If at any time during the term of this contract the work of Contractor fails to meet the specifications of the contract, City shall notify Contractor immediately and Contractor shall immediately correct such deficiency and complete the work required under this contract to the satisfaction of City. Contractor shall pay all costs and attorneys fees incurred by City in the enforcement of any provision of this contract. The remedies provided for herein are in addition to any other remedies available to City elsewhere in this contract. 11. RIGHT TO AUDIT Contractor agrees that the City shall, until the expiration of five (5) years after final payment under this contract, have access to and the right to examine and photocopy any directly pertinent books, documents, papers and records of the Contractor involving transactions relating to this contract. Contractor agrees that the City shall have access during normal working hours to all necessary Contractor facilities and shall be provided adequate and appropriate workspace in order to conduct audits in compliance with the provisions of this section. The City shall give Contractor reasonable advance notice of intended audits. Contractor further agrees to include in all its subcontractor agreements hereunder a provision to the effect that the subcontractor agrees that the City shall, until the expiration of five (5) years after final payment under the subcontract, have access to and the right to examine and photocopy any directly pertinent books, documents, papers and records of such subcontractor, involving transactions to the subcontract, and further, that the City shall have access during normal working hours to all subcontractor facilities, and shall be provided adequate and appropriate work space, in order to conduct audits in compliance with the provisions of this article together with subsection C. hereof. City shall give subcontractor reasonable advance notice of intended audits. C. Contractor and subcontractor agree to photocopy such documents as may be requested by the City. The City agrees to reimburse Contractor and/or subcontractor for the cost of copies at the rate published in the Texas Administrative Code in effect as of the time copying is performed. 12. INDEPENDENT CONTRACTOR It is understood and agreed by the parties hereto that Contractor shall perform all work and services hereunder as an independent contractor, and not as an officer, agent, servant or employee of the City. Contractor shall have exclusive control of and the exclusive control of and the exclusive right to control the details of all the work and services performed hereunder, and all Demolition of 5901 Boca Raton Blvd. CRL l2.0S .07v3 Page 13 I I I I I I I persons performing same, and shall be solely responsible for the acts and omissions of its officers, agents, servants, employees, contractors, subcontractors, licensees and invitees. The doctrine of respondeat superior shall not apply as between City and Contractor, its officers, agents, employees, contractors and subcontractors, and nothing herein shall be construed as creating a partnership or joint enterprise between City and Contactor. A. B. 13. NON-DISCRIMINATION During the performance of this contract, Contractor agrees not to discriminate against any employee or applicant for employment because of race, religion, color, sex or national origin, except where religion, sex or national origin is a bona fide occupational qualification reasonably necessary to the normal operation of the Contractor. Contractor agrees to post in conspicuous places, available to employees and applicants for employment, notices setting forth the provisions of the non-discrimination clause. Contractor also agrees that in all solicitations or advertisements for employees placed by or on behalf of this contract, that Contractor is an equal opportunity employer. C. Notices, advertisements, and solicitations placed in accordance with federal law, rule or regulation shall be deemed sufficient for the purpose of meeting the requirements of this section. 14. GOVERNING LAW The City and Contractor agree that the laws of the State of Texas shall govern the validity and construction of this contract, except where preempted by federal law. 15. RIGHTS AND REMEDIES NOT WAIVED In no event shall the making by the City of any payment to Contractor constitute or be construed as a waiver by the City of any breach of covenant, or any default which may then exist, on the part of Contractor, and the making of any such payment by the City while any such breach or default exists shall in no way impair or prejudice any right or remedy available to the City with respect to such breach or default. Any waiver by either party of any provision or condition of the contract shall not be construed or decreed to be a waiver of any other provision or condition of this contract, nor a waiver of a subsequent breach of the same provision or condition, unless such waiver is expressed in writing and signed by the party to be bound. 16. ENTIRETY This contract and any other documents incorporated by reference herein contain all the terms and conditions agreed to by the City and Contractor, and no other contracts, oral or otherwise, Demol ition of 5901 Boca Raton Blvd. CRL l2.0S .07v3 Page 14 I I I I I regarding the subject matter of this contract or any part thereof shall have any validity or bind any of the parties hereto. 17. ASSIGNMENT The City and Contractor bind themselves and any successors and assigns to this contract. Contractor shall not assign, sublet, or transfer its interest in this contract without written consent of the City. Nothing herein shall be construed as creating any personal liability on the part of any officer or agent of the City, nor shall it be construed as giving any rights or benefits hereunder to anyone other than the City and Contractor. 18. NOTICE Notices required to be made under this contract shall be sent to the following persons at the following addresses; provided, however, that each party reserves the right to change its designated person for notice, upon written notice to the other party of such change: Ifto City: Written notice shall be sent to: Brian Boemer, Director Department of Environmental Management 1000 Throckmorton Fort Worth, Texas 76102 If to Contractor: Questions should be directed to: Michael Gange, Assistant Director Department of Environmental Management 1000 Throckmorton Fort Worth, Texas 76102 (817) 871-8504 I Fax (817) 871-6359 Mirc Wtlraven Vice President ·~ Q:nstru:ticn & Ehvi.rcmB1tal ~ces, L.P. 9701. Fast I-Xl F.astlarl, To>cas 7fA48 Demolition of S901 Boca Raton Blvd. CRL l2.0S .07v3 (254) ~1718 / Fmc (254) 62<}-ffi25 Page 1S I I I I I 19. VENUE Should any action, real or asserted, at law or in equity, arise out of the terms and conditions of this contract, venue for said action shall be in Tarrant County, Texas. 20. SEVERABILITY The provisions of this contract are severable; and if for any reason any one or more of the provisions contained herein are held to be invalid, illegal or unenforceable in any respect, the invalidity, illegality or unenforceability shall not affect any other provision of this contract, and this contract shall remain in effect and be construed as if the invalid, illegal or unenforceable provision had never been contained iz.1 the contract. 21. MODIFICATION No modification of the contract shall be binding on Contractor or City unless set out in writing and signed by both parties. 22. AUTHORIZATION The undersigned officer and/or agents of the parties hereto are properly authorized officials and have the necessary authority to execute this contract on behalf of the parties hereto, and each party hereby certifies to the other that any necessary resolutions extending such authority have been duly passed and are now in full force and effect. Demolition of 5901 Boca Raton Blvd . CRL 12.05 .07v3 INTENTIONALLY BLANK Page 16 I I i I I IN WITNESS WHEREOF, on this date )).QQ... l ~ , 2007, the parties hereto have executed this contract in triplicate originals in Fort Worth, Tarrant County, Texas. Date: __ /)_·_,1,_,o_:.r-_______ _ Approved as to Form and Legality:. ~ ~-~ Christa ~pez, Assistantity Attorney By. Marc Walraven -Vice President Date: I :J. -1 -o"l -------------- Witness: Title: Assistant to the v P Corporate Seal: ,,,,,11111111,,,, ~,,,''~N-0 EN\11,9, 111''1: ~~ ~~ ............. 0~ ~ ~ 0 .... ·-•. ~ ~ s~.· ·-~'S. ?gf SEAL \~~ -a:· ·>-- • 2000 ·r--:t-: !0S ::\~ :l'I::: io-.. .:~§ ~ u ··. TEXAs .-·~ ~ ~ .. ~··· •• ;,;..1 ;::. ~.., .,~~··········· ,~ ... ,, ~ ;,,. * . .1"\ ~ ... NO M&C REQUIRED ,,,,, 0 ,,, .... ''''""'""'''' Demolition of 590 I Boca Raton Blvd. CRL l2.0S .07v3 Page 17 -CITY SECRETARV:11 ~ CONTRACT NO. Y...,._"""'--0~~.c.- CONTRACT Between CITY OF FORT WORTH and EAGLE CONSTRUCTION AND ENVIRONMENTAL SERVICES, L.P. For Alternative Asbestos Control Method (AACM) Oak Hollow Office Building 5901 Boca Raton Fort Worth, Texas Environmental Management Department December 2007 L____------~---~--~-~J'-- STATE OF TEXAS § § § § KNOW ALL PERSONS BY THESE PRESENTS COUNTIES OF TARRANT§ DENTON AND WISE CONTRACT FOR THE DEMOLITION OF THE OAK HOLLOW APARTMENT OFFICE BUILDING LOCATED AT 5901 BOCA RATON BOULEVARD This agreement is entered into by and between the City of Fort Worth, Texas, a home-rule municipal corporation situated in Tarrant, Denton and Wise Counties, Texas, hereinafter called "City," acting herein through .Libby Watson, its duly authorized Assistant City Manager, and Fagle G:nst:ncticn & EhvircrnHltal Srvs,L.Jhereinafter called "Contractor," by and through Mm-WJ]rmrn , its duly authorized President/Vice President. In consideration of the mutual promises and benefits of this contract, the City and Contractor agree as follows: 1. DEFINITIONS In this contract, the following words and phrases shall be defined as follows: AACM shall mean Alternative Asbestos Control Method. Amended Water shall mean Kiddie Fire Foam as determined by the EPA. Asbestos shall mean the asbestiform varieties of chrysotile, amosite , crocidolite, tremolite, anthophyllite, and actinolite and all materials containing one percent or more of any of those substances. Asbestos Abatement shall mean the removal, the encapsulation or the enclosure of asbestos . Asbestos Abatement Activity shall mean asbestos abatement and any on-site preparations or clean up related to the abatement. Asbestos-Containing Material (ACM) shall mean materials or products that contain more than one percent (1.0%) of any kind or combination of asbestos, as determined by Environmental Protection Agency (EPA) recommended methods as listed in Section 40 of the Code of Federal Regulations, (CFR) Part 763, Subpart F and 40 CFR 763 Subpart E, Appendix A. This means· any one material component of a structure . Demolition of 5901 Boca Raton Blvd. CRL 12.05.07v3 Page 1 Asbestos Removal shall mean any action that dislodges , strips, or otherwise takes away asbestos containing material (ACM). City shall mean the City of Fort Worth, Texas. Contract Docwnents shall mean this docwnent and all other exhibits as described in this contract and all ancillary documents . Contractor shall mean Fagle Ccnstn:rtim & Ftntiz:r;;mmtal Services, L.P. DEM shall mean the Department of Environmental Management. Director shall mean the Director of the City of Fort Worth's Environmental Management Department. EPA shall mean the United States Environmental Protection Agency. NESHAP shall mean the United States Environmental Protection Agency National Emissions Standards for Hazardous Air Pollutants, as described in Title 40 CFR Part 61. Regulated Asbestos-Containing Material (RACM) shall mean (a) friable asbestos material, (b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or ( d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by forces expected to act on the material in the course of demolition or renovation operations. DSHS shall mean the Texas Department of State Health Services. Structure shall mean the Oak Hollow Apartment office building located at 5901 Boca Raton Boulevard, Fort Worth, Texas. 2. TERM AND TIME TO COMPLETE This contract shall be effective from the date of its execution by both parties, until the completion of all Contractor services as provided in Section 3, or January 31, 2008, whichever date occurs first, notwithstanding the survival of the terms and rights in Section 7. Contractor agrees to begin demolition activities of the structure as instructed by the City. City shall use its best effort to provide Contractor with reasonable notice of the date of demolition, however, Contractor acknowledges and waives the right to object to the City decision to postpone or cancel the date of demolition. Contractor shall complete the demolition of the Structure within 24 hours of the commencement of the demolition activities. Demolition of5901 Boca Raton Blvd. CRL 12 .05 .07v3 Page 2 3. SCOPE OF CONTRACTOR'S SERVICES A. Contractor shall provide all the labor, materials, and equipment necessary for performing the demolition of the Structure at 5901 Boca Raton Boulevard, Fort Worth, Texas using the AACM in strict compliance with the Quality Assurance Project Plan (QAPP) attached as Exhibit A, as instructed by the City. B . Contractor understands and hereby acknowledges that the use of the AACM is done with the EPA and DSHS' discretion of enforcement to allow EPA and the City to evaluate the AACM. Contractor further understands and acknowledges that the EPA has issued a letter of No Action Assurance attached as Exhibit B, and DSHS has issued a letter of similar assurance attached as Exhibit C. Contractor understands and acknowledges that the discretion of enforcement from the EPA applies only to the NESHAP provisions in 40 CFR Part 61, Subpart M, §§61.145{c){l) thru (6). Contractor agrees that Contractor shall comply with all other DSHS and NESHAP regulations in the performance of the demolition of the Structure. C. In compliance with the QAPP , Contractor agrees to the following specifications for the demolition of the Structure: 1. Wetting Process • Structure shall be thoroughly and adequately wetted, as defined by NESHAP , with Amended Water (surfactant addition) one-day prior to demolition, the morning prior to demolition, and during demolition activities, and during debris handling and loading. • Amended Water will be applied with a minimum of two (2) fire hoses. • Amended Water will be delivered in a manner that most effectively wets the demolition debris and controls airborne emissions. • Direct high-pressure impact of structure, structure components and resultant structure debris shall be prohibited at all times. • · Visible foaming must occur at impact of the spray mist and the structure. • Wetting process will occur in the aforementioned stages with the interior and the exterior portions of the structure addressed. • Interstitial wall spaces and cavity areas shall also be adequately wetted. 2. Wetting Schedule • One day prior to initiating demolition activities, access openings shall be made into attic spaces from the exterior. • Structure will be pre-wet from the interior and then from the exterior access operungs. • Once the pre-wetting begins, access into the Structure shall be prohibited. • Structure shall be re-wet through exterior access openings on the day demolition activities are to begin, prior to demolition commencing. Demolition of 590 I Boca Raton Blvd . CRL 12.05 .07 v3 Page 3 • Wetting shall continue through demolition of the Structure and during the loading of debris . 3. Demolition • Contractor shall minimize breakage of ACM. • Demolition activities shall be conducted in a timely manner. • Debris generated shall be removed from the demolition site the same day that it is generated. 4. Visible Emissions • Demolition activities shall not generate visible emissions . • If a representative from the City or the EPA determines that visible emissions have occurred or are occurring, or if the Contractor has actual knowledge of such emissions, activities shall cease until the area of concern is adequately wetted. Once the area of concern is determined to be adequately wet, the demolition activities shall continue. 5. Weather Restrictions • Activities may be halted in the case of inclement weather by the determination of the City. • Visible dusting in the area of demolition shall warrant a stoppage in operations. 6 . Monitoring Requirements • Contractor shall comply with all applicable OSHA requirements including but not limited to 29 CFR 1910 and 1926. • Contractor shall provide personal air monitoring for all workers within the bermed area including the heavy equipment operator. 7. Waste Handling • ~11 waste gene~~ ~~;1:1~! during the day shall be removed and disposed of at . ·•-:;<7",-~ '•,:;·s~ -,,~ w <· • • Contractor shall tran~p~rt rui'd -dispose of all debris in accordance with all state and federal regulations • Waste transport containers shall be leak-proof. • The containers will be double-lined with at least 6-mil thick polyethylene sheeting and subsequently sealed along the top in order to prevent leakage from the trailer. • An application of expandable spray foam between the trailer and the end-gate shall be applied prior to installing the polyethylene liners in order to prevent leakage from the trailer during transport. • The transport vehicle and trailer will be decontaminated prior to leaving the controlled (bermed) area. Decontamination shall include but not be limited to the removing of all debris in the bermed area and the rinsing of the vehicle, trailer and undercarriage, including wheels and tires with the use of Amended Water. • All demolition debris shall be disposed of as RACM and no sorting of debris will be allowed for this project. Demolition of 5901 Boca Raton Blvd . CRL 12.05.07v3 Page 4 • All PPE shall be disposed of as RACM and non-disposable PPE shall be thoroughly decontaminated according to OSHA standard practices. 8. Applied Water Collection and Containment • No potentially contaminated water is permitted to leave the site during demolition activities. • All impervious surfaces remaining will be thoroughly washed with Amended Water prior to site closure . • Best Management Practices (BMPs) shall be utilized in order to prevent water runoff. • BMPs shall provide containment of excess amounts of applied water with collection station(s) strategically located to remove the runoff water from the bermed area. • Collected water shall be pumped into holding tanks of sufficient size for disposal as RACM or filtered with a series of filters in order to remove any fibers larger than five microns. If filtered, this water may be transported to the local POTW for disposal. • BMPs should extend at least 25' horizontally from the structure in order to allow for movement of demolition equipment and loading of waste trailers. • Applications of at least 6-mil polyethylene sheeting over bermed areas is required. • Polyethylene sheeting utilized will disposed of as RACM. 9. Potentially Contaminated Soils • Following the removal of all demolition debris, bare soils within the demolition bermed area will be excavated to a depth of at least 3" below ground surface and disposed of as RACM. 10. Additional Workplace Requirements • One layer of 6-mil polyethylene lining will be placed surrounding the immediate adjacent side of the apartment buildings located adjacent north and south of the project building. • A 75' long by 20 ' wall shall be constructed along the tree line located adjacent east of the project building. The wall shall be covered with at least one layer of 6- rnil polyethylene and the wall will be anchored sufficiently to prevent toppling or falling. • Only the trailer of debris transport vehicles shall be allowed to enter the bermed area. The tractor portion shall remain outside of the bermed area and the driver shall remain inside the tractor cab during loading operations and sealing of the polyethylene sheeting around the load. • Personnel access will be required for the adjacent roof-top areas in order to install air-monitoring devices and for hourly calibration and adjustments during the course of the project. • Portable toilet facilities shall be stationed at the project location in an area that is outside the Contamination Reduction Zone (CRZ). Demolition of 5901 Boca Raton Blvd . CRL I2.05 .07 v3 Page 5 D. Contractor agrees that it shall maintain during the term of this contract, current and appropriate federal, state, and local licenses and permits to perform the services contained in this contract. E . Contractor agrees that it shall not assign, delegate, or subcontract any of the work described in this contract without first obtaining express written approval to do so from City. Contractor shall remain fully responsible for the satisfactory performance of such work and shall remain fully bound by the terms of this contract. City shall have the right to approve or reject all subcontractors retained by Contractor to perform services under this contract. F. Contractor shall attend Pre-Demolition Meeting(s) with the City to discuss all aspects of the Project. 4. CITY'S RESPONSIBILITIES A . City shall designate a City representative to provide timely direction to the Contractor and render City decisions. · B. City shall provide timely notice to Contractor of the start of the demolition project. 5. COMPENSATION A. In consideration for the work performed by Contractor under this contract , City shall pay Contractor a sum not to exceed twenty-four thousand nine hundred fifty dollars ($24,950 .00). Payment shall be based on the unit price charges as set forth in exhibit D. B. Mobilization of equipment is for travel time from Contractor's place of business to 5901 Boca Raton Boulevard and from 5901 Boca Raton Boulevard to Contractor's place of business only. C. City shall only be billed for actual work performed. Idle time on the site shall not be billable. D. City shall make payment within thirty (30) days of receiving a correct invoice from Contractor. City is responsible for notifying Contractor of any questions concerning an invoice. In the event of a disputed or contested billing, only that portion so contested will be withheld from payment, and the undisputed portion will be paid. The City will exercise reasonableness in contesting any bill or portion thereof. No interest will accrue on any contested portion of the billing until mutually resolved. E. Contractor shall receive no compensation for delays or hindrances to the work, except when direct and unavoidable extra cost to Contractor was caused by City's failure to Demolition of 5901 Boca Raton Blvd. CRL 12.05.07v3 Page 6 provide information, if any , which it is required to do . When extra compensation is claimed, a written statement thereof shall be presented to the City. 6. INSURANCE Contractor agrees to furnish the following proof satisfactory to City, that it or it 's subcontractor(s) has secured and paid for the following policies of liability insurance for the term of this contract covering all risks related to the work of this project. A. Insurance coverage and limits: 1. 2. 3. Commercial General Liability Insurance o $1,000,000 each occurrence o $2,000,000 aggregate Professional Liability Insurance -NOT APPLICABLE. Automobile Liability Insurance- a. Coverage on vehicles involved in the work performed under this contract: o $1,000,000 per accident on a combined single limit basis m:: o $500,000 bodily injury each person; $500,000 bodily injury each accident; and $250,000 property damage b. Uninsured/Underinsured Motorist: o $20,000 bodily injury each person; $40,000 bodily mJury each accident; and$15,000 property damage each accident The named insured and employees of Contractor shall be covered under this policy. The City of Fort Worth shall be named an Additional insured on Endorsement TE 9901 or equivalent, as its interests may appear. Liability for damage occurring while loading, unloading and transporting materials collected under the Contract shall be included under this policy. 4. Worker's Compensation - o Coverage A: statutory limits o Coverage B: $100,000 each accident $500,000 disease -policy limit $100,000 disease -each employee 5. Environmental Impairment Liability (EIL) and/or Pollution Liability - $2 ,000 ,000 per occurrence. EIL coverage(s) must be included in policies listed in subsections 1 and 2 above; or, such insurance shall be provided under separate policy(s). Liability for damage occurring while loading, unloading and transporting materials collected under the contract shall be included under the Automobile Liability insurance or other policy(s). Demolition of 590 l Boca Raton Blvd . CRL 12 .05 .07v3 Page 7 6. Asbestos Abatement Insurance -$l,OOO,OOO each occurrence with no ~ Sunset Clause(tr, he prov,deJ (,.; f:aJfeJ qjl:,tJ 5-/o5 -S vbco,tlr-6-clor J ~ ~ B. Certificates of insurance evidencing that the Contractor has obtained all required insurance shall be delivered to the City prior to Contractor proceeding with the contract. 1. Applicable policies shall be endorsed to name the City an Additional Insured thereon, as its interests may appear. The term City shall include its employees, officers, officials, agents, and volunteers as respects the contracted services . • 2. Certificate( s) of insurance shall document that insurance coverage specified according to items in section (a) above are provided under applicable policies documented thereon. 3. Any failure on part of the City to request required insurance documentation shall not constitute a waiver of the insurance requirements. 4. A minimum of thirty (30) days notice of cancellation or material change in coverage shall be provided to the City. A ten (10) days notice shall be acceptable in the event of non-payment of premium. Such terms shall be endorsed onto Contractor's insurance policies. Notice shall be sent to Brian Boemer, Director, Department of Environmental Management, City of Fort Worth, 1000 Throckmorton, Fort Worth, Texas 76102. 5. Insurers for all policies must be authorized to do business in the state of Texas or be otherwise approved by the City; and, such insurers shall be acceptable to the City in terms of their financial strength and solvency. 6. Deductible limits, or self-insured retentions, affecting insurance required herein shall be acceptable to the City in its sole discretion; and, in lieu of traditional insurance, any alternative coverage maintained through insurance pools or risk retention groups must be also approved. Dedicated financial resources or letters of credit may also be acceptable to the City. 7. Applicable policies shall each be endorsed with a waiver of subrogation in favor of the City as respects the contract. 8. The City shall be entitled, upon its request and without incurring expense, to review the Contractor's insurance policies including endorsements thereto and, at the City's discretion, the Contractor may be required to provide proof of insurance premium payments. Demolition of 5901 Boca Raton Blvd. CRL 12.05.07v3 Page 8 ,~J 9. The Commercial General Liability insurance policy shall have no exclusions by endorsements unless the City approves such exclusions . 10. The City shall not be responsible for the direct payment of any insurance premiums required by the contract. It is understood that insurance cost is an allowable component of Contractor's overhead. 11 . All insurance required in section (a) above shall be written on an occurrence basis in order to be approved by the City. 12. Subcontractors to the Contractor shall be required by the Contractor to maintain the same or reasonably equivalent insurance coverage as required for the Contractor. When subcontractors maintain insurance coverage , Contractor shall provide City with documentation thereof on a certificate of insurance. Notwithstanding anything to the contrary contained herein, in the event a subcontractor's insurance coverage is canceled or terminated, such cancellation or termination shall not constitute a breach by Contractor of the contract. 7. INDEMNIFICATION A. For purposes of this contract, the phrases "Environmental Damages" and "Environmental Requirements" shall be defined as stated below: 1. Environmental Damages shall mean all claims, judgments, damages, losses, penalties, fines , liabilities (including strict liability), encumbrances, liens , costs , and expenses of investigation and defense of any claim, whether or not such claim is ultimately defeated, and of any good faith settlement or judgment, of whatever kind or nature, contingent or otherwise, matured or unmatured, foreseeable or unforeseeable , including without limitation reasonable attorney 's fees and disbursements and consultant's fees, any of which are incurred as a result of handling, collection, transportation, storage, disposal, treatment, recovery, and/or reuse of waste pursuant to this contract, or the existence of a violation of environmental requirements pertaining to , and including without limitation: a. Damages for personal injury and death, or injury to property or natural resources; b . Fees incurred for the services of attorneys , consultants, contractors , experts, laboratories and all other costs in connection with the investigation or remediation of such wastes or violation of environmental requirements including, but not limited to, the preparation of any feasibility studies or reports of the performance of any cleanup, remediation, removal, response, abatement, containment, closure, restoration or monitoring work required by any federal , state or local Demolition of 5901 Boca Raton Blvd . CRL 12.05 .07 v3 P age 9 governmental agency or political subdivision, or otherwise expended in connection with the existence of such wastes or violations of environmental requirements, and including without limitation any attorney 's fees, costs and expenses incurred in enforcing this contract or collecting any sums due hereunder; and c. Liability to any third person or governmental agency to indemnify such person or agency for costs expended in connection with this Agreement. 2. Environmental requirements shall mean all applicable present and future statutes , regulations , rules, ordinances, codes, licenses, permits , orders, approvals , plans , authorizations, concessions, franchises , and similar items, of all governmental agencies, departments , commissions, boards , bureaus , or instrumentalities of the United States , states, and political subdivisions thereof and all applicable judicial , administrative, and regulatory decrees , judgments, and orders relating to the protection of human health or the environment, including without limitation: a. All requirements , including, but not limited to, those pertaining to reporting, licensing, permitting, investigation, and remediation of emissions, discharges , releases , or threatened releases of hazardous materials, pollutants, contaminants or hazardous or toxic substances , materials, or wastes whether solid, liquid , or gaseous in nature , into the air, surface water, groundwater, storm water, or land, or relating to the manufacture, processing, distribution, use , treatment, storage , disposal , transport, or handling of pollutants, contaminants, or hazardous or toxic substances, materials, or wastes , whether solid, liquid, or gaseous in nature;and b . All requirements pertaining to the protection of the health and safety of employees or the public. B. General Indemnification: CONTRACTOR DOES HEREBY RELEASE, INDEMNIFY, REIMBURSE, DEFEND, AND HOLD HARMLESS THE CITY, ITS OFFICERS, AGENTS, EMPLOYEES AND VOLUNTEERS, FROM AND AGAINST ANY AND ALL LIABILITY, CLAIMS, SUITS, DEMANDS, OR CAUSES OF ACTIONS WHICH MAY ARISE DUE TO ANY LOSS OR DAMAGE TO PERSONAL PROPERTY, OR PERSONAL INJURY, AND/OR DEATH OCCURRING AS A CONSEQUENCE OF THE PERFORMANCE OF THIS CONTRACT, WHEN SUCH INJURIES, DEATH, OR DAMAGES ARE CAUSED BY THE SOLE NEGLIGENCE OF CONTRACTOR, ITS OFFICERS, AGENTS, OR EMPLOYEES, OR THE JOINT NEGLIGENCE OF CONTRACTOR, ITS OFFICERS, AGENTS, OR El\1PLOYEES, AND ANY OTHER PERSON OR ENTITY. Demolition of 5901 Boca Raton Blvd . CRL 12 .05 .07 v3 P age 10 C. Environmental Indemnification: CONTRACTOR DOES HEREBY RELEASE, INDEMNIFY, DEFEND, REIMBURSE, AND HOLD HARMLESS THE CITY, ITS OFFICERS, AGENTS, EMPLOYEES AND VOLUNTEERS, AGAINST ANY AND ALL ENVIRONMENTAL DAMAGES AND THE VIOLATION OF ANY AND ALL ENVIRONMENTAL REQUIREMENTS RESULTING FROM THE HANDLING, COLLECTION, AND TRANSPORTATION, OF NON-CONTAMINATED CONSTRUCTION DEBRIS AND FRIABLE ASBESTOS-CONTAINING OR ASBESTOS-CONTAMINATED DEBRIS, AS A CONSEQUENCE OF THE PERFORMANCE OF TIDS CONTRACT, WHEN SUCH DAMAGES OR VIOLATIONS ARE CAUSED BY THE SOLE NEGLIGENCE OF CONTRACTOR, ITS OFFICERS, AGENTS, OR EMPLOYEES, OR THE JOINT NEGLIGENCE OF CONTRACTOR, ITS OFFICERS, AGENTS, OR EMPLOYEES, AND ANY OTHER PERSON OR ENTITY. D. No Action Assurance Contractor hereby acknowledges that the demolition of the Structure pursuant to the QAPP and through the use of the AACM is being done through the discretion of enforcement by EPA and DSHS as more particularly described in Section 3B. Contractor hereby accepts and assumes the risks associated with the demolition of the Structure using the AACM under such discretion. E. The obligations of the Contractor under this section shall include, but not be limited to , the burden and expense of defending all claims, suits and administrative proceedings (with counsel reasonably approved by City), even if such claims, suits or proceedings are groundless, false, or fraudulent, and conducting all negotiations of any description, and paying and discharging, when and as the same become due, any and all judgments, penalties or other sums due against such indemnified persons. F. Upon learning of a claim, lawsuit, or other liability that Contractor is required hereunder to indemnify City, City shall provide Contractor with reasonably timely notice of same. G. The obligations of the Contractor under this section shall survive the expiration of this Agreement and the discharge of all other obligations owed by the parties to each other hereunder. H. In all of its contracts with subcontractors for the performance of any work under this contract, Contractor shall require the subcontractors to indemnify the City in a manner consistent with this Section. I. In the event City receives a written claim for damages against the Contractor or its subcontractors prior to final payment, final payment shall not be made until Contractor either submits to City satisfactory evidence that the claim has been settled and/or a Demolition of 5901 Boca Raton Blvd. CRL 12 .05 .07v3 Page 11 release from the claimant involved, or provides City with a letter from Contractor's liability insurance carrier that the claim has been referred to the insurance carrier. 8. WARRANTY Contractor warrants that it understands the currently known hazards and suspected hazards that are present to persons, property and the environment by the performance of the demolition of the structure using the AACM pursuant to the QAPP; as well as all other known hazards and suspected hazards associated with the demolition of the Structure. Contractor further warrants that it will perform all services under this contract in a safe, efficient and in a manner using industry accepted practices, and in full compliance with all applicable state and federal laws governing its activities, except for those activities described in the QAPP. Contractor warrants that it will strictly adhere to the QAPP as it pertains the use of the AACM in the demolition of the Structure. Contractor also warrants that it is under no restraint or order that would prohibit performance of services under this contract. 9. TERMINATION A. City may terminate this contract, with or without cause, by giving five (5) days written notice to Contractor, provided that such termination shall be without prejudice to any other remedy the City may have. In the event of termination, any work in progress will continue to completion unless specified otherwise in the notice of termination. B. If the City terminates this contract under paragraph A of this section, City shall pay Contractor for all services performed prior to the termination notice. C. All completed or partially completed original documents prepared under this contract shall become the property of the City when the contract is terminated, and may be used by the City in any manner it desires; provided, however, that the Contractor shall not be liable for the use of such documents for any purpose other than as described when requested. D. In the event either party defaults in the performance of any of its obligations under this contract, misrepresents to the other a material fact, or fails to notify the other party of any material fact which would affect the party's performance of its obligations hereunder, the non-defaulting party shall have an immediate right to terminate this contract upon giving the defaulting party notice describing the breach or omission in reasonable detail. 10. DEFAULT A. Contractor shall not be deemed to be in default because of any failure to perform under this contract, if the failure arises from causes beyond the control and without the fault or negligence of Contractor. Such causes shall include acts of God, acts of the public Demolition of 5901 Boca Raton Blvd. CRL 12.05 .07 v3 Page 12 enemy, acts of Government, in either its sovereign or contractual capacity, fires, flood, epidemics , quarantine restrictions, strikes, freight embargoes, and unusually severe weather. B. If at any time during the term of this contract the work of Contractor fails to meet the specifications of the contract, City shall notify Contractor immediately and Contractor shall immediately correct such deficiency and complete the work required under this contract to the satisfaction of City. Contractor shall pay all costs and attorneys fees incurred by City in the enforcement of any provision of this contract. C. The remedies provided for herein are in addition to any other remedies available to City elsewhere in this contract. 11. · RIGHT TO AUDIT A. Contractor agrees that the City shall, until the expiration of five (5) years after final payment under this contract, have access to and the right to examine and photocopy any directly pertinent books, documents, papers and records of the Contractor involving transactions relating to this contract. Contractor agrees that the City shall have access during normal working hours to all necessary Contractor facilities and shall be provided adequate and appropriate workspace in order to conduct audits in compliance with the provisions of this section. The City shall give Contractor reasonable advance notice of intended audits. B. Contractor further agrees to include in all its subcontractor agreements hereunder a provision to the effect that the subcontractor agrees that the City shall, until the expiration of five (5) years after final payment under the subcontract, have access to and the right to examine and photocopy any directly pertinent books, documents, papers and records of such subcontractor, involving transactions to the subcontract, and further, that the City shall have access during normal working hours to all subcontractor facilities, and shall be provided adequate and appropriate work space, in order to conduct audits in compliance with the provisions of this article together with subsection C. hereof. City shall give subcontractor reasonable advance notice of intended audits. C. Contractor and subcontractor agree to photocopy such documents as may be requested by the City. The City agrees to reimburse Contractor and/or subcontractor for the cost of copies at the rate published in the Texas Administrative Code in effect as of the time copying is performed. 12. INDEPENDENT CONTRACTOR It is understood and agreed by the parties hereto that Contractor shall perform all work and services hereunder as an independent contractor, and not as an officer, agent, servant or employee of the City. Contractor shall have exclusive control of and the exclusive control of and the exclusive right to control the details of all the work and services performed hereunder, and all Demolition of 5901 Boca Raton Blvd. CRL l2.0S .07v3 Page 13 persons performing same, and shall be solely responsible for the acts and omissions of its officers, agents, servants , employees, contractors , subcontractors, licensees and invitees. The doctrine of respondeat superior shall not apply as between City and Contractor, its officers, agents, employees, contractors and subcontractors, and nothing herein shall be construed as creating a partnership or joint enterprise between City and Contactor. 13. NON-DISCRIMINATION A. During the performance of this contract, Contractor agrees not to discriminate against any employee or applicant for employment because of race, religion, color, sex or national origin, except where religion, sex or national origin is a bona fide occupational qualification reasonably necessary to the normal operation of the Contractor. Contractor agrees to post in conspicuous places, available to employees and applicants for employment, notices setting forth the provisions of the non-discrimination clause. B. Contractor also agrees that in all solicitations or advertisements for employees placed by or on behalf of this contract, that Contractor is an equal opportunity employer. C. Notices, advertisements, and solicitations placed in accordance with federal law, rule or regulation shall be deemed sufficient for the purpose of meeting the requirements of this section. 14. GOVERNING LAW The City and Contractor agree that the laws of the State of Texas shall govern the validity and construction of this contract, except where preempted by federal law. 15. RIGHTS AND REMEDIES NOT WAIVED In no event shall the making by the City of any payment to Contractor constitute or be construed as a wruver by the City of any breach of covenant, or any default which may then exist, on the part of Contractor, and the making of any such payment by the City while any such breach or default exists shall in no way impair or prejudice any right or remedy available to the City with respect to such breach or default. Any waiver by either party of any provision or condition of the contract shall not be construed or decreed to be a waiver of any other provision or condition of this contract, nor a waiver of a subsequent breach of the same provision or condition, unless such waiver is expressed in writing and signed by the party to be bound. 16. ENTIRETY This contract and any other documents incorporated by reference herein contain all the terms and conditions agreed to by the City and Contractor, and no other contracts , oral or otherwise, Demolition of5901 Boca Raton Blvd. CRL 12 .05.Q7v3 Page 14 regarding the subject matter of this contract or any part thereof shall have any validity or bind any of the parties hereto. 17. ASSIGNMENT The City and Contractor bind themselves and any successors and assigns to this contract. Contractor shall not assign, sublet, or transfer its interest in this contract without written consent of the City. Nothing herein shall be construed as creating any personal liability on the part of any officer or agent of the City, nor shall it be construed as giving any rights or benefits hereunder to anyone other than the City and Contractor. 18. NOTICE Notices required to be made under this contract shall be sent to the following persons at the following addresses; provided, however, that each party reserves the right to change its designated person for notice, upon written notice to the other party of such change: If to City: Written notice shall be sent to: Brian Boerner, Director Department of Environmental Management 1000 Throckmorton Fort Worth, Texas 7 6102 If to Contractor: Mrrc W3h:avEn Vice President Questions should be directed to: Michael Gange, Assistant Director Department of Environmental Management 1000 Throckmorton Fort Worth, Texas 76102 (817) 871-8504 / Fax (817) 871-6359 Fagl~ Ccnstnctim & Ebv:iram:ntal ~ces, L.P. 9701 East I-2D Fastlarrl, Texas 7f:A48 Demolition of 590 I Boca Raton Blvd. CRL 12 .05.07v3 (254) 629--1718 / Fax (254) 629-ffi25 Page 15 19. VENUE Should any action, real or asserted, at law or in equity, arise out of the terms and conditions of this contract, venue for said action shall be in Tarrant County, Texas. 20. SEVERABILITY The provisions of this contract are severable; and if for any reason any one or more of the provisions contained herein are held to be invalid, illegal or unenforceable in any respect, the invalidity, illegality or unenforceability shall not affect any other provision of this contract, and this contract shall remain in effect and be construed as if the invalid, illegal or unenforceable provision had never been contained ~ the contract. 21. MODIFICATION No modification of the contract shall be binding on Contractor or City unless set out in writing and signed by both parties. 22. AUTHORIZATION The undersigned officer and/or agents of the parties hereto are properly authorized officials and have the necessary authority to execute this contract on behalf of the parties hereto , and each party hereby certifies to the other that any necessary resolutions extending such authority have been duly passed and are now in full force and effect. Demolition of 5901 Boca Raton Blvd . CRL 12 .05.07v 3 INTENTIONALLY BLANK Page 16 IN WITNESS WHEREOF, on this date ))QQ__ l~ , 2007, the parties hereto have executed this contract in triplicate originals in Fort Worth, Tarrant County, Texas. Date: _......,/J_,_,_~_,_o_~ _______ _ Approved as to Form and Legality: ~ K.~ Christa ~pez, Assistantity Attorney ~ Marty Hendrix, By. Marc Walraven -Vice President Date: --------------- Witness: Name: Nancy inson Title: --=A=s""'s .... i ... s .... t .... a ..... o ... t_...to...._t .... b ..... e~V ........ P ____ _ Corporate Seal: ,,,,,11111111,,,, '.\,,,''~NO ENI//~ 111'1,._ ~"' ~~.~ •••..•••.• 0~ ~ ~ 0 .... ·· .. ~ ~ s~~ ~~~ ::g.: SEAL -..~~ = : ~';P= =I== 2000 :,: : ,,"': : en = -"' • • rr, --; 'Z... .:.:o ~ ~o . T ."~ ~ o ··. EXAS ···~ ;:: ~ .,.'\),,._'•. •• ;,,;.J ~ ~ 'V 7h~··········· "(:,'"' ~ ~.I. o,;;J *'-''"\ '.\'-,,,, a ,,,..,, NO M&C REQUIRED ''''""'""'''' Demolition of 5901 Boca Raton Blvd. CRL !2.05 .07v3 Page 17 CONTRACTOR COMPLIANCE WITH WORKERS' COMPENSATION LAW Pursuant to V.T.C.A. Labor Code §406 .96 (2000), as amended , Contractor certifies that it provides workers' compensation insurance coverage for all of its employees employed on City of Fort Worth Department of Environmental Management Project for Alternate Asbestos Control Method (AACM), Oak Hollow Office Building , 5901 Boca Raton , Fort Worth , Texas . CONTRACTOR Eagle Construction &c=ental Services, LP. By : ~tPt,- STATE OF TEXAS EASTLAND COUNTY OF~ Title § § § MARC WALRAVEN VICE PRESIDENT Before me , the undersigned authority , on this day personally appeared MARC WALRAVEN , known to me to be the person whose name is subscribed to the foregoing instrument, and acknowledged to me that he executed the same as the act and deed of EAGLE CONSTRUCTION AND ENVIRONMENTAL SERVICES, IP for the purposes and consideration therein expressed and in the capacity therein stated. Given Under My Hand and Seal of Office this 11 ··-day of DEC. , 20 07 .• This certificate is executed b Libe Mutual Insurance Grou as res ts such insurance as is affo rded b those corn anies. BM0068 Certificate of In surance This certificate is issued as a matter of information only and confers no rights upon you the certificate holder. This certificate is not an in surance policy and does not amend, extend, or alter the coverage afforded b the lici es listed be low. Thi s is to certify that (Name and address of In sured) Eag le Construction & Environmental Services , L.P . 970 I 1-20 East Eastland, TX 76448 ~LiberlJ. \P Mutual.M 1s, at the issue date ofth1s certificate, msured by the Company under the pohcy(1es) listed below . The msurance afforded by the li sted pohcy(1es) 1s subj ect to all their terms, exclusions and conditions and is not altered bv anv reauirement, tenn or condition of any contract or o th d th er ocumentwi respect to which this certificate may be issued. Expiration Type Eff./Exp. Date(s) Policv Number(s) Limits of Liability Continuous* Coverage afforded under WC law of Employers Liability -the following states: Extended Bodily Injury By Accident -X Policy Term Each Accident Bodily Injury By Disease Policy Limit Workers Compensation Bodily Injury By Disease ' Each Person General Aggregate-Other than Prod/Completed Operations General Liability Products/Completed Operations Aggregate H Claims Made Occurrence Bodily Injury and Property Damage Liability Per Occurrence I Retro Date I Personal and Advertising Injury Per Person/ Or2anization Other Liability I Other Liability 06/30/2007 I 06/30 /2 008 AS2-l 91-446214-0l 7 Each Accident -Single Limit -B. I . and P . D . Combined Automobile Liability $1,000,000 Each Person X Owned -X Non-Owned Each Accident or Occurrence -X Hired Each Accident or Occurrence C ity of Fort Worth shall be listed as Additional Insured as respects to Aut omobile Liability. C 0 M M E N T s Notice of cancellation : (not applicable unless a nwnber of days is entered below) . policies until at least 30 days notice of such cancellation has been mailed to : Office: IRVING, TX Phone: 972-55 0-7899 Certificate Holder: City of Fo r t Worth 1000 Throckmorton St Fort Worth , TX 76102 Before the stated ex:piration date the com pany will not cancel or reduce th e insurance afforded under th e above ~ ~-~ JENNIFER DAVIS Authorized Reoresentative Date Issued: 12/11/2007 Prepared By: AW j l : fl . PAGE B2102 ACORD .,----···· ..................... -----···· --------··----·-----ro;:'r;;r;:;fl\.'DD'YY) CE R TIFICATE OF LIABILITY INSURANCE 1 1211012007 fHE WYATT AGENCY !JOO 11l H ST REET SUITE 30 6-E HUNTSVILLE. TX 77J40 Serial if 100:,5,; lHi5 CE.RTIFICAl E 1s'"'issuED AS A MAT'TER Of INFORMAT ION ONLY AN O CONHJ~S NO R IGHTS UPON THE CER TI FICATE HOLDER THIS CtRT IFICATE DOEG NOT IIMl:NO. EXTEND on ALTER THE COVERAGE AFFORDED BY THE POLICIES ElHOW. ---·-···-· ·-·__,;..._ INS UR ERS Af f OROI NG COVERAGE NAJCII ..-----..... -·---------------------------t NS,.,.~£.-C R UI COMPANiE.S , INC 10 1 UNDAl.ANF. -H:AH1 TX 75032 ARCH SPECIAL TY INS CO PROGRESSIVE COUNTY MUHJA.t INS. CO _,, _____ .............. ------............. · -----+------~ ______ j_ .. INSV '!ER () INSVRft~ f.. ---------------------'-------·-··--- I I COV(RAGE·S ............. --....... , .. -# _______ ·-------· T•·•( PO;, (',C Of lf{S,,RANCt US ltD etLOW hAVE BEUi IS5V£0 TO !HE H.JSVRED NAMED A60V!;' FO~ TH€ PQUCY P(q1QO INDICATED. N01"NITHS TANO>NG ,,NY '{t(.'.,J ,>f,','l,.'J l TERM Oil CO>JOn1 0/'1 Df "-N" C()NrRAC I QR OlHER DOC'!JMEN ' WITH R£SPECT TO WHl(l H THIS CERTIFICATE MAY llE ISSIJf.0 OR './-AV Pie»' •. ,, · H 1'1 SU RANCl A>·f OROlcD 8Y 1~.e PQclCES DESCR18ED H(~EI N IS SUBJlC r JO AL L 1HE Tf C1>1.1 S P ( ;1 !\ .. ;t ~: ~,<_,•,H t (.A i t dM!f'i SH ()V>IN 1..\AY '4AVE S EEN R.EOUC:f"O BY PAi O CLAl'-4S EXC~USIONS AMO cc,..iorno,,s OF SlJCt, :i!ir"'-ttr ... P( 0 " INn u ~ANCt ..... +-----·---~~;~~--'.;..'u:..."'...;D:_;<:_" ___ ~i-p-'~"'· .... ,cFc.:;.li~ .... rn·,."~ .. c""'utv""_.,,•.-"'-l,'--P""Q n,,A",.,f(,._.!..,n~""'"'ro,.':'o,.t-.c.:.'··.:.."°'1...~+---·······-····---u~'l's .. 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CCMPl()P A(\(\ 1 000 000 rn ""' ~! n ~f!..0; n.oc 1~l0M0 8l;,.f \,1 A6l,,ll'1 ~ A."ifA;Jl:, ;.. .. , t,-.A"~~eo A_1.ros )( ':,. -e:l.:;,,,d,.Ai .. ros. ~, -,., , ::.;,c:, A i,..•,:~- t"y' ~ .. .............. ~-~-"tt"" ..... ,-... ·---······-··-·--t---------- 12/10/07 '12110/08 C0"-~6-1'0 tHNOLE UfiliT (tt QCCidMf; 1 000,000 ---------------+------·--l 60011.~f INJLR.< (?e! p c,,:,'.)=") P :')!').'Yi1',,Ul)l-{Y (;.,~:t Qcc, non( ··················~-.--.-----. .. r ...... . -----------·------+--------+----------+------·-·-·- I EXCf:.:Sr.!:IO M8Ri::U.A UAOit.lJ 'r :J CC-Ct.,R m CLA:MS V AC E. WOfH(i;:R·i r.:or,M''E.NS A.r 10N ANO f,V,Pi.OYf:R.5 u.a.au .. 1TY A'.'<" r>fJOP"'*' ! ~;V,;.~·f\CfVC,:.CC:... "hl'E Of<i<-ICE 'V~;y~~i:.· ~ .. ACt, .. ,'.":iE:~ SPEC ,~'''f;tt~ ·~~; .s i .. , o.-. t---------+.c.s _________ _ < -·---------t-------.. - 1 ----+'·~--o. s~ ... s, . POi..icv 1 ... 1r.1,r __ 1,. ""' -----···-······-- ........ ________ ,,_ .. ___ ,_ _________________________ ... _ ................. ______ ~----------------~ ()1-M'.,'R :~l·.o~, o .r O Pf.-A;:.j .C)N6,'\ OCAT•O!lll4.'Vt:~_ICt£::,,iE:1.CLVS10N5 AOCEC CY El'4D0tl,6£MEN.rr5PfC;A.i. PI\O'v'l ~tC"f!) l FOR l~H:'.QRVAT IOi~ AND 8 100:NG PURPOSES O NL Y Nov 07 07 04:17p Stocks Insur~nce 9727713?47 p. 1 CERTIFICATE OF LIABILITY INSURANCE DA TE (MM/0Df(YY'f) I 1 i/07/2007 i Pl!OOOCER THIS CE.RTIFlCATION IS ISSUED AS A MATTER Of INFORMATION ·11 ONLY AND CONFERS NO RIGHTS UPON rnE CERTIFlCATE HOLDER. nus CER.TlFICATE ooEs NOT At.lENo, EXTEND OR. I ALTER THE COVERAGE AFFORDED 8Y THE POLICIES BELOW. STOCKS INSURANCE AGENCY ,INC 201 LAURENCE STE 203.PMB 312 HEA·rH TX 75032 ; rms~R/:-0 _____ _ 1 DIANA CROSS OBA RNDI COM PAN IES.I N C 2305 RIDGE ROAD STE 207 ROCKWALL TX 75087 , INSURERS AFFORDING COVERAGE j ! NAJC# ...... -------·-7;~;·:;R-;k-; 1NF1NnY CO~GREAT TX CouNTY MUTUAL-· · 'Y"·-· ' FARMERS lNS EXCHANGE -· ··--·--i i iNS!JRERB: --···-··-··· ·-------~~-------l i INSURE RC; ·-+·---~ l 11'11SURS-R O , I J..-.-----------------------"1-[_1N-=-SU-=-R-€_R-=_E:--_-_-_-_:_-_-_--=--------/-·-·-j cOVEAAGES rnE Pouc1es OF INSURANCE LISTED BELOW HAVE BEEN 1ssue o TO THE INSURED NAMED ABOVE: FOR THE POUcv PEmoo INDICATED. NOTWlTHSTAND!NG j ANY RE?QUIRO/IE'NT. TERM OR CONOmON OF NIY CONTRACT OR OTHER oocur~ENT WITH RESPECT TO WHICH TI1IS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN JS SUBJECT TO ALL THE TERMS, EXCLUS!ONS ANO CONDITIONS OF SUCH I l>OllCIES. 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RETI'.NTION $ I W~ERSCOMPCNSA.'nON ANO C:IIP\..OYEJ\S" UABUJTY AN1 PffOPflJ!ITORl?AR1NERJ£Jll:CUTIVE Ott'!CE!l/MOl;!leR EXCUJDa!7 KY""'lleo<ti!>e\Jtld/,j sP!!CIAL l>ROll'ISIONS bof""' OTHl!lt I l A070Nl2-39 00 l i ! 0 1/\012007 011101200a ~--J rJil?IRiirn...12< I 0 ~;,-···-. _____ _ ~-l;,l.. EACHACCIO!,NT ! S 1.000.000 ' e .L. OISE.Ase -EA EMPLOY!!ii $ 1.000~000 i fiL DISEASE -POLICY I.IMJr $ 1,000,COO I I l CERTIFICATE HOLDER CANCELLATION I .. _. _ _J -----··-----------------------.,.....---------------------------- L ___ ,...._ ______ .. ___ .... _________ ... _ ... _ SttOULb ANY Of 't»I'! A8()Vi, DelCRl"® l>Ol..!Clf/$ SE CA.liC9.1.£0 llEFOR.> 'THf.! l!ltPIRATION OATE THl!llEOf, THE ISS1Ji1'G INWRER Wll.L ENO FAVORTO !AAIL .. 30 .. _ OAYS w,urru,i ,ionct. TO rri e CaRT!FlCAT!i !IOI.~ NAM~D TO 'IHI: Ll!fT, OUT l'Al~\IRE lO DO so Sl<Al.L , .. = NO cHlUOATiO>I OR UAOll.ff'/ OF Alf\' KIND .JIPON Tllli lNSliRER, rrs A(;ENT6 OR REl'RESeNTAl / City of Fort Worth Environmental Department 1000 Throckmorton Fort Worth, Texas 76102 N"ove01berl4,2007 9701 East 1-20 P.O. Box 872 Eastland, Texas 76448 Phone (254) 629-1718 Fax (817) 306-8086 RE: RFQ Wet Demolition of Oak Hollow Office 5901 Boca Rotan Fort Worth, Texas .Mr. Roger Grantham: Eagle Construction and Environmental Services appreciates the opportunity to present this revised proposal to the City of Fort Worth. Should you have any questions, please do not hesitate to me a call. Eastland, Tx (254)629-1718 Fort Worth, Tx (817)847-1333 La Porte, Tx (281)867-9131 Very truly yours, JD May San Antonio, Tx (210)946-2258 Gonzales, La (225)677-7877 Harriman, Tn (865)882-7717 Roger Grantham City of Fort Worth Environmental Department 'll.OlNlCALAPPllOACH Introduction As a full service environmental and demolition company with proven nationwide experience, EAGLE offers the City of Ft. Worth a best value approach to the wet demolition of the building located at 5901 Boca Raton Blvd. Ft. Worth, Texas. Eagle maintains a highly experienced staff represented through the following divisions: • Project Management • Technical Staff • Environmental Safety and Health (ES&H) • Waste Management • Field Supervision • Contracts (includes subcontract management) Each of the above divisions will play an integral role in successful completion of the wet demolition. EAGLE will incorporate key elements such as ES&H and Integrated Safety Management Systems (ISMS) into every function that is performed. Incorporating these functions attribute to a safe work environment and completion of projects within project milestones. This is planning the work and working the plan. II. Technical Approach General Work Activities. The following activities are required for the project as a whole and are not specific to demolition. Specific work activity descriptions begin in section (a) below. Pre-Mobilization Pre-mobilization will consist of preparing required submittals in accordance with the contract. EAGLE maintains a database of similar documents that will allow quick preparation and eliminate lost time due to multiple review cycles. Included in EAGLE's database are documents previously approved on similar projects, which can be tailored to fit task specific requirements. The pre-mobilization submittal process is key in effectively establishing an Integrated Safety Management System into the project. EAGLE will incorporate safety and quality into the work process before the work starts. Each key submittal is prepared with safety and quality in mind. Prior to beginning the submittal preparation process, the key personnel perform a document review including any provided characterization data, facility photos, drawings, specifications, and the contract documents. Documentation review assists the project team with the following: • Familiarize with the scope of work • Evaluate hazards associated with the work • Attempt to identify major issues prior to beginning work • Prepare outline for key submittals Following the above preparation activities, EAGLE key personnel begin to prepare the required pre-mobilization submittals. Key pre-mobilization submittals include the following: Page I Roger Grantham City of Fort Worth Environmental Department • Comprehensive Work Plan. Defines the scope of work and outlines details associated with key phases of work including mobilization, site preparation, deactivation, demolition, environmental cleanup, site restoration and demobilization . Written by Project Manager. • Task Specific Safety and Health Plan. Outlines a task specific approach to safety for the project. Written by the ES&H Manager. • Water Management Plan. Outlines information related to the management of water, including run- off, containment controls and the implementation of best management practices . Worker feedback. Prior to submitting the pre-mobilization documents to the City of Ft. Worth the Project Manager will review them with the project team. This input adds functionality to the documents . Management Review Meeting. Upon review and approval of all required pre-mobilization submittals, EAGLE will conduct an in-house pre-construction meeting. The meeting will establish EAGLE's readiness to proceed with fieldwork. Key topics will consist of the following: o Safety Topic o Detailed Discussion of the Weeks Activities o Introduction of Key Personnel o Waste Management Activities o Preparation for Work Activities o Sequence of Events (Schedule Review) o Submittals o Safety -Submittal Register Review (discuss status 2 documents ) Plan of the Day (POD) Meetings. EAGLE will conduct daily PODs to co ver specific work activities and associated hazards. Each meeting will start with a management safety minute followed by a craft safety minute ( craft is randomly selected). This creates an atmosphere of involvement for craft personnel and gets them thinking safety. The safety minutes are followed by a work improvement minute that allows craft to participate in providing the EAGLE management team with feedback on improving worker safety and/or work methods. The worker improvement minute has provided EAGLE management with an aspect that may not be seen. Mobilization and Site Preparation Following the Notice to Proceed and approval of pre-mobilization submittals, the project team will commence mobilization activities. All personnel required to complete initial mobilization activities will review the project plans including the Comprehensive Work Plan and applicable safety documentation with the Site Superintendent during the POD. During the initial POD, EAGLE will discuss assembly locations and evacuation requirements . All in-house and subcontracted personnel will be notified of transportation routes for equipment deliveries and normal entry and exiting routes. Site activities for mobilization will consist of the following: • Review and Walk-through of Work Area • Porta Toilet Set Up • Establishment of Lay-Down/ Stage Areas • Controls for Water Containment • Establishment of Site postings • Other Equip/Mater ials Set Up • Establishment of Site boundaries • Delivery of Initial Equipment/Materials Also as part of mobilization activities, EAGLE will demarcate site boundaries as required. Best Management Practices (BMP) consisting of absorbent booms and containment areas will be Page 2 Roger Grantham City of Fort Worth Environmental Department installed as necessary and as outlined in the contract documents. Eagle will also contact DIGG TESS utility locates for verification and marking of all utilities in the area. Site Activities a. Site Set-Up EAGLE will use a trackhoe with bucket/grapple attachment to demolish the two stairways and landings on the two buildings on either side of the building to be wet demolished. The demolition debris will be left on site and staged in an area as directed. Six-mill poly sheeting will cover the entire side and rap around the comers of the building sides facing the demolition building. Eagle will cover the ground area around the outer perimeter of the demolition building with 6 mil plastic sheeting and absorbent booms forming the burmed containment. Pumps, hoses and containers will be set to remove and contain excess water for later filtering or disposal. Eagle will construct a 20ft high by 80ft long screen wall utilizing scaffold framing with a 6 mil reinforced poly sheeting attached to the side facing the wet demolition building. The wall will erect along Boca Rotan Blvd., which will be closed to traffic by the City of Ft. Worth during the wet demolition process. Eagle will furnish two generators and power cords ( one main, one stand by) along with one boom lift to be utilized by the City of Ft. Worth Environmental Department and OSHA personnel on site to facilitate installing and recording results from their perimeter monitors. b. Decontamination Area Set Up EAGLE personnel will set up a personnel and equipment decontamination area consisting of 6- mil plastic sheeting and a small berm. Decontamination equipment will consist of a pressure washer, small pump, and poly drums (for water containment) and hand tools such as brushes and wipes for dry decontamination. c. Wetting EAGLE will install a 2" meter on the nearest fire hydrant with fire hose running to a splitter manifold having two spray hoses with adjustable nozzles. A sufficient amount of penetrate will be injected and controlled at the manifold to assure adequate foam action wetting. Wetting of the exterior and interior through existing extension access openings will commence the day prior to demolition and continue through the entire demolition process. Eagle's Asbestos NESHAP Representative will observe and verify the ACM is adequately wet during all of the demolition activities. d. Demolition Eagle will utilize a trackhoe with a bucket/grapple attachment to dismantle the building, taking as large sections as possible and placing them into roll-off boxes (double lined and gate sealed). After the roll-off box is filled to capacity, the two layers of plastic sheeting will be over lapped and sealed with a spray sealant. The roll-off box will be covered with a tarp, properly labeled and manifested for shipment to the designated disposal facility. Eagle will have the appropriate number of roll-off boxes staged, lined and ready to prevent any delays during demolition. A roll- off truck will be on site to handle the boxes from staging through filling and securing. Page 3 Roger Grantham City of Fort Worth Environmental Department e. Personnel Monitoring Eagle will place personnel pumps on operators and technicians in the direct area of asbestos work. Eagle will analyze the pumps for total asbestos count. f. Cleaning Once the building has been removed from its foundation , Eagle will use trackhoe with a scrapper bar to remove the floor coverings to bare concrete. Eagle will pressure wash the floor by making up to two passes or until visually clean . Pressure washing the surface will render the concrete a non-asbestos containing material (ACM). Following decontamination of the slab and equipment, spillage, plastic sheeting, absorbent booms, PPE etc , will be remove and placed in the roll-off boxes with other ACM for disposal. g. Excavation Eagle will remove three inches of soil from the area around the outer perimeter of the floor slab and place it in a roll-off box separated from demolition debris. Following loading the roll-off will be sealed and transported to an approved disposal facility for final disposition. h. Transportation/ Disposal Eagle 's roll-off truck will handle transporting the ACM boxes from the demolition site to Waste Management 's Lewisville, Texas disposal facility. Eagle will collaborate with Waste Management for timely transporting and disposal of all materials along with proper documentation. It is Eagle understanding that a City of Fort Worth Representative will be present to sign transportation documents . A copy of all transportation and disposal documentation will be provided to the City of Fort Worth. i. Slab Removal Following cleaning Eagle will use the trackhoe to break the floor slab into manageable sizes . Concrete will be loaded into an Eagle end-dump and transported to a recycling facility. j. Water All water recovered from the site will be filtered through five micron filters and disposed of at the local POTW or a licensed ACM disposal facility . k. Screen Wall The framework of the screen wall will be disassembled and removed, allowing Boca Rotan to be reopened. I. Demobilization Following completion of work activities, EAGLE will demobilize all personnel, equipment, and materials from the site . Page4 Roger Grantham City of Fort Worth Environmental Department Cost Schedule Wet Demo/ All ACM as outlined above: Personnel and Equipment Rates: Supervisor w/ pickup Operators Technicians Trackhoe Generators (2) Boom.lift Roll-off Truck/trailer Roll-off Bobtail Porte-Johns (2) Scaffolding Rental $ 70.00 Hr $ 55.00 Hr $ 45.00 Hr $110.00 Hr $305.00 Day Ea. $285.00 Day $ 95.00 Hr $ 85 .00 Hr $ 35.00 Day Ea. $1515.00 Ls Eagles proposal is based on the following conditions: $24,950.00 a. Pricing does not include Texas Department of Health Services (DSHS) notification or fees . b. Eagle is not responsible for air monitoring for final clearance. c. No allowance for site restoration has been included. d. Eagle is not responsible for preparation or submittal of an asbestos work plan. e. No sales taxes are included. The City of Ft. Worth will be required to furnish a Tax Exemption Certificate if applicable. Page S EXHIBIT "A" EXHIBIT "A" Project Name : AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page]_ of 99 QUALITY ASSURANCE PROJECT PLAN BUILDING DEMOLITION EVALUATION PHASE III STUDY ALTERNATIVE ASBESTOS CONTROL METHOD FOR BUILDING DEMOLITION December 4, 2007 Prepared by: William M. Barrett and Roger C. Wilmoth U.S. EPA, Office of Research & Development National Risk Management Research Laboratory 26 West Martin Luther King Drive Cincinnati, OH 45268 The Cadmus Group, Inc. 57 Water Street Watertown, MA 02472 The Louis Berger Group, Inc. 2300 N Street, NW Washington, DC 20037 Contract No. EP-C-05-058 Task Order No. 0057 Project Name : AACM Phase III Evaluation Revision No . 0.0 Date: December 4, 2007 Page I.. of99 A.1. QUALITY ASSURANCE PROJECT PLAN APPROVAL SHEET BUILDING DEMOLITION EVALUATION PHASE III STUDY ALTERNATIVE ASBESTOS CONTROL METHOD FOR BUILDING DEMOLITION Contract No. EP-C-05-058 Task Order No. 0057 Alan M . Segrave, P .O ., Division Manager, Laboratory Services Bureau Veritas North America, Inc., Kennesaw, GA Craig Napolitano , Quality Assurance Manager Louis Berger Group , Inc. New York Seth Schultz, Project Manager (Berger) The Louis Berger Group , Inc., New York Holly Wootten , Task Order Lead (Cadmus) The Cadmus Group, Inc., Woodbridge , VA William Barrett, Project Officer ORD , NRMRL , U.S. EPA Roger C . Wilmoth , Program Manager ORD , NRMRL , U.S. E PA Date Date Date Date Date Date A.2. TABLEOFCONTENTS Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 1_ of 99 A.1. QUALITY ASSURANCE PROJECT PLAN APPROVAL SHEET ............................. 2 A.2. TABLE OF CONTENTS ................................................................................................ 3 A.3. DISTRIBUTION LIST ................................................................................................... 9 A.4. PROJECT TASK/ORGANIZATION ........................................................................... 10 A.4.1. Project Organization ............................................................................................. 10 A.5. PROBLEM DEFINITION/BACKGROUND ............................................................... 12 A.5.1. Background ........................................................................................................... 12 A.5.2. Objectives ............................................................................................................. 14 A.5.2.1. Primary Objective ......................................................................................... 14 A.5.2 .2. Secondary Objectives .................................................................................... 14 A.6. PROJECT/TASK DESCRIPTION ............................................................................... 15 A.6.1. Task 1 -Pre-Demolition Site and Building Inspection ......................................... 15 A.6.1.1. Site Description ............................................................................................. 16 A.6.2. Task 2 -Building Demolition ............................................................................... 18 A.6.3. Task 3 -Building Demolition Sampling and Sample Analysis ............................ 18 A.6.4. Task 4 -Quality Assurance Activities .................................................................. 20 A.6.5. Task 5 -Reporting and Deliverables .................................................................... 20 A.6.5.1. Deliverable A. Pre-Demolition Site and Building Inspection Report ........... 20 A.6.5.2. Deliverable B. Draft Report .......................................................................... 20 A.6.5.3. Deliverable C. Final Report .......................................................................... 20 A.6.6. Project Schedule .................................................................................................... 20 A.7. QUALITY OBJECTIVES AND CRITERIA FOR MEASUREMENT DATA ........... 21 A.7.1. Primary Objective ................................................................................................. 21 A. 7.1.1. Step 1: State the Problem ............................................................................. 21 A.7.1.2. Step 2: Identify the Decision ........................................................................ 22 A. 7 .1.3. Step 3: Identify Inputs to the Decision ........................................................ 22 A.7.1 .4. Step 4: Define the Study Boundaries ........................................................... 22 A. 7 .1.5. Step 5: Develop a Decision Rule ................................................................. 23 A.7.1.6. Step 6: Tolerable Limits on Decision Errors ............................................... 23 A. 7.1. 7. Step 7: Optimize the Design for Obtaining Results ..................................... 26 A. 7 .1.8 . Analytical Sensitivity/Limit of Detection ..................................................... 27 A.7.1.9. Data Quality Indicators (DQI) ...................................................................... 27 A .7.1.9.1. Sample Collection DQI.. ........................................................................... 27 A .7.1.9.2. Sample Analysis DQI.. .............................................................................. 28 A.8. SPECIAL TRAINING REQUIREMENTS/CERTIFICATION ................................... 29 A.8.1 . Field Personnel. ..................................................................................................... 29 A.8.2. Laboratory Personnel ............................................................................................ 29 A.9. DOCUMENTATION AND RECORDS ...................................................................... 30 A.9.1. Field Operations Records ...................................................................................... 30 A.9 .1.1. Sample Documentation ................................................................................. 30 A.9 .1.2. Meteorological Measurements ...................................................................... 40 A.9.1.3. Photo Documentation .................................................................................... 40 Project Name: AACM Phase III Evaluation Revision No . 0.0 Date: December 4, 2007 Page!. of 99 A.9 .2. Chain-of-Custody Records .................................................................................... 40 A.9.3. Laboratory Records ............................................................................................... 40 B. MEASUREMENT/DATA ACQUISITION ......................................................................... 42 B.I. EXPERIMENTAL DESIGN ........................................................................................ 42 B.1.1 . Air Dispersion Modeling ...................................................................................... 42 B.1.1. I. Source Identification ..................................................................................... 42 B.1 .1.1.1. Source No . I: Oak Hollow Office Apartment Building Demolition .......... 42 B.1.1 .1.2. Source No. 2: Transfer of Building Demolition Debris into Truck Bed ... 42 B.1.1.1.3. Model Selection ......................................................................................... 43 B.1.1.1.4. Source Characterization ............................................................................ 43 B.1.1 .1.5. SCREEN3 Model ...................................................................................... 44 B.1.2. Monitoring During Demolition ............................................................................. 47 B.1.2.1. Background Air and Surface Monitoring ..................................................... 48 B.1.2.2. Perimeter Air Asbestos Monitoring .............................................................. 48 B.1.2 .3. Worker Personal Breathing Zone Monitoring .............................................. 51 B.1.2.4. Impact of Demolition Activities on the Surrounding Ground Surface ......... 52 B.1.2.5. Settled Dust from Demolition ....................................................................... 53 B.1.2.6. Source , Surface, and Treated Water ............................................................. 53 B.1.3. Amended Water Application and Monitoring ...................................................... 54 B.2 . SAMPLING METHOD REQUIREMENTS ................................................................ 57 B .2 .1. Air Sampling For Asbestos ................................................................................... 57 B .2.2. Personal Breathing Zone Sampling for Asbestos ................................................. 58 B.2.3. Meteorological Monitoring ................................................................................... 58 B.2.4. Pre and Post Demolition Ground Surface Sampling ............................................. 58 B.2.4.1 . Surface soil sampling .................................................................................... 58 B.2.4 .2. Paved Surface Sampling ............................................................................... 59 B.2.5. Settled Dust Sampling ........................................................................................... 59 B.2.6. Water Sampling-Source, Amended Water, Pooled Surface Water, and Treated Efflueunt 59 B.2.7. Costs ...................................................................................................................... 60 B.3. SAMPLE CUSTODY REQUIREMENTS ................................................................... 60 B .3.1. Field Chain-of-Custody ........................................................................................ 60 B.3.2. Analytical Laboratory ........................................................................................... 62 B.4. ANALYTICAL METHOD REQUIREMENTS ........................................................... 62 B .4.1. Air Samples (TEM) ............................................................................................... 62 B.4.2. TEM Specimen Preparation .................................................................................. 62 B .4.3. Measurement Strategy .......................................................................................... 62 B.4.4. Determination of Stopping Point .......................................................................... 64 B.4 .5. Air Samples (PCM) ............................................................................................... 65 B.4.6 . Soil Samples .......................................................................................................... 66 B.4.6.1. Soil Preparation ............................................................................................. 66 B.4 .6.2. Soil Analysis (TEM and PLM) ..................................................................... 66 B.4.7. Settled Dust Samples (TEM) ................................................................................ 66 B.4.8. Pavement Dust Sample s ........................................................................................ 66 Project Name : AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page i. of99 B .4.9. Water Samples ...................................................................................................... 67 B.5. QUALITY CONTROL REQUIREMENTS ................................................................. 67 B.5.1. Field Quality Control Checks ............................................................................... 67 B.5 .1.1. Air Field QC for Asbestos and Total Fibers ................................................. 67 B.5.1 .1.1 . Field Blanks ............................................................................................... 68 B.5 .1.1.2. Field Duplicates ......................................................................................... 68 B.5.1.2. Pavement Dust Field QC .............................................................................. 68 B.5 .1.3. Settled Dust Field QC ................................................................................... 68 B.5.1.3.1. Field Blanks ............................................................................................... 68 B.5 .1.3 .2. Field Duplicates ......................................................................................... 68 B.5.1.4. Water Field QC ............................................................................................. 69 B.5.1.4.1. Field Blanks ............................................................................................... 69 B.5.1.4.2. Field Duplicate .......................................................................................... 69 B.5.2. Laboratory Quality Control Checks ...................................................................... 69 B .5.2.1. Air Laboratory QC ........................................................................................ 69 B.5.2.1.1. LotBlanks ................................................................................................. 69 B.5 .2.1.2. Laboratory Blank. ...................................................................................... 69 B.5.2.1.3. Laboratory Clean Area Blanks .................................................................. 70 B.5 .2.1.4. Replicate Analysis ..................................................................................... 70 B .5 .2.1.5. Duplicate Analysis .................................................................................... 70 B.5.2.1.6. Verification Counting ................................................................................ 70 B.5.2.1.7. Interlaboratory QA Checks ....................................................................... 71 B .5.2.2 . Soil Laboratory QC ....................................................................................... 71 B.5.2.2 .1. Laboratory Blanks ..................................................................................... 71 B.5 .2.2.2. Laboratory Duplicates ............................................................................... 71 B.5.2.2.3. Replicate Analysis ..................................................................................... 71 B .5.2 .3. Settled Dust /Pavement Dust Laboratory QC ............................................... 72 B.5 .2.3 .1. Laboratory Blanks ..................................................................................... 72 B.5.2.3.2. Laboratory Duplicates ............................................................................... 72 B .5.2 .3.3. Replicate Analysis ..................................................................................... 72 B.5.2.4. Water Laboratory QC ................................................................................... 72 B.5.2.4.1. Laboratory Blanks ..................................................................................... 72 B.5.2.4.2. Laboratory Duplicates ............................................................................... 72 B.5.2.4.3. Replicate Analysis ..................................................................................... 72 B.6. INSTRUMENT/EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE REQUIREMENTS .................................................................................................................... 79 B.6.1 . Instrumentation/Equipment.. ................................................................................. 79 B.6.2. Laboratory Equipment/Instrumentation ................................................................ 79 B.7. INSTRUMENT CALIBRATION AND FREQUENCY .............................................. 79 B.7.1. Field Instrument/Equipment Calibration .............................................................. 79 B. 7.1.1. Air Sampling Pumps ..................................................................................... 79 B.7.1.2. Airflow Calibration Procedure ...................................................................... 79 B.7.2 . Calibration of TEM ............................................................................................... 80 Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page§_ of99 B .8. INSPECTION/ACCEPTANCE REQUIREMENTS FOR SUPPLIES AND CONSUMABLES ..................................................................................................................... 80 B.8.1. Air Sampling Filter Media .................................................................................... 80 B.8.2. Sampling Containers for Water Samples .............................................................. 80 B.8.3. Hydrant Water ....................................................................................................... 81 B.9. NON-DIRECT MEASUREMENTS ............................................................................ 81 B.10. DATA MANAGEMENT .......................................................................................... 81 B. l 0.1. Field Data Management.. ...................................................................................... 81 B . l 0.2 . Laboratory Data Management .............................................................................. 81 B.10.2.1. Data Validation ............................................................................................. 82 B. l 0.2.2. Exported Data ............................................................................................... 82 C. ASSESSMENT/OVERSIGHT ............................................................................................. 83 C. l. ASSESSMENT AND RESPONSE ACTIONS ............................................................ 83 C.1.1. Performance and System Audits ........................................................................... 83 C.1.1.1. Field Audit .................................................................................................... 83 C.1.1.2. Laboratory Audits ......................................................................................... 83 C.1.2. Corrective Action .................................................................................................. 83 C.2. REPORTS TO MANAGEMENT ................................................................................. 84 D. DATA VALIDATION AND USABILITY .......................................................................... 85 D.1. DATA REVIEW, VERIFICATION, AND VALIDATION ........................................ 85 D.1.1. Laboratory Data Review ....................................................................................... 85 D.1.2. Field and Laboratory Data Verification/Validation .............................................. 85 D .2. DATA AND SAMPLE ARCHIVAL ........................................................................... 86 E. REFERENCES ..................................................................................................................... 87 Project Name : AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page L of99 APPENDICES Appendix A. Alternative Asbestos Control Method Appendix B. Soil Sample Preparation and Analysis Method for Asbestos LIST OF TABLES Table 1. Roles and Responsibilities of Key Project Personnel .................................................... 11 Table 2. RACM Identified in the former office of the Oak Hollow Apartments, 5901 Boca Raton Boulevard, Fort Worth, Texas ...................................................................................................... 16 Table 3. Major Project Milestones ............................................................................................... 21 Table 4. Upper and Lower Confidence Limits of the Poisson 95-Percent Confidence Interval of a Count. a ........................................................................................................................................ 24 Table 5. Effect Sizes for Type I Error Rate= 0.05, Power= 0.9 ,Based on a Two-Independent Sample t-Test ................................................................................................................................ 26 Table 6. Sample Location Sketch Form ....................................................................................... 31 Table 7. Daily Inspection Log Sheet.. .......................................................................................... 32 Table 8. Contractor Workers/ Visitors Log ................................................................................. 33 Table 9. Asbestos Pavement Sample Chain of Custody Form .................................................... 34 Table 10. Air Sample Field Log .................................................................................................. 35 Table 11. Asbestos Air/Worker Sample Chain of Custody Form ............................................... 36 Table 12. Water Chain of Custody Form ..................................................................................... 37 Table 13. Weather Station Measurement Log ............................................................................. 38 Table 14. Asbestos Bulk Chain of Custody for Soils and Settled Dust Samples ........................ 39 Table 15. Summary of Selected Volume Source Modeling Parameters ...................................... 44 Table 16. Air Monitoring Samples for Asbestos Analysisa ......................................................... 50 Table 17. Worker Breathing Zone Monitoring Samples for Asbestos ........................................ 51 Table 18. Ground Surface Samples for Asbestosa Analysis ........................................................ 52 Table 19. Settled Dust Samples for Asbestosa Analysis .............................................................. 53 Table 20. Source and Surface Water Samples For Asbestosa Analysis ....................................... 54 Table 21. Sample Numbering Scheme ......................................................................................... 61 Table 22. Target Analytical Sensitivity ....................................................................................... 64 Table 23. Stopping Rules For Asbestos Counting ....................................................................... 65 Table 24. Analytical Methods and Quality Assurance (QA)/Quality Control (QC) Checks ....... 73 Table 25. Accepted Analytical Variability For Sample Re-Analysis* ......................................... 78 LIST OF FIGURES Figure 1. Project Organizational Structure .................................................................................. 1 O Figure 2. Oak Hollow Apartment Complex Office Building located at 5901 Boca Raton in Fort Worth , Texas ................................................................................................................................. 17 Figure 3 . Aerial Photograph of Subject Site and Surrounding Area ............................................. 19 Figure 4. Transfer of building debris to truck bed ....................................................................... 43 Project Name : AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page~ of99 Figure 5. SCREEN3 Results for Building Demolition Source (0 to 1,000 feet) .......................... 46 Figure 6. SCREEN3 Results for Building Demolition Source (0 to 100 feet) ............................. 46 Figure 7. SCREEN3 Results for Truck Loading Source (Release Ht =7 ft) ................................ 47 Figure 8. SCREEN3 Results for Truck Loading Source (Release Ht = 15 ft) .............................. 4 7 Figure 9. Sampling Locations ....................................................................................................... 49 Figure 10. Wetting agent supply tank for the AACM demolition ............................................... 55 Figure 11 . Calibration Curve for the NF-3000 Wetting Agent.. .................................................. 57 A.3. DISTRIBUTION LIST Adele Cardenas , USEP A Region 6 Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 2._ of 99 Lauren Drees , USEPA ORD NRMRL QA Officer William Barrett, USEP A NRMRL Project Officer Alan M. Segrave , P.G., Division Manager, Bureau Veritas North America, Inc . Craig Napolitano , Quality Assurance Manager, The Louis Berger Group Bob Olexsey. USEPA NRMRL Seth Schultz, Project Manager, The Louis Berger Group Roger C. Wilmoth, USEPA, NRMRL Program Manager Holly Wootten , Task Order Lead, The Cadmus Group, Inc. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page lQ_ of 99 A.4. PROJECT TASK/ORGANIZATION A.4.1. Project Organization The United States Environmental Protection Agency's (U.S . EPA 's) Office of Research and Development (ORD) and U.S. EPA 's Region 6 are cooperatively conducting this research project to determine the effectiveness of the Alternate Asbestos Control Method. The Cadmus Group, Inc. (Cadmus) is the prime contractor on the project and will have overall responsibility to ensure that the project is conducted in accordance with the approved Quality Assurance Project Plan (QAPP). The Louis Berger Group , Inc. (Berger) will assist Cadmus in the conduct of this study. The overall project organization is presented in Figure 1. It graphically shows the functional organization structure and lines of communication for this project. The project structure along with the technical personnel selections are designed to provide efficient management and a high level of technical competence to accomplish this research project. The roles and responsibilities of key project personnel are summarized in Table 1. ions EPA Reg Enforcemen David Ep 214-665- t Officer pier 6529 of State Texas Department Health Serv Enforcemen ices t Officer -· -,--·- I I I _ .. 1-.. - EPA Program Manage,s l Roger Wilmoth, ORD, NRMRL 513-569-7509 -. ·, ·-··-··- Adele Cardenas, Region 6 1 214-665-7210 : I I I EPA Task Order Manager ...... J. William Barrett ·-··-· 513-569-7720 I Cadmus Program Manager ] Holly Wootten 703-850-1412 I Berger Project Manager Seth Schultz 212-612-7934 I I Demolition Contractor Alan M. Segrave, P.G ., City of Fort Worth Bureau Veritas North Michael Gange America, Inc., 817-392-6569 Kennesaw, GA Figure 1. Project Organizational Structure. EPAQAPP Technical Development Team EPA Quality Assurance Manager Lauren Drees 513-569-7087 Berger QA Manager Craig Napolitano 212-612-7961 I QA /QC Laboratory Analyses REI Jeanne Orr Project Name: AACM Phase III Evaluation Revision No. 0 .0 Date: December 4, 2007 Page 11. of 99 T bl 1 R l a e o es an dR "bT. espons1 1 1t1es o fK P . P ey ro1ect ersonne Personnel Role and Responsibility Roger Wilmoth Program Manager, will have overall administrative and U.S. EPA, ORD, NRMRL technical responsibility for this program. William Barrett Task Order Manager (TOM), will direct the project and ensure U.S. EPA, ORD , NRMRL that it is proceeding on schedule and within budget. Point of contact for Cadmus . QA Officer, will provide QA oversight to ensure that the Lauren Drees planning and plan implementation are in accordance with the U.S. EPA, ORD, NRMRL approved QAPP. In addition, ORD's QA Officer will oversee a field audit and laboratory audit. Holly Wootten Overall Project and Task Order Lead, will have overall Cadmus administrative responsibility for the Cadmus Team and to serve as the primary client interface to ensure continuity between EPA, the Cadmus Team and all subcontractors (listed below) in working towards stated project objectives. Seth Schultz Berger 's Project Manager, will have overall administrative and LBG technical responsibility for LBG on this project. Will also have overall administrative and technical responsibility for Berger and its sub-contractors to ensure that data collection and analysis and the technical report meet the planned study objectives. Craig Napolitano Quality Assurance Manager to ensure compliance with final LBG QAPP and study objectives. Will oversee laboratory analysis and perform data validation. Tracy Bramlett Industrial Hygiene subcontractor to Berger. Conducted building IHST inspection, will perform worker sampling. Jerrold Andrews Demolition Contractor Intercon Environmental , Inc. Michael Gange Management of the AACM demolition contractor City of Port Worth, Texas Alan M . Segrave, P.O., Will provide primary laboratory analysis of asbestos samples Bureau Veritas North America, Inc. Jeanne Orr Will provide quality assurance (QA) secondary sample analysis Reserviors Environmental, Inc (REI) Project Name: AACM Phase III Evaluation Revision No . 0.0 Date: December 4, 2007 Page .12._ of 99 A.5. PROBLEM DEFINITION/BACKGROUND A.5.1. Background The Clean Air Act provides the USEP A with the authority to promulgate and enforce a "work practice standard" for demolition of buildings that contain regulated asbestos containing materials (RACM) if it is not feasible to establish an emission standard . Section 112 of the Clean Air Act, determined asbestos to be a hazardous air pollutant, and the use of asbestos is regulated under the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Asbestos , 40 CFR Part 61 , Subpart M (Asbestos NESHAP). Requirement for the demolition and renovation of buildings that contain asbestos are contained in 40 CFR 61.145. The asbestos NESHAP defines RACM as the following [40 CFR 61.141]: (a) Friable asbestos material, (b) Category I nonfriable ACM 1 that has become friable , (c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding , cutting, or abrading , or (d) Category II nonfriable ACM 2 that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations . The asbestos NESHAP requires emissions control when demolition or renovating a facility if the combined amount of RACM is: [40 CFR 6I.145(a)(l)] • At least 80 linear meters (260 linear feet) on pipes or at least 15 square meters (160 square feet) on other facility components , or • At least 1 cubic meter (35 cubic feet) off facility components where the length or area could not be measured previously. 1 Category I nonfriable asbestos-containing material (ACM) means asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products containing more than 1 percent asbestos as determined using the method specified in 40 CFR 763 , Appendix E(l), Polarized Light Microscopy. 2 Category II nonfriable ACM means any material , excluding Category I nonfriable ACM, containing more than I percent asbestos as determined using the methods specified in 40 CFR 763Appendix E(l), Polarized Light Microscopy that, when dry , cannot be crumbled , pulverized , or reduced to powder by hand pressure. [ 40 CFR 61.141] Project Name: AACM Phase III Evaluation Revision No . 0 .0 Date: December 4, 2007 Page .Ll.._ of 99 For facilities containing asbestos above the threshold quantity, the emissions controls required for demolition include removal of all RACM prior to any demolition activity that w ould break up , dislodge , or similarly disturb the material or preclude access to the material for subsequent removal. The asbestos NESHAP specifies emissions control procedures to be used during RACM removal and/or building demolition [40 CFR 61.145 (c)] and w astes generated during demolition must be disposed of in accordance with the requirements of 40 CFR 61.150. If the facility is being demolished under an order issued by a State or local go v ernment agency because the facility is structurally unsound and in danger of imminent collapse , the RACM is not required to be removed prior to demolition, but the portion of the building that contains RACM must be kept adequately wet during demolition [40 CFR 145(a)(3) and 40 CFR 61.145(c)(9)]. It is generally regarded that the cost of compliance with the asbestos NESHAP is currently forestalling redevelopment efforts in a number of communities because the labor costs associated with removal of the RACM is significantly greater than the costs of building demolition. As a result, the USEPA has devised the Alternate Asbestos Control Method (AACM) that provides emissions controls believed to be equivalent to the current work practices required by the asbestos NESHAP. Previous studies indicated that there were situations where releases of asbestos were documented from demolition acti v ities. These studies included both demolitions conducted by the NESHAP process and ones conducted under imminent danger of collapse situations. (Wilmoth et al 1993 , Wilmoth et al 1994, City of Saint Louis 2004 ). To date , the USEPA has conducted an evaluation of the AACM by performing a controlled side-by-side comparison of the AACM and the NESHAP on identical buildings at Fort Chaffee Redevelopment Authority (Wilmoth et al, 2007). The buildings in the first study had positive asbestos-<:ontaining wall systems and vinyl asbestos floor tile. A follow-up study has also been conducted to evaluate the AACM's ability to control emissions from the demolition of a building that had exterior transite siding. This third phase of the AACM evaluation is intended to evaluate the ability of the AACM to control emissions from a building that has textured wallboard surfaces , such as asbestos- containing popcorn ceiling. The AACM requires that certain RACM (such as thermal sy stem insulation and fireproofing) be removed before demolition in accordance with the asbestos NESHAP ; other RACM (such as transite , wallboard joint compound, res ilient flooring/mastic, glazing compound , popcorn ceilings , etc .) may remain in place. The AACM varies from the e x isting Asbestos NESHAP in the use of an amended-water wetting process , type of demolition equipment, and demolition techniques. Once the RACM has been removed , the demolition can then be conducted using amended water to suppress emissions of asbestos before , during , and after demolition to trap asbestos fiber s, minimizing the potential for release to the air. The RACM is less likel y to become friable w hen the wetting process and demolition techniques specified in the Project Name: AACM Phase III Evaluation Revision No . 0.0 Date: December 4. 2007 Page H_ of99 AACM are used. Wastewater generated during the demolition is collected and filtered , and all debris is disposed of as asbestos-containing waste. Soil in the affected area is excavated and disposed as asbestos-containing waste. Appendix A contains the AACM developed by EPA Region 6 , the EPA ORD, and with input from the EPA QAPP Technical Development Team . The purpose of this research project is to gather additional data to document the environmental and cost-effectiveness of the AACM. A.5.2. Objectives The goal of this research study is to collect data on the environmental effectiveness and cost of the AACM for demolition of buildings that contain popcorn-ceiling style wallboard texture, troweled-on surfacing on walls, and some vinyl asbestos floor tile. The AACM may be considered for modification to the asbestos NESHAP as an additional tool to safely demolish asbestos-containing structures. Emissions must be inferred from measured concentrations in receptors (air, soil, water, dust, and personal monitoring). Because of the complex nature of the potential emissions from building demolition, it is difficult to state in advance precisely how these data will be evaluated, but all the data and observations obtained will be used to document environmental releases, time requirements, and costs. A.5.2.1. Primary Objective 1. To determine the airborne asbestos concentrations during the demolition of the subject building by the AACM process and compare to background concentrations. A.5.2.2. Secondary Objectives The following secondary objectives will provide additional information to further characterize the interrelationships among several multimedia parameters to enhance the understanding of the process and to further the science. These data will also be considered in a holistic sense in assessing the effectiveness of the demolition method: I. To document visible emissions during the AACM demolition. 2. To determine total fibers in air (phase contrast microscopy (PCM)) during the AACM demolition and compare to background concentrations. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date : December 4, 2007 Page 12.. of 99 3. To determine the settled dust asbestos loadings during the building demolition building by the AACM process and compare those to background loadings. WORKER 4. To determine worker breathing zone fiber concentrations (PCM) during the AACM . 5. To determine worker breathing zone asbestos concentrations (TEM-transmission electron microscopy) during the AACM. SURROUNDING SOILS/PAVEMENT/BUILDING SLAB 6. To determine the asbestos concentration in post-cleanup soils and /or pavement (TEM) from the AACM demolition and compare those to pre-demolition soils and/or pavement concentrations and to background soils/pavement asbestos concentrations. WATER 7 . To measure the asbestos concentrations in the source water, the amended water during demolition , the surface water collected during the AACM demolition., and the treated water released to the POTW. TIME 8. To document the time required for all activities related to the demolition by the AACM. COST 9 . To document the cost required for all activities related to the demolition by the AACM and to compare those with estimated costs for demolition of the building by the NESHAP process. A.6. PROJECT/TASK DESCRIPTION The following sections provide a description of each project task. A.6.1. Task 1 -Pre-Demolition Site and Building Inspection The first task was the conduct of a comprehensive pre-demolition inspection in accordance with the Asbestos Hazard Emergency Response Act (AHERA) (40 CFR 763), and the requirements of the American Society of Testing and Materials (ASTM) E2356-04el Standard Practice for Comprehensive Building Asbestos Survey s to identify the type , quantity , location , and condition of Asbestos-Containing Materials (instead of only RACM) in the building in accordance with the asbestos NESHAP and the Texas Department of State Health Project Name: A ACM Phase III Evaluation Revision No . 0.0 Date: December 4, 2007 Page 1§_ of 99 Services (DSHS) asbestos program requirements. This section prov ides an outline of the known environmental condition of the site. A.6.1.1. Site Description The site selected for conduct of this study is the former office building for the Oak Hollow Apartment complex located at 5901 Boca Raton, Fort Worth , Texas . The subject building is a two-story structure that is slab-on grade construction, as shown in Figure 2. It appears that the building was constructed with wood frame , and has exterior brick veneer applied to the lower portion of the structure. The upper portion of the structure use wood panel siding . The building has an asphalt shingled roof. The interior of the building contains a wallboard sy stem that has a surface texture coating and a wallboard system ceiling with asbestos-containing "popcorn" ceiling tex ture. The walls have been painted, likely numerous times , using latex paint. Various flooring materials are present in the structure, including flexible tile with mastic and carpets . The City of Fort Worth conducted an asbestos survey of the building for their own purposes . The RACM identified during this inspection are listed in Table 2. Table 2. RACM Identified in the former office of the Oak Hollow Apartments, 5901 Boca Raton Boulevard, Fort Worth, Texas. RACM Asbestos Estimated Type Description Quantity Type Concentration Location Range Office #1 Upstairs Open Sheetrock Ceiling Texture 2200 ft2 chrysotile 2-5 % Area Next to (Popcorn) Fire Place Lounge , Work Room Sauna Upstairs Open Sheetrock and Joint Area Office #3 Sheetrock 5700 ft2 chrysotile 2% Foyer, Work Compound Room Storage Room Flooring 9" x 9" Floor Tile 80 ft 2 chrysotile 2% Kitchen Materials with Mastic Project Name: AACM Phase III Evaluation Revision No . 0.0 Date: December 4, 2007 Page 11.. of 99 Figure 2. Oak Hollow Apartment Complex Office Building located at 5901 Boca Raton in Fort Worth, Texas. The comprehensive pre-demolition inspection was conducted in accordance with the Asbestos Hazard Emergency Response Act (AHERA) (40 CFR 763) and the requirements of the ASTM E2356-04el Standard Practice for Comprehensive Building Asbestos Surveys to identify the type, quantity , location, and condition of Asbestos-Containing Materials (instead of only RACM) in the building in accordance with the asbestos NESHAP and the Texas Department of State Health Services (DSHS) asbestos program requirements. As noted in the asbestos NESHAP [40 CFR 61.145(a)], in addition to RACM, Category I and Category II Non-friable Asbestos-Containing Materials must also be identified prior to demolition or renovation. The building has been surveyed for the presence of inorganic lead (e .g . lead paint) in accordance with Housing and Urban Development's (1997) "Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing" to characterize the potential for occupational exposure during demolition. Representative composite bulk samples of the suspect lead- containing building materials were collected in accordance with the HUD sampling protocols and analyzed to determine the lead content by EPA SW-846 Methods 3050B/7420. No lead was Project Name : AACM Phase III Evaluation Revision No . 0.0 Date : December 4, 2007 Page l.[_ of 99 present in the paint chips , and as a result, lead is not a concern for either worker exposure or waste disposal. Additionally, the electrical switches in the building were inspected and found to not contain mercury. The ballasts in the fluorescent lights were visually inspected and found to be labeled as "non-PCB containing." The fluorescent light tubes will be removed from the building prior to demolition and properly disposed of, or recycled. The area surrounding the project is primarily residential, including apartment complexes, townhouses and single-family homes , as shown on Figure 3 . The apartment complex that the subject building is located within and the apartment complex to the south , circled in yellow, have been acquired by the City of Fort Worth, are currently unoccupied , and will be demolished following conduct of the AACM evaluation. The apartment complex located to the southeast, across Boca Raton Boulevard , and the apartment complex to the north of the subject building are currently occupied. In addition , a low-density residential community is located approximately 300 feet to the northwest of the subject building. A police substation is located approximately 500 feet southeast of the subject building. For purposes of the evaluation, Boca Raton Boulevard will be closed during the demolition and subsequent soil removal. Additionally, the bus stop located along Boca Raton Boulevard will be relocated. The City of Fort Worth will also construct a wall along Boca Raton Boulevard to provide elevated sampling locations. A.6.2. Task 2 -Building Demolition The AACM building will be demolished using the demolition practices specified in the "Alternative Asbestos Control Method " contained in Appendix A. This task will be conducted by Intercon Environmental, Inc. (Intercon), a contractor to the City of Fort Worth, Texas. The USEPA will coordinate with the City of Fort Worth to conduct the demolition in such a way that the goals of Task 3 -Building Demolition Sampling and Sample Analysis can be accomplished. A.6.3. Task 3 -Building Demolition Sampling and Sample Analysis Task 3 includes the collection and analysis of air, dust, worker , water, soil , and pavement samples in order to evaluate the impact of the AACM at this site. Specific requirements for monitoring are described in Section B of this QAPP. ,.. ,:.,.: ~ ,· Project Name: AACM Phase III Ev aluation Revision No . 0.0 Date: December 4, 2007 Page l2_ of 99 Figure 3. Aerial Photograph of Subject Site and Surrounding Area. A.6.4. Project Name : AACM Phase III Evaluation Revision No. 0.0 Date : December 4, 2007 Page 20 of99 Task 4 -Quality Assurance Activities This project is a Category II Project -this study is being performed to generate data u sed in support of the development of environmental regulations or standards . All field and laboratory data shall be reviewed , verified , and v alidated, including as a minimum, review of field sampling logs , verification of sample collection data ( e.g., air sampler flow rates and volume collected), re v iew of laboratory count sheets , verify count and other data transcription, check all mathematical calculations , and review and summarize QA/QC related sample analyses. The USEPA will conduct on-site audits (laboratory and field ) of project-specific activities. A.6.5. A.6.5.1. Task 5 -Reporting and Deliverables. Deliverable A. Pre-Demolition Site and Building Inspection Report A report of the pre-demolition site and building inspection will be prepared. This report shall include , but are not limited to, a detailed site description , building description, results of the pre-demolition inspection documenting the types and nature of ACM within the building, demolition work plan including schedule , ACM removal cost estimates , demolition cost estimates , field sampling plan , demolition specifications, berm construction details , and water treatment system details. A.6.5.2. Deliverable B. Draft Report A draft report will be prepared of the research project and a final PowerPoint presentation , including a detailed site description , the project-specific methodology employ ed for the demolition, sample collection and analysis , discussion of monitoring data including statistical analysis of the sample data to determine whether project objectives have been met, and cost effectiveness of the demolition technique . The contractor will present a briefing to Agency officials on the results /conclusions. A.6.5.3. Deliverable C. Final Report The draft report will undergo independent peer review at the direction of the USEP A. The contractor shall make the necessary changes after all peer review comments have been received by EPA and communicated to the contractor . A.6.6. Project Schedule Table 3 includes the major milestones . Project Name: AACM Phase III Ev aluation Revision No . 0.0 Date: December 4, 2007 Page ll_ of 99 T bl 3 M . P . t M 0 l t a e . a.t0r roJec 1 es ones ID Task Description Completion Date 1 Kick Off Conference Call -(Site Selected) 10/12/2007 2 Site Visit 11 /1/2007 3 Site Assessment Sampling 11 /1/2007 4 Draft QAPP for Review 11/16/2007 6 Receipt of Site Assessment Laboratory Analysis 11/19/2007 7 Finalize QAPP 11/30/2007 8 Conduct AACM Demo 12/12/2007 9 Laboratory Audit 12/20/2007 10 Data Analysis & Preparation of Draft Report 2/1/2008 11 Review Draft Report 3/1/2008 12 Final Report 4/30/2008 A . 7. QUALITY OBJECTIVES AND CRITERIA FOR MEASUREMENT DATA The ov erall quality assurance objective of this project is to implement procedures for field sampling, laboratory analysis , and reporting that will prov ide data for the development of scientifically valid conclusions and support decision making regarding the project objectives identified in Section A.5.2 . EPA has developed a seven-step Data Quality Objective (DQO) procedure designed to ensure that data collection plans are carefully thought out and to maximize the probability that the results of the project will be adequate to support decision-making (EPA QA/G-4 , August 2000 , EPA/600/R-96/055). This seven-step decision process has been applied to the Primary Project Objective . A.7.1. Primary Objective To determine the airborne asbestos concentrations during the demolition of the apartment complex office building by the AACM process and compare to background concentrations. A.7.1.1. Step 1: State the Problem The asbestos NESHAP (40 CFR Part 61 , Subpart M) requires the removal of RACM prior to demolition of the facility as described in Section A.5. I. Asbestos remov al in accordance with NESHAP can account for a significant portion of the total demolition cost. Because of the abatement cost for these types of buildings , demolition is not occurring in many cases . Demolition of asbestos-containing buildings that have been declared to be unsafe for entry could result in the release of asbestos to the environment because RACM is not required to be removed under this scenario. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date : December 4, 2007 Page 22 of 99 The EPA will perform a controlled demonstration as part of the Agency 's effort to evaluate the effectiveness of the AACM. The AACM, if successful , would likely accelerate the demolition of many orphaned buildings around the nation that remain standing and present a variety of potentially serious risks to nearby residents. A. 7.1.2. Step 2: Identify the Decision Is the airborne concentration of asbestos during demolition of a building and debris loading using the AACM greater than the background asbestos concentration ? A.7.1.3. Step 3: Identify Inputs to the Decision Information that is required to resolve the decision statement: 1. Accurate and representati ve measurements of airborne asbestos concentrations released during demolition of the building using the AACM. 2. An analytical sensitivity that is sufficiently low to detect an anomalies when using the AACM. 3. Accurate and representati ve measurements of the wind speed and wind direction during demolition of the building. 4. Accurate and representati ve background data for use in distributional testing . A.7.1.4. Step 4: Define the Study Boundaries 1. Spatial boundary of th e decision statement: This decision related to the air concentration of asbestos is defined as the area within the sampling ring around the building. This ring is outside the work area, no more than 25 to 35 feet from the building or demolition activities. Further, decisions regarding the air matrix apply to air within the breathing zone of potentially exposed individuals engaged in demolition and debris handling at the Fort Worth site . 2. Temporal boundary of the decision s tatement: Weather conditions such as freezing temperatures will impede the demolition contractor's ability to adequately wet the structure. Rain conditions may influence the transport and deposition of asbestos fibers released from demolition and debris handling. The study will not be conducted during rain or snow conditions . Sustained w ind speeds of 15 mph (60-minute average) or gusts above 20 mph may affect the transport and dispersion of asbestos fibers; i.e., the asbestos concentration would be inversely proportional to the wind speed. To ensure that this does not occur, demolition and sampling will cease when the wind speed in the area exceeds these values. To ensure adequate conditions to detect any visible emissions that are visually detectable without the aid of instruments , the demolition will be conducted during daylight hours (07 :00 to 17 :00 hours). Project Name: AACM Phase III Evaluation_ Revision No. 0.0 Date: December 4, 2007 Page 2.1. of 99 3. Practical constraints on data collection: • Loading of particulate on a single sample filter collected over the entire one-day period of the demolition and debris loading activities could prevent the direct preparation of the filters for TEM analysis .3 To minimize the probability of such an occurrence , the air sampling flow rate has been selected to achieve acceptable filter loading during the sampling period. As an additional safeguard, low volume air samples will be collected at the same locations as the high volume samples. These samples will be archived. Although undesirable, should overloading occur on most filters , an indirect TEM method will be used for analysis (ISO 13794:1999). • The number and placement of stationary air monitors could be affected by demolition and debris handling activities. This is particularly applicable on the southeast side of the buildings where the demolition excavator is located and debris loading activities will occur. Physical constraints for demolition equipment access may necessitate the movement of some samplers as the physical conditions require. A.7.1.5. Step 5: Develop a Decision Rule Decision rules will be used to quantify the degree of difference between various characteristics of the demolition and background data distributions. All hypotheses are set up as one-sided with the alternative hypothesis that some characteristic of the demolition distribution (e.g. mean, median, quantile) is greater than the corresponding characteristic from the background distribution. The result from each of these tests is a p-value, which represents the probability of obtaining the observed difference in the distributional characteristic of interest (e.g. the mean) under the assumption of the null hypothesis that the demolition and background data sets both arise from the same underlying distribution. If the p-value is small, then the assumption that the demolition and background data sets both arise from the same underlying distribution is rejected, and the alternative hypothesis as stated above is concluded. A.7.1.6. Step 6: Tolerable Limits on Decision Errors In the first Fort Chaffee demonstration, there were a high proportion of air sample filters where zero asbestos fibers were identified. The area of a sample collection filter is about 385 square millimeters (mm2), and the area of an individual grid is 0.0091 mm2, or a filter contains about 40,000 grid openings. During the initial study at Fort Chaffee, as many as 50 grid openings The direct transfer TEM method (ISO 10312 :1995) should not be used if the general particulate loading of the sample collection filter exceeds approximately 10 µg /cm 2 of filter surface, which corresponds to approximately 20 percent coverage of the collection filter by particulate. Project Name: AACM Phase III Evaluation Revision No . 0.0 Date: December 4, 2007 Page 24 of 99 Table 4. Upper and Lower Confidence Limits of the Poisson 95-Percent Confidence Interval of a Count.• Structure Count Lower 95 Percent Confidence Limitb 0 0 1 0.025 2 0.242 3 0.619 4 1.090 5 1.624 6 2.202 a Source: ISO Method 10312:1995(E) Annex F, Table F.l. b Two-tailed confidence interval. Upper 95 Percent Confidence Limitb 3 .689 5 .572 7.225 8.767 10.242 11.669 13.060 were counted, resulting in an examination of less than 0.5 mm2 , or an area ofup to 0.12 percent of the total filter area was counted. The Poisson distribution can be used to describe the number of asbestos fibers on a sample collection filter . The 95% Poisson confidence intervals for means ranging from zero to six are displayed in Table 4. A 95% confidence interval would contain the mean number of asbestos fibers 95 times out of one hundred, if the demolition of the same building using the same method were repeated again and again. ISO Method 10312:1995(E) defines the analytical sensitivity as the calculated airborne asbestos structure concentration in asbestos structure/liter, equivalent to counting of one asbestos structure in the analysis. The limit of detection is defined as the calculated airborne asbestos structure concentration per liter equivalent to counting 2.99 asbestos structures in the analysis. Annex F of ISO 10312: 1995(E) indicates that the level of detection is 2 .99 times the analytical sensitivity, which corresponds with the one-sided 95 percent upper confidence interval of the Poisson distribution. As such, fiber counts below 3, which is the one-tailed 95-percent upper confidence interval for a count of zero from a Poisson distribution. In this case, the sample counts will be evaluated to determine whether the data fit a Poisson distribution using a goodness-of-fit test such as the Kolmogorov-Smirnov test or the x2 test such as the Pearson- Fisher. Depending on the distribution of fiber counts observed, the statistical treatment of low fiber count data will be evaluated. A suite of background comparison tests for dealing with a set of data with a large number of non-detect ( censored) data, originally developed in the early 1990s by Dr. Richard Gilbert at Pacific Northwest National Laboratory, will be used to compare the demolition and background data distributions. Each test compares a somewhat different (although correlated) characteristic of the demolition and background data distributions. For each test, if the p-value is small enough ( e .g . less than a significance level of 0.05) the null hypothesis is rejected, and the conclusion is drawn that the demolition data are greater than the background in the context of the characteristic tested. If the p-value is much greater than 0.05 then the demolition and background data Project Name : AACM Phase III Evaluation Revision No. 0.0 Date : December 4, 2007 Page~of99 distributions are considered similar, or the background data are greater than demolition data , which might instead indicate a comparability problem with the background data set. The background comparison suite of inferential tests , t , Gehan, Quantile Q(.80) and Slippage , consists of a single parametric and three non-parametric tests. A parametric test makes assumptions about the underlying distributions , whereas a non-parametric test does not. Distributions are uniquely characterized by parameters (e.g. mean and standard deviation) and hence the name "parametric test." For example , the t-test , which quantifies the observed difference between the means of two distributions , is a parametric test that require s the assumption of normality . The results of the t-test are relatively robust to departures from . normality ; however for extremely skewed or bimodal distributions , the results of the t-test may be suspect. The non-parametric analog of the t-test is the Gehan test, a generalization of the Wilcoxon Rank Sum test that accommodates multiple detection limits through an ordering algorithm. The Gehan test quantifies the degree of difference between the medians of two distributions. As a non-parametric test, the Gehan test is less prone to the effects of v ery extreme data. Statistical tests that ev aluate normality (e .g. D ' Agostino & Pearson) will be used to determine the appropriateness of apply ing the t-test. Two additional non-parametric tests will be used to assess differences that may exist in the tails of the two distributions. Specifically, the Quantile test is used here to determine if there are an anomalously large number of demolition data that exceed the 801 h percentile of the background distribution. This test is performed using combinatorial counting techniques under the assumption that both the demolition and background data arise from the same underl y ing distribution. lfthere are an anomalously large number of demolition data greater than the 80th percentile of the background distribution, then it is concluded that, with respect to statistical significance, the 801h percentile of the demolition data distribution is greater than the 80 1h percentile of the background data distribution. Effectively this means the tail of the demolition distribution is "fatter" than that of the background distribution ; therefore there is a statistical difference in the tails of the distributions. The Slippage test will be used to see if there are an anomalously large number of demolition data that exceed the maximum of the background data . This test is similar in function to the Quantile test. If there are an anomalously large number of demolition data greater than the maximum of the background data , then it is concluded that, with respect to statistical significance , the maximum data of the demolition distribution are greater than the maximum of the background distributions. If any of the p-values from the four hypothesis tests are less than the nominal alpha level of 0.05 , the conclusion from that test will be used for the overall result. The t-test will be included onl y if the assumptions of normality and homogeneity of variance are met. If these assumptions are not met, the conclusion for the overall result will be based on the three nonparametric inferential tests. In addition , exploratory data analysis plots such as box plots , histograms, q-q plots and cumulative distribution plots, will be used as qualitative assessment of the form of the distributions for both demolition and background data. Displays meet the need to see the Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 26 of 99 behavior of the data, to reveal unexpected features, such as outliers; and confirm or disprove assumptions , such as the distributional assumptions of normality and homogeneity of variance required for the t-test. In the event an observation(s) is outside the main body of the data, records will be reviewed for an assignable cause( s) and the data value( s) corrected if appropriate. Even ifthere is no assignable cause(s), the value(s) will be included in all analyses and appropriate measures will taken to meet inferential test assumptions if necessary (i.e., data transformation to meet normality or homogeneity of variance assumptions). A .7.1.7 . Step 7: Optimize the Design for Obtaining Results Using the data from the first Fort Chaffee demonstration (Wilmoth et al, 2007) to estimate the standard deviation for the various matrices effect size differences were calculated using a two sample t-test. An approximation to the standard deviation was used, the range divided by four, due to the number of non -detects. The approximation was used in order to avoid the controversy surrounding which is the "best" method for calculating summary statistics when data are censored. For each standard deviation estimate where censored data were encountered, zero was used as the minimum value. This was done to provide a conservative estimate of the standard deviation. Effect size estimates are based on the proposed sample sizes in Section B 1.2 , a Type I Error rate of 0.05, power of 0.90, and using either a two sample independent t-test. The Type I Error rate is the probability of rejecting the null hypothesis when it is actually true and the power is the probability of rejecting the null hypothesis when it is actually false. The effect size is the smallest mean difference that is statistically significant under the proposed sample sizes and based on the assumption the observed standard deviations are no larger than the estimated. The effect sizes are displayed in Table 5. Table 5. Effect Sizes for Type I Error Rate = 0.05, Power= 0.9,Based on a Two- 1 d d S IT t n epen ent amp et-es Primary Objective: To determine the airborne asbestos concentrations during the demolition of the apartment complex office building by the AACM process and compare to background concentrations. Backf[round Air AACMAir Air Effect Size Sample size = 6 aSD = 0 .00024 s/cm3 Sample size = 18 aSD = 0.00095 s/cm3 0 .00074 s/cm3 .. "SD = Approximate standard deviation ( determmed as the difference between the mm1mum and maximum concentrations divided by four). Minimum and maximum concentrations were generated during Phase l. Ring 2 AACM data used as background, if available; otherwise, NESHAP data used for background . bSD = Standard deviation. A.7.1.8. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 27 of 99 Analytical Sensitivity/Limit of Detection The target analytical sensitiv ity will be 0.0005 structure/cubic centimeter of air (s/cm3) for all asbestos structures (minimum length of::::0.5 µm). An analytical sensitivity of 0.0005 s/cm3 was selected for the following reasons: 1) It is near concentrations that have been reported as a background level of asbestos in ambient air (EPA 1986), and 2) It has been used in other EPA ambient air studies (Wilmoth et al , 2007, Stewart 2003 ; California Env ironmental Protection Agency 2003 ; Wilmoth et al 2004; Wilmoth et al 1990; Kaminsky and Freyberg 1995 ; and "Contaminants of Potential Concern Committee of the World Trade Center Indoor A ir Task Force Working Group " (May 2003)). This analytical sensitivity was also used in the Phase 1 study . Achieving the analytical sensitivity for asbestos in air samples is generally dependent on two factors : the volume of air collected through the filter and the area of the filter analy zed ; i.e., the number of grid sections analyzed multiplied by the area of the grid sections anal yzed. The required analytical sensitiv ity will be achieved for each collected air sample by collecting as large a volume of air as practical and by increasing the filter search areas , as needed . The method detection limit is general considered to be the concentration of the analyte that can be measured and reported with a known confidence that the concentration of the anal yte is significantly different from zero. EPA 's Test Methods for Evaluating Solid Waste, Phy sical/Chemical Methods (SW-846) indicates that the method detection limit is the 99 percent one-tailed upper confidence limit based on the standard deviation of a minimum of three samples with a known spike addition . In accordance with ISO Method 10312: l 995(E), the limit of detection will be 2.99 times analytical sensitivity, which is the one-tailed 95 percent upper confidence interval of a zero fiber count. All samples having less than 3 fibers counted will be treated as non-detect. A.7.1.9. Data Quality Indicators (DQI) A. 7.1.9.1. Sample Collection DQI • Precision is the absolute value of the difference of the two analyses , divided by the square root of the sum , which is an estimate of the standard deviation of the difference based on a Poisson counting model. Precision criteria for co-located samples are presented in Table 25. If these criteria are not met the effect on project conclusions will be evaluated. • Completeness is defined as follows: V %Completeness = -x l 00 N Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page~of99 where V is the number of measurements judged valid, and N is the number of measurements planned. An overall measure of completeness will be given by the percentage of samples specified in the sampling design that yield usable "valid" data. Although every effort will be made to collect and analyze all of the samples specified in the sample design, the sample design is robust to sample loss. The loss of a few samples, provided they are not concentrated at a set of contiguous sectors, will likely have little effect on the false-negative error rate. The project goal is to collect at least 95 percent of the samples specified in the sample design. If completeness objectives are not met the effect on conclusions will be evaluated. • Representativeness is a subjective measure of the degree that the data accurately and precisely represent the sample collection conditions of the environment. Representative sample collection depends on the expertise and knowledge of the personnel to make sure the samples are collected in a manner that reflects the true concentration in the environment. The sampling locations , number of samples, sampling periods , and sampling durations have been selected to ensure reasonable representativeness. • Comparability is a qualitative term that expresses the measure of confidence that one data set can be compared to another and combined for the decision to be made. Data collection using a standard sampling and analytical method (e.g., ISO 10312:1995, counting structures longer than and shorter than five µm in length, and PCME (PCM equivalent fibers 4 ) maximizes the comparability of the results with both past sampling results (if such exist) and future sampling results. A. 7.1.9.2. Sample Analysis DQI Analysis of identical image fields as measured by the primary analytical laboratory who will determine the precision data quality indicator. Precision in number of asbestos fibers and asbestos fiber dimensions from the same filters and image fields from selected tests will be measured. Filters loaded with asbestos collected by air filtration have an inherent variability that is exacerbated by the exceedingly small area analyzed by TEM. Although the variability cannot be mitigated by sampling strategies or sampling preparation strategies, it can be quantified, and if factors exist that are artificially magnifying the variability, those factors can in theory be isolated and identified. The best approach to this is through interlaboratory re-preparation and re-analysis of filters and intra-laboratory re-preparation and re-analysis of filters. Interlaboratory re-analysis establishes that the variability is not caused by the laboratory's sample preparation and analytical techniques. If the laboratory was improperly preparing the samples and was causing the results to consistently bias high or low, then the second laboratory's analysis of numerous samples should A PCME(phase contrast microscopy equivalent) fiber is a fiber with an aspect ratio greater than or equal to 3:1, longer than 5 µm , and which has a diameter between 0 .2 and 3 .0 µm. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 29 of99 reveal this trend. If the samples had exceedingly high variability across the filter ( or if the lab was causing artificial variability through sample preparation and analysis techniques), then this would be revealed by re-preparation and analysis of the filter by the same laboratory. Because no reference materials are available to assess the accuracy of the TEM measurements, the best approach is to establish consensus standards through duplicate analysis of precise sub-samples. This is accomplished through a procedure called "verified counting," which is documented in a National Institute of Standards and Technology (NIST) technical guide and used by asbestos analytical laboratories. Two laboratories (in this case the primary analytical laboratory and the QC laboratory) analyze precise identical areas of the sampling filter , and compare their results , which consist of numbers of asbestos structures and drawings and dimensions of each asbestos structure. In this fashion, they can mutually agree on the concentration of asbestos in the sub-sample, and can verify that each is following the very specific guidelines for asbestos structure counting by TEM. Any lack of precision or presence of bias can be readily established and quantified. A.8. SPECIAL TRAINING REQUIREMENTS/CERTIFICATION A.8.1. Field Personnel Field leaders must have extensive experience in conducting asbestos-related field research studies including those related to building demolitions. A state-licensed Asbestos Abatement Consultant with training in the Asbestos NESHAP ( 40 CFR Part 61 , Subpart M) will be on site during demolition and debris loading activities to oversee the demolition process as well as document the release of any visible emissions. Other field personnel will be properly trained to conduct their job at the site. As appropriate, field personnel shall have experience in asbestos ambient air monitoring, occupational exposure monitoring, related environmental measurements , and data recording. The field personnel will be trained in the requirements of the site-specific Health and Safety Plan (HASP). All personnel entering the containment area demolition will be state licensed asbestos abatement supervisors and/or workers. A.8.2. Laboratory Personnel Laboratory personnel must be familiar with the analytical methods and reporting requirements outlined in the QAPP. Bureau Veritas is a National Voluntary Laboratory Accreditation Program (NVLAP)-accredited lab for the analysis of airborne asbestos. Project Name_:AACM Phase III Evaluation- Revision No. 0.0 Date: December 4, 2007 Page .N_ of 99 A.9. DOCUMENTATION AND RECORDS A.9.1. Field Operations Records A.9.1.1. Sample Documentation The following information will be recorded: • Name(s) of person(s) collecting the sample; , • Date of record ; • Description of sampling site ( e .g., Air Monitoring Station I); • Description of sample including a photographic image showing the sample number; • Location of sample documented on site map with GPS coordinates, as applicable ; • Type of sample (e.g., area, personal, settled dust, water, duplicate , field blank); • Unique sample number that identifies the sampling site, sample type , date , and sequence number; • Flow meter number and airflow reading (start/stop); • Sample time (start/stop) recorded in 24-hour time ; • A pre-printed sheet of sample labels (two identical labels per sample number) will be prepared . One label will be attached to the sample container before sample collection period begins , and the other matching label will be attached to the field data sheet that records relevant data on the sample being collected. The labels will be water-proof and will be printed using indelible ink. • Relevant notes describing site observations such as , but not limited to , site conditions , weather conditions , demolition and debris handling equipment, water application technique (spray or concentrated stream), equipment problems , etc. The notes will be recorded in a bound notebook. Example data forms are presented in Table 6 through Table 14 . At the end of each day , all samples and the corresponding Sampling Data Forms will be submitted to the contractor project manager at the demolition site. The contractor project manager will verify I 00% of the information recorded on the Sampling Data Form for completeness and that all samples are in custody; any discrepancy will be resolved and corrections will be noted , initialed , and dated on the form. Table 6. Sample Location Sketch Form CLll:HT: SIT[: SIHillt>Hi;:ss;. _____________ _ WOF:KillF:l:illlSI .... : ------------ Project Name: AAeM-Plnrsniti~v-aluatiun- Revision No. 0.0 Date: December 4, 2007 Pagell_of99 l)illTI:: ------------ HOHITOF:: l>F:0). HillHilloGl:F:: -------- LS-oG l>F:0). I: SANPU: LOCATION SKJJCH (PER EACH SHIFT) Lr~roi: :I IHSII) illl':l:ill Si11Hl>LI: LOCillT IOH IIWilll Ca••••lo: · !. o·. our s1i:,i:wo1>:K-i111>:1:A sA Hi>LE i:-;c rn~tt 1owA1 > .. , ·1~ . ,, • -· ,. -~ T bl 7 D ·1 I f L Sh a e . auv nspec 100 02 CLIENT: SITE: INSPECTOR: CONTRACTOR: Type of Work being performed: TIME (24-hour) eet Project Name: AACM Phase-1II Evaluation- Revision No. 0.0 Date: December 4, 2007 Pagel2._of99 I PROJECT MANAGER: PAGE OF ---- I SIGNATURE: I IDATE: I CONSTRUCTION ACTIVITIES (Narrative Description of Activities) T bl 8 C a e . on tra c tor W k /V° ·t L or e rs 1s 1 ors oe C ONTRACTOR WORKE RS/ VISITORS LOG CLIENT: I PROJECT MANAGER: SITE : CONTRACTOR: Type of Work Performed : TITLE CE RTIFICATE & LICENSE NAME (Circle one) ADEQ Cert # SUPERVISOR HANDLER SUPERVISOR HANDLER SUPERVISOR HANDLER SUPERVISOR HANDLER SUPERVISOR HANDLER Notes : Project Name: AACM Phase III Evaluat ion Revision No . 0 .0 Date: December 4, 2007 Page 11. of 99 I DATE PAGE OF ---- LICENSE MISC. TYPE OF EXPIRATION EXPIRATI ON RES P. DATE DATE 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 Key: I. Half Face Re s p. 2. Full Face Respirator 3. PAPR 4. Type "C" es pirator 5 . Type C Supplied Air Project Name: AACM Phase III Evaluation R ev is ion No . 0 .0 D ate: December 4, 2007 Page l!_ of 99 Tabl 9 Asb e . estos p avement s I Ch . ampe amo re d F usto 1y orm LOUIS BERGER I ASBESTOS PAVEMENT SAMPLE LOG/CHAIN OF CUSTODY I PAGE_OF _ GROUP, INC. PROJ . NO .: DATE : CLIENT : TECHNICIAN : SIT E: PROJ . MANAGER : RESULTS TO : TURNAROUND TIME : THE LOUIS BERGER GROUP , INC . - TELEPHONE#: (212) 612-7900 FAX #: (212) 425-1 618 ~----------------01 HR 0 4HR 0 6HR ADDRE SS : 199 Water Street 23rd Floor, New York , NY 10038 -· 0 24HR D EMAIL TO : -- SAMPLE ID DESCRIPTION / LOCATION TI ME FLOW RATE (UMI N) VO L UME START/E ND MIN UTES START/E NO AVERAGE (L) SAMPLE# V / . . .. . . . . . . . . PUMP# SAMPLE# V / .. PUMP# . . -. . . SAMPLE# V / .. . . PUMP# SAMPLE# / / . . .. PUMP # . . SAMPLE# / / .. . . PUMP # SAMPLE# / V . . .. . . PUMP# . . SAMPLE# V V .. . . PUMP # . . SAMPLE# V V . . .. . . PUMP# . . TECHNICIAN'l! LQG CASSETTE ROTOMETER TYPE OF SAMPLI NG DPCM 0TEM ID#: I CALIB . DA TE : I~ D BACKGRO UND D POST ABATEMENT D PERIODIC [ALL GIVEN FLOW RATES INCORPORATE TH E D PR E-ABATEMENT DAMB IENT D CALIBRA TIDN FACTOR] D D DURI NG ABATEMENT DOSHA CHAIN OF CUSTODY DATE TIME LABORATORY INFORMATION RelioouishedbY1.-11 /Sian) I I Anil'm LAB NAME : Receilled bY 1.,.;,.,11 (Sion\ I I Anil'm ANALYZE D BY: RelinauishedbY',.,...11 !,~on\ I I Anil'm DATE : I I I TIME : -ReceilledbY',.,.;,,11 fSia nl I I Anil'm QC BY: Relinaui!lhed hll f,...1'11) :/S1Qnl I I Am'Pm DATE : I I I TIME : -Receivedtl'{lrmn •/Ski n\ I I Ani!'m NQTEl!/COM MEN!l! Project N ame: AACM Phase III Evaluati on...... T able 10. Air Sample Field Log The Louis Berger Group, Inc. 199 Water Street, 23rd Floor New York, New York10038 Tel 212 612 7900 Fax 212 363 1618 AIR SAMPLING FIELD LOG Re v ision No . 0.0 Date: December 4 , 2007 Page & of 99 TIME ON: SAMPLE NUMBER TIME OFF: DATE GPS COORDINATES FLOW 2L 4L SAMPLE HEIGHT SAMPLING SESSION WETTING DEMOLITION PUMP NUMBER ' ,,, ' !''i ' .•. . · .i, ?-'£~"Ii -~~ • .,. •.a;.,.~ -,··o • ~ '\,,;'.'":." -, •.• TIME FLOW NOTES 900 2.02 1100 2.12 Changelessthan10% 1300 2.35/2.02* Change greater than 10% sample adjusted back to 2.02 NOTES: All sample time must be in milatary time If sample flow is greater than 10% adjustment must be made back to orignally intended vol. Rotometer correction factor MUST be applied in the field Tabl 11 Ash t A. /W k S e es os Ir or er I Ch . ampe am o Project Name: AACM Phase III Evaluation Revision No . 0.0 Date: December 4, 2007 Page 1Q_ of 99 re d F usto IV orm .LOUIS BERGER GROUP , INC . I ASBESTOS AIR SAMPLE LOG/CHAIN OF CUSTODY I PAGE --OF -- PROJ . NO .: DATE: CLIENT : TECHNICIAN : SITE: PROJ. MANAGER : THE LOUIS BERGER GROUP , INC . RESULTS TO: TURNAROUND TIME: TELEPHONE#: (212) 612-7900 01 HR 04HR 06HR FAX#: (212) 425-1618 AD DRESS : 199 Wate r Street 23rd Floor, New York , NY 10038 024HR D EMAIL TO: -- SAMPLE ID DESCRIPTION / LOCATION TIME FLOW RATE (UMIN) VOLUME START/END r.tNUTES START/END AVERAGE (L) SAMPLE# V V . . ... . . PUMP# SAMPLE# V V PUMP # SAMPLE# Iv V .. PUMP# . . . SAMPLE# V V ... PUMP# SAMPLE# V V .. PUMP# SAMPLE# V V PUMP# SAM PLE# V V PUMP # SAMPLE# V V PUMP# TECHNICIAN'S LOG CASSETTE ROTOMETER TYPE OF SAMPLING 0 PCM DTEM ID#: I CALIB . DATE: I I D BACKGRO UND D POST ABATEMENT D PERIODIC [ALL GIVEN FLOW RATES INCORPORATE THE D PRE-ABATEMENT D AMBIENT D CALIBRATION FACTOR] D D DURING ABATEMENT D OSHA CHAIN OF CUSTODY DATE TIME LABORATORY INFORMATION R.a..v..•ished...,'"""11 !tsion) I I Am/Pm LAB NAME: Recffiecfhvl,...i..t\ fSbol I I Am/Pm ANALYZED BY : RelinQuishedtwtm.n !tsion\ I I Am/Pm DATE : I I I TIME : -Recewedi...i-...t1 ISianl I I Am/Pm QC BY : Relinaulshed..._, ... nn fSbol I I Am/Pm DATE : I I I TIME : -RecePJ9dhv!r.-wl fSbol I I Aln/Pm NOTES/COMMENTS Table 12. Water Chain of Custody Form EMSL Analytical, Inc. Chemistry Lab 307 West JS"' S11tt~ N.V" N.V. n:L: (212) 290-0051 FAX: (112) l90-ll058 REPORT RESULTS TO: Name: Company: Address Cltv State ZIP TEL: FAX: Sampled by: (Signature) Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page TI_ of 99 Chain of Custody/ Analysis Request Form EMSL Project I# Account Rep: Print ALL Information. Put N/A in blanks not Indicate State where sample, collected: applicable SEND INVOICE TO: TURNAROUND TIME Name: PO#: Date Results needed bv: Company •s1udard 6-10 days or 2 "'""' U *16-21 davs or 4 weeks n *ll-15 days or J weeksO Address The following turnaround times require Jab approval: Cltv ~ *4-5 days or I week U 72 Hrs U48Hn State ZIP 24 Hn Approved bv TEL: FAX: •same nrice and tat for weeks or davs Date of Sample Shipment: # of Samples in Shipment: hil•re II COtllplete 1baded areas will hinder proctstl•C of um pies. MATRIX Method Preserved Sampling Lbit Tat Needed " s A s C H H H I 0 D T A 0 I L T C N 2 C T A I T I R u II L 0 s E H T M Sa01ple [ L D [ 3 0 E [ E R G R 4 R Nuraber Station Location /Sample COMP GRAB [ ID 1. 2. 3. 4. 5. 6. 7. 8. 9. 10 Rdeal<dBy Date & Time Rdtntd Delivery Mtlhod Received By Agency Date & Th11e Rueived Condition Noted Sl11nature Slonature Com meats:. PIHae lodlnb: rtporU"I requlmHtlll:01. Rt1•lt1 Only TI2, Rt1•b ind QC LJJ. Redaced Ddlvtnble, 04. Dllk Dellnnoble Table 13. Weather Station Measurement Log Project Name: AACM Phase III Evaluation I Revision No . 0.0 D 1 ate : December 4. 2007 Page~of99 (Use of form is optional-Information must be in bound notebook) Date: Page of Time Wind Speed Wind Direction Barometric Temperature Relative Entries By MPH Pressure, in H2 OF Humidity% Tab le 14 . As bestos B ul k Chain of C usto dy for So il s and Settled Dust Samp les Proj ect Name : AACM Phase III Evalu ation Revision No . 0 .0 D ate : D ecemb er 4, 2 007 Page 12_ of 99 1· I A51U;5IQi EIU LIS kl:t8 1~ QE ~U~IQl2l I PADE:_or_ -·---·-··· . --.. .. --. ·-.. . ---. ; Pf!Ql EiCT NQ.; !. Q!;8I H.HUl ~~ll~:i'.~!;! ; I QJ.W!: tfl0f0S,EO ffiOJ t C..T ; I f' K UJ !!_I_: I ~1111:. I.Ji'II t i 'li I U!' IN 'H 't,\.; II UN : Pm·iS M'i;n3E1§£; ltili!ISii!!rl'.i }; , , lfE-..,.J m1::1 aE l©B9; mw llf , 1R¢. !.liRIL--Dm~ I TUll,llA,P;o l ., TP&: TEIE ~Ho Ne m .: cm ) 6'1:n m W N0,:1,212) :2}3§38 PIH• CDI al ,I l'il GJ I"" ti lrlr ~lllilDlftliH o:atisp [] ·• kll. 0 12 MIi.. tl 2 • li ll. !:I "8 111.. i ... ot fl.Qll3 : 19!W1'11irl:=n~·1 Zhl Foor.-.w.~.N~ ,'.IIIDil ----.. -ifi PPJ;!Oli: HA. S:s.t111~'_ll: S.0/11 P'L E LOCJ).TI ON M.-i TI: R l,.L OE SCRIP TI OH QL~NTITl:' Siadl 5tr:tp Iiml' I ~ fL FfSFl I I I j ' --. -- -- ' c 11 a I gf c;;u 1r::c1g 1 ~-..., r -I . I I _1i;r .... ,--I . I -11·;--· r -I . I !ot,l -..;-"'"' r .. I . I I 11-i'"' r .. I I 11-i •• r -I I .. A.9.1.2. Meteorological Measurements Project Name: AACM Phase III Evaluation Revision No. 0 .0 Date : December 4, 2007 Page 40 of 99 Met One Instruments , Inc or equivalent, meteorological stations will record temperature , barometric pressure , relative humidity, wind speed, and wind direction at five-minute averages. The data files will be downloaded by using an on-site personal computer. These same metrics will also be noted from the instrument 's visual display and recorded on a Meteorological Data Measurement Log (Table 13) at least hourly . A.9.1.3. Photo Documentation A digital photographic image will be taken of every sampling location at the time of sample collection. This will include the sampling station and visual debris on the pavement. A five-inch by seven-inch sample location identification marker that lists the sample number will be shown in the photograph adjacent to the sample and location. The sample location identification will be legibly printed on the sample location identification marker. Other digital photographic images will be taken as necessary to thoroughly document the site conditions (such as "visible emissions ," if such occur) and activities. In addition, a camcorder will be used by EPA staff to videotape the demolition and demolition debris removal operations. A.9.2. Chain-of-Custody Records Sample chain-of-custody procedures as described in Section B.3 shall be followed. A.9.3. Laboratory Records The laboratory shall submit complete data packages for all sample analysis (i.e ., asbestos and total fibers , as applicable) for all matrices (air, settled dust, pavement, and water). This information will be submitted in sufficient detail to allow the subsequent verification of the reported analyses. Alternative forms routinely used by the laboratories may be substituted for those forms specified in the referenced methods. TEM Reporting TEM analytical data reports shall include the following is required: • Structure counting data shall be recorded on forms equivalent to the example shown in ISO 10312:1995. • The test report shall contain items (a) to (p) as specified in Section 11, "Test Report," of ISO 10312: 1995. In addition, the files containing the raw data (in Microsoft Excel format) shall be submitted. The format of these files shall be as directed by the project manager, but shall contain the following items: 1. Laboratory Sample Number 2 . Project Sample Number 3 . Date of Analysis 4. Air Volume 5. Active Area of Sample Filter 6. Analytical Magnification Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 1:1_ of99 7. Mean Grid Opening Dimension in square millimeters (mm2) 8. Number of Grid Openings Examined 9. Number of Primary Structures Detected 10. One line of data for each structure , containing the following information as indicated in Figure 7 "Example of Format for Reporting Structure Counting Data" ofISO 10312 :1995 , with the exception that the lengths and widths are to be reported in millimeters as observed on the screen at the counting magnification: 11. Grid Opening Number 12. Grid Identification 13. Grid Opening Identification/Address 14. Structure or Sub-structure Number 15 . Asbestos Type (Chrysotile or Amphibole) 16. Morphological Type of Structure (fiber, bundle, matrix, cluster) 17. Length of Structure in millimeter (mm) units (e.g., 32) 18. Width of Structure in 0.1 mm units (e.g., 3.2) 19. Any Other Comments Concerning Structure (e.g., partly obscured by grid bar) Project Name: AACM Phase III Evaluation Revision No. 0.0 Date : December 4, 2007 Page 42 of 99 B. MEASUREMENT/DATAACQUISITION B.1. EXPERIMENTAL DESIGN B.1.1. Air Dispersion Modeling This section presents the modeling approach used to assist in the placement of ambient air monitors that will be used to measure the concentration of airborne asbestos fibers during the demolition. Results of the modeling were used as a predictive tool to ev aluate possible monitoring locations, both laterally (x, y) as well as vertically (z), around the building. B.1.1.1. Source Identification The sources identified for purposes of this modeling consist primarily of two major operations taking place during the demolition activities: 1) the actual demolition of the building itself and 2) the loading of the truck bed with demolition debris. These two operations w ill be occurring simultaneously and have the potential to release dust and other airborne particulate matter to the atmosphere . Therefore , both were included in the modeling analysis to account for their potential contributions. The following describes in further detail the characterization of these sources. B.J.J.J.J. Source No.I: Oak Hollow Office Apartment Building Demolition The Oak Hollow Apartment Office Building is approximatel y 3,500 square feet and has a second story loft . A demolition grappler will be used to remove finite sections of the building and then transfer the debris to a large open-bed truck. The demolition process will start at one end of the building and work its way down along the length of the building. The source defined in this case is associated with the extraction of sections of the building being demolished by the grappler prior to loading the debris onto the truck. B.1.1.1.2. Source No. 2: Transfer of Building Demolition Debris into Truck Bed Figure 4 is a photograph of a grappler loading extracted material from a demolition site into a truck bed . As shown in the figure , the grappler has extracted a section of a building and is unloading the debris into the back of a truck. The emission source defined in this case is associated with the potential emissions resulting from the transfer of the extracted material into the bed of the truck. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 43 of 99 --:'.:-,-.-..... · __ Figure 4. Transfer of building debris to truck bed. B.1.1.1.3. Model Selection Two U.S. EPA-approved models , SCREEN3 and the Industrial Source Complex Model , Version 3, in its short-term mode (ISCST3), were considered for use in this analysis. Both models are based on a steady-state Gaussian plume algorithm , and are applicable for estimating ambient impacts from point, area , and volume sources out to a distance of about 50 kilometers. B.1.1.1.4. Source Characterization Due to the nature and extent of the building demolition process , both of these sources are most appropriately modeled as volume sources. A volume source is used to model emissions that initially disperse three-dimensionally with no plume rise . These sources can either be surface based, structure based (elevated sources on or adjacent to a structure), or elevated (elevated sources not on or adjacent to a structure). Typical volume sources include side or roof building vents , conveyor transfer points , emiss ions from a crusher or screen, and emissions from loadin g and unloading trucks . The inputs for modeling a volume source include the following : • Emissions rate (grams per second , g/s) • Initial lateral dimension of the volume source ( cryo ) • Initial vertical dimension, initial depth of the volume source ( crzo ) Table 15 summarizes these inputs for the building demolition and truck loading activities . 2 3 Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 44 of 99 T bl 15 S a e . ummaryo fSI tdVI e ec e oume s ource Md I' P o em2 arameters Source Parameter Basis/Comment Bldg. Demolition 1 Truck Loading2 Emission Rate (g/s) 1 g/s 1 g/s Unit Emission Rate Init. Lateral Dim. ( CJvo ) 0.70 ft 0 .70 ft Defined based on model Init. Vertical Dim. Ccrzo ) 6.98 ft 1.4 ft guidance for ISCST3 14 ft -Avg. Height of Bldg. Release Height (m) --7, 12 , 15 ft Based on multiple drop distances to truck bed. Parameters based on size of grappler (assuming 3 ft x 3 ft) and a building height of 15 ft. Parameters based on size of grappler (assuming 3 ft x 3 ft), height of side wall of truck bed, and a release height evaluated at 7 ft , 12 ft , and 15 ft . U .S. EPA, User's Guide for the Industrial Source Complex (ISC3) Dispersion Models: Volume 2 -Description of Model Algorithms , September 1995 (EPA-454/B-95 -003b), Table 6-1 "Summary of Suggested Procedures for Estimating Initial Lateral Dimensions and Initial Vertical Dimensions for Volume and Line Sources". Refer to the following assumptions described below : Initial Lateral Dimension for both sources: Based on size of grappler (assuming 3 ft x 3 ft), where for single volume source , is equivalent to length of side divided by 4 .3. Thus cry o == 3 ft / 4.3 == 0.70 ft for both source types. Initial Vertical Dimension for both sources: Building Demolition: For an elevated source on or adjacent to a building, the initial vertical dimension is equivalent to the building height divided by 2.15. Thus CTzo == 14 ft / 2 .15 == 6.51 ft. Truck Loading: For an elevated source not on or adjacent to a building , the initial vertical dimension is equivalent to the vertical dimension of the source divided by 4.3. Thus CT zo == 3 ft / 4.3 == 0.70 ft (Assuming the vertical dimension of the grappler is 3 ft). Add the release height of 12 ft ==12 .7 ft; therefore the average height (12.7+6.5)/2== 9.6ft • Release height (m). B.1.1.1.5. SCREEN3 Model SCREEN3 was the U.S. EPA 's regulatory screening model for many New Source Rev iew (NSR) and other air permitting applications . The SCREEN3 model utilizes a predefined Project Name: AACM Phase III Evaluation Revision No . 0 .0 Date : December 4, 2007 Page 12-of 99 matrix of meteorological conditions that cover a range of wind speeds and stability categories (A through F), where the maximum wind speed is stability-dependent. The model is designed to estimate the worst-case impact based on a defined meteorological matrix for use as a "conservative " screening technique. In order to determine the relative extent of impact due to these operations , the SCREEN3 model was used to assess the impacts from the building demolition and truck loading sources defined previously. In lieu of actual emissions data, a unit emission rate of 1 g/s was assigned to each of the two sources. Impacts from these sources were modeled from the source origin out to a distance of 1,000 feet. Receptors were spaced every 5 feet out to 100 feet , then every 100 feet thereafter until reaching a distance of 1000 feet. In addition to the ground level impacts , SCREEN3 has the capability to model elevated (free standing) receptors , called flagpole receptors. Therefore, to assess the potential impacts from these sources at elevations abov e ground level , flagpole receptors were modeled at heights of 5, 10 , and 15 feet. Results of the SCREEN3 modeling associated with the building demolition activities for each of the flagpole heights are shown in Figure 5 and Figure 6. Figure 5 shows the resulting change in concentration as a function of distance from this source out to a distance of 1000 feet. As shown in Figure 5, peak concentrations occur within the first 50 feet of the source and rapidl y taper off as distance from the source increases. Figure 6 presents the same profile from the source out to 100 feet. Figure 6 shows that the peak concentration from the building demolition source is predicted to occur within 10 feet of the source. 0 .0 100.0 Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 46 of 99 Ft. Worth, Texas -SCREEN3 Results -Building Demolition (Based on Volume Source Where: RH= 7.5', Sigma-y = 0 .70", Sigma-z = 6.98') Receptor Height = O feet -.-Receptor Height = 1 O feet 200.0 300.0 400.0 500.0 600.0 700.0 800 .0 900.0 1000.0 Distance from Building, feet Figure 5. SCREEN3 Results for Building Defl!ol~tion S01:_1rce (0 to 1,000 feet) . C .!! ~ I C B ..---------·----·---·-------.----·-----·----·-·--· 0 .0 10 .0 20 .0 30 .0 40.0 50.0 60.0 Distance from Building, feet Receptor He ight= 0 feet --Receptor He ight= 5 feet --Receptor He ight = 10 feet _._ Receptor Height= 15 feet 70.0 80.0 90.0 -I 100.0 Figure 6. SCREEN3 Results for Building Demolition Source (0 to 100 feet). A similar procedure was used to assess the SCREEN3 results for the truck loading source. Figure 7 and Figure 8 display the predicted concentration profiles as a function of Project Name: AACM Phase III Evaluation Revision No. 0 .0 Date: December 4, 2007 Page 47 of 99 distance for source release heights of seven and 15 feet. Multiple source release heights were evaluated because as the bed of the truck becomes full , the distance that the material will drop can change. The data from these figures also shows that the maximum/peak concentrations, regardless of release height, occur within 15 feet of the source origin. 00 10.0 200 30 .0 40 .0 co.o t:1st1n ce lrom Truck ,lul Receptor Heigtt = O eet ----Receptor Heigtt = 5 eet ......-Receptor Heigtt = 10 feet ----Receptor Hei gtt = 15 feet 70.0 80.0 800 1000 Figure 7. SCREEN3 Results for Truck Loading Source (Release Ht =7 ft). DO 100 20.0 311.0 400 50 .0 ~0.0 Ostance from Truck, fut ~ - Receptor He i gtt • O eet ----Receptor Hei gtt = 5 eel ___. Receptor Hel gtt • 1 O leet ---Receptor He l gtt • 15 leet 700 80 .0 900 100 .0 Figure 8. SCREEN3 Results for Truck Loading Source (Release Ht =15 ft). B.1.2. Monitoring During Demolition Project Name: AACM Phase III E valuation Revision No. 0.0 Date: December 4, 2007 Page~of99 Because of the variability of the wind direction, it was concluded that the air and dust sampling design should be based on a concentric ring approach rather than on an upwind to downwind approach. This study design is consistent with the primary objective of this project: i.e., to compare the effectiveness of the AACM to control asbestos emissions during demolition and compare this to the asbestos background levels for air. It is expected that demolition and debris removing/site cleanup will take approximately four to five hours . B.1.2.1. Background Air and Surface Monitoring Background air monitoring will be conducted at a minimum of 500 feet up w ind from the demolition activity . Potential sites for various wind conditions will be GPS located and documented. The background sampling will be conducted during both the demolition and the overnight wetting period. Six background air samples will be collected at a height of five feet. The background samples will be collected during the overnight period, as described below, at an air flow rate of two liter/min from the time that the building was wetted on the previous day until changed out prior to building demolition. Background samples collected during the demolition will be collected at both the two and four liters per minute flow rate over the time required to demolish the building. Air samplers will be spaced at a minimum of three feet apart at the background sampling site. Asbestos in dust will also be monitored. Settled dust collectors will be placed at the same locations as the background air samples . The dust collectors will be placed five feet abo ve ground. · Pavement dust asbestos levels will also be monitored to enable comparisons with the pre- demolition and post-cleanup pavement dust asbestos concentrations . Four microvac samples will be taken in a parking lot of the police substation located southeast of the subject site prior to the conduct of the demolition . B.1.2.2. Perimeter Air Asbestos Monitoring Modeling conducted using the EPA dispersion models SCREEN3 indicates that the maximum airborne asbestos concentrations during demolition and loading of debris will most likely occur approximately between ten and 25 feet from the building and during loading activities at a height between ten to 15 feet above the ground. The perimeter air samplers will be located outside the work area bounded by the amended water containment structures , and the samplers will be placed no closer than 25 feet from the exterior of the building . The 25-ft distance was chosen based upon lessons learned during the first study at Fort Chaffee where some evidence of splashing was observed at the 15-ft distance from the loading process. On the southeast side of the building the monitors in the primary ring will be positioned 20 feet outside the edge of the truck loading area (see Figure 9). Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 49 of99 The primary sampling ring will consist of 18 samplers spaced evenly around the building as shown on Figure 9 . The air sampler intakes in this primary ring will be at a ten-ft height above the ground. The ring will be augmented by six samplers placed on the roofs of the adjacent buildings, of which three will be placed on each roof of the apartment buildings located immediately to the north and south of the subject building. Supplemental air samplers will also be located along the wall to be constructed along Boca Raton Boulevard and near the Woodstock Apartment complex located across Boca Raton Boulevard, east of the building. The supplemental samplers will consist of three sampler locations on the wall, and three in the Woodstock Apartments. X X X X X X I Sidewalks Soil Area 5 Soil Area 6 X X Soil Area 3 Soil Area 4 X X X Soil Area 1 X Soil Area 2 Asphalt Parking Area/Truck Loading X X X X X X X -Air Sampler Location Figure 9. Sampling Locations. Project Name: AACM Phase III E valuation Rev ision No. 0.0 Date : December 4, 2007 Page .2.Q_ of 99 It is assumed that the demolition, construction debris , and cleanup will be completed in one day. The air sampling will commence prior to the wetting of the building on the day before the conduct of the demolition . The sample filters will be changed prior to the rewetting of the building on the morning of the demolition . The second set of samples will be initiated on the morning of the demolition and will continue until demolition/cleanup activities cease for following completion of the demolition . It is assumed that the sampling schedule will be as follows: • 5PM to 6 AM -Wetting and overnight period. • 6 AM to 5 PM -Building demolition and cleanup. All primary air samples will be collected at an air flow rate of four liter/minute to achieve a target air volume of 2,400 liters; however, higher sample volumes can be acceptable if the filters do not become overloaded . In addition , a set of low volume samples will be collected at a flow rate of two liter/minute to achieve a target air volume of 1,200 liters. These samples will be archived and analyzed only if the primary samples are overloaded. The estimated number of air samples to be collected and analyzed for asbestos (including background) is summarized in Table 16 . T bl 16 A' M 't . S a e 1r om ormg amp es fi Abt A I ·a or s es os na1ys1s Overnight ' Demolition Sample Type Samples Samples Number of Samples ,. -. ~ High-Volunfe (41/min , Perimeter A$bestos ,, · "" • ·< •; ' ,, .. :,: <r • ;> Perimeter Ring 18 18 Adjacent Building Roofs 6 6 Wall along Boca Raton Blvd 3 3 Woodstock Apartments 3 3 Duplicates 2 2 Field blank 2 2 Total Samples 34 34 .:.··· "'·-~.,,-· Low-Volume (2-l/min)sPerimeter Asbestosb .. ..• ' "' Efil -~ • • ,, " -~ . (. . ·-· _, .. Perimeter Ring 18 18 36 Adjacent Building Roofs 6 6 Wall along Boca Raton Blvd 3 3 Woodstock Apartments 3 3 Duplicates 2 2 4 Field blank 2 2 4 Total Samples 22 34 56 , . Low and High.Volume Backgrntind Asbestos •' .';;." . ...,.,.;_ ... " ... 't " •. . • ;, 1,J:.,. ,. -" ,,~ Background Samples 6 @2 l/min 6@4 L/min 18 6 (@,2 I/min b Duplicate 1 @ 21/min 1@4 L/min 3 1 (@,2 I/min b . Field blank TOTAL NUMBER OF ASBESTOSS~LES ANALY~D TOTAL NUMBER OF ASBESTOS S,AMI>bES COLLECTEP 1 Project Name: AACM Phase III Evaluation Revision No. 0.0 Date : December 4, 2007 Page 21_ of99 2 3 Samples will be analyzed both for asbestos (ISO 10312 :1995) and total fibers(NIOSH 7400 , A Rules). b These samples will not be analyzed unless the high-volume samples are overloaded with the exception of the overnight .samples they will be analyzed. B.1.2.3. Worker Personal Breathing Zone Monitoring Personal breathing zone samples will be collected from all workers directly involved with the wetting of the building prior to demolition, the demolition of the building, and the handling of the resultant construction debris. Samples for asbestos/total fibers will be collected and the time-weighted average concentration will be calculated for comparison to the OSHA Permissible Exposure Limit for Asbestos (29 CFR §1926.1101). In addition , this monitoring will provide a reasonable characterization of the asbestos concentrations in air closest to the source of any potential release; i.e., building demolition and debris loading. Table 17. Work B th' Z er rea mg one M 't . S om ormg fi Asb t amp es or es os Worker Number of Samples ~ . ,, ·5 Asbesfosa . -C. , '~ ./" ... .. ,, .r> • ..-: .. ;• . Hose Operators, Building Wetting 2 Excavator Operator 1 Hose Operators (2) 2 Laborers (4) 4 Truck Operators (3) 3 Duplicate 2 Field Blank 2 Total Samples 16 a Samples will be analyzed both for asbestos (ISO 10312: 1995) and total fibers (NIOSH 7400, A Rules). Each worker will be fitted with a personal sampling pump to collect samples that represent the entire demolition activity. The samplers will run the entire time the individual is performing the specific assigned task. The estimated number of air samples to be collected and analyzed for asbestos and total fibers is presented in Table 17. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 PageR_of99 B.1.2.4. Impact of Demolition Activities on the Surrounding Ground Surface The potential impact to the ground surface from the demolition activities will be evaluated by comparing the asbestos concentrations on the ground surface (parking lot and soil areas) before demolition ("pre-demol ition") to that after the demolition operations. The soil /ground surface sampling plan has been developed to assess the existing surface materials prior to demolition. The building is surrounded by sidewalks and areas that were formerly planted with grass and maintained. The sidewalks delineate six distinct soil areas surrounding the building. Pre- demolition parking lot pavement and soil samples will be collected prior to demolition of the building. Following demolition and removal of sidewalks and the building slab, a set of post- demolition (pre-excavation) and post-excavation soils samples will be collected. Additionally following the completion of demolition operations, a set of parking lot pavement dust samples will be collected. A total of 13 hard surface dust samples and QA samples will be collected from the paved parking areas. In paved areas, microvac samples will be collected from the surface of the asphalt/concrete pavement. A total of 28 soil samples and QA samples will be collected from the site, one from each of the six delineated areas prior to the demolition, and one from each of 9 grid areas demarcated following demolition, and soil excavation. Four background soil and four background pavement dust samples will also be collected from the surrounding areas . The T bl 18 G a e . roun d s f s ur ace i Abt 8 A I . ampes or s es os na1ys1s Sample Type Number of Samples Pavement/Solid Surface Soil Background 4 4 Field Blank 1 - Pre-Demolition 3 6 Field Blank 1 - Post-Demolition/Cleanup 3 9 Field Blank 1 - Post-Excavation NA 9 Field Blank NA - Total Sani:ples ,;ir · (' . . :L ,_r.:f _ 't) . ,7 .. -, ~ ,,f :}Lf.~~ · 28 -.;, ;_l;~: ., .. ,, :r .. ·;R .• ,· · .. ·,~ '~ .;\;\!-, .. ~ ,,,,._· 1 ~ aTEM only NA-Not applicable. estimated number of ground surface samples to be collected and analyzed for asbestos is presented in Table 18 . B.1.2.5. Settled Dust from Demolition Project Name: AACM Phase III Evaluation Revision No. 0.0 Date : December 4, 2007 Page 21_ of 99 If any asbestos -containing dust is released during the demolition of the building and associated debris-loading activities, it could settle on nearby surfaces. Settled dust collectors will be placed at the same locations as the perimeter air samples. The dust collectors will be placed five feet above ground at 20 -degree intervals at each air sampling monitor location on the sampling ring . All stationary dust containers will be activated by removing the cover shortly before demolition activities begin, and will continue for one hour after demolition activities cease. The estimated number of settled dust samples for asbestos analysis, including background samples , is presented in Table 19. B.1.2 .6. Source, Surface, and Treated Water Source Water-Samples of the source water (i.e., fire hydrant water) applied during the AACM will be collected for asbestos analysis at both the commencement and completion of the building demolition. Samples of the amended water used will also be collected and analyzed for asbestos at both the commencement and completion of the building demolition. Perimeter Ring Adjacent Building Roofs Wall along Boca Raton Blvd Woodstock Apartments Duplicates Field blank Samples Duplicate Field Blanks Total Sam les aTEM only Table 19. Settled Dust Sam Jes for Asbestos8 Anal Overnight Sam les Perfnteter. ; 18 18 6 3 3 2 2 2 2 sis Number of Samples 36 6 3 3 4 4 12 2 2 16 ·72 Project Name: AACM Phase III Evaluation Rev ision No. 0.0 Date: December 4, 2007 Page~of99 Surface Water-As required by the AACM, amended water from the demolition will be controlled and contained to prevent runoff of potentially asbestos-containing water during demolition and debris loading . Representative samples of surface water will be collected during the duration of the demolition activity. Drainage channels or berms will be constructed to direct water runoff for collection in basins . The sampling of the collected runoff water will be spaced over the duration of the demolition activity. Sample collection volumes will be noted as a function of time and as a function of the progression of the demolition. Treated Water-As required by the AACM, water collected from within the containment berms will be.treated using a 5-micron filter prior to disposal. Representative samples of treated water will be collected during the duration of the demolition activity. The sampling of the treated water will be spaced over the duration of the demolition activity . Sample collection volumes will be noted as a function of time and as a function of the progression of the demolition. The estimated number of water samples that will be collected for asbestos analysis is presented in Table 20. T bl 20 S a e ou rce an dS f Wt S ur ace a er amp es F Ab or s estos na1ys1s Number of Samples Sample Type Source Surface Treated Total Samples Hydrant Amended Water 2 3 3 3 11 Duplicate 1 1 1 1 4 Field Blank 1 1 1 1 4 Total Samples 4 5 5 5 19 aTEM only B.1.3. Amended Water Application and Monitoring Amended water is water to which a surfactant (wetting agent) has been added to improve the penetrating capability of water. The surfactant reduces the surface tension of the water which allows it to penetrate a material where water might normally run off, to reach interior spaces of materials. For this study, the chosen surfactant is Kidde Fire Fighting NF-3000 Class "A" Foam Concentrate , as shown on Figure 10. Foaming ingredients give water the ability to adhere to vertical surfaces , which allows the water longer contact with the surface. This w etting agent is similar to Kidde Fire Fighting product Knockdown® that is used by firefighters to aid in extinguishing a fire and is the same wetting agent used in the first AACM study at Fort Chaffee. Project Name: AACM Phase III Ev aluation Revision No. 0.0 Date: December 4, 2007 Page 2i_ of 99 The NF-3000 wetting agent will be added to achieve a target application strength of one- half-percent concentration. According to the manufacturer, the surfactant is effective at significantly lower concentrations. Optimizing the application concentration is not a research goal of this project. It is important for the project to assure that at least O. IO-percent concentration is present at all times in the water applied during the demolition activities. Figure 10. Wetting agent supply tank for the AACM demolition. The amended water can be applied either directly from the flush hydrant equipped with a water meter, nitrile rubber weave construction fire hose , ball shutoff nozzle , and in-line foam eductor system. If used, the proportioning with the eductor system will be tested prior to the demolition to assure adequate delivery at the one-half percent amended concentration. Alternatively, the contractor may opt to use a non-potable water truck to transport water to the site . If a water truck is used , the amended water can be pre-mixed to the desired one-half percent concentration. It should be noted that the use of a water truck is typical procedure for a demolition contractor in remote locations where a city-water source is not av ailable . The wetting agent application system that will be u sed during the pre-wetting of the building consists of a: single 30-gpm high-foaming nozzle and matching eductor. This sy stem Project Name: AACM Phase III Evaluation Revision No. 0 .0 Date : December 4, 2007 Page 2Q_ of 99 prov ides the best foam quality , but has less application range , which is not a problem at this site . The maximum reach of the foam from the 30-gpm nozzle is approximately 30 feet . The wetting agent application system to be used during demolition w ill employ two matched 15-gpm non-aspirating variable-pattern nozzles and matching in-line eductor. Wetting agent proportioning will be verified by performing periodic conductivity measurements of the application flow throughout the duration of the AACM demolition process . According to the National Fire Protection Association (NFPA) Standard for Low-, Medium , and High-Expansion Foam (NFPA 11 , 2005 Edition), there are two acceptable methods for measuring the ~etting agent concentrate in water: (1) Refractive Index Method and (2) Conductiv ity Method . Both methods are based on generating a baseline calibration curve comparing percent concentrations (of pre-measured foam solutions) to the instrument reading . The method selected for the NF-3000 solution concentration determination for this study was the conductivity method. As stated previously, the target application strength of the NF-3000 wetting agent is approximately one-half percent. Therefore , following the procedures contained in the NFP A 11 Standard using the Conductivity Method, three standard solutions will be prepared using the hydrant water and the foam concentrate from the application system . The percent concentrations for the three standards are 0.25 , 0.5, and 1.0 based on a target concentration of one-half percent. The conductivity of each foam solution standard will then be measured and a plot created of the foam concentration versus conductivity . Figure 11 shows the plot serving as the baseline calibration curve for the first Fort Chaffee AACM study which used a foam concentration of one percent. Throughout the duration of the AACM demolition acti vities , the concentration of the wetting agent will monitored by taking conductivity measurements at a minimum of every two hours . Sample collection will take place after water flowed for enough time to assure a good sample. The real-time sample conductivity measurements will be compared with the baseline calibration curve ( conductivity versus concentration) as illustrated in Figure 11. ·-0900 oJOO 1100 ,i ,..., .: I: 0:,00 OlOO Q.IIOQ • = = ~ = --Y. C- 0.5 0361 HI 0.632 u Q~j n .. .. Project Name: AACM Phase III Evaluation Revision No . 0.0 Date: December 4, 2007 Page 5J._ of 99 • --ll y•0.4Q8x +D.123 =::::::: R•,.o.998 :::::t:::. .. LI Figure 11. Calibration Curve for the NF-3000 Wetting Agent. B.2. SAMPLING METHOD REQUIREMENTS B.2.1. Air Sampling For Asbestos The samples for both asbestos and total fibers analysis will be collected on the open-face, 25-mm-diameter 0.45-µm pore size mixed cellulose ester (MCE) filters with a five-µm pore size MCE diffusing filter and cellulose support pad contained in a three-piece cassette with a 50-mm conductive cow l. This design of cassette has a longer cowl than the design specified in ISO 10312 : 1995 , but it has been in general use for some years for ambient and indoor air sampling . Disposable filter cassettes with shorter conductive cowls, loaded with the appropriate combination of filter media of known and consistent origin , do not appear to be generally available. The filter face will be positioned at approximately a 45-degree angle toward the ground. At the end of the sampling period , the filters will be turned upright before being disconnected from the vacuum pump and then stored in this position. The filter assembly will be attached with flexible T ygon ® tubing ( or an equivalent material) to an electric-powered (110-volt alternating current) 1/10-hp v acuum pump operating at an airflow rate of approximately four liter/min. An air volume of 1,920 to 2 ,400 liters is targeted for all samples. Lower volume samples (960-1 ,200 liters) from the same locations w ill also be collected and archived. B.2.2. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page~ of99 Personal Breathing Zone Sampling for Asbestos Personal breathing zone samples for asbestos will be collected on open-face, 25-mm- diameter 0 .8-µm pore size MCE filters with a cellulose support pad contained in a three-piece cassette with a 50-mm conductive cowl. The filter assembly will be attached to a constant-flow, battery-powered vacuum pump operating at a flow rate of two liters per minute. An air volume of approximately 480 to 900 liters will be targeted for all samples . B.2.3. Meteorological Monitoring A portable meteorological station manufactured by Met One Instruments, Inc., and equipped with AutoMet Sensors, or equivalent, will be used to record five-minute average wind speed and wind direction data, as well as temperature, barometric pressure, and relative humidity. The data files will be downloaded and archived using an on-site personal computer. Periodic (at least hourly) direct readout of the data will be recorded on a Meteorological Measurement Log. B.2.4. Pre and Post Demolition Ground Surface Sampling Samples will be collected from the ground surface of the site prior to the initiation of, and following the completion of demolition activities. The pre-demolition sampling will involve collection of samples from the land surface from six soil locations delineated by the sidewalks and three pavement dust samples located in the parking area. In addition, background surface samples will be collected from outside the bermed demolition area to document background asbestos concentrations. The following subsections describe the sampling protocols for either a soil or a pavement finished surface. B.2.4.1. Surface soil sampling Composite soil samples will be collected from the within the portions of the site that has bare soil surface cover. Each composite soil sample will be comprised of six separate grab subsamples. Each grab subsample will be collected from an area measuring six-inches by six- inches with approximately a Yz-inch depth. The area will be delineated using a metal template, which helps ensure that each component of the 6-part composite sample will be of similar mass. Rocks and organic material (e.g., roots larger than Ys-inch, surface grass covering) will be excluded from the subsamples. The soil samples will be collected using a clean metal scooping tool (e.g., a garden trowel) and placed in a clean one-liter plastic container with lid. Between collections of each sample, the template and trowel will be cleaned with detergent water and rinsed with non- asbestos containing water. B.2.4.2. Paved Surface Sampling Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 22.. of 99 Surface dust samples will be collected from portions of the site with paved surfaces prior to and following building demolition using ASTM Method D 5755 -03 entitled "Standard Test Method for Microvacuum Sampling and Indirect Analysis of Dust by Transmission Electron Microscopy for Asbestos Structure Number Surface Loading." In accordance with the Method D 5755 -03, a 10 cm by 10 cm area will be sampled with the microvacuum sampling apparatus. The sampling will be conducted with a 0.45-micron filter for two-minute duration at a rate of 2 liters/min (I/min). The pre-demolition sampling location will be marked with a nail and the post- demolition sample will be collected immediately adjacent to that same location. Then, after debris removal and site cleanup, an additional set of pavement samples will be collected (post-demolition/cleanup). B.2.5. Settled Dust Sampling Settled dust samples for asbestos analysis will be passively collected using ASTM Method D 1739-98 "Method for Collection and Measurement of Dustfall (Settleable Particulate Matter)." The collection container is an open-topped cylinder approximately 6 inches in diameter with a height of 12 inches. The container will be fastened to the same sampling pole as the air samples at a height of 5 feet above the ground. The sampling time for the ASTM protocol will be extended 1 hour beyond the end of demolition activity. Upon completion of sampling the dust collection container will be capped and sealed for shipment to the laboratory. B.2.6. Water Sampling-Source, Amended Water, Pooled Surface Water, and Treated Efflueunt The sample container is an unused, one-liter pre-cleaned, screw-capped, plastic or glass bottle. Prior to sample collection, the water from the water source will be allowed to run for a sufficient period to ensure that the sample collected was representative of the source water. Approximately 800 milliliters of water for each sample will be collected. An air space will be left in the bottle to allow efficient re-dispersal of settled material before analysis. A second bottle will be collected for each sample and stored for analysis if confirmation of the results obtained from the analysis of the first bottle is required. The samples will be transported to the laboratory and filtered by the laboratory within 48 hours of collection. No preservatives or acids may be added to the sample . At all times after collection, the samples will be stored in the dark at about 5° C ( 41 ° F) in order to minimize bacterial and algal growth. The samples will not be allowed to freeze because the effects of freezing on asbestos fiber dispersions are not known. On the same day of collection the samples Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page .@_ of 99 will be shipped in a cooler at about 5° C ( 41 ° F) to the lab for analysis via one-day courier service. B.2.7. Costs All costs associated with all aspects of the demolition will be documented and later analyzed to clearly assign the appropriate cost element to the individual demolition activity . Ultimately, the total costs per unit operation will be obtained and finally summarized. In addition, the City of Fort Worth has obtained cost estimates from contractors for the purpose of comparing the cost of the AACM demolition with the proposed cost of demolishing the building under the current asbestos NESAP. Information that is required to be collected includes but is not limited to : • Obtain contractor estimates on the cost of all labor, materials, and supplies to perform the abatement and demolition of the building as if the NESHAP Method was going to be used . These costs include: preparation of asbestos abatement specifications by a licensed Asbestos Project Designer; removal of the RACM by a licensed asbestos abatement contractor; oversight of the abatement, worker, Personal Breathing Zone monitoring (asbestos and lead), and clearance testing by a licensed asbestos consultant; transportation and disposal of the RACM to a licensed asbestos disposal facility. • Accurate and reliable information on the cost of all labor, materials, and supplies to demolish the AACM Building. These costs include: pre-demolition wetting of the structure ; demolition of the structure using asbestos-trained workers and NESHAP- trained observers; personal protective equipment and OSHA-mandated monitoring for asbestos and lead; transportation and disposal of all construction debris as asbestos- containing waste at a licensed landfill. B.3. SAMPLE CUSTODY REQUIREMENTS Chain-of-custody procedures emphasize careful documentation of constant secure custody of samples during the field , transport, and analytical stages of environmental measurement projects. B.3.1. Field Chain-of-Custody Each sample will have a unique project identification number . A unique sample identification system will be developed for the samples collected at the demolition site as shown in Table 21. This identification number will be recorded on a Sampling Data Form (Table 6) along with the other information specified on the form. After the labeled sample cassettes and containers are inspected, the sample custodian will complete an Analysis Request and Chain-of- Custody Record (Table 9 through Table 14). The required Chain-of-Custody forms will Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page fil__ of 99 accompany the samples, and each person having custody of the samples will note receipt of the same and complete an appropriate section of the form. Samples will be sent to the appropriate Laboratory (see Section A.9.2) via an overnight delivery service, such as Federal Express Overnight Service. T bl 21 S a e . I N b . S h ampe um ermg c eme Monitor Flow Sampling Location Sample Type Rate, Station liter/min Period DUST BG01-BG06 WorD BG AIR BG01-BG06 4L WorD SOIL 01-04 PAVE 01-04 2L HW 01-02 AW 01-02 AWSURF 01-03 TREATW 01-03 WORK NAME 2L Perimeter AIR M01-M18 2L,4L WorD Roofs R01-R06 2L ,4L D PC Boca Raton Wall B01-B03 2L,4L D Where: Woodstock WSOl-02 PAVEPRE 01-10 PAVEPOST 01-010 SOILPRE 01-06 SOILINT 01-06 SOILPOST 01-06 BG=Background PC=Popcorn ceiling Building PA VE= Pavement SOIL= Soils HW=Water from Hydrant AW=Amended Water Source 2L,4L D 2L 2L AWSURF=Amended Water Collected from Surface TREA TW= Treated water WORK=Worker W = Wetting D = Demolition NAME= Last Name of Worker POST=Post Duplicates Blanks DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL DUP BL Project Name : AACM Phase III Evaluation Revision No. 0.0 Date: December 4 . 2007 Page 62 of 99 As an example of the sample numbering scheme, sample PC-AIR-M07-4L-D-DUP designates the duplicate air sample from the· building monitor number 07 , collected during building demolition at the four-liter/min flow rate. Another ex ample would be PC-WORK- DREES-2L , which would be the worker Drees at the two-liter/min flow rate. B.3.2. Analytical Laboratory The laboratory 's sample clerk w ill examine the shipping container and each sample cassette or sample container to verify sample numbers and check for any evidence of damage or tampering. The cqain of custody form w ill be checked by the laboratory for completeness , signed , and dated to document sample receipt. Any changes will be recorded on the original chain-of-custody form and then the form will be forwarded to the Berger Project Manager. The sample clerk will log in all samples and assign a unique laboratory sample identification number to each sample and sample set, in accordance with laboratory standard operating procedures . Chain-of-custody procedures will be maintained in the analytical laboratory. B.4. ANALYTICAL METHOD REQUIREMENTS B.4.1. Air Samples (TEM) Perimeter Samples-The 0.45-µm pore size MCE air sampling filters will be prepared and analyzed using EPA-modified ISO Method 10312:1995 , Ambient Air-Determination of Asbestos Fibres -Direct-Transfer Transmission Electron Microscopy Method." Note: After TEM analysis , a sector from the same filter will then be analyzed using PCM. Personal Samples-The 0.8-µm pore size MCE air sampling filters will be prepared and analyzed using EPA-modified ISO Method 10312: 1995 , Ambient Air -Determination of Asbestos Fibres -Direct-Transfer Transmission Electron Microscopy Method." Note: After TEM analysis , a sector from the same filter will then be analyzed using PCM . B.4.2. TEM Specimen Preparation TEM specimens will be prepared from the air filters using the collapsing procedure of ISO 10312:1995 , as specified for cellulose ester filters. Acetone w ill be used as the solvent in place of dimethylformamide (DMF). For each filter , a minimum of three TEM specimen grids will be prepared from a one-quarter sector of the filter by using 200 mesh-indexed copper grids . The remaining part of the filter w ill be archived in the original cassette in clean and secure storage. B.4.3. Measurement Strategy Project Name : AACM Phase III Evaluation Revision No . 0.0 Date : December 4, 2007 Page §1_ of 99 1. The minimum aspect ratio for the analyses will be 3: 1, as permitted by ISO 10312: 1995. As required in the ISO method , an y identified compact clusters and compact matrices will be counted as total asbestos structures , even if the 3: 1 aspect ratio was not met. 2 . Table 22 presents the size ranges of structures that will be evaluated, and target analytical sensitivities for each TEM method. The laboratories will adjust individual numbers of grid openings counted based upon the counting rules and the amount of material prepared for each sample. 3. The structure counting data will be distributed approximately equally among a minimum of two specimen Wids prepared from different parts of the filter sector. 4 . The TEM specimen examinations w ill be performed at approx imately 20 ,000 magnification. 5. PCM-equivalent asbestos structures , as defined by ISO 10312:1995 , will also be determined. 6 . The type of structure will be specified. In addition to classifying structures as one of the six NESHAP-regulated asbestos types , any other amphibole mineral particles meeting the aspect ratio of~3:1 and lengths ~0.5 µm) will be recorded , (e.g., winchite , richterite), but not included in the total asbestos concentration calculation. Reference to or implication of either use of the term cleavage fragments and/or discriminatory counting does not apply. Table 22. B.4.4. Tan?et Analytical Sensitivity Method ,. ISO 10312:1995 Perimeter Air Direct Preparation ISO 10312:1995 Worker Air Direct Preparation ' EPA/600/R-93/116 , 1993 Soil Modified ASTM D 5755-03 - Settled Dust ASTM D 5755-03 -Pavement Dust EPA 100.2 Water, Flush Hydrant, Pooled Surface Water, and Treated Water Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 64 of99 Structure Size Target Analytical Range Sensitivity All Structures (minimum length of 0.0005 s/cc 0.5 µm; aspect ratio >3:1) All Structures (minimum length of 0.005 fl ee 0.5 µm; aspect ratio >3:1) All Structures (minimum length of 0.1% 0.5 µm; aspect ratio >3:1) All Structures (minimum length of 250 s/cm2 0.5 µm; aspect ratio >3:1) All Structures (minimum length of 1000 s/cm2 0.5 µm ; aspect ratio >3:1) All Structures 0.04 million s/L (minimum length of for Source; 2 million s/L for 0.5 µm; aspect ratio Surface and ~3 :1) Treated Determination of Stopping Point The analytical sensitivity and detection limit of microscopic methods (such as TEM and PCM) are a function of the vol ume of air drawn through the filter and the number of grid openings or fields counted. In principle , any required analytical sensitivity or detection limit can be achieved by increasing the number of grid openings or fields examined. Likewise, statistical uncertainty around the number of fibers observed can be reduced by counting more and more fibers. Stopping rules are needed to identify when microscopic examination should end, both at the low end (zero or very few fibers observed) and at the high end (many fibers observed). Table 23 identifies the stopping rules used for this study. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page Q.2-of 99 Table 23. Stoppm2 Rules For Asbestos Countm2 Method TEM (EPA-modified ISO 10312:1995) Perimeter air TEM , (EPA-modified ISO 10312:1995) Worker air EP A/600/R-93/116, 1993 Soil EPA-modified ASTM D 5755-03 Settled Dust/Pavement Dust Modified EPA 100.2 Water Stopping Rules Count a minimum of four grid openings. If 2: 100 structures are identified, counting is stopped. If <100 structures are identified, count until 100 structures are identified or the required number of grid openings to achieve an analytical sensitivity of 0.0005 asbestos structures/cm3 . Always complete the structure count for the last grid opening evaluated. Count a minimum of four grid openings. If2:100 structures are identified, counting is stopped. If< 100 structures are identified, count until 100 structures are identified or the required number of grid openings to achieve an analytical sensitivity of 0.005 asbestos structures/cm3• Always complete the structure count for the last grid opening evaluated. Count a minimum of four grid openings. If2:100 structures are observed, counting is stopped. If< 100 structures are identified, continue counting additional grids until the 100 structures are counted or until an analytical sensitivity of 0.1 % has been achieved. Always complete the structure count for the last grid opening evaluated. Count a minimum of four grid openings. If2:100 structures are observed, counting is stopped. If< 100 structures are identified, continue counting additional grids until the 100 structures are counted or until an analytical sensitivity of 250 s/cm2 for settled dust or 1000 s/cm2 for pavement samples has been achieved. Always complete the structure count for the last grid opening evaluated. Count a minimum of four grid openings. If2:100 structures are observed, counting is stopped. If< 100 structures are identified, continue counting additional grids until the 100 structures are counted or until an analytical sensitivity of 0.04 million s/L or two million s/L depending on water source has been achieved. If not, continue until this analytical sensitivity has been achieved. Always complete the structure count for the last grid opening evaluated. B.4.5. Air Samples (PCM) Perimeter Samples-The 0.45-µm pore size MCE air sampling filters will be prepared and analyzed for total fibers using NIOSH Method 7400 "Asbestos Fibers by PCM" ("A" Counting Project Name: AACM Phase III Evaluation Revision No . 0.0 Date: December 4, 2007 Page 66 of99 Rules). Fibers greater than 5 µmin length having an aspect ratio greater than or equal to 3:1 will be counted. Personal Samples-0.8-µm pore size MCE air sampling filters will be prepared and analyzed for total fibers using NIOSH Method 7400 "Asbestos Fibers by PCM" (A Counting Rules). Fibers greater than 5 µm in length and with an aspect ratio greater than or equal to 3: 1 will be counted. B.4.6. B.4.6.1. Soil Samples Soil Preparation The composite soil samples will be shipped to the laboratory where the samples will be dried and homogenized as described in the Standard Operating Procedure (SOP) in Appendix B. B.4.6.2. Soil Analysis (TEM and PLM) Soil samples will be analyzed for asbestos using EPA' s "Method for the Determination of Asbestos in Bulk Building Materials" (EPA/600/R-93 /116, July 1993). The specific procedures for implementing this method for the soils in this study are provided in the SOP in Appendix B. B.4.7. Settled Dust Samples (TEM) The analytical sample preparation and analysis for asbestos will follow ASTM Standard D5755-03 "Microvacuum Sampling and Indirect Analysis of Dust by Transmission Electron Microscopy for Asbestos Structure Number Surface Loading" with the following exceptions: Section 10.4.1 through 10.4.3: The sample collection container will be rinsed with approximately 100ml of 50/50 mixture of particle-free water and reagent alcohol using a plastic wash bottle. The suspension will be poured through a 1.0 by 1.0 mm opening screen into a pre- cleaned 500 or 1000 ml specimen bottle. All visible traces of the sample contained in the collection device will be rinsed through the screen into the specimen bottle. The washing procedure will be repeated three times . The volume of the suspension in the specimen bottle will be brought to 500ml with particle free water. Section 16.2 Recording Data Rules: ISO 10312:1995 counting rules will be followed . B.4.8. Pavement Dust Samples The analytical sample preparation and analysis for asbestos will follow ASTM Standard D5755-03 "Microvacuum Sampling and Indirect Analysis of Dust by Transmission Electron Microscopy for Asbestos Structure Number Surface Loading." B.4.9. Water Samples Project Name: AACM Phase III Evaluation Revision No. 0 .0 Date: December 4, 2007 Page 67 of 99 The asbestos content of the water samples will be determined using EPA Method 100 .2 "Analytical Method Determination of Asbestos in Water." The method will be modified to count all structures greater than or equal to 0.5 µmin length and with an aspect ratio of greater than or equal to 3: 1 to achieve an analytical sensitivity of 0.04 million s/L for the source water and 2.0 million s/L for the surface/treated water. B.5. QUALITY CONTROL REQUIREMENTS The overall quality assurance objective is to provide defensible data of known quality meeting quality assurance objectives. To that end, procedures are developed and implemented for field sampling , chain-of-custody, laboratory analysis, reporting , and audits that will provide results which are scientifically valid. B.5.1. Field Quality Control Checks Quality control checks for the field sampling aspects of this project will include , but not be limited to, the following: • Use of standardized forms (e.g., Table 6 through Table 14) to ensure completeness , traceability, and comparability of the data and samples collected. • The air flow rate of the sampling pump will be set to the target value and measured at the beginning, then ever two hours with adjustments as necessary , and at the end of the sampling period. If the flow rate deviates more than ten percent, the impact to the results will be evaluated and the sample will be adjusted to its intended volume. All adjustments and readings will be recorded and factored in to a TWA over the sampling period of time to achieve the sample total volume. • Proper handling of air sampling filters and sample containers to prevent cross contamination . • Collection of field blanks and field duplicate samples. • Field cross-checking of data forms to ensure accuracy and completeness. Strict adherence to the sample chain of custody procedures outlined in this QAPP. B.5.1.1. Air Field QC for Asbestos and Total Fibers Field QC air samples will include field blanks and field duplicates. B.5.1.1.1. Field Blanks Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page .@_ of 99 Field blank samples are used to determine if any contamination has occurred during sample handling. Field blanks will be collected each day of sampling. Field blanks are filter cassettes that have been transported to the sampling site, opened for a short-time(< 30 seconds) near an actual sampling location without any air having passed through the filter , and then sent to the laboratory. B.5.1.1.2. Field Duplicates A duplicate sample is a second sample collected concurrently at the same location as the original sample. B.5.1.2. Pavement Dust Field QC Field QC air samples will include field blanks. Field blank samples are used to determine if any contamination has occurred during sample handling. Field blanks will be collected each day of sampling. Field blanks are filter cassettes that have been transported to the sampling site, opened for a short-time(< 30 seconds) near an actual sampling location without any air having passed through the filter, and then sent to the laboratory. B.5.1.3. Settled Dust Field QC Field QC settled dust samples will include field blanks and field duplicates. B.5.1.3.1. Field Blanks A field blank is prepared by placing a collection device in the field , removing the lid and then immediately replacing the lid. B.5.1.3.2. Field Duplicates A duplicate sample is a second sample collected concurrently at the same location as the original sample. B.5.1.4. Water Field QC Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 69 of 99 Field QC water samples will include field blanks and field duplicates . B.5.1.4.1. Field Blanks A field blank is a clean glass empty container. The container will be opened in the field for approximately 30 seconds. When received at the laboratory , the container will be filled with approximately 800 ml of laboratory water. B.5.1.4.2. Field Duplicate A duplicate sample is a second sample collected at the same location as the original sample, but is collected immediately after the original sample is collected. B.5.2. Laboratory Quality Control Checks A summary of the analytical methods and the quality assurance /quality control (QA/QC) checks is presented in Table 24. B.5.2.1. Air Laboratory QC B.5.2.1.1. Lot Blanks Before air samples are collected, a minimum of two percent of unused filters from each filter lot of 100 filters will be analyzed to determine the mean asbestos structure count. The lot blanks will be analyzed for asbestos structures by using ISO 10312: 1995. If the mean count for all types of asbestos structures is found to be more than 10 structures/mm2 the filter lot will be rejected . B.5.2.1.2. Laboratory Blank Laboratory blanks are unused filters (or other sampling device or container) that are prepared and analyzed in the same manner as the field samples to verify that reagents, tools, and equipment are free of the subject analyte and that contamination has not occurred during the analysis process. The laboratory will analyze at least one blank for every ten samples or one blank per prep series. Blanks are prepared and analyzed along with the other samples. If the blank control criteria (Section B.5 .2.1 .1) are not met, the results for the samples prepared with the contaminated blank are suspect and should not be reported ( or reported and flagged accordingly). The preparation and analyses of samples should be stopped until the source of contamination is found and eliminated. Before sample analysis is resumed , contamination-free conditions shall be demonstrated by preparing and analyzing laboratory clean area blanks (see Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 7Jl of 99 Section B.5 .2.1.3) that meet the blank control criteria. Laboratory blank count sheets should be maintained in the project folder along with the sample results. B.5.2.1.3. Laboratory Clean Area Blanks Clean area blanks are prepared whenever contamination of a single laboratory prep blank exceeds the criteria specified in Section B.5 .2.1.1 or whenever cleaning or servicing of equipment has occurred. To check the clean area , a used filter is left open on a bench top in the clean area for the duration of the sample prep process. The blank is then prepared and analyzed by using ISO Method 10312:1995. If the blank control criteria (see Section B.5.2.1.1) are not met, the area is cleaned by using a combination of HEPA-filter vacuuming and a thorough wet-wiping of all surfaces with amended water. In addition, air samples should be taken in the sample prep room to verify clean air conditions. At least 2,500 liters of air should be drawn through a 25-mm- diameter 0.45-µm pore size MCE filter by using a calibrated air sampling pump. The samples should then be analyzed by using ISO Method 10312: 1995. If blank control criteria are not met, sample preparation shall stop until the source of contamination is found and eliminated. Clean area sample results shall be documented. B.5.2.1.4. Replicate Analysis The precision of the analysis is determined by an evaluation of repeated analyses of randomly selected samples. A replicate analysis will be performed on a percentage of the samples analyzed to assess the precision of the counting abilities of the individual analysts. A replicate analysis is a second analysis of the same preparation, but not necessarily the same grid openings, performed by the same microscopist as in the original analysis. The conformance expectation for the replicate analysis is that the count from the original analysis and the replicate analysis will fall within an acceptable analytical variability as shown in Table 25. B.5.2.1.5. Duplicate Analysis A duplicate sample analysis is also performed on a percentage of the samples analyzed to assess the reproducibility of the analysis and quantify the analytical variability due to the filter preparation procedure. A duplicate analysis is the analysis of a second TEM grid preparation prepared from a different area of the sample filter performed by the same microscopist as the original analysis . The conformance expectation for the duplicate analysis is that the counts from the original and duplicate analyses will fall within the acceptable analytical variability shown in Table 25 B.5.2.1.6. Verification Counting Due to the subjective component in the structure counting procedure, it is necessary that recounts of some specimens be made by a different microscopist (i.e ., a microscopist different than the one that performed the original analysis) in order to minimize the subjective effects. Verification counting will be done by more than one analyst in the initial laboratory and also by Project Name: AACM Phase III Evaluation Revision No. 0 .0 Date : December 4, 2007 Page lL of99 the QC laboratory. Counting will involve re-examination of the same grid openings by the participating analysts. Such recounts provide a means of maintaining comparability between counts made by different microscopists. Repeat results should result in a level of consensus between laboratories such that both laboratories have >80% true positives, <20% false negatives , and <20% false positives in their verified counting analysis of asbestos structures . B.5.2.1. 7. Interlaboratory QA Checks Bureau Veritas shall submit a percentage of air samples to a QA laboratory for verified counting and duplicate analyses as described in the previous sections. B.5.2.2. Soil Laboratory QC For TEM on soils, QC checks include blanks, duplicates , replicates , and verified counting. For PLM on soils, QC checks include duplicates. B.5.2.2.1. Laboratory Blanks A laboratory blank is prepared by filtering 50 mL of water (the same type as used for sample suspension/sonication) through the same type of filter used to prepare TEM grids. A sample blank should be prepared each time a new batch of filters is opened and each time the filtering unit is cleaned. Blanks will be considered contaminated if they have a running average fiber loading greater 18 asbestos structures per square millimeter (EPA 1987). This generally corresponds to three or four asbestos structures found in ten grid openings . The source of the contamination must be found before any further analysis can be performed . Reject samples that are processed along with the contaminated blank samples and prepare new samples after the source of the contamination is found. B.5.2.2.2. Laboratory Duplicates A duplicate sample analysis is also performed on a percentage of the samples analyzed to assess the reproducibility of the sample preparation and analysis. A duplicate analysis is the analysis of a second aliquot of the original soil sample. B.5.2.2.3. Replicate Analysis Replicate analysis will be performed on a percentage of the samples as described for the air samples in Section B.5.2.1.4. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 71... of 99 B.5.2.3. Settled Dust /Pavement Dust Laboratory QC B.5.2.3.1. Laboratory Blanks A laboratory blank is prepared by filtering water through the same type of filter used to prepare TEM grids. A sample blank should be prepared each time a new batch of filters is opened and each time the filtering unit is cleaned. Blanks will be considered contaminated if they have greater than or equal to ten asbestos structures per square millimeter. The source of the contamination must be found before any further analysis can be performed. Reject samples that are processed along with the contaminated blank samples and prepare new samples after the source of the contamination is found. B.5.2.3.2. Laboratory Duplicates A duplicate sample analysis is also performed on a percentage of the samples analyzed to assess the reproducibility of the sample preparation and analysis . A duplicate analysis is the analysis of a second aliquot of the original dust samples aqueous suspension. B.5.2.3.3. Replicate Analysis Replicate analysis will be performed on a percentage of the samples as described for the air samples in Section B.5.2.1. B.5.2.4. Water Laboratory QC B.5.2.4.1. Laboratory Blanks A laboratory blank is prepared by filtering 100 mL of water through the same type of filter used to prepare TEM grids. A sample blank will be prepared with each sample set. B.5.2.4.2. Laboratory Duplicates A duplicate sample analysis is also performed on one of the samples analyzed to assess the reproducibility of the sample preparation and analysis. A duplicate analysis is the analysis of a second aliquot of the original water sample. B.5.2.4.3. Replicate Analysis Replicate analysis will be performed on one of the samples as described for the air samples in Section B.5.2.1.4. Table 24. Analytical Methods and Quality Assurance (QA Method and Matrix Analyte Analytical QA/QC Checks Sensitivity Lot Blanks Laboratory Blanks Laboratory Clean Area Blanks Replicate Analysis (recount by same analyst) EPA-modified Verification Counting Perimeter Air Asbestos ISO Method byTEM 10312:1995; Duplicate Analysis 0.0005 s/cm3 (reprep and analysis by same analyst) lnterlaboratory Verified Counting Interlaboratory Duplicate Analysis Blind recounts on reference slides Blind recounts on filter samples Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 7.]_ of 99 )/Quality Control (QC) Checks Corrective Action if Frequency Acceptance Criteria Acceptance Criteria Not Met 2% of unused <10 asbestos s/mm 2 Reject filter lot filters - Each sample batch <10 asbestos s/mm 2 Collect and analyze clean area blanks ; re-prep filter samples Whenever <10 asbestos s/mmi Find and eliminate source of laboratory blanks contamination do not meet criteria 6 samples Acceptable Analytical Re-examine grids to detem1ine Variability from cause of variation Table 25 4 samples >80% true positives, <20% Re-examine grids to determine false negatives , <20% false cause of variation positives 6 samples Acceptable Analytical Re-examine grids to determine Variability from cause of variation ; re-prep filter Table 25 samples 2 samples >80% true positives, <20% Re-examine grids to determine false negatives, <20% false cause of variation positives 3 samples Acceptable Analytical Re-examine grids to determine Variability from cause of variation ; re-prep filter Table 25 samples Daily Per laboratory control charts Investigate source of imprecision ; re-count reference slides 10% See Step 13 of Method 7400 Investigate source of imprecision ; re-count filter sample Table 24 . Analytical Methods and Quality Assurance (QA)/Quality Control Method and Matrix Analyte Analytical QA/QC Checks Frequency Sensitivity NIOSH Blind recounts on Daily Method 7400; reference slides Total Fibers 0 .006 f/cm 3 by PCM (480 L) Blind recounts on 10% 0.003 f/cm 3 filter samples (960 L) Lot Blanks 2% of unused filters Laboratory Blanks Each sample batch Worker Laboratory Clean Whenever Air Area Blanks laboratory EPA-modified blanks do not Asbestos by ISO Method meet criteria TEM 10312:1995 ; Replicate Analysis 2 samples 0.005 s/cm3 Verification 1 sample Counting Duplicate Analysis 2 samples (reprep and analysis by same analyst) Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 74 of 99 QC) Checks , Continued . Corrective Action if Acceptance Criteria Acceptance Criteria Not Met Per laboratory control Investigate source of charts . imprecision ; re-count reference slides See Step 13 of Method Investigate source of 7400 imprecision ; re-count filter sample <10 asbestos s/mm.:: Reject filter lot <l O asbestos s/mm.:: Collect and analyze clean area blanks ; re-prep filter samples <10 asbestos s/mm2 Find and eliminate source of contamination Acceptable Analytical Re-examine grids to Variability from determine cause of variation Table 25 >80% true positives, Re-examine grids to <20% false negatives , determine cause of variation <20% false positives Acceptable Analytical Re-examine grids to Variability from determine cause of variation ; Table 25 re-prep filter samples Project Name: AACM Phase -..-~ , 1 • · ~,.. J ~v a uat 1 m Rev · i1n No. (J.0 Date:~ Page&of 19 Table 24. Analytical Methods and Quality Assurance I QA)/Qualitv Control (QC) Checks, Continued. Method and QA/QC Acceptance Corrective ~cfon if Matrix Analyte Analytical Frequency Sensitivitv Checks Criteria Acceptance C l"'i t tria Not 2%of Met Lot Blanks unused <l O asb_estos filters s/mm2 Reject filter Jot 1 per 10 Collect and analyze c lean Laboratory samples or <IO asbesto s Blanks each sample s/mm2 area blanks; re-pr p fi lter batch sampl Whenever ASTMD Laboratory laboratory <10 asbestos 5755-03; Clean Area blanks do Find and elimin ate so ur ce Settled 250 s/cm2 Blanks not meet s/mm2 of contamination Dust/Pavement Asbestos by (Settled Dust) criteria TEM Dust and 6 settled 1000 s/cm2 dust Acceptable (pavement) Replicate samples , 1 Analytical Re-examine grids to Analysis pavement Variability from determine cause of dust Table 25 variation samples 6 settled dust Acceptable Reprepare and re-examine Duplicate samples , l Analytical sample to determine cause Analysis pavement Variability from of variation ; re-prep filter dust Table 25 sampl es samples J Table 24. Matrix Soil Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page~of99 Analytical Methods and Quality Assurance I QA)/Qualitv Control (QC) Checks, Continued. Method and QA/QC Acceptance Corrective Action if Analyte Analytical Frequency Acceptance Criteria Not Sensitivity Checks Criteria Met Laboratory Each sample Running average Find and eliminate source Blanks batch <18 s/mm2 of contamination; re-prep samples EPA/600/R-93/116 Acceptable Re-examine grids to Asbestos by (TEM) Replicate 3 samples Analytical determine cause of TEM 0.1% Analysis Variability from variation Table 25 Acceptable Duplicate Analytical Re-examine grids to Analysis 3 samples Variability from determine cause of Table 25 variation; re-prep samples EPA/600/R-93/116 Acceptable Reprepare and re-examine Asbestos by Duplicate Analytical PLM (PLM) Analysis 3 samples Variability from sample to determine cause 0.1% Table 25 of variation '\ Table 24. Matrix Water Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 77 of99 Analytical Methods and Quality Assurance i QA)/Quality Control (QC) Checks, Continued . Method and QA/QC Acceptance Corrective Action if Analyte Analytical Frequency Acceptance Criteria Not Sensitivity Checks Criteria Met 2%of Lot Blanks unused <10 asbestos Reject filter lot filters s/mni2 1 per 10 Collect and analyze clean Laboratory samples or <10 asbestos area blanks; re-prep filter Blanks each sample s/mm2 samples batch EPA 100.2; 0.04 Whenever million str/liter Asbestos by source Laboratory laboratory <10 asbestos Find and eliminate source TEM Clean Area blanks do s/mm2 of contamination 2 million str/ liter Blanks not meet runoff criteria Acceptable Re-examine grids to Replicate 1 sample Analytical determine cause of Analysis Variability from Table 25 variation Acceptable Reprepare and re-examine Duplicate 1 sample Analytical sample to determine cause Analysis Variability from of variation; re-prep filter Table 25 samples Table 25 Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page TI_ of 99 . Accepted Analytical Variability For Sample Re-Analysis* Type of Sample Accepted Variability lab replicate 1.96 lab duplicate 2.24 Air Samples Interlaboratory duplicate, co-2.50 located Non-Air Samples lab replicate 2.24 lab duplicate 2.50 Note: These accepted variabilities will be used as guidelines to assess data quality: no data will be automatically excluded 'without thorough review. AnalysisA -AnalysisB Analytical Variability = ~ AnalysisA + AnalysisB which is the absolute value of the difference of the two analyses , divided by the square root of the sum, which is an estimate of the standard deviation of the difference based on a Poisson counting model. For replicate air samples, for which the simple Poisson model is most directly applicable , the value 1.96 is chosen so that the criterion will flag approximately 1 replicate pair out of 20 for which the difference is due only to analytical variability, i.e., it has a "false positive" rate of 5%. For the other types of analyses , where greater natural variability is expected than indicated by a pure Poisson model, the criterion value has been increased from 1.96 in order to avoid flagging too many cases where the difference between the values is due only to normal variation, and not to any problem with either analysis. The values 2.24 and 2.50 were selected as targeting false positive rates of 2.5% (1/40) and 1.125% (1/80) for the Poisson model. Example 1: For replicate air samples where A= 0 fibers and B = 3 fibers, the variation is considered acceptable, while A = 0 and B = 4 would be flagged for further investigation. Likewise A = 1 and B = 6 is acceptable, while A = 1 and B = 7 is flagged. At higher levels, A = 20 and B = 34 is acceptable, but A = 10 and B = 24 is flagged. Example 2: For interlab duplicate non-air samples, A= 0 and B = 6 is acceptable, but A= 0 and B = 7 is flagged. Likewise , A = 1 and B = 8 is acceptable, but A = 1 and B = 9 is flagged. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page 79 of 99 B.6. INSTRUMENT/EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE REQUIREMENTS B.6.1. Instrumentation/Equipment Field equipment/instruments (e.g., sampling pumps , meteorological instrumentation) will be checked and calibrated before they are shipped or carried to the field . The equipment and instruments will be checked at least daily in the field before and after use. Spare equipment such as air sampling pumps and conductivity meter will be kept on site to minimize sampling downtime . A backup meteorological instrument will be available onsite . B.6.2. Laboratory Equipment/Instrumentation As part of the laboratory 's QA/QC Program, a routine preventive maintenance program is performed to reduce instrument failure and other system malfunctions of transmission and scanning electron microscopes. The laboratory has an internal group and equipment manufacturers ' service contract to perform routine scheduled maintenance , and to repair or to coordinate with the vendor for the repair of the electron microscope and related instruments. All laboratory instruments are maintained in accordance with manufacturer specifications and the requirements ofISO Method 10312:1995. B. 7. INSTRUMENT CALIBRATION AND FREQUENCY B.7.1. Field Instrument/Equipment Calibration B.7.1.1. Air Sampling Pumps Before the sampling pumps are used in the field, their performance will be evaluated by a qualified technician. The air sampling pumps for asbestos sampling, which are the primary air sampling item , will be evaluated to determine that they are capable of maintaining a stable flo w rate for a given static pressure drop; i.e., the pressure drop created by a 25-mm, 0.45 µm MCE membrane filter with a five-µm pore-sized MCE backup diffusing filter and cellulose support pad contained in a three piece cassette at a flow rate of 4 liter/min @ STP. The air sampling pumps with a flow control valve will be evaluated to ensure that they are capable of maintaining a stable flow rate for a given static pressure drop ; i.e., the pumps can maintain an initial volume flow rate of within+/-10% throughout the sampling period. B.7.1.2. Airflow Calibration Procedure Flow measurements will be taken by either a primary standard or secondary standard that has been pre-calibrated in the laboratory using a primary standard. Primary standard calibration documentation will be available in the field. The flow meter will be placed downstream of the Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page~of99 filter cassette at the beginning, every two hours and ending of the sampling periods and the measurement recorded. A detailed written record will be maintained of all calibrations. The record will include all relevant calibration data, including the following elements: • Flow meter model and serial number • Sampling train (pump , flow control valve, and filter) • Relevant calculations Pump checks will be performed at least every two hour during sample calibration . These periodic checks will include the following activities: • Observe the sampling apparatus (filter cassette, vacuum pump , etc.) to determine whether it's been disturbed. • Check the pump to ensure that it is working properly. • Inspect the filter for overloading and particle deposition • Record all information (location, pump number, time, flow rate , and corrective action) in a log book. B. 7 .2. Calibration of TEM The TEM shall be aligned according to the specifications of the manufacturer . The TEM screen magnification, electron diffraction (ED) camera constant, and energy dispersive X-ray analysis (EDXA) system shall be calibrated in accordance with the specifications in ISO Method 10312:1995 , Annex B. B.8. INSPECTION/ACCEPTANCE REQUIREMENTS FOR SUPPLIES AND CONSUMABLES B.8.1. Air Sampling Filter Media See Section B.5 .2 .1.1 regarding the quality control check of the filter media. B.8.2. Sampling Containers for Water Samples Sample containers used to collect water samples for asbestos analysis will be provided by the Bureau Veritas who will be responsible for pre-cleaning these containers as required by EPA Method 100.2. B.8.3. Hydrant Water Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page .ll_ of 99 Hydrant water was collected prior to the demolition to verify its acceptability for use. B.9. NON-DIRECT MEASUREMENTS No data are needed for project implementation or decision making that will be obtained from non-measurement sources such as computer data bases, programs, literature files, or historical data bases. B.10. DATA MANAGEMENT Commercially available computer hardware and software will be used to manage measurement data to ensure the validity of the data generated . Controls include system testing to ensure that no computational errors are generated and evaluation of any proposed changes to the system before they are implemented. Commercially available software does not require testing, but validation of representative calculations is required by using alternative means of calculations . B.10.1. Field Data Management Field data will be entered into a Microsoft Excel spreadsheet (or other applicable spreadsheet) to facilitate organization, manipulation, and access to the data. Field data will include information such as sampling date , sample number, sampling site , sample description and location, sample type, air volume, sampling period and weather patterns for that day. Information will be collected and recorded via daily Jogs and chains ---of-custodies (COC) in order to have a seamless flow of project specific data that can be QA/QC'ed accordingly. The project logs will record the contractors as well as the consultant project site specific activities. Special consideration will be given to the sample location graph as well as the contractor's progress with the demolition activities. The consultant (Berger) will be adequately staffed to provide ample attention to each activity (i.e . air sample calibration and COC, QA/QC, monitoring of demolition contractor's activities . It is anticipated that several consultant personnel will be on-site throughout the project from setup until completion in order to actually capture all of the data , work practices, and sampling required by the QAPP. B.10.2. Laboratory Data Management Laboratory data will be entered into a Microsoft Excel spreadsheet ( or other applicable spreadsheet) to facilitate organization, manipulation, and access to the data. Laboratory data will include information such as sample number, sample date received and analyzed, type of analysis, magnification, grid location, grid square area, filter type, number of grids examined, number of asbestiform structures counted, structure type (fiber, bundle, cluster, or matrix), and structure length and width . An example format for reporting the structure counting data is contained in Figure 7 ofISO Method 10312:1995 . Project Name: AACM Phase III Evaluation Revision No . 0.0 Date: December 4, 2007 Page~ of99 Bureau Veritas utilizes an automated Laboratory Information Management Sy stem (LIMS) to record , document and assimilate pertinent field , laboratory, and administrative data. The validation of this software, including final report templates are performed by the Corporate MIS Department and the Quality Assurance Department. Data validation is a continuing process that takes place every time samples arrive at the laboratory and is carried through during log in, analysis and final reporting. This process is performed by the Laboratory Manager each time a final report goes through the procedures of review and signature. All calculations and reporting performed by the software is implemented by the Laboratory Management, the Corporate MIS staff or the Quality Assurance (QA) Department. This coordination between the QA. Department, Laboratory Management and the MIS Department allows the software to be reviewed and altered as necessary to comply with regulatory agencies and/or accrediting organizations requirements. B.10.2.1. Data Validation In addition to the initial verification, there is a continual validation process that occurs each time that the Laboratory Manager proofs a report prior to release to the client. If any of the errors that are found during this proofing process are not traced back to transcription or analytical error, then the computer system is suspect and will be investigated. The processes that undergo this continuous validation include: • Sample Receiving • Sample Log In • Sample Analysis • Analytical Results Entry • Proofing of Reports B.10.2.2. Exported Data Exported data is provided in a variety of formats. Export formats for data deliverables are implemented and controlled by the corporate MIS staff, which has the flexibility to implement new export formats as required. Electronically delivered data is not intended to replace hard copy results. Final , signed client reports are submitted in addition to delivery by email or diskette. In this way , exported data can be verified. Laboratory data is typically exported into a Microsoft Excel spreadsheet to facilitate organization, manipulation, and access to the data. Laboratory data will include information such as sample number, sample date received and analyzed , type of analysis , magnification, grid location, grid square area, filter type , number of grids examined , number of asbestiform structures counted, structure type (fiber, bundle , cluster, or matrix), and structure length and width . C. ASSESSMENT/OVERSIGHT Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page~of99 C.1. ASSESSMENT AND RESPONSE ACTIONS C.1.1. Performance and System Audits C.1.1.1. Field Audit The EPA-ORD QA Officer (or their representative) will audit the field sampling and data collection activities. The audit will include, but not be limited to , the examination of sample collection and equipment calibration procedures, sample labeling, sampling data and chain-of- custody forms , and other sample collection and handling requirements specified in the QAPP. Prior to the audit, a detailed checklist will be developed for use based on the approved QAPP. The auditor will document any deviations from the QAPP so that they can be corrected in a timely manner. Prior to leaving the site, the auditor will debrief the EPA-ORD Task Order Manager and the Berger Project Manager regarding the results of the audit and any recommendations, if necessary . The results of the audit will be presented in a written report prepared by the auditor to the EPA-ORD Task Order Manager. C.1.1.2. Laboratory Audits The EPA-ORD QA Officer (or their representative) will conduct a laboratory quality assurance audit. The focus of the review will be the air analyses performed to support the primary project objective. Prior to the audit, a detailed checklist will be developed for use based on the approved QAPP. This audit will be conducted as soon after the laboratory receives the samples as practical to ensure compliance with the approved QAPP. The auditor will debrief the EPA-ORD Task Order Manager and the Berger Project Manager regarding the results of the audit and any recommendations, if necessary. The results of the audit will be presented in a written report prepared by the auditor to the EPA-ORD Task Order Manager. If any serious problems are identified, the Berger Project Manager will ensure that immediate corrective action is performed. The laboratory will not analyze any samples until all audit recommendations have been resolved and documented in a memorandum to the Berger Project Manager. The Berger/Cadmus Project Manager will keep the EPA-ORD TOM informed of audit results and corrective actions. C.1.2. Corrective Action Sampling and analytical problems may occur during sample collection, sample handling and documentation, sample preparation, laboratory analysis, and data entry and review. Immediate on-the-spot corrective actions will be implemented whenever possible and will be Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page M_ of99 documented in the project record . Implementation of the corrective action will be confirmed in w~iting through a memorandum to the Berger Project Manager. The Cadmus/Berger Project Manager will then forward a copy to the EPA Task Order Manager. C.2. REPORTS TO MANAGEMENT Effective communication is an integral part of a quality system . Planned reports provide a structure to inform management of the project schedule, deviations from the approved QAPP , impact of the deviations , and potential uncertainties in decisions based on the data. The Cadmus Project Manager will provide verbal progress reports to the EPA Task Order Manager. These reports will include pertinent information from the data processing and report writing progress reports and corrective action reports, as well as the status of analytical data as determined from conversations with the laboratory. The Cadmus Project Manager will promptly advise the EPA-ORD Task Order Manager on any items that may need corrective action. A written report will be prepared for each field and laboratory audit. The audit reports will be prepared by the person who conducts the audit. These reports will be submitted to the EPA Task Order Manager. The final project report will be prepared in accordance with the guidelines specified in the EPA Handbook for Preparing ORD Reports, EP A/600K/95/002. Project Name: AACM Phase III Evaluation Revision No. 0.0 Date : December 4, 2007 Page~of99 D. DATA VALIDATION AND USABILITY D.1. DATA REVIEW, VERIFICATION, AND VALIDATION The analytical laboratory will perform in-house analytical data reduction and verification under the direction of the laboratory 's Quality Assurance Manager. The laboratory's Quality Assurance Manager is responsible for assessing data quality and advising of any data rated as "unacceptable" or other notations that would caution the data user of possible unreliability. The analytical results will be compared to the stated data quality indicators for each data quality objective. Field data and laboratory reports will then be reviewed and validated by Cadmus/Berger. D.1.1. Laboratory Data Review Sample data will be reviewed by the laboratory during the reduction, verification, and reporting process. During data reduction, all data will be reviewed for correctness by the microscopist or analyst. A second data reviewer will also verify correctness of the data. Finally, the Laboratory Quality Assurance Manager will provide one additional data review to verify completeness and compliance with the project QAPP . Any deficiencies in the data will be documented and identified in the data report. D.1.2. Field and Laboratory Data Verification/Validation Data verification and data validation will be conducted in accordance with EPA "Guidance on Environmental Data Verification and Data Validation," EPA QA/G-8 (EPA/240/R-02/004, November 2002. This will be performed by Cadmus/Berger's QA Officer, or designee. Data verification is the process of evaluating the completeness, correctness, and conformance/compliance of a specific data set against the method or QAPP requirements. The goal of data verification is to ensure and document that the data are what they purport to be, that is, that the reported results reflect what was actually done. Data validation is the analyte-and sample-specific process that extends the evaluation of the data beyond data verification. Data validation continues with the review of the raw analytical data and analysis notes. The data review will identify any out-of-control data points and data omissions. Based on the extent of the deficiency and its importance in the overall data set, the laboratory may be required to re-analyze the sample. Included in the data validation of a sample set will be an assessment of chain-of-custody and analyses of field quality control samples ( e.g., field blanks). Analytical data not appearing to be valid or not meeting data quality indicators will be flagged and reported to the Cadmus/Berger Project Manager. The Cadmus/Berger Project Manager will then transfer this information to the EPA Task Order Manager. D.2. DATA AND SAMPLE ARCHIVAL Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page~of99 Data and sample storage encompasses an archival of all collected samples, generated electronic files , and any laboratory notes collected during collection or analysis of samples. Upon completion of the analysis , the respective laboratory will store the remaining portions of the samples or sample preparations (e.g., TEM grids) until such mat erials are requested to be shipped to EPA. Note : No samples or sample preparations will be discarded . Following submission of the final project report, all laboratory and field records/files (paper and electronic) will be transferred to the Cadmus Project Manager. The Cadmus Project Manager will then transfer the complete project file to the EPA-ORD Task Order Manager for permanent retention. E. REFERENCES Project Name: AACM Phase III Evaluation Revision No. 0.0 Date: December 4, 2007 Page ll_ of99 1. Bickel , P .J., and K.A. Doksum. Mathematical Statistics: Basic Ideas and Selected Topics. Holden-Day , San Francisco. 1977. 2 . Berman, D .W. and A.J. Kolk. Draft: Modified Elutriator Method for the Determination of Asbestos in Soils and Bulk Materials , Re v ision 1. Submitted to the U.S . EPA, Region 8. May 3, 2000. 3. California Environmental Protection Agency Air Resources Board . Sampling for Airborne Naturally Occurring Asbestos at Oak Ridge High School , June 2003. (Report dated November 6, 2003). 4. Ferguson , David. QAPP -AACM Evaluation (Phase 2) -Site Assessment Sampling and Analysis, US EPA National Risk Management Research Laboratory , March 2007. 5. Wikipedia (2007), Poisson distribution , URL : http://en.w ikipedia.org/wiki /Poi sson distribution , Accessed October 11 , 2007 . 6 . Ulm , K. (1990), A Simple Method to Calculate the Confidence Interval for a Standardized Mortality Ratio (SMR), American Journal of Epidemiology , 131(2):373-5. 7. Kaminsky , J.R. Environmental Quality Management, Inc. Sampling and Analysis Plan: Pre-Demolition Asbestos and Lead Inspection of Buildings 3602 , 3603, 3607 , and 3606 at Ft. Chaffee , Fort Smith , Arkansas. Contract No. 68-C-00-186/Task Order No . 0019. July 16 , 2005. 8. Kaminsky, J.R., R .W. Freyberg, J.M . Boiano, et al. Performance Evaluation ofHEPA- Filtration Systems at Asbestos-Abatement Sites. Contract No. 68-03-4006. U.S. EPA , September 30 , 1989. 9. Kaminsky , J.R. and R.W. Freyberg. Ambient Airborne Asbestos Levels in Alviso , CA. Report prepared under Contract No. 68-C0-0048, Work Assignment 0-65 , Environmental Quality Management, Inc., Cincinnati , OH. April 21 , 1995. 10. Lenth , R. V . (2006). Java Applets for Power and Sample Size [Computer software]. Retrieved May 30 , 2007 , from http://www.stat.uiowa.edu/-rlenth/Power 11. Smith , B.E. Environmental Enterprise Group , Inc. Asbestos Inspection Report for Buildings 3602 and 3607 at Fort Chaffee , Arkansas 72917 . August 23 , 2005. 12. Smith , B.E. Environmental Enterprise Group , Inc. Specifications and Drawings for Asbestos Abatement Project, Building 3602 , Fort Chaffee , Arkansas . F e bruary 2006. Project Name: AACM Phase III Evaluation Revision No . 0.0 Date: December 4, 2007 Page M_ of99 13 . Wilmoth , R.C., J.R. Kominsky, J. Boiano , et al. Quantitative Evaluation of HEPA Filtrations Systems at Asbestos Abatement Sites. The Environ. Inform. Associa. J . Vol. 2 (1):6- 12 . 1993. 14. Wilmoth, R .C., B.A. Hollett, J.R. Kominsky, et al. Fugitive Emissions of Asbestos During Building Demolition and Landfilling of Demolition Debris: Santa Cruz, CA . U.S . EPA, RREL , Cincinnati , OH. October 17 , 1990. 15. Contaminants of Potential Concern Committee of the World Trade Center Indoor Air Task Force Working Group. World Trade Center Indoor Environment Assessment: Selecting Contaminants of Potential Concern and Setting Health-Based Benchmarks. New York, NY . May 2003. 16 . U.S. EPA. AHERA, 40 CFRPart 763, FR Vol. 52 , No. 210 , Oct. 30 , 1987 . 13 . Wilmoth , R.C ., P.J .Clark, B.R. Hollett, I .Powers , and J. Millette. Asbestos Release During Building Demolition. Environmental Choices Technical Supplement, Volume 1, No. 2, Atlanta, GA. March/April 1993. 14. Wilmoth , R .C ., M.S. Taylor, and B.E.Mey er. Asbestos Release From the Demolition of Two Schools in Fairbanks , AK. Applied Occupational and Environmental Hygiene Volume 9 , No.6. June 1994. 15 . Technical Report on: Area Air, Soil, and Water Monitoring During Asbestos Demolition Method. Prepared for City of Saint Louis by Industrial Hygiene and Safety Technology, Inc., Carrollton , TX . December 2004. 16. Wilmoth , R.C ., L. M . Drees, J.R. Kominsky , G.M. Shaul, D . Cox , D.B. Eppler, W.M . Barrett, F.D. Hall , J.A. Wagner, Comparison of the Alternative Asbestos Control Method and the NESHAP Method for Demolition of Asbestos-Containing Buildings , Cincinnati, OH . Draft April 2007. EXHIBIT 1 APPENDIX A. DRAFT ALTERNATIVE ASBESTOS CONTROL METHOD Page 1 of 7 ALTERNATIVE ASBESTOS CONTROL METHOD Developed by EPA Region 6 and EPA Office of Research and Development November 1, 2007 1.0 Background In response to Section 112 of the Clean Air Act which requires EPA to develop emission standards for hazardous air pollutants, EPA promulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP). 40 CFR Part 61 Subpart M (Asbestos NESHAP) specifically addresses asbestos , including demolition activities. Asbestos NESHAP regulations require that all regulated asbestos-containing materials (RACM) above a specified amount be removed from structures prior to demolition. Asbestos-containing materials (ACM) are defined as those materials containing more than one percent asbestos as determined using the method specified in Appendix E , Subpart E , 40 CFR Part 763 , Section 1, Polarized Light Microscopy (PLM). RACM includes friable ACM; Category I non-friable ACM that has become friable , Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading ; and Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected during demolition operations. Asbestos removal can account for a significant portion of the total demolition costs. In many cities, the cost of asbestos removal prohibits timely demolitions and results in substandard structures which become fire and safety hazards, attract criminal activity, and lower property values. For structures that are structurally unsound and in imminent danger of collapse, the Asbestos NESHAP requires that the portion of the structure which contains RACM must be kept adequately wet during demolition and during handling and loading of debris for transport to a disposal site. No other engineering controls are required. This Alternative Asbestos Control Method (AACM) was developed by EPA as an alternative work practice to the Asbestos NESHAP , where certain RACM are removed prior to demolition and other RACM are left in place. The goal is to provide significant cost savings while achieving an equal or better standard of protection of human health and the environment. This method is much more restrictive than the Asbestos NESHAP requirements for buildings in imminent danger of collapse. EXHIBIT 1 Page 2 of 7 2.0 Applicability This Alternative Asbestos Control Method applies to any structure subject to the Asbestos NESHAP regulation (i.e., structures that meet the definition of facility under the Asbestos NESHAP), except as noted below. The size of structures which can be demolished using this method is limited to three stories or less (maximum height of 35 feet). This apows adequate wetting of both the interior and exterior of the structures and is within the working reach of both the wetting and the demolition equipment. 3 .0 Building Inspection/Asbestos Assessment A comprehensive inspection of the interior and exterior of the structure to be demolished shall be conducted in accordance with EPA's Asbestos Hazard Emergency Response Act (AHERA, 40 CFR Part 763). Specific criteria for inspection, sampling, and assessment are in Subpart E (763.85, 763.86, and 763.88, respectively). The inspection shall be performed by an accredited asbestos building inspector. 4.0 Asbestos Removal Table 1 summarizes the ACM that may be present in buildings and whether or not the ACM must be removed prior to demolition. All thermal system insulation (TSI) and spray-applied fireproofing shall be removed due to the inability to adequately wet these materials during demolition. Fire curtains may be removed if it is easier to do so than to adequately wet and handle this heavy material. Vermiculite insulation, if present, shall be removed prior to demolition as an RACM, regardless of the measured asbestos concentration. All asbestos removal operations shall be performed in accordance with state and federal law by a licensed asbestos abatement contractor. 5.0 Demolition Practices Several demolition work practice standards shall be employed to ensure that the method is protective of human health and the environment. These standards involve the equipment used, the wetting process , the demolition process, and visible emissions. Demolition contractors shall provide an Asbestos NESHAP-trained individual to oversee the demolition process. 90 EXHIBIT 1 Page 3 of 7 5.1 Equipment Used Track hoes and end loaders or equivalent shall be used during demolition to minimize the generation of dust. No bulldozers , explosives, or burning will be permitted. 5 .2 Wetting Process Structures to be demolished will be thoroughly and adequately wetted with amended water (water to which a surfactant has been added) prior to demolition, during demolition, and during debris handling and loading. Surfactants reduce the surface tension of the water, increasing its ability to penetrate the ACM . For this method, the Asbestos NESHAP definition for "adequately wet" will be used. That is , "sufficiently mix or penetrate with liquid to prevent the release of particulates. If visible emissions are observed coming from the asbestos-containing material (ACM), then that material has not been adequately wetted. However, the absence of visible emission is not sufficient evidence of being adequately wet." The demolition contractor's Asbestos NESHAP-trained individual will verify that ACM is adequately wetted. Amended water shall be applied with a minimum of two hoses. The water shall be delivered as a mist. Direct high-pressure water impact of RACM is prohibited. The wetting process consists of three stages. In each stage , both interior and exterior wetting of the structure shall be performed. To the extent feasible, cavity areas and interstitial wall spaces shall be wetted during each of the wetting stages. 91 EXHIBIT 1 Page 4 of 7 Table 1. Asbestos Removal Reqmrements of AACM Asbestos-Containing Material Thermal System Insulation (TSI) • Tank insulation • Pipe insulation • Elbow/fitting/valve insulation • Boiler insulation • Duct insulation • Cement and patching compound Surfacing Material • Asbestos-impregnated plaster, stucco • Spray-applied fireproofing • Spray-applied surface coatings (popcorn ceiling, vermiculite treatments) • Spray applied acoustical or decorative surfacing • Troweled-on crows foot texture , splatter texture, and joint compound. • Spray-applied surface coatings crows foot texture, splatter texture, etc. Miscellaneous Material • Fire curtains in auditoriums • Fire doors • Vibration-dampening cloths • Asbestos-cement tiles , sheets, roofing, shingles , and transite • Asbestos-impregnated roofing cement and asphalt roofing • Shingles • Linoleum or other floor tile • Roll flooring • Ceiling tile • Asbestos-impregnated pipe • Vermiculite insulation • Mastic for flooring • Window Cauking 92 Removed Prior to Demolition? Yes Yes Yes Yes Yes Yes No Yes No No No No Optional Optional No No No No No No No No Yes No No EXHIBIT 1 Page 5 of 7 On the day before the demolition , access openings shall be made into the attic spaces from the exterior. The structure shall be first pre-wet (until adequately wet) from the interior and then from the constructed exterior attic access openings to enhance water retention and maximize wetting effectiveness. This pre-wetting shall prohibit further access into the structure , because of safety concerns. The structure shall be re-w et (until adequately wet) from the exterior through the windows , doors , and attic access openings on the day of demolition prior to demolition. Finally , wetting (until adequately wet) shall be done during the demolition and during loading of debris into lined disposal containers. 5.3 Demolition Process The demolition contractor shall mm1m1ze breakage of asbestos-containing materials. All demolition shall be completed in a timely manner that will allow the debris generated during that day to be completely removed from the demolition site for disposal. 5.4 Visible Emissions The Asbestos NESHAP standard of "no visible emissions" shall be employed. Visible emissions mean any emissions , which are visually detectable without the aid of instruments, coming from RACM or asbestos-containing material. This does not include condensed, uncombined water vapor. The demolition contractor's NESHAP-trained indi vidual shall verify the absence of visible emissions and has the authority to stop work if visible emissions are observed. During a demolition , it is often not possible to distinguish visible emissions from ACM and those from construction debris ; therefore , should a visible emission be observed , the demolition effort shall pause until the deficiencies in the application of the wetting controls eliminate the visible emission. 6.0 Weather Restrictions Demolition activities shall be delayed/halted in the case of any inclement weather that will impede the demolition contractor 's ability to adequately wet the structure ( e.g., freezing temperatures). In addition, if visible dusting is observed in the v icinity of the demolition site , the demolition shall be delayed/halted. 7.0 Monitoring Requirements Demolition contractors are required to compl y with all applicable OSHA (29 CFR 1926) regulations for worker protection during asbestos remo val and demolition activities . This 93 EXHIBIT 1 Page 6 of 7 includes the use of personal protective equipment (PPE) such as Tyvek suits or equivalent, respirators (as necessary), and gloves (as necessary); and personal monitoring. Because , like the Asbestos NESHAP, this method is designed to be a work practice standard, monitoring of air ( other than that mandated by OSHA statute), soil , and other media is not required. 8.0 Waste Handling Several wastes are generated during demolition activities, including demolition debris, disposable PPE , and potentially contaminated water and soil, and must be properly disposed . All wastes generated must be removed from the site at the end of the day and transported to an appropriate disposal facility . Transport and disposal shall be in accordance with all federal, state, and local requirements. All waste haulers shall be leak-proof. Double-lining of the haulers with 4-mil or thicker polyethylene film and then sealing the top seams of the film is a suggested mechanism, but the contractor must do what is required to prevent leaks from the transport vehicles. Vehicles shall be decontaminated within the bermed area before leaving the demolition area. 8.1 Demolition Debris Segregation of portions of a structure that may contain RACM from portions of a structure that clearly do not contain RACM shall be done when practical in an effort to minimize RACM debris. For example, segregation may be used if a large warehouse is being demolished and only a small portion (e.g., office space) contains RACM . When segregation is not practical, all demolition debris shall be disposed as RACM in a licensed asbestos disposal facility. Debris shall be kept adequately wet during loading into containers. Containers shall be covered during transport. 8.2 PPE All disposable PPE shall be disposed as RACM. Reusable PPE shall be decontaminated m accordance with OSHA standard practices. 8.3 Potentially Contaminated Water and Impervious Surfaces No potentially contaminated water runoff is permitted from the site during the demolition period. All impervious surfaces will be thoroughly washed with amended water before site closure. Construction site best management practices shall be used to prevent water runoff. Drains and sewer connections must be capped or plugged prior to wetting. Berms and/or trenches must be created as necessary to prevent runoff of water from the demolition site. If possible, the bermed/trenched area should extend 25 ft from the building and/or loading area. If not possible , adjacent areas and structures need to be covered with plastic. 94 EXHIBIT 1 Page 7 of 7 The berm/trench must be sufficiently spaced from the building to permit the movement of the demolition equipment and to allow the truck loading to occur within the enclosed space. All plastic shall be disposed as RACM. If large water volume use or impermeable conditions surrounding the building create excessive water volume and simple containment and percolation is not feasible, the water must be pumped and either disposed as ACM or filtered through a series of filters ultimately removing all fibers equal to or larger than five microns before transporting to a publicly-owned treatment works or discharging to a sanitary sewer. The filters must be disposed as RACM. 8.4 Potentially Contaminated Soil Following the removal of demolition debris, bare soil within the bermed area shall be excavated to a minimum depth of three inches or until no debris is found. Berms created shall also be removed and disposed as potentially asbestos-contaminated. All removed soil shall be disposed asRACM. 9.0 Site Closure Following demolition and waste disposal, all waste and debris must be gone from the site and the site must be secured so as not to create a safety hazard 95 Appendix B. Soil Sample Preparation and Analysis Method for Asbestos Evaluation of an Alternative Asbestos Control Method (AACM) for Building Demolition (Phase 3) Prepared: May 2, 2006 Revised: May 24, 2007 This procedure has been developed to describe how EPA/600/R-93 /116 , July 1993 "Method for the Determination of Asbestos in Bulk Building Materials " will be specifically implemented for the analysis of soils during the AACM evaluation. Sample Preparation The outsides of all soil sample containers received are to be cleaned in a hood. All sample preparation is conducted under a negative air ventilation hood with a HEPA filter. Samples are weighed to the nearest O.lg prior to and after the every step of the preparation process. If rocks are observed, these are removed and weighed. If visible chunks of building materials are observed, these are removed and weighed. Building materials are analyzed by PLM, and the asbestos type and percentage are documented , if present. The soil sample will be analyzed for moisture using ASTM 2540G. Using flat trays, the sample is spread out as much as possible to maximize surface area. The wet soil is reduced by hand to < 1 cm in size . Samples are dried in a convection oven at 60°C for a period of 24-48 hours , or until a constant weight is obtained. A constant weight is determined when less than 4 % of the previous weight or 0.5 mg is lost. The dried sample is transferred to its original clean air-tight heat dried container until it is placed in the riffle splitter. Using the riffle splitter, the sample will be distributed into two receiving pans. One pan will be immediately returned to its original container. This portion will be archived and stored if reanalysis is necessary. The portion in the second pan will be used for PLM/TEM. This portion will be coned and quartered to generate an optimal sample size for PLM/TEM (-20 grams). This sample will be transferred to a clean airtight bottle. PLM!fEM Analysis The PLM/TEM subsample is first ex amined by stereomicroscopy ( qualitative and quantitative) with PLM identification and documentation of any fibers or bundles. Suspect fibers are removed and examined by polarized light microscopy (PLM) to determine their optical properties and to achieve a positive fiber identification. If no selected fibers are positively identified as asbestos, the analyst will proceed to the grinding and sample reduction steps. The sample ( excluding any rock material observed) is ground and homogenized, using a standard plate grinder, to a particle size of approximately 250 micrometers. 96 A portion of the ground sample is weighed and ashed in a muffle furnace for one hour at 250 °C and for four hours at 480 °C. After weighing the ashed sample, it is then hydrolyzed in concentrated hydrochloric acid, filtered onto tared MCE filters, and weighed. The dried sample is then ground lightly for 1 minute using a mortar and pestle to gently break up any agglomerations. The gravimetric reduction ratio (GRR) is calculated. A quarter portion of the residue is prepared for PLM analysis. Polarized light microscopes are equipped with two polarizing filters , a first order red I compensator, a retardation plate, objective lenses ranging from 1 OX to 40X magnification, a 1 OX central stop dispersion staining objective, a 360 degree rotating stage, and a cross hair reticle. Samples are mounted with glass slides and coverslips using Cargille refractive index liquids. All stereoscopic analysis and slide mount preparation is done in a negative air ventilation hood, equipped with a HEPA filter. Positive identification of asbestos is achieved through the determination of the following optical properties: • Morphology (3: 1 minimum aspect ratio) • Sign of elongation • Extinction characteristics • Birefringence • Color and pleochroism • Refractive indices These properties are summarized in "Table 2-2. Optical properties of asbestos fibers," from EPA/600/R-93/116, July 1993. If, through stereoscopic and polarized light analysis of the sample, the analyst determines that the sample contains greater than or equal to ten percent asbestos, a visual estimate technique may be used to report the sample's overall percent asbestos. If 0-10 percent asbestos is observed, point counting will be done. The point count procedure begins with the preparation of twenty slide mounts (required analytical sensitivity is 0.1 percent) of the gravimetrically reduced sample. Slide mounts should ideally be prepared such that a single layer of the sample exists between slide and coverslip with no overlapping particles, and such that the slide mount contains 50-75 percent empty area within the field of view. If the sample has been sufficiently reduced by gravimetric reduction, the analyst may adjust the number of fields to be counted, as long as they maintain a 0.1 % analytical sensitivity. A cross hair reticle is used to count fifty random non-empty points on each slide mount at 1 OOX magnification, under crossed polars. A point is counted when the cross hairs fall directly above or on the edge of a fiber or particle. An empty point occurs when the cross hairs fall above an area of the mount without any material. If the cross hairs fall directly above two or more overlapping non asbestos particles, one point is counted. If the cross hairs fall directly above the overlap of one asbestos fiber and one non asbestos particle, a point is counted for each. 97 For each slide mount, fifty such non-empty points are counted and recorded as either an asbestos point or a non-asbestos point. This method is repeated for twenty different slide mounts so that a total of 1000 non-empty points are recorded. With this data , an overall percentage of asbestos can be determined by dividing the number of asbestos points by the number of total points (1000), and multiplying by 100 and the GRR as in the following equation: (asbestos points/total points) x 100 X GRR = percent asbestos In the event that an analyst positively identifies an asbestos fiber , but does not count any asbestos points during a point count, the sample will be reported as containing a trace percentage of asbestos. Another quarter portion of the residue is suspended in deionized water and aliquoted onto MCE filters for TEM analysis. This is accomplished by placing 100 mg of the sample residue in a 120 mL bottle and filling the bottle with 100 mL of 50:50 water and reagent alcohol. This solution is acidified to pH 3 to 4 with acetic acid , handshaken for 30 seconds, sonicated for three minutes , handshaken for another 30 seconds, and allowed to settle for two minutes. A range of aliquots (no less than one mL) is pipetted into a 25 mm filtration system utilizing 25 mm MCE filters. Aliquots are taken from the middle of the bottle. If the 1 mL aliquot is too heavily loaded, a serial dilution must be performed so that no filtered aliquot is less than 1 mL. Any remaining portion of the suspension is archived. TEM filters are prepped by direct standard prep methods for MCE filters . Strips are cut from the filters , then collapsed in a DMF/acetic acid solution, etched to remove the top organic layer and coated with carbon in a high vacuum evaporator. Three-millimeter squares are cut and placed on 200 mesh copper TEM grids , which are then placed on a DMF Jaffe wicke bath for 55 minutes to dissolve filter material. Filters are then placed on an acetone Jaffe wicke for 55 minutes to remove any remaining filter material. The grid preparations are examined in the TEM at low magnification (about 500-1 ,000x) to determine the preparation showing optimal particulate loading. Optimal loading for bulk samples is slightly more than for air samples, generally between 10% to 20%. Analysis on each grid opening is done at 15,000-20,000x screen magnification. At least 4 grid openings are analyzed evenly over 2 grids until the grid opening containing the 100th asbestos structure is completed or until the analytical sensitivity is achieved ( sufficient area must be analyzed such that one 3 µm X 0.1 µm asbestos structure relates to <0.1 % mass of the original sample). Structures are identified and classified according to ISO counting rules. In the event that the density of asbestos structures creates too many overlapping structures to effectively classify each primary structure individually , a less-dense aliquot is chosen. Data Reporting Data output for each analytical procedure is as follows: 98 PLM: • percent asbestos of the ground fraction determined by point counting, if conducted • percent asbestos in the original sample, determined by v isual estimation • percent asbestos in the chunks of building material (if any ) removed after drying • a calculated recombined percent of asbestos in the entire sample ( chunks of building material plus the ground sample, if point counting was done , or the original dried sample , if visual estimation was done) • method reference, sample identification (lab and project), anal y sis date , and analyst identification • type or types of asbestos present • number of asbestos points an9 non-asbestos points counted • identity and quantity of other fibrous minerals, if known ( determined by visual estimation) • description of any departures from the test method • description of any sample preparation steps • reporting of gravimetric calculations TEM : • percent asbestos and structures/gram in the ground fraction analyzed • method reference, sample identification (lab and project), analy sis date , and analy st identification • filter effective area, magnification, grid opening size , number of grid openings analyzed • any non-standard procedures • complete structure counting data per ISO 10312 • milligrams per kilogram (mg/kg) by weight and structures/gram of each asbestos type • separate concentration values for chrysotile and amphibole • analytical sensitivity • compositional data for amphibole varieties, if present 99 REMEDIAL ACTION PROJECT PLAN BUILDING DEMOLITION EVALUATION PHASE III STUDY ALTERNATIVE ASBESTOS CONTROL METHOD FOR BUILDING DEMOLITION November 20, 2007 Prepared by: William M. Barrett and Roger C. Wilmoth U.S. EPA, Office of Research & Development National Risk Management Research Laboratory 26 West Martin Luther King Drive Cincinnati, OB 45268 The Cadmus Group, Inc. 57 Water Street Watertown, MA 02472 The Louis Berger Group, Inc. 2300 N Street, NW Washington, DC 20037 Contract No. EP-C-05-058 Task Order No. 0057 TABLE OF CONTENTS 1.0 PROJECT DESCRIPTION ................................................................................................. 1 1.1. Background ..................................................................................................................... 1 1.2. Site Description ............................................................................................................... 3 1.3. Environmental Condition of Building ............................................................................ 4 2.0 Purpose ................................................................................................................................ 6 3.0 Criteria for Determining Impacts ........................................................................................ 6 4.0 Organizational System ........................................................................................................ 7 5.0 Response Actions .............................................................................................................. 10 5 .1. Visible Emissions .......................................................................................................... 10 5.2. Airborne Fiber Release ................................................................................................. 11 5 .3. Surface Water Impacts .................................................................................................. 12 5.4. Soil Impacts .................................................................................................................. 12 6.0 Worker Protection ............................................................................................................. 13 LIST OF TABLES Table 1. RACM Identified in the former office of the Oak Hollow Apartments, 5901 Boca Raton Boulevard, Fort Worth, Texas ........................................................................................................ 4 Table 2. Roles and Responsibilities of Key Project Personnel.. .................................................... 9 LIST OF FIGURES Figure 1. Oak Hollow Apartment Complex Office Building located at 5901 Boca Raton Boulevard in Fort Worth, Texas ..................................................................................................... 5 Figure 2. Project Organizational Structure .................................................................................... 8 APPEDNDICES Appendix A. Alternative Asbestos Control Method DISTRIBUTION LIST Adele Cardenas, USEP A Region 6 Lauren Drees , USEP A ORD NRMRL QA Officer William Barrett, USEP A NRMRL Project Officer Charles LaCerra, Craig Napolitano , Bob Olexsey. USEPA NRMRL Seth Schultz, Roger C. Wilmoth, USEPA, NRMRL Program Manager Holly Wootten 11 1.0 PROJECT DESCRIPTION This Remedial Action Plan is being prepared to address concerns with the potential for release of asbestos during the upcoming test of the Alternati ve Asbestos Control Method (AACM) on the former office of the Oak Hollow Apartment Complex located at 5901 Boca Raton Boulevard in Fort Worth, Texas. This document will provide a description of the AACM, a description of the subject building, the organizational chart and responsibility for conduct of the project and contingency plans for responding to various release mechanisms. 1. 1. Background The Clean Air Act provides the USEP A with the authority to promulgate and enforce a "work practice standard" for control of asbestos during building demolition if it is not feasible to establish an emission standard. Section 112 of the Clean Air Act, determined asbestos to be a hazardous air pollutant, and the use of asbestos regulated under the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Asbestos, 40 CFR Part 61 , Subpart M (Asbestos NESHAP). Requirement for the demolition and renovation of bui ldings that contain asbestos are contained in 40 CFR 61.145. The asbestos NESHAP defines a regulated asbestos-containing material (RACM) as the following [40 CFR 61 .141]: (a) Friable asbestos material , (b) Category I nonfriable ACM 1 that has become friable , ( c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting , or abrading, or (d) Category II nonfriable ACM 2 that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations. 1 Category I nonfriable asbestos-containing material (ACM) means asbestos-containing packings, gaskets , resilient floor covering, and asphalt roofing products containing more than I percent asbestos as determined using the method specified in 40 CFR 763 , Appendix E(l), Polarized Light Microscopy. 2 Category II nonfriable ACM means any material , excluding Category I nonfriable ACM, containing more than 1 percent asbestos as determined using the methods specified in 40 CFR 763Appendix E(l), Polarized Light Microscopy that, when dry , cannot be crumbled, pulverized, or reduced to powder by hand pressure . [ 40 CFR 61.141] The asbestos NESHAP requires emissions control when demolition or renovating a facility if the combined amount of RACM is: [40 CFR 61.145(a)(l)] • At least 80 linear meters (260 linear feet) on pipes or at least 15 square meters (160 square feet) on other facility components, or • At least 1 cubic meter (35 cubic feet) of facility components where the length or area could not be measured previously. For facilities containing asbestos above the threshold quantity, the emissions controls required for demolition include removal of all RACM prior to any demolition activity that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal. The asbestos NESHAP specifies emissions control procedures to be used during RACM removal and/or building demolition [40 CFR 61.145(c)] and wastes generated during demolition must be disposed of in accordance with the requirements of 40 CFR 61.150. If the facility is being demolished under an order issued by a State or local government agency because the facility is structurally unsound and in danger of imminent collapse, the RACM is not required to be removed prior to demolition, but the portion of the building that contains RACM must be kept adequately wet during demolition [40 CFR 145(a)(3) and 40 CFR 61.145(c)(9)]. It is generally regarded that the cost of compliance with the asbestos NESHAP is currently forestalling redevelopment efforts in a number of communities because the labor costs associated with removal of the RACM is significantly greater than the costs of building demolition. As a result, the USEP A has devised the Alternate Asbestos Control Method (AACM) that provides emissions controls believed to be equivalent to the current work practices required by the asbestos NESHAP, particular for abandoned buildings that are left unoccupied and unmaintained until the building becomes in "imminent danger of collapse" and can be demolished without removal of all of the RACM prior to demolition. Previous studies indicated that there were situations where undesirable releases of asbestos were documented from demolition of these unsafe structures. These studies included both demolitions conducted by the NESHAP process and ones conducted under imminent danger of collapse situations. (Wilmoth et al 1993, Wilmoth et al 1994, City of Saint Louis 2004). To date, the USEPA has conducted an evaluation of the AACM by performing a controlled side-by-side comparison of the AACM and the NESHAP on identical buildings at Fort Chaffee Redevelopment Authority (Wilmoth et al, 2007). The buildings in the first study had positive asbestos-containing wall systems and vinyl asbestos floor tile . A Follow-up Study has also been conducted to evaluate the AACM's ability to control emissions from the demolition of a building that had exterior transite siding. This third phase of the AACM evaluation is intended to evaluate the ability of the AACM to control emissions from a building that has textured wallboard surfaces, such as popcorn ceiling. These data would then be used in conjunction with data obtained during the initial study involving evaluations on environmental impacts during implementation of two demolition 2 processes (one using the AACM) and the other following NESHAP to help EPA determine whether it is appropriate to include an alternate method in the current asbestos regulations contained in 40 CFR Part 61 Subpart M. The AACM, if determined to be equally environmentally acceptable to the current regulations, may hav e the benefit of allowing municipalities to demolish abandoned buildings that otherwise would remain standing until they were in danger of imminent collapse. The AACM requires that certain RACM (such as thermal system insulation and fireproofing) be removed before demolition in accordance with the asbestos NESHAP; other RACM (such as transite, wallboard joint compound, resilient flooring/mastic , glazing compound) may remain in place. The AACM varies from the existing Asbestos NESHAP in the use of an amended-water wetting process, type of demolition equipment, and demolition techniques. Once the RACM has been removed, the demolition can then be conducted using amended water to suppress emissions of asbestos before, during, and after demolition to trap asbestos fibers , minimizing the potential for release to the air. The RACM is less likely to become friable when the wetting process and demolition techniques specified in the AACM are used. Wastewater generated during the demolition is collected and filtered, and all debris is disposed of as asbestos-containing waste. Soil in the affected area is excavated and disposed as asbestos-containing waste. Appendix A contains the AACM developed by EPA Region 6, the EPA ORD, and with input from the EPA QAPP Technical Development Team. The purpose of this research project is to gather additional data to document the environmental and cost-effectiveness of the AACM. This research project will assist EPA in considering modification of the practices of the Asbestos NESHAP. 1.2. Site Description The site selected for conduct of this study is the former office building for the Oak Hollow Apartment complex located at 5901 Boca Raton Boulevard, Fort Worth, Texas. The subject building is a two-story structure that is slab-on grade construction, as shown in Figure 1. It appears that the building was constructed with wood frame , and has exterior brick veneer applied to the lower portion of the structure . The upper portion of the structure exterior is finished with wood panel siding. The building has an asphalt shingled roof. The interior of the building contains a wallboard system that has a surface texture coating and a wallboard system ceiling with asbestos-containing "popcorn" ceiling texture. The wells have been painted, likely numerous times, using latex paint. Various flooring materials are present in the structure , including flexible tile with mastic and carpets. The City of Fort Worth conducted an asbestos survey of the building for their own purposes. The RACM identified during this inspection are listed in Table l . 3 Table 1. RACM Identified in the former office of the Oak Hollow Apartments, 5901 Boca Raton Boulevard Fort Worth Texas. ' ' RACMType Description Location Office #1 Sheetrock Ceiling Texture (White, Popcorn) Upstairs Open Area Next to Fire Place Lounge Upstairs Open Area Sheetrock Sheetrock (White) and Joint Compound Office #3 ' Fover Flooring Materials 9" x 9" Floor Tile with Mastic Kitchen Sheetrock Ceiling Texture (Beige, Popcorn) Work Room Sauna Sheetrock Sheetrock and Joint Compound, Beige Work Room Walls Storage Room The area surrounding the project is primarily residential , including apartment complexes, townhouses and single-family homes . There are no occupied buildings within 300 feet of the building. A police substation is located approximately 500 feet from the site. For purposes of the evaluation, Boca Raton Boulevard will be closed during the demolition and subsequent soil removal. Additionally, the bus stop located along Boca Raton Boulevard will be relocated. Also, to assure against accidental release of asbestos in the direction of the occupied structures, a protective poly wall will be built to shield potential releases in that general direction . As an additional safeguard, if the wind is blowing toward the occupied buildings, the demolition will be delayed until a time when that is not the case. 1.3. Environmental Condition of Building The comprehensive pre-demolition inspection has been conducted in accordance with the Asbestos Hazard Emergency Response Act (AHERA) (40 CFR 763) and the requirements of the ASTM E2356-04el Standard Practice for Comprehensive Building Asbestos Surveys to identify the type, quantity , location, and condition of Asbestos-Containing Materials (instead of only RACM) in the building in accordance with the asbestos NESHAP and the Texas Department of State Health Services (DSHS) asbestos program requirements. As noted in the asbestos NESHAP [40 CFR 61.145(a)], in addition to RACM, Category I and Category II Non-friable Asbestos-Containing Materials must also be identified prior to demolition or renovation. The building has been survey ed for the presence of inorganic lead (e.g. lead paint) in accordance with Housing and Urban Development's (1997) "Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing" to characterize the potential for occupational exposure during demolition. Representative composite bulk samples of the suspect lead- containing building materials were collected in accordance with the HUD sampling protocols 4 and analyzed to determine the lead content by EPA SW-846 Methods 3050B/7420. Based upon these results, additional samp!e.~ rp.~y __ be collected for waste characterization :~t:!_~·:·:}J'.;:~:i;~~: .~r, .,_· - Figure 1. Oak Hollow Apartment Complex Office Building located at 5901 Boca Raton Boulevard in Fort Worth, Texas. 5 2.0 Purpose This Remediation Plan is intended to: • Identify communication channels for response effort; • Set criteria for determining if an airborne asbestos release has occurred based on air monitoring data; • Outline impacts based on wind speeds observed; • Outline cleanup methods; and • Set criteria for sampling met~ods. 3.0 Criteria for Determining Impacts The demonstration of the AACM will be conducted on the two-story office building for the former Oak Hollow Apartment Complex. As in any demolition operation allowed under the asbestos NESHAP, visible emissions will be monitored and demolition operations will be adjusted based on the visible emissions. Visible emissions will serve as a real-time trigger for corrective actions; particularly if the emission is more than a momentary release. The corrective action will attempt to correct the work practice implementation that might have caused the release . If visible emissions are observed, the demolition will be halted while the practice is investigated and then resumed when the practice has been corrected. Airborne asbestos samples will be collected and analyzed during the demonstration project as described in the QAPP. Laboratory analysis of the air samples will be conducted by both PCM (NIOSH 7400) and TEM analysis (ISO Method 10312:1995). If the asbestos airborne concentrations downwind are found to be statistically significantly different that upwind then the average upwind concentration will be subtracted from the downwind concentration and then: • If the adjusted downwind sample average is less than or equal to 0.01 asbestos structures per cubic centimeter of air analyzed by TEM using PCME (equivalency) techniques then a response action is not necessary . • If the adjusted downwind sample average exceeds 0.01 asbestos structures per cubic centimeter of air analyzed by TEM using PCME ( equiv al ency) techniques then a response action will be initiated. 6 4.0 Organizational System The United States Environmental Protection Agency's (U.S. EPA's) Office of Research and Development (ORD) and U.S. EPA's Region 6 are cooperatively conducting this research project to determine the effectiveness of the Alternate Asbestos Control Method. The Cadmus Group, Inc. (Cadmus) is the prime contractor on the project and will have overall responsibility to ensure that the project is conducted in accordance with the approved Quality Assurance Project Plan (QAPP). The Louis Berger Group, Inc. (Berger) will assist Cadmus in the conduct of this study. The overall project organization is presented in Figure 2. It graphically shows the functional organization structure and lines of communication for this project. The project structure along with the technical personnel selections are designed to provide efficient management and a high level of technical competence to accomplish this research project. The roles and responsibilities of key project personnel are summarized in 7 Table 2. EPA Reg'ion 6 Enforcement ,Officer David Eppler 214-66~529 . 'T ' I -·T EPAQAPP Technical Development Team Texas . Department of State · Health Services Enforcement Officer .·_ .. L EPA Task Order Manager William Barrett 513-569-7720 EPA Quality Assurance Manager . · · ...1 . · -· · -· Lauren Drees 513-569~7087 Cadmus :Program Manager Holly Wootten 703-850-1412 Berger Project Manager Seth Schultz · 212-612-7934 Demolition Contractor City of FortWorth Laboratory Analyses . EMSL . , Michael Gange · . 817-392-6569 Figure 2. Project Organizational Structure. Chairles LaCerra 800-220-3675 ext 1253 · 8 Berger QA Manager Craig Napolitano · 212-612-7961 QA /QC Laboratory Analyses AmeriSci Laboratories Robert Bell 781-337-9334 T bl 2 R 1 a e o es an dR "bTf espons1 1 1 1es o fK P . tP ey ro1ec ersonne Personnel Role and Resvonsibilitv Roger Wilmoth Program Manager, will have overall administrative and technical U.S. EPA, ORD, NRMRL responsibility for this program. William Barrett Task Order Manager (TOM), will direct the project and ensure U.S. EPA, ORD, NRMRL that it is proceeding on schedule and within budget. Point of contact for Cadmus. QA Officer, will provide QA oversight to ensure that the planning Lauren Drees and plan implementation are in accordance with the approved U.S. EPA, ORD, NRMRL QAPP. In addition, ORD 's QA Officer will oversee a field audit and laboratory audit. Holly Wootten -Overall Project and Task Order Lead, will have overall Cadmus administrative responsibility for the Cadmus Team and to serve as the primary client interface to ensure continuity between EPA, the Cadmus Team and all subcontractors (listed below) in working towards stated project objectives. Seth Schultz Berger's Project Manager, will have overall administrative and LBG technical responsibility for Berger on this project. Will also have overall administrative and technical responsibility for Berger and its sub-contractors to ensure that data collection and analysis and the technical report meet the planned study objectives. Craig Napolitano Quality Assurance Manager to ensure compliance with final LBG QAPP and study objectives. Will oversee laboratory analysis and perform data validation. Michael Gange Will Provide Contractor to Perform AACM demolition City of Fort Worth, Texas Charles LaCerra Will provide primary laboratory analysis of asbestos samples EMSL Amerisci Laboratories, Inc. Will provide quality assurance (QA) secondary sample analysis The actual demolition will be performed by a contractor properly trained in accordance with the OSHA Hazard Waste Operations and Emergency Response (HAZWOPER). The City of Fort Worth's Fire and Rescue Department will be first responder for a potential transportation related accident to ensure waste debris remains adequately wet and contained. The City of Fort Worth -Transportation and Public Works Department will be on ready call to provide heavy equipment support as necessary to respond to transportation related emergencies. The demolition contactor will be primary responder to release to outdoor air or surface water from the demolition operation. Contractor will utilize personnel with current HAZWOPER Training in accordance with OSHA requirements. 9 ii 5.0 Response Actions 5. 1. Visible Emissions Response actions will vary based on the observed visible emission(s). Visible emissions from the demolition operation (i.e., demolition of structure, handling of demolition debris, loading of demolition debris for disposal and transportation of demolition debris), and associated response actions will be grouped into the following categories: • Momentary release (e.g., puff) that is controlled by the water stream in an immediate fashion will not require additional engineering controls. For example , a slight puff from a working edge of demolition that is dissipated by the applied water as it is produced. • Small sustained release ( e.g., small dust cloud) that either dissipates through dispersion into the air column or through additional use of the wetting hoses will require a temporary halt in demolition operations while the working edge of demolition is wetted for approximately one minute. At the initiation of demolition activities both wetting water streams will be directed at this area providing a mixture of misting and wetting. • Medium sustained release (e.g., small dust cloud that drifts) that is transported away from the working edge of demolition but dissipates prior to leaving the footprint of the demolition area will require a temporary halt in demolition operations while the while the working edge of the demolition is wetted for approximately five minutes. At the initiation of demolition activities both wetting water streams will be directed at this area providing a mixture of misting and wetting. • Large sustained release (e.g ., dust cloud that drifts) that is transported away from the working edge of the demolition but dissipates prior to leaving the property boundary will require a temporary halt in demolition while the working edge of the demolition is wetted for approximately 15 minutes. At the initiation of demolition activities both wetting water streams will be directed at this area providing a mixture of misting and wetting. • Uncontrolled release (e.g., dust cloud leaves site) that is transported off the facility boundary and onto surrounding properties. Demolition operations will cease immediately . Wetting of the demolition debris will continue to ensure all exposed areas are adequately wetted. Response actions will be initiated following TEM analysis of air samples. Visibly impacted areas may be cleaned with a HEPA vacuum if possible. Special Note: an uncontrolled release may occur if the building becomes unstable for some reason collapses under its own pressure. Also, an uncontrolled release as defined here is any release , not necessary an asbestos release, and the NESHAP trained individual on site as well as other observers will have to determine the potential source of the release. 10 5.2. Airborne Fiber Release Response actions will vary based on the observed wind conditions on the day of the release. Wind speeds will be grouped into the following categories: • Light: • Moderate: • High: Less than or equal to 3 mph on average. Greater than 3 mph and less than or equal to 10 mph with an average wind speed of 6 mph. Greater than 10 mph with an average wind speed of 16 mph. It s)lould be noted that in the event of high winds, the demolition will be halted. Monitoring of the site for visible emissions will continue through the duration of the high winds. If the winds remain elevated and the evaluation must be halted overnight, the structure will be covered with visqueen until the winds subside and the demolition can be resumed. The light and high wind speed ranges reportedly have similar potential impacts and will treated as the equivalent for cleanup method use. • Light Wind Speeds 1. HEP A vacuum hard surfaces within 300 feet of the site. 2. Wet wipe hard surfaces within 300 feet of the site. 3. Wash down roadways, walkways, and driveways within 300 feet of the site and collect rinse and filter rinse water prior to discharge to the sanitary sewer system. Filter media will be disposed as asbestos-contaminated waste. 4. Recommend HV AC filters be changed in buildings within impacted area • Moderate wind speeds observed I. HEP A vacuum hard surfaces within 3 50 feet of the site. 2. Wet wipe hard surfaces within 350 feet of the site. 3. Wash down roadways, walkways, and driveways within 350 feet of the site and collect rinse and filter rinse water prior to discharge to the sanitary sewer system. Filter media will be disposed as asbestos-contaminated waste. 4. Recommend HVAC filters be changed in buildings within impacted area • Heavy Wind Speeds I. HEP A vacuum hard surfaces within 400 feet of the site. 2. Wet wipe hard surfaces within 400 feet of the site. 3. Wash down roadways, walkways, and driveways within 400 feet of the site and collect rinse and filter rinse water prior to discharge to the sanitary sewer system. Filter media will be disposed as asbestos-contaminated waste. 4. Recommend HV AC filters be changed in buildings within impacted area 11 5.3. Surface Water Impacts In accordance with the Quality Assurance Project Plan (QAPP) for the Phase 3 Demonstration of the AACM, if runoff is produced in sufficient quantities to sample then samples will be collected on a periodic basis of runoff water collected and contained. 1. The containment system will be inspected hourly for breaches, and if a breach in the containment system is identified, it will immediately be repaired. 2. The following response actions will be initiated as follows based on the estimated release amount: a) Less than 10 gallons no further response action will be initiated. b) Greater 10 gallons and less than 50 gallons then hard surfaces of the impacted area will be HEP A vacuumed. c) Greater than 50 gallons then the surface water body will be temporarily dammed using earthen material and the water pumped and filtered before disposal into the sanitary sewer. All collected water will be contained on site and filtered with a five-µm particle filter prior to being discharged into the sanitary sewer located at the site. Samples of the filtered water will be collected and analyzed for asbestos as described in the QAPP. 5.4. Soil Impacts A minimum depth of three inches of soil within the containment area shall be removed and disposed as asbestos-containing wastes in accordance with the Quality Assurance Project Plan (QAPP) for the Phase 3 Evaluation of the AACM. Should there be a breach of the water containment system that spills onto soil surfaces, soil removal in the affected areas shall be accomplished to minimum depth of three inches and disposed as asbestos-containing waste. a) Soil will be wetted during excavation activities to suppress airborne dust. b) Soil will be loaded for transportation. During loading operations the soil will be wetted. c) All transportation dumps will be covered with a tarp during transport and shall not leak. Following the excavation of the 3+ inches of soil from within the containment area, soil samples will be collected in accordance with the QAPP. If the concentrations of asbestos in any of these samples exceed the Texas Risk Reduction Program (TRRP) standard of2,900 mg/kg asbestos for a residential source area less than 0.5 acres, an additional 3 inches will be excavated and re- sampled until the soil meets the TRRP cleanup criterion. 12 6.0 Worker Protection Cleanup workers will have the following Personal Protective Equipment (PPE) during remediation efforts: • Half-face air purifying respirators equipped with P-100 (formerly HEPA) cartridges; • Disposable Tyvek suits; • Safety glasses as necessary; and • Steel toe boots. Decontamination of workers will be performed using a one-stage dry decontamination system. This system will include: 1. HEP A vacuum Tyvek suit. 2. Wash face and hands. 3. Remove Tyvek suit by inverting or rolling it into itself. 4. Only after completion of the above tasks will the respirator be removed and prepared for proper storage. Comply with OSHA 29 CFR 1926.1101 and 1910.134 as applicable. 13 APPENDIX A AL TERNA TE ASBESTOS CONTROL METHOD Page 1 of 7 ALTERNATIVE ASBESTOS CONTROL METHOD Developed by EPA Region 6 and EPA Office of Research and Development November 1, 2007 1.0 Background In response to Section 112 of the Clean Air Act which requires EPA to develop emission standards for hazardous air pollutants, EPA promulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP). 40 CFR Part 61 Subpart M (Asbestos NESHAP) specifically addresses asbestos, including demolition activities. Asbestos NESHAP regulations require that all regulated asbestos-containing materials (RACM) above a specified amount be removed from structures prior to demolition. Asbestos-containing materials (ACM) are defined as those materials containing more than one percent asbestos as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, Polarized Light Microscopy (PLM). RACM includes friable ACM; Category I non-friable ACM that has become friable, Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; and Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected during demolition operations. Asbestos removal can account for a significant portion of the total demolition costs. In many cities, the cost of asbestos removal prohibits timely demolitions and results in substandard structures which become fire and safety hazards, attract criminal activity, and lower property values. For structures that are structurally unsound and in imminent danger of collapse, the Asbestos NESHAP requires that the portion of the structure which contains RACM must be kept adequately wet during demolition and during handling and loading of debris for transport to a disposal site. No other engineering controls are required. This Alternative Asbestos Control Method (AACM) was developed by EPA as an alternative work practice to the Asbestos NESHAP, where certain RACM are removed prior to demolition and other RACM are left in place. The goal is to provide significant cost savings while achieving an equal or better standard of protection of human health and the environment. This method is much more restrictive than the Asbestos NESHAP requirements for buildings in imminent danger of collapse. Page 2 of 7 2 .0 Applicability This Alternative Asbestos Control Method applies to any structure subject to the Asbestos NESHAP regulation (i.e ., structures that meet the definition of facility under the Asbestos NESHAP), except as noted below. The size of structures which can be demolished using this method is limited to three stories or less (maximum height of 35 feet). This allows adequate wetting of both the interior and exterior of the structures and is within the working reach of both the wetting and the demolition equipment. 3.0 Building Inspection/Asbestos Assessment A comprehensive inspection of the interior and exterior of the structure to be demolished shall be conducted in accordance with EPA's Asbestos Hazard Emergency Response Act (AHERA, 40 CFR Part 763). Specific criteria for inspection, sampling, and assessment are in Subpart E (763.85 , 763.86, and 763.88, respectively). The inspection shall be performed by an accredited asbestos building inspector. 4 .0 Asbestos Removal Table I summarizes the ACM that may be present in buildings and whether or not the ACM must be removed prior to demolition. All thermal system insulation (TSI) and spray-applied fireproofing shall be removed due to the inability to adequately wet these materials during demolition. Fire curtains may be removed if it is easier to do so than to adequately wet and handle this heavy material. Vermiculite insulation, if present, shall be removed prior to demolition as an RACM, regardless of the measured asbestos concentration. All asbestos removal operations shall be performed in accordance with state and federal law by a licensed asbestos abatement contractor. 5.0 Demolition Practices Several demolition work practice standards shall be employed to ensure that the method is protective of human health and the environment. These standards involve the equipment used, the wetting process, the demolition process, and visible emissions . Demolition contractors shall provide an Asbestos NESHAP-trained individual to oversee the demolition process. Page 3 of 7 5.1 Equipment Used Track hoes and end loaders or equivalent shall be used during demolition to minimize the generation of dust. No bulldozers, explosives, or burning will be permitted. 5 .2 Wetting Process Structures to be demolished will be thoroughly and adequately wetted with amended water (water to which a surfactant has been added) prior to demolition, during demolition, and during debris handling and loading. Surfactants reduce the surface tension of the water, increasing its ability to penetrate the ACM. For this method, the Asbestos NESHAP definition for "adequately wet" will be used. That is, "sufficiently mix or penetrate with liquid to prevent the release of particulates. If visible emissions are observed coming from the asbestos-containing material (ACM), then that material has not been adequately wetted. However, the absence of visible emission is not sufficient evidence of being adequately wet." The demolition contractor's Asbestos NESHAP-trained individual will verify that ACM is adequately wetted. Amended water shall be applied with a minimum of two hoses. The water shall be delivered as a mist. Direct high-pressure water impact of RACM is prohibited. The wetting process consists of three stages. In each stage, both interior and exterior wetting of the structure shall be performed. To the extent feasible, cavity areas and interstitial wall spaces shall be wetted during each of the wetting stages. Page 4 of7 Table 1. Asbestos Removal Reqmrements of AACM Asbestos-Containing Material Thermal System Insulation (TSI) • Tank insulation • Pipe insulation • Elbow/fitting/valve insulation • Boiler insulation • Duct insulation • Cement and patching compound Surfacing Material • Asbestos-impregnated plaster, stucco • Spray-applied fireproofing • Spray-applied surface coatings (popcorn ceiling, vermiculite treatments) • Spray applied acoustical or decorative surfacing • Troweled-on crows foot texture, splatter texture, and joint compound. • Spray-applied surface coatings crows foot texture, splatter texture, etc. Miscellaneous Material • Fire curtains in auditoriums • Fire doors • Vibration-dampening cloths • Asbestos-cement tiles, sheets, roofing, shingles, and transite • Asbestos-impregnated roofing cement and asphalt roofing • Shingles • Linoleum or other floor tile • Roll flooring • Ceiling tile • Asbestos-impregnated pipe • Vermiculite insulation • Mastic for flooring • Window Cauking Removed Prior to Demolition? Yes Yes Yes Yes Yes Yes No Yes No No No No Optional Optional No No No No No No No No Yes No No Page 5 of 7 On the day before the demolition, access openings shall be made into the attic spaces from the exterior. The structure shall be first pre-wet (until adequately wet) from the interior and then from the constructed exterior attic access openings to enhance water retention and maximize wetting effectiveness. This pre-wetting shall prohibit further access into the structure, because of safety concerns. The structure shall be re-wet (until adequately wet) from the exterior through the windows , doors , and attic access openings on the day of demolition prior to demolition. Finally, wetting (until adequately wet) shall be done during' the demolition and during loading of debris into lined disposal containers . 5.3 Demolition Process The demolition contractor shall mmumze breakage of asbestos-containing materials. All demolition shall be completed in a timely manner that will allow the debris generated during that day to be completely removed from the demolition site for disposal. 5.4 Visible Emissions The Asbestos NESHAP standard of "no visible emissions " shall be employed. Visible emissions mean any emissions , which are v isually detectable without the aid of instruments, coming from RACM or asbestos-containing material. This does not include condensed, uncombined water vapor. The demolition contractor 's NESHAP-trained individual shall verify the absence of visible emissions and has the authority to stop work if v isible emissions are observed. During a demolition , it is often not possible to distinguish visible emissions from ACM and those from construction debris; therefore, should a visible emission be observed, the demolition effort shall pause until the deficiencies in the application of the wetting controls eliminate the visible emission . 6.0 Weather Restrictions Demolition activities shall be delayed/halted in the case of any inclement weather that will impede the demolition contractor's ability to adequately wet the structure (e.g., freezing temperatures). In addition , if visible dusting is observed in the vicinity of the demolition site, the demolition shall be delayed/halted. 7.0 Monitoring Requirements Demolition contractors are required to comply with all applicable OSHA (29 CFR 1926) regulations for worker protection during asbestos removal and demolition acti vities . This Page 6 of7 includes the use of personal protective equipment (PPE) such as Tyvek suits or equivalent, respirators (as necessary), and gloves (as necessary); and personal monitoring. Because, like the Asbestos NESHAP, this method is designed to be a work practice standard, monitoring of air ( other than that mandated by OSHA statute), soil, and other media is not required. 8.0 Waste Handling Several wastes are generated during demolition activities, including demolition debris, disposable PPE, and potentially contaminated water and soil, and must be properly disposed. All wastes generated must be removed from the site at the end of the day and transported to an appropriate disposal facility. Transport and disposal shall be in accordance with all federal, state, and local requirements. All waste haulers shall be leak-proof. Double-lining of the haulers with 4-mil or thicker polyethylene film and then sealing the top seams of the film is a suggested mechanism, but the contractor must do what is required to prevent leaks from the transport vehicles. Vehicles shall be decontaminated within the bermed area before leaving the demolition area. 8.1 Demolition Debris Segregation of portions of a structure that may contain RACM from portions of a structure that clearly do not contain RACM shall be done when practical in an effort to minimize RACM debris. For example, segregation may be used if a large warehouse is being demolished and only a small portion (e.g., office space) contains RACM. When segregation is not practical, all demolition debris shall be disposed as RACM in a licensed asbestos disposal facility. Debris shall be kept adequately wet during loading into containers. Containers shall be covered during transport. 8.2 PPE All disposable PPE shall be disposed as RACM. Reusable PPE shall be decontaminated m accordance with OSHA standard practices. 8.3 Potentially Contaminated Water and Impervious Surfaces No potentially contaminated water runoff is permitted from the site during the demolition period. All impervious surfaces will be thoroughly washed with amended water before site closure. Construction site best management practices shall be used to prevent water runoff. Drains and sewer connections must be capped or plugged prior to wetting. Berms and/or trenches must be created as necessary to prevent runoff of water from the demolition site. If possible, the bermed/trenched area should extend 25 ft from the building and/or loading area. If not possible, adjacent areas and structures need to be covered with plastic. Page 7 of 7 The berm/trench must be sufficiently spaced from the building to permit the movement of the demolition equipment and to allow the truck loading to occur within the enclosed space. All plastic shall be disposed as RACM. If large water volume use or impermeable conditions surrounding the building create excessive water volume and simple containment and percolation is not feasible, the water must be pumped and either disposed as ACM or filtered through a series of filters ultimately removing all fibers equal to or larger than five microns before transporting to a publicly-owned treatment works or discharging to a sanitary sewer. The filters must be disposed as RACM. 8.4 Potentially Contaminated Soil Following the removal of demolition debris, bare soil within the bermed area shall be excavated to a minimum depth of three inches or until no debris is found. Berms created shall also be removed and disposed as potentially asbestos-contaminated. All removed soil shall be disposed asRACM. 9.0 Site Closure Following demolition and waste disposal, all waste and debris must be gone from the site and the site must be secured so as not to create a safety hazard 12/05/2007 WED 11:57 FAI ~002/003 EXHIBIT "B" UNITED STATES ENVIRONMENTAL PROTECTION AGENCY - WASHINGTON, D.C. 20460 DEC 4 -2007 MEMORANDUM ASSIST ANY /\OM1N l$1'M"l'OR r.<>n ENFORCEMENT AND COMPLIANCE ASSUl'I/INCI:: · SUBJECT: No Action Assurance Concerning The Alternative Asbestos Control Method; National Emjssion Standard for Asbestos, Asbestos Demolition and Renovation Standard, 40 C.F.R. Part 6 I, Subpart M, section 61.l 4S FROM; GrantaY. Nakayama,,,_;(, r 127 ----~T=o-: --~g=1chllt'd B, Greeac Reg1oniil-Kdmirustrator, Regioifo _______________ _:__----------------------·-· ··- I am in receipt ot your letter dated November 8, 2007, that requests a no action assurance (NAA) to allow EPA to conduct the third phase of testing to evalu.ate an Alternate Asbestos Control Method (AACM) for demolition of buildings with asbestos-containing building materials. In order to determine whether the AACM provides ao equivalent reduction in asbestos · cmis.ciions when compared to the demolition control method currently prescribed under the a~bestos NESHAP, EPA will exercise its enforcement discretion to tcmporaiily allow EPA Region 6, the EPA Office of Research and Development (ORD), the City of Fort Worth, the Texas Dcpartn1eot of State Health Services (DSHS), and their contractors to evaluate the AACM at a prope1ty under the control of the City of Fort Worth, Texas. This exercise of enforcement discretion applies only to the project identified in th~ Quality Assurance Project"Plan (QAPP) · (Atlachment A) and only to the provisions of the a.<ibestos NESHAP found jn 40 CFR Part 61, Subpai1 M, § §61.145 ( c )( 1) thru ( 6). AH other provisions of the asbestos NESHAP will be fully applicable. This NAA is effective immediately and will continue until midnight, Thursday, January 31, 2008. I understand that the site specific QAPP for the first phase of testing the AACM was su~jccted to outside peer review prior to U1at test being performed, and that the test report from that phase of testing also was subjected to outside peer review. The site specific QAPP for this third phase of testing the AACM incorporates reco1nn1enda1ions fron, those peer reviews to ensure that it is protective of public health and the environment. Representatives from several offices within the Agency will evaluate the air and other monitoring data in the post-demolition demonstration report. In addition, the draft final post-demolition demonstration report will be subjected to outside peer review. · · 1r11crn<tt Addroi:s {llFIL) • !lllp:l/www.ep.i .gov · Rocyc:loc:1/Roeyc:loble • Printed with Vogolal)IC Oil Ba~ed lr1k~ 011100':I. Pm;!con:;um~r. Procon..~ Chlorine Frei, H0r;-yc1od PPpor ;:·, { ~:."- :··· ;:·. 1:· t :·' ~ ... ::;·. 12/05/2007 WED 11:58 . FAX ~003/003 J further understand that the QAPP for the third phase of testing also will provide that the field leaders, comprised of representatives from the City of Fort Worth, DSHS, ORD, and their contractors, must be trained in and familiar with the asbestos NESHAP requirements and the means of complying wilb those requirements, will be present during the project, and wil1 have the authority to stop work jf necessary. All asbestos-containing waste materials generated during the demolition wi11 be handled, transported, and disposed of in accordance with the asbest6s NESHAP provisions pertaining to waste disposal. Moreover~ although not required under the . asbestos N~SHAP. wastewater generated during tbe demonstration project will he contained and filtered, and a minimum of three inches of soil, where it exists, will be: removed from the site at the completion of lhe demolition and disposed of as asbestos-containing waste material. ·mese latter actions arc an integral part of the AACM itqelf. As a further precaution, the project includes a Remedial Action Project Plan (Attachment B) in the unlikely event of an asbestos release. Finally, I understand that the public was notified of this proposed test through a November 2, 2007 letter froin the City of Fo1t Worth and that a public infonnational meeting was held in Fort Worth on·Novcmbcr 1S, 2007. Jn addition, tlJ.e City of Fort Worth posted a notice of the meeting on their City website, as required by the City, and meetings were held with --; e-Ea-stsiue-S-ector Atliancc;-Woodhaven--Neighborhecxl--Assooiati-On,--Sierr.a------ ~·_:---:..:=...:=--::-=-=..:..e1illi--of-Tcfu~tlie:Fon=-wo · 1~ 1em1.= -u ·:an· : -: --o: 1SCUSS--C--PIOJCC -n . -.: _::..:=:·=-~======- ;--· they might have. The City of Fort Worth and the EP /\ proj~1. team will continue to keep the i: neighborhood apprised as the project proceeds forward with the actual demolition. and subsequently follow-up with the nejghborhood on the re.c;ulL<: collected at the demolition site. C~pies of the AACM third phase research project Final Report required by the QAPP shall be sent to the following address: Pamela J. Maiakas, Associate Director Air E11forcemenl Division U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW (MC 2242A) Washington, DC 20460 lfyou have any questions or comments regarding this enforcement discretion, please contact Pamela Mazakas of my staff. She can be reached at (202) 564-4028. Attachments 2 Industrial Hygiene and Safety Technology, Inc. 2235 Keller Way Carrollton, TX 75006 Phone : (972) 478-7415 Fax: (972) 478-7615 http://www.ihst.com Leaders in Quality, Service and Innovation Report of Comprehensive Asbestos Survey Prepared for: City of Fort Worth 1000 Throckmorton Fort Worth, TX 76102 Building Surveyed: Oak Hollow Office 5901 Boca Raton Fort Worth, TX 76112 (Oak Hollow Office) Report Date: Monday, July 09, 2007 Industrial Hygiene and Safety Technology , Inc . 1111 1.0 2 .0 3.0 4 .0 5 .0 5.1 5 .2 5 .3 6 .0 6 .1 6.2 7 .0 7 .1 8.0 Introduction Purpose and Scope Report Organization Field Investigation Sampling Comprehensive Asbestos Survey Oak Hollow Office 5901 Boca Raton Fort Worth, TX 76112 (Oak Hollow Office) Table of Contents Laboratory Analysis Analytical Methods Bulk Sample Results Hazard Assessment Hazard Assessment Ratings Asbestos-Conta,jning Material Assessments Hazard Assessment Summary Response Actions Qualifications Appendices Appendix A: Site Drawings Appendix B: Lab Results Appendix C: Bulk Summary Report Appendix D : Cost Estimate for Removal Comprehensive Asbestos Survey City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth, TX 76112 IHST Project Number: 17617 3 3 3 3 4 4 5 5 6 6 7 8 8 9 Page 2 of9 Industrial Hygiene and Safety Technology , Inc . IHST Project Number: 17617 1.0 Introduction This document is a report of a Comprehensive Asbestos Survey performed by Industrial Hygiene and Safety Technology, lnc.(IHST). IHST is licensed by the Texas Department of State Health Services (DSHS), formerly the Texas Department of Health, as an Asbestos Consultant Agency (DSHS License #10-0145 . Figure 1 provides a description of the assessment described by this report. Figure 1. Comprehensive Asbestos Survey Profile Client Name: City of Fort Worth Facility/Campus: Oak Hollow Office Building: Oak Hollow Office 5901 Boca Raton Fort Worth, TX 76112 Survey Date(s): 7/3/2007 lnspector(s): Doug Easley -DSHS Asbestos Inspector License #60-2207 2.0 Purpose and Scope The purpose of this project was to locate , identify, and assess the condition of asbestos containing material (ACM) present at the subject building, and to develop recommendations based on existing and potential asbestos related hazards . The following scope of work was used during the asbestos assessment for the subject property : A . Collecting and analyzing bulk samples of suspected asbestos-containing materials. B. Quantification of the suspected asbestos-containing material. C. Approximate costs of abatement, to include abatement specifications, contractor selection , and on-site management during remediation activities . D. Provide an approximate time schedule for abatement procedures . E. Make recommendations based on survey data collected to implement an Operation and Maintenance (O&M) Program or abatement procedures . F. Preparing a report discussing the findings and remedial recommendations . 3.0 Report Organization This report is divided into sections which discuss the review of ava ilable documentation, field investigation , laboratory analysis, hazard assessments, and recommendations . Illustrations , such as tables and figures follow the text. Other supporting documentation , such as laboratory reports are also included. 4.0 Field Investigation The survey was conducted to determine the amount of asbestos-containing materials present in the subject building . The survey included an observation of accessible areas and unusual conditions ; and bulk sampling of suspected asbestos-containing materials . Bulk samples were collected of suspect materials and analyzed by Polarized Light Microscopy (PLM) w ith dispersion staining, in accordance with the Environmental Protection Agency's (EPA) Method for the Determination of Asbestos in Bulk Insulation Samples (Method 600/R-93/116). Percentage estimates are based on the analyst's best 1111 __ .. SdllyT~lrc. Comprehensive Asbestos Survey City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth , TX 76112 Page 3 of 9 Industri al Hygiene and Safety Technology, Inc . IHST Proj ect Number: 176 17 judgment following PLM/DS and examination with a stereoscope. Laboratory reports containing sample location and results are included with this report. The survey was designed to identify the presence of both friable and non-friable asbestos-containing materials present in the surveyed area . Friable means that the material , when dry , may be crumbled , pulverized , or reduced to powder by hand pressure . Building materials suspected of containing asbestos were grouped into "Homogeneous" sampling areas. The homogeneous areas were defined based on uniform texture , color, and appearance . Additionally , homogeneous areas were further defined based on building construction date(s). Each of the items sampled were classified into one of three categories : 1.) Surfacing Material : A surfacing material is a building material which has been applied to a surface (i.e ., walls or ceilings) or structural members. Examples of surfacing materials which may contain asbestos are : spray-applied fireproofing , spray-applied acoustical texture , and trowel-applied textured ceilings and walls . 2 .) Thermal System Insulation : All types of insulation used on a building's mechanical system are classified into the category of thermal system insulation . Examples of thermal system materials which may contain asbestos are : boilers and related piping, or duct insulation . 3.) Miscellaneous: All remaining materials which do not fall into the two above categories are placed in the miscellaneous category . Examples of miscellaneous materials which may contain asbestos are : lay-in ceiling tile , floor tile, mastic adhesives and roofing felt. An assessment was conducted for each building material sampled . The physical assessment consists of evaluating the condition of the suspect material and the potential for future disturbance. Recommendat ions made for a building material which contains asbestos are based on the assessments made by the inspector during the survey . The data developed during the asbestos survey is presented in the following sections of this report. Table 1 contains the Summary of Bulk Sample Analysis and Assessment and Table 2 contains the Cost Estimate Summary. Both tables present specific locations , results of additional asbestos analysis, time schedules , and quantities of asbestos . These cost estimates are based on IHSTs experience and commercial estimates used by local abatement contractors. However, it should be noted that the cost estimates are not based on a written set of specifications or a confirmed scope of work , which can affect the final contract cost. 5.0 Sampling Sampling during the field investigation included the collection of bulk samples of suspected asbestos containing materials , as listed in Table 1., Summary of Bulk Sample Analysis and Assessment. After sample recovery, samples were placed in secure containers, and the sampling vicinity was cleaned and sealed . Appropriate chain-of-custody protocols were initiated at that time to track handling of bulk samples. 5.1 Laboratory Analysis The samples were transported to and analyzed by the analytical laboratory specified in Figure 2 ., a successful participant in the Department of Commerce , National Institute of Standards and Technology's (NIST) National Voluntary Laboratory Accreditation Program and licensed by the Texas Department of State Health Services (DSHS}, formerly the Texas Department of Health. Ten percent (10%) of the bulk samples were reanalyzed independently as part of the quality assurance and quality control programs . 1111 __ .. .._.T.......,.,lnc. Comprehensive Asbestos Survey City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth , TX 76112 Page 4 of 9 Industrial Hygiene and Safety Technology , Inc . Figure 2. Bulk Sample Laboratory Profile Laboratory Name: DSHS License Number: Steve Moody Micro Services #30-0084 IHST Project Number: 17617 NVLAP Lab ID: #102056 Expires: 5/31/2009 5.2 Analytical Methods Bulk samples were analyzed by Polarized Light Microscopy (PLM). This technique characterizes the materials refractive indices , fiber morphology, birefringence , extinction angle, sign of elongation, and dispersion staining colors to detect asbestos. Percentage estimates are based on approximate area compositions under a stereo-microscope . 5.3 Bulk Sample Results The results of the sample analysis are presented in Table 1, and the laboratory analysis report is included as Appendix B. Figure 3. Materials with Asbestos Detected at 1% or Greater Mat'/ Type • Sheetrock • Sheetrock • Flooring Matis • Sheetrock • Sheetrock Description Ceiling Texture (\Nhite , Popcorn) Sheetrock (\Nh ite) and Joint Compound 9" x 9" Floor Tile with Mastic Ceiling Texture (Beige , Popcorn) Sheetrock and Joint Compound , Beige Walls Location Office #1 , Upstairs Open Area , Next to Fire Place Lounge Upstairs Open Area , Office #3 , Foyer Kitchen Work Room , Sauna Work Room, Storage Room Figure 4. Materials with NO Asbestos Detected (Pursuant to EPA and DSHS Definition) Mat'/ Type Description • Flooring Matis 12" x 12" Floor Tile (Green and White) with Mastic (Yellow) 1111 __ ... tnt,,Tedn6orJ,lllc. Comprehensive Asbestos Survey City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth , TX 76112 Location Work Room , Kitchen Page 5 of9 Industrial Hygiene and Safety Technology, Inc. IHST Project Number: 17617 6.0 Hazard Assessment Asbestos is an airborne hazard . A hazard assessment refers to the process by which we evaluate a material's potential to release fibers into the air. Fibers may be released spontaneously as part of the aging process, or as a result of sudden impact, vibration, air movement, or localized deterioration. Assessing a material's potential for fiber release , and hence its associated hazard , is based upon evaluating the material's condition and potential for further disturbance, damage , or deterioration . 6.1 Hazard Assessment Rankings Any material identified as asbestos containing that exhibits damage , should be considered a hazard to anyone who works in the area . Typically , damage is classified as minor or significant. Minor damage is characterized by small cuts, tears , scuffs , small openings , or other limited disturbance to asbestos containing materials. Areas with minor damage represent varying degrees of hazards from slight to high depending on : * The nature of the damage; * Proximity to d isturbers, such as airstreams; * Location with respect to building occupants ; * Activity in the immed iate area; and * Frequency of maintenance in the area. Significant damage is characterized by large openings, visible flaking, loose particles, and debris on surfaces below the material. Asbestos containing materials which exhibit significant damage are either high or critical hazards, depending upon accessibility. High hazards exist where significantly damaged materials are generally inaccessible ; however, where significant damage is accessible , or in the vicinity of building occupants , there is a critical hazard. The recommended action for address ing asbestos related hazards depends upon the degree of hazard. For example : * An immediate hazard or critical assessment describes a situation in which the material is exposed and friable , accessible to personnel, and is disturbed releasing fibers in the air. In this situation, immediate action should be taken . At a minimum, the area should be isolated and access restricted . * A high assessment describes a s ituation in which the material is in poor condition , exposed and friable , with a potential for disturbance. In this case , interim controls should be instituted , and the material should be removed when practical. Repairs should be made to the ACM if abatement is not scheduled . * A medium or moderate assessment describes a situation in which a combination of the determining factors vary , such as a material that is in good cond ition but has a high asbestos content and is generally accessible. In situations like this , abatement can be scheduled with future building renovation or maintenance. * A low or slight assessment describes a situation in which the material is in good condition and has a low potential for disturbance , damage, or deterioration . In this situation , an O&M program is usually all that is needed. In general , those areas that are classified as critical or high damage should be abated . These are areas where a high probability of exposure could occur. Moderately damaged areas would require an Operations and Maintenance (O&M) Program to be instituted. In addition , these areas should be considered for abatement, or at the very least repaired . 1111 __ ... ._,.T~-. Comprehensive Asbestos Survey City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth , TX 76112 Page 6 of9 Industrial Hygiene and Safety Technology , Inc. IHST Project Number: 17617 6.2 Asbestos-Containing Material Assessments Figure 5 provides a summary of the asbestos identified during the survey , along with a hazard assessment for each type and condition of asbestos-containing material. Figure 5. Hazard Assessments for Asbestos-Containing Materials Flooring Materials Condition: Good, Friability: NF I, Disturbance Potential: Low The floor tile and mastic in good condition presents a low potential health hazard to building occupants due to its observed good condition and intact binding matrices. Prior to building demolition, renovation or work activities that would disturb these materials , removal must be performed by a properly trained and TDSHS-licensed abatement contractor. Prior to building demolition , removal of any damaged or significantly damaged floor tile and linoleum flooring should be performed by a properly trained and state-licensed abatement contractor. Currently, National Emission Standards for Hazard Air Pollutants (NESHAP) regulations allow Category I non-friable asbestos floor tile , sheet flooring and mastic in good condition , to be left in place during structural building demolition. Buildings subject to NESHAP regulations , require that wet demolition work be conducted with no visible emissions , and the presence of a "Competent Person" trained under the provisions of NESHAP to supervise the demolition work. The asbestos-containing materials should be placed in a management program and monitored until renovation or demolition activity occurs . The preceding hazard assessment applies to the asbestos-containing materials listed below: Area Ref# Homogeneous Area Description Quantity Location li:ll 04 9" x 9" Floor Tile with Mastic 80 s.f. Kitchen Sheetrock Wall or Ceiling Covering Condition: Good, Friability: NF II, Disturbance Potential: Low Sheetrock wall and ceiling covering in good condition presents a low potential health hazard to building occupants due to its observed good condition and intact binding matrices. Prior to building demolition, renovation or work activities that would disturb these materials, removal must be performed by a properly trained and licensed abatement contractor. The preceding hazard assessment applies to the asbestos-containing materials listed below: 1111 __ .. w.ty T.....,_ft. Area Ref# Homogeneous Area Description ~ 01 Ceiling Texture (VVhite , Popcorn) li'ii 02 Sheetrock (VVh ite ) and Joint Compound ~ 05 Ce iling Texture (Be ige , Popcorn) ~ 06 Sheetrock and Joint Compound , Beige Walls Comprehensive Asbestos Survey City of Fort Worth -Oak Hollow Offi ce 5901 Boca Raton Fort Worth , TX 76112 Quantity Location 1803 s.f. Office #1, Upstairs Open Area , Next to Fire Place Lounge 5628 s.f. Upstairs Open Area , Office #3, Foyer 200 s.f. Work Room , Sauna 1152 s.f. Work Room , Storage Room Page 7 of9 Industrial Hygiene and Safety Technology , Inc. IHST Project Number: 17617 7.0 Hazard Assessment Summary In the event other building materials are discovered in addition to the materials sampled in this survey, those building materials should be presumed to contain asbestos and treated as such until proven otherwise by PLM laboratory analysis . 7 .1 Response Actions Popcorn ceiling and sheetrock joint compound The popcorrn ceiling and sheetrock joint compound should be placed into an operations and maintenance program and managed appropriately until such time that renovation or demolition plans call for removal by a Texas licensed asbestos abatement contractor. 7 .2 Explanation of Response Ratings Table 1 includes a response rating based on factors such as friability , accessibility , potential for disturbance , etc. Definitions for the response ratings are listed below: O = Material does not contain detectable amounts of asbestos and requires no asbestos-related abatement action . 1 = Material contains asbestos, was non-friable, and requires no abatement action unless sanded, abraded, drilled or otherwise disturbed. 2 = Material contains asbestos and was friable. Damage was not observed ; no immediate abatement action is required. 3 = Material contains asbestos , was friable , and shows signs of localized damage with a potential for disturbance. 4 = Material contains friable asbestos and was significantly damaged . 1111 __ .. S*tT~lnc. Comprehensive Asbestos Survey City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth , TX 76112 Page 8 of 9 Industrial Hygiene and Safety Technology, Inc . IHST Project Number: 17617 8.0 Q u alificat i ons Industrial Hygiene and Safety Technology, Inc. has attempted to observe the existing conditions within the aforementioned building utilizing generally accepted procedures. Regardless of the thoroughness of a survey, the possibility exists that some areas containing asbestos were overlooked, inaccessible or different from those at specific locations. Furthermore, renovation and/or construction may reveal altered conditions. This report describes only the conditions present at the time of the survey, In the areas surveyed. The recommendations presented apply to the conditions that were observed during the survey. IHST policies are to not perform destructive sampling unless previously authorized by the client. Therefore , IHST does not perform core sampling of roofing materials unless previously authorized and accompanied by the owner and/or his representative. Other conditions may exist in unsurveyed or inaccessible areas such as behind walls and above permanent ceilings. In addition, the conditions of asbestos-containing materials may change gradually or suddenly depending upon use, maintenance or accident. As a result, the recommendations presented should be periodically reviewed and updated. The quantity estimates presented in this report were based upon observations during the survey as well as information from building plans provided by the owner. While It is believed that the estimated quantities are reasonable , unanticipated conditions could be present in inaccessible or unsurveyed areas. Industrial Hygiene & Safety Technology, Inc. do not warrant or guarantee the quantity estimates. The use of such estimates shall be at the user's own risk and shall constitute a release and agreement to defend and indemnify Industrial Hygiene & Safety Technology, Inc. from and against any liability. If you have any questions or comments regarding the content of this report, I would be glad to discuss them at your convenience. Sincerely, SHS Asbestos Inspector License #60-2207 Tracy K. Bramlett President DSHS Individual Asbestos Consultant License #10-5040 Comprehensive Asbestos Survey City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth, TX 76112 Page 9 of9 Industrial Hygiene and Safety Technology , Inc. IHST Project Number: 17617 1111 ---1,MyT ..... -. Appendix: Appendix A: Site Drawings Asbestos Survey Appendix City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth, TX 76112 16 1 1 Beige Sheetrock walls with joint compound Beige Sheetrock ceiling with joint compound ----White Sheetrock walls with joint compound + + .. + .. + + + + + + .. + White Popcorn ceiling . : • : . : . : • : . : . 9x9 Floortile ~~ -----============================::::: City of Fort Worth Oak Hollow Office, 5901 Boca Raton Fort Worth, Texas Asbestos Removal Specification Pro'ect # 17617 Drawin #1 Not To Scale Drawn by: AHG Date: 07/09/07 Revised by: Date: Downstairs 1111 Industrial Hygiene and Safety Technology, INC 2235 Keller Way Carrollton , Texas 75006 TEL (972) 478-741 E FAX (972) 478-761 1 Storage ----White Sheetrock walls with joint compound [S' ~ White Popcorn ceiling City of Fort Worth Oak Hollow Office, 5901 Boca Raton Fort Worth. Texas Asbestos Removal Specification Proiect # 17617 Drawina #1 Not To Scale Drawn by: AHG Date: 07/09/07 Revised by: Date: Upstairs 1111 Industrial Hygiene and Safety Technology , INC 2235 Keller Way Carrollton , Texas 7500€ TEL (972) 478-741 ! FAX (972) 478-761 Industri al Hygiene and Safety Technology , Inc. IHST Project Number: 176 17 1111 __ ... ...,t~IM. Appendix: Appendix B: Lab Results Asbestos Survey Appendix City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth , TX 76112 PLM Summary Report Steve Moody Micro Services , Inc. 2051 Valley View Lane Farmers Branch, TX 75234 (Phone 972-241-8460) Client : Industrial Hygiene & Safety Technology, Inc. Project: City of Fort Worth, Oak Hollow Office , 5901 Boca Raton Project#: Not Provided Sample Date: 07/03/2007 Identification: Asbestos, Bulk Sample Analysis Test Method : Polarized Light Microscopy/ Dispersion Staining (PLM/DS) EPA Method 600 / R-93 / 116 NVLAP Lab No. 102056 TDH License No . 30-0084 Lab Job No.: x7B-06214 Report Date : 07/04/2007 Page 1 of 2 On 7/3/2007, eighteen (18) bulk material samples were submitted b y Doug Easley of Industrial Hygiene & Safety Technology, Inc. for asbestos analysis b y PLM/DS . The PLM Detail Report is attached; additional information may be found therein . The results are summarized below: Sample Number Client Sample Description/ Location OHO 01 Ceiling Texture (White, Popcorn), Office #1 OHO 02 Ceiling Texture (White, Popcorn), Upstairs Open Area OHO 03 Ceiling Texture (White, Popcorn), next to Fireplace Lounge OHO 04 Sheetrock (White) and Joint Compound, Ceiling and Walls, Upstairs Open Area OHO 05 Sheetrock (White) and Joint Compound, Ceiling and Walls, Office #3 OHO 06 Sheetrock (White) and Joint Compound, Ceiling and Walls, Foyer OHO 07 12" x 12" Floor Tile (Green and White) with Mastic (Yellow), Work Room OHO 08 12" x 12" Floor Tile (Green and White) with Mastic (Yellow), Kitchen OHO 09 12" x 12" Floor Tile (Green and White) with Mastic (Yellow), Kitchen OHO IO 9" x 9" Floor Tile with Mastic, Kitchen OHO 11 9" x 9 " Floor Tile with Mastic, Kitchen OHO 12 9" x 9" Floor Tile with Mastic, Kitchen OHO 13 Ceiling Texture (Beige, Popcorn), Work Room OHO 14 Ceiling Texture (Beige, Popcorn), Work Room OHO 15 Ceiling Texture (Beige, Popcorn), Sauna Asbestos Content 5% Chrysotile -Acoustic Texture 5% Chrysotile -Acoustic Texture 5% Chrysotile -Acoustic Texture None Detected -Drywall Material 2% Chrysotile -Joint Compound None Detected -Joint Compound 2 % Chrysotile -Joint Compound None Detected -Floor Tile None Detected -Yellow Mastic None Detected -Floor Tile None Detected -Yellow Mastic None Detected -Floor Tile None Detected -Yellow Mastic None Detected -Yellow Mastic 2% Chrysotile -Floor Tile None Detected -Yellow Mastic None Detected -Yellow Mastic 2% Chrysotile -Floor Tile None Detected -Yellow Mastic None Detected -Yellow Mastic 2% Chrysotile -Floor Tile None Detected -Yellow Mastic None Detected -Acoustic Texture 5% Chrysotile -Acoustic Texture 5% Chrysotile -Acoustic Texture PLM Summary Report Steve Moody Micro Services, Inc. 2051 Valley View Lane Farmers Branch, TX 75234 (Phone 972-241-8460) Client: Project: Project#: Identification : Test Method : Industrial Hygiene & Safety Technology, Inc. City of Fort Worth, Oak Hollow Office, 5901 Boca Raton Not Provided Sample Date: 07/03/2007 Asbestos, Bulk Sample Analysis Polarized Light Microscopy / Dispersion Staining (PLM/DS) EPA Method 600 / R-93 / 116 NVLAP Lab No. 102056 TDH License No . 30-0084 Lab Job No . : x7B-06214 Report Date : 07/04/2007 Page 2 of 2 On 7/3/2007, eighteen (18) bulk material samples were submitted by Doug Easley of Industrial Hygiene & Safety Technology, Inc. for asbestos analysis by PLM/DS . The PLM Detail Report is attached; additional information may be found therein . The results are summarized below : Sample Number Client Sample Description/ Location Asbestos Content OHO 16 Sheetrock and Joint Compound, Beige Walls, Work Room None Detected-Drywall Material 2% Chrysotile -Old Joint Compound None Detected -New Joint Compound OHO 17 Sheetrock and Joint Compound, Beige Walls, Work Room 2% Chrysotile -Old Joint Compound None Detected -New Joint Compound OHO 18 Sheetrock and Joint Compound, Beige Walls, Storage Room None Detected -Drywall Material 2% Chrysotile -Old Joint Compound None Detected -New Joint Compound These samples were analyzed by layers. Quantification, unless otherwise noted , is performed by calibrated visual estimate. Results may not be reproduced except in full. This test report relates only to the samples tested. These test results do not imply endorsement by NVLAP or any agency of the U.S . Government. Accredited by the National Voluntary Laboratory Accreditation Program for Bulk Asbestos Fiber Analysis under Lab Code 102056. Analyst(s): Steve Moody _--<? ~ ,#/ Lab Manager: Bruce Crabb Approved Signatory : ~ ~ __ ~-1Y~~ Lab Director : Steve Moody Approved Signatory : Thank you for choosing Steve Moody Micro Services Industrial Hygiene and Safety Technology, Inc. IHST Project Number: 17617 1111 Asbestos Survey Appendix Appendix: Appendix C: Bulk Summary Report City of Fort Worth -Oak Hollow Office 5901 Boca Raton FortWorth,TX 76112 Table 1. Summary of Bulk Sample Analysis and Assessment City of Fort Worth Oak Hollow Office 5901 Boca Raton Fort Worth, TX 76112 Survey Date(s): 7/3/2007 through 7/3/2007 Sample ID# OH0-01 OH0-02 OH0-03 OH0-04 OH0-05 OH0-06 1111 __ ... --- Sample Description Material Location Ceiling Texture (White, Office #1, Upstairs Open Area , Popcorn) (homogeneous Next to Fire Place Lounge area# 01) Ceiling Texture (\/Vhite, Office #1, Upstairs Open Area , Popcorn) (homogeneous Next to Fire Place Lounge area# 01) Ceiling Texture (\/Vhite, Office #1 , Upstairs Open Area, Popcorn) (homogeneous Next to Fire Place Lounge area# 01) Sheetrock (White) and Joint Upstairs Open Area, Office #3, Compound (homogeneous Foyer area# 02) Sheetrock (White) and Joint Upstairs Open Area , Office #3, Compound (homogeneous Foyer area# 02) Sheetrock (White) and Joint Upstairs Open Area , Office #3, Compound (homogeneous Foyer area# 02) Asbestos Survey -IHST 17617 City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth , TX 76112 Percent & Type of Asbestos Detected (a) Acoustic Texture -5% CH Acoustic Texture -5% CH Acoustic Texture -5% CH Drywall Material -NAO Joint Compound -2% CH Joint Compound -NAO Joint Compound -2% CH Estimated Type of ACM Quantity (b) 1803 s.f. Surfacing 1803 s.f. Surfacing 1803 s.f. Surfacing 5628 s.f. Surfacing 5628 s.f. Surfacing 5628 s.f. Surfacing Frlablllty Physical PotenUal for Response (c) Condition Disturbance Rating NF II Good Low 1 NFII Good Low 1 NF II Good Low 1 NF II Good Low 1 NF II Good Low 1 NFII Good Low 1 Bulk Sample Analysis and Assessment Summary Page 1 of 3 Sample ID# OH0-07 OH0-08 OH0-09 OH0-10 OH0-11 OH0-12 OH0-13 OH0-14 1111 Sample Description Material Location 12" x 12" Floor Tile (Green Work Room , Kitchen and White) with Mastic (Yellow) (homogeneous area# 03) 12" x 12" Floor Tile (Green Work Room, Kitchen and White) with Mastic (Yellow) (homogeneous area# 03) 12" x 12" Floor Tile (Green Work Room , Kitchen and Wh ite) with Mastic (Yellow) (homogeneous area# 03) 9" x 9" Floor Tile with Mastic Kitchen (homogeneous area# 04) 9" x 9" Floor Tile with Mastic Kitchen (homogeneous area# 04) 9" x 9" Floor Tile with Mastic Kitchen (homogeneous area# 04) Ceiling Texture (Beige , Work Room, Sauna Popcorn) (homogeneous area# 05) Ceiling Texture (Beige, Work Room , Sauna Popcorn) (homogeneous area# 05) Asbestos Survey -IHST 17617 City of Fort Worth -Oak Hollow Office 5901 Boca Raton FortWorth ,TX 76112 I t Percent & Type of Asbestos Detected (a) Floor Tile -NAD Yellow Mastic -NAD Floor Tile -NAD Yellow Mastic -NAD Floor Tile -NAD Yellow Mastic -NAD Yellow Mastic -NAD Floor Tile -2% CH Yellow Mastic -NAD Yellow Mastic -NAD Floor Tile -2% CH Yellow Mastic -NAD Yellow Mastic -NAD Floor Tile -2% CH Yellow Mastic -NAD Acoustic Texture -NAD Acoustic Texture -5% CH ' I Estimated Type of ACM Quantity (b) 234 s.f. Misc . 234 s.f. Misc 234 s.f. Misc 80 s.f. Misc 80 s.f. Misc 80 s.f. Misc 200 s.f. Surfacing 200 s.f. Surfacing ' -Friablllty Physical Potential for \. ,nse (c) Condition Disturbance atlng NFI Good Low 0 NFI Good Low 0 NFI Good Low 0 NFI Good Low 1 NFI Good Low 1 NFI Good Low 1 NF II Good Low 1 NF II Good Low 1 Bulk Sample Analysis and Assessment Summary Page 2 of 3 Sample Sample Description Material Location Percent & Type of Estimated ID# Asbestos Detected (a) Quantity OH0-15 Ceiling Texture (Beige , Work Room, Sauna Acoustic Texture -5% CH 200 s.f. Popcorn) (homogeneous area# 05) OH0-16 Sheetrock and Joint Work Room , Storage Room Drywall Material -NAD 1152 s.f. Compound , Beige Walls Old Joint Compound -2% CH (homogeneous area # 06) New Joint Compound -NAD OH0-17 Sheetrock and Joint Work Room, Storage Room Old Joint Compound -2% CH 1152 s.f. Compound, Beige Walls New Joint Compound -NAD (homogeneous area # 06) OH0-18 Sheetrock and Joint Work Room, Storage Room Drywall Material -NAD 1152 s.f. Compound , Beige Walls Old Joint Compound -2% CH (homogeneous area # 06) New Joint Compound -NAD Table Key: (a) CH = Chrysotile ; AM = Amosite ; CR = Crocidolite; AN = Anthophyllite ; AC = Actinolite ; NAD = NAD = No Asbestos Detected (b) Misc = Miscellaneous; TSI = Thermal Systems Insulation (c) F = Friable ; NF I = Non-Friable Category I; NF II = Non-Friable Category II 1111 __ ... __ .... Asbestos Survey -IHST 17617 City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth , TX 76112 Type of ACM (b) Surfacing Surfacing Surfacing Surfacing Frlablllty Physical Potential for .mse (c) Condition Disturbance Katlng NF II Good Low NFII Good Low NFII Good Low NFII Good Low Bulk Sample Analysis and Assessment Summary Page 3 of 3 Industrial Hygiene and Safety Technology, Inc. IHST Project Number: 17617 1111 __ ... .....,,.......,,i.c. Asbestos Survey Appendix Appendix: Appendix D: Cost Estimate for Removal City of Fort Worth -Oak Hollow Office 5901 Boca Raton FortWorth,TX 76112 Table 2. Approximate Cost to Remove Asbestos City of Fort Worth Oak Hollow Office 5901 Boca Raton Fort Worth, TX 76112 Survey Date(s): 7/3/2007 through 7/3/2007 Material Description Locatlon(s) Popcorn ceiling texture Ceiling of office, work room and sauna Sheetrock and joint compound Throughout complex 9" x 9" floor tile Kitchen Approx. Quantity 2003 s.f. 6780 s.f. 200 s.f. Unit Cost #Days Removal Air Monitoring to Abate Cost (per day) $2.00 3 $4,006.00 $600.00 $2.00 5 $13,560.00 $600.00 $2 .50 1 $500.00 $600.00 Removal Costs Subtotal: Abatement Specifications: Total Abatement Cost: 1. The price estimates were derived from current estimates from asbestos abatement contractors. 2. Price does not include replacement costs with non-asbestos materials. 3. Air monitoring costs do not include final air clearance by Transmission Electron Microscopy. 4. Price estimates listed above are intended as a guide for budget estimating only. To determine the total abatement costs for the project, asbestos removal specifications should be prepared and the project bid by professional asbestos abatement contractors . 5. Prices could be reduced if all abatement activities are performed at one time . 6. Prices may be slightly higher for small abatement projects due to mobilization costs. 7 . Prices do not include the Texas Department of State Health Services (DSHS) fee for asbestos regulated units generated for the removal of ACM quantified in Table 2. 8 . Time schedule includes air clearance monitoring and contractor demobilization from site . Time schedule for abatement will also vary depending on the size of the contractor's work force and the specified scope of work . 1111 Approximate Cost to Remove Asbestos City of Fort Worth -Oak Hollow Office 5901 Boca Raton Fort Worth, TX76112 Line Item Subtotal $5,806.00 $16,560.00 $1,100.00 $23,466.00 $350.00 $23,816.00 Page 1 of 1 PLM Summary Report Steve Moody Micro Services, Inc. 2051 Valley View Lane Farmers Branch, TX 75234 (Phone 972-241-8460) Client: Project : Project#: Identification : Test Method : Industrial Hygiene & Safety Technology, Inc. Fort Worth, Oak Hollow and Villa Del Rio Apartments Not Provided Sample Date : 10/11/2007 Asbestos, Bulk Sample Analysis Polarized Light Microscopy / Dispersion Staining (PLM/DS) EPA Method 600 / R-93 / 116 NVLAP Lab No. 102056 TOH License No . 30-0084 Lab Job No .: x7B-10510 Report Date: 10/12/2007 Page 1 of 1 On 10/12n007, six (6) bulk material samples were submitted by Eve Whitehead of Industrial Hygiene & Safety Technology, Inc. for asbestos analysis by PLM/DS . Toe PLM Detail Report is attached; additional information may be found therein. Toe results are summarized below: Sample Number Client Sample Description I Location 1 Roofing Material, Villa Del Rio, 5828 Boca Circa 2 3 4 5 6 Roofing Material, Villa Del Rio, 5828 Boca Circa Roofing Material, Villa Del Rio, 5828 Boca Circa Roofing Material, Oak Hollow Apartments, 5901 Boca Raton Roofing Material, Oak Hollow Apartments, 5901 Boca Raton Roofing Material, Oak Hollow Apartments, 5901 Boca Raton Asbestos Content None Detected -Roof Membrane None Detected -Roofing Material None Detected -Underlayment None Detected -Roof Membrane None Detected -Roofing Material None Detected -Underlayment None Detected -Roof Membrane None Detected -Roofing Material None Detected -Underlayment None Detected -Roofing Shingle None Detected -Roofing Shingle None Detected -Roofing Shingle These samples were analyzed by layers. Quantification, unless otherwise noted , is performed by calibrated visual estimate. Results may not be reproduced except in full . This test report relates only to the samples tested. These test results do not imply endorsement by NVLAP or any agency of the U .S. Government. Accredited by the National Voluntary Laboratory Accreditation Program for Bulk Asbestos Fiber Analysis under Lab Code 102056 . Analyst(s): Shaun Wilkerson _-4 ~ ,#/ Lab Manager: Bruce Crabb Approved Signatory:~~ ~ __ Lab Director : Steve Moody Approved Signatory : .,..-1 ______- Thank you for choosing Steve Moody Micro Services -~ -J • / ,r-4 -- Steve Moody Micro Services, Inc. PLM Detail Report TOH License No. 30-0084 2051 Valley View Lane Supplement to P L M S ummary Report NVLAP Lab No. 102056 Fanners B ranch , TX 75234 C lient: Industrial Hygiene & Safety Technology, I nc . Lab Job No .: x7B-10510 Project: Fort Worth, Oak Hollow and Villa Del Rio Ap artments Report D ate : 10/12/2007 Project#: Not Provided Page 1 of 2 Sample Number I Layer 1 %0 f Samo le Components I % of ~alysis IAnal st Laver D ate y 1 R oof Memb rane (Black) 10% Synthetic Fibers 10% 10/12 SW Calcite 30% Binders I Fillers 60% Roofing Material (Black) 80% Cellulose Fibers 25% Aggregate 20% Tar Binders 55% Underlayment (Tan) 10% Cellulose Fibers 80% Perlite 20% 2 Roof Membrane (B lack) 10% Synthetic Fibers 10% 10/12 SW Calcite 30% Binders I Fillers 60% Roofing Material (Black) 80 % Cellulose Fibers 25% Aggregate 20% Tar B in ders 55% Underlayment (Tan) 10% Cellulose Fibers 80% Perlite 20% 3 Roof Membrane (B lack) 10% Synthetic Fibers 10% 10/12 SW Calcite 30% Binders / Fillers 60% Roofing Material (Black) 80% Cell ulose Fibers 25% Aggregate 20% T ar B inders 55% Underlayment (Tan) 10% Cellulose Fibers 80% Perlite 20% Aggregate (Tan) 5% Aggregate 100% 4 Roofing Shingle (Black) 95% Glass Wool Fibers 15% 10/12 SW Calcite 25% Sand 30% Tar Binders 30% Steve Moody Micro Services, Inc. 2051 Valley View Lane Farmers Branch, TX 75234 PLM Detail Report Supplement to PLM Summary Report TDH License No . 30-0084 NVLAP Lab No. 102056 Client : Project : Industrial Hygiene & Safety Technology, Inc . Fort Worth, Oak Hollow and Villa Del Rio Apartments Not Provided Lab Job No . : x7B-10510 Report Date : 10/12/2007 Project#: Sample Number I 5 6 Layer Aggregate (Tan) Roofing Shingle (Black) Aggregate (Tan) Roofing Shingle (Black) 1 %0f Sample Components 5% 95% 5% 95% Aggregate Glass Wool Fibers Calcite Sand Tar Binders Aggregate Glass Wool Fibers Calcite Sand Tar Binders Page 2 of2 I % of Malysis IAnal st Laver Date y 100% 15% 10/12 SW 25% 30% 30% 100% 15% 10/12 SW 25% 30% 30% EXHIBIT "C" - FORT WORTH December 5, 2007 Kathryn C. Perkins, RN, MBA Assistant Commissioner Division for Regulatory Services, Mail Code 1949 Texas Department of State Health Services 1100 W. 49th Street Austin, Texas78756 Re: City of Fort Worth · Request for Enforcement Discretion Concerning the Alternative Asbestos Control Method; Demolition of the Oak Hollow Apartment Office Building located at 5901 Boca Raton Boulevard, Fort Worth, Texas With · Regulated Asbestos-Containing Materials In-Situ Dear Ms. Perkins, The City of Fort Worth (City) hereby makes this request for a grant of discretionary enforcement from the Texas Department of State Health Services in order to demolish a structure known as the Oak Hollow Apartment office building, located at 5901 Boca Raton Boulevard, Fort Worth, Texas, utilizing the Alternative Asbestos Control Method (AACM). Background The United States Environmental Protection Agency's (EPA) Office of Research and Development and EPA Region 6 are currently conducting a study to compare the' effectiveness of the AACM for .the demolition of certain structures against the required method under the National Emissions Standard for Hazardous Air Pollutants (NESHAP), 40 CFR Part 61, Subpart M. AACM method allows the non-friable asbestos to remain in a building to be demolished provided the interior is wetted with amended water prior to demolition and the exterior is wetted with amended water during the demolition to control fiber release. The friable asbestos material is removed from the building prior to the demolition. The dem0Iit10n debris is disposed as asbestos waste at an approved landfill, including several inches of soil. Water is captured and also removed from the site. Two controlled demonstrations have already been conducted by the EPA, one with the discretion of enforcement. Both demonstrations occurred in Fort Chaffee, Fort Smith, Arkansas. CITY MANAGER'S OFF1CE THE C 1Tv or, FoRT WORTH * 1000 THROCKMORTON SmEET • FORT WORTH, TEXAS 76102 817-392-6111 * FAX 817-392-6134 ,,. t..: Printed on recycled paper Kathryn C . Perkins December 5, 2007 Page2 Demolition of the Structure The City owns, in fee, the apartment buildings and the office building known as Oak Hollow Apartments located at 5901 Boca Raton Boulevard. The office building proposed to be demolished using the AACM contains asbestos containing material, specifically "popcorn ceiling" asbestos material, :finished sheetrock ceilings and walls and floor tile. As owner of the building, the City of Port Worth and its contractor for such demolition work are regulated persons and therefore required to demolish the structure pursuant to Texas Asbestos Health Protection Act (TAHP A) and NESHAP. EPA has asked the City to use the AACM to demolish the building in strict compliance the site specific Quality Assurance Project Plan (QAPP) enclosed herein, and EPA' s No Action Assurance letter provided that DSHS grants similar discretion of enforcement to regulated persons. Request for Discretion of Enforcement On December 5, 2007, the City of Fort Worth received a No Action Assurance Letter from the EPA for the use of the AACM for the demolition of the Oak Hollow Apartment office building located at 5901 Boca Raton Boulevard under the specifications of the QAPP (a copy of which is attached to this letter). Pursuant to the Texas Administrative Code (TAC) Section 295.34(k)(l) the City requests a similar letter exempting the City from Texas Asbestos Health Protection Act (TAHPA). DSHS may also grant the City an exemption under TAC 295.34(k)(2), from the TAHP A/NESHAP rules because the demolition as proposed using the AACM and adhering to the QAPP is at least equivalent if not greater for the protection of the public's health and safety than the TA.HP A/NESHAP. We appreciate your attention to this matter, and hope for a swift resolution to our request. Libby Watson Assistant City Manager Attachments: USEPA No Action Assurance Letter dated December 4, 2007 Quality Assurance Project Plan dated December 4 1 2007 CRLl2.5.07v2 EXHIBIT "C" TEXAS DEPARTMENT OF STATE HEALTH SERVICES DAVID L LAKEY, M.D. COMMISSIONER Ms. Libby Watson Assistant City Manager City of Fort Worth 1000 Throckmorton Street Fort Worth , Texas 76102 Dear Ms. Watson : 1100 West. 49th Street• Austin, Texas 78756 P.O . Box 149347 • Au stin, Texas 78714-9347 l-88&-96 3-7111 .. WWW,!hb.s.S IJ]J .dx.u s TrY: 1-800-735-2989 December10, 2007 This is an agreement by the Department of State Health Services (DSHS) to take no enforcement action regarding the demolition of the structure located at 5901 Boca Raton Boulevard, in the Oak Hollow Apartments in Fort Worth, using the Alternate Asbestos Control Method (AACM). The Region 6 office of the United States Environmental Protection Agency (EPA), the EPA Office of Research and Development. and the City of Fort Worth are cooperating in an evaluation of the AACM for demolition of buildings constructed with certain asbestos- containing building materials. EPA issued its decision on December 4, 2007 to exercise discretion to exempt this demolition project from enforcement of certain provisions of the National Emission Standard for Hazardous Air Pollutants (NESHAP) for asbestos. The City of Fort Worth has requested an assurance of no enforcement action from DSHS for this project. DSHS will exercise its enforcement discretion, as provided in Texas Occupations Code § 1954.060(c), to refrain from enfordngapplicable provisions of the Texas Asbestos Health Prote<..iion Act and Rules (Occupations Code Chapter 1954 and 25 Texas Administrative Code, Chapter 295, Subchapter C), and the federal asbestos NESHAP, 40 CFR Part 61 , Subpart M, §§61.145(c)(1) through (6), against activities conducted to demolish the property in accordance with the AACM as detailed in the site-specific Quality Assurance Project Plan. The DSHS no-action assurance is effective immediately and expires at midnight on Thursday, January 3·t. 2008. The DSHS no- action assurance expires immediately upon deviation from the AAGM protocols as detaiied in the site-specific Quaiiiy Assurance Project Pian. Sincereiy, ~~vL K~~n C. Perkins . RN .. M .B.A. A ss is t a nt Co mmiss ioner F<eg u!atory Servic es D ivision