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Initial Asbestos Abatement Work Plan (Revised)

______________________________________________________________________________

Marco Polo Apartments 2333 Kapiolani Boulevard

Honolulu, Hawaii

Prepared for:

Associa On Call Hawaii 737 Bishop Street, Suite 3100

Honolulu, Hawaii 96813

Prepared by:

ENPRO Environmental 151 Hekili Street, Suite 210

Kailua, Hawaii 96734

808.262.0909 (t)

ENPRO Project Number 1707-00424-CSL July 24, 2017

© Copyright ENPRO Environmental 2017

TABLE OF CONTENTS Section Page

1.0 Introduction and Purpose ........................................................................... 1 1.1 Scope of Work .................................................................................................... 1

2.0 Asbestos Abatement ............................................................................................. 2 2.1 Sequence of Work ............................................................................................ 2 2.2 Notification to the Department of Health ................................... 3 2.3 Documents to be retained on-site ........................................................ 3 2.4 Asbestos Abatement Contractor Documentation .................... 4 2.5 Asbestos Abatement Contractor Materials .................................... 6 2.6 Respiratory Protection Requirements ............................................... 7 2.7 Preparation of the Work Area .............................................................. 11 2.8 Containment ..................................................................................................... 12 2.9 Removal and Disposal .................................................................................. 13 2.10 Daily Clean-Up ................................................................................................... 13 2.11 Transportation and Disposal of PACM Waste .............................. 14 2.12 Final Clearance ................................................................................................ 15 2.13 Asbestos Abatement Contractor Final Documentation ...... 15

3.0 Asbestos Air Monitoring and Analysis ............................................. 16 3.1 Area Sampling .................................................................................................... 16 3.2 Personal Sampling .......................................................................................... 17 3.3 Clearance Sampling ....................................................................................... 17 3.4 Sample Analysis ................................................................................................. 18 3.5 Quality Control ............................................................................................ 18 3.6 Review of Analytical results .................................................................. 19 3.7 Contractor’s Responsibilities ................................................................. 19

4.0 Final Clearance Report ................................................................................. 21

5.0 Certified Project Designer ........................................................................... 22

Initial Asbestos Abatement Work Plan 1 Marco Polo Apartments Project ENPRO Project: 1707-00424-CSL Honolulu, Hawaii

1.0 INTRODUCTION AND PURPOSE

Associa On Call Hawaii (the Owner’s representative) retained ENPRO Environmental (ENPRO) to prepare an Asbestos Abatement Work Plan to address the handling and removal of asbestos containing materials (ACM) from severely damaged areas of the Marco Polo Apartments, located at 2333 Kapiolani Boulevard, Hawaii (the project site). This Work Plan is intentionally general to provide Contractors on this project with flexibility to determine the most efficient way to accomplish the scope of work described herein.

Marco Polo Apartments was constructed in 1971 and contains 586 residential units, in

addition to common areas. The subject building was damaged by a fire incident that occurred on July 14, 2017.

The most severely damaged floors are the 26th, 27th and 28th. Because not all of the

common areas and residential units of the building have been surveyed for asbestos containing materials at this time, this work plan addresses remediation of any residential unit where other parties have determined these areas to be a total loss and will require comprehensive remediation, including the abatement of presumed ACM (PACM), and of debris and ash contaminated with PACM.

1.1 Scope of Work

This Work Plan addresses the following areas of importance:

• A sequence of work • Notification to the DOH • Preparation of the work area, including warning signs and construction

barriers, the asbestos work control area, entrances and exits to the work area, decontamination area, ambient air sampling, etc

• ACM handling, removal, disposal, and transportation methods and procedures to be used

• Materials, equipment, and tools, including personal protective equipment (PPE), including respiratory protection, cartridges/filters, and protective clothing

• Decontamination procedures • Air monitoring procedures and protocols • Cleanup and clearance


2.0 ASBESTOS ABATEMENT

2.1 Sequence of Work

A licensed Asbestos Abatement Contractor (Contractor) shall be retained to remove debris and construction building materials from specified residential units and common areas. The Contractor shall determine the best and most efficient method of removal. ENPRO has received (as of July 24, 2017) emergency authorization from the State of Hawaii Department of Health for this work to begin immediately. The asbestos abatement (C-19) contractor shall contact the State of Hawaii Department of Health for proper emergency notification procedures, as described in Section 2.2.

The Owner shall retain a DOH certified Asbestos Project Monitor (PM) who shall inspect the work area and collect area air samples during abatement activities daily. The PM shall be responsible for collecting personal air monitoring 30-minute excursion air samples and 8-hour time weighted average (TWA) air samples from within the breathing zone of 25% of the workers during abatement activities in accordance with Occupational Safety and Health (OSHA) permissible exposure limit (PEL) regulations.

The PM shall also perform a visual clearance inspection and collect area air and

clearance samples from the asbestos abatement work area. The Contractor shall remove the ACM from the work area by bagging the material

and using a HEPA vacuum to prevent asbestos fibers from escaping the bags. The bags shall be sealed and HEPA vacuumed prior to being removed from the work area.

All asbestos abatement workers in the project area shall decontaminate and remove

PPE in a designated decontamination area at the project site. PPE shall be HEPA vacuumed and wet wiped prior to removal as described in Section 2.6. In the event that containment is used, workers shall decontaminate by removing PPE within the decontamination chamber and showering in the Contractor supplied shower stall. Rinse water shall be collected and filtered by the Contractor in accordance with industry standards and state and federal regulations. All disposable PPE shall be properly disposed of as asbestos contaminated waste at an approved waste facility as described in Section 2.13.

Once all ACM has been removed and the analysis of clearance air samples has

confirmed that the work area does not have fiber concentrations above 0.01 fibers per cubic centimeter (f/cc), the work area barriers and signage and/or containment shall be broken down and removed by the Contractor.

The PM shall prepare a Final Clearance Report which shall include all documentation

from the project, including detailed description of the ACM removal, disposal and clearance


documentation, and documentation of area air monitoring and Contractor provided personal air monitoring results.

2.2 Notification to the Department of Health

The Contractor must ensure that proper notification of the proposed abatement project is sent in writing to the DOH Indoor & Radiological Health Branch in accordance with DOH 11-501-7 and 11-504-14. The Contractor shall contact the DOH Indoor & Radiological Health Branch for proper emergency notification procedures in order to obtain an emergency waiver pertaining to the required ten-working day notification.

2.3 Documents to be retained on-site

The following documents shall be retained on-site for the duration of the abatement project, in accordance with DOH 11-504-18:

• A current copy of DOH chapters 501 through 504;

• Documentation of the adequacy of compressed air systems and respiratory protection systems including a list of compatible components and specifications of the types and maximum number of respirators that may be used with the system;

• Copies of the procedures for the use of the decontamination enclosure system or any other procedures which have been established to prevent contamination of areas outside the work area;

• Copies of procedures to be followed during medical emergencies, including phone numbers of the nearest hospital or other emergency facility, which shall be posted by the nearest telephone;

• Copies of certificates held by all abatement workers and abatement contractor/supervisors actively engaged in the abatement project;

• Certification of the project designer who wrote procedures for the job;

• Copies of bulk sampling results, including inspector and laboratory names for all suspect material to be disturbed that is not assumed to be asbestos-containing; and

• Records of all air sampling as required in DOH section 12-145-5.


2.4 Asbestos Abatement Contractor Documentation

The following documentation is required of the Asbestos Abatement Contractor:

• National Emission Standards for Hazardous Air Pollutants (NESHAP) Compliance: Compliance with the requirements of the Environmental Protection Agency (EPA) NESHAP regulation is required. Proper notification to the DOH shall be the Contractor’s responsibility (see Section 2.2 above).

• License (C-19) and Insurance: Proof of Workman’s Compensation and General Liability Insurance, which covers lead, asbestos, and pollution.

• Asbestos Training: Documentation of all the Contractor’s site workers and supervisors, their experience, their title and/or assigned responsibilities during the project, and current asbestos removal training for the Asbestos Abatement Worker and/or Asbestos Contractor Supervisor, whichever is relevant to the worker’s responsibilities.

• Respiratory Protection: Current documentation of training and fit testing for all personnel who will enter the work area wearing negative-pressure respirators.

• Medical Examination/Monitoring: Current clearance of comprehensive medical examinations, including ability to wear a respirator. Complete and sign an Employee Release Form, which shall act as the employee’s acknowledgement that the following medical monitoring by a physician was performed; the employee understands the results of the examination; and is willing and able to work on this project. The Contractor shall ensure and keep on file documentation from a physician that all employees or agents who may be exposed to airborne asbestos have been provided with an opportunity to be medically monitored to determine whether they are physically capable of working while wearing the respirator required without suffering adverse health effects. In addition, document that all individuals permitted within the project site have received medical monitoring or had such monitoring made available to them as required by Occupational Safety and Health administration (OSHA) 29 Code of Federal Regulations (CFR) 1926.1101, Hawaii Occupational Safety and Health (HIOSH) 12-145.1, and DOH 11-504. The Contractor must be aware of and provide information to the examining physician about unusual conditions in the work place environment (e.g. high temperatures, humidity, chemical contaminants) that may impact on the employee’s ability to perform work activities. The Contractor shall keep and make available to all affected individuals a record and the results of such examinations.


• Proposed Disposal Landfill Waste Acceptance: Name, address, telephone number, and type of waste accepted.

• Emergency Response and Evacuation Plan: written program and training.

• Manufacturer’s data: Manufacturer’s specifications, installation instructions, and field test procedures for each material and all equipment related to asbestos handling and abatement and include other data as may be required to show compliance with these specifications and proposed uses. Include (but not limited to) the following:

Personal protective equipment (PPE) including clothing and gloves

Air supply equipment, respirators and cartridges/filters: Certification that air supply equipment and respirators meet all requirements of OSHA and EPA. Submit documentation of National Institute for Occupational Safety and Health (NIOSH) approval of all respiratory protective devices utilized on site. Include manufacturer’s certification of HEPA filtration capabilities for all cartridges and filters.

HEPA vacuums: Manufacturer’s certification that vacuums conform to American National Standards Institute (ANSI) Z9.2-79, Fundamentals Governing the Design and Operation of Local Exhaust Systems, as applicable to this project.

Rental equipment: When rental equipment is to be used in abatement areas or to transport asbestos contaminated waste, a written notification concerning intended use of the rental equipment must be provided to the rental agency.

Decontamination unit system: Manufacturer’s literature and description of water filtration system for all contaminated water. Include the procedure of changing filters and handling and disposal of wastewater.

Water filtration system: Manufacturer’s literature and description of water filtration system for all contaminated water. Include the procedure of changing filters, and handling and disposal of wastewater.

Encapsulant: Manufacturer’s literature including all laboratory data, application instructions, and compatibility with materials.

Surfactant: Manufacturer’s literature including all laboratory data, and mixing and application instructions.

Tapes and adhesives: including all laboratory data.

Warning labels and signs: Examples of all required signage (see appendix).


2.5 Asbestos Abatement Contractor Materials

The following materials are required of the Asbestos Abatement Contractor:

• Respirators and Cartridges/Filters: Use appropriate respirators and cartridges/filters, which meet all applicable requirements.

• Personal Protective Clothing: Use appropriate personal protective clothing (disposable coveralls/suits, boots, gloves, eye protection, etc.) as required by all applicable requirements. The Contractor shall have all the required sets of coveralls required for this project on island prior to the start of work. There will be no time extension for the unavailability of coveralls or related equipment.

• Plastic Sheeting: Minimum thickness 6-mil polyethylene film.

• Plastic Bags: Minimum thickness 6-mil polyethylene film labeled as specified hereinafter.

• Tapes: Tape shall be capable of sealing joints of adjacent sheets of polyethylene and for attaching polyethylene sheets to finished or unfinished surfaces of dissimilar materials and capable of adhering under both dry and wet conditions, including the use of amended water. Silver cloth duct tape, minimum 2 inches wide; red or NATO orange tape, minimum 2 inches wide for exit arrows.

• Adhesives: Adhesives shall be capable of sealing joints of adjacent sheets of polyethylene and for attachment of polyethylene sheet to finished or unfinished surfaces of dissimilar materials and capable of adhering under both dry and wet conditions, including use of amended water.

• Surfactants (Wetting Agents): Fifty percent polyoxyethylene ester and 50% polyoxyethylene ether, or equivalent, and shall be mixed with water to provide a concentration of one ounce, or more as needed, of surfactant to 5 gallons of water. (An equivalent surfactant shall be understood to mean material with a surface tension of 29 dynes/cm as tested in its properly mixed concentration, using ASTM method D 1331-56 (R 1980), “Surface and Interfacial Tension of Solutions of Surface Active Agents.”

• Warning Labels and Signs: As required by OSHA regulations 29 CFR 1926.1101 and HIOSH regulation 12—145.1.

• Other Materials: Provide all other materials, such as, but not limited to lumber, plywood, nails, fasteners, metal studs, hardware, foam sealants, and caulking which may be required to properly prepare and complete this project.

• Portable shower stall with industry standard water filtration system for decontamination of workers.


2.6 Respiratory Protection Requirements

Asbestos abatement workers at the project site may be exposed to respiratory hazards during work activities such as asbestos fibers and other hazardous dust and debris. Respiratory protection ensures workers are protected from exposure to these respiratory hazards.

The following table lists the types of respirators which may be required during

asbestos abatement work at the project site:

Respirator Requirements

Respirator Use/Application Filtering face piece (dust mask) Voluntary use for workers during

construction of containment and workers outside of the work area to protect from dust inhalation

N-95

N-100 Half-face respirator with P-100 filter cartridge

Minimum required for asbestos abatement workers during work activities provides a protection factor (PF) of 10

Full-face respirator with P-100 filter cartridge(s)

Required for workers with greater exposure risk requiring a PF of 50

The PF rating is a number which expresses the protection from inhalation provided by

the respirator. A respirator with a PF of 10 will effectively filter out ten times the number of particles which a worker without a respirator would be exposed to.

Based on the types of materials which may be encountered during the activities at the

project site, additional types of respirators such as Powered Air Purifying Respirators (PAPR) and Self-Contained Breathing Apparatus (SCBA) are not anticipated to be required.

The Contractor is responsible for administering the respiratory protection program

and for ensuring that the respiratory protection plan is implemented as needed. The Contractor must ensure that the plan is understood and followed by all workers. Duties of the Contractor include:

• Identifying possible activities, processes or tasks that require employees to wear respirators, and evaluating hazards

• Selection of respiratory protection options

• Monitoring respirator use to ensure that respirators are used in accordance with their certifications

• Arranging for and/or conducting training


• Ensuring proper storage and maintenance of respiratory protection equipment.

• Conducting qualitative fit testing with Bitrex or other OSHA approved method

• Administering the medical surveillance program

• Maintaining records required by the program

• Evaluating the program

• Updating the written program, as needed

• Ensuring that employees under their supervision (including new hires) have received appropriate training, fit-testing, and annual medical evaluation

• Ensuring the availability of appropriate respirators and accessories

• Being aware of tasks requiring the use of respiratory protection

• Enforcing the proper use of respiratory protection when necessary

• Ensuring that respirators fit well and do not cause discomfort

• Continually monitoring and evaluating current and potential situations where respiratory hazards exist or may exist

Each worker has the responsibility to wear his or her respirator when and where

required and in the manner in which they were trained. Workers must also:

• Care for and maintain their respirators as instructed, and store them in a clean, sanitary location

• Inform their supervisor if the respirator no longer fits well, and request a new one that fits properly

• Inform their supervisor of any respiratory hazards that they feel are not adequately addressed in the work environment and of any other concerns that they have regarding the program

Hazard Assessment

The Contractor shall select respirators to be used on site, based on the hazards to which workers are exposed and in accordance with all OSHA standards. The Contractor must revise and update this hazard assessment as needed. NIOSH Certification

All respirators must be certified by the National Institute for Occupational Safety and Health (NIOSH) and shall be used in accordance with the terms of that certification. Also, all filters, cartridges, and canisters must be labeled with the appropriate NIOSH approval label. The label must not be removed or defaced while it is in use.


Medical Evaluation

Workers who are either required to wear respirators, or who choose to wear a respirator voluntarily, must pass a medical exam before being permitted to wear a respirator on the job. Workers are not permitted to wear respirators until a physician has determined that they are medically able to do so. Any worker refusing the medical evaluation shall not be allowed to work in areas requiring respirator use.

A licensed physician must provide the medical evaluations. Medical evaluation procedures are as follows:

• The medical evaluation is conducted using a questionnaire provided by the physician. The contractor or the physician shall provide a copy of the questionnaire to all employees requiring medical evaluations.

• To the extent feasible, the contractor shall assist workers who are unable to read the questionnaire (by providing help in reading the questionnaire). When this is not possible, the worker shall be sent directly to the physician for the medical evaluation.

• All affected workers shall be given a copy of the medical questionnaire to fill out, along with a stamped and addressed envelope for mailing the questionnaire to the company physician, if required.

• Follow-up medical exams shall be granted to workers as required by the standard or deemed necessary by the physician.

• All workers shall be granted the opportunity to speak with the physician about their medical evaluation, if they so request.

• The contractor shall provide the physician with a copy of this program, a copy of the Respiratory Protection Standard, the list of hazardous substances that workers may be exposed to, and for each worker requiring evaluation: his or her job title, proposed respirator type and weight, expected length of time required to wear respirator, expected physical work load (light, moderate, or heavy), potential temperature and humidity extremes, and any additional protective clothing required.

• Any worker required for medical reasons to wear a positive pressure air purifying respirator shall be provided with a powered air purifying respirator or shall not be allowed to work in environments requiring respiratory protection.

• After a worker has received medical clearance and has begun to wear his or her respirator, additional medical evaluations shall be provided under the following circumstances:


Worker reports and/or symptoms related to their ability to use a respirator, such as shortness of breath, dizziness, chest pains, or wheezing.

The physician informs the contractor that the employee needs to be reevaluated;

Information from this plan, including observations made during fit-testing and plan evaluation, indicates a need for reevaluation;

A change occurs in workplace/field work conditions that may result in an increased physiological burden on the employee.

All examinations and questionnaires are to remain confidential between the worker

and the physician. Fit Testing

Fit testing is required for workers wearing half-face or full-face respirators. Workers wearing half-face or full-face respirators must be fit tested:

• Prior to being allowed to wear any respirator with a tight-fitting face piece

• Annually

• When there are changes in the employee’s physical condition that could affect respiratory fit (e.g., obvious change in body weight, facial scarring, etc.).

Workers must be fit tested with the make, model, and size of respirator that they will

actually wear. Workers should be provided with several models and sizes of respirators so that they may find an optimal fit. Fit testing of PAPRs is to be conducted in the negative pressure mode.

The Contractor shall conduct fit tests following the OSHA approved Bitrex Solution Aerosol Qualitative Fit Testing (QLFT) Protocol. Cleaning

Respirators are to be regularly cleaned and disinfected. Respirators issued for the exclusive use of a worker shall be cleaned as often as necessary. Cleaning of respirators is required prior to exiting the work area during asbestos abatement work activities. The following procedure is to be used when cleaning and disinfecting respirators:

• Disassemble respirator, removing any filters, canisters, or cartridges.

• Wash the face piece and associated parts in a mild detergent with warm water. Do not use organic solvents.

• Rinse completely in clean warm water.


• Wipe the respirator with disinfectant wipes (70% isopropyl alcohol) to kill germs.

• Air dry in a clean area.

• Reassemble the respirator and replace any defective parts.

• Place in a clean, dry plastic bag or other air tight container. Maintenance

Respirators are to be properly maintained at all times in order to ensure that they function properly and adequately protect workers. Maintenance involves a thorough visual inspection for cleanliness and defects. Worn or deteriorated parts shall be replaced prior to use. No components shall be replaced or repairs made beyond those recommended by the manufacturer. Repairs to regulators or alarms of atmosphere-supplying respirators shall be conducted by the manufacturer. Storage

Respirators must be stored in a clean, dry area, and in accordance with the manufacturer’s recommendations. Each worker shall clean and inspect his/her own air-purifying respirator in accordance with the provisions of this plan. Training

The contractor shall provide training to respirator users on the OSHA Respiratory Protection standard. Workers shall be trained prior to using a respirator in the field.

Documentation

The Contractor shall maintain copies of training and fit testing record and copies of the medical records for all workers on this project covered under the respirator program. The completed medical questionnaire and the physician’s documented findings are confidential and shall remain with the physician. The contractor shall only retain the physician’s written recommendation regarding each worker’s ability to wear a respirator.

2.7 Preparation of the Work Area

The PACM removal work area shall be secured and asbestos warning signs posted to control entrance and exits to the work area. The contractor shall construct adequate containment to protect the environment and the general public from exposure to asbestos fibers which may be released during PACM removal. The contractor shall be responsible for maintaining the integrity of the work area at all times.


The contractor shall maintain a Visitor/Worker Entry Log for all personnel entering the work area. All personnel entering the work area shall have completed an Employee Release Form prior to entering the work area.

All workers entering the work area shall be required to remove all clothing which will

not be left in the work area for disposal (synthetic fiber bathing suits which can be rinsed prior to exiting the work area may be worn beneath disposable coveralls) and don appropriate PPE prior to entering the area.

2.8 Containment

Due to the current site conditions, the DOH has agreed to waive the full negative pressure containment requirement for the removal of PACM, and of debris and ash contaminated with PACM throughout the project site.

The Contractor shall set up a modified containment by installing critical barriers

using 6-mil polyethylene sheeting over all openings within each residential unit. The Contractor shall establish and maintain negative air pressurization as feasible, with the negative air machine positioned at the furthest point of the containment from the entrance. The exhaust of the negative air machine shall have a HEPA filter to filter the air prior to exhaust from the containment area.

If feasible, set up a three-chambered decontamination room at the entrance and exit

where workers will be able to remove PPE and shower prior to exiting the containment area. The shower shall include a standard water filtration system to filter fibers from rinse water for proper disposal.

If a shower cannot be provided due to site conditions, workers shall decontaminate in

a designated decontamination area with drop polyethylene sheeting and assisting attendants. Attendants shall HEPA vacuum dust and debris from the surface of the worker’s PPE and clean PPE using disposable wet wipes, as necessary. Once surface dust and debris are removed, workers shall remove the protective coveralls and gloves by turning inside out and balling it up. All wet wipes, gloves, and contaminated suits shall be properly disposed of as asbestos contaminated waste material. Following the removal of all disposable PPE, workers shall wipe the surface of the respirator and exposed body surfaces, proceed to the clean area, and remove the respirator to be properly cleaned and stored.

Prior to the disassembly of the containment, the surfaces shall be wiped down and

HEPA vacuumed and sampling within the containment shall be conducted to ensure that airborne fiber counts are below the EPA clearance level criteria of 0.01 fibers per cubic centimeter (f/cc).


The air samples shall be analyzed using phase contrast microscopy (PCM) by an AIHA (American Industrial Hygiene Association) accredited laboratory in accordance with the National Institute for Occupational Safety and Health (NIOSH) Method 7400.

2.9 Removal and Disposal

PACM at the project site shall be removed by certified asbestos abatement workers. During PACM removal work acceptable industry standard dust control methods shall be used to control dust.

All PACM removal work shall employ the use of aggressive dust control methods

such as amended water to wet the material by misting and workers shall avoid crushing and pulverizing materials during removal. Removal of PACM shall be conducted using manual methods to maintain the integrity of the whole material as much as possible. Provisions must be made to prevent any contaminated water run-off from the work area.

PACM material which is removed shall be double bagged in minimum 6-mil

transparent polyethylene bags and sealed using the “goose-neck” sealing procedure after excess air is removed with a HEPA vacuum. All bagged PACM waste shall be labeled as ACM by the abatement workers. Bagged waste PACM shall then be packed into containers labeled as ACM waste and disposed of by the Contractor at an approved on-island waste facility.

Alternatively, large volumes of wastes containing PACM and or debris/ash contaminated with PACM, shall be rolled and “burrito wrapped” in 6-mil polyethylene plastic and sealed with duct tape. The rolled PACM waste must be double wrapped to achieve a minimum thickness of 12-mil. All rolled and “burrito wrapped” PACM waste shall be labeled as ACM by the abatement workers, then be packed into containers labeled as PACM waste and disposed of by the Contractor at an approved on-island waste facility.

The Contractor shall be responsible for providing disposal receipts.

2.10 Daily Clean-Up

After wetting, and while still adequately wet, promptly seal all asbestos-containing waste material in leak-tight containers; or, for materials that will not fit into containers without additional breaking, put materials into leak-tight wrapping as specified in DOH 11-501-12 (iii). All plastic wrapping or containerizing material shall be transparent. Bagging of all loose asbestos material shall be performed at least twice during each work day, before main rest break and at completion of the work day. Bagging shall be done prior to the removal of the materials from containment as specified in DOH 11-501- 7(c)(6)(E) and the containers shall remain leak-tight.


Respirators shall be cleaned prior to exiting the work area following manufacturer recommended cleaning procedures.

Workers shall decontaminate by removing PPE within the decontamination chamber

or area and showering in the Contractor supplied shower stall. Rinse water shall be collected and filtered by the Contractor in accordance with industry standards and state and federal regulations. All disposable PPE shall be properly disposed of as asbestos contaminated waste at an approved waste facility.

All equipment used in the abatement area which is not disposed of as ACM waste

shall be HEPA vacuumed and wiped clean by the abatement workers prior to being removed from the work area.

At the conclusion of the abatement, once the PM has reviewed clearance sample

analytical results, determined that the abatement has been completed, and provided the Contractor with a Clearance Letter, the Contractor shall remove all work-related waste, equipment, materials, and signage. All PACM waste from the project site shall be disposed of at an approved landfill.

2.11 Transportation and Disposal of PACM Waste

All PACM shall be placed in asbestos disposal bags (or rolled and “burrito wrapped” according to Section 2.10) and marked with OSHA labels as prescribed by HIOSH (Hawaii) regulations. Labels shall state:

“DANGER - ASBESTOS FIBERS - AVOID CREATING DUST -BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM.” Additionally, bags (or burrito wraps according to Section 2.10) shall be labeled in

accordance with OSHA requirement 29 CFR 1926.1101, DOH 11-501-12 (v); HIOSH 12-145.1; EPA regulation 40 CFR 61.150; or EPA 40 CFR 763 if more restrictive. For asbestos-containing waste material removed from containment, label containers or wrapped materials with the name of the owner and operator and the location at which the waste was generated.

Asbestos-contaminated waste with sharp edges (e.g., nails, screws, sharp plaster

fragments, etc.) will tear the polyethylene bags and sheeting and therefore shall be placed in drums or enclosed with cardboard and double wrapped and sealed with plastic. Contaminated non-ACM material shall be double-bagged with OSHA labels as described above in accordance with OSHA requirement 29 CFR 1926.1101, HIOSH 12-145.1, and EPA 40 CFR 61.150.

Transportation of PACM to the disposal site shall be in accordance with 49 CFR 172.101. All asbestos regulated waste must be disposed of at a waste landfill facility that is


State-approved to accept such waste. The Contractor shall advise the landfill operator, at least twenty-four (24) hours prior to transportation, of the material to be delivered.

2.12 Final Clearance

The PM shall conduct a visual inspection of the work area after the removal has been completed to confirm that no visible PACM remains. Negative pressure enclosures shall be allowed to exchange the air 72 exchanges divided by 4 every hour (0.2 inches of water with respect to the outside air), 18 hours prior to commencement of sampling activity. The Contractor shall apply encapsulant to any exposed surfaces and allow it to dry, and the PM shall conduct clearance sampling of the abatement area by collecting a minimum of two asbestos air clearance samples from the work area. Sampling procedures are described in Section 3.0.

Once the PM has reviewed final clearance sample results and confirmed that fiber

counts in the work area meet with EPA clearance criteria of 0.01 f/cc, the PM shall provide the Contractor with a written Clearance Letter and instruct the Contractor to proceed with the breakdown of the abatement work area. The Contractor shall not remove any barriers or any protective signage until the Contractor has received the written Clearance Letter confirming that the abatement has been completed.

2.13 Asbestos Abatement Contractor Final Documentation

At the conclusion of the abatement project, the Contractor shall provide the following final documentation:

• A statement signed by the Contractor that states that all asbestos abatement

and disposal was completed in compliance with federal, state, and local regulations, and the approved Work Plan.

• The Visitor/Worker Entry Log: The daily log of all personnel who enter the work area while asbestos abatement operations are in progress and until final clearance is received. The log shall include, as a minimum: Date of visit/worker entry; Visitor/Worker’s name, employer, business address, and telephone number; Time of entry and exit from work area; Purpose of visit; Type of protective clothing and respirator worn; and Certificate of release signed and filed with the contractor.

• All documents that had been submitted or generated during the course of the project shall be compiled and submitted to the reportable agencies.


3.0 ASBESTOS AIR MONITORING AND ANALYSIS

The PM shall conduct area air sampling in order to monitor the airborne fibers which are released during the abatement activities. The PM shall also be responsible for collecting personal air samples on workers in the abatement area.

The risk of exposure to workers and the general public during the abatement activity

will be determined by calculating an eight-hour time weighted average (TWA) from the sampling results and presenting the results to the Contractor. In the event that PELs are exceeded, the PM shall advise the Contractor regarding the use of alternative abatement procedures which may reduce airborne fiber concentrations and regarding required PPE to protect workers.

At the conclusion of the abatement, the PM shall collect area clearance samples from

within the work area to confirm that airborne fiber counts are below acceptable EPA clearance concentrations. Documentation of all sampling and analytical results shall be presented in a Final Clearance Report.

3.1 Area Sampling

The PM shall collect area samples from the containment areas of the project site. Two area samples shall be collected from inside the containment and two area samples shall be collected from outside the containment area. The samples collected outside the containment area shall be collected at the entrance to the containment and at the negative air exhaust (when feasible).

Area samples shall be collected using low volume air pumps calibrated to collect air samples at a rate of two to three liters per minute (L/min) throughout the abatement activity. Samples shall be drawn through a 25-mm diameter cassette containing a 0.8 micron mixed-cellulose ester filter in accordance with OSHA asbestos sampling Method ID-160. The maximum air volume collected shall not exceed 2,400 liters.

The PM shall record the air pump flow rate at the beginning and at the end of the area

sampling along with the start and stop times on field notes, which shall be used to calculate the total air volume of the sample. A laboratory provided chain of custody form shall be completed by the PM and submitted to the laboratory along with the samples.

The results of the area air samples collected inside the containment shall be compared

to the OSHA PEL of 0.1 f/cc. However, the area air samples collected outside the containment shall be below ½ of the OSHA PEL of 0.1 f/cc (0.05 f/cc), as recommended by the DOH Indoor & Radiological Health Branch. Whenever the area air monitoring sampling


results are greater than the OSHA PEL (0.1 f/cc) inside the containment, and/or greater than ½ the OSHA PEL (0.05 f/cc) outside the containment, the work must stop and the Contractor must reassess the engineering controls in order to safeguard the safety and health of the workers and the general public prior to commencing work.

3.2 Personal Sampling

Personal air samples shall be collected by the PM on each day of abatement activities. Personal air samples shall be collected on 25% of the abatement workers working within the abatement area. Low volume pumps shall be affixed to abatement workers using tape or other secure strapping and the sampling cassette shall be positioned within twelve inches of the worker’s breathing zone during the abatement activity. The results of the personal air samples shall be compared to OSHA PELs.

Personal samples shall be collected using low volume air pumps calibrated to collect

the air samples at a rate of 2-3 L/min throughout the abatement activity. Samples shall be drawn through a 25-mm diameter cassette containing a mixed-cellulose ester filter in accordance with OSHA asbestos sampling Method ID-160. The maximum air volume collected shall not exceed 2,400 liters.

The PM shall record the air pump flow rate at the beginning and at the end of the

personal sampling along with the start and stop times on field notes which shall be used to calculate the total air volume of the sample. A laboratory provided chain of custody form shall be completed by the PM and submitted to the laboratory along with the samples.

The results of the personal air samples shall be compared to OSHA PELs.

3.3 Clearance Sampling

At the conclusion of the abatement, the PM shall conduct a visual inspection of the work area for evidence of remaining asbestos debris and fibers. In the event that the PM identifies suspect ACM fibers at the work area, the PM shall instruct the Contractor to re-clean the area. Once the PM approves the final cleaning of the work area, the PM shall instruct the Contractor to encapsulate any surfaces from which PACM was removed.

Negative pressure enclosures should be allowed to exchange the air 72 exchanges

divided by 4 every hour (0.2 inches of water with respect to the outside air), 18 hours prior to commencement of sampling activity.

Following encapsulation, the PM shall collect area clearance samples from the

abatement work area. A minimum of two clearance samples shall be collected using high volume air pumps with the flow rate set at 15 L/min shall be collected for a period of one and


a half hours to draw air through a 25-mm diameter cassette containing a mixed-cellulose ester filter for a total air volume of 1,350 L.

A laboratory provided chain of custody form shall be completed by the PM and

submitted to the laboratory along with the samples. The results of the clearance air samples shall be compared to the EPA clearance

criteria of 0.01 f/cc.

3.4 Sample Analysis

All asbestos air samples shall be analyzed by an AIHA (American Industrial Hygiene Association) accredited laboratory in accordance with the National Institute for Occupational Safety and Health (NIOSH) Method 7400 phase contrast microscopy (PCM). Samples shall include a chain of custody providing the laboratory with the total air volume collected during the sampling.

The laboratory shall provide analytical results as the number of fibers per cubic

centimeter as calculated based on the air volume provided on the chain of custody. Samples with analytical results exceeding the OSHA PEL (personal and inside area air samples), ½ of the OSHA PEL (outside area air samples), and EPA clearance level (clearance air samples) using the PCM method may be re-analyzed using the Transmission Electron Microscopy (TEM) method to determine whether fibers are asbestos.

3.5 Quality Control

For each day of area sampling, the PM shall submit two field blank sampling cassettes along with the air samples collected to be analyzed by the laboratory. Field blanks shall be used to confirm accurate sampling procedures in the field and check laboratory analysis procedures. Documentation of sample volumes collected in the field and locations shall be kept in field notes and recorded in the chain of custody submitted with the samples to the laboratory. The chain of custody shall be completed and signed by the PM who collects the samples in the field.

Field notes shall also document conditions at the site during the abatement work,

including documentation of the work activity, the measurement of negative air pressure throughout the project in the event that the work area is within constructed containment, and any unusual circumstances of the abatement activity.

All sampling and analytical methods shall be in accordance with all Federal and State

requirements for asbestos abatement monitoring.


3.6 Review of Analytical results

The PM shall review all analytical results of air sampling conducted. The PM shall calculate the eight-hour TWA of each area and personal sample using the following calculation:

8-hour TWA = [CONC]ACM x Sample Time/480 minutes

Where:

[CONC]ACM = the laboratory calculated fiber concentration (f/cc)

Sample Time = the period of time the sample was collected (in minutes)

480 minutes = 8 hours The 8-hour TWA shall be compared to the OSHA PEL of 0.1 f/cc for personal air

samples and area air samples collected inside the containment, and ½ the OSHA PEL (0.05 f/cc) outside the containment.

Whenever the area air monitoring sampling results are greater than the OSHA PEL

(0.1 f/cc) inside the containment, and/or greater than ½ the OSHA PEL (0.05 f/cc) outside the containment, the work must stop and the Contractor must reassess the engineering controls in order to safeguard the safety and health of the workers and the general public prior to commencing work.

Clearance sampling analytical results shall be compared to the EPA clearance criteria

of 0.01 f/cc. In the event that the clearance sampling results are greater than the 0.01 f/cc limit, then the PM shall instruct the Contractor to re-clean the abatement area and the clearance inspection and sampling shall be repeated until the work area meets the clearance criteria.

The PM shall provide the Contractor with a Clearance Letter stating that there is no

visible asbestos containing debris, all air samples were collected and analyzed in accordance with NIOSH Method 7400, and all work has been completed in accordance with the project specifications and EPA and DOH regulations.

3.7 Contractor’s Responsibilities

The work shall stop whenever maximum permissible exposure to airborne concentrations of fibers is exceeded and the contractor shall remedy the condition prior to commencing work. The Contractor shall be responsible for the following:


1. Provision of personal monitoring and necessary records for all Contractor’s employees as required by OSHA (29 CFR 1926.1101), Hawaii State law (12-145.1), and all other applicable laws.

2. Reports provided by the PM may be available for the Contractor’s use. The Contractor may accept such reports as they are offered at his or her own risk.

3. Air monitoring and testing that becomes necessary in order to follow-up on work by the abatement contractor which is rejected as not conforming to the requirements shall be the responsibility of the Contractor.

4. As a minimum, the Contractor shall follow the requirements of HIOSH (Hawaii), EPA, OSHA and NIOSH and take all necessary precautions to ensure there is no asbestos contamination to those areas not included in the work schedule.

5. The contractor shall furnish all labor, materials, and equipment necessary to complete the safe and proper handling, treatment, removal, clean-up, transportation, and disposal of PACM and associated debris in compliance with all applicable laws and regulations concerning asbestos, including all incidental and pertinent operations.


4.0 FINAL CLEARANCE REPORT

The PM shall prepare a Final Clearance Report which shall include the following documentation:

• Contractor license number, notification form to the Hawaii DOH and EPA, work duration, respiratory protection and decontamination procedures employed.

• All ambient and post-abatement air sampling results collected by the PM.

• All personal air sampling results in accordance with OSHA regulations.

• Visual clearance certifications provided by the PM.

• EPA waste generator number, material removed, and total quantity of waste.

• Waste shipping and disposal manifests of all waste material, signed and accepted by the waste disposal facility, to include names and addresses of the Contractor, the Transporter, the Facility, and information on the type and number of waste containers.


5.0 CERTIFIED PROJECT DESIGNER

I have prepared this Asbestos Abatement Work Plan to address the handling and removal of PACM and debris and ash contaminated with PACM from the residential units where other parties have determined be a total loss at the Marco Polo Apartments, located at 2333 Kapiolani Boulevard, Honolulu, Hawaii (the project site). This Work Plan is intentionally general to provide Contractors with flexibility to determine the most efficient way to accomplish the scope of work described herein.

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State of Hawaii Certified Asbestos Project Designer Certification Number HIASB-2783