Asbestos 3-Year Re-inspection Report and Updated Management

Asbestos 3-Year Re-inspection Report and Updated Management
Asbestos 3-Year Re-inspection Report and Updated Management Plan
Lowell High School - Freshman Academy
40 Paige Street
Lowell, Massachusetts, 01852
Prepared by:
Cardno ATC
600 West Cummings Park, Suite 5450
Woburn, Massachusetts 01801
September 4, 2014
Cardno ATC Project No. 060.30634.0036
600 West Cummings Park, Suite 5450
Woburn, Massachusetts 01801-6350
www.cardno.com
781.932.9400
Fax 781.932.6211
September 4, 2014
To Whom it May Concern,
Cardno ATC was contracted by the Lowell Public School District located in Lowell, Massachusetts to perform the
asbestos three-year AHERA re-inspection and provide this updated Management Plan for Lowell High School Freshman Academy. The asbestos re-inspection and management plan update was performed in compliance with
the AHERA Final Rule and Notice (40 CFR Part 763, Subpart E).
The enclosed asbestos re-inspection and updated management plan was completed in May and June 2014 by
Cardno ATC Commonwealth of Massachusetts Department of Labor Standards (DLS) certified Asbestos Inspector
Michael Tiernan, and Cardno ATC DLS certified Asbestos Management Planner J. Brendan Phelan. Copies of the
appropriate licenses and certification are included in Section 11.0 of this report.
_________________________________
Michael Tiernan, DLS License No. AI-073158
Project Manager
__________________________________
J. Brendan Phelan, DLS License No. AP-900428
Senior Project Manager
TABLE OF CONTENTS
1.0
REVIEW OF EXISTING PAPERWORK/RECORD KEEPING ........................................................ 1
2.0
2014-2015 RESPONSE ACTIONS PRIORITY LIST ....................................................................... 2
MANAGEMENT PLAN OPERATION COST ESTIMATE ........................................................................................ 2
3.0
AHERA INSPECTION REPORT ..................................................................................................... 3
AHERA TERMS, ABBREVIATIONS, AND ACRONYMS....................................................................................... 3
STATEMENT OF COMPLIANCE ....................................................................................................................... 4
CONSULTANT ACCREDITATION ..................................................................................................................... 5
ASBESTOS RE-INSPECTION INFORMATION .................................................................................................... 6
BULK SAMPLE ANALYSIS.............................................................................................................................. 9
4.0
LOCAL EDUCATION AGENCY (LEA) ......................................................................................... 10
LEA RESPONSIBILITIES ............................................................................................................................. 10
RECOMMENDATION TO LEA ....................................................................................................................... 12
5.0
PUBLIC NOTIFICATION ............................................................................................................... 13
OCCUPANT NOTIFICATION ......................................................................................................................... 13
PLAN FOR NOTIFICATION ........................................................................................................................... 13
ACBM LOCATIONS.................................................................................................................................... 14
ASBESTOS ACTIVITIES ............................................................................................................................... 14
6.0
ASBESTOS-CONTAINING MATERIALS RESPONSE ACTIONS ............................................... 16
RESPONSE ACTION DETERMINATION SUMMARY .......................................................................................... 16
RESPONSE ACTION DESCRIPTIONS ............................................................................................................ 16
RESPONSE ACTION RECOMMENDATION / IMPLEMENTATION ......................................................................... 17
RISK ASSESSMENT AND ASBESTOS CONTROL ............................................................................................ 18
SUMMARY TABLE OF ACBM ...................................................................................................................... 19
AHERA MATERIAL/CONDITION ASSESSMENT KEY FOR FUNCTIONAL SPACES .............................................. 20
METHOD OF RESPONSE ACTION DETERMINATION FOR SURFACING AND MISCELLANEOUS ACM .................... 20
METHOD OF RESPONSE ACTION DETERMINATION FOR THERMAL SYSTEM INSULATION (TSI) ACM ................ 21
7.0
RESPONSE ACTION DETERMINATION SUMMARY ................................................................. 23
INTRODUCTION .......................................................................................................................................... 23
LEA RESPONSIBILITIES ............................................................................................................................. 23
TRAINING REQUIREMENTS AND W ORKER PROTECTION ............................................................................... 25
PERIODIC SURVEILLANCE & RE- INSPECTION .............................................................................................. 25
W ARNING SIGNS ....................................................................................................................................... 26
PREVENTIVE MEASURES............................................................................................................................ 26
CLEANING ................................................................................................................................................. 27
ACM W ASTE ............................................................................................................................................ 27
8.0
SAFE WORK PRACTICES & PROCEDURES FOR ASBESTOS-CONTAINING MATERIALS . 29
INTRODUCTION .......................................................................................................................................... 29
EQUIPMENT .............................................................................................................................................. 29
MINI-ENCLOSURE OPERATIONS ................................................................................................................. 31
ASBESTOS-DEBRIS CLEAN UP PROCEDURES .............................................................................................. 32
ASBESTOS EMERGENCY PROCEDURES ...................................................................................................... 34
HEPA VACUUM ........................................................................................................................................ 34
9.0
RECORDKEEPING ....................................................................................................................... 36
SUMMARY ................................................................................................................................................. 36
10.0
FORMS .......................................................................................................................................... 37
SAMPLE RECORD FORMS .......................................................................................................................... 37
11.0
MISCELLANEOUS DOCUMENTATION ....................................................................................... 50
2014 AHERA Re-inspection
and Updated Management Plan
1.0
Lowell High School - Freshman Academy
Lowell, Massachusetts
REVIEW OF EXISTING PAPERWORK/RECORD KEEPING
Each Local Education Agency (LEA) must keep an updated copy of the management plan in its
administrative office for each school under its administrative control or direction. The plan must
be available without restriction to the public school personnel and their representatives, parents,
and representatives of United States Environmental Protection Agency (EPA) and the
Commonwealth of Massachusetts for inspection during normal business hours.
Section 763.94 (Record-keeping) of the AHERA Final Rule (40 CFR Part 763, Subpart E)
requires that the following paperwork be obtained for each response action and fiber release
episode (commonly referred to as asbestos abatement activities)
•
•
•
•
•
copies of all personnel accreditation’s and licenses (40 CFR 763.94(b)(1), 763.94(g)
and 763.94(h))
copy of the company's (Abatement Contractor) license, (40 CFR 763.94(b)(1) and
763.94(g))
copies of any required notifications,
copies of disposal receipts, (40 CFR 763.94(b)(1), 763.94(g) and 763.94(h)), and
records of the particulars of the job as to activity, location, and personnel used with
their signatures, where applicable (40 CFR 763.94(b)(1), 763.94(g) and 763.94(h)).
Review of Response Action Records and Other AHERA Documentation:
Response Actions Completed by In-House Staff:
No information available for review.
Response Actions Completed by Independent Abatement Contractors:
No information available for review; any in-house records.
Six-Month Periodic Surveillance:
No information available for review.
Annual Notifications:
No information available for review; TBD with District.
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Lowell High School - Freshman Academy
Lowell, Massachusetts
2014-2015 RESPONSE ACTIONS PRIORITY LIST
There are no high priority response items based on the 2014 re-inspection.
All identified ACBM and suspect materials assumed to be ACBM should be maintained in
accordance with the school’s AHERA Management Plan. However, please note that in 2014 reinspection, none of the previously identified ACBM were observed. Based on our review of the
prior re-inspection reports and our 2014 re-inspection of the campus, all of the previously
identified ACBM appear to have been removed.
MANAGEMENT PLAN OPERATION COST ESTIMATE
3-Year Operation and Maintenance
3-Year AHERA Re-Inspection and Management Plan Update
Training, Equipment, and Periodic Surveillance
$1,000.00
$2,000.00
Total estimated cost for Management Plan Operation
$3,000.00
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Lowell High School - Freshman Academy
Lowell, Massachusetts
AHERA INSPECTION REPORT
AHERA TERMS, ABBREVIATIONS, AND ACRONYMS
AHERA
Asbestos Hazard Emergency Response Act
Rule
40 CFR Part 763 Subpart E – Asbestos-Containing Materials
in Schools Rule, including Appendices A, B, C, and D
Section
Sections 763.80 - 763.99 in the Rule
LEA
The Schools' Local Education Agency (as defined in the Rule)
Plan
The AHERA Management Plan for the School
Part
Subsections of the Plan
EPA
Environmental Protection Agency
OSHA
Occupational Safety and Health Administration
NESHAPS
National Emission Standards for Hazardous Air Pollutants
ACBM
Asbestos-containing Building Material (as defined in the Rule)
ACM
Asbestos-containing Material
Non-ACM
Non-Asbestos-containing Material
S No.
Bulk Sample Number
F
Friable
NF
Non-friable
HA
Homogeneous Area
FS
Functional Space
O&M
Operation and Maintenance Program
MIS
Miscellaneous Building Material (as defined in the Rule)
CT
Ceiling Tile
FT
Floor Tile
FBGL
Fiberglass
TSI
Thermal Systems Insulation (as defined in the Rule)
SURF
Surfacing Materials
HVAC
Heating, Ventilation, Air Conditioning System
N/A
Not Applicable
MA DLS
Massachusetts Department of Labor Standards
(Formerly DOS – Division of Occupational Safety)
Other relevant terms, abbreviations, and acronyms may be found within regulations included in
the Appendices.
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Lowell, Massachusetts
STATEMENT OF COMPLIANCE
AHERA REINSPECTION REPORT FOR MANAGEMENT PLAN
LOWELL HIGH SCHOOL – FRESHMAN ACADEMY
40 PAIGE STREET
LOWELL, MASSACHUSETTS
This school was inspected in order to comply with the Asbestos Hazard Emergency Response
Act (AHERA), signed into law by President Reagan in 1986. This AHERA Re-inspection Report
is based on the re-inspection and condition assessment of previously identified asbestoscontaining materials. The re-inspection conducted by the Cardno ATC accredited Asbestos
Inspector.
Asbestos-containing materials were classified according to guidelines in the AHERA
regulations. Based on a material’s asbestos content, and the condition, location, and hazard
potential of the material that was sampled, Cardno ATC's accredited Asbestos Management
Planner recommended a response action if deemed necessary or the material should be
maintained in good condition in accordance with the existing AHERA Management Plan.
Requirements of the Asbestos Hazard Emergency Response Act, Subpart E (Asbestoscontaining Materials in Schools) were complied with for the purpose of this Re-inspection
Report.
The following Consultant Accreditation Page identifies the inspectors and management planners
who contributed to the Plan. Also provided are the certificate numbers, signatures, and date of
signature of each.
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Lowell, Massachusetts
CONSULTANT ACCREDITATION
CARDNO ATC
Woburn, Massachusetts
1.
ACCREDITED ASBESTOS INSPECTOR
Name
MA DLS Accreditation Number
Date
Michael Tiernan
AI-073158
(Exp. Date 02/18/15)
August 25, 2014
Signature
2.
ACCREDITED ASBESTOS MANAGEMENT PLANNER
Name
MA DLS Accreditation Number
Date
John Brendan Phelan
AP-900428
(Exp. Date 09/18/14)
August 25, 2014
Signature
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2014 AHERA Re-inspection
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Lowell High School - Freshman Academy
Lowell, Massachusetts
ASBESTOS RE-INSPECTION INFORMATION
1
GENERAL
"Asbestos" is the term used to describe certain fibrous silicate minerals that were formerly
widely used for insulating, construction, and other purposes. Asbestos fibers were used
throughout the construction industry due to their properties of non-flammability, high tensile
strength, and low heat conductance. In the northeastern United States, the most commonly
encountered types of asbestos are "chrysotile" and "amosite". Other types of asbestos are
found in a wide variety of construction materials.
Asbestos poses a health hazard when very small asbestos fibers, approximately five
micrometers in length, are released into the air and inhaled into the lungs. Once in the
lungs these fibers can either be expelled or become trapped. If they become trapped the
body cannot break the fibers down, and the lungs try to encase the foreign material with
tissue. This process can cause scarring of the lung tissue that may ultimately result in
impaired lung elasticity and subsequent chronic dysfunction. This disease is called
asbestosis.
Asbestos diseases may manifest in other forms that are equally dangerous, such as
mesothelioma, a form of cancer. The latency period of these diseases has been determined
by medical professionals to be anywhere between ten and thirty years following exposure.
For additional information regarding the health hazards of asbestos, consult Health Hazards
of Asbestos, U.S. Department of Labor, Occupational Safety and Health Administration
(OSHA 3040), and Guidance for Controlling Friable Asbestos-Containing Materials in
Buildings, U.S. Environmental Protection Agency (EPA 560/5-83-002, March 1983). These
documents are available from the regional office of the U.S. Environmental Protection
Agency, Federal Office Building, 26 Federal Plaza, New York, New York 10007, 212-2642525.
Asbestos-containing building materials (ACBM) can be categorized into two groups: (1)
friable; and (2) non-friable. Friable asbestos-containing material is that which can be
crumbled, pulverized, or reduced to dust or powder using hand pressure. The presence of
friable ACBM creates the need for the most urgent attention, while the presence of nonfriable ACBM should be documented and proper handling procedures established, in order
to avoid allowing the material to deteriorate to a friable and hence potentially hazardous
condition. Non-friable ACBM, as well as friable ACBM, must be assessed periodically to
determine their potential for fiber release. An operation and maintenance program including
preventive measures must be established to prevent disturbance of all asbestos-containing
materials.
Note:
The AHERA Rule differentiates between ACBM and ACM. In the remainder of
this report, all asbestos-containing material, including ACBM, will be referred to by the
acronym "ACM".
2
AHERA CLASSIFICATIONS
AHERA classifies asbestos-containing materials
miscellaneous materials, or surfacing materials.
as
thermal
system
insulation,
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Lowell High School - Freshman Academy
Lowell, Massachusetts
a. Thermal System Insulation (TSI)
The most common asbestos-containing thermal system insulation (TSI) are the
following: (1) aircell, which is an asbestos-containing paper; (2) calcite and
magnesia, which are powdery fibrous silicas; and (3) preformed asbestos lagging or
blocks. These types of TSI were used for many years as the insulation wrapped
around pipes, boilers, ducts, and hot water tanks in order to reduce thermal heat loss
and prevent condensation.
When asbestos-containing insulation and its outer wrapping are in good condition,
there is minimal chance that asbestos fibers will become airborne, provided the
insulation is not disturbed. Insulation that is intact may remain in place as long as its
location and condition are documented, and proper education is provided to
individuals who may potentially disturb the insulation and may thereby cause a fiber
release episode.
If TSI is intact and in good condition, it must be maintained according to an
Operations and Maintenance Program in order to monitor its condition, since the
physical condition of the insulation may change, thereby increasing the potential for
fiber release. If asbestos insulation is frayed, punctured, ripped, water damaged, or
vandalized, a fiber release episode may occur. Whenever a fiber release occurs, the
insulation should be repaired, encapsulated, enclosed, or removed in order to
decrease the potential hazard to both human health and the environment.
b.
Miscellaneous Materials
Floor and ceiling tiles are categorized as miscellaneous interior building materials.
Of the two, ceiling tiles are the most common friable materials. Ceiling tiles may
release asbestos fibers upon the slightest disturbance. Air currents from HVAC
systems may also cause erosion of ceiling tiles and subsequent asbestos fiber
release. Routine maintenance of pipes located above asbestos-containing ceiling
tiles can possibly cause some quantity of fibers to be released due to disturbance of
the tiles. Under normal conditions, non-friable miscellaneous ACM has virtually no
potential for fiber release. However, if these materials are sanded drilled, broken, or
otherwise structurally disturbed, they can release fibers to the air and the
environment.
c.
Surfacing Materials
Acoustical troweled-on-plaster and sprayed-on fireproofing are categorized as
surfacing ACM. Fireproofing insulation was applied as a fluffy coating in order to
provide two to four-hour fire protection, so that structural beams would not warp and
collapse during a fire. Insulation of this type has a high potential to release fibers
into the air upon any physical contact or by the action of air currents. Asbestoscontaining plaster was also used for fireproofing and for acoustical purposes. Nonfriable surfacing ACM that has a low potential for disturbance also presents a low
potential for fiber release.
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Lowell High School - Freshman Academy
Lowell, Massachusetts
RE-INSPECTION METHODOLOGY
This school was re-inspected for ACM by a trained and licensed Cardno ATC Asbestos
Inspector. The re-inspection was conducted in general accordance with 40 CFR Part
763.86 (b)(3) and included the following:
a.
b.
c.
d.
e.
f.
g.
Visually re-inspect and reassess the condition of all friable known or assumed
ACM.
Visually inspect the material that was previously considered non-friable ACM
and touch material to determine whether it has become friable since the last
inspection or re-inspection.
Identify any homogeneous areas with material that has become friable since
the last inspection or re-inspection.
For each homogeneous area of newly friable material that is already
assumed to be ACM, bulk samples may be collected and submitted for
analysis.
Assess the condition of the newly friable material in areas where the samples
are collected and in areas that are assumed to be ACM.
Re-assess the condition of friable known or assumed ACM previously
identified.
Record the following information and submit to the LEA within 30 days of the
re-inspection:
1.
The date of the re-inspection, the name and signature of the person
making the re-inspection, MA license number, and any changes in the
condition of known or assumed ACBM.
2.
The exact locations where samples are collected during the reinspection, a description of the manner use to determine the sample
locations, the name and signature of the person who collected the
samples, and MA license number.
3.
An assessment or re-assessments made of friable material, the name
and signature of the person who made the assessments, and MA
license number.
The ACM and locations that were included in the re-inspection were based upon the
information presented in the AHERA Re-inspection and Updated Management Plan, Lowell
High School - Freshman Academy, Address, Lowell, Massachusetts, prepared by ATC
Associates Inc. and dated October 2011. The 2008 Re-inspection and Updated
Management Plan, also prepared by ATC Associates, Inc., was used as reference for both
the 2011 and 2014 re-inspection report. Please refer to Section 6.0 of this report for reinspection results and current material condition assessment of the identified ACBM.
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Lowell, Massachusetts
BULK SAMPLE ANALYSIS
No inspection or bulk sampling of suspect asbestos-containing materials was conducted as part
of this re-inspection.
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Lowell High School - Freshman Academy
Lowell, Massachusetts
LOCAL EDUCATION AGENCY (LEA)
LEA RESPONSIBILITIES
The following list summarizes the LEA's responsibilities as denoted in the Rule. The complete
text may be found at Section 763.84 of the Rule.
1.
All aspects of the inspection and management plan are carried out in accordance
with the Rule.
2.
Custodial and maintenance staff receives proper training as required by all federal
and state regulations.
3.
Workers and building occupants or their legal guardians are informed at least once
each school year about all asbestos-related activities that are planned or are in
progress.
4.
Short-term workers who may come in contact with asbestos are informed about the
locations of ACM and assumed ACM.
5.
Required warning labels are posted in routine maintenance areas according to
Section 763.95 of the Rule.
6.
Parent, teacher, and employee organizations are notified yearly of the availability of
the Plan. The School maintains a copy of the Plan at the School for inspection per
Section 763.93(g) of the Rule.
7.
Per Section 763.84(g)(1) of the Rule, the LEA shall "Designate a person to ensure
that requirements under this section are properly implemented and ensure that the
designated person receives adequate training as described in Section 763.84 (g)(2)."
8.
"Consider whether any conflict of interest may arise from the interrelationship among
accredited personnel and whether that should influence the selection of accredited
personnel to perform activities under this Subpart." (Section 763.84(h) of the Rule.)
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Lowell, Massachusetts
Confirmation of Designated Person
LEA
Lowell Public Schools
School
Lowell High School – Freshman Academy
Address
40 Paige Street, Lowell, Massachusetts 01852
Telephone
(781) 441-3704
Designated Person
Mr. Brian Curley
Title
Director of Facilities
Address
155 Merrimack Street, Lowell, Massachusetts
Telephone
Office: 978-674-2016 and Cell 978-423-0953
_______
QUALIFICATIONS
Training
_
Training Facility
Town, State
Certificate Number
Hours of Training
Date of Course
ASSURANCE OF RESPONSIBILITIES ASSUMED
As the AHERA Designated Person, I shall assume responsibility to ensure that the LEA's
duties are carried out as described in 40 CFR 763, Subpart E.
Date
Signature of Designated Person
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Lowell, Massachusetts
RECOMMENDATION TO LEA
There is an increasing number of regulations regarding the handling, removal, transportation,
and disposal of asbestos-containing materials. The LEA must be kept informed of and perform
all response actions and other asbestos-related activities, in accordance with all federal, state,
and local regulations regarding asbestos. In addition to AHERA 40 CFR Part 763 Subpart E,
these regulations include, but are not limited to: 453 CMR 6.00 (Massachusetts DLS); 29 CFR
1926.1101 and 29 CFR 1910.134 (OSHA); 40 CFR Part 763, Subpart G (EPA Worker
Protection); 40 CFR Part 61, Subpart M (NESHAPS); 310 CMR 7.15 (Massachusetts DEP); 49
CFR Part 100-177 (DOT); and all amendments and mandatory appendices and regulations
cited within these regulations.
The regulations are meant to protect the health and safety of those working with and around
asbestos, as well as building occupants. Given the LEA's responsibility to protect both human
health and the environment of the school building's occupants, and the high potential liability
associated with asbestos remediation projects, the LEA MUST ENSURE that the interests of the
building's occupants are protected.
All response actions other than small-scale, short duration activities must be designed and
conducted by persons accredited and licensed to conduct such activities. Design specifications
should be sufficiently explicit to avoid conflicts or confusion that may arise concerning the scope
of work and required procedures. It is recommended that the LEA contract a Massachusetts
certified and licensed Asbestos Abatement Project Monitor to help ensure that projects are
carried out safely, thoroughly, and in compliance with all applicable laws and regulations. Areas
adjacent to the project should be sufficiently monitored throughout the project to provide clear
documentation of project integrity. Final inspection and air clearance must be achieved as
required in Section 763.90(i) of the Rule before any response action may be considered
successfully completed.
The LEA must consider any conflict of interest that may potentially arise when retaining
accredited designers and contractors to perform asbestos-related activities. Generally it is
recommended that the LEA choose separate accredited entities: one for project design
(including project oversight, clearance visual inspection, and air monitoring); and another to
conduct the asbestos project according to the design. Appendix A of the Rule states that ". . .
air sampling operations must be performed by qualified individuals completely independent of
the abatement contractor".
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Lowell High School - Freshman Academy
Lowell, Massachusetts
PUBLIC NOTIFICATION
OCCUPANT NOTIFICATION
In accordance with Section 763.84(c) of the Rule, the LEA will notify in writing, at least once
yearly, all relevant occupants of the school of all asbestos-related activities that take place at
the school. Relevant occupants include, but are not limited to: building occupants or their legal
guardians; staff, including teaching, administrative, custodial, maintenance, and all other
personnel; all parent, teacher, employee, and administrative organizations; and/or any similar
organizations at the school which serve similar functions.
Asbestos activities include, but are not limited to: inspections; response actions, including
removal, encapsulation, enclosure, repair, and operation and maintenance; and post-response
action activities, including periodic surveillance and reinspection.
In addition, Section
763.93(g)(4) of the Rule requires the LEA to inform occupants at least once per year that the
AHERA Management Plan exists and is available for review in the school's Administration
Office.
In accordance with the aforementioned Sections and Section 763.93(b) of the Rule, the LEA
must maintain a dated copy of all such notifications. The list of relevant groups to be notified
will be added to and updated as necessary and should also be kept on file.
PLAN FOR NOTIFICATION
In accordance with Sections 763.84(c) and Sections 763.93(e)(10) and (g)(4) of the Rule, all
school building occupants will be informed by written notification about all asbestos-related
activities at least once every school year.
Building occupants to be notified include, but are not limited to, all students or their legal
guardians, and all staff members and their committees, representatives, and organizations.
As of January 2013, building occupants at the school include the following:
•
•
•
•
Students
Legal guardians of students
Staff (including teaching, custodian, maintenance,
Administrative, and all other personnel)
The LEA may choose various methods of notification to building occupants. The method of
notification, such as written notification via posted notices at the school, through publications
such as a legal notice in the local newspaper, or by posting the information to the LEA website,
must be documented and details of the new notification methods used must be included in the
Management Plan. Copies of the annual public notice must be included in the Management
Plan.
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Lowell High School - Freshman Academy
Lowell, Massachusetts
ACBM LOCATIONS
According to Section 763.84(d) of the Rule, the LEA must ensure that all short-term workers
who may come in contact with asbestos in the school (e.g., telephone, plumbing, HVAC,
electrical workers, etc.) are provided information regarding the locations of identified or
assumed ACM. In addition, as required by Section 763.92(a)(i)(iii), members of the school's
maintenance and custodial staff must be informed of the locations of ACM identified throughout
each school building in which they work.
Please refer to Section 6.0 of this report for the locations of the previously identified ACBM and
their current material condition assessment.
ASBESTOS ACTIVITIES
Prior to the start of asbestos abatement and/or associated or remediation projects, proper
notifications must be made by the appropriate entities to all applicable federal, state, and local
agencies and authorities. The local Health and Fire Departments are often good places to
begin researching local regulations and notification requirements. Notifications may include but
are not limited to the following.
1.
NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS)
NESHAPS notifications are submitted to the EPA Region I Office per 40 CFR Part 61,
Subpart M. NESHAPS requires notification whenever asbestos is being removed according
to the quantities involved, as follows:
a.
Demolition
10 days notice for any asbestos abatement project. Notification must include friable
and potentially friable ACBM
b.
Renovation
10 days notice for any asbestos abatement project. Notification must include friable
and potentially friable ACBM
2.
MASSACHUSETTS DEPARTMENT OF LABOR STANDARDS (DLS)
The Massachusetts Department of Labor Standards (DLS) must be given proper notice
when any asbestos abatement project or asbestos associated project involving more than
three linear or three square feet is planned. The Commissioner of the DLS must be notified
at least ten days prior to the project start date (postmark or hand delivery), or in the case of
an emergency, within one working day after the project start date (DLS 453 CMR 6.00).
3.
MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP)
The Massachusetts DEP requires proper notification and ten days prior notice (one day prior
notice in the event of emergency) before the start date of any and all asbestos removal
projects (310 CMR 6.00, 7.00, and/or 8.00).
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Lowell High School - Freshman Academy
Lowell, Massachusetts
*Contact the agencies denoted above or refer to the appropriate regulations for further
information requiring proper notification procedures and guidelines.
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Lowell High School - Freshman Academy
Lowell, Massachusetts
ASBESTOS-CONTAINING MATERIALS RESPONSE ACTIONS
RESPONSE ACTION DETERMINATION SUMMARY
Response Action Determinations were made by using the EPA recommended method to
determine the risk to human health associated with exposure to asbestos within a given ACM
category. Appropriate response actions that are consistent with applicable regulations and
protect human health and the environment are then recommended in order to best respond to
and/or control ACM.
RESPONSE ACTION DESCRIPTIONS
Future building uses and planned renovations all should be taken into consideration when the
LEA must choose among the alternative response actions recommended, or otherwise
available, for reducing the hazard to human life and the environment posed by the presence of
ACM. Conditions that must be taken into consideration when determining the appropriate
method of treatment for ACM are location, quantity, physical condition, future uses, renovation
or demolition plans, and any social, political, or economic constraints that may apply.
The following is a brief and general description of the Response Actions recommended in the
Plan. The following response actions may only be undertaken in accordance with all applicable
federal, state, and local regulations governing the handling and disposal of asbestos.
Procedural requirements and work practices regarding small-scale, short-duration asbestos
activities may be found in the O&M Section of this Plan. Refer to the Table at the end of Part V
for a complete list of ACM and recommended response actions.
1.
Removal
Although initially the most expensive option, removal is a permanent solution and often the
most cost-effective. Removal means the complete removal and disposal of designated
asbestos-containing material of any kind. If ACM debris is present, the area must be
isolated and the debris cleaned up immediately. Not only are future potential hazards
associated with asbestos-containing materials eliminated, operation and maintenance,
repair, and periodic surveillance and inspection (as required with the options described
above) become unnecessary. Future problems or costs for asbestos control are thus
completely eliminated.
2.
Repair
Repair is generally one of the least expensive forms of treatment. Repair means to restore a
damaged area to its original intact condition. This includes making the damaged area
airtight to prevent the release of fibers into the air. If ACM debris is present, the area must
be isolated and the debris cleaned up immediately. All repaired ACM is incorporated into
the O&M Program and repair activities must be documented in the O&M program to monitor
the future condition of the material and its potential for damage. This method also leaves the
leaves the ACM in the building where it will continue to age and deteriorate.
3.
Encapsulation
Encapsulation is the other least expensive form of treatment. Encapsulation means the
application of a material with a bonding or sealing property to prevent the release of airborne
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fibers. If ACM debris is present, the area must be isolated and the debris cleaned up
immediately.
Encapsulated ACM is incorporated into the O&M Program and the
encapsulation activities must be documented in the O&M program to monitor the future
condition of the material and its potential for damage. This method also leaves the leaves
the ACM in the building where it will continue to age and deteriorate.
4.
Enclosure
Enclosure offers a more expensive but more secure solution for some ACM. Enclosure
means creating an airtight structure around an affected area to prevent the release of
airborne fibers and significantly reduce the possibility of future physical disturbance or
damage to the ACM. Any damaged ACM must be repaired prior to enclosure. If ACM
debris is present the area must be isolated and the debris cleaned up immediately. The
enclosed area is incorporated into the O&M Program. In addition, the NESHAPS legislation
requires that if future plans include activities that would disturb the ACM, the ACM must first
be removed.
5.
Operation & Maintenance (O&M) Program
An O&M program describes a structured plan of action to maintain ACM in a condition that
protects the health and safety of the occupants in a building and provides for remedial action
in the event that ACM is disturbed.
RESPONSE ACTION RECOMMENDATION / IMPLEMENTATION
Regardless of the abatement method chosen, it is important to bear in mind that any
disturbance of friable asbestos-containing material can cause fibers to be released, if proper
procedures and precautions are not observed.
Asbestos abatement workers licensed in Massachusetts must be employed to perform any
large-scale operation (one involving greater than three square or three linear feet of asbestos).
It is recommended that a Massachusetts DLS certified Asbestos Project Monitor be employed to
ensure the safety of employees and building occupants and to ensure that proper work
practices and procedures are followed during all phases of an abatement project. Collection of
samples to determine ambient air fiber levels upon completion of a project is also required.
Final inspection and air clearance must be achieved as required in Section 763.90(i) of the Rule
before any response action may be considered successfully completed.
It is also recommended that ambient air fiber levels be measured before and during a project.
These added precautionary measures greatly increase a school's ability to document and
record pertinent data and thereby reduce its own potential liability.
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RISK ASSESSMENT AND ASBESTOS CONTROL
Actual risk due to asbestos exposure cannot be quantitatively defined, nor can the relationship
between an exposure and its consequential effect be estimated. The only precise quantitative
statement that can be made concerning asbestos is that zero exposure will give zero risk. It is
generally agreed, however, that the greater the exposure, the greater the risk.
The above consideration, combined with the fact that over time, any building material will decay
and eventually most systems will be replaced by newer, more advanced and efficient systems,
is the basis for the recommendation that, whenever possible, exposed friable asbestos be
removed and that any remaining asbestos-containing materials be controlled with an asbestos
O&M Program. Recommended control methods are outlined in the Operation and Maintenance
Program in Part VII. Appendix B of the Rule should be consulted regularly as a guide for
specific work practices to use for jobs that require contact with asbestos in a School. Again,
bear in mind that NESHAPS regulations currently in force require the proper removal of ACM
before any major renovation, repair, or demolition occurs.
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SUMMARY TABLE OF ACBM
Lowell High School - Freshman Academy
Lowell, Massachusetts
Re-inspection Date: April 25, 2014
Material
Flex Joints
Location/
Functional
Space
Penthouse
Quantity
Observed in
2011 3-Year
Re-inspection
3 each
Quantity
Observed in
2014 3-Year
Re-inspection
None
Friable /
NonFriable
N/A
Material/
Condition
Assessment
Code
Comments
Response Action
Recommendation
N/A
Vinyl flex joints (e.g. nonsuspect ACBM) were observed.
No records of abatement were
present in the AHERA
management plan file.
None. Obtain records if
available and file with
AHERA management plan.
NOTES:
Information presented in red and/or strikethrough text indicates changes in condition, quantity, or name change of functional space since the 2011 re-inspection
Material Condition/Assessment Code Definitions: According to the AHERA Regulation, 763.88 Assessment, the following categories are provided to assess the ACBM, suspected
ACBM or assumed ACBM in the school building: (1) damaged or significantly damaged TSI, (2) damaged friable surfacing material, (3) significantly damaged friable surfacing
material, (4) damaged or significantly damaged friable miscellaneous material, (5) ACBM with potential for damage, (6) ACBM with potential for significant damage, (7) any
remaining friable known or suspect ACBM, or (8) damaged or significantly damaged non-friable ACBM (note that this category is not listed in the AHERA regulations but is
provided for reference in this report.)
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AHERA MATERIAL/CONDITION ASSESSMENT KEY FOR FUNCTIONAL SPACES
(AS FOUND IN 40 CFR 763.88(B))
1.
Damaged or significantly damaged TSI.
2.
Damaged friable surfacing material.
3.
Significantly damaged friable surfacing material.
4.
Damaged or significantly damaged friable miscellaneous material.
5.
ACM with potential for damage.
6.
ACM with potential for significant damage.
7.
Any remaining friable known or suspect ACM.
8.
Damaged or significantly damaged non-friable ACMB. Note that this category is not
listed in the AHERA regulations but is provided for reference in this report.
METHOD OF RESPONSE ACTION DETERMINATION FOR SURFACING AND MISCELLANEOUS ACM
1.
Friable Surfacing or Miscellaneous ACM with Significant Damage
Response Action 1: Remove – Isolate the area and clean up debris immediately.
Remove ACM as soon as possible.
2.
Friable Surfacing or Miscellaneous ACM with Damage and High Potential for
Disturbance
Response Action 1: Remove – Isolate area and clean up immediately. Remove
ACM as soon as possible.
3.
Friable Surfacing or Miscellaneous ACM with Damage and Moderate Potential
for Disturbance
Response Action 4: Enclose – Institute preventive measures. Repair ACM to return
to airtight, intact condition, and enclose with an impermeable encasement to prevent
physical disturbance. Continue with O&M.
4.
Friable Surfacing or Miscellaneous ACM with Damage and Low Potential for
Disturbance
Response Action 3: Encapsulate – Institute preventive measures. Repair damaged
material to return to intact condition and encapsulate to reduce the possibility of fiber
release. Continue with O&M.
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5.
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Friable Surfacing or Miscellaneous ACM with No Damage and High Potential
for Damage
Response Action 4: Enclose – Institute preventive measures. Enclose material to
reduce effects of future disturbance. Continue with O&M.
6.
Friable Surfacing or Miscellaneous ACM with No Damage and Moderate
Potential for Damage
Response Action 3: Encapsulate – Institute preventive measures.
material to reduce the possibility of fiber release. Continue with O&M.
7.
Encapsulate
Friable Surfacing or Miscellaneous ACM with No Damage and Low or no
Potential for Damage
Response Action 5: O&M Program – Continue with O&M until condition factors
change, requiring additional response.
8.
Non-Friable Surfacing or Miscellaneous ACM
Response Action 5: O&M Program – Continue with O&M until condition factors
change, requiring additional response.
METHOD OF RESPONSE ACTION DETERMINATION FOR THERMAL SYSTEM INSULATION (TSI) ACM
1.
Significantly Damaged Thermal System Insulation (TSI)
Response Action 1: Remove - Isolate the area and restrict access. ACM debris
should be removed and the area cleaned up immediately.
2.
Damaged Thermal System Insulation with High Potential for Disturbance
Response Action 1: Remove - Institute preventive measures and remove material as
soon as possible.
3.
Damaged Thermal System Insulation with Moderate Potential for Disturbance
Response Action 4: Enclosure - Institute preventive measures. Repair insulation to
airtight condition and enclose with an impermeable encasement to protect against
further physical damage. Continue with O&M.
4.
Damaged Thermal System Insulation with Low Potential for Disturbance
Response Action 2: Repair - Repair to airtight condition and take preventive
measures necessary to eliminate any potential disturbance. Continue with O&M.
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5.
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Undamaged Thermal System Insulation with High Potential for Disturbance
Response Action 1: Remove - Institute preventive measures. Remove to prevent the
high possibility of disturbance to the ACM.
6.
Undamaged
Disturbance
Thermal
System
Insulation
with
Moderate
Potential
for
Response Action 4: Enclose - Institute preventive measures. Enclose the ACM
within an airtight barrier to prevent potential disturbance of ACM. Continue with
O&M.
7.
Undamaged Thermal System Insulation with Low or No Potential for
Disturbance
Response Action 5: O&M - Continue with O&M.
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RESPONSE ACTION DETERMINATION SUMMARY
INTRODUCTION
In compliance with the AHERA Rule, the LEA must establish and implement an Operation,
Maintenance, and Repair (O&M) Program for each school that contains ACM. The purpose of
an O&M program and its required periodic surveillance and re-inspection is to monitor and
control the condition and location of any remaining ACM in the school and to reassess the
potential for hazard to human health and the environment that the ACM poses. The following
summary of Section 763.91 of the Rule highlights the LEA’s responsibilities with respect to O &
M for all ACM that remains in the school.
LEA RESPONSIBILITIES
1.
Establish and implement an Operation, Maintenance, and Repair (O&M) Program
for all material identified or assumed to be ACM, including both friable ACM and nonfriable ACM with the potential to become friable due to activities performed.
2.
Implement the initial cleaning of any areas containing friable ACM or assumed friable
ACM that is present after the inspection has been completed and before response
actions other than O & M takes place.
3.
Cleaning techniques [taken directly from Section 763.91(c)(1) of the Rule] include but
are not limited to:
a.
HEPA-vacuum or steam-clean all carpets.
b.
HEPA-vacuum or wet-clean all other floors and all other horizontal surfaces.
c.
Dispose of all debris, filters, mop heads, and cloths in sealed, leak-tight
containers.
4.
Initiate any additional cleaning recommended in the Plan.
5.
Implement the following procedural techniques (taken directly from Section 763.91(d)
of the Rule) for all O & M activities that involve the disturbance of friable ACM:
a.
Restrict entry into the area by persons other than those necessary to perform
the maintenance project, either by physically isolating the area or by
scheduling.
b.
Post signs to prevent entry by unauthorized persons.
c.
Shut off or temporarily modify the air handling system and restrict other
sources of air movement.
d.
Use work practices or other controls, such as wet methods, protective
clothing, HEPA vacuums, mini-enclosures, and glovebags, as necessary to
inhibit the dispersal of released fibers.
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e.
Clean all fixtures or other components in the immediate work area.
f.
Place asbestos debris and contaminated cleaning materials in a sealed, leaktight container.
6.
Make certain that all response actions involving more than three linear or square feet
of ACM will be designed by a Massachusetts accredited designer, and performed by
Massachusetts accredited contractors and consultants. The Commonwealth of
Massachusetts requires that proper notifications be made as necessary to the
Department of Labor Standards (DLS), the Department of Environmental Protection
(DEP), and/or the U.S. EPA (per NESHAPS).
7.
Ensure that the following procedures (from Section 763.91(f)(1) of the Rule) are
adhered to in the event of a minor fiber release episode or the falling or dislodging of
three linear or square feet or less of friable ACM:
8.
a.
Thoroughly saturate the debris using wet methods.
b.
Clean the area as described in Section 763.91(c) of the Rule.
c.
Place the asbestos debris in a sealed, leak-tight container.
d.
Repair the area of damaged ACM with materials such as asbestos-free
spackling, plaster, cement, or insulation, or seal with latex paint or other
encapsulant, or immediately have the appropriate response action
implemented as required by Section 763.90 of the Rule.
Make certain that the following procedures (taken directly from Section 763.91(f)(2)
of the Rule) are adhered to in the event of a major fiber release episode or the falling
or dislodging of more than three linear or square feet of friable ACM:
a.
Restrict entry into the area and post signs to prevent entry by persons other
than those necessary to perform the response action.
b.
Shut off or temporarily modify the air-handling system to prevent the
distribution of fibers to other areas in the building.
c.
The response action for any major fiber release episode must be designed by
persons accredited to conduct response actions.
9.
Post warning labels immediately adjacent to all ACM or assumed ACM located in
routine maintenance areas as described in Section 763.95 of the Rule.
10.
Make certain the designated person and custodial and maintenance staff are
properly trained in accordance with the Rule and all other applicable federal, state,
and local regulations. Staff members who may disturb ACM must receive sixteen
hours of training. Members of the building's maintenance or engineering staff or
outside contractors (plumbers, electricians, installers, etc.) who may be required to
handle or disturb ACM are required by the Massachusetts DLS to be trained by a
state-certified training provider regarding proper handling procedures for asbestos.
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11.
Once the Plan is in effect, the LEA must implement periodic surveillance of all
remaining ACM in the facility for changing condition and hazard assessment every
six months after the Plan is in effect. Staff members who have completed the
aforementioned sixteen-hour training can perform this.
12.
Make certain that re-inspection of all remaining ACM is conducted by an accredited
asbestos inspector every three years while ACM remains in the school in accordance
with Section 763.85(b) of the Rule.
13.
Make certain that all short-term workers (generally outside contractors) are provided
with information regarding the locations of ACM and assumed ACM, per Section
763.84(d) of the Rule.
TRAINING REQUIREMENTS AND WORKER PROTECTION
In compliance with Section 763.92(a) of the Rule, all maintenance and custodial staff must
receive at least two hours of asbestos awareness training prior to the implementation of the O &
M Program described in this Plan. Lowell High School - Freshman Academy maintenance
personnel training certificates should be attached in Section 11.0.
New staff personnel must similarly be trained within sixty days of commencement of
employment. In addition, personnel who will conduct activities that may result in the disturbance
of ACM must receive an additional fourteen hours of training, as required by the Rule.
As described in Section 763.92(a) of the Rule, awareness training must include information
regarding: the forms and uses of asbestos; the health effects associated with asbestos
exposure; the locations of ACM identified throughout the school; how to recognize damage,
deterioration, and delamination of ACM; the name and telephone number of the person
designated by the LEA; and the availability and location of the Plan.
As described in Section 763.91(b) of the Rule, all LEA employees who perform O & M and
repair activities involving ACM and who are not covered by OSHA 29 CFR 1926.1101, or are
approved by Section 19 of the Occupational Safety and Health Act, are extended worker
protection provided by the EPA at 40 CFR 763.121. According to the EPA's "AHERA Fact
Sheet", the LEA may choose to institute the provisions of Appendix B of the Rule in the case of
small-scale, short-duration projects rather than comply with the full EPA Worker Protection Rule.
PERIODIC SURVEILLANCE & RE- INSPECTION
The LEA must conduct a periodic surveillance in each building every six months after the Plan is
in effect. An assigned person trained in accordance with Section 763.92(a) of the Rule shall
visually inspect all areas that are identified in the Plan as ACM or assumed ACM, record the
date of the surveillance, his or her name, any changes in the condition of the materials, and
submit to the Designated Person a copy of such record to be included in the Plan, in
accordance with Section 763.92(b) of the Rule.
At least once every three years after the plan is in effect, the school must conduct a reinspection of all friable and non-friable, assumed and identified ACM. The re-inspection must
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be conducted by a Massachusetts accredited inspector and performed in accordance with
Section 763.85(b) of the Rule.
Once the Plan has been approved by the Governor's Designee, the Plan is considered to be "in
effect", so that the first periodic surveillance will have to occur before the expiration of six
months from the "effective date." Likewise, the first re-inspection will have to take place within
three years of the effective date.
It is recommended that the effective date and appropriate periodic surveillance and reinspection dates be entered into the Plan in tabular form and also be posted to serve as a
frequent schedule reminder.
WARNING SIGNS
In accordance with Section 763.95 of the Rule, the LEA is responsible to prominently place
warning signs immediately adjacent to all identified or assumed, friable and non-friable ACBM
that is located in all routine maintenance areas in the School.
Based on our re-inspection of the campus, the previously identified and assumed, friable and
non-friable ACBM appear to have been removed from the routine maintenance areas in the
School
PREVENTIVE MEASURES
Preventive measures include any action or actions taken in order to eliminate or reduce the
possibility of disturbing ACM. All preventive measures taken must be properly recorded
according to Section 763.94(b) of the Rule. Examples of precautions to take include the
following:
1.
Do not cut, sand, drill, break, nail into, or otherwise disturb ACM or create dust.
2.
Avoid contact damage to any ACM. Remove any adjacent items that may contact
ACM.
3.
Keep suspended ceiling tiles in place wherever any ACM exists above them. Do not
remove or displace ceiling tiles without taking the proper precautionary measures
outlined in 'ACM Above Ceilings', in Part VII below.
4.
Do not hang fixtures, wires, etc. from ACM.
5.
Prevent water damage to ACM.
6.
Do not disturb asbestos-containing materials when replacing lights, etc.
7.
Do not allow doors or dividers to rub against ACM.
8.
Isolate, redirect, or eliminate direct airflow onto any friable or damaged ACM.
Note: Always take proper precautions when working around ACM. Report any damaged ACM
to the Designated Person IMMEDIATELY.
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CLEANING
1.
INITIAL CLEANING
Areas of the school where identified and assumed friable ACM and damaged or significantly
damaged Thermal System Insulation ACM are present are required according to Section
763.91(c)(1) of the Rule to be cleaned at least once after the completion of the inspection
and before the initiation of any response actions other than O & M.
2.
ADDITIONAL CLEANING
In addition to initial cleaning and that which is required after any fiber release episode, the
LEA is required to perform additional cleaning according to Section 763.91(c)(2) of the Rule.
According to Section 763.91(c)(1) of the Rule, additional cleaning recommendations include,
but are not limited to, cleaning all proximate surfaces of the areas previously identified:
a.
Areas containing ACM where a suspect film or dust occurs.
b.
Anytime any friable or non-friable ACM becomes damaged or significantly
damaged.
c.
Anytime the LEA's Designated Person determines cleaning is necessary to
protect the health and environment of the building occupants.
It is important that all cleaning be completed prior to the initiation of other response actions
that may be necessary. The initial cleaning will prevent or greatly reduce the possibility of
further contamination within an affected area as well as surrounding areas, and reduce the
possibility of exposure to school workers and all other building occupants.
ACM WASTE
Waste generated from asbestos projects must be properly stored and disposed. A minimum of
a half-face negative pressure respirator and disposable clothing, with a hood and booties, are
required when handling asbestos-containing materials. The following procedures must be
implemented when handling asbestos-containing waste:
1.
All waste must be placed in either sealed barrels or two six-mil polyethylene disposal
bags. All waste containers must have two labels as required by both OSHA and the
U.S. Department of Transportation (DOT). The labels are worded as follows:
OSHA Label:
DANGER
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
CANCER AND LUNG DISEASE HAZARD
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DOT Label:
RQ HAZARDOUSSUBSTANCE,
SOLID, NOS
ORM-E, NA 9188
(ASBESTOS)
2.
Waste must be adequately wet. Once the debris is in the barrel or disposal bag,
sufficient water must be added so that there is a noticeable amount.
3.
Disposal bags must be sealed to reduce airspace and make them leak-tight.
Twisting and sealing with duct tape is one method to prevent leaks at the opening of
the bag. All waste must be double-bagged and sealed. In the case of a glovebag,
the use of one labeled bag around the glovebag is considered double-bagging. If the
second bag is used to dispose of other contaminated waste and water, a third
labeled bag must then be properly sealed around both.
4.
Place the bags into a drum or other rigid container equipped with secure or locking
ring lids and label with the same information described above.
5.
The drums or container must be secured in a temporary storage area previously
identified at your facility. This should be an area with limited access and preferably
with a locked entry door.
6.
Record the date and amount of waste placed in the temporary storage area. A log
sheet should be established for this purpose.
7.
Keep the temporary storage area clean by using good work practices. If any bags of
waste break, clean the area using the 'Asbestos Debris Cleanup Procedures' in Part
VII, and in compliance with all applicable regulations.
8.
Before the temporary storage area is full or the expiration of the maximum allowable
storage date, make arrangements to have the asbestos waste picked up and
delivered to an approved asbestos waste disposal site.
9.
Make advance arrangements with the waste disposal facility to ensure that your
waste will be accepted.
10.
Arrange to have the asbestos waste delivered safely to the previously identified
disposal facility.
11.
Receipts from both the transporter and landfill for each shipment of waste must be
kept on file. Record all dates, destinations, and responsible persons involved in
transporting the waste from the temporary storage area to the disposal facility
previously identified in the Plan. For further information concerning storage,
transportation, and disposal of asbestos-containing waste, contact the
Massachusetts DEP.
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SAFE WORK PRACTICES & PROCEDURES FOR ASBESTOS-CONTAINING MATERIALS
INTRODUCTION
The following safe work practices and procedures are minimum requirements and/or
recommended guidelines for working with or around asbestos-containing materials. School
personnel may perform Work involving three linear or square feet or less of ACM and smallscale or short-duration projects provided that they have received the required sixteen-hour
asbestos O&M training.
All school employees who perform small-scale or short-duration projects must be provided with
appropriate personal protective equipment. This equipment includes, at a minimum, half-face
negative-pressure respirators equipped with High Efficiency Particulate Air (HEPA) filters and
full-body Tyvek disposable coveralls or their equivalent. The following procedures are to be
performed only after first donning this minimum personal protective equipment.
Activities which will disturb greater than three linear or three square feet of ACM must be
designed and performed by persons or companies licensed in Massachusetts to perform such
activities. All asbestos activities must be performed in compliance with all applicable federal,
state, and local regulations. Notifications to appropriate agencies are necessary. Isolation of
the affected area is usually required. All asbestos work must also be performed in such a
manner as to minimize the release of asbestos fibers and protect the health and environment of
all building occupants.
EQUIPMENT
In addition to protective equipment such as disposable clothing and respirators, the following
equipment may be necessary to perform work involving asbestos.
1.
DUCT TAPE
Heavy-gauge tape used to seal glove-bags and secure adjacent sheets of polyethylene.
2.
POLYETHYLENE OR PLASTIC SHEETING
Plastic sheeting (6 - mil thick) used to seal off an area in which an asbestos project is taking
place in order to prevent contamination of other areas. Also used to seal waste.
3.
SURFACTANT
A chemical wetting agent added to water that improves the ability of water to penetrate
asbestos-containing material.
4.
DISPOSAL BAGS
Six-mil-thick bags used to dispose of asbestos-containing materials. All bags must be properly
labeled according to OSHA and DOT regulations.
5.
RETRACTABLE UTILITY KNIFE
Used to cut asbestos-containing materials or equipment during removal.
retractable utility knives so as not to risk puncturing glove-bags.
Always use
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GLOVE-BAG
A pre-manufactured polyethylene bag generally used as a containment around asbestoscontaining insulation on pipes or valves so that the insulation may be removed without releasing
asbestos fibers into the ambient air. The glove-bag consists of a 6- to 12-mil-thick polyethylene
bag fitted with long-sleeve gloves, a tool pouch and an opening for a HEPA vacuum hose and
garden sprayer wand. The size, quality, style, and cost vary depending on the manufacturer.
7.
WARNING SIGNS
Warning signs are posted at the entrance to the work area and at a sufficient distance so as to
allow all building occupants adequate forewarning of the occurrence of an asbestos associated
project. The purpose of warning signs is to keep unauthorized personnel away from the work
area. The OSHA warning sign is worded as follows:
DANGER
ASBESTOS
CANCER AND LUNG DISEASE HAZARD
AUTHORIZED PERSONNEL ONLY
RESPIRATORS AND PROTECTIVE
CLOTHING ARE REQUIRED IN THIS AREA
8.
HEPA VACUUM CLEANER
A High Efficiency Particulate Air (HEPA) filtered vacuum cleaner capable of trapping and
retaining 99.97% of all particles larger than 0.3 microns. The HEPA vacuum cleaner is
equipped with an extensive filtering system consisting of primary, secondary, and HEPA filters
which trap fine particles.
9.
RE-WETTABLE FIBERGLASS CLOTH
A canvas-like material impregnated with glue. The cloth is saturated with water and molded
over asbestos-containing pipe and boiler insulation, and hardens as it dries. When completely
dry, it is sealed with latex paint. Because the cloth contains fiberglass, it is best to wear gloves
when handling this material.
10.
GARDEN SPRAYER
A garden sprayer is filled with amended water and is used to wet asbestos-containing material
or to lock down fibers remaining on substrate from which asbestos-containing material has been
removed. When performing the glove-bag technique, a garden sprayer with a 2-3 gallon
capacity is sufficient. It is best to have a hose at least six feet long. If the hose is not sufficiently
long, it can be replaced or extended with flexible tubing.
11.
ENCAPSULANT
A substance applied to asbestos-containing materials that controls the release of asbestos
fibers. Encapsulant is applied over re-wettable fiberglass cloth, after the cloth has dried. Latex
paint is suitable for this purpose. Be sure the encapsulant chosen has a fire rating appropriate
to the area where it is used.
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12.
Lowell High School - Freshman Academy
Lowell, Massachusetts
SPRAY BOTTLE
A spray bottle filled with water is used to wet any suspect debris.
13.
SMOKE TUBES AND ASPIRATOR BULB
Used to test glove-bags for leaks and for respirator fit-testing.
14.
RE-SEALABLE STORAGE BAGS
If repairs to pipe insulation are completed using the glove-bag technique, the patching material
(i.e., re-wettable fiberglass cloth) must remain free of asbestos contamination. Placing the
material inside a storage bag will prevent contamination.
15.
RAGS, NYLON BRISTLE SCRUB BRUSHES (OR SCRUB PADS)
These items are used to clean the surface of a pipe or valve once asbestos-containing
insulation has been removed. The scrub brush or pad are particularly useful when removing
debris from threading. These items cannot be decontaminated and must be discarded as
asbestos waste.
16.
PATCHING COMPOUND (OR CEMENT)
Used to fill in cracks or holes in pipe or boiler insulation.
17.
STAPLE GUN AND STAPLES
Used to temporarily secure polyethylene sheeting and glove-bags.
18.
BUCKET
Preferably plastic and washable. Do not use wooden buckets. Used to catch asbestos debris
and to wash equipment following use.
MINI-ENCLOSURE OPERATIONS
Any work that would require the use of a mini-enclosure operation must be performed by a
Commonwealth of Massachusetts DLS licensed Asbestos Abatement Contractor and these
general procedures are provided for informational purposes as part of this updated
management plan for Lowell High School - Freshman Academy.
1.
Persons not immediately involved in asbestos-related activities are to be excluded
from the work area. Use physical barriers where necessary to limit access to the
work area for the duration of the work.
2.
Construct airtight barriers to prevent the release of asbestos fibers. Where feasible,
glove-bags are permitted in place of barriers to remove insulation on pipes and
ducts.
3.
Adequately wet the asbestos before disturbing it. Removed asbestos and asbestoscontaminated items are to be containerized in two six-mil polyethylene bags, or
double-wrapped in six-mil polyethylene sheeting. If the material has sharp edges,
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Lowell High School - Freshman Academy
Lowell, Massachusetts
double-wrap or bag it and then place the material in metal, fiber, or plastic drums that
can be sealed.
4.
Properly repair, enclose, or encapsulate friable asbestos that has been exposed
during asbestos work.
5.
HEPA-vacuum and wet-wipe until there is no visible debris or dust.
6.
Asbestos-containing waste must be containerized, transported, and disposed of at
an approved asbestos landfill in accordance with all applicable regulations.
ASBESTOS-DEBRIS CLEAN UP PROCEDURES
Any debris suspected of containing asbestos found on the floor, on top of ceiling tiles, or other
building structures should be cleaned up immediately. Asbestos debris is extremely friable. Any
suspected debris that is equal to or greater than three linear or square feet must be cleaned up
by a Commonwealth of Massachusetts DLS licensed Asbestos Abatement Contractor according
to a plan designed by an accredited and DLS licensed Asbestos Project Designer.
1.
WHEN ASBESTOS-CONTAINING DEBRIS IS DRY OR DAMP AND SMALL IN SIZE
a.
Asbestos-debris clean up shall be performed after occupied school hours and
must be performed by workers with asbestos training. Workers shall wear
protective clothing and respiratory protection.
b.
Isolate and seal the work area and post warning signs, as required by DLS
453 CMR 6.14.
c.
Thoroughly wet-mop, using a bucket of water, rags and/or mops, all of the
structures and items on which the debris has fallen. Be sure all visible debris
is removed.
d.
Vacuum the floor using a HEPA vacuum. Again, be sure all visible debris is
removed.
e.
When the area is dry, inspect for any visible asbestos debris. Sometimes wet
asbestos debris becomes hidden during the clean-up. If any visible asbestos
material is found, repeat the wet-mop or HEPA-vacuuming procedure until no
visible asbestos debris is observed.
f.
Dispose of the protective clothing, mop heads, and rags into a six-mil
polyethylene disposable bag. Pour the water from the bucket into the
disposal bag also. Twist the top of the polyethylene bag and seal it with duct
tape. Double-bag the waste material with another six-mil polyethylene bag.
Dispose of the bagged asbestos waste according to all applicable
regulations.
g.
Remove respirator, clean, and place in re-sealable storage bag.
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2.
Lowell High School - Freshman Academy
Lowell, Massachusetts
h.
Clean the bucket in a sink, if available, and thoroughly rinse the sink used.
i.
Remove barriers and posted warning signs.
WHEN ASBESTOS DEBRIS IS TOO WET OR TOO LARGE TO BE VACUUMED
a.
This type of work shall be performed after occupied school hours and must
be performed by workers with asbestos training. Workers shall wear
protective clothing and respiratory protection.
b.
Isolate and seal the work area and post warning signs as required by DLS
453 CMR 6.14.
c.
Thoroughly wet the asbestos material and the surrounding area to a distance
of six inches with the garden sprayer. Use a light mist of water when wetting
the area and the material, as a heavy stream of water could dislodge and
disperse asbestos fibers.
d.
If the material is intact and too large to be easily handled with a shovel, pick
up the wet material and place it in a six-mil polyethylene disposable bag.
e.
Scoop up smaller debris with a shovel, dust pan, or garden trowel and place
in a six-mil polyethylene bag. Use another washable item, such as another
garden trowel or ice scraper, to push the material into the shovel, dustpan, or
trowel. DO NOT USE A BROOM OR BRUSH! A broom or brush cannot be
decontaminated and also will increase the possibility of dispersing asbestos
fibers into the air.
f.
Wet-mop the entire area and items that the asbestos material contacted,
using a bucket of water, rags, and mops. If the floor is carpeted, vacuum the
carpet with a HEPA-filtered vacuum cleaner. If the carpet is wet, or the
debris is wet, the carpet must be steam-cleaned. A HEPA-filtered vacuum
cleaner cannot be used to pick up water or wet material unless the vacuum is
designed to do so.
g.
Wash the items used in the cleanup, including hands, shovel, ice scraper,
etc., by holding items over the six-mil disposal bag and washing them
thoroughly with the garden sprayer. Pour the bucket of contaminated water
into the disposal bag.
h.
Place the protective clothing, mop heads, and rags in a six-mil polyethylene
disposable bag and dispose of as contaminated waste. Twist the top of the
polyethylene bag and seal it with duct tape. Double-bag the waste material
with another six-mil polyethylene bag.
i.
Place the respirator in a re-sealable storage bag and take it to a sink to clean.
j.
Clean the respirator, re-clean the bucket, and thoroughly rinse the sink.
Store the respirator after cleaning.
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k.
Lowell High School - Freshman Academy
Lowell, Massachusetts
Remove the barriers and posted warning signs.
ASBESTOS EMERGENCY PROCEDURES
An asbestos emergency situation is one in which there is an unexpected change in the condition
of asbestos-containing material that results in the release of asbestos fibers. This is called an
asbestos fiber release episode. Fiber release episodes have the potential to contaminate the
area and expose the building occupants to asbestos fibers.
The following procedures should be followed in the event of an emergency:
1.
Remove occupants from the immediate area and contact the appropriate building
supervisor and the School's Designated Person.
2.
Isolate the area as described in DLS 453 CMR 6.14.
3.
Trained personnel who will perform the work should wear the appropriate disposable
clothing and respiratory protection.
4.
Vents and ducts leading into or out of the emergency area should be shut down and
sealed with six-mil polyethylene sheeting and duct tape according to DLS 453 CMR
6.14 (2)(a)(2).
5.
If the asbestos debris or material is less than three linear or square feet, continue by
following the "Asbestos Debris Clean-up Procedures" described above. If the
asbestos material is greater than or equal to three square or linear feet, DO NOT
TOUCH OR REMOVE THE ASBESTOS. Contact a Massachusetts licensed asbestos
abatement contractor and a Massachusetts accredited project designer.
HEPA VACUUM
The HEPA vacuum cleaner is the ONLY vacuum cleaner designed to clean asbestos debris.
Using a household or shop vacuum will not only contaminate the vacuum cleaner itself, but will
expose the user and the area to high levels of airborne asbestos dust.
It is important that personnel read and follow manufacturer's directions for proper use and
maintenance of the HEPA vacuum. Some HEPA vacuum cleaners cannot pick up wet
materials. Consult the manufacturer's directions.
CLEANING AND MAINTENANCE
When the inside of the vacuum cleaner needs to be accessed, whether to change a
filter, a bag, or a part, the following procedures must be followed.
1.
Gather the necessary equipment required by this section, including:
a.
b.
Half-face negative pressure respirator
Re-sealable storage bag or similar substitute
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2014 AHERA Re-inspection
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c.
d.
e.
f.
g.
Lowell High School - Freshman Academy
Lowell, Massachusetts
Disposable clothing
Bucket of water
Sponges or rags
Disposal bags
Duct tape
2.
Take the HEPA vacuum cleaner to a location away from non-authorized
personnel.
3.
Put on the half-face negative pressure respirator and disposable clothing.
4.
Perform the necessary maintenance or repair according to the manufacturer's
instruction. Place any of the contaminated, used, or worn parts, bags, and filters
in the six-mil polyethylene disposal bag.
5.
With a damp rag or sponge, clean visible debris from the interior and exterior of
the vacuum cleaner.
6.
Pour the bucket of water into the disposal bag. Thoroughly rinse the bucket and
pour the rinse water into disposal bag.
7.
Place the sponge or rag in the six-mil polyethylene disposal bag, along with the
disposable clothing and any other contaminated items.
8.
Seal the six-mil bag securely with duct tape, making sure there are no leaks in
the bag. Place the used and sealed disposal bag into a second labeled six-mil
polyethylene disposal bag. Twist the top of the bag and seal with duct tape.
9.
Remove, clean, and store respirator.
10.
Store and dispose of the asbestos waste properly.
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9.0
Lowell High School - Freshman Academy
Lowell, Massachusetts
RECORDKEEPING
SUMMARY
Pursuant to requirements specified in the Rule, the LEA is responsible for maintaining adequate
records for all the asbestos activities listed below in two locations: (1) the Local Education
Agency office; and (2) the School Administration’s offices. Refer to Section 763.94 of the Rule
for the specific items required to be recorded for each activity.
It is recommended that the sample forms included in this section be used as a guide from which
the LEA may develop its own forms. If the sample forms are chosen to be used, the LEA must
ensure they provide a record of all of the information required by the Rule and all other
applicable regulations. The guidance forms included within this section in no way supersede or
replace records that may be necessary to comply with any applicable asbestos regulations. The
LEA must take care to remain informed and ensure compliance with all new and existing
regulations and update their methods of recording activity accordingly. This is especially
important as long as any ACM remains in the School and building occupants may come in
contact with or otherwise handle asbestos-containing materials. It is also recommended that
the LEA maintain updated copies of the blank forms it chooses to use in this Record-keeping
section.
The following asbestos activities, projects, and occurrences, and the entities involved in such
projects, are to be recorded as required in Section 763.94 of the Rule. The activities to be
recorded include, but are not limited to:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Preventive Measures
Response Actions
Contractors or Personnel Involved
Air Monitoring and Results
Personnel Training
Periodic Surveillance
Cleaning (per Section 763.91© of the Rule)
Operation and Maintenance (O&M) Activities
Major Asbestos Activities (per Section 763.91(e) of the Rule)
Fiber Release Episodes
Additional records required by OSHA (particularly if negative pressure respirators are used)
include those required for, but are not limited to, medical surveillance and respiratory protection.
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Lowell High School - Freshman Academy
Lowell, Massachusetts
10.0 FORMS
SAMPLE RECORD FORMS
In order to maintain all proper records required, it is essential to establish an organized format
for record keeping. The following record forms and recommended formats are provided as
guidance for creating and maintaining adequate records. The information requested in the
forms should only be viewed as minimum requirements as stated in the Rule. It is important to
be sure that additional records be kept as necessary to fully comply with all applicable
regulations.
Additional record-keeping forms, such as medical surveillance or respiratory protection forms,
may similarly be recorded and continued as necessary. Keep a blank copy of the record forms
used in the Record-keeping section and revise as necessary. Copy several blank forms. Keep
these blanks and completed forms in the Records section.
Project records may be compiled (copied as necessary in the case of repeat records, such as
Worker Training) and grouped together, project by project, in order of occurrence.
.
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FORM A
PERIODIC SURVEILLANCE & RE-INSPECTION SIGNOFF TABLE
SIX-YEAR PLAN
Lowell High School - Freshman Academy, Lowell, MA
Form No. A-
LATEST DATE
SURVEYOR OR INSPECTOR NAME
PROJECT DATE(S)
RECORD FORM NO(S).
SURVEILLANCE: 10/2014
SURVEILLANCE: 04/2015
SURVEILLANCE: 10/2015
SURVEILLANCE: 04/2016
SURVEILLANCE: 10/2016
_______
RE-INSPECTION: 04/2017
SURVEILLANCE: 10/2017
SURVEILLANCE: 04/2018
SURVEILLANCE: 10/2018
SURVEILLANCE: 04/2019
SURVEILLANCE: 10/2019
RE-INSPECTION: 04/2020
(Periodic Surveillance every 6 months thereafter. Re-inspection every 3 years thereafter.)
_______
FORM B
ACTIVITY / PROJECT RECORD
Lowell High School - Freshman Academy, Lowell, MA
Project No.
Form No. B-
Measure or Action:
If Periodic Surveillance or Re-inspection, Record Form No(s).
Start Date:
Completion Date:
ACM Type: Check Appropriate Material Type; see appropriate ACM Table or Summary)
F - Friable
NF - Nonfriable
S - Surfacing
T - Thermal
M - Miscellaneous
A - Other ACM
F/S
NF/S
A/F/S
A/NF/S
A/T
F/M
NF/M
A /F/M
A/NF/M
NF/O
ACM Description:
Homogeneous Area:
Specific Area Location(s):
ACM Location in Area(s):
HVAC Supply:
Air System:
Passive
Shut Down
Was Area Isolated?
Yes
Direct
Isolated
No
Air Movement:
High
Moderate
Not Present
Proper Signs Posted?
Yes
No
Project Description and Methods:
Why was action taken?
Was Project Resultant of a Major Fiber Release Episode (> 3 feet)?
Yes
No
Was Project Resultant of a Minor Fiber Release Episode (< 3 feet )?
Yes
No
Low
FORM B
ACTIVITY / PROJECT RECORD (CONTINUED)
Lowell High School - Freshman Academy, Lowell, MA
Was any ACM Removed?
If YES:
Yes
No
Total Amount
Storage Record Form No.
Disposal Record Form No.
If less than or equal to 3 linear or square feet then:
School Worker Record Form No.
Worker Training Record Form No(s).
Contractor Record Form No(s).
If greater than 3 linear or square feet then:
Design Consultant Record Form No(s).
Air Monitoring Consultant Record Form No(s).
Laboratory Consultant Record Form No(s).
Contractor Record Form No(s).
Does ACM remain in location?
Yes
No
Amount
If YES: Describe additional Preventive Measures:
* Continue with Operations and Maintenance Program.
If NO:
Be sure to update asbestos location blueprint, diagrams, and/or written
description and adjust periodic surveillance forms.
Date of Notification to:
DLS
____
DEP
EPA
Inspection Form No(s).
Name of Competent or Designated Person:
School Worker Record Form No.
Signature:
Date:
Competent or Designated Person
FORM C
SCHOOL WORKER RECORD
Lowell High School - Freshman Academy, Lowell, MA
Form No. C-
Project No.
Project Form No.
Project Date(s)
Designated Person
Worker
Respiratory
Workers'
Protection
Names
No(s).
Date(s) of
Activity
Training
Record Form No(s).
Medical
Surveillance
Record Form No(s).
Record Form
FORM D
DESIGN CONSULTANT RECORD
Lowell High School - Freshman Academy, Lowell, MA
Form No. D-
Project No:
Project Form No.:
Consultant Company Name:
________________
Address:
_____________________________
Telephone:
_______________
Specification Location:
Project Designer Name:
State of Accreditation:
Accreditation Number:
Completion Date Project Designed:
Project Designer Signature:
FORM E
ABATEMENT CONTRACTOR RECORD
Lowell High School - Freshman Academy, Lowell, MA
Form No. EProject No.
Project Form No.
Project Date(s):
Designated Person:
Contractor Name:
Address:
Telephone:
Contractor's State of Accreditation:
Accreditation Number:
Worker
Name
Date
on Site
State of
Accreditation
Accreditation
Number
Day Supervisor/
Foreman
FORM F
AIR MONITORING CONSULTANT RECORD
Lowell High School - Freshman Academy, Lowell, MA
Form No. FProject No.
Project Form No.
Designated Person:
Consultant Company Name:
Address:
Telephone:
Air Sample Collection Date:
Air Sample Collector's Name:
State of Accreditation:
Accreditation Number:
Collectors Signature:
Sample No.
Sample Location
Results
FORM G
LABORATORY RECORD
Lowell High School - Freshman Academy, Lowell, MA
Form No. GProject No.
Project Record Form No.
Project Date(s):
Designated Person:
Consultant Company Name:
Address:
Telephone:
State of Accreditation:
Accreditation Number:
Check if applicable:
This laboratory is accredited by the National Institute
for Standards and Technology to conduct air sample
analysis using Transmission Electron Microscopy (TEM).
This laboratory is enrolled in the EPA-sponsored
Proficiency Analytical Testing Program for Phase
Contrast Microscopy (PCM).
Sample
Number
Result of
Analysis
Method of
Analysis
Date of
Analysis
Name of
Analyst
Signature
Analyst
FORM H
DISPOSAL RECORD
Lowell High School - Freshman Academy, Lowell, MA
Form No. H-
Project No.
Project Date(s):
Designated Person:
Site Name:
Address:
Telephone:
How Material is Containerized:
Material Quantity:
Date Material Transported
for Disposal:
Transporter Name:
Address:
Telephone:
Project Record Form No.
FORM I STORAGE RECORD
Lowell High School - Freshman Academy, Lowell, MA
Form No. I-
Project No.
Project Record Form No.
Project Date(s):
Designated Person:
Storage Site:
Address:
Telephone:
Storage Area at Site:
Material Quantity:
Area Sealed?
How:
Area Secured?
How:
Date Material Transported
for Disposal
FORM J
WORKER TRAINING RECORD
Lowell High School - Freshman Academy, Lowell, MA
Check if Designated Person
Form No. J-
Individual's Name
Individual's Identification No.
Permanent Street Address
Emergency Contact Person
Permanent City, State, Zip Code
Emergency Contact Phone No.
Home Phone No.
Attending Physician
Job Title
Attending Physician's Phone No.
ASBESTOS TRAINING HISTORY
Course
Date
Course Location
Course Title
Training Center
Name
Hours of
Instruction
Certification
Number
THIS INDIVIDUAL IS QUALIFIED TO PERFORM THE FOLLOWING TYPE(S) OF ASBESTOS-RELATED WORK
1)
Restricted to maintenance work which does not involve the
disturbance of asbestos-containing building materials.
Signature
Title
2)
May perform "small-scale, short-duration" work as defined
by the applicable rules and regulations, under proper supervision.
3)
May perform "small-scale, short-duration" work as defined
by the rules and regulations and is qualified to supervise other
workers performing the same type of work.
4)
May perform work in any type of asbestos removal project under
proper supervision.
5)
May perform work on any type of asbestos removal project and is
qualified to supervise others performing the same type of work.
Date
FORM K
GLOVE BAG REMOVAL RECORD
Lowell High School - Freshman Academy, Lowell, MA
Form No. KDate Performed:
Designated Person:
Performed by:
Contractor MA
Certification No.:
DEP Notification No.:
Work Performed:
Worker Name:
Worker Massachusetts
Certification No.:
Waste Landfill:
Waste Transporter:
11.0 MISCELLANEOUS DOCUMENTATION
(Bulk Sample Results, ACM Location Drawings, 6-Month Periodic Surveillance Records, Completed Response Action
Records, Licenses, Employee Training Certificates, etc.)
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