HomeMy WebLinkAboutNavy North Hangar Fire_Above Ground Remediation Work Plan - July 2024WORK PLAN FOR ABOVE-GROUND INSPECTION AND REMEDIATION
OF FIRE-RELATED SUSPECTED ASBESTOS-CONTAINING MATERIAL
FROM DESIGNATED RESIDENTIAL NEIGHBORHOODS AND SCHOOLS
Former MCAS Tustin Navy North Hangar Fire
Prepared on Behalf of:
Navy North Hangar Fire Environmental Health Unit for
The City of Tustin, California, Acting as the U.S. Navy’s Response Action Contractor
July 11, 2024
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TABLE OF CONTENTS
1.0 Introduction ................................................................................................................................................... 3
2.0 Incident Background ...................................................................................................................................... 4
2.1 Regulatory Recommendation for Above-Ground Remediation .................................................................... 5
2.2 Asbestos ......................................................................................................................................................... 5
3.0 Proposed Area of Above Ground Inspection, Remediation .......................................................................... 6
4.0 Work Plan Announcement, Timing, and Scheduling Process ........................................................................ 7
5.0 Process For Above-Ground Inspection, Remediation ................................................................................... 7
5.1 Pre- and Post-Remediation Inspections ........................................................................................................ 8
5.2 Remediation Procedures ............................................................................................................................... 9
Safety, PPE, and other Hygiene Practices ...................................................................................................... 9
Cleaning Objective and Contractor Procedures .......................................................................................... 10
6.0 Waste Disposal ............................................................................................................................................. 11
7.0 Post-Remediation Quality Control Evaluation ............................................................................................. 11
8.0 Reporting ...................................................................................................................................................... 11
9.0 Points of Contact and Information Requests ............................................................................................... 13
ATTACHMENTS
Attachment A: Proposed Area of Above-Ground Inspection and Remediation
Attachment B: National Econ Corporation Scope of Work for Above Ground Inspection
Attachment C: ATI Restoration, LLC Residential Roofs Work Plan
Attachment D: Example Quality Control Visual Inspection Checklist
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1. INTRODUCTION
As a result of the Former MCAS Tustin Navy North Hangar Fire that occurred in November 2023, an
extensive seven-month ground-based inspection, collection, and remediation operation was performed
under emergency conditions by teams of asbestos abatement contractors and California Certified
Asbestos Consultants (“CAC”) under the supervision of a multi-agency Incident Response Command
(“Incident Command”) and federal, state, and county environmental regulators that included
representatives from the Orange County Fire Authority (“OCFA”), U.S. Environmental Protection Agency
(“USEPA”), South Coast Air Quality Management District (“South Coast AQMD”), Orange County Health
Care Agency (“HCA”), the City, and the U.S. Department of the Navy (“Navy”). Ground-based remediation
continues today but is nearing completion.
Because of rain and winds, fire-related debris and suspected asbestos-containing materials (ACM)
continues to migrate from above-ground structures to ground surfaces. The completion of the ground-
based remediation of suspected ACM will therefore be dependent upon an adequate reduction of visible
fire-related suspected ACM deposited on above-ground structures, such as roofs, gutters, balconies, and
other horizontal surfaces. This will be the last step in the Navy’s cleanup of suspected ACM at off-site
properties.
This operational Work Plan for Above-Ground Inspection and Remediation of Fire-Related Debris (herein
referred to as the “Work Plan”) was prepared on behalf of the Navy North Hangar Fire
Environmental/Health Unit for the City of Tustin (“City”) to implement, acting as the Navy’s Response
Action Contractor. The Work Plan will support offsite debris remediation operations for the Navy North
Hangar Fire and subsequent regulatory review and closure of these operations. The Environmental/Health
Unit recognizes that not every piece of fire-related suspected ACM can reasonably be recovered.
Additionally, it also recognizes that above-ground suspected ACM in many locations may have already
been blown to the ground and remediated during ground-level operations. Therefore, the objective of
this Work Plan is to remove visible suspected ACM from above-ground locations, in conjunction with
ongoing ground-level remediation, to mitigate risks to levels that are deemed by the
Environmental/Health Unit to be sufficient to protect human health and the environment and bring
closure to the response action.
The objectives of the proposed Work Plan include:
1. Define the target region for receiving above-ground inspection and remediation,
2. Provide an overview of the process for notification and requesting inspection and remediation,
3. Establish the inspection and remediation scope of work to be carried out at each structure, and
4. Define the endpoints of the inspection and remediation operations and reporting.
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2. INCIDENT BACKGROUND
On November 7, 2023, a 17-story wooden former WWII blimp hangar located at former MCAS Tustin near
Armstrong Avenue and Valencia Avenue caught fire. The Navy North Hangar and immediately
surrounding former MCAS property are owned by the Navy. The Navy previously identified various ACM
present in the Navy North Hangar structure that primarily included transite (asbestos/cement) paneling
and felt roofing underlayment. The Navy North Hangar fire spread debris and suspected ACM convection
through the air across nearby residential and commercial areas. The Navy North Hangar burned for
approximately one week and reignited several times while it smoldered for 24 days.
The OCFA coordinated all fire management operations and declared the Navy North Hangar fire to be
extinguished on December 1, 2023. Both the City of Tustin and County of Orange issued proclamations
of emergency on November 9, 2023, which continue today.
A multi-agency Incident Command was established in response to the emergency to coordinate response
efforts for the Navy North Hangar fire. The Incident Command included representatives from OCFA,
USEPA, South Coast AQMD, HCA, the City, and Navy. Additionally, the Navy North Hangar Fire
Environmental/Health Unit (“Environmental/Health Unit”) was established within the Incident Command
to oversee and review environmental and public health issues. The environmental regulators within the
Environmental/Health Unit provided guidance on the protocols and scope of remedial activities for the
debris in affected schools and residential areas. The Environmental/Health Unit assisted daily, and in real
time, with developing and implementing a strategy to monitor and sample the air at the Navy North
Hangar site and in the surrounding residential areas from the start of the emergency through today. The
Environmental/Health Unit has included representatives from USEPA, AQMD, HCA, City, Navy, and
California Department of Toxic Substances Control (“DTSC”).
Extensive (i.e., daily) air monitoring performed from November 2023 through June 2024 at locations
around the Navy North Hangar site, including impacted Tustin neighborhoods, demonstrate no airborne
asbestos fibers have been detected as a consequence of the fire. All Tustin schools have been inspected
by CACs, remediated (below rooftops), and re-opened. primarily After the OCFA declared the fire
“extinguished” on December 1, 2023, a series of wind and rain events caused fire-related debris and
suspected ACM located in gutters, on rooftops, and on other above-ground structures to fall to the
ground, including areas previously remediated. This debris and suspected ACM was identified during
ongoing ground-level re-inspections in residential areas adjacent to the Navy North Hangar site following
wind and rain events, which prevented CACs from certifying that Tustin properties previously remediated
by ground-level emergency response teams remained clean.
On January 26, 2024, USEPA and AQMD recommended that an above-ground inspection of structures in
areas surrounding the Navy North Hangar site be performed to allow the Environmental/Health Unit to
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evaluate the health and safety risks from future recontamination by above-ground debris. Between
January 26 and February 1, 2024, the City’s emergency management contractor, Innovative Emergency
Management (IEM), performed an above-ground inspection of roofs and gutters at thirteen locations,
including two neighborhoods adjacent to the incident site, six Tustin Unified schools, the Annex at Tustin
Legacy, Columbus Square Community Center, and OCFA Fire Stations 21, 26, and 79. The results of this
exterior above-ground inspection were included in an Exterior Top-Down Inspection Evidentiary Package,
dated February 16, 2024, which was provided to the Environmental/Health Unit on February 20, 2024.
This inspection identified visible fire-related debris and suspected ACM on above-ground structures at
approximately half of the home rooftops inspected, on all of the school rooftops inspected, on the rooftop
of the Annex at Tustin Legacy, on the Columbus Square Community Center rooftop, and on each of the
OCFA Fire Station rooftops inspected.
2.1 Regulatory Recommendation for Above-Ground Remediation
On February 28, 2024, DTSC sent a letter to the Environmental/Health Unit following its review of the
Exterior Top-Down Inspection Evidentiary Package Report, acknowledging that the above-ground
inspection results indicated that suspected ACM and fire-related debris still exists on above-ground
structures in sufficient quantities that additional removal work is recommended. DTSC also acknowledged
that while fire-related debris and suspected ACM may have been significantly reduced because of ground-
based remediation efforts, further above-ground efforts may be necessary to ensure the risk of future
exposure to the debris is mitigated appropriately. DTSC’s recommendation is that an implementation
plan be developed for above-ground removal actions to mitigate the potential risk of ongoing migration
to the ground.
2.2 Asbestos
Asbestos is a naturally occurring thin, fibrous mineral with high tensile strength that exists in many
different forms (i.e., amosite, chrysotile, crocidolite, and fibrous varieties of tremolite, actinolite, and
anthophyllite) and has historical application in many manufactured products, including building materials,
heat-resistant fabrics, and friction products.1 Asbestos fibers do not have a detectable odor or taste and
do not evaporate into air or dissolve in water.
Exposure to asbestos may occur from both natural and anthropogenic (i.e., human-generated) sources,
with potential adverse health effects being contingent on the factors of dose, exposure duration, and fiber
type and size. Asbestos exposure at high levels over long periods of time can produce adverse health
effects, such as increased risk for scarring, plaque development, and cancer in lung tissue.2 To mitigate
unnecessary asbestos exposure and protect cleanup crews as well as the general population, guidelines
1 https://www.atsdr.cdc.gov/toxprofiles/tp61.pdf
2 https://publications.iarc.fr/Book-And-Report-Series/Iarc-Monographs-On-The-Identification-Of-Carcinogenic-
Hazards-To-Humans/Asbestos-1977
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such as of those presented by the USEPA Asbestos National Emission Standard for Hazardous Pollutants
(NESHAP; 40 CFR Part 61, Subpart M) promote proper cleanup of ACM following emergency events.3
3. PROPOSED AREA OF ABOVE GROUND INSPECTION, REMEDIATION
The Navy North Hangar burned for approximately one week and reignited several times while it smoldered
for 24 days. Debris was spread via air across nearby residential and commercial areas. Areas of
remediation operations for this Work Plan were selected based ground-level debris investigation and
remediation operations conducted during response efforts, and proximity to the Navy North Hangar.
IEM has created maps that illustrate the ground-level remediation requests received to date, as well as
the expected areas for above ground inspection and remediation (Attachment A). This area includes the
following:
Columbus Square, including Coventry Court
Tustin Meadows and Cherrywood Estates
Centennial and Veterans Sports Park
The Landing
Anton Legacy Apartments
Amalfi Apartments
All Schools and Fire Departments listed within the initial evidence gathering that was performed
that contained suspected ACM upon inspection. (OCFA Fire Stations 21, 26, 37, 79. Tustin Unified
Schools Heritage, Legacy, Beswick, Hillview, Sycamore, and Tustin High/ Elementary)
Within these listed areas, inspection and remediation operations have the potential to address up to 3,522
residences, including:
1,625 Single-Family Homes, and
1,897 Multi-Family Homes
Additionally, the areas noted above contained the largest amounts of debris from the fire and had the
highest number of public reports to the City’s incident response website. As noted in Attachment A, of
the 1,354 requests for ground-level remediation that have been received, 1,163 (86%) are within the areas
noted above.
3 https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-61/subpart-M
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4. WORK PLAN ANNOUNCEMENT, TIMING, AND SCHEDULING PROCESS
The City’s emergency management contractor, IEM, will develop a public outreach strategy to announce
this Work Plan to property owners/tenants in the targeted areas noted in Section 3 who are interested in
having above-ground structures on their property inspected/remediated. It should be noted that above-
ground inspection and remediation will be performed on a “by request” basis and will be a completely
voluntary and complementary service.
It is anticipated that a 14-day enrollment period will initiate this Work Plan, beginning with the
aforementioned outreach strategy, as well as intake and scheduling. This timeline is subject to change
depending on levels or participation by property owners/tenants in the program. A flyer campaign in the
selected area will be initiated to communicate with residents. This would allow for residents to use a
provided QR code to enroll online for the service. Once the request is received, it would be verified to be
within the outlined area and then set into the cue for field staff to service.
Before the main inspection/remediation effort begins, there will be a set-up phase which would include
the standardization of the process, proper documentation, and equipment facilitation guidelines. This
would allow for all supervisors and inspectors from remediation and CAC companies to get properly
trained and familiarized with the expected operation to allow for proper dissemination across all teams
before they begin.
Once underway, above-ground inspection and remediation of enrolled properties is anticipated to be
completed within a 90-day period. Once the amount of residences requesting the above-ground
inspection service are identified, contractors will be able to scale according in order to meet the 90-day
window. IEM has created a Site Evaluation form that will be utilized by remediation supervisors the day
prior to showing up to a residence. This form will require the remediation supervisor to detail the property
with information such as (1) does it contain gutters? And (2) is it a single-family, single-story home? The
remediation contractor will be required to take photos of the property and outline any specific equipment
needed in order to perform the service. This process will streamline the fielding of teams and equipment
and reduce the amount of overall wasted time and material for the effort. Progress will be tracked by
IEM and a dashboard created in order to display overall progress.
5. PROCESS FOR ABOVE-GROUND INSPECTION, REMEDIATION
National Econ Corporation (“National Econ”; CAC contractor) and ATI Restoration (“ATI”; remediation
contractor) and other contracted CACs will performing the above-ground inspection and remediation
work. Work plans developed by National Econ and ATI for these activities are provided as Attachment B
and Attachment C.
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Above-ground inspection and remediation work protocols will not involve workers walking on pitched
residential roofing because of the risks of falling and man-made damage to roofing, tiles, and gutters.
Appropriate lifts and safety equipment will be utilized. Residents and property owners will need to
provide permission to access their roofs, and the City anticipates some residents may be reluctant to
provide permission to perform work if there is a risk of human harm and property damage. Further, the
City’s emergency management contractor, IEM, has extensive experience working with the community
on ground-based remediation and indoor studies. IEM will be available to implement the access requests
necessary to perform the anticipated above-ground work, and it will work with incoming staff to train
them on already-existing and in-use systems. IEM will perform public outreach functions and solicit the
necessary access agreement from interested Tustin residents. The City will also facilitate access to the
roofing of Tustin Unified School District schools.
Operations to remove visible suspected ACM from rooftops, gutters, and above-ground structures must
involve, as necessary, the input of a CAC to determine the design and inspection protocols. Per Cal/OSHA’s
Division of Occupational Safety and Health, certification is required by Title 8, California Code of
Regulations, Article 2.6, Section 341.15 for individuals who contract to provide health and safety services
for asbestos-related work (projects involving more than 100 square feet of asbestos-containing
construction material).4
5.1 Pre- and Post-Remediation Inspections
Prior to debris-removal operations, National Econ will perform a visual inspection of identified properties,
structures, and surfaces to determine if visible suspected ACM debris is present. This task will be
accomplished utilizing lifts suitable to the needs of the work. The inspection will include photos of the
address and above-ground structures such as roofs, gutters, and all other external areas where services
may be performed. The contractor will also document the locations where they will be staging equipment
to ensure that no damage is caused to properties. The various types of equipment may include:
Scissor lifts
Boom lifts
Ladders
Bakers scaffolding
National Econ will observe contractors performing removal of suspected ACM and provide post-
remediation inspections upon completion of all designated suspected ACM removal and cleaning to
determine if more above-ground cleaning needs to be performed or the work is completed and a property
is deemed sufficiently remediated. The inspections, noting the acceptance of the work performed, will be
documented in coordination with IEM. National Econ’s scope of work is provided as Attachment B.
4 https://www.dir.ca.gov/databases/doshcaccsst/caccsst_query_1.html
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5.2 Remediation Procedures
Safety, PPE, and other Hygiene Practices
Cleaning activities must begin with proper personal protective equipment (PPE) and hygiene practices
performed by remediation personnel. At a minimum, remediation personnel will be required to wear:
Company identification / uniform,
Safety Vest
Disposal, nitrile gloves (when appropriate for the task), and
Other PPE as required in the scope of work.
Cleaning personnel must use all prescribed PPE following OSHA regulation 29 CFR 1910.132 – General
Requirements and all other applicable regulations contained in 29 CFR 1910 Subpart I – Personal
Protective Equipment.5,6
Cleaning personnel should also employ good hygiene practices during the cleaning process, to include
proper donning/doffing of PPE, avoiding touching eyes, nose, and mouth with unwashed hands, and
practicing hand hygiene upon doffing gloves. PPE should be discarded as contactors are vacating
properties.
Compliance with regulatory requirements is important to minimize or prevent exposure to asbestos.7,8
The contractor performing work must abide by applicable regulations, including U.S. Department of
Transportation (“DOT”), and Occupational Safety and Health Administration (“OSHA”) requirements that
may apply. Staff working on-site will need to possess at a minimum an OSHA-10 certification and any
workers utilizing a lift must have received proper lift safety/operator training.
Each morning a safety brief with all staff working will need to be conducted to ensure that all operational
and safety protocols are reinforced daily. This will also allow for changes to be briefed and any
observations from the field to be voiced and heard for proper dissemination to all those on-site. Please
see the entirety of the Site-Specific Safety Plan for the Navy North Hangar Fire response for additional
safety topics, including:
Emergency evacuation
Injuries and incidents protocol
Sign-in, job hazard analyses (JHA), and daily safety meetings
Key personnel
5 https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-I/section-1910.132
6 https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-I?toc=1
7 https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926SubpartT
8 https://www.govinfo.gov/content/pkg/CFR-2011-title40-vol8/pdf/CFR-2011-title40-vol8-part61-subpartM.pdf
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Vehicles and traffic control
Illumination
Employee medical surveillance
Air monitoring
Decontamination
Heat stress monitoring
Extended shifts policy
Working near apartments, commercial, residential, and school rooftops present unique hazards and
challenges. All remediation cleanup teams must avoid mounting or stepping on peaked rooftops of
residential homes and homes with breakable tiles. HEPA vacuums can be equipped with extensions that
allow teams to better reach and remediate portions of roofs that cannot be accessed readily without
walking on roofs. It is not expected every area of a roof can be reasonably and safely accessed, and before
deviating from established inspection and remediation protocols, the contractor must first collaborate
with IEM and the City and obtain their concurrence. The objective of this Work Plan is to undertake a
reasonable inspection and cleanup of accessible portions of above-ground structures that possess
significant amounts of fire-related suspected ACM consistent with worker safety.
Additional discussion of safety precautions for above-ground remediation are also provided in a
Residential Roofs Work Plan developed by ATI Restoration, LLC, which is included as Attachment C.
Cleaning Objective and Contractor Procedures
The objective of above-ground remediation is to reduce the overall mass of fire-related suspected ACM
to levels that the Environmental/Health Unit concludes are sufficient to be protective of human health
and the environment. To achieve this, ATI Restoration, LLC has developed a Residential Roofs Work Plan,
which is included as Attachment C. This plan covers the methods of removal, safety precautions,
employee qualifications, what to do in case of an emergency, and other key components.
Wet methods will be utilized throughout the process of collecting debris. HEPA-filtered vacuum cleaners
may be utilized to collect visible suspected ACM where it exists.1 The filtered vacuum cleaner or debris
collector should meet the requirements of 40 CFR 61.152.1,9 Once a rooftop is inspected and remediated,
as appropriate, the contractor should proceed to work from the top of the residence (e.g., rooftop,
gutters) downward, removing fire-related suspected ACM located on windows, windowsills, balconies,
awnings, and other horizontal above-ground surfaces.
9 https://www.govinfo.gov/content/pkg/CFR-2010-title40-vol8/pdf/CFR-2010-title40-vol8-sec61-152.pdf
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6. WASTE DISPOSAL
Suspected ACM debris that is collected will be placed into appropriate plastic bags which will be double-
bagged and goosenecked for transportation and disposal in accordance with standard asbestos
abatement practices. All suspected ACM debris waste will be secured and relocated to a designated
staging area on Navy property (Buildings 20A and 161) located near the Navy North Hangar for future
disposal by the Navy in accordance with applicable regulatory requirements. The Navy maintains a nearby
temporary and compliant storage facility to handle the fire-related suspected ACM waste and will perform
the necessary disposal of above-ground suspected ACM as part of its remediation of the remaining on-
site and non-dispersed debris and ACM at the Navy North Hangar site. Once properly disposed of at an
appropriate disposal facility by the Navy, the Navy’s contractor will provide all waste manifests
documenting the transportation and disposal.
7. POST-REMEDIATION QUALITY CONTROL EVALUATION
As a quality control measure, a minimum of 20% of remediated properties will be evaluated by an
independent CAC from the pre- and post-mediation inspections. The property selections will be
randomized, as much as is feasible based on available applicable properties, on a daily basis to ensure a
representative sample. All CACs performing quality control surveys will follow all safety, PPE, and hygiene
practices as established by this Work Plan for each property inspection. An inspection checklist will be
utilized, covering key areas pending accessibility such as but not limited to, roof, gutters, landscaping,
front and back lawns, trees, driveway, and porches. An example quality control visual inspection checklist
is provided as Attachment D. Any property with suspected ACM debris identified through the quality
control survey will trigger a review of the remediation procedures and may necessitate additional
remediation. CAC inspectors will follow a similar process as the pre- and post-remediation inspectors by
documenting their findings with detailed notes and photographic evidence, which will be submitted in
coordination with IEM to the City of Tustin or their representatives prior to leaving the property.
Continuous feedback will be provided to the cleaning teams on a daily basis to maintain and enhance
cleaning quality across all properties.
8. REPORTING
To support regulatory review, a report will be prepared following completion of the above-ground
inspection and remediation operations performed in accordance with this Work Plan. The report, which
will be reviewed by the Environmental/Health Unit, will demonstrate that cleanup operations have met
the objectives in this Work Plan and that the offsite remediation operations for the Navy North Hangar
Fire are sufficient for a regulatory determination of response complete.
The post-cleanup report following completion of this Work Plan will include:
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Summary of community outreach efforts to announce this Work Plan to property owners/tenants
for having their property inspected/remediated.
A detailed account of the inspections and cleanup activities conducted.
Details on the handling, transportation, and disposal of collected debris.
Description of QA/QC procedures implemented to ensure data integrity and reliability.
Request for regulatory approval of conditional closure of offsite remediation operations.
Appendices with supporting documents including maps, photographs, and waste manifests. If
manifests are not available from the Navy at the time the report is prepared, they will be provided
separately once available as an addendum to the report.
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9. POINTS OF CONTACT AND INFORMATION REQUESTS
The following representatives will be available to answer questions in connection with this Work Plan.
CTEH Representative
Christopher Kuhlman, PhD, CIH, DABT
Senior Toxicologist
Director, ER Sciences
CTEH, LLC
5120 Northshore Drive
North LiƩle Rock, AR 72118
ckuhlman@cteh.com
501-247-3871
IEM Representative
Spencer Kostus
Project Manager
IEM
c/o City Manager’s Office
City of TusƟn
300 Centennial Way
TusƟn, CA 92780
spencer.kostus@iem.com
(Cell)
City Representative
Ken Piguee
Senior Management Analyst
Economic Development Department/City
Manager’s Office
City of TusƟn
300 Centennial Way
TusƟn, CA 92780
kpiguee@tusƟnca.org
714-573-3316
Attachment A:
Proposed Area of Above-Ground Inspection and Remediation
N
Legend
= Cleared Address
= Hangar
Anticipated Area for Above-
Ground
Inspection/Remediation
•This map is representing all
requests for ground-level
remediation that was received to
date. As shown, this area was the
most requested and also contained
the highest concentrations of ACM.
•Total Requests Received: 1354
•Total Received within outlined
perimeter: 1163
** 86% of requests of all
requests received are within
outlined perimeter**
Residential Area for Above-Ground
Inspection/Remediation
This option would include the following:
•Columbus Square
•Tustin Meadows/ Cherrywood Estates
•Centennial and Veterans Sports Park
•The Landing
•Anton Legacy Apartments
•Amalfi Apartments
•All Schools and Fire Departments listed within the
initial evidence gathering that was performed that
contained suspected ACM upon inspection. (OCFA
Fire Stations 21, 26, 37, 79. Tustin Unified Schools
Heritage, Legacy, Beswick, Hillview, Sycamore, and
Tustin High/ Elementary)
•Total Single Family Homes- 1,625
•Total Multi Family Homes- 1,897
•Total Possible Residences- 3,522
•Time to complete will be scaled at the appropriate
level to meet 90-day operational period. All schools
will be completed in coordination with TUSD and
prioritized on the weekends until complete.
Attachment B:
National Econ Corporation Scope of Work for Above Ground Inspection
NATIONAL ECON
C O R P O R A T I O N
E N V I R O N M E N T A L C O N S U L T I N G & T R A I N I N G
June 19, 2024
City of Tustin
300 Centennial Way
Tustin, CA 92780
Re: Section 10. MISCELLANEOUS PROVISIONS, Items 10.2 Integrated Agreement. and 10.3
Amendment. of the Certified Asbestos Consultant (“CAC”) Service Agreement, Purpose
and Scope of Work
To Whom It May Concern,
As requested, and in compliance with, Section 10. MISCELLANEOUS PROVISIONS, Items 10.2
Integrated Agreement. and 10.3 Amendment. of the Certified Asbestos Consultant (“CAC”) Service
Agreement, the information on the attached page is submitted by National Econ Corporation for
review, consideration, agreement and subsequent addition to the original contract with the City of
Tustin, as an amendment to the Purpose and Scope of Work:
We trust that this amendment to the agreement will meet with your approval. Should you have
any questions, please feel free to contact our office at (714) 978 -6320.
Sincerely,
National Econ Corporation
Mark S. Ervin, President
Certified Asbestos Consultant #92-0141
CDPH Lead Inspector/Assessor #705
25th
anniversary
1899 S. Santa Cruz Street, Anaheim, CA 92805
Tel: 714•978•6320 Fax: 714•978•6323 Email: office@nationalecon.com Website: nationalecon.com
Labor Rates and Charges: Additional Rates Related to “Top Down” Phase
These additional rates are an “amendment” to the original contract. Other tasks listed or stated in the
original contract and not mentioned here remain unaffected and remain in effect.
“Top Down” Phase Clearance Visual Inspection Only
° Commercial/Public
• Commercial property, schools, apartments or public/private right of ways will
be charged to and paid by the City at an hourly rate of $165.00 for all hours
of a shift. In addition, if requested or determined necessary, all costs
associated with collection, documentation, delivery of samples to the
laboratory, reporting of sample results and/or other costs incurred shall be
charged to and paid by the City as noted in the original contract.
° Residential (Exterior Only)
• Single Family property completed during a single shift will be charged to and
paid by the City at a flat rate of $1,900.00 per task. A “task” is defined in the
original contract. In addition, if requested or determined necessary, all costs
associated with collection, documentation, delivery of samples to the
laboratory, reporting of sample results and/or other costs incurred shall be
charged to and paid by the City as noted in the original contract.
• Single Family property taking more than a single shift to complete will be
charged to and paid by the City at an hourly rate of $165.00 for all hours over
multiple shifts to complete the task. In addition, if requested or determined
necessary, all costs associated with collection, documentation, delivery of
samples to the laboratory, reporting of sample results and/or other costs
incurred shall be charged to and paid by the City as noted in the original
contract.
Explanation of Terms not included in the original contract.
Shift - A shift begins 15 minutes before official start time and 15 minutes after the handing in of
equipment provided by the City or its representatives , by NEC personnel. Time taken for lunch break
will not be charged during a shift.
Top Down – This is reference to the inspection of a property prior to, during and after abatement of
materials known or suspected to be asbestos containing materials or contaminated by asbestos
containing materials by a third party. These services will include the visual inspection of accessible
areas of roofs, gutters, other roof related surfaces (excluding vertical interior areas of gutter down
spouts which cannot be reached or seen visually from the exterior and with the gutter downspout in
place), as well as, all other below roof level surfaces as performed in previous
commercial/public/residential clearance inspections.
Mechanical Equipment – All mechanical equipment necessary to gain access to roofs or elevated
surfaces/areas and necessary to remove identified debris and materials from surfaces will be provided
by a third party and are not the responsibility of NEC.
Additional Information for Clarification of Roles, Practices and Procedures
Work will be performed under the direction of Innovative Emergency Management (IEM) and the City
of Tustin. The scope of the work National Econ Corporation (NEC) will perform includes but is not
limited to:
• Pre-inspections of identified properties, structures and surfaces to determine if debris is
present which may be suspect for containing or being contaminated by asbestos containing
materials. This task will be accomplished utilizing lifts (supplied and operated by a third party
contractor, not NEC) suitable to the needs of the work.
• Observation of contractors performing removal of materials determined to contain or be
contaminated with asbestos and post inspections for the purposes of confirming identified
materials have been removed and the property is cleared.
• Post-inspection upon completion of all designated removal and cleaning by the contractor to
determine if more cleaning needs to be performed or the work is completed and the property
is cleared. The acceptance of the work will be documented utilizing IEM provided “tablets” by
filling out all required information particular to the site and submit ting that information
electronically.
• In addition, NEC will provide (as needed) additional reports, consultations , sampling, etc. as
outlined in the original contract with the City.
Employees of NEC will follow all asbestos procedures as they have been since the start of the
operation. This includes following all donning and doffing protocol s included in the Site Specific Safety
Plan for the project. NEC inspectors will provide at a minimum 2 photos (one of the front and one of
the back) per property for additional documentation as required.
Employees of NEC will continue to attend all required morning briefings, meetings, specified project
trainings or other field necessary tasks to fulfill the requirements of the project. All NEC inspectors
assigned to the project to perform inspections will be current licensed CAC’s or CSST’s by the State of
California and hold current training certificates or training documentation in subjects and
requirements (as needed) specific to the project or in compliance with current applicable OSHA
regulations.
Attachment C:
ATI Restoration, LLC Residential Roofs Work Plan
DISASTER RECOVER Y SERVICES
Work P lan
CATA ST R O P H E S E R V IC ES
LIFE, REBUILT
WITH CA RE.
( 800 ) 40 0 - 935 3
www.AT Ire st o ra t i o n .co m
Page 2 of 7
Residential Roofs Work Plan
Tustin Hangar 1 Date:
01/27/2024
ATI Restoration, LLC
Plan to clean the roofs of residential houses Revision: 1 Total pages: 7
Contents
PURPOSE........................................................................................................................................................1
ACCESS TO ROOFS AND GUTTERS.....................................................................................................................1
A-frame Step and Extension Ladders...................................................................................................... 1
Boom Lifts ................................................................................................................................................ 3
SCOPE OF WORK .............................................................................................................................................3
EMPLOYEE QUALIFICATIONS............................................................................................................................4
PERSONAL PROTECTIVE EQUIPMENT (PPE) .......................................................................................................4
RESCUE PLAN .................................................................................................................................................5
SAFETY TIPS FOR BOOM LIFTS ..........................................................................................................................5
POWERLINES AND BARRICADES .......................................................................................................................6
WEATHER.......................................................................................................................................................6
ADDITIONAL RESOURCES .................................................................................................................................7
PURPOSE
At ATI Restoration, LLC (ATI), the safety and well-being of our team are the most important aspects of
our work. This plan is specifically focused on the removal of Presumed Asbestos Containing Material
(PACM) debris from the roofs and gutters of resident’s houses. This plan will go over the methods of
removal, safety precautions, what to do in case of an emergency, and other key components. ATI aims
to not step foot on any of the roofs as much as possible. Instead, ladders and boom lifts will be utilized
to put employees in a position to reach the debris. ATI will not drill any holes into any of the roofs out in
the community, rendering most traditional anchorage devices obsolete.
ACCESS TO ROOFS AND GUTTERS
All of the roofs and gutters around the community can be reached by utilizing either a ladder or a boom
lift. ATI will be utilizing both A-frame step ladders and extension ladders. As well as articulating boom
lifts and telescopic boom lifts.
A-frame Step and Extension Ladders
Page 3 of 7
A-frame step ladders will be used only when there is an adequate amount of space for the legs on the
ground. These ladders can be set up on side yards and in the front/back of the buildings to access the
gutters around the perimeter of the building. Extension ladders will be used in conjunction with the A-
frame step ladders. The extension ladders will allow employees to access gutters around the perimeter
of the buildings that do not have much ground space below.
Page 4 of 7
Key things to remember for ladders:
1. Choose the Right Size : Ensure that the ladder is tall enough to reach the gutters without
overreaching.
2. Inspect the Ladder: Before each use, inspect the ladder for any signs of damage or defects.
Check for loose screws, cracks, or bent parts that could compromise its stability.
3. Set Up on a Stable Surface : Place the ladder on a firm, level surface. Avoid soft or uneven
ground that could cause the ladder to wobble or tilt.
4. Angle Matters: When setting up the ladder, follow the manufacturer's guidelines regarding the
angle of inclination. Typically, the base of the ladder should be about one-quarter of the working
length of the ladder away from the wall or gutter.
5. Locking Mechanisms: Ensure that the ladder's locking mechanisms are engaged properly
before climbing. This prevents accidental collapses while you're on the ladder.
6. Maintain Three Points of Contact : Always maintain three points of contact with the ladder
while climbing – two hands and one foot or two feet and one hand. This provides stability and
reduces the risk of falls.
7. Don’t go on the Top Two Steps: Employees are not permitted to step on the top two steps of
any ladder they are using.
8. Face the Ladder: Always face the ladder while climbing up or down. Avoid leaning too far to the
side, as this could cause the ladder to tip over.
9. Use a Tool Belt: If you need to carry tools or materials while on the ladder, use a tool belt or
pouch instead of carrying them in your hands. This keeps your hands free for climbing and
provides better balance.
10. Don't Overreach: Avoid overreaching while on the ladder. If you can't reach a certain area
comfortably, reposition the ladder instead of stretching dangerously.
11. Weather Considerations: Be mindful of weather conditions, especially wind. Strong gusts can
destabilize the ladder, so avoid working on the ladder during windy conditions.
12. Don't Leave Unattended: Never leave the ladder unattended while it's set up, especially if
there are children or pets around who could climb on it unsupervised.
13. Descend Carefully: When descending from the ladder, do so slowly and carefully. Maintain
three points of contact until both feet are securely on the ground.
Photo of an A-frame ladder being used to reach the gutters of a building.
Page 5 of 7
Boom Lifts
Boom lifts will be utilized for reaching the middles and tops of roofs as necessary. They will also be
used to reach second and third layers of gutters on the roofs if there are any. Employees will be
wearing a fall protection harness and will be attached to the boom lift basket by either a lanyard or a yo-
yo self-retracting lifeline. Employees are not permitted to step outside of the boom lift basket onto any
pitched or sloped roofs. Employees are only permitted to step onto a flat roof at any given time, so long
as they are tied off to an anchor point, such as a boom lift basket.
Key guidelines for boom lifts:
• Only authorized individuals will be allowed to operate the boom lifts
• Only 2 people in the boom lift at one time.
• Boom lifts will be inspected when they are dropped off by the rental company
• No work will be done under the boom lift arms or baskets
• Boom lifts will stay on the street or driveways of resident houses
• Boom lifts will be used to give employees access to middle parts of the roofs or high gutters
• All boom lift mechanics will be checked before each use
• Whenever a boom lift is moving on a public road, there will be a vehicle in front and behind of
the boom lift caravanning with the lift
• Employees will be tied into the basket by utilizing either a 6 ft lanyard or self-retracting lifeline
Below is a photo of one of the boom lifts being used.
SCOPE OF WORK
Work will be performed under the direction of Innovative Emergency Management (IEM) and the City of
Tustin. The scope of this work is to verify that there is no additional PACM present on roofs or within
gutter systems. ATI personnel will be directed by IEM as to which buildings to attend to and then the
CAC or Hygienist will sign off on that building being cleaned. Employees will follow all asbestos
procedures as they have
Page 6 of 7
been since the start of the operation. This includes following all donning and doffing protocol that is
included in the Site Specific Safety Plan for the project.
Water misting per SCAQMD will be utilized throughout the process of collecting debris. HEPA
vacuums and double bagging will also continue to be implemented. Homeowners and residents will be
encouraged to stay inside their houses or apartments while the debris removal is taking place. This
will only help prevent accidental exposure to PACM.
EMPLOYEE QUALIFICATIONS
All employees who are operating the boom lifts are to have up to date MEWPS certifications. Every
employee has either the Asbestos 32-hour worker course or the Asbestos 40-hour supervisor course
completed. Each employee operating the boom lifts will also have their boom lift or MEWPs
certification.
After the initial morning safety meeting and stretches, the crews going on the boom lifts will have their
own safety meeting near the boom lifts. This meeting will consist of checking all of the fall protection
equipment and going over the work plan for the day.
PERSONAL PROTECTIVE EQUIPMENT (PPE)
PPE for abatement is necessary 100% of the time. There will be a 0 tolerance for employees who do
not follow PPE protocol. The PPE needed is as follows:
• ½ face Respirator with P100 filters
• Coveralls
• Safety Vests
• Hard Hats
• Safety Glasses
• Cut Resistant Gloves
• Safety Shoes / Boots
• Fall Protection Harnesses (For boom lifts)
• Fall Protection Lanyards / Yo -yos (For boom lifts)
Below is a photo of an employee with their PPE on for the boom lifts.
Page 7 of 7
RESCUE PLAN
In the event that a worker falls off of the boom lift or roof and is dangling by their harness, the following
steps will be taken immediately:
1. Notify supervisor and EHS right away (There will be a supervisor and a member of the EHS
Team there already).
2. Dial 9-1-1 and ask for paramedics if necessary.
3. The other employee up there will safely and swiftly lower basket down to the ground, allowing
the dangling employee to return to the ground.
4. All employees on site will stop work.
5. The employee who was rescued will be given immediate first aid as necessary until the
paramedics arrive to do a thorough evaluation.
6. Once the employee who was rescued has been taken care of, there will be another safety
meeting with everyone still onsite. We will go over the situation that happened, what steps need
to be taken to avoid it going forward, and answer any questions that the crew has.
7. A thorough investigation will be conducted by the EHS Team that will include pictures,
interviews of witnesses, an evaluation of the work area, and anything else related to the
incident.
SAFETY TIPS FOR BOOM LIFTS
Below are safety tips for operating a boom lift. Operators will go over these each morning:
1. Proper Training: Only trained and certified operators should operate a boom lift.
Comprehensive training should cover equipment operation, safety procedures, and emergency
protocols.
2. Pre -Operation Inspection: Before using the boom lift, conduct a thorough pre-operation
inspection to check for any damage, leaks, or malfunctions. Ensure all safety devices, including
harnesses and guardrails, are in good working condition.
3. Stable Ground: Set up the boom lift on firm and level ground. Use outriggers and stabilizers as
needed to increase stability.
4. Weight Limit: Never exceed the boom lift’s maximum weight capacity. Consider the combined
weight of operators, tools, and equipment to stay within the safe limits.
5. Harness and Personal Protective Equipment (PPE): Always wear a full-body harness and
attach it to the boom lift’s designated anchor point. Additionally, wear appropriate PPE, including
a hard hat, safety glasses, gloves, and high-visibility clothing.
6. Clear Work Area: Ensure the work area is clear of obstacles and people. Keep bystanders and
non-essential personnel at a safe distance during operation.
7. Weather Conditions: Avoid operating the boom lift during adverse weather conditions such as
high winds, storms, or lightning.
8. Smooth Movements: Make slow and controlled movements with the boom lift. Avoid abrupt
starts, stops, or rapid movements to maintain stability.
9. Be Mindful of Overhead Hazards: Watch for overhead obstacles such as power lines,
branches, or other structures. Maintain a safe distance from these hazards.
10. Stay on the Platform: Never stand or climb on the guardrails or attempt to reach outside the
platform while the boom lift operates.
11. Communication: Establish clear communication between the operator and ground personnel.
Use hand signals or two-way radios to convey important information.
Page 8 of 7
12. Emergency Procedures: Familiarize yourself with the emergency procedures for the specific
boom lift model you are operating. Know how to lower the platform in case of power failure or
other emergencies.
13. Battery/Energy Source Safety: If batteries power the boom lift, follow the manufacturer’s
guidelines for charging, storage, and handling of batteries. For fuel-powered lifts, handle fuel
safely and keep fuel containers away from ignition sources.
14. Travel with Boom Lowered: Lower the boom and secure all equipment before moving the lift
to a new location. Avoid moving the boom lift with the platform raised.
15. Parking and Storage: When not in use, park the boom lift in a designated area and engage the
parking brake. Store the boom lift in a secure location.
POWERLINES AND BARRICADES
All boom lift operations must stay further than 10 feet away from all powerlines. The boom lift basket is
not permitted within 10 feet of a powerline. It is the duty of an on site ground watch to ensure that the
basket does not get close to a powerline.
Barricades, in the form of cones and caution tape, must be set up around the boom lifts while they are
in the streets. This is to ensure that no public vehicles will come close to the boom lift while it is in
operation.
WEATHER
EHS and on-site management will be monitoring the weather constantly throughout the roof and gutter
clean-up operations. Below are several weather scenarios and what needs to be done if dangerous
weather is present:
1. High Winds: Boom lifts are susceptible to tipping or swaying in high winds. The specific wind
speed at which work should cease varies depending on the lift's specifications and
manufacturer recommendations. However, as a general rule, if wind speeds exceed 20-30 mph
(32-48 km/h), it's typically unsafe to operate a boom lift.
2. Thunderstorms: Thunderstorms bring the risk of lightning strikes, which pose a severe danger
to workers on elevated platforms. If there is any lightning within 10 miles of the work area, boom
lift operations must cease. There must be a 30 minute time period where no thunder is heard
before boom lift operations may be started again.
3. Heavy Rain: Operating a boom lift in heavy rain or snow can reduce visibility and create
slippery conditions on the platform, ladder, and ground. If the rain is causing employees to slip
while moving around in the basket or on ladders, operations must cease.
4. Fog or Low Visibility: Foggy or low-visibility conditions impair the operator's ability to see
obstacles, other workers, or potential hazards around the work area. Employees must wait until
there is at least enough visibility to see the basket in the air from the ground to commence work.
5. Severe Weather Warnings: Pay attention to weather forecasts and severe weather warnings
issued by local authorities. If severe weather conditions are predicted, it's best to stop working
on the boom lift and seek shelter until the weather improves.
6. Sudden Weather Changes: Be aware of sudden changes in weather conditions, such as
rapidly developing storms or unexpected wind gusts. If weather conditions deteriorate rapidly,
it's safer to stop working and lower the boom lift to the ground until conditions improve.
ATI HEADQUARTERS 3360 E. La Palma Ave, Anaheim, CA 92806 | (800) 400‐9353 | www.ATIrestoration.com
ATI Scope of Work – Roofs and
Gutters
Page 9 of 5
ADDITIONAL
RESOURCES
For comprehensive information
regarding all aspects of the Tustin
Hangar Fire job, please refer to the
complete Site-Specific Safety Plan.
This document includes detailed
information on the following critical
topics:
• Site History and
Description: A detailed
account of the site's
background, previous uses,
and current conditions,
providing essential context
for all operations.
• Emergency Evacuation:
Clear instructions for
evacuation procedures in
the event of an emergency,
including designated
evacuation routes and
assembly points.
• Injuries and Incidents
Protocol: Guidelines on
how to respond to injuries
and incidents, including
reporting procedures,
immediate actions to take,
and follow -up processes to
ensure safety and
compliance.
• Sign-in, Job Hazard
Analysis (JHA), and Daily
Safety Meetings:
Requirem ents for daily sign-
in procedures, conducting
job hazard analyses to
identify and mitigate risks,
and holding daily safety
meetings to discuss
ongoing safety concerns
and updates.
• Key Personnel: Identification and contact
information of key personnel responsible
for various aspects of the job, including
safety officers, supervisors, and
emergency contacts.
• Vehicles and Traffic Control: Protocols
for the safe operation and management of
vehicles on-site, including traffic control
measures to ensure the safety of all
personnel and visitors.
• Illumination: Standards and guidelines
for adequate lighting on-site to ensure
safe working conditions, especially during
low -light conditions or night operations.
• Employee Medical Surveillance: Details
of medical surveillance programs for
employees to monitor their health and
well-being, particularly for those exposed
to hazardous conditions.
• Air Monitoring: Procedures for
monitoring air quality to detect and
mitigate the presence of harmful
substances, ensuring a safe breathing
environment for all personnel.
• Disposal of Waste: Guidelines for the
proper disposal of waste materials
generated on-site, including hazardous
waste, to minimize environmental impact
and comply with regulatory requirements.
• Decontamination: Processes for
decontaminating personnel, equipment,
and materials that may have been
exposed to hazardous substances,
ensuring safety and preventing
contamination spread.
• Heat Stress Monitoring: Measures to
monitor and mitigate the risks associated
with heat stress , particularly for
employees working in high-temperature
environments.
• Extended Shifts Policy: Policies
regarding the management of extended
work shifts, including provisions for
adequate rest, hydration, and monitoring
to prevent fatigue-related incidents .
ATI HEADQUARTERS 3360 E. La Palma Ave, Anaheim, CA 92806 | (800) 400‐9353 | www.ATIrestoration.com
ATI Scope of Work – Roofs and
Gutters
Page 10 of
For these and other pertinent
details, please consult the Site-
Specific Safety Plan thoroughly. It
is crucial for all team members to
be familiar with the contents of this
document to maintain a safe and
productive work environment.
ATI SITE CONTAC TS
Tim Nunn
Executive Project Director
O: 714‐283‐9990
C: 714‐474‐6286
E: tim.nunn@atirestoration.com
Dustin McCormick
National Operations Manager
O: 714‐283‐9990
C: 479‐799‐1565
E:
dustin.j.mccormick@atirestoration.co
m
Jerry Cielak
President, National Response Services
O: 714‐283‐9990
C: 847‐875‐6021
E: jerry.cielak@atirestoration.com
Shannon Thurgood
Director of EHS
O: 714‐283‐9990
C: 813‐940‐1059
E:
shannon.thurgood@atirestoration.co
m
Attachment D:
Example Quality Control Visual Inspection Checklist
Quality Control Visual Inspection Checklist
Property Address:
Date:
*Mark N/A if property does not have designated area/structure to assess
CAC Representative: ______________________________________________________
Area/Structure* Accessible/Visible Debris Present
Front Yard
Rear Yard
Side Yard(s)
Front Porch
Rear Porch
Driveway
Sidewalk(s)
On-Ground Landscaping
Above-Ground Trees/Landscaping
Roof
Gutters
Additional Locations, if applicable: