attachment 5 asbestos abatement alternative work … · 2019-06-19 · 10-foot wide (from the...

ATTACHMENT 5

ASBESTOS ABATEMENT ALTERNATIVE WORK PRACTICES AND SUPPORTING DOCUMENTATION

Non-traditional Asbestos Abatement Work Plan 1

March 2019

NON-TRADITIONAL ASBESTOS ABATEMENT WORK PLAN

Former National Amusements Showcase Cinema Building

936 Silver Lane

East Hartford, Connecticut

This project calls for the removal and disposal of the following per the attached MMI

Survey Report (See Appendix A) dated March 8, 2019:

• approximately 23,500 Square Feet (SF) of asbestos-containing exterior

white textured wall paint (portions covered by new renovations);

• approximately 1,000 Linear Feet (LF) of gray masonry caulk;

• approximately 4,000 SF of black foundation mastic; and,

• asbestos-containing/contaminated debris on concrete walkways and

slabs, and within surficial soils (up to 1 inch of contamination to be

abated as part of this work).

For the purposes of this project, according to the in-house Milone and MacBroom, Inc.

structural engineer, Mr. Glenn D. Jarvis, P.E., the above materials are associated with the

structural concrete masonry unit (CMU) block wall of the Site building and shall be

demolished into the existing building footprint for “Make Safe” purposes (not pulled

away from the building slab; this will allow for decontamination of the existing slab

following demolition). A letter provided by Mr. Jarvis can be found within Appendix

B of this document. Paint debris and masonry caulk were also discovered to be

comingled on the concrete sidewalks and within surficial soils; see the Photo Document

showing the CMU block wall and associated surficial debris is in Appendix C. More

specifically, surficial contaminated soils (and/or decontamination of concrete

surrounding the base of the original perimeter building footprint exterior walls) shall also

be removed/disposed of as asbestos waste. Separate “Exclusion Zones - EZs” may also

be required as the work progresses. EZ(s) will be erected and consist of an approximate

10-foot wide (from the building edge) area to allow for surficial decontamination. After

visible debris has been removed from porous surfaces, at grade to a minimum of 1 inch

of soil (otherwise considered “surficial soils” will be removed and disposed of as

Asbestos-Containing Waste Material (ACWM); surficial concrete surfaces will be

decontaminated and inspected by the licensed project monitor as the work

progresses. If additional debris is then found in soils, additional soil removal will

continue in increments of at least 2 inches until no visible debris is observed. Sporadic

locations on the interior building walls also contain white textured wall paint. These areas

will be abated during interior conventional abatement work activities, providing the walls

are non-structural in nature.


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Demolition/”live loading” work shall be performed following conventional interior

abatement activities and selective demolition/disposal work of non-asbestos materials.

Conventional work will be performed utilizing hand tools only. Demolition/”live loading”

activities will be performed within an EZ and utilize large construction equipment (i.e.,

100-yard dump trailers supplied by the abatement contractors trucking company,

closed-cab excavator(s), front loaders, etc.) and hand tools as necessary. Excavation

operators will be asbestos-licensed and hazardous materials OSHA/HazWoper trained in

order to perform work within the EZ. All dump trailers will be lined with two layers of 10-

mil poly liners; the liners shall be installed by the ACM Contractor and labeled with

appropriate Generator/OSHA labels on liners, including #9 Placard atop each liner. The

trucks will be located within the EZ during the loading while on laydown areas via rubber

membrane. Connecticut-certified asbestos workers shall be on the ground to assist with

material wetting and hand removal of any loose ACM generated within the EZ. Ten-

millimeter rubber laydown sheeting will be placed on the ground, beneath and around

each trailer truck, during loading on soil and pavement surfaces respectively to prevent

any debris from impacting surrounding soils outside the EZ. Debris that has fallen

onto/around the rubber membrane will be picked up and placed in the lined trailer,

along with the rubber membrane, once the truck has been loaded. As previously

mentioned, a continuous visual inspection shall be conducted during the loading around

the excavator to ensure that no ACM debris is released, and no visible emissions occur.

A licensed asbestos abatement contractor shall conduct all waste trailer lining (each

trailer bed will be lined with two 10-mil polyethylene liners and labeled accordingly with

appropriate #2212 hazardous waste placards on each of the 4 sides of the trailers),

wetting of soils and perimeter block walls/debris during loading, sealing of waste trailers,

and decontamination of waste trailers and excavation equipment. The Contractor and/or

Contractor’s Trucking Company are required to perform the appropriate soil

characterization testing (via profile and sampling frequency) required by the landfill. A

water source will be provided by the Contractor to maintain the assumed asbestos-

contaminated soils/associated surrounding soils and confirmed asbestos debris within

the building footprint in a wet condition during removal activities.

Vehicles and equipment entering the EZ’s will pass through a control point one at a time.

An equipment decontamination pad shall be constructed and utilized for this work. The

decontamination (decon) pad shall be set up to allow for the collection and filtering of all

rinsate. The decon pad shall be constructed of heavy gauge rubber membrane material

placed over a gravel/crushed stone base. A berm will be constructed around the pad for

the collection of the rinsate. Trucks and equipment that enter the EZ shall be

decontaminated in the EZ’s after loading and cleaned again at the decon pad during exit.

Exiting trucks and equipment will pass over the decon pad where tires, chassis,

walls/sides, etc., which have been in contact with debris will be pressure washed. The

decon pad and asphalt paved areas shall be cleaned of all debris at the end of each work

shift, as well as, at the end of the project and washed down with water (decon pad) via


March 2019

HEPA vacuums. Rinsate will be collected at the decon pad (and excess water on the

surface of the contaminated soils footprint (as needed) and treated utilizing an asbestos

5 micron water filtration system. Filtered rinsate shall be removed off-site to a water

treatment plant set up to handle this type of water. The Decontamination Pad is

shown on Site Figure within Appendix D.

A remote 3 stage personnel decontamination unit shall be set up contiguous to the

Exclusion Zone(s). All workers shall wear appropriate respiratory and personal protective

equipment while in the EZ’s/Hot Zones.

The Town of East Hartford (TOWN) is requesting relief from Subsections 19a-332a-5(c),

(d), (e), and (h), Subsection 7(c), and from Section 19a-332a-12 of the Regulations of

Connecticut State Agencies (RCSA). The work area shall be isolated from non-work

areas by air-tight barriers attached securely in place. It is not feasible for the Asbestos

Abatement Contractor (CONTRACTOR) to erect a negative pressure containment within

the exterior building regulated area. The proposed deviations and alternatives must be

performed in accordance with, but not limited to, the current revision of the OSHA

General Industry Standard for Asbestos (29 CFR 1926.1001), the OSHA Asbestos in

Construction Regulations (29 CFR 1926.1101), the United States Environmental

Protection Agency (USEPA) Asbestos National Emission Standards for Hazardous Air

Pollutants (NESHAP) Regulations (40 CFR Part 61 Subpart M), the Connecticut

Department of Public Health (CTDPH) Standards for Asbestos Abatement, Licensure and

Training (19a-332a-1 through 16, 20-440-1 through 9 & 20-441), the Connecticut

Department of Energy and Environmental Protection (CTDEEP) Special Waste Disposal

Regulations (22a-209-8(i), local statutes, local ordinances, local codes and any other

applicable federal, RCSA and any other local government regulations and guidelines.

Except as noted, all other work practices specified in the RCSA are mandatory.

A DEEP/DPH licensed Project Monitor shall monitor all activities involving asbestos

abatement on a full-time basis. The Project Monitor shall, as a minimum, collect air

samples at the boundary of the regulated area during each shift to document airborne

fiber concentrations. If air samples collected during abatement activities indicate

airborne fiber concentrations greater than background levels or greater than 0.01 f/cc, as

determined by Phase Contrast Microscopy, whichever is larger, work shall stop and the

DEEP/DPH shall be informed. Engineering controls will be adjusted, and permission from

the DEEP/DPH shall be received prior to work recommencing.

In lieu of the requirements of Subsection 19a-332a-5(c), (d), (e), and (h), Subsection 7(c)

and Section 19a-332a-12, a regulated area, as defined by the existing construction fence,

barrier tape and appropriate signage, will be established around the building prior to the

contractor commencing work (otherwise known as the EZ); a plan is attached showing

the anticipated work areas. The work area shall be continually wetted during this project

to ensure that all waste is maintained wet. The demolition, sorting and segregating of

the facility shall not proceed without the full-time review of a DEEP/DPH licensed


March 2019

asbestos Project Monitor. Work shall proceed at a pace that will allow ACM to be

identified and appropriately sorted. All non-discrete waste from this building that

cannot be categorized by the Project Monitor as being asbestos-free shall be treated as

friable asbestos waste. It is understood by Milone and MacBroom, Inc. (MMI) that if the

CTDEEP/CTDPH determines that any materials or equipment have left the regulated area

without first being inspected by the MONITOR, this NTP will be immediately rescinded,

and all work on this project shall stop until a new work plan is approved by the

DEEP/DPH. At the completion of this project, the Project Monitor shall inspect the

regulated work area to ensure that no visible asbestos residue is present. The Project

Monitor shall document this inspection result in writing.

NOTE: If accumulated water remains within the Building footprint surrounding the

assumed asbestos-contaminated CMU, it will be filtered through the 5-micron

water filtration system and discarded off-site to a water treatment plant. If

allowable/authorized by the Town of East Hartford and the DPH, the most efficient

means of disposal would be to allow the contractor to discard the water into a

nearby municipal drain, FOLLOWING filtration of the water through a 5-micron

system.

Refer to attached Site Plan for a detail of the EZ and support zones.

Building Owner

Town of East Hartford

Abatement Inspections

Pre-abatement inspections may be conducted by the DEEP/DPH, or a Connecticut-

licensed asbestos project monitor (AM). The DEEP/DPH is to be provided a minimum of

24-hours’ notice, to schedule pre and post visual inspections of the work area.

Post-abatement inspections may be conducted by DEEP/DPH, or the AM.

Asbestos Removal Contractor

TO BE DETERMINED

Asbestos Designer

Ryan Rouillard of Milone & MacBroom, Inc. (MMI), License # AD062001

Asbestos Project Monitor

TO BE DETERMINED

Waste Hauler

TO BE DETERMINED

Landfill - TO BE DETERMINED


March 2019

“Competent Person” Requirements

A. On all construction sites with asbestos operations, CONTRACTOR will name a

“competent person” qualified and authorized to ensure worker safety and health,

as required by Subpart C, General Safety and Health Provisions for Construction

(29 CFR 1926.20). Under these requirements for safety and health prevention

programs, the “competent person” will frequently inspect/assess job site,

materials, and equipment for changing conditions, and upon employee request.

B. The “competent person” will supervise:

1. the setup and integrity of regulated areas, enclosures, exclusion zones or

other containments via onsite inspection,

2. procedures to control entry to and exit from the regulated area(s),

3. all employee exposure monitoring, ensuring it is properly conducted,

4. use of required protective clothing and equipment by employees working

within the enclosure and/or using glove bags,

5. proper setup, removal, and performance of engineering controls, work

practices, and personal protective equipment through onsite inspections,

6. employee use of hygiene facilities and required decontamination procedures,

and

7. notification requirements.

C. The “competent person” should have attended a comprehensive training course

for contractors and supervisors certified by the U.S. Environmental Protection

Agency (EPA), a state-approved training provider, or a course that is equivalent in

length and content.

Work Area Preparation

A. An EZ will be established where CONTRACTOR employees work with asbestos,

including any adjoining area(s) where debris and waste from asbestos work

accumulates or where airborne concentrations of asbestos exceed or can possibly

exceed the permissible exposure limit (PEL).

B. All Class II asbestos work or any other operations where airborne asbestos

exceeds the PEL will be done within regulated areas. Authorized personnel only

may enter. The designated “competent person” will supervise all asbestos work

performed in the area.

C. CONTRACTOR will mark off the regulated area in any manner that minimizes the

number of persons within the area and limits persons outside the area from


March 2019

exposure to airborne asbestos. Red asbestos barrier tape and yellow

construction tape will mark off the regulated areas.

D. Posted warning signs demarcating the work area will be easily readable and

understandable. The signs will bear the following information:

DANGER

ASBESTOS

CANCER AND LUNG DISEASE HAZARD

AUTHORIZED PERSONNEL ONLY

RESPIRATORY AND PROTECTIVE CLOTHING ARE

REQUIRED IN THIS AREA

E. CONTRACTOR will supply a respirator to all persons entering the regulated areas

(See respiratory protection requirements elsewhere in this document).

F. ONTRACTOR employees will not eat, drink, smoke, chew tobacco or gum, or

apply cosmetics in regulated areas.

G. MMI will oversee this asbestos abatement and decontamination work. As

supervisor of the entire project, MMI will determine whether the CONTRACTOR

complies with the standard and will make necessary recommendations to

CONTRACTOR to correct non-compliance.

H. The signs and barrier tape (labelled “asbestos”) shall be posted at the perimeter

of the regulated area allowing sufficient space for the work to be performed.

I. The following is the sequence of work that CONTRACTOR shall adhere to during

the asbestos removal and decontamination of the structure:

1. CONTRACTOR shall post all required signage. Warning signs shall be

posted on all critical barriers at the commencement of the work area

preparation, as required in all applicable federal, state and local

regulations and specifically 1926.1101(k)(6)(i) of the Occupational Safety

and Health Standards Federal Register. The signs shall display the proper

legend in the lower panel, with letter sizes and styles of a visibility at least

equal to that specified in OSHA Standard OSHA’s 1926.1101(k)(6)(i).

2. CONTRACTOR shall secure the work area from unauthorized access for

the duration of the asbestos abatement.

3. A remote 3-stage personal decontamination unit shall be constructed at

the edge of each demarcated EZ associated with the asbestos work areas,


March 2019

and must include an equipment room, a shower room, and a clean room

adequate to accommodate the number of asbestos workers performing

removal activities. All personnel performing any work activities within the

designated asbestos work areas shall decontaminate through the remote

personnel decontamination unit, upon exiting the designated work areas.

a. The Equipment Room shall serve as a transfer room and an

intermediate area between the work area and any

decontamination procedures to occur in the shower room. This

room shall be vacuumed and washed whenever necessary in order

to prevent asbestos dust and or debris accumulations. The

Equipment Room will also serve as an access area to the shower

for personnel leaving the work area. Workers leaving the

containment shall remove and dispose of disposable protective

suits and wear only respirators into the Shower. At the end of

each day, bags of asbestos waste and contaminated materials shall

be removed after a thorough decontamination procedure as

described in the contract specifications. Workers performing this

operation will wear respirators and disposable full-body protective

suits

b. The Shower Room shall have a continuous supply of cold and hot

water and be suitably arranged for complete showering during

decontamination. The Shower Room with curtained doorways will

comprise an airlock between contaminated and clean areas. All

materials being passed from the equipment room to the clean

room must pass through the shower and be thoroughly

decontaminated. The shower floor will be a leak tight catch basin

equipped with a sump pump and waste water will be pumped into

a waste container. There shall be no discharge to ground or

drains. The contractor shall provide disposable towels and soap in

the shower area.

c. The Clean Room shall store asbestos worker's clean protective

clothing and clean respirator equipment. Contaminated clothing,

respirators, tools, equipment, or other materials shall not be

allowed into the Clean Room or beyond. The Clean Room will

serve as an access for personnel entering the work area, and for

the donning of respiratory protection and protective clothing.

CONTRACTOR shall provide space in the clean room for the

worker's personal clothing. This may be in the form of hangers or

lockers.


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Remote 3-stage Decontamination Unit

Requirements for Non-Traditional Masonry Paint and Joint Caulk Removal

A. A “work area” (CTDPH Standards for Asbestos Abatement 19a-332a-1(jj)), shall be

established that extends outward from the exterior side of the building where

removal will result in disturbance of asbestos-containing materials. There should

be no visible emissions at any time.

B. Work shall be temporarily halted if sustained wind speeds exceeding 15 miles per

hour during abatement activities, which generate dust.

C. Should CONTRACTOR utilize heavy construction equipment:

1. All components shall be cleaned of visible debris at the end of each

workday, or when DEEP/DPH the regulated areas.

2. Equipment Operators will wear PPE associated with asbestos regulations,

as well as OHSA-approved equipment and hard hats.

D. Should CONTRACTOR utilize scaffolding for interior operations:

1. All staging and scaffolding (if needed) shall be furnished and erected by the

CONTRACTOR in accordance with all applicable requirements (including, but

not limited to OSHA regulation 29 CFR 1926.451) and be maintained in safe

condition by him at no additional cost to the Owner.

E. Asbestos-containing materials shall be adequately wet with amended water prior

to and during removal. All material may be removed utilizing hand-tools, a

HEPA-vacuum, and a wet wipe collection method.

F. The work area, including ground covers and equipment, shall be cleaned of

visible debris at the end of each workday.


March 2019

G. Upon completion of the asbestos-containing material removal, the wall areas

shall again be cleaned by HEPA –vacuuming and/or wiped with a wet sponge or

cloth. Polyethylene sheet (where used) shall be removed and disposed of as

ACWM in accordance with 310 CMR 7.15(15)-(18).

H. Soils will be removed from the edge of the building (approximately 3 feet).

I. Pavement/Concrete shall be decontaminated from the edge of the building

(approximately 6 feet) utilizing HEPA-vacuums at the completion each day.

J. CONTRACTOR shall set-up barriers to prevent the release of contaminated water

from the regulated area.

K. If accumulated water remains within the regulated area, it will be filtered through

a 5-micron water filtration system and used to wet the ACM, and then discarded

off-site; more specifically, the water shall be discarded as asbestos-contaminated

and disposed of at an approved treatment plant as asbestos.

L. All equipment within the regulated area shall be cleaned of visible dust and

debris via HEPA-vacuum and/or wet wipe, prior to removal from the work area.

Wet wipes shall be managed as ACWM.

M. The polyethylene sheets shall be cleaned of visible dust and debris by HEPA-

vacuum and/or wet wipe. Dry sweeping shall not be allowed.

N. If disposable protective clothing is used, it shall be disposed as ACWM.

O. Thoroughly wetted ACM shall be live-loaded into tractor trailer dumpsters

utilizing heavy construction equipment; for interior operations, conventional

abatement regulations regarding removal/disposal shall apply.

P. At the conclusion of the work, the work site shall be inspected for dust or debris.

The work area shall be re-cleaned until no such debris is found.

Q. All waste shall be labeled as ACWM prior to removal from the work areas.

R. Visual Clearance inspection of the regulated areas shall be conducted by the

project’s AM.

S. For activities that disturb friable ACM, no visible emissions shall be discharged to

the air during the collection, processing, packaging, or transporting of any ACM.


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Labels

A. CONTRACTOR will attach warning labels to all waste containers. As stated above,

labels will be printed in large, bold letters on a contrasting background and used

in accordance with the Occupational Safety Health Administration (OSHA’s)

Hazard Communication Standard (29 CFR 1910.1200), including the #9 placard.

All labels will contain a warning statement against breathing asbestos fibers and

contain the following legend:

DANGER

CONTAINS ASBESTOS FIBERS

AVOID CREATING DUST

CANCER AND LUNG DISEASE HAZARD

B. Following removal of the exterior wall system, and double-wrapping with 6-mil

poly (and labelling), all ACWM shall be removed from the exclusion zone at the

time of abatement and transported off-site daily, within a fully enclosed/lined

and locked container per RCSA requirements. Waste will NOT be stored on-site. A

Copy of the partially executed waste shipment record must be submitted directly

to the CTDEEP/DPH by CONTRACTOR on the day the waste leaves the Site.

Air Monitoring

A. CONTRACTOR shall provide OSHA personal air monitoring during the removal

process. CONTRACTOR will ensure that no employee is exposed to an airborne

concentration of asbestos in excess of 0.1 fibers per cubic centimeter (f/cc) as an

8-hour time-weighted average (TWA). Also, CONTRACTOR will ensure that no

employee is exposed to an airborne concentration of asbestos in excess of 1 f/cc

as averaged over a sampling period of 30 minutes. Sampling shall be performed

by a competent person as described in the OSHA regulations.

B. For the exterior operations, the Owner’s industrial hygienist (IH) shall select a

minimum of four ambient air monitoring points (North, East, South, West) around

the EZ and collect two (2) sets of air monitoring samples, per an 8-hour shift (one

set per 4-hours). For interior operations, the IH shall collect outside containment

area air samples during work to monitor the containment(s) structural integrity.

The samples shall be analyzed using Phase Contrast Microscopy (PCM). All PCM

samples shall be analyzed on a daily basis via phase contrast microscopy method

7400. Analytical data shall be e-mailed to the DEEP/DPH on a daily basis (if

requested).

C. Should fiber concentrations reach or exceed the criterion of 0.010 f/cc, the

Owner’s IH will stop all abatement activities, the CTDEEP/DPH shall be


March 2019

immediately notified by telephone, and adjust engineering controls to decrease

fiber concentrations. The work methods shall be evaluated by the CTDEEP/DPH

prior to continuing any further work. Additionally, as noted above, work shall be

temporarily halted if wind speeds exceed 15 miles per hour during work activities

that generate dust.

Respiratory Protection

A. Respirators will be used during:

1. the removal of asbestos or presumed asbestos-containing materials,

2. Class II work where an asbestos-containing material is not removed

substantially intact,

3. Class II and III work without a negative exposure assessment,

4. Class III jobs where asbestos-containing or presumed asbestos-containing

material is cut, abraded, or broken, and

5. Class IV work within a regulated area where respirators are required.

B. CONTRACTOR will provide respirators at no cost to employees, selecting the

appropriate type from among those approved by the National Institute of

Occupational Safety and Health (NIOSH) Administration.

C. CONTRACTOR will provide half-mask purifying respirators--other than disposable

respirators--equipped with high-efficiency filters for Class II and III asbestos jobs

without a negative exposure assessment and for Class III jobs where work

disturbs asbestos-containing or presumed asbestos-containing materials.

D. If a particular job is not covered above and exposures are above the PEL or STEL,

the asbestos standard, 29 CFR 1926.1101 contains a table specifying types of

respirators CONTRACTOR will use.

E. CONTRACTOR institutes a respiratory program in accordance with Respiratory

Protection, 29 CFR 1910.134. CONTRACTOR will permit employees using filter

respirators to change the filter elements when breathing resistance increases;

CONTRACTOR will maintain an adequate supply of filters for this purpose.

CONTRACTOR will permit employees wearing respirators to leave work areas

through the shower decontamination facility (DF) to wash their faces and

respirator face pieces as necessary to prevent skin irritation.

F. CONTRACTOR will ensure that the respirators issued have the least possible face

piece leakage and fit properly. For employees wearing negative-pressure

respirators, CONTRACTOR will perform either quantitative or qualitative face fit

tests with the initial fitting and at least every 12 months following or if a worker’s


March 2019

physical condition changes (weight loss/gain). The qualitative fit tests can be

used only for fit testing of half-mask respirators where they are permitted or for

full face piece air-purifying respirators where they are worn at levels where half

face piece air-purifying respirators are permitted. CONTRACTOR will conduct

qualitative and quantitative fit tests in accordance with Occupational Exposure to

Asbestos (29 CFR 1926.1001, Appendix C) and use the tests to select face pieces

that provide the required protection.

G. CONTRACTOR will not assign any employee, based on the most recent physical

exam and the examining physician’s recommendations would be unable to

function normally, to tasks requiring respirator use.

Protective Clothing

A. CONTRACTOR will provide and require the use of protective clothing in

accordance with asbestos regulations and OSHA regulations (as applicable to

work being performed), such as suits/coveralls or similar whole-body safety

clothing, head coverings, respirators (per appropriate Class of work being

performed), safety gloves, and foot coverings for:

1. employees exposed to airborne asbestos exceeding the PEL or STEL;

2. work without a negative exposure assessment; and

3. any employee performing Class I and Class II work involving the removal

of over 160 square feet/260 linear feet of asbestos-containing or

presumed asbestos-containing materials.

B. The “competent person” will examine employee work suits at least once per work

shift for rips or tears. Rips or tears found while the employee is working must be

mended or replaced immediately.

Hygiene Facilities

Decontamination is required for Class I and II asbestos work with a negative exposure

assessment above OSHA requirements, and where exposures exceed the PEL specific to

work practices being performed. CONTRACTOR will establish a three-chamber DF

connected to the regulated work areas for the decontamination of employees and their

equipment. All equipment and the surfaces of containers filled with asbestos-containing

materials will be cleaned prior to removal. CONTRACTOR will ensure employees enter

and exit the regulated areas through the equipment area.


March 2019

Smoking

CONTRACTOR will ensure that no employees smoke performing any class of asbestos

work, or within the regulated area.

MILONE & MACBROOM, INC.

Ryan Rouillard

State of Connecticut Department of Health Asbestos Project Designer

License Number AD062001

attachment 5 asbestos abatement alternative work … · 2019-06-19 · 10-foot wide (from the...

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