Document 6wz6617nozOrpBdwYd0ZQnE4o
^ a UDiiaailyyssiiss 3SarrvviGlcas wDiivviibsiiwonii I I I | I O National Madlcal Cara, Inc.
JtrMmdiemi AppHcatttu Oi totAnv**, Inc.
South Bay Dialysis Unit 1123 Wesr Carson Street Torrance. California 9D502 (213) 320-4C93
002191
April 19, 1990
Mr. Tibor Horvath Commercial Building Co. 500 E. Carson St. #206 Carson, CA 90745
Dear Mr. Horvath:
'
;
I am attaching copies of the final reports from two separate consultants regarding the asbestos found in our facility. We have been investigating various options regarding the management of this problem and have found out the following:
-The cost estimates for leaving the asbestos in place but imple menting an Operations & Maintenance program range from $32,000 to $55,812 for the first year.
-The cost estimates for removing the material range from $15,000 to $21,028. .. '
The regional personnel involved in this matter ^re Mr. Benny Manalo, Area Manager, and Mr. Gerald Beebe, Regional Manager; both of them may be con tacted at (818)346-18281 Mr. Larry Park is the corporate contact ir Waltham, MA; his phone number is (800)662-1237. Please do not hesitate to contact any of us if you have questions.
Sincerely,
Kathleen W. Smith, R.N. Director of Nursing
att
KWS/me
cc: Larry Park/NMC Corporate Gerald Beebe/NMC Regional Benny Manalo/NMC Regional
R007811
DRAFT
Special Operations and Maintenance Program Bio-Medical Applications of Los Angeles, Inc. t March 1, 1990
Purpose: It has been determined through two independent
environmental surveys that certain building materials at BMA Los
Angeles contain asbestos.
Although laboratory tests have
determined that airborne asbestos fibers were well within OSHA
guidelines, National Medical Care is instituting this Special
Operations and Maintenance Program in order to protect the health
and safety of patients, employees, and visitors of BMA Los
Angeles.
/<
(
Scope: The Special Operations and Maintenance Program applies to Bio-Medical Applications of Los Angeles, Inc. located at 1120 W. Carson St., Torrance, CA 90502.
Program Elements:
1. Special O&M Committee
i
Individuals who will be responsible for the implementation and
oversite of this Special Operations and Maintenance Program are
as follows:
Venus Mann-Aguilar (Area Administrator, O&M Program Mgr)
Peter Parsa, M.D.
(Medical Director)
Kathleen Smith
(Director of Nursing Services)
Mark Halloren
(Chief Technician)
Benny Manalo
(Area Manager)
1.
R?81s
Notification
DRAFT
a. Appropriate signs will be posted in areas known to
contain ACM in order to inform building inhabitants of
' the existence of asbestos in the environment.
b. All building drawings for BMA Los Angeles will be
properly marked so as to indicate the existence and
specific location of ACM.
The real estate and
construction department at National Medical Care will
be responsible for marking such drawings and forwarding
a copy of each to the facility. All previous copies of
building drawings not properly marked will be discarded
by the Chief Technician.
;
c. All outside service Organizations, such as * the
(
janitorial service, having access to ACM locations will
be notified in writing by the Program Manager that ACM
exist in the facility. Such notification will inform
outside service organizations of minimal safety
precautions to be utilized when working in the
facility.
The facility will also provide all
,t
appropriate training to outside Service employees such
as proper use of respiratory equipment. Such training
will be fully documented and such documentation will be
maintained by the Program Manager.
d. All employees and patients of BMA Los Angeles will be
notified of the existence of ACM and of airborne fiber
laboratory test results.
In addition, the facility
will establish a mechanism to ensure that all new
2.
*007813
DRAFT
(future) patients and employees of the facility
are also so informed.
e. All employees who work in areas known to contain ACM
' will be trained in precautionary measures to be
employed while working in the facility. Such training
will include a review of all asbestos containing
materials, visual inspection methods to determine
possible damage to known ACM, and proper notification
procedures for discovery of damage to ACM.
Monitoring System;
a. The O&M Program Manager will be responsible for
scheduling quarterly testing of airborne
utilizing Transmission 'Electron
technology.
Microscopy
fibers tTEM)
b. Air samples will be drawn on a continuous basis over a
3 month period and sent to a certified laboratory for
analysis. The O&M Program Manager will be responsible
for procuring all necessary equipment to obtain such
samples.
c. Laboratory test results of >air samples will be
published by the O&M Committee upon receipt and copies
will be made available to facility employees and
patients upon request.
d. In the event that quarterly laboratory samples indicate
airborne fibers which are in excess of OSHA standards,
the facility will immediately begin conducting monthly
airborne tests.
In addition, the O&M Committee, in
3.
R007814
DRAFT
conjunction with NMC's Director of Safety, will
consider the need to implement an abatement program to
enclose, encapsulate or remove ACM from the facility.
4. Initial Cleaning:
a. The O&M Program Manager will contract with a janitorial
service to clean the facility and properly remove
asbestos fibers. The initial cleaning will address the
following minimum requirements:
(1) Steam-clean all carpets using High Efficiency
Particulate Air (HEPA) filtered vacuum
cleaners.
(2) Spray vacuum cleaner bags with water before
removal and discard such bags in scaled i
plastic bags in accordance with Environmental
Protection Agency (EPA) regulations.
Such
regulations require that ACM be disposed in
double-ply 6 mil plastic bags which are
prominently labeled with a sign indicating
"CAUTION: Asbestos Waste". /*
Such bags are to
be sealed with heavy vduty tape and placed
with other solid wastes for pick up and
delivery to an approved waste disposal site.
(3) Discard vacuum filters in similar manner and
in accordance with EPA regulations.
(4) HEPA vacuum all curtains, books or other
similar materials which might collect
asbestos fibers.
4.
R007815
DRAFT
(5) Wet mop all non-carpeted floors. Under
no circumstances are non-carpeted floors to
be swept with a broom.
' (6) Wipe all shelves and other horizontal
surfaces with damp cloths.
Cleaning
personnel must keep such cloths damp by use
of a spray bottle. Under no circumstances
are such shelves or other horizontal surfaces
to be dusted using a dust cloth or brush.
(7) Discard all cloths and mop heads in sealed
plastic bags in accordance with EPA
regulations. (see 4.a.2)
:
(8) Cleaning personhel will be required to -wear
half-face respirators (MSHA/NIOSH approved)
with disposable cartridge filters or a more
substantial respirator if necessary. Monthly Cleaning:
a. The O&M Program Manager will contract with a janitorial
service to clean the facility on a monthly basis to
remove asbestos fibers.
The Monthly cleaning will
address the following requirements:
(1) Spray with water any debris found near
surfacing ACM and place the debris in plastic
bags using a dust pan. Rinse the pan with
water in the utility sink. Report presence
of debris immediately to the O&M Program
Manager.
5.
R07qi6
DRAFT
(2) HEPA vacuum all carpets.
(3) Wet mop all non-carpeted areas.
(4) Wipe all shelves and other horizontal
< services with damp cloths. Cloths should be
kept damp by use of a spray bottle.
(5) Dispose of all cleaning materials in
accordance with EPA regulations.
(see
4.a.2 .)
Building Maintenance:
a. No building maintenance or construction will be
permitted in areas known to contain ACM without the
full knowledge and consent of the O&M Program Manager.
In such cases where permission is granted to perform
(
building maintenance or construction, the following
minimal precautionary measures will be taken:
(1) Containment barriers around work areas will
be constructed in accordance with EPA
regulations. Such regulations require that
containment barriers be constructed of 6 mil
' polyethylene plastiq' sheets joined with
folded seams and with sealing tape at the
seams and boundaries.
(2) All construction workers must wear
appropriate clothing and safety equipment
including coveralls and respirators.
(3) All HVAC return vents in construction areas
will be completely sealed until all
6.
R007817
DRAFT
construction activities are complete so as not to contaminate the ventilation system. (4) The entire construction area will be , thoroughly cleaned (as described in Initial Cleaning and Monthly Cleaning) before the construction area is reinhabited by facility personnel. B. Facility personnel will avoid patching or repairing any damaged surfacing ACM. In addition, personnel are to be cautioned against hanging plants or other objects from ceilings containing ACM. Maintenance personnel will be cautioned about disturbing ACM in ceiling materials when replacing , lights in light fixtures or
* when otherwise working around surfacing materials containing ACM. C. Maintenance personnel will be required to use proper precautionary methods when replacing acoustical ceiling tiles. When doing so, maintenance personnel must clear the area of all other personnel, wear the proper
respirator, cover the flooring yith a drop cloth and
clean up the work area carefully in accordance with cleaning procedures outlined in "Initial Cleaning" and "Monthly Cleaning".
D. Filters in the central HVAC system will be misted with water from spray bottles when removed during routine maintenance. All such filters will be disposed of in
7.
R007818
DRAFT
sealed bags in accordance with EPA regulations.
(see 4.a.2.)
7. Periodic Inspection:
The O&ty Program Manager will schedule an inspection every 6
months to inspect all ACM for damage or deterioration.
The
inspection team will include a representative from the
environmental consultant group, preferable the individual who
conducted the initial environmental study. Such inspections will
be fully documented and the O&M Program Manager will maintain
such documentation. A copy of such inspection findings will be
sent to the NMC Director of Safety.
>i (
J
8.
R007819
Dialysis Services Division I I I I I >/ National Medical Care, Inc.
o-Medical Applications Of Torrance, Inc.
3295 Skypark Drive Torrance, CA 90505 (213) 539-5091
March 13, 1990
i
r
Mr. Kyle Bishop
R.J. Lee Group, Inc.
2424 6th Street
Berkley, CA
94710
RE; Operations and Maintenance Program for BMA Los Angeles
Dear Kyle:
First off, I would like to thank you and Will Harris for all of the information you have shared with us regarding the air sampling pump, miscellaneous accessories, and classes for the operations of such said equipment.
Secondly, I have enclosed a DRAFT version of the O&M Program that Jerry Beebe composed for your review and comments. Please review this document with a fine*toothed comb, and change, add or delete any information that will validate this program.
.Lastly, after you have reviewed and modified this "DRAFT", please give us your opinion in terms of the committee that has been designated to monitor this program. The committee as a whole, feels strongly about the need for an additional member on the committee, i.e., a person such as yourself, Larry Park, or a designee that can be our "program expert". None of us feel qualified to manage nor oversee the.functions of such a program, due to the extensive guidelines and precautions that the EPA or OSHA may require. Please let us know your opinion.
After the final program has been compiled, we will then forward it to our Corporate Offices--Larry Park, and our legal council for their approval.
Thank you for your assistance in this matter.
Enclosure
cc: P. Parsa, M.D G. Beebe B. Manalo
K. Smith, R.N. M. Halloran L. Park
R007820
Special Operations and Maintenance Program Bio-Medical Applications of Los Angeles, Inc. ' March 1, 1990
Purpose: It has been determined through two independent
environmental' surveys that certain building materials at BMA Los
Angeles contain asbestos.
Although laboratory tests have
determined that airborne asbestos fibers were well within OSHA
guidelines, National Medical Care is instituting this Special
Operations and Maintenance Program in order to protect the health
and safety of patients, employees, and visitors of BMA Los
Angeles.
,c
i
Scope: The Special Operations and Maintenance Program applies to Bio-Medical Applications of Los Angeles, Inc. located at 1123 W. Carson St., Torrance, CA 90502.
Program Elements:
1 Special O&M Committee
' J
Individuals; who will be- responsible for the implementation and
oversite of this Special Operations and Maintenance Program are
as follows:
Venus Mann-Aguilar (Area Administrator, O&M Program Mgr)
Peter Parsa, M.D.
(Medical Director)
Kathleen Smith
(Director of Nursing Services)
Mark Halloran
(Chief Technician)
Benny Manalo
(Area Manager)
R007821
.2 Notification
a. Appropriate signs will be posted in areas known to
contain ACM in order to inform building inhabitants of
the existence of asbestos in the environment.
b. All building drawings for BMA Los Angeles will be
properly marked so as to indicate the existence and
specific location of ACM.
The real estate and
construction department at National Medical Care will
be responsible for marking such drawings and forwarding
a copy of each to the facility. All previous copies of
building drawings not properly marked will be discarded
by the Chief Technician.
c. All outside service organizations, such as the t
janitorial service, having access to ACM locations will
be notified in writing by the Program Manager that ACM
exist in the facility. Such notification will inform
outside service organizations of minimal safety
precautions to be utilized when working in the
facility.
The facility will also provide all
f4
appropriate training to outside service employees such
as proper use of respiratory equipment. Such training
will be fully documented and such documentation will be
maintained by the Program Manager.
d. All employees and patients of BMA Los Angeles will be
notified of the existence of ACM and of airborne fiber
laboratory test results.
In addition, the facility
will establish a mechanism to ensure that all new
R007822
(future) patients and employees of the facility
are also so informed.
e. All employees who work in areas known to contain ACM
f
will be trained in precautionary
measures to be
employed while working in the facility. Such training
will include a review of all asbestos containing
materials, visual inspection methods to determine
possible damage to known ACM, and proper notification
procedures for discovery of damage to ACM.
Monitoring System;
a. The O&M Program Manager will be
responsible for
scheduling quarterly testing of airborne fibers
utilizing Transmission Electron Microscopy
(TEM)
technology.
b. Air samples will be drawn on a continuous basis over a
3 month period and sent to a certified laboratory for
analysis. The O&M Program Manager will be responsible
for procuring all necessary equipment to obtain such samples.
c. Laboratory test results of ajtr samples will be
t published by the O&M Committee upon receipt and copies
will be made available to facility employees and
patients upon request.
d. In the event that quarterly laboratory samples indicate
airborne fibers which are in excess of OSHA standards,
the facility will immediately begin conducting monthly
i
airborne tests.
In addition, the O&M Committee, in
R007823
conjunction with NMC's Director of Safety, will
consider the need to implement an abatement program to enclose, encapsulate or remove ACM from the facility.
Initial Cleaning: a. The O&M Program Manager will contract with a janitorial
service to clean the facility and properly remove
asbestos fibers. The initial cleaning will address the
following minimum requirements:
(1) Steam-clean all carpets using High Efficiency
; Particulate Air (HEPA) filtered vacuum
cleaners.
(2) Spray vacuum cleaner bags with water before
removal and discard such bags in sealpd (
plastic bags in accordance with Environmental
Protection Agency (EPA) regulations.
Such
regulations require that ACM be disposed in
double-ply 6 mil plastic bags which are
prominently labeled with a sign indicating
"CAUTION: Asbestos Waste". Such bags are to
, be sealed with heavy dyty tape and placed
with ` other solid wastes for pick up and
delivery to an approved waste disposal site.
(3) Discard vacuum filters in similar manner and
in accordance with EPA regulations.
(4) HEPA vacuum all curtains, books or other
similar materials which might collect
asbestos fibers.
^007824
(5) Wet mop all non-carpeted floors. Under no circumstances are non-carpeted floors to
be swept with a broom.
(6) Wipe all shelves and other horizontal
surfaces with damp cloths.
Cleaning
personnel must keep such cloths damp by use
of a spray bottle. Under no circumstances
are such shelves or other horizontal surfaces
to be dusted using a dust cloth or brush.
(7) Discard all cloths and mop heads in sealed plastic bags in accordance with EPA
regulations. (see 4.a.2)
(8) Cleaning personnel, will be required to w^ar i
half-face respirators (MSHA/NIOSH approved)
with disposable cartridge filters or a more
substantial respirator if necessary.
Monthly Cleaning;
a. The o&M Program Manager will contract with a janitorial
service to clean the facility on a monthly basis to
remove asbestos fibers.
/4 The monthly cleaning will
address the following requirements:
(1) Spray with water any debris found near
surfacing ACM and place the debris in plastic
bags using a dust pan. Rinse the pan with
water in the utility sink. Report presence
of debris immediately to the O&M Program
Manager.
R007Q25
(2) HEPA vacuum all carpets.
(3) Wet mop all non-carpeted areas.
(4) Wipe all shelves and other horizontal
r
services with damp cloths. Cloths should be
kept damp by use of a spray bottle.
(5) Dispose of all cleaning materials in
accordance with EPA regulations.
(see
4.a.2.)
Building Maintenance:
a. No building maintenance or construction will be
permitted in areas known to contain ACM without the
full knowledge and consent of the O&M Program Manager. In such cases where permission is granted to perfqrm
building maintenance or construction, the following
minimal precautionary measures will be taken:
(1) Containment barriers around work areas will
be constructed in accordance with EPA
regulations. Such regulations require that
containment barriers be constructed of 6 mil polyethylene plastic /sheets joined with
folded seams and with sealing tape at the seams and boundaries.
(2) All construction workers must wear
appropriate clothing and safety equipment
including coveralls and respirators.
(3) All HVAC return vents in construction areas
will be completely sealed until all
ROo? 6^6
construction activities are complete so
as not to contaminate the ventilation system.
(4) The entire construction area will be
thoroughly cleaned (as described in Initial
Cleaning and Monthly Cleaning) before the
construction area is reinhabited by facility
personnel.
B. Facility personnel will avoid patching or repairing any
damaged surfacing ACM. In addition, personnel are to
be cautioned against hanging plants or other objects
from ceilings containing ACM.
Maintenance personnel
will be cautioned about disturbing ACM in ceiling
materials when replacing lights in light fixtures i;or
(
when otherwise working around surfacing materials
containing ACM.
C. Maintenance personnel will be required to use proper
precautionary methods when replacing acoustical ceiling
tiles. When doing so, maintenance personnel must clear
the area of all other personnel, wear the proper
respirator, cover the flooring w^th a drop cloth and
clean up the `work area carefully in accordance with
cleaning procedures outlined in "Initial Cleaning" and
"Monthly Cleaning".
D. Filters in the central HVAC system will be misted with water from spray bottles when removed during routine maintenance. All such filters will be disposed of in
R007827
sealed bags in accordance with EPA regulations.
(see 4.a.2.)
7. Periodic Inspection;
The O&M Program Manager will schedule an inspection every 6
months to inspect all ACM for damage or deterioration.
The
inspection team will include a representative from the
environmental consultant group, preferable the individual who
conducted the initial environmental study. Such inspections will
be fully documented and the O&M Program Manager will maintain
such documentation. A copy of such inspection findings will be
sent to the NMC Director of Safety.
(
/
.J
R007828