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Environmental Consultant Updates

2 months ago

Scranton, United States Scranton School District, Pennsylvania Full time

Pennoni is providing this update to the Scranton School District (District) to detail response actions relative to asbestos containing materials discovered during recent renovations at the Robert Morris Elementary School located at 1842 Boulevard Avenue, Scranton, PA 18509. BACKGROUND Pennoni has been in close coordination with Scranton School District regarding ongoing renovations at Robert Morris Elementary School (RMES). On Thursday, May 11, 2023, Pennoni was notified of suspect material identified above ceilings on the second floor of the east wing. This normally inaccessible area between the ceiling and the roof of the building, was being accessed by the project’s mechanical contractor to surveil for routing locations of pipe and ductwork to be installed at a later date. The suspect material was then assessed by Pennoni licensed asbestos building inspectors, and the determination was made to collect and mitigate this material on Saturday, May 13th during a previously schedule asbestos floor tile abatement in Rooms 201 and 202. Upon investigation, the area of impact was greater than anticipated and work progressed into Sunday to conclude the clean-up. The material is presumed to be asbestos and most likely was deposited in the space following the removal of cast iron roof drain piping. It is undetermined as to when this occurred, but the assessed quality and condition are defined as a Major Fiber Release in both the Asbestos Hazard Emergency Response Act (AHERA) and the District’s Management Plan. Approximately 150 linear feet of this friable and damaged material was located in this area, described as a space with limited access, no occupancy, and not part of the heating, ventilating, and air conditioning system (HVAC). While a clean-up of the damaged material occurred under containment and areas were HEPA vacuumed, the entire space (~5,000 SF) could not be rendered free of visible dust. Due to the age of the structure, the location and confinement of the space, dust remains in sections of this wing on the top of ceiling plaster. Due to the potential for asbestos contamination within parts of the space, Pennoni is recommending the following conditions of reoccupancy: Sealing of any openings or pathways between the ceiling and the space with dust tight barriers. Air sampling of occupied areas on a regular, pre-defined schedule. Surveillance inspections of the building at a greater frequency (currently semiannually). Labeling of access points to the designated area with asbestos signage. Suspension of construction activities on the second floor in this area to prevent disruption. Air sampling via both TEM and PCM methodologies has been conducted throughout the area and all tests outside of contained asbestos abatement areas, have passed USEPA criteria for “clean air.” Despite the sampling and confirmation of no exposure in the areas sampled, the area above the ceiling may be contaminated and should be considered partially abated. As an alternative to the above conditions of reoccupancy, the District may consider closure of the school and relocation of staff and students to other schools for the remainder of this school year. Such a relocation would allow Pennoni, in conjunction with a licensed abatement contractor and the district engineer, to commence the work necessary to clear the ceiling area and abate the potential asbestos hazard. This would allow up to 4 weeks of activities to occur and to deliver these areas back to renovation contractors to resume the remaining work needed to have the school ready for the 2023-2024 school year. If you have any questions concerning this report or if you require additional information, please feel free to contact us.

PENNONI ASSOCIATES INC. Rocco DiPietro, CSP - Senior Health and Safety Professional Michael Baltrusaitis, CHMM, CSP - Senior Health and Safety Professional RE: ROBERT MORRIS RENOVATION FREQUENTLY ASKED QUESTIONS SCRANTON SCHOOL DISTRICT SCRANTON, PA Dear Mr. Rucker: Pennoni

is providing this update to the

Scranton School District (District)

to detail responses to Frequently Asked Questions (FAQs) relative to asbestos containing materials discovered during recent renovations at the Robert Morris Elementary School located at 1842 Boulevard Avenue, Scranton, PA 18509. BACKGROUND Pennoni and the Scranton School District continue to manage hazardous materials, primarily asbestos, within the Robert Morris Elementary School (RMES) throughout planned extensive renovations. Due to the discovery of potentially asbestos contaminated dust above the ceilings of the second-floor renovation wing, the District and the school board chose to relocate students and close the school throughout the remainder of the school year. This closure and relocation have allowed planned renovation work to accelerate based on the additional time for renovations; however, the abatement of these materials will mostly likely take the remaining weeks of the school year to complete. All work conducted was/is done in strict accordance with US EPA rules under the Asbestos Hazard Emergency Response Act (AHERA), including project Designs, Management Plans, and protective measures. At the onset of the determination to relocate students and teachers, a school-wide meeting was held with faculty, staff, and administrators of RMES on May 15, 2023. During that meeting, stakeholders were notified of the current plans and updated as to the building’s status. Participants were asked to submit questions via an online portal. The questions received following this meeting were coalesced and presented to Pennoni on May 23, 2023. Below are the responses to these questions provided by the environmental consultant and licensed Project Designers/Management Planners. FREQUENTLY ASKED QUESTIONS (FAQ) Q: Did anyone bother to read the Robert Morris inspection report from 2019? Specifically Section 6&7. A: Yes, asbestos Management Plans are required to be updated every three years minimally under the US EPA’s Asbestos Hazard Emergency response Act (AHERA). The District updated all Management Plans in 2021. Previous copies were removed and replaced with more current versions. Q: If asbestos was discovered on Thursday evening, and work by Scranton Electric stopped in that area, why were staff and students in the building on Friday when it was clearly stated by Mr. DiPietro said he recommended no one be in the building on Monday? A: No disturbance of materials occurred prior to Saturday. Thursday evening, Pennoni was made aware of materials within a previously unidentified space at RMES. The area in question was not identified on drawings. Upon review of previous plans, it was determined that the best course of action would be to further investigate the area when the building was unoccupied. This occurred on Friday afternoon, following dismissal of the students. Q: There was a probability of asbestos being disturbed throughout this construction project from the beginning, due to the past AHERA reports. Why wasn't proper protocol and procedures put in place and where do we go from here? Who is being held accountable for this error and who will make sure this doesn't happen again? A: While there a possibility of discovering unknown/unidentified materials once renovations occur, in this case, prior to renovation activities, the known asbestos containing materials were being managed in accordance with the AHERA regulations. This included pipe fittings within the basement area and sink coatings in classrooms. These areas were being managed per AHERA and licensed abatement contractors were coordinating removal as the schedule allowed. Q: If previously identified/reported asbestos has been partially abated does the remaining (friable AND non-friable) asbestos need to be included in our AHERA building plan? A: Yes, any ACM within the building (some exceptions are allowed for items such as roofs) must be included in the Management Plan. Q: When Mr. DiPietro knew about new asbestos on Thursday May 11th, was the school district, the principal notified about this? A: Yes, the District Designated person was made aware of the issues on Friday, following the investigation by Pennoni of previous plans and drawings. Q: Why wasn't an abatement team brought in the second asbestos was found (in March)? A: A licensed asbestos abatement contractor was scheduled to be onsite Friday for the scheduled removal of floor tile on the second floor. According to the initial report and subsequent investigation, the material was not “new” but rather newly discovered. It appeared that it had been there for some time previous. Q: Did anyone contact OHSA and the EPA concerning the handling of this project? A: All appropriate notifications were made. The Occupational Safety and Health administration (OSHA) does not have authority or jurisdiction for public sector entities within the state of Pennsylvania. An asbestos notification was filed and subsequently amended following the discovery of the ceiling materials with appropriate agencies (USEPA, PADEP, PADOLI). Q: I have been reporting ceiling issues with water damage for 10 years in room 201. That is disturbance of asbestos materials each and every time it has rained. I am at a loss for words. The TEM test read as 83 after Sunday's test. How long has this room and this building been unsafe during the last 10 years? A: The building was and remains safe. Air sampling conducted throughout this project and others indicate no asbestos overexposures to occupants. Samples that indicated some levels of asbestos were collected on Sunday, following the abatement and disturbance of the material, which had a connection to the space above due to the recent renovations; however, these samples were statistically similar to ambient levels. All samples collected from outside of the containment showed no asbestos. It has not been determined when or how the materials within this space got to their current condition. Q: Mr. Dipietro from Pennoni stated. "Suspicious material was reported Thursday night" How was it safe for the building to be occupied? The lack of concern for the children and adults in this building is in disheartening. A: The building was and remains safe. Multiple air sampling events have occurred within the renovation area and adjacent areas since March of 2023. At no time did any air samples outside of containment exceed USEPA Clean Air Criteria, defined as

Q: I requested to view and did view the AHERA documents for our building. Why weren't the contents complete and up to date? A: The Management Plan is available upon request, to view at any time. While Pennoni provides documentation to the District, we do not update each school’s Plan. Q: Why were students and staff allowed into the school building Friday May 12th after discovery of the new asbestos found on the second floor, possibly risking the health and well-being of said students and staff? A: A licensed asbestos abatement contractor was scheduled to be onsite Friday for the scheduled removal of floor tile on the second floor. According to the initial report and subsequent investigation, the material was not “new” but rather newly discovered. It appeared from the research and looking at the material that it had been there for some time previous. Q: Why was work continued in areas where we know there is/was asbestos? (Sinks, doorway, floor tiles) A: The District follows AHERA, in all cases. While there is always a possibility of discovering unknown/unidentified materials once renovations occur, in this case, prior to renovation activities, the known asbestos containing materials were being managed. This included pipe fittings within the basement area and sink coatings in classrooms. These areas were being managed and licensed abatement contractors were coordinating removal as the schedule allowed. Q: Can someone explain to me why the district and Mr. DiPietro didn't know that the floor tile under the carpets contained asbestos? Or the fact that many tiles were broken and could have become friable but air quality wasn't tested for over a month later? A: Simply broken or cracked tiles does not render them friable. The definition of friable per the USEPA includes

“…which when dry may be crumbled, pulverized, or reduced to powder by hand pressure .” Q: Why wasn't any type of abatement work started prior to construction? Why was any work at all started while children were in the building in 2023 after everything this district has been through thus far? A: An abatement was conducted in the summer of 2022. At that time a numerous ACM were removed from the building. This included floor tiles, stair treads, pipe insulation, and sinks. The only known materials left in place at that time was sink coatings in occupied classrooms. It was the intent of the District to keep these in place throughout the school year for use by students and teachers until such time that the rooms were scheduled for renovation. Q: Were and are the ventilation systems still running in the building? They were on Friday. Side fact - I have been working in this building for 11 years and have had repeated respiratory illnesses. I was relocated to a different building last school year and had ZERO sickness. This is a scary coincidence. A: There is no central heating, ventilating, and air conditioning system in this part of the building. Each classroom in the renovation area has a “Unit Ventilator” which serves the classroom. These units do not have any connection to the space above the ceiling. Q: Who is responsible for both updating AHERA building plan contents and overseeing that the requirements are followed/met? A: The District’s Designated Person. Per the USEPA AHERA regulations each local education agency (LEA) is required to designate a person to ensure that all LEA responsibilities and/or requirements are properly implemented. Q: Does the construction company realize that if any students or staff incur health issues from being in the building at the same time asbestos was discovered, it opens up the construction company to possibly litigation in the form of a class action lawsuit or independent lawsuits? A: Pennoni cannot speak to their understanding of this; however, it is common practice in the construction trades to encounter asbestos containing materials. Additionally, private sector construction contractors are required to comply with OSHA regulations. Q: What good is an air quality test a month after work was done? A: Air samples are the “gold standard” for determining if an abatement project has cleared and is safe for reoccupancy by unprotected individuals. Air testing was completed on the following dates: April 21, April 27, May 13, May 14, May 15 via both TEM and PCM methodologies and in both occupied and unoccupied areas continued to demonstrate that air quality was safe. Q: Why haven't the reports from the finding of asbestos on March 27, not been made available to staff and parents? A: The report covering the bulk sampling event from March 28, and a subsequent sampling event of additional tile on April 7, was issued to the District on April 18, 2023. This report indicated the tiles in Room 202 were asbestos and Room 103 were negative. Q: Why were the ventilation systems on and running in the building on Friday, May 12, 2023 after this discovery of asbestos material was found while people were in the building? Clearly this spread fibers. A: There is no central heating, ventilating, and air conditioning system in this part of the building. Each classroom in the renovation area has a “Unit Ventilator” which serves the classroom. These units do not have any connection to the space above the ceiling. Q: Why wasn't the AHERA report referenced before construction began? A: The current Management Plan was refenced prior to the start of renovations and subsequent to an abatement was conducted in the summer of 2022. The only known material was sink coatings in occupied classrooms. It was the intent of the District to keep these in place throughout the school year for use by students and teachers until such time that the rooms were scheduled for renovation. Q: Was building maintenance notified Thursday evening about turning/keeping ventilation system off? A: There is no central heating, ventilating, and air conditioning system in this part of the building. Each classroom in the renovation area has a “Unit Ventilator” which serves the classroom. These units do not have any connection to the space above the ceiling. If you have any questions concerning this report or if you require additional information, please feel free to contact us. PENNONI ASSOCIATES INC. Senior Health and Safety Professional Pennsylvania Asbestos Project Designer (No 002672)

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