- Published on Thursday, 01 November 2012 02:59
All school districts with older buildings are required to maintain records of the hazardous materials in their facilities. Asbestos is the most common of these materials. In August, I made a public records request to the superintendent to see the reports for Wellington's buildings. I never actually received this report from the school district. Instead, while retrieving files from a public server for a records request that I had made to OSFC, I found a copy of the report. This was just last week. I'm not going to get into why the district didn't furnish the report to me as requested, let's just examine what is in the report. Feel free to download a copy of the report if you wish, but fair warning: the report is nearly 50MB and may take a while on some connections to download.
The report covers all three school buildings. It tells what type of material samples were taken, where they were taken from, and if any hazardous material was found it lists the type and concentration. To be clear, there is asbestos in all three of our school buildings. However, in my opinion, the amount of asbestos within McCormick has been overstated and the amounts in Westwood and the high school have been forgotten as much as possible. At the high school, for instance, the original floor tile that was used during construction contains asbestos. While some of those tiles may have been replaced, most have not. That means asbestos is in nearly every classroom and hallway at WHS. Many of the samples taken from Westwood show higher concentrations of asbestos than those in McCormick. Read more for details.
First, let's briefly look at what asbestos is. Asbestos has gotten a bad name because in some circumstances, specific types of asbestos have been shown to cause cancer. Many people have a misconception that asbestos is a man-made material. In fact, asbestos is a naturally occurring substance that is mined just like coal, iron ore, silver, or copper. There are six primary types of asbestos that exist in nature and although they are all closely related they each have slightly different properties. Asbestos has been mined for more than 4,000 years, but it wasn't until the late 1800s that its use ballooned. Asbestos is used in manufacturing goods because it has many useful properties: excellent sound absorption; average tensile strength; resistance to damage from heat, fire, electrical and chemical damage; and it is economical. Asbestos was intentionally added to many products like insulation, floor and ceiling tiles, joint compound, caulk, brake pads, fire blankets, firefighter protective gear, roofing shingles, and drywall. Asbestos also occurs naturally in shallow deposits in at least 20 states. Asbestos can also naturally contaminate other common materials. The most notable is talc. In 2000, crayons made by Rose Art, Prang, and Crayola all tested positive for asbestos due to the use of talc. In June 2000, Crayola agreed to reformulate their crayons so that talc was no longer needed.
Let's get back to the local relevancy of asbestos. Since McCormick is our primary concern, we will start there. There were 151 samples taken of different materials from McCormick to be analyzed for any hazardous materials. Of the 151 samples, 21 contained at least a trace amount of asbestos. Sixty-six (66) of the total samples were taken from hard plaster surfaces around the building. Only five (5) of those 66 samples contained asbestos - four had a trace amount and one had a 0.25% concentration. The remaining 16 samples that tested positive for asbestos were found in black sink insulation, window glaze, caulk, mastic used on ceiling tiles, floor tile (only in the dark room within the art room), and duct wrap. Each of these has a concentration of between trace and 2.5%, except the duct wrap which has a concentration of 50%. This duct wrap only appears in the 1867 section, which would be demolished in the alternate plan. While most of the positive test results for McCormick show a concentration below 2%, the same cannot be said for the high school or Westwood, as we'll examine next.
There were 36 samples taken from Westwood, nine of which came back positive for Asbestos. The positive samples were found in duct insulation (in a mechanical/store room), pipe fittings, mastic used on floor tiles, and black sink insulation. The concentrations range from 1.8% for the mastic adhesive used for the floor tile to 60% in the duct insulation. The pipe fittings, located in a mechanical room and a classroom, registered 5.3% and 3.5%. The black sink insulation ranged from 4.2% to 4.8%. Keep in mind; the adhesive for the floor tile is probably the same throughout the 1960 and 1967 sections of the building, meaning most of the classrooms would contain asbestos under the floor tiles. Also, most classrooms in the building have a sink and most, if not all, are original and probably all have the same asbestos insulation around them.
At Wellington High School, 34 samples were taken and 13 tested positive for asbestos. Positive results were found in floor tiles, mastic for floor tiles, grey sink insulation, joint compound, and black sink insulation. The results show concentrations ranging from 2.3% for floor tile to 10% for grey sink insulation. Most likely, every floor tile that was originally installed contained some asbestos fibers and the adhesive used to glue them down also contained asbestos.
It seems interesting to me that 38% of the samples from the high school tested positive, 25% from Westwood tested positive, and only 14% of the samples from McCormick tested positive.
This report is significant in that a large portion of the projected renovation cost that the school district is using (provided by OSFC) is for removal of asbestos and other hazardous materials. The OSFC projected a cost of nearly $1 million in 2008. Of that total, nearly $700,000 would be for removal of all hard plaster in the 1916 and 1938 sections of the building. Is this really necessary? Let's look at the test results for the hard plaster:
Hard Plaster Test Results
1867 Section - No Asbestos Detected - Scratch and Skim Tests (Basement Storage #1, Cafeteria #1, RM 205, Kitchen, 2nd Floor Storage, Cafeteria #2, Basement Storage #2, RM 205/206 Hall #1, RM 206 #1, RM 205/206 Hall #2, RM 205/206 Hall #3, RM 206 #2)
1916 Section - No Asbestos Detected - Skim Test (South Art Room, North Stairwell, Media Center, RM 208, Basement Storage #2, 1st Floor Hall, RM 213)
1916 Section - No Asbestos Detected - Scratch Test (South Art Room, North Stairwell, RM 208, Basement Storage #2)
1916 Section - No Asbestos Detected - Drywall (RM 210)
1916 Section - No Asbestos Detected - Joint Compound (RM 210)
1938 Section - No Asbestos Detected - Skim Tests (1st Floor Auditorium, RM 215)
1938 Section - No Asbestos Detected - Scratch Tests (RM 215, 3rd Floor Hall, RM 111, RM 217, RM 114, RM 304)
1953 Section - No Asbestos Detected - Scratch and Skim Tests
1916 Section - Trace - Scratch Test (Media Center and RM 213)
1916 Section - 0.25% - Scratch Test (1st Floor Hall)
1938 Section - Trace - Skim Test (3rd Floor Hall)
1938 Section - Trace - Scratch Test (1st Floor Auditorium)
So with only five positive samples, one 0.25% and the rest just a trace, is it really necessary to remove all of the hard plaster? The Ohio School Design Manual contains the following text on asbestos:
A. Under Environmental Protection Agency (EPA), National Emission Standards for Hazardous Air Pollutants (NESHAP), and inspection for asbestos-containing materials (ACM) must be completed prior to renovation or demolition of a facility. While some of the information in this report can be used, the Enhanced Environmental Assessment prepared for the Ohio School Facilities Commission does not satisfy this inspection requirement.
1. The inspection for asbestos-containing materials must be conducted by an Asbestos Hazard Evaluation Specialist (AHES) licensed by the Ohio Department of Health.
2. To conduct this inspection, the AHES should be provided with the results of any previous sampling conducted for the District and will need to know whether or not the buildings or portions thereof will be demolished or renovated.
3. If the building will be demolished, the AHES will need to know if the design for demolition will include requirements to recycle building materials or portion thereof.
B. ACM is defined as those materials containing greater than 1% asbestos. Since OSHA still regulates the removal of materials containing less than or equal to 1% asbestos, OSFC policy is to treat all materials (even those containing less than 1%asbestos) as ACM.
C. Prior to collecting bids for the removal of ACM found during the inspection, an asbestos hazard abatement design must be prepared by an individual licensed by the Ohio Department of Health as an Asbestos Hazard Abatement Project Designer.
D. Generally, OSFC’s policy is that all asbestos-containing materials be removed prior to renovation work. Materials allowed to remain in a facility during demolition under NESHAP regulations not be removed. Regulatory requirements regarding removal of asbestos-containing materials include, but are not limited to, the following:
1. Under NESHAP, EPA mandates the following:
a. Demolition Work: regulated Asbestos-Containing Materials (RACM) must be removed. RACM includes the following: friable ACM (e.g., fireproofing and mechanical insulation); Category I nonfriable ACMs that become friable or will be subjected to sanding, grinding, cutting or abrading (e.g., non-intact/nonpliable resilient floor coverings and glazing compound); and Category II nonfriable ACMs (e.g., hard plaster, gypsum board and cement board) which have a high probability of becoming crumbled, pulverized, or
reduced to powder during the course of demolition work. Typically, Category I nonfriable ACM and pliable Category II nonfriable ACMs need not be removed prior to demolition work where standard demolition procedures and equipment are utilized (i.e., wrecking ball and cranes, bulldozer wrecking, explosions/ implosions, heavy equipment loading and materials handling, etc.).
1) Any Category I or Category II asbestos-containing material that becomes damaged from either deterioration or attempts at removal or abatement resulting in small fragments the size of four square inches or less shall also be considered friable or RACM.
b. Renovation Work: if a variance to OSFC’s policy regarding removal of all ACM is granted, NESHAP requires that ACM be removed prior to renovation if such work will disturb them.
2. In schools being renovated, abatement work shall also be conducted per EPA’s Asbestos Hazard Emergency Response Act which includes, but is not limited to, procurement of air samples following asbestos hazard abatement work prior to dismantlement of work areas.
3. Occupational Safety and Health Administration (OSHA) Standards require implementation of appropriate engineering controls and work practices for renovation and demolition work where ACM is present. These controls and practices include specific methods for removal of each type of ACM, air monitoring, appropriate personal rotective equipment, hygiene facilities, and proper containerization and disposal of asbestos waste. OSHA also regulates disturbance of materials which contain trace amounts (one percent or less) of asbestos. For removal of materials containing trace amounts of asbestos, OSHA requires air monitoring of employee exposures, use of wet methods, and proper containerization of waste. Therefore, for purposes of this report, material containing trace amounts of asbestos have been treated as if they are ACM.
4. Ohio Department of Health (ODH) regulations require that credentialed and licensed personnel be used for asbestos-related work (survey, design, abatement work, etc.).
The other peculiar thing to me involves the mastic (adhesive) used under the linoleum in the 1953 section. Six samples of this mastic were taken. Three of them tested negative for asbestos. However, the other three samples were not large enough to analyze so they are assumed to contain asbestos. Removal of this assumed asbestos containing material is then calculated into the renovation budget.
Disclaimer:This site is not affiliated with the Village of Wellington, Wellington Exempted Village School District, or Citizens for Wellington Schools. This site is privately owned and maintained and all expenses are paid for out of my own pocket. This portion of the website was created to bring all pertinent information to one place, because when I did my own research on the subject I found that the information being published is sometimes incomplete or incorrect. I have been careful to verify as much of my information as possible. The sources of my data can be found within the links on the Resources page.