VII. Procedures for Managing Asbestos Abatement Projects

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Environmental Health and Safety

The Office of

Environmental Hazards Policy & Responsibilities

VII. Procedures for Managing Asbestos Abatement Projects

a. Preparation of asbestos project specifications/selection of abatement alternative


To summarize, the most common EPA approved asbestos abatement alternatives may be described as the following:

Abatement AlternativeAdvantagesDisadvantages
1. in-place management/no action (in conjunction with O&M programs low cost not permanent remedy ACM must be in good condition
2. complete or partial removal permanent remedy highest initial cost
3. encapsulation/wrap & repair moderate cost not permanent remedy ACM must be in fair condition
enclosure ACM may be in poor condition not permanent remedy high initial cost

 

It is the policy of Teachers College to select the most effective abatement alternative. However, the need for upcoming renovation work (i.e. replacement of the HVAC system) may dictate removal as the most feasible abatement option since it does offer a permanent solution. In many circumstances it is recommended that the Project Manager solicit price quotations for several alternatives such that they may be compared.

In addition to asbestos abatement procedures the requirements for 3rd party air monitoring and analysis (including sampling frequency and analytical methodology) shall be outlined in the project specifications. A copy of the project specifications may be forwarded to the appropriate union representatives upon request.

b. Selection of approved licensed Contractor and Project Monitor

If a proposal for asbestos abatement work is approved, a licensed asbestos abatement Contractor and 3rd Party Asbestos Air Monitoring Firm must be retained. Both parties shall be selected from the "Teachers College Approved Asbestos Contractor List" on-file at the EH&S and Facilities Management offices. Standard Facilities Management bidding/contracting rules shall be applied to asbestos abatement projects. Sufficient time should be allotted for the contracting process since the cost of "rush" (i.e. less than 10 days’ notice) is substantially higher than standard projects.

c. Regulatory agency filing requirements/waiting periods

The NYC and NYS asbestos regulations clearly state that it is the abatement Contractor's responsibility to notify the appropriate regulatory agency of the impending abatement project. However, failure to file asbestos abatement projects subjects both the Contractor and the Building Owner to fines.

The filing requirements in NYC are summarized according to the following:

Regulatory AgencySize of ProjectFiling RequestedWaiting Period
NYC DEP Minor ( Small (10-160 sq./25-260 ln.ft.)
Large (n/a
ACP-7
ACP-7no
7 days
7 days
NYS DOL minor
small
large
no
no (full cont.)
yes (glovebag) yes
n/a
n/a
10 days
10 days
EPA minor/small
large
no
yes
n/a
10 days

 

It should be mentioned that applicable and special variances to deviate from the regulations normally require three to six weeks to obtain. All variance applications shall be pre-approved by EH&S prior to submittal to the DEP.

Copies of asbestos project filings shall be posted in the buildings, on-file at the EH&S office, and be submitted to affected union authorized representatives.

The NYC DEP ACP-7 form must be signed and dated by the Contractor, the Building Owner Authorized Representative, and the Project Monitor.

d. Additional air sampling/exposure monitoring required to satisfy union contract requirements:

In addition to the asbestos air monitoring requirements specified in the applicable regulations (only require air monitoring when >10 sq./25 ln.ft. of ACM is disturbed) Teachers College bargaining unit contract may require asbestos air monitoring when any amount of ACM is disturbed. Such additional air monitoring shall be coordinated by the EH&S office.

e. Responsibilities of Facilities Project/Construction Managers during abatement projects (see attached checklist):

In order to simplify the construction management aspects of asbestos abatement projects as much as possible an Asbestos Project Management Checklist has been prepared. The items included on the list have been shown to be "critical pathways" to achieving in successful (i.e. no DEP or other violations, content building occupants) projects in a cost effective and timely manner.

 

* Asbestos Project Management Checklist

In order to efficiently manage asbestos abatement projects Facilities Project and Construction Managers should confirm that the following Issues are addressed:

 

Bidding issues

(1) Has the abatement Contractor's scope of work been clearly defined? The project specifications/work plan should provide clear instructions on how to conduct the project (including how the Contractor should file, what engineering controls should be used, etc.)

(2) Have the quantities of ACM, which the cost of the project is primarily based upon, been verified by someone other than the Contractor (i.e. Project Engineer, Director of Environmental Health & Safety)?

(3) Is re-insulation of the removal substrate required by NYC Fire/Building Code? If so, has re-insulation been included in the project bidding specifications?

 

Pre-project administrative issues

The following should be addressed at least 10 days prior to the start of abatement work:

(4) Selection of licensed asbestos abatement Contractor found on EH&S "approved Contractor list"

(5) Selection of licensed 3rd party asbestos air monitoring firm found on EH&S "approved Contractor list" [asbestos air monitoring is typically 15-20% of the total contract value]

(6) Has the project been filed with the NYC DEP, NYS DOL, and EPA as required? If required, have variance applications been prepared and submitted?

(7) Have copies of the filings been forwarded to the EH&S office, the appropriate union representatives, and posted in the building?

(8) Have the appropriate Faculty been notified of the abatement project?

(9) A definite start date for abatement work must be selected (may only be amended one time without monetary penalty from the NYC DEP)

 

Logistical & scheduling issues

The following items should be addressed at least 24 hours to one week prior to the onset of abatement work:

(10) Has a list of emergency phone/beeper numbers been prepared & distributed?; the following individuals should be included:

  • Director of Environmental Health  & Safety
  • Facilities Project/Construction Manager
  • Contractor Supervisor
  • Air Monitoring Technician

(11) Has the Contractor provided a written work schedule; has it been distributed to EH&S, the Faculty involved the Project Manager, etc.?

(12) Does the Contractor have access to the space? Have arrangements been made with Public Safety?

(13) The College is normally responsible for providing a source of water and electricity; the Contractor must identify the source and provide suitable hook-ups/panels; have such arrangements been made?

(14) Is there a service elevator available for use by the Contractor for equipment mobilization and bag-out?

(15) Is there space available for the Contractor to store equipment?

(16) For full containment abatement projects utility lines running through the work area must be de-activated including electrical, steam heat, and fire alarms; have work orders been completed to accomplish this? [failure to de-activate such lines may result in a DEP violation]

 

Construction phase issues

(17) Are daily air monitoring results being posted in the building, faxed to union representatives, and the EH&S Department within 24 hours of sample collection? Failure to post results may result in a DEP violation and is a violation of the in-house union contract agreements

(18) Are asbestos hazard signs posted in appropriate locations?

(19) Is the asbestos Contractor posing a nuisance hazard to building occupants by generating excessive levels of noise, dust, chemical hazards, etc.?

(20) The Project/Air Monitor must conduct a final visual inspection and clearance air sampling prior to dismantling of the containment; such events should be documented.

 

Project closeout issues prior to payment of Contractor & Consultant

(21) Has the landfill copy of the waste manifest been returned to the EH&S office?

(22) Has the Project Monitor's final report been submitted to the EH&S office?

(23) Has the work area sustained damages (e.g. water damaged carpets, ceiling tiles) which the Contractor should be back charged for?