Indoor Air Quality Management Plan

                              for

              US EPA Headquarters. Waterside Mall


                   Version of:  April 13, 1990
Concurrence:

I approve of this Plan in terms of both its concept and its
specific contents.  Further, I recommend it on the part of the
organization I represent to Mr. Charles L. Grizzle, Assistant
Administrator, Office of Administration and Resources Management,
for review and action.
                                                            date
                              Julius Jimeno, Chairman,
                              Labor/Management Health and Safety
                              Committee and
                              Director, Environmental Health and
                                                    EPA
                              for"  ^/            //       /Qatfe
                              Lores Murray, Membe]
                              Labor/Management Health and Safety
                              Committee and
                              President,
                              American Federation
                              of Government Employees,
                              Local #3331

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                        TABLE OF CONTENTS

ACKNOWLEDGEMENTS	2

A NOTE ON THE SCOPE AND DEVELOPMENT OF THIS PLAN	3


                              PART 1

                      BACKGROUND INFORMATION

SICK 'BUILDING" SYNDROME AND BUILDING RELATED ILLNESS	4


                              PART 2

      INDOOR AIR QUALITY RISK MANAGEMENT AT EPA HEADQUARTERS

RISK IDENTIFICATION AND ASSESSMENT. .	10

RISK CONTROL	12

RISK COMMUNICATION	14

RISK FINANCING	15


                              PART 3

                      THE GOALS OF THIS PLAN

SHORT-TERM	16

MID-RANGE	18

LONG-TERM	. .	19


                              PART 4

             INDOOR AIR QUALITY IMPROVEMENT MEASURES

FACTUAL BASIS FOR SOME SPECIFIC IMPROVEMENT MEASURES	20

OTHER PREMISES  FOR IMPROVEMENT MEASURES	25

SHORT-TERM IMPROVEMENT MEASURES	26

MID-RANGE AND LONG-TERM IMPROVEMENT MEASURES	31

                              PART 5

BIBLIOGRAPHY	36
APPENDICES	beginning  at. . .37

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                         ACKNOWLEDGEMENTS

        This version of the Plan, dated April 13, 1990,
incorporates the most recent changes made by management in
response to union input.  The first version of this Plan that was
jointly approved in concept and principle by both management and
labor was developed by the Indoor Air Quality Management Plan
Subcommittee, in January 1990, under the auspices of the Labor/
Management Health and Safety Committee, US EPA Headquarters.
The Subcommittee was composed of four regular voting members, two
of whom represented management and two others who represented the
certified unions - one from the AFGE and the other from the NFFE.
In addition, an ex-officio, non-voting member was appointed to
serve in an advisory capacity.  The original official members of
the Subcommittee, and the organizations they represented, were:

               Bob Axelrad, ex-officio representative
                    Indoor Air Division,
                    Office of Air and Radiation

               Kirby Biggs, union representative
                    American Federation of Government Employees

               Myra Cypser, union representative
                    National Federation of Federal Employees

               Stan Fredericks, Chairman and management
                    representative
                    Facilities Management and Services Division,
                    Office of Administration

               David Scott Smith, management representative
                    Environmental Health and Safety Division,
                    Office of Administration

       Special contributions in Part 1 of this Plan, entitled
"Background Information," were made by:

               Bob Axelrad
                    Office of Air and Radiation

               Kevin Teichman
                    Office of Research and Development

               David Weitzman
                    Office of Solid Waste and Emergency Response

       Additionally, material is quoted from the Guidelines for
the Assessment of Bioaerosols in the Indoor Environment.
published by the American Conference of Governmental Industrial
Hygienists in November,  1989.

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        A NOTE  ON THE SCOPE AND DEVELOPMENT OF THIS PLAN
     Although this Plan references the EPA's facilities at the
Waterside.Mall building complex,  there is no intent to imply the
exclusion of other EPA facilities located in the Fairchild
building or at Crystal City.   The Agency intends to ensure a high
level of indoor air quality for its employees at those locations,
too.  Modification of'appropriate elements of this Plan to
accomodate the unique needs of EPA occupied areas of its other
Headquarters facilities shall be made as required.  This Plan is
considered a "living document,"  and thus modifications may be~
made to it from time-to-time as significant additional
information about Indoor Air Quality matters becomes available.

     The direct participation of the unions in the important and
continuing process of revising this Plan is considered to be
essential.   However, in late March 1990, the NFFE's leadership
announced its withdrawal from participation on the parent
Labor/Management Health and Safety Committee.  Their action ended
NFFE's participation on the parent Committee and its
Subcommittees at that time.  However, this Plan shall continue to
evolve, as intended, from its first version that was initially
jointly developed and approved in concept and principle by
management and representatives of both unions in January 1990.
Both management and the AFGE union continue to maintain their
commitment to work together in a spirit of close cooperation to
further develop and oversee the implementation of this Plan.
Such efforts will further enhance the health, safety, and
wellness, and sense of well-being of all EPA Headquarters
employees.

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                              PART 1


                      BACKGROUND INFORMATION

       SICK BUILDING SYNDROME AND BUILDING-RELATED ILLNESS

     A new term - "sick building" - has come into use in recent
years.  The term characterizes a building in which a substantial
percentage of its occupants complain of health and comfort
problems that can be related to working or being in the building.
Some problems suffered by occupants that are associated with sick
buildings have been termed "sick building syndrome" (SBS) and
"building related illness" (BRI).   (These terms generally apply
to problems related to indoor air pollution; they are not used to
characterize buildings where complaints stem solely from
inadequate temperature or humidity control.)

     Some experts consider a building to be sick whenever about
20% or more of its occupants complain of multiple symptoms that
are always or often expressed shortly after they enter the
building, and which most often resolve shortly after they leave
the building. Examples of such symptoms include:  headache;
stuffy nose or sinus congestion; dry or itching skin;  tearing
and/or burning sensation in eyes; dry, irritated throat; unusual
fatigue or tiredness; sleepiness or drowsiness; dizziness and/or
nausea; sensitivity to odors. From a medical perspective, other
abnormal physical signs and/or positive laboratory tests are not
associated with individuals experiencing SBS, who complain of
these symptoms.

     A World Health Organization committee estimates that the
occupants of up to 30 percent of new and remodeled buildings may
have such problems.  In fact, almost every building may at some
time experience indoor air-quality (IAQ)  problems.  Frequently,
the problems result from the building being used, operated, or
maintained in ways unforeseen by those who originally designed
it, or from poor judgment in the building design itself.

     A building is said to manifest SBS when;

     •    A substantial number of building occupants complain of
          multiple symptoms associated with acute discomfort,
          which occur shortly after entering the building.

     •    The cause of the symptoms is not known.

     •    Most of the complainants report relief shortly after
          leaving the building.

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     Building-related illness (BRI)  is?less common,  but often
more serious than SBS.  Building-related illnesses can be
clinically diagnosed and they are accompanied by abnormal medical
findings.  These include abnormal physical signs and symptoms,
and abnormal laboratory test results.   Examples of building-
related illnesses include:  infections,  such as "Legionnaire's
Disease," toxic syndromes associated with exposure to chemical or
physical agents, and hypersensitivity diseases (including
hypersensitivity pneumonitis, "humidifier fever," asthma, and
allergic rhinitis).

     When occupant exposure to indoor air contaminants results in
cases of clinically defined illness, disease, or infirmity, the
building is said to manifest building-related illness, which is
characterized by;

     •    Complaints of symptoms such as cough; chest tightness;
          fever; chills, and muscle aches which can be associated
          with illness.

     •    The cause or causes of the symptoms are believed to be
          exposure to indoor pollutants.

     •    Complainants may require prolonged recovery times after
          leaving the building.


     It is important to note that it is normal for some
percentage of a building's occupants to experience one or more of
such symptoms, and that occupant complaints may also result from
an illness contracted outside the building/ acute sensitivity of
certain individuals (such as allergy),  job-related stress or
dissatisfaction, or other psychosocial  factors.  Nevertheless,
studies have shown that such symptoms may be caused or
exacerbated by indoor air contamination.

     Indoor air problems that have been cited in the literature
as causes of, or contributing factors to, sick buildings include:

     •    inadequate ventilation;

     •    pollutants emitted inside the building;

     •    contamination from outside sources;

     •    biological contamination.

     These causes are thought to act in combination, and often
supplement other occupant complaints such as inadequate
temperature, humidity, or lighting.   However, even after a
building investigation, specific causes of SBS - by current
definition - remain undetermined.

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     Prior to the 1973 oil embargo, most office building's
heating, ventilating, and air conditioning (HVAC) systems were
designed and operated to provide as much as 15 cubic feet per
minute  (cfm) of treated outside air for each building occupant.
To save energy, conservation measures were later implemented
which reduced the standard amount of treated outdoor air provided
for ventilation in some office buildings to only 5 cfm per
occupant.  Thus, the capabilities of HVAC systems to provide
ventilation can vary considerably, based on the particular design
criteria effective at a given time.  Additionally, many
ventilation systems do not effectively distribute the treated air
to people in the building.  The result is inadequate ventilation
which allows pollution levels from existing sources to increase.
This is thought by many IAQ experts to be a major contributing
factor to SBS.

     Some indoor pollutants come from sources inside the
building.  For example, adhesives, carpeting, vinyl or rubber
molding, manufactured wood products, copying machines,
pesticides, and cleaning agents may emit volatile organic
compounds (VOCs), including formaldehyde.  Research shows that
some VOCs can cause acute and chronic health effects at various
concentrations.  Tobacco smoke is also a source of indoor air
pollution, which can contribute to harmful levels of VOCs and
respirable particulate matter.

     The indoor air can also be contaminated from sources outside
the building.  This occurs primarily when pollutants from motor
vehicle exhausts, plumbing vents, and building exhausts (such as
those for toilets and kitchens) enter the building through
improperly located outside air intakes, windows, and other
openings.  In addition, combustion products such as oxides of
carbon, nitrogen, and sulfur can enter a building from an
attached or underground garage, or a nearby industrial source.
These pollutants can cause both SBS symptoms and BRI.

     Other causes of building-related health effects include some
biological agents.  Among these are certain bacteria and fungi,
and their spores, pollen, and other living and non-living agents.
Biological contamination at levels sufficient to cause illness is
sometimes associated with HVAC systems.  For example, disease
causing biological agents may breed in stagnant water that is
allowed to accumulate in humidifiers and cooling coil condensate
pans, or where,,water has collected on ceiling tiles, carpeting,
insulation or internally lined duct work.  Physical symptoms
related to biological contamination may include cough, chest
tightness, fever, chills, muscle aches, and general allergic-
type responses such as mucous membrane irritation and upper
respiratory congestion.

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          "Specific causes of SBS remain unknown.  It.is
     often assumed that SBS results from insufficient fresh
     air (outdoor air)  being brought into the enclosed
     environment. However, little published evidence
     supports this hypothesis and complaints are not always
     correlated with ventilation rates.  (Skov,  1987; Fanger,
     1988; Robertson, et.  al.,  1985; Harrison,  1987).
     European studies suggest that SBS is associated with
     ventilation systems that use humidification and
     chillers (S. Burge, 1987;  Finnegan, 1984;  Skov, 1987;
     Valbjorn, 1987; Fanger, 1988). Job category and gender
     also affect the perception of work-related symptoms.
     Occupant activities and furnishings can affect indoor
     air quality and complaint rates.  Specifically, the
     surface area of 'fleecy' materials, exposed paper
     materials, and the amount and allergenic portion of
     floor dust have been related to complaint rates
     (Gravesen, 1986).  Different buildings may have
     different sources of poor indoor air quality; sometimes
     a contaminated ventilation system itself is a source."

          "Bioaerosols have not been conclusively associated
     with SBS. S.Burge (1987) and Finnegan (1984)  suggest
     that correlations between SBS and humidification and
     cooling were due to microbial contamination.  Fungal
     amplification and unusual fungi associated with SBS
     have been reported (Morey, 1984 and 1988).  Endotoxins,
     mycotoxins, and other microbial products are chief
     candidates for future research into the relationship
     between SBS and bioaerosols since their effects would,
     theoretically, not be dependent on immunologic
     sensitization, and their effects might be of short
     enough duration to account for complaints that resolve
     when occupants leave a building."

          "In summary,  a single cause for SBS is unlikely.
     Rather, many hypotheses (sources/causes)  must be
     considered in determining the cause of complaints in
     any particular building, including ventilation rates,
     ventilation system maintenance and type,  off-gassing of
     building furnishings, and evolution of a multitude of
     irritants from occupant activities, microbial
     contamination, etc."

[These quotations were extracted from:  Guidelines for the
Assessment of Bioaerosols  in the Indoor Environment. American
Conference of Governmental Industrial Hygienists,  November,
1989.]

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     Solutions to indoor air problems usually include
combinations of the following prevention and control measures;

     •    Education.  This is the most important control method.
          If building occupants, management, building maintenance
          personnel, and others understand the various sources
          and effects of indoor pollutants, they can act together
          to reduce indoor pollutant exposures.

     •    Pollutant source removal, modification, or
          substitution.  This is the most effective way to
          resolve an indoor air quality problem when specific
          sources causing the problem can be identified.  This
          approach reduces or eliminates the emissions from a
          pollutant source, and may be used in combination with
          increased ventilation to dilute the indoor pollutant
          level.  Examples of this method include cleaning or
          replacing contaminated filters in the HVAC system,
          removing water-stained ceiling tile and carpeting;
          instituting a no smoking or restricted smoking policy;
          exhausting combustion products to the outdoors; and
          using and storing paints, adhesives, solvents, and
          pesticides in well-ventilated areas.  In fact,
          resolution of problems in a building which manifests
          BRI usually requires removal of the pollutant source.

     •    Increasing ventilation rates.  This can often be a
          cost-effective means of reducing indoor pollutant
          levels.  In a building with mechanical ventilation
          systems, outdoor air quantities should be provided at
          rates at least as high as those specified in
          appropriate standards or codes.  The American Society
          of Heating, Refrigerating and Air Conditioning
          Engineers (ASHRAE)  1989 ventilation standards (which
          are being implemented at EPA Headquarters facilities)
          specify a minimum of 20 cfm of outdoor air per person,
          in general office areas. It is important to ensure that
          ventilation systems are operated and maintained to
          provide at least these rates.  Also, when there are
          strong pollutant sources, additional ventilation should
          be provided to dilute and/or exhaust contaminated air.
          Optimally, local exhaust systems should be employed to
          remove indoor pollution from such sources as restrooms,
          copying rooms, and printing facilities.
                                8

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Time of use adjustment of* a pollutant source.  This is
another important IAQ control strategy.   When feasible,
pollutant sources should be used when the least number
of people will be exposed,  e.g., painting during
weekend or nonworking hours, and allowing building
materials in new or remodeled areas to off-gas
pollutants under high ventilation conditions before
occupancy.

Air filtration and purification.  These processes can
be used in combination with source control and
ventilation where specific problems are identified and
practical air cleaning options exist.  Particulate
filtration, for example, is a highly advanced
technology, but increasing performance in filtration
can translate to major increases in both capital and
operating expenses.  Ordinary furnace filters do not
effectively capture pollen and other small particles.
Vapor and gas removal equipment is also available for
some specific types of pollutants, but these
technologies are usually not appropriate for general
use in ordinary office environments.

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                              PART 2


      INDOOR AIR QUALITY RISK MANAGEMENT AT EPA HEADQUARTERS

             RISK IDENTIFICATION AND RISK ASSESSMENT

     Risks associated with IAQ problems at EPA's Headquarters
facilities include, but are not limited to:

     1)   adverse impacts on employee's safety, sense
          of well-being, and comfort;

     2)   diminished health and wellness, including
          increasing employee's psychological stresses
          to unhealthy levels;

     3)   lessening of employee's morale;

     4)   reduction of employee's productivity;

     5)   impairment of the Agency's abilities to meet
          its mission related goals;

     6)   diversion of human, financial, and other
          resources to resolve related contingencies.

     It is often difficult (or impossible) to quantitatively
assess and prioritize the wide range of risks to employees and to
organizations resulting from poor indoor air quality.  Many of
the arts and sciences that use quantitative methods are still in
nascent stages of development; they are - at best - inexact.

     Frequently, the actual causes of adverse health effects
among building occupants that are attributed to indoor air
quality are never identified.  However, certain universally
applicable control measures have historically been shown to be
effective. They can eliminate, or significantly diminish, reports
of adverse health effects that are attributed by building
occupants to indoor air quality. Such measures can prove
effective even in instances where the causes of problems are not
positively identified.

     For these reasons, and others, the difficulties of
developing and using meaningful, quantitative risk assessments
when constructing a comprehensive corrective plan are compounded.
Some broad qualitative assessments of the impacts of poor indoor
air quality are possible to determine and they can be useful, in
a strategic sense, to develop priorities for corrective
approaches. Options for specific remedial actions of a tactical
nature can then be explored.   Quantitative methods can be a
useful adjunct to such tactical efforts.  They are most

                                10

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effectively used-when dealing with a known causative agent, or
when a specific agent is highly suspected.

     The risk identification and assessment methods used in
developing this Plan are premised upon those that are currently
recognized, established, and accepted among a wide community of
IAQ experts.

     Actions to date at EPA's Headquarters facilities, include
both formal and informal steps to qualitatively and
quantitatively identify and assess IAQ related risks.  These have
included, among others:

     1)   monitoring for, and assessment of, potential
          stressors such as those of a chemical,
          biological, particulate, ergonomic, or
          physical nature in the work environment;

     2)   establishment of a medical surveillance
          program for symptoms and illnesses attributed
          by employees to IAQ;

     3)   assessments of labor/management relations;

     4)   identifying employee health, safety, comfort,
          and wellness issues;

     5)   determining employee job satisfaction and
          some causes of job related psychosocial
          stresses; and

     6)   evaluations of various building systems,
          including mechanical components of heating,
          ventilating, and air conditioning (HVAC)
          systems.

     A major effort in these regards has been pursued through a
comprehensive study of indoor air quality and the work
environment, which was conducted under the coordination of Kevin
Teichman at EPA and Lawrence Fine at NIOSH.   To date, Volume 1 of
three - the Employee Survey, and a Union supplement to Volume 1 -
have been published.  Volume 2 - Results of Environmental
Monitoring -and Volume 3 - Multivariate Analysis - are now in
preparation. Volume 2 has been scheduled for release in late
April 1990.  This comprehensive study is in addition to other
previous studies of a more targeted nature that were conducted
under the auspices of groups such as the Environmental Health and
Safety Division, the Indoor Air Branch,  and the Office of
Technology Transfer and Regulatory Support.  A variety of
additional risk identification and risk assessment efforts, in
addition to these studies, currently continue on an on-going
basis.

                                11

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                           RISK CONTROL

     Previously, efforts to control employee and Agency risks
related to IAQ at Headquarters have included measures intended
to:

     1)   maintain a well functioning ventilation
          system capable of providing an adequate
          supply of air, in terms of quantity and
          quality, to all employees;

     2)   maintain a program to control pollutants
          generated or accumulated within the building,
          including environmental monitoring as
          necessary;

     3)   prepare and distribute a survey of employees'
          perceptions about indoor air quality, working
          conditions, comfort and well-being to enable
          targeted corrective actions; and

     4)   conduct educational programs and maintain
          open communications between employees and
          management on matters pertaining to
          occupational health, safety, and wellness
          concerns.

     Other risk control measures that have been, or are being
taken, are further characterized in a number of documents: the
EPA labor/management agreement of July 13, 1987 [Appendix 1],
several desk-to-desk memoranda such as that sent from Loree
Murray (President of AFGE), Robert Carton (President of NFFE) and
Charles L. Grizzle (AA for OARH) to all Headquarters employees on
November 17, 1989 [Appendix 2], and reports sent to the Honorable
Barbara A. Mikulski by Mr. Grizzle [Appendix 3].

     Risk control measures specified in this Plan include:

     - pollutant source removal, modification, or substitution;

     - time of use adjustments of pollutant sources;

     - increasing ventilation rates;

     - additional air filtration and purification;

     - educational programs and communications activities.
                                12

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     These measures are intended to improve the quality and
quantity, of indoor air provided to EPA employees at its
Headquarters facilities.  In doing so, the Agency hopes that it
will significantly enhance employee's safety,  sense of well-
being, and comfort. Such measures are also expected to improve
employee's general health and wellness, while  diminishing
psychological stresses related to IAQ.  These  steps should have a
major positive impact on morale and result in  increased
productivity.  Human, financial, and other resources can then be
redirected to activities that will further the Agency's abilities
to meet its nationally and globally directed mission related
goals.

     As such risk control efforts are conducted, together with
additional efforts that will be implemented in the future, it is
essential that this IAQ Management Plan remain flexible in terms
of:

     1)   specific control related measures,

     2)   time frames for completion of individual
          proj ects, and

     3)   allocations of resources.

     This flexibility is necessary because information that may
be developed during the evolution of control measures could point
to the need for some project modifications, reprioritization of
projects, and development of other control measures.  Maintaining
such flexibility will help to assure that this Plan is optimally
effective and efficient in addressing such additional issues as
they arise.

     The control measures in this IAQ Plan are based upon
information that has been developed about the  quality of air and
employee perceptions about their workplace since 1986.  Because
Volumes 2 and 3 of the Indoor Air Quality and  Work Environment
Study are still in preparation, this Plan may  undergo subsequent
modifications when the remaining volumes are released, or upon
receipt of additional information from other sources
necessitating such changes.
                               13

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                        RISK COMMUNICATION

     The proposed communications strategy includes both internal
and external entities as targeted audiences.  Communications
conducted in the context of this strategy must be constructed and
implemented so as to reach a maximum number of identified
audiences.  In instances where the members of an audience will be
expected to understand a decision that has been made on their
behalf, or where the members of an audience are expected to
participate in a decision making process, the communication of
risks must be understandable by the target audience in terms of
their personal and/or institutional risk management.

     Members of each target audience must be able to make
informed risk management decisions. The significance of risks
should be conveyed in terms that are well known and understood by
the members of the target audience. In some instances a
meaningful appreciation for a particular risk can be established
by anecdote. The risk can be compared to, or contrasted with,
other risks that are commonly encountered by members of the
target audience. The costs of different options as they pertain
to the audience should also be made known.  Information releases
of a purely advisory nature, such as those to external media, may
also be presented in such terms.

     The strategy also includes recommendations for
communications intended for all employees, line supervisors and
managers, members of the senior management team, internal and
external media, and various oversight bodies - such as the US
Senate and House of Representatives, General Accounting Office,
and others.  Active involvement by the EPA's Office of Executive
Support, Executive and Congressional Communications, and the
Office of Human Resources Management, Employee Participation and
Communications Division - as well as other information
dissemination groups (including labor organizations) - is
considered essential.

     This Plan, prior to its transmittal to the AA for OARM
by the Labor/Management Health and Safety Committee, may be
forwarded to such information dissemination groups for their
review and further development of the comprehensive
communications strategy.  These groups may then engage in advance
planning for the implementation of components of the IAQ
communications strategy relative to their areas of
responsibility.
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                         RISK FINANCING

        While some of the IAQ risk identification,  risk
assessment, risk control, and risk communication measures can be
priced - even if on an approximate basis - others are not
possible to calculate at this time.  Therefore,  only rough
estimates of budgetary allocations are currently possible, and
major adjustments may be required over time.

     A preliminary determination was made by the Environmental
Health and Safety Division of costs for IAQ related projects
initiated by Headquarters from 1986 through August of 1988. It
reflected that the Agency had spent in excess of $1.7 M, at that
time.  Direct costs incurred since that time, to support similar
activities, are currently greater than $1 M.   No known attempts
have been made to calculate other costs incurred by the Agency -
such as those related to diminished employee productivity, human
resources administration and employee turnover,  lost workdays,
alternative work space, and others.

     Listed in Part 4 of this Plan, entitled "IAQ IMPROVEMENT
MEASURES," are the specific control measures that are to be
implemented.  At the present time it is not feasible to
accurately estimate the amount or level of internal staff effort
required to support all of these activities.   Neither is it
feasible to accurately estimate the costs for services and
products that must be acquired in order to implement all of the
control measures.  However, such estimates will  be prepared later
as the additional data required to develop such  estimates is
received.
                               15

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                              PART 3

                      THE GOALS OF THIS PLAN

[Note: scientifically valid measurement techniques shall be used
when appropriate to periodically assess progress made towards
achieving the goals described  in this sectioni  Actions to
achieve these goals may be taken and evaluated, however, based on
other than scientific methods.]

Short-term:

1)   to have the IAQ Management Plan approved by the
     Labor/Management Health & Safety Committee and
     transmitted to the AA for OARM by not later than
     4/12/90;

2)   to have the IAQ Management Plan approved for
     implementation by the AA for OARM, and other
     appropriate entities, by not later than 4/30/90;

3)   to continue on-going efforts, and to immediately .take
     additional steps, to improve the quality and quantity
     of indoor air provided to EPA employees at its WSM
     facilities; to continue and to enhance established risk
     management activities related to indoor air quality at
     EPA Headquarters.  These activities include risk
     identification, assessment, control, financing, and
     communications efforts currently underway within the
     Office of Administration, Environmental Health and
     Safety Division, Facilities Management and Services
     Division, and other collaborating Offices and
     Divisions.  Emphasis is to be placed on employing
     proven measures that have been historically
     demonstrated to eliminate, or significantly reduce,
     reports by building occupants of adverse health effects
     attributed to the building;

4)   to immediately initiate new communications activities
     intended to inform all EPA Headquarters employees,  and
     others, about this comprehensive IAQ Management Plan.
     This includes its goals and the risk management
     activities to be conducted short-ten,  mid-te'rm, and
     long-range. [All reasonable steps must be taken to
     insure that IAQ Management Plan related communications
     with employees, and others, do not create,  or
     exacerbate, employee's psychological stress.]   Such
     communications should employ methods suggested in
     various risk communication guidance documents,  such as
     the EPA's publication entitled:   Risk Communication for
     Air Toxics.
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Developing employee's understanding of this Plan's
goals, and training and educating employees about the
vital and active roles they must play-to insure its
effective implementation, is critical to success.
Effective communications and employee driven control
methods are essential in these regards.
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Mid-range;

1)   to reduce the levels of specific employee health,
     safety, and well-being risks - of significance - and
     which are associated with IAQ, to levels acceptable to
     labor and management, by not later than June 30, 1991;

2)   the IAQ Plan Subcommittee will ensure the elaboration of
     specific, objective measures for determining
     improvements in IAQ. Examples include measurably lower
     levels of significant indoor air pollutants,.as.well as
     increases in the quantity and quality of treated
     outdoor air provided to employees in meeting the goal
     of 20% minimum outside air, per 1989 ASHRAE standards;

3)   to reduce the percentage of employees at WSM who
     indicate that they often or always have symptoms
     frequently associated with indoor air quality [exhibit
     ES-2 within Volume 1*] from an average of 13.4% to less
     than 6%, by not later than June 30, 1991;

4)   to reduce the percentage of employees at WSM who
     associate one or more symptoms with their work building
     [as cited in exhibit 5-10 (see also 5-3) within Volume
     1 of the Indoor Air Quality and Work Environment
     Survey*! from 62% to less than 30%, by not later than
     June 30, 1991;

5)   to reduce the percentage of employees at WSM who
     indicate that their building associated symptoms
     reduced their ability to work at least some of the time
     [exhibit 5-9 within Volume 1*] from 29% to less than
     15%, by not later than June 30, 1991;


6)   to reduce the percentage of employees at WSM who
     indicate that the frequency and duration of their
     infections had increased since they began work in the
     WSM building [exhibit 5-12 within Volume 1*] from 39%
     to less than 19%, by not later than June 30, 1991.

     * See Appendix 4
                                18

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Long-term;

1)    to achieve and fulfill all programmatic elements and
     goals  of this IAQ Management Plan,  in a manner
     acceptable to labor and management;

2)    to establish a model of excellence  - recognized as
     outstanding in both the private and public sectors -
     for the planning, developing,  implementing,  and on-
     going  management of a comprehensive IAQ Management
     Plan.
                               19

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                              PART  4

             INDOOR AIR QUALITY IMPROVEMENT MEASURES

      FACTUAL  BASIS  FOR SOME  SPECIFIC  IMPROVEMENT MEASURES
1.   An average of 13.4% of respondents to the Indoor Air
     Quality and Work Environment Survey conducted among EPA
     Headquarters personnel at Waterside Mall have reported
     that they often or always experienced indoor air
     quality related symptoms during 1988 which got better
     upon leaving work.  Those symptoms included:

     a. headache
     b. stuffy nose/sinus congestion
     c. dry, itching, or tearing eyes
     d. burning eyes
     e. dry throat
     f. unusual fatigue or tiredness
     g. sleepiness or drowsiness;

2.   according to the Indoor Air Quality and Work
     Environment Study. Volume 1. there were a significant
     number of complaints made by EPA Headquarters personnel
     about a variety of symptoms that they perceived to be
     associated with the workplace in 1988, although not all
     such symptoms were related to indoor air quality.  For
     example, 62% of Waterside Mall employees reported
     associating one or more of their symptoms - ranging
     from headaches, runny noses and coughs, to backaches
     and wrist pain - with the 401 M Street facilities;

3.   at Waterside Mall, employees ranked fumes from new
     carpeting, paint, and tobacco smoke as the leading
     causes of eye, nose, throat, and respiratory
     irritation;

4.   24% of employees have reported that they want to adjust
     physical conditions relating to odors in winter months;
     30% in summer;

5.   the highest ranking odors noticed at workstations last
     year at Waterside Mall were "other food smells,"
     "cosmetics," and "new carpet odors";
                               20

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the.results -of environmental monitoring conducted by
hygienists as a part of the Indoor-Air Quality and Work
Environment Study. Volume 2. had not been received at
the time this Plan was prepared.  Other industrial
hygiene studies at Waterside Mall have previously been
performed, with the following general results:

a.   biological agents; no viable microbes or
     their spores - that are pathogenic to humans
     - have been found in concentrations that are
     deemed clinically significant to the general
     population, in any air sampling conducted to
     date at WSM;

b.   chemicals; No specific chemicals found in the
     workplace have been positively identified by
     the EPA as a causative agent of employees'
     general, on-going, health complaints at W5H -
     that they attribute to the building;

     However, 4-phenylcyclohexene (4-PC) - at low
     parts-per-billion concentrations - has been
     attributed by the National Federation of
     Federal Employees union,  local #2050, as the
     cause of some EPA employee's adverse health
     effects.  (This chemical is present in about
     95% of the carpeting currently produced in
     the US.)  In this regard,  seventy-six
     employees' complaints attributed to 4-PC were
     first associated, in both temporal and
     spacial terms, with the odor of certain
     carpeting installed in areas of Headquarters
     facilities beginning in October 1987.
     According to the local NFFE union, at least
     20 of these employees have reported that they
     acquired "multiple chemical sensitivity"
     during the time in 1987 when odors from the
     newly installed carpet were the strongest. At
     the present time, it is not possible to
     firmly conclude with a degree of scientific
     or medical certainty that the correlation of
     4-PC with employee's health complaints is
     valid. [See Van Ert letter, dated February
     1990 (Appendix 5).]  4-PC is the subject of
     various on-going EPA and other studies to
     further characterize its toxicity, determine
     its concentrations in carpet and other
     materials, and in the workplace air;
                          21

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c.   participates:  respirable particulates have
     been sampled, and there have only been
     findings of "...interest..." related to
     11... carbonaceous soot..."  and other
     particles stated to be "...sulfur
     condensates...".  These particulates were
     found in concentrations consistent with what
     would normally be expected in a metropolitan
     environment such as Washington, D.C., and in
     a building configured and HVAC-eguipped as
     WSM.

     Some of these particulates can be attributed
     to the proximity of the Headquarters
     buildings to several coal-fired power and
     steam generation plants.  Amounts of
     respirable particulates measured have
     averaged less than 20 micrograms/cubic meter
     of indoor air, as compared to the EPA's
     standard of 150 micrograms average/cubic
     meter.  Assessments of the allergenic
     potential of some of these particulates has
     been made.

     [Note: the preceding is a general summary
     intended to characterise only those results
     of the specific tests, and expert
     professional interpretations thereof, for the
     environmental monitoring performed at EPA
     Headquarters from 1986 to date.]

     [Note:  some individual employees with
     specific medically diagnosed allergies to
     various commonly encountered substances have
     been identified.  Measures have been/are
     being taken to provide appropriate
     aeeommoCations to such employees for their
     medical conditions, in accordance with
     recommendations from their physicians.]

comments about dusty, dirty working conditions were
recorded in the Employee Survey, with "...lack of
vacuuming...contributing to the problem, and
"...vermin..." reported.  Remarks on the presence of
mice and roaches were more common at Waterside.
Specific concerns were expressed about the ventilation
system, with Waterside-based employees referring to
"...dirt filled air blowing around, sooty, powdery
dust, black particles falling from ventilators, and
other strange material coming from the ventilation
system...";
                           22

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8.   there are several food service operations,  a large
     supermarket,  and a smaller grocery  store located in the
     WSM complex.   Such operations are generally known to
     attract vermin,  such as insects and rodents. Health and
     sanitation laws  require special vermin control measures
     to be implemented by such types of  businesses; the
     degree and manner of compliance with such regulations
     by those businesses located in the  WSM complex is not
     currently known  by EHSD staff.  There is no coordinated
     vermin control program practiced by all WSM building .
     complex tenants  at this time;

9.   the current condition of components of the AHU/HVAC
     systems is not known to EPA personnel; the supply air
     ductwork is thought to have fiberglass insulation
     lining portions  of the interior - there are no EPA
     records reflecting recent comprehensive ductwork
     inspections to determine its condition; interior air is
     returned to AHU's throughout the system through above-
     the-ceiling plenums,  and a large percentage (up -to 90%)
     may be recirculated;  there are no EPA records
     reflecting that  the plenum spaces have been cleaned;.
     the AHU's are equipped with intake  air filters stated
     by various parties to have efficiencies of between
                    "
                 0 • •  ,
10.  the smoking of tobacco products is  currently permitted
     in certain designated areas of the  building,  under the
     provisions of a written smoking policy;  these
     provisions were in effect at the time  of the employee
     survey; problems with enforcement have been  reported
     anecdotally to EHSD staff in recent months;

11.  painting of the building's interior is presently
     accomplished using water based latex paints;  interior
     painting is done during other than  regular business
     hours with special ventilation methods employed;
     managers and supervisors are now being informed in
     advance when such work is scheduled, so  that
     appropriate notification of staff can  be accomplished
     and necessary arrangements for minimizing staff
     exposure to paint odors made;  these provisions  were not
     in effect at the time of the employee  survey;

12.  there are written provisions for dealing with the use
     of fragrances and/or cosmetics by employees;  these
     provisions were in effect at the time  of the employee
     survey; anecdotal reports of enforcement problems have
     been made to EHSD staff in recent months;
                               23

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13.  according to various reports, certain ventilation
     exhaust stacks, including some of those serving WSM
     complex restaurant operations, are net designed,
     constructed, or located so as to minimize the re-entry
     of stack effluents back into the building through
     supply air intakes and other openings; FMSD recently
     arranged for the relocation of an intake near the -
     Safeway loading dock, to minimize capture of odors and
     delivery vehicle exhaust emissions.
                               24

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             OTHER PREMISES FOR IMPROVEMENT MEASURES


1.   There are several reasons for EPA employees'  complaints
     about adverse health effects related to indoor air
     quality at Headquarters facilities:

          - there are some adverse health effects  being
            experienced by employees that are related to indoor
            air quality;

          — some on-going health problems being experienced by
            employees are not related to  the workplace, although
            they are attributed by the affected employees,  and
            others, to it;

          - some complaints are psychosocial in origin and may be
            based upon misperceptions and unfounded fears about
            the building and the quality  of indoor air at the
            workplace.

2.   The most rational approach to resolving employee
     complaints about indoor air quality  involves  taking
     immediate steps to improve air quality using  methods
     and materials that have,  historically,  been proven to
     be effective in significantly reducing or eliminating
     such complaints in other settings.   It is also
     important to address employee's perceptions about the
     causes of symptoms that they relate  to the building.
     The first steps proposed are intended to isolate,
     reduce,  or remove conditions generally recognized as
     potential causes of sick building syndrome complaints
     and building related illnesses.   Additional steps are
     intended to assure employees that management  recognizes
     and is being responsive to their concerns,  by
     addressing symptoms that employees associate  with their
     workplace.  Further steps are intended to ensure that
     IAQ Management Plan related communications with
     employees do not exacerbate stress related symptoms,
     which are currently expressed by some employees.
                               25

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                 SHORT-TERM IMPROVEMENT MEASURES
1.    Engage in a three part cleaning of the building:

     a.   encourage all employees to participate in
          "Operation Cleanup" - a general cleaning and
          dusting campaign for each organizational
          element's spaces, by building, beginning
          April 22 1990; make arrangements to have
          extra housekeeping staff and carts available
          to haul away unwanted general office
          detritus; have salvage crews available to
          haul away unwanted equipment; have trucks
          available to haul away bulk waste, salvaged
          equipment, and records for appropriate
          disposition;

     b.   have the USSI housekeeping contractor engage
          in a thorough cleaning (vacuuming, mopping,
          dusting, and sanitizing)  of each building or
          building zone following the employee's
          "clean-up" within that building or zone;

     c.   inspect, photograph, and document the
          condition of the HVAC systems servicing EPA
          occupied spaces at Waterside Mall facilities
          - within 30 days.

          Within 90 days (and only after parts "A" and
          "B" are completed)  have a contract let to
          have all interior components of all AHUs
          serving EPA occupied areas at WSM cleaned
          [See Appendix 6 - the WORK STATEMENT for
          cleaning the HVAC systems, dated March 26,
          1990.]  All fiberglass insulation is to be
          removed from within AHUs and related ductwork
          and replaced with sound insulating material
          acceptable to EHSD; all HVAC system ductwork
          is to be vacuumed and wiped clean, all
          diffusers to be cleaned,  all above-the-
          ceiling plenum spaces to be cleaned and
          ceiling tile cleaned and vacuumed on its
          upper surface (such work to be performed
          after regular business hours); damaged,
          stained, and/or moldy ceiling tiles to be
          replaced; USSI (or other housekeeping staff)
          shall vacuum and dust all office areas in
          which ductwork has been cleaned prior to
          employee occupancy, during the same night/
          morning that such ductwork cleaning is
          performed;

                                26

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Continue to conduct briefings of senior management,
line managers and supervisors, staff,  and others - as
necessary - to address concerns about indoor air
quality; disseminate information through appropriate
sources about the positive steps that Administration,
EHSD, FMSD, and the Unions, working hand-in-hand with
other groups, have taken/are taking to identify and to
resolve significant indoor air quality problems,
employee complaints about building related symptoms,
employee diseases that may be related to the building,
and other employee concerns about health, safety and
well-being; in addition, and at the specific request, of
the Director, Office of Administration, monthly
progress reports related to implementation of various
elements of the Plan, problems encountered, and other
matters requiring resolution by senior-level management
will be prepared under the auspices of the IAQ
Management Plan Subcommittee. These progress reports
will be sent to the Labor/Management Health & Safety
Committee for its information and necessary action,
with a copy to the Director, OA by not later than the
fifth (5th) day of each month. In addition, three
copies of the monthly progress reports will also be
sent to the OA Director's designee, for transmittal to
House and Senate Committees;

Invite additional individuals to serve as non-voting,
ex-officio members of the IAQ Management Plan
Subcommittee, as necessary.  Such individuals may
include a representative of Town Center Management,
such as the supervisor of building engineering, a
physician representative of the Headquarters EPA Health
Unit, a senior-level representative of the Indoor Air
Division, a senior-level representative of the Office
of Technology Transfer and Regulatory Support, a
senior-level representative of the Employee
Participation and Communications Division, and an
independent Mechanical Engineer, employed as a
registered Professional Engineer with a local
engineering design firm having extensive experience in
renovating HVAC systems in response to IAQ
considerations; others who the Subcommittee members
feel may make significant scientific,  technical, or
managerial contributions to the Subcommittee's
activities; the Subcommittee shall continue to develop
the IAQ Management Plan modifying it as conditions may
necessitate, and shall monitor and report on its
implementation, with the goal of resolving currently
identified problems of significance - within 2 years'
time;
                          27

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Reach an agreement with TCM mandating the continued use
of only (water-based) latex paints for indoor painting
jobs within EPA occupied space at WSM; verify that all
indoor painting is conducted after hours and with the
use of special ventilation methods to reduce odors to
the maximum extent feasible; assure that a mechanism is
established to enable informing line supervisors as far
in advance as possible of planned interior painting
jobs - so that necessary arrangements can be made to
inform the staff in the affected areas, and to assure
that paint-sensitive employees have an opportunity to
make contingency arrangements with their supervisors;
have an indoor painting safety protocol (related to
indoor air quality) for EPA Headquarters facilities
developed under the auspices of the Subcommittee -
within 90 days;

Appoint a SMOKING POLICY TASK FORCE, which shall report
to the Subcommittee, and charge the group with
developing a phased plan - within 90 days - that has- as
its ultimate goal the development of a plan to
eliminate violations of the current smoking policy at
EPA Headquarters facilities;

[The AA for OARH has proposed a total smoking ban,
Agency-wide, which is now in the "Green Border" review
process.  Negotiations on this proposal, as it relates
to Headquarters, are expected to begin in the near
future.]

The Headquarters' WELLNESS PROGRAM will continue to
provide smoking cessation classes and related health
education programs;
Review the current procedures for resolving complaints
made by employees in which adverse health effects are
attributed to cosmetic or fragrance use by others.
Make revisions to the procedures, with the goal of
minimizing adverse health effects; review and revisions
of the procedures to be conducted within 90 days;

Review the current environmental services
(housekeeping) contracts between TCM and contractors,
as they pertain to EPA Headquarters facilities - begin
within 30 days; closely monitor and document the
performance of work under these contracts, and make
whatever changes are necessary to insure that the EPA
WSM Headquarters facilities are properly cleaned and
maintained; conduct scheduled, zone-based inspection
walk-throughs with representatives of TCM, USSI, EHSD,
                           28

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     FMSD,  and area managers/supervisors to document"all
     findings and to insure corrective actions are
     implemented (place special emphasis on vacuuming,
     dusting, and sanitary cleaning procedures);  work with
     area managers to assure that spaces within their
     geographic sphere of control are made accessible to
     housekeeping crews; schedule walk-throughs so that each
     EPA occupied space is subject to inspection at least
     once per year;

8.   Review current vermin control procedures at EPA
     Headquarters facilities - within 30 days; attempt to
     reach an agreement for the initiation of coordinated
     vermin control monitoring and vermin control procedures
     in accordance with the provisions of the Integrated
     Pest Management Plan and existing collective bargaining
     agreements with Town Center Management and the other
     building leasees, within 90 days - if possible;

9.   Attempt to reach an agreement to require prior EHSD
     approval, in consultation with the Unions,  for the use
     of all cleaning agents and disinfecting agents- -and
     procedures used by TCM and USSI in Headquarters-
     facilities, as well as all vermin control agents -
     within 90 days;

10.  Attempt to reach an agreement with TCM to have
     restaurant associated exhaust ventilation stacks at
     Waterside Mall redesigned and reconfigured to minimize
     the ingress of effluents back into the building through
     fresh air intakes and other building openings - within
     90 days;

11.  Immediately initiate efforts to identify and inspect
     all AHUs in the Waterside Mall complex servicing EPA
     occupied space - within 30 days; obtain the
     specifications for all such equipment and obtain the
     most complete and accurate set of as-built drawings
     available - within 90 days; have the contractor update
     all such drawings,  to include associated main supply
     and exhaust ductwork,  controllers,  thermostats, and
     other related equipment; have the contractor supply the
     requested utility related information in a hard-copy
     format as well as on an IBM-PC driven database (using
     off-the-shelf, purchased software)  sh-jwing HVAC system
     components by building,  zone,  and room/area  for all
     headquarters facilities - within 180 days -  and keep
     all information current in the future;  [Notes  refer to
     Booz,  Allen, & Hamilton Inc.  report dated September 28,
     1989,  by Kenneth R.  McLauchlan,  PE,  entitled:  "Results
     of Inspection and Analysis of HVAC Systems at Waterside
     Mall..."  Available for review by appointment at  EHSD.]

                               29

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12.   *MSD to have contracts let for the performance of one-
     half of this work in FY90, the balance to be performed
     in FY91: physically separate from contiguous areas of
     the building (using slab-to-slab construction, self^
     closing corridor doors,  negative air pressure
     balancing, and ducted return air discharging directly
     to the building's exterior), the following types of
     areas within EPA facilities:

        restrooms;
     -  locker rooms;
     -  shower/bathing rooms
     -  laboratories where toxic chemicals are routinely
        used (there are none currently at WSM);
     -  photographic development facilities;
     -  janitor's closets and rooms dedicated to storage of
        cleaning and/or sanitizing agents;
     -  core rooms dedicated to reproduction and/or copying
        machines;
     -  carpentry, woodworking, metalworking, or similar.
        shops (there are none currently at WSM);
     -  print shop facilities.
                               30

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          MID-RANGE AMD LONG-TERM IMPROVEMENT MEASURES

1.   Ventilation study and HVAC modification  implementation;

     obtain recommendations for enhancements  of  WSM HVAC
     systems required to meet requirements  negotiated in the
     Agency's "Clean Air Agreement"  [Appendix 1];  have
     recommendations made by the Engineering  Design Group
     independently evaluated by another HVAC  mechanical
     engineering design firm; have specifications  and
     drawings prepared for required  upgrades  to  the WSM HVAC
     systems (make available results of previous engineering
     analyses,  and facilitate communications  between
     knowledgeable parties); award construction  contracts,
     with the first areas targeted for renovations to be
     those identified from historical data  as "hotspots" for
     employee complaints.   Have all  work monitored for
     compliance with engineering specifications, drawings,
     and good practice and workmanship by an  independent air
     balancing company having current membership in the
     Associated Air Balance Council; set goal of having all
     HVAC systems modifications completed within 18 months,
     with one-third to be completed  in 1990 and  the balance
     of two-thirds to be completed in 1991.


     [All provisions of the Clean Air Agreement  shall be
     followed.   Ventilation system design specifications for
     air exchanges and temperature shall conform to the
     ASHRAE standards effective in 1989.  Engineering design
     goals should be based on premised conditions  of 75
     degrees under peak cooling load and 72 degrees under
     peak heat load - at 20 cfm outside air/person.
     Filtration specified shall have an efficiency of not
     less than 65%  based on ASHRAE  52-76,  using extended
     bag-type filters.   Prefilters shall be installed to
     enhance the life of the final filters.   Filter beds
     shall be equipped with instrumentation to measure
     pressure drops to aid in the determination  of the
     condition of filters and maintenance.  No provisions
     shall be made for the humidification of  indoor air.
     Equip all cooling towers with drift eliminators.]
                               31

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     Attempt to revise leases with TCM to reflect such
     modifications, and include revisions relative to
     acceptable temperature ranges and ventilation rates,
     working with GSA officials as necessary.   Continue
     extended hours of HVAC system operation to assure an
     acceptable level of occupant comfort - start systems
     during early morning hours, by 5:00 am on weekdays
     (except 4:00 am on Monday or the first day of the work
     week)  and run to 7:00 pm, M - F; run systems as
     necessary on weekends.

     Take necessary steps to assure that installations of
     new HVAC systems meet the 20% outside air goal, per
     ASHRAE standards.  Agency designated personnel, who may
     be accompanied by union representatives,  shall randomly
     monitor the dampers on 5 AHUs, through unannounced
     inspections with TCM personnel, monthly;  concurrently
     inspections shall be made for leaks, stagnant water,
     and evidence of unacceptable biological growth.  Desk-
     dropped flyers shall be issued whenever the HVAC system
     is being balanced.  Quarterly air monitoring for carbon
     dioxide levels shall be performed in "hot spots." • See
     the attachment entitled "Rationale for the Evaluation
     of Ventilation System Efficiency."

2.    Continue to remove damaged or troublesome carpet on an
     accelerated basis from areas where employees and
     managers agree that it is desirable to do so.

     Develop revised procedures for acquiring, installing,
     maintaining, and removing floor coverings.
     Acquisitions of floor coverings should take into
     consideration: 1) vendor certification of the off-
     gassing rates of organic chemicals, conforming with EPA
     criteria, or 2) airing-out procedures to minimize
     indoor air pollutants.  Revised procedures are to be in
     place by July 1, 1990.

3.    Space acquisition and occupancy control.

     Take steps to reduce the occupant load of the WSM
     facility to an average density of no more than 1
     employee per 135 square feet gross floor area, in
     accordance with GSA stipulations.

     A.   First, focus on "hotspots", giving priority
          for relocation to those employees determined
          by EPA's physician(s)  to be candidates for
          alternative work space or work assignments.
                               32

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     B.   Within 30 days,  review the memorandum from
          Mr. Charles L. Grizzle dated July 10, 1989
          [Appendix 7],  to determine if changes in
          procedures may be needed to improve the
          process.

     C.   Within 30 days,  conduct mandatory meetings
          with all supervisory personnel to fully
          explain their role and responsibility in
          evaluating employee health concerns and
          making accommodations when a supervisor
          believes that an employee's health may be
          adversely affected by his/her working
          conditions. [A guidance document is being
          prepared by the Labor/Management Health and
          Safety Committee explaining options for
          resolution of work-related health issues
          identified by employees.]

     D.   Reduce occupancy loading through relocation
          of organizationally related,  functional
          areas, by "AA-ship."

          Currently Scheduled Space Acquisitions;

          Crystal City #1             50,000 sq. ft.

          Northeast Mall              16,000  "   "
          (subbasement)

          Crystal City #2              50,000  "   "

          Additional space            working with GSA

4.   Control of indoor pollutants and employee exposures to
     chemicals.

     Mechanisms shall be maintained in place to insure that
     employees will not be exposed to chemicals at levels
     known to be toxic or acutely irritating to eyes,  nose,
     or throat, or cause other physical ills to employees.
     [This includes measures to limit employee's exposures
     to VOCs, including 4-PC,  and other chemicals which may
     off-gas from newly installed floor covering materials.]
     Construction work in  occupied areas of the building
     which results in the  release of irritating or toxic
     dusts,  aerosols, or vapors will be performed in
     occupied areas only during non-work hours.   Clean-up
     must be completed before employees return to work.
                               33

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     EHSD shall keep a listing of toxic chemicals present in
     the building as required by the OSHA Hazard
     Communication Rule.

     (See the Clean Air Agreement for additional details
     concerning specific programs for PCB's,  radon,
     solvents,  and asbestos.)  The mechanisms established
     under short-term action item #9, herein, shall  be
     maintained as a permanent program by EHSD.   In  .
     addition,  the services of the Indoor Air Branch (MD-
     54) shall be employed to initiate a pilot program by
     10/31/90 on the evaluation and testing of selected
     indoor materials.  The proposed testing procedures may
     be reviewed by the IAQ Management Plan Subcommittee.
     [Appendix 8 - memorandum from W. Gene Tucker to Julius
     Jimeno dated 12/18/89.] Determine the feasibility of an
     Agency-wide program by 10/31/92.

     Current operating procedures for investigation  of
     indoor air quality complaints at WSM, and emergency
     procedures shall be maintained in force, and expanded
     to include appropriate provisions for all EPA
     facilities by October 1992.

5.   Continue,  and enhance, the established IAQ medical
     surveillance program for Headquarters employees

     Appoint a "Blue-ribbon EPA Health Task Force" composed
     of independent, nationally recognized occupational
     medicine physicians, allied-health professionals,  and
     other health-care professionals.  These individuals,
     together with other professional and technical
     consultants (such as medical statisticians and
     epidemiologists) will make recommendations for
     enhancing the medical surveillance program, and provide
     on-going oversight and monitoring of the program.   The
     Task Force may recommend other projects - such  as
     epidemiologic studies - involving WSM employees,
     including those who have reported multiple chemical
     sensitivities. Empanel such a Task Force by September
     1, 1990. Expand the scope of the Task Force's charge to
     include all EPA activities, nationally,  by June 30,
     1991.
                               34

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Establish an "All EPA Task Force" to develop and
implement an Agency-wide IAQ plan.

Appoint a Task Force by October 31,  1990,  to develop
and oversee the implementation of a  comprehensive IAQ
Plan for all EPA facilities.  Publish information,
periodically, about the group's process and outcomes.
The active participation of EPA program offices and
other federal agencies in this activity, including GSA,
NIOSH, OSHA, and the Public Health- Service - among
others - will be sought.  The EPA plan will be designed
as a model for the public sector and serve as a guide
for Federal Indoor Air Quality management plans.
                          35

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                           BIBLIOGRAPHY

Surge, H.A.; Feeley, J.C.; Kreiss, K.; et al: Guidelines for the
Assessment of Bioaerosols in the Indoor Environment. American
Conference of Governmental Industrial Hygienists. Ohio  (1989).

Surge, S.; Hedge, A.; Wilson, S.; et al.: Sick Building Syndrome:
A Study of 4373 Office Workers. Ann. Occup. Hyg. 31(4A):493-504
(1987)

Fanger, P.O.; Lauridsen, J.; Bluyssen, P.; Clausen, G.: Air
Pollution Sources in Offices and Assembly Halls, Quantified by
the Olf Unit. Energy Build. 12:7-19  (1988).

Finnegan, M.J.; Pickering, C.A.C.; Burge, P.S.; The Sick Building
Syndrome: Prevalence Studies. Br. Med. J. 289:1573-1575 (1984)

Gravesen, S,; Larsen, L.; Gyntelberg, F.; Skov, P.: Demonstration
of Microorganisms and Dust in Schools and Offices. Allergy
41:520-525 (1986).

Harrison, J.; Pickering, A.C.; Finnegan, M.J.; et al.: The Sick
Building Syndrome - Further Prevalence Studies and Investigation
of Possible Causes. In: Indoor Air '87. Proceedings of the 4th
International Conference on Indoor Air Quality and Climate, pp.
487-491. B. Seifert, H. Esdorn, M. Fischer, et al., Eds.:
Institute for Water, Soil, and Air Hygiene. Berlin  (1987).

Morey, P.R.: Microorganisms in Buildings and HVAC Systems: A
Summary of 21 Environmental Studies. In: Proceedings of IAQ  '88,
Engineering Solutions to Indoor Air Problems. American Society
for Heating, Refrigeration, and Air-Conditioning Engineers, Inc.
Atlanta, GA (1988)

Morey, P.R.; Hodgson, M.J.; Sorenson, W.G.; et al.: Environmental
Studies in Moldy Office Buildings: Biological Agents, Sources and
Preventive Measures. Ann. Am. Conf. Govt. Ind. Hyg. 10:21-35
(1984)

Robertson, A.S.; Burge, P.S.; Building Sickness. The
Practitioner. 229:531-534 (1985).

Skov, P.; Valbjorn, O.; Danish Indoor Climate Study Group: The
"Sick" Building Syndrome in the Office Environment: The Danish
Town Hall Study. Environ. Intl. 13:139-349 (1987).

Vaibjorn, O.; Skov, P.: Danish Indoor Climate Study Group.
Influence of Indoor Climate on Sick Building Syndrome Prevalence.
In: Indoor Air  '87. Proceedings of the 4th International
Conference on Indoor Air Quality and Climate, pp. 593-597.
B. Seifert, H. Esdom, M. Fischer, et al., Eds.: Institute for
Water, Soil, and Air Hygiene. Berlin  (1987).

                                36

-------
                           APPENDICES

#1   EPA Headquarters'  Labor Management Committee
     Clean Air Policy for Headquarters,  dated July 13, 1987

#2   Headquarters'  Labor Management Joint Letter to All Employees
     Concerning Health and Safety Concerns at Waterside Mall,
     dated November 17,  1989

#3   Letters from Mr-. Charles L.  Grizzle,  Assistant
     Administrator, Office of Administration and Resources
     Management to the Honorable  Barbara A.  Mikulski Concerning
     Efforts to Provide Quality Work Environment, dated 12/12/89;
     01/26/90; 02/27/90.

#4   Exhibits ES-2, 5-3,  5-9, 5-10,  5-12 from "Indoor Air Quality
     and Work Environment Study,  EPA Headquarters' Buildings,
     Volume 1, Employee Survey,"  November 1989 [Publication #19K-
     1003]

#5   Letter from Mark Van Ert,  Ph.D.,  Director,  Occupational
     Safety and Health Program, School of Health' Related
     Professions, The University  of Arizona  to Jeff Davidson,
     Ph.D., Section Chief,  Existing Chemical Assistance Group,
     Office of Toxic Substances,  EPA,  Concerning EPA Employees'
     Complaints of Illness and Indoor Air Pollution dated,
     February 02, 1990

#6   Work Statement for the Cleaning of Heating,  Ventilating, and
     Air Conditioning Systems at  Waterside Mall,  dated March 26,
     1990

#7   Letter from Mr.  Charles L. Grizzle,  AA  for  OARM,  EPA, to All
     Headquarters Managers and Supervisors Concerning Guidance
     Regarding Employee Requests  for Alternative Workspace or
     Work Assignments,  dated July 10,  1989

#8   Letter from W. Gene Tucker,  Ph.D.,  Chief, Indoor Air Branch
     (MD-54),  EPA to Mr.  Julius Jimeno,  Acting Director,
     Environmental  Health and Safety Division, EPA,  Concerning
     Testing Indoor Materials, dated December 18,  1989
                               37

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      APPBJOJX 4.
                       EPA LA30R MAX*3E>EJT CCMMirnZ
          (Established Pursuant to Collective Bargairj.ng  Pqrecncnt
         Between SITE, Local 2050,  AF3E.  Local 3331 and the Agency)


 PURPOSE;  To establish a clean air policy for EPA Headquarters buildincs
 (Waterside,  Crystal City, Fairchild)  which ensures that  the  level of air-
 borne pollutants in these buildings is kept suf ficisntly low to provide a
 healthful work environment.

 BACKGROUND;   Section 19 of the Occupational Safety and Health Act of 1970
 seeks to ensure safe and healthful working conditions  to all employees.
 The Environmental Protection Agency,  regarded nationally as  being in the
 forefront of establishing good environmental health policies, has identi-
 fied indoor air pollution as a source of health risks  and  is therefore,
 striving to provide its employees with a work environment  free frcm signi-
 ficant health risks associated with exposure to chemcal,  physical, and
 biological agents,   fenagsnent is ccntnitted to maintaining a program
 capable of attaining this goal and the following principles  are adopted:

    •  Maintain a well functioning ventilation system capable
      of distributing an adequate air  supply to all employees;

    •  Maintain a program to control pollutants generated or
      accunulated within the building  including monitoring  as
      necessary;

    *  Institute,  analyze and distribute the results  of an employee
      occupational health survey at Headquarters buildings to
      detect  possible indoor air related  illness;

    *  Maintain an open f orun for communications between employees and
      management on  occupational health related concerns.

 PROGRAM

 1.  Ventilation Systems

    The Agency will take  reasonable actions to overcome the constraints
of the  leases  and other factors that Management does not fully control
and that  are impediments  to achieving the  following objectives:

    The ventilation systems  in buildings occupied by EPA employees  at
Headquarters will be well  functioning as defined by recognized engineering
standards and  Federal and  local codes.  The amount of fresh air taken
ir.to  these buildings will be equal to or greater than the  latest American
Society of Keating,  Refrigerating,  and Air Conditioning Engineers (ASHP-AE)
guidelines (code 362) .  The  rate of fresh air changes will be equal to
or greater than the current ASHFAE guidelines fcr buildings that permit
tracking (20  cSn/person) .

-------
      At no tune will outside air 
-------
 2.  Control of PoUutAnts

      E\3llutant3 brought jLnto the buildings or created in the buildings
 shall be controlled in order that unacceptable levels are not reached
 where erployees are working (includes copy center and print shop}.

      The Occupational Health and Safety Staff shall keep a listing of
 toxic' chanicals present in each building as required by the OSHA Hazard
 ODmtunication Rule (29 CFR 1910.1200).  This list nust be kept up to
 date,  tfetenal Safety Data Sheets (MSDS) shall be made available to the
 Union,  the Facility Advisory Qxincil and to any requesting employee for
 all chanicals used in Headquarters buildings occupied by the Agency,
 contractor or owner personnel,   Management will request that MSDS's are
 provided by contractors for all the chemicals being used in the  building.

      The integrated Pest Management program shall be used to control
 insects and vermin within the buildings so that pesticide use will be
'kept as low as possible.

 a.   Sicking

      Btployeea are ethically responsible for naking sure that their
 colleagues are not adversely affected by pollutants brought into their
-buildings for their personal use (e.g.,  hair sprays,  cosnatics,  etc.) QZ
 created within the building by personal habits (e.g.,  smoking, stared
 food, etc.)

      The Agency understands that a smoking policy will increase  stress to
 certain employees.  However, the goal of the Headquarters smoking policy
 is  to minimize exposure of nonsncking EPA Headquarters employees to second
hand smoke. This  goal will be achieved by Uniting all  sucking to areas
where the air 'is exhausted outside the building and not returned into the
general  building ventilation systems.  At this tine the only locations
meeting this requirement are res treats.

     To  reduce  the inconvenience to both smokers and nonsmokers,  rest-rears
on  approximately every third floor, starting with the  second floor, will be
designated as smoking restrccns  if  this  is permitted by  the building  owners.
Smoking  will not be permitted in the  restrccns that are not designated.

     This rule will take effect  15 days after signing.  During the first 6
months,  penalties  for non compliance with  the smoking policy will be  limtec
to  warnings through reprimands.  After 6 months the parties will  convene to
resolve  any problems that have arisen.  This delayed enforcement  will perm1
smokers  time to adjust to the change and atterpt to quit smoking. Also, al
designated  smoking restroons will be checked  to insure that their exhaust
systems  are functioning to a level which will insure that smcke generated i
the restroom is exhausted and does not enter the general work place.  Rest-
rooms exhaust rates will be checked prior  to  the mplementation of the
smoking policy using velometers to measure the exhaust rate.  Stoke tubes
will be  used to determine that a negative  pressure exists in the  restrccr.
with respect to the general building air pressure.  Ventilation in the


                                   -3-

-------
  designated snxxirrj res-.ruJTs *il^ .>2 checked  -w-jally.  !
-------
      Only persons adequately trained and wearuic protective equipment
 should be allowed in the area during, immediately following,  the  fire.

      Since decontamination may be necessary, wipe sanples will be taken
 and analyzed- by CHSS.  PCB contaminated items will be decontaminated or
 discarded so they will pose no hazard to employees.
      The Occupational Health and Safety Staff will institute a radon
 monitoring program in each of the buildings occupied by EPA Headquarters
 employees sufficient in scope to assess whether there  is any health risk
 to employees associated with radon exposure during the work day.  The
 results of 'such surveys and the assessment will be nade available to the
 Union and the Facilities Advisory Council.

 d.   Solvents

   •   Bnployees will not be exposed to chemicals at levels known to be
 toxic or acutely irritating to the eyes, nose or throat or cause other
 physical ills to employees.  construction work  in  the  buildings which
 results in the release of irritating or toxic dusts, aerosols or vapors
 will be conducted during atployee non work  hours whenever warranted.  If
 construction, work which would result in such releases must be conducted
 during work hours, EPA employees will  be assigned  to other work space
 not  affected by the activity.  •

      New carpeting shall be shaqpcoed  before the space is occupied unless
 it has been properly aired out or has  been  shown to not emit chemicals
 which cause health reactions to occupants.   If vapors  frcn carpeting or
 furniture result in a health reaction,  the  affected employees should be
 allowed to work at a temporary location until the problen is solved.
 tenagenent will provide safe and healthful working conditions.   If con-
 ditions at a work station are found to endanger  the health of an employee,
management will take reasonable actions to protect the employee.

 e.   Asbestos

     The Asbestos Operations and Maintenance program is currently undei
 revision and will be added  in as soon  as it is ccrpleted.

 3.   Occupational  Health Survey

     The Agency  shall perform an occupational health survey cf Headquarters
 orployees  to obtain baseline information on employees health and  indoor
air  pollution.   Results of  the study will be surTiarized and nade  available
tp the  Union and  Facilities Advisory Council.  Subsequent surveys will
be initiated in response to  specific problems.
                                   -5-

-------
 4.  Dae of Technical Expertise

      Managenent will request the support cf the Agency's o*n scientific
 and technical experts to help resolve Headquarters employee health
 related issues.

 5'.  OamTurucation

      The Agency will establish and maintain a forur. for the sharing
 of information between enplcyees and upper management concerning health -,
 and safety issues at the Headquarters buildings.  This forun (called  the
 Facilities Advisory Oauncil) will consist of management officials  an.*
 interested employees.

      FAC will meet on a regular basis every 4-6 weeks.   The agenda will
 be posted in all Headquarters facilities in advance and management will
 review topics for discussion fron all employees.
By their signatures, the duly authorized representatives of the ft.   can
Federation of Government Employees,  Local 3331,  the National Federation
of Federal Employees, local 2050 and .the Headquarters,  Bwironnental
Protection Agency attest that they have agreed to and executed this
collective bargaining agreement.
      For ATCE, Local 3331
                      r NFFS,  Local 2050
                 g^^
fery Qjaato
President''
CATE
               President
For the Agency
                                                    tvD^l
                   W. Hu.rzy
                resident Elect
                          LATE
Ceralil A. 'Bryan   Y

-------
 /         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 «
                        NOV  | 7 '989
FILE
MEMORANDUM TO ALL HEADQUARTERS EMPLOYEES

SUBJECT:  Health and Safety Concerns at Waterside Mall


      In a recent memorandum to all employees,  Bill Reilly expressed
his  concerns  about  the working conditions in  the .Waterside  Mall
facility  and  his  commitment to seeing that  these  conditions are
improved  significantly.  The unions and other concerned employees
have  also devoted  much time  and energy  in  identifying  issues
associated  with the  Headquarters facility.   Consequently,  the
Office of Administration and Resources Management (OARM) staff and
union officials have met several times to address these concerns.
Our goal  is to work together to improve the indoor air quality at
Waterside Mall and to take whatever steps are necessary to provide
EPA  employees  with a  safe and healthful  work environment.    As
promised  in Bill's memorandum, we  will be  communicating  with you
on a continuing basis as to the specific actions that we are taking
to address health and safety needs.  This memorandum is the first
of these  communications.   Listed below are the actions  that are
being taken.

Creation of a Labor-Management Health and Safety  Committee

     To assure that we are receiving1 adequate input from employees,
we are establishing a Health and Safety Committee  to be comprised
of  an  equal   number   of   representatives  from  the  unions   and
management.   The purpose of this group is  to develop strategies,
identify problems, and set priorities for  corrective actions.  We
have  already met several  times to discuss the formation  of  this
committee.  The unions will  continue working  closely with their
bargaining unit members on a range of issues  affecting the health
and safety of  Agency personnel.  The unions will conduct a meeting
for all interested employees on December 7,  from 12:00 to  1:00p.m.
in the EPA Auditorium.

Ventilation Enhancements

     Many employees  have complained of poor office air quality  in
the mornings,  particularly on Mondays.   To correct this, we are
pleased to announce that Facilities will operate the  ventilation
system on an extended basis, effective November  17.   Specifically,
Facilities will run  the system  on Sunday and start the  system
earlier on weekday mornings.

-------
                              -2-

     OARM  has'ihired a ventilation engineer  to design corrective
actions and "-to  provide  immediate  recommendations to meet the new
American Society  of Heating,  Refrigeration,  and Air-Conditioning
Engineers  (ASHRAE)  standard for the introduction  of cuts-do dir
into the workspace of 20 cubic feet per minute  per  employee.  This
action will  help attain  the  goals  set  forth  in  the  Indoor Air
Quality Collective  Bargaining Agreement  of July 1937.   OARM will
also obtain the services of a  construction engineer to assure that
corrective actions are completed as designed.

New Space

     As requested, GSA is about to sign a lease for 50,000 square
feet of additional  space in Crystal  City.    While  this  space was
requested to  accommodate new  employees  hired  as a result of the
FIFRA Amendments,  it will allow the Agency  to ease some of the
overcrowding.   Another  request  for  space is  being prepared  to
further relieve the overcrowding.

Carpet Removal

     The first 2,000 square feet of carpet was removed  from room
2827 of the mall  over the weekend of September 23 and 24.   As
result of recent flooding,  Facilities has also removed carpet fro
portions of the East and West Towers.  We- are now compiling a list
of other  areas from which we will  remove  carpet.   One  of the
initial tasks to be  addressed by the 'Health  and Safety  Committee
will be to set priorities  of rooms for carpet  removal.   Together
with program managers we will inform all affected  employees in a
systematic  and  timely   fashion  to  minimize  disruption.    The
committee will also review the advisability  of replacing the old
carpet with new  carpet or tile.  At this point in time, carpet that
is removed is being replaced with  tile.

Elevators

     We recognize that the elevators were not  designed to handle
the inordinate number of passengers and amount  of freight traffic
on a sustained  basis.    Accordingly, Facilities has started the
complete overhaul of all  the  elevators,  beginning with  the East
Tower.   This will ensure their safe and efficient use.  As a part
of this project,  Facilities will upgrade  the  cabs to meet current
standards  for  handicapped accessibility  and  computerize  the
operating system to make it run  more  effectively.

-------
                               -3-

Comrauni cations

     To  provide a more  effective  method of promptly  identifying
problem  areas,  the Facilities  Management and Services  Division is
restructuring  its operations office so  that each  AA~ will have a
single   contact  point   for  these  types  of   issues.     Each
Assistant/Associate Administrator  (AA) will be asked to designate
a  liaison within his/her organization to act as  the facilities
ombudsman  to  interact with.  Facilities and  the Health and Safety
Committee.

     We  are acutely  aware  of  the challenges presented  by this
building.   Nonetheless,  we  are committed  to carrying  out Bill
Reilly's  pledge  to  you  to  provide  a  safe  and  healthful  work
environment.  With your help  and understanding, we will accomplish
this task.
Loree Murrayfl       Charles L. Grizzle ££/        Robert Carton
President           Assistant Administrator       President
AFGE                OARM •                         NFFE

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           APPENDIX 3
               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          WASHINGTON. D.C.  20460

                                                             OFFICE of
                                                             INISTRATIO
                                                             O RESOURCE
                                                            MANAGEMEN"
Honorable Barbara A. Mikulski
Chair, VA, HUD and Independent
  Agencies Subcommittee
Committee on Appropriations
United States Senate
Washington, D. C. 20510

Dear Madam Chair:

     This is the first in a series of reports you will be receiving
which highlight our efforts to provide our employees with a quality
working environment.

     Attached is the Environmental Protection Agency's  (EPA)  plan
of action to remedy the concerns associated with the Waterside Mall
(WSM) complex.  As you will note,  the plan  contains key  milestones
which represent realistic time frames for completing major building
enhancements  and modifications.   We  have been  conservative  in
estimating our start and completion dates,  since we do not wish .to
create expectations which cannot be fulfilled.  Also, we  have taken
into consideration factors which could delay implementation.

     Some of the problems associated with EPA's occupancy  in WSM
are caused by overcrowding.   We  have been working with the General
Services Administration on this  matter,  and have been assured that
our space needs will be met.  As a result of these meetings, we are
seeking to  procure an additional  150,000  square  feet  of  office
space in the Washington Metropolitan area.  This space will be used
to  house  both  new  hires  as  well  as   to   alleviate   current
overcrowding.

     Additionally, we  have been working with  the  unions to  gain
their input concerning building deficiencies and to share with then
our proposals  for  addressing these concerns.   The enclosed  plan
represents a joint venture between  EPA management and  the  unions
to ensure that our Headquarters facility meets the highest  building
standard.

-------
                               -2-
     Your  concern  for the  quality  of  Federal work  space  is
appreciated.  I am sure that all of us working together can
ensure that  EPA employees will be  housed in a  safe  and healthy
facility.  Your continued interest and support is welcomed.

                              Sincerely,
                              Charles L.'GrizzJo&y
                              Assistant Administrator

-------
   U.S.  ENVKKQ*
SCHEDULE OF
                                                    RL P1RDTECTION AGBO
                                                   ^ IMPROVEMENT ACTIVITIES
ACTIVITY
    START
    DATE
OJMPLETION
   DATE
COST
REMARKS
A. Voitilation Study
         Contract with Engineering   11/01/89
         Design Group for recommen-
         dations to make HVAC systems
         more effective
                01/12/90
                     $60,000
      2. Implement Study Recommen-
         dations
    01/15/90     unknown
                     unknown
                Initial HV7C iro^stigation
                completed
                Cost and completion
                date will not be known until
                study is complete.  We plan
                to approach the project
                in stages, improving
                the worst areas first.
B. HVAC Modifications

      1. Ex tend hours of HVAC         11/17/89
         operation to start earlier
         in the am and run longer
         on Sunday
                   NA
                    $473,000
      2. New Air Handling Unit
         for rooms  3219 & 3404
      3. New Air Handling Unit
         for rooms 3009, 3242,
         & parts of 3238
    11/20/89    12/22/89
                     $50,000
    12/11/89    01/16/90
                     $40,000
                Increase in annual utilities
                costs
                Will add 2,500 cubic feet
                per minute (CFM)  of air
                to the SW corner of the
                3rd floor  of  the Mall
                    »
                Will add 2,500 CFM of air
                to the NW  corner of  the
                3rd floor  of  the Mall

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                                                    -2-
ACTIVITY
START
DATE
COMPLETION
   DATE
COST
REMARKS
B. HVAC Modifications (Cont.)

      4. New Air Handling Unit
         for rooms  3002,  3006,
         3519, and part of 3020

      5. Vent Copy Rooms at WSM,
         Fairchild, and Crystal
         directly outside
C. Remove Carpet and Tile Hotspots

      1. Room 2003

      2. Rooms 2821

      3. Room 2809, 2811, & 2815

      4. Room 2817

      5. Rooms 2102 & S205

      6. Room SE205

      7. Schedule other rooms
         and continue
02/01/90    02/28/90
03/01/90    until
            completed
                   $45,000
                  $240,000(est)
12/09/89
12/15/89
01/05/90
01/12/90
01/19/90
01/26/90
02/03/90
12/10/89
12/18/89
01/08/90
01/15/90
01/22/90
01/29/90
ongoing
$7,000
$4,200
$10,800
$9,000
$2,200
$7,200
$330,000
                Will add 2,500 CFM of air
                to the NW corner of  the
                3rd floor  of the Mall

                24 copy centers at
                $10,000 each
                                                IMSD  space,  1,500 sq  ft

                                                OSW space, 1,093 sq ft

                                                OSW space, 2,662 sq ft

                                                OSW space, 1,994 sq ft

                                                OSW space, 600 sq ft

                                                OSW space, 1,900 sq ft

                                                approx. $4/  sq ft

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                                                -3-
ACTIVITY
D. Elevator Overhaul

      1. Replace door closure
         mechanisms

      2. Upgrade panels to meet
         requirements for
         handicapped employees

      3. Computerize elevator
         control mechanisms
E. Space Acquisition

      1. Crystal City #1
      2. Northeast Mall
         Sub-basement
      3. Crystal City  #2
      4. Additional space
F. Indoor Air Management Plan

      1. Prepare Comprehensive
         Indoor Air Management
         Plan
START
DATE
01/02/90


01/02/90
12/07/90
02/01/90
COMPLETION
   DATE
03/31/90
03/31/90
     COST
RUWKKS
05/01/90    09/30/90
Request
Sent
01/01/89
08/26/88
Rent*
Begins
03/01/90
01/01/90
 09/30/90


 02/01/91




 01/31/90
   $90,000
  $140,000
                  $600,000
                            Rent
                              $758,331 (FY90)
                            $1,300,000 (FY91)

                              $264,000 (FY90)
                              $352,000 (FY91)
   $217,000  (FY90)
$1,300,000 (FY91)
East and West Tower
elevators

All elevators
                    East  and West Tower
                    elevator banks. Requires
                    the awarding of a new
                    contract
50,000 sq ft for FIFRA
employees

16,000 sq ft for
Contractors RMD, NICT,
etc.

 50,000 sq ft for
1990 growth
  $933,000 (FY91)    We've been working  with
$1,400,000 (FY92)  GSA to get additional space
                    to reduce overcrowding
                               $20,000
                    Currently meeting with
                    unions and preparing plan
* Occupancy gene tally occurs  one month after rent begins to allow for Agency build-out,

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V*.
              UNITED STATES ENVIRONMENTAL PR01LCTION AGENCY
                         WASHINGTON. D C.  20460
    'f
                           ,WN 2 6 1990
                                                           OFFICE OF
                                                          ADMINISTRATION
                                                          AND RESOURCES
Honorable Barbara A. Mikulski                             MANAGEMENT
Chair, VA, HUD, and Independent
  Agencies Subcommittee
Committee on Appropriations
United States Senate
Washington, D. C. 20510

Dear Madam Chair:

     Last month,  I  promised to provide  you  with regular reports
which highlight our efforts to provide EPA employees with a quality
work environment.  This is the second of these reports.

     During the last month,  we  completed the installation of the
first of the new air handling units and are nearing completion on
the second.  Work to rebalance the air distribution in the larger
zone where the  first  unit was installed is  ongoing.   The carpet
removal, elevator upgrades,  and  the space acquisitions detailed in
our last report are on schedule  and we have added additional rooms
for carpet removal to this month's schedule.   We are also working
to award  a large carpet  removal and tile installation  contract
which will allow us to accelerate this portion of the work.   The
indoor air management  plan  will be completed  as  scheduled.   Our
only disappointment was with the  draft report on the ventilation
study.  We have directed the engineering firm  to perform additional
analyses and  provide  a more detailed  report by the  end  of this
month.

     We have been working  with the unions on these issues and will
continue to meet and negotiate with them.  As you might expect, we
are not always in total agreement. However,  I believe we have the
same goals,  and as we continue to  talk and understand each other's
concerns the intensity of the situation will  subside.

    -If you have  any  questions  regarding the  enclosed schedule,
please call me  on 382-4600  or have your staff call  Rich Lemley,
Acting Director,  Facilities  Management and  Services  Division on
382-2030.

                                   Sincerely,
                                   Charles L.  Grizzle
                                   Assistant Administrator
Enclosure

-------
                      U.S. ENVIRONMENTAL PROTECTION AGENCY
                   SCHEDULE OF BUILDING IMPROVEMENT ACTIVITIES
    ACTIVITY
A.  Ventilation Study.

    1. Contract with Engineer-
       ing Design Group for
       recommendations to make
       HVAC systems more effec-
       tive

    Remarks:

       Project delayed.  Draft
       report not acceptable.
       Contractor directed to
       perform additional analyses.
       Next draft expected 1/26/90.

    2. Implement Study Recommen-
       dations.

    Remarks:

       Cost and completion date
       will not be known until
       study is complete.  We
       plan to approach the pro-
       ject in stages,  improving
       the worst areas first.
       New start date will be
       1/29/90.
START
DATE

11/01/89
COMPLETION
    DATE

01/12/90
COST
$60,000
01/15/90
Unknown
Unknown

-------
    ACTIVITY
START
DATE
COMPLETION
    DATE
COST
B.  HVAC Modifications

    1. Extend hours of HVAC           1/17/89
       operation to start earlier
       in the a.m. and run longer
       on Sunday

    Remarks:

       Cost is annual increase in
       utilities costs.

    2. New Air Handling Unit          11/20/89
       for Rooms 3219 & 3404

    Remarks:

       Completed

    3. New Air Handling Unit          12/11/89
       for Rooms 3009, 3242,
       and parts of 3248

    Remarks:

       Project delayed.  New
       completion date is 1/30/80.

    4. New Air Handling Unit          02/01/90
       for rooms 3002, 3006,
       3519, and part of 3020

    Remarks:

       Will add 2,500 CFM of air
       in the NW corner of the third
       floor of the Mall

    5. Vent Copy Rooms at WSM,        03/01/90
       Fairchild, and Crystal
       directly outside

    Remarks:

        24 copy centers at $10,000
        each.   Cost proposal for
        N.E. Mall received 1/17/90.
               N/A
               12/22/89
               01/16/90
               02/28/90
               Until
               Completed
               $473,000
               $ 50,000
               $ 40,000
               $ 45,000
               $240,000
               (Estimate)

-------
ACTIVITY
B.  HVAC Modifications  (Continued)

    6.  Relocate outside air
        intake- to avoid exhaust
        fumes-..

    Remarks:

        Completed.  Building owner
        corrected initial installa-
        tion deficiency at no cost.

C.  Remove Carpet and Tile Hotspots

    1.  Room 2003
    2.  Room 2821
    3.  Rooms 2809, 2811, & 2815
    4.  Room 2817
    5.  Room 2102
    6.  -Room SE205 and part, of 2101
    7.  Rooms 3225 & 3410
    8.  Room SE225
    9.  Room SE226
    10. Room SE273
    11. Room SE 274
    12. Room 3006
    13. Schedule other rooms

    Remarks•

        Items 1-5 completed.
        6.  OSW space, 1,900 sq. ft.
        7.  OCEM space 1,700 sq. ft.
        8.  OERR space 1,200 sq. ft.
              II    II     f\f\ft fmrf
    9.
   10.
   11.
n
n
it
n
n
it
                         900 sq,
                       1,000 sq.
                         600 sq.
                         800 sq.
ft,
ft.
ft,
   12.   OPPE space   800 sq.  ft
   13.   Approximate $4 sq.  foot
                        START
                        DATE
                                  01/02/90
                                  12/09/89
                                  12/15/89
                                  01/05/90
                                  01/12/90
                                  01/19/90
                                  02/02/90
                                  02/09/90
                                  02/16/90
                                  02/23/90
                                  03/02/90
                                  03/09/90
                                  03/16/90
                                  COMPLETION
                                      DATE
                                       01/16/90
                                       12/10/89
                                       12/18/89
                                       01/08/90
                                       01/15/90
                                       01/22/90
                                       02/05/90
                                       02/12/90
                                       02/19/90
                                       02/26/90
                                       03/05/90
                                       03/12/90
                                       03/19/90
                                       ongoing
                                                                     COST
                                                  None
                                                  $  7,000
                                                  $  4,200
                                                  $ 10,800
                                                  $  9,000
                                                     2,200
                                                     7,200
                                                     r
                                    $
                                    $
                                    $
                                    $      o
                                    $  3,oOO
                                       4,000
                                       2,400
                                    $  3,200
                                    $300,000
                                                  $
                                                  $

-------
    ACTIVITY
Elevator Overhaul

1
E.
        Replace door closure
        mechanisms- East and
        West Towers

        Upgrade panels to meet
        requirements for handi-
        capped employees - All
        elevators

        Computerize elevator
        control mechanisms -
        East and West Towers
                                  START
                                  DATE
01/02/90
                                  01/02/90
                                  05/01/90
    Remarks:

        1.
        Two elevator cabs in
        the West Tower and one
        in-the East Tower have
        been completed.

        Start date delayed but
        completion still expected
        for 3/31/90.

        Requires the awarding
        of a new contract.
Space Acquisition

1.  Crystal City #1

2.  Northeast Mall
    Sub-basement
3.  Crystal City #2

4.  Additional Space


Remarks:

    1.  65,000 sq. ft,
        available starting
        4/1/90

    2.  16,000 sq. ft.
        available 2/1/90
                                  Request
                                  Sent

                                 01/01/89

                                 08/26/88

                                 12/07/90

                                 02/01/90
                                                 COMPLETION
                                                     DATE
                                                 03/31/90
               03/31/90
               09/30/90
               Rent*
               Begins

              03/01/90

              01/01/90

              09/30/90

              02/01/91
                              COST
     $  90,000
                                                                $140,000
                                                                $600,000
    Rent

$  758,331-
$1,300,000-
$  264,000-
$  352,000-
$  217,000-
$1,400,000-
$  933,000-
$1,400,000-
                                                                          FY90
                                                                          FY91
                                                                          FY90
                                                                          FY91
                                                                          FY90
                                                                          FY91
                                                                          FY91
                                                                          FY92

-------
                                      START          COMPLETION
    ACTIVITY	                    DATE               DATE       COST

E.  Space Acquisition (Continued)

    Remarks:

     3.  50,000 sq. ft.  for
            199'0 growth

     4.  Space request to GSA
         to reduce overcrowding

    * Rent usually begins one month before occupancy.

F.  Indoor Air Management Plan

    1.  Prepare Comprehensive                        01/31/90  $   20,000
        Indoor Air Management
        Plan

     Remarks s

        Meeting with Unions to
        discuss draft.

-------
      UNITRD STATES ENVIRONMENTAL PROTECTION AGENCY
                     WASHINGTON. D.C. 20460
                         FEB 27 1990
                                                      OFFICE OF
                                                    ADMINISTRATION
                                                    AND RESOURCES
                                                    MANAGEMENT
Honorable  Barbara A. Mikulski
Chair, VA, HUD,  and  Independent
  Agencies Subcommittee
Committee  on Appropriations
United States Senate
Washington, D.C.  20510

Dear Madam Chair:

     Enclosed  is our February  report on efforts  to provide  EPA
employees  with a quality work environment.

     During the  last month, we completed the Indoor Air Management
Plan and received the report from our contract engineers containing
recommendations  for enhancing indoor air quality at Waterside Mall,
Both of these items are discussed further below.  The installation
of  the  second of  the new air  handling units was completed  and
although  initiation of  the  installation of the  third  unit  was
delayed, the work  is now progressing nicely.   We are actually a
little ahead of  our schedule for  carpet removal,  having  removed
over 25,000 square feet of carpet  and replaced it  with vinyl tile
from November through last weekend. As can be seen on the attached
schedule,  we are also on track on  the elevator upgrades  and space
acquisition.

     As we indicated last month,  we  have been meeting  regularly
with  both  our  unions  on  the  development  of  our  Indoor   Air
Management Plan.  The National Federation  of Federal Employees,
declined to approve the plan because it did not state that we would
remove all carpet  from our headquarters  buildings.  Previously,
they had only requested removal of  the carpet which was  installed
in the fall of 1987 and  spring of  1988.  However, even while these
discussions continue, we are proceeding to implement the  plan.  We
will keep  you  advised of the status  of  our discussions with  the
unions.

-------
     As stated  above, we  now have the ventilation  study report.
The findings and recommendations contained in it  do not point to
a single, cause or cure for our problems.  However, upon discussions
with several indoor air experts,  we  understand  that this is most
often the  case.   The problems in  our  buildings did not  crop up
overnight from a single cause—and they will  not be solved with a
single fix.  The solutions to our situation lie  in the completion
of the tasks listed in our schedule, as well as the implementation
of the recommendations in the report and the methods and procedures
in our Indoor Air Management Plan.  We are proceeding accordingly.
As  tasks  and  dates become  firm, these  will  be  added to  our
schedule.

     If you have any questions, or  if you would like to see a copy
of our Indoor Air Management Plan,  please  do  not hesitate to call
me.

                              Sincerely,
                           /  /-
                          /"^Charles  L.  Grizzle
                         / /^Assistant Administrator

Enclosure

-------
                      U.S. ENVIRONMENTAL PROTECTION AGENCY
                   SCHEDULE OF BUILDING IMPROVEMENT ACTIVITIES
    ACTIVITY
A.  Ventilation Study

    1. Contract with Engineer-
       ing Design Group for
       recommendations to make
       HVAC systems more effec-
       tive

    Remarks:  Draft report
    received. -Recommendations
    include increasing minimum
    outside air mix to 20%,
    cleaning of ducts, direct
    exhausting of copy
    centers, and enhancing
    filtration.
START
DATE

11/01/89
COMPLETION
    DATE

01/26/90
COST
$60,000
    2. Implement Study Recommen-
       dations.

    Remarks:  We have begun dis-
    cussions with our contracts
    office to determine the
    quickest strategy for imple-
    mentation. _As dates and costs
    are established, they will be
    reflected.  Copy center
    exhausting work has begun and
    is reflected under a new sub-
    heading G.
01/29/90
Unknown
Unknown

-------
    ACTIVITY
START
DATE
COMPLETION
    DATE
COST
B.   HVAC Modifications

    1.  Extend hours of HVAC          1/17/89
       operation to start earlier
       in the a.m.  and run longer
       on Sunday

    Remarks:   Cost is annual
    increase  in utilities costs.

    2.  New Air Handling Unit         11/20/89
       for Rooms 3219 & 3404

    Remarks:   Completed
               N/A
               12/22/89
                $473,000
                $  50,000
    3.  New Air Handling Unit
       for Rooms 3009,  3242,
       and parts of 3248

    Remarks:   Completed

    4.  New Air Handling Unit
       for rooms 3002,  3006,
       3519,  and part of 3020

    Remarks:   Project delayed
    while new mechanical room
    to  house  air handling unit
    is  constructed.  New sched-
    uled completion date is
    03/30/90.

    5.   Relocate outside air
        intake to avoid exhaust
        fumes.
12/11/89
01/30/90
02/01/90
02/28/90
$ 40,000
$ 45,000
01/02/90
01/16/90
None
    Remarks:   Completed.   Building
    owner corrected initial  installa-
    tion  deficiency at no cost.

-------
    ACTIVITY
START
DATE
COMPLETION
    DATE
COST
C.  Remove Carpet and Tile Hotspots

    1.  Room 2003                     12/09/89
    2.  Room 2821                     12/15/89
    3.  Rooms 2809, 2811, & 2815      01/05/90
    4.  Room 2817                     01/12/90
    5.  Room 2102                     01/19/90
    6.  Room SE205 and part of 2101   02/02/90
    7.  Rooms 3225 & 3410             02/09/90
    8.  Room SE225                    02/16/90
    9.  Room SE226                    02/16/90
    10. Room SE273                    02/23/90
    11. Room SE274                    02/23/90
    12. Room 3241                     03/02/90
    13. Rooms SE256 and 264E          03/09/90
    14. Room 3103-13                  03/16/90
    15. Room 3006                     03/23/90
    16. Schedule other rooms
               12/10/89
               12/18/89
               01/08/90
               01/15/90
               01/22/90
               02/05/90
               02/12/90
               02/19/90
               02/19/90
               02/26/90
               02/26/90
               03/05/90
               03/12/90
               03/19/90
               03/26/90
               Ongoing
               $
               $
   7,000
   4,200
$ 10,800
$  9,000
   2,200
   7,200
   6,800
   4,800
   3,600
   4,000
   2,400
               $  3,200
               $300/000
    Remarks:

    Items 1-11 completed.
    Removed approximately 25,000
    square feet to date.

-------
ACTIVITY
                                  START
                                  DATE
                                  01/02/90



                                  03/01/90
Elevator Overhaul

1.,  Replace door closure
    mechanisms

2.  Upgrade panels to.meet
    requirements for handi-
    capped, employees - All
    elevators

3.  Install electric eyes on
    on all elevators

4.  Computerize elevator
    control mechanisms -
    East and West Towers

Remarks:
1.  Door mechanisms on all four cars
    in East Tower have been replaced;
    cars 1 and 2 in West Tower complete.

2.  Awaiting arrival of parts to begin work.

3.  Same as 2 above.

4.  Requires awarding of new
    contract.
Space Acquisition

1.  Crystal City #1

2.  l.'ortheast Mall
    Sub-basement
3.  Crystal City #2

4.  Additional Space

Remarks:

1.  65,000 sq. ft,
    available starting
    5/1/90

2.  16,000 sq. ft. occupied
    2/16/90
                                   Request
                                   Sent

                                 01/01/89

                                 08/26/88

                                 12/07/90

                                 02/01/90
 COMPLETION
     DATE
 03/31/90



 04/14/90
Rent*
Begins

04/01/90

02/01/90

09/30/90

02/01/91
COST




$ 90,000



$140,000
03/01/90
05/01/90
04/15/90
09/30/90
$ 52,386
$600,000

-------
    ACTIVITY
            START
            DATE
COMPLETION
    DATE
COST
E.  Space Acquisition  (Continued)

    Remarks:

    3.  50,000 sq. ft. for
        1990 growth

    4.  Space request to GSA
        to reduce overcrowding

    * Rent usually begins one month before occupancy.
F.  Indoor Air Management Plan

    1.  Prepare Comprehensive
        Indoor Air Management
        Plan
                           01/31/90   $  .  20,000
    Remarks:  Completed.
    with unions.
Negotiating
6.  Copy Center Exhausting

    1.  Main Mall Copy Center         02/20/80
        Room 3501

    Remarks:  Will exhaust
    toner, paper dust and
    heat directly outside

    2.  Northeast Mall Copy           02/26/90
        Centers - Rooms 107,206,
        and 320

    Remarks:  Will exhaust t.cr,:r,
    paper oust and heat uiiu^ciy
    outside.

    3.  Southeast Mall Copy           03/05/90
        Centers - Rooms 216 and
        310

    Remarks:  Will exhaust toner,
    paper dust and heat directly
    outside.
                           03/09/90   $     9,780
                          03/16/90   $    27,380
                          03/30/90  $   23,340

-------
    ACTIVITY
START
DATE
COMPLETION
    DATE       COST
G.  Copy Center Exhausting (Continued)

    4.  Award contracts for other    03/01/90
        copy centers

    Remarks:  24 copy centers
    in total, 18 left to do.
    Estimated at $10,000 each
               Until     $   180,000
               Completed

-------
Exhibit ES-2:
                                                       !  Iraployee Survey
                                                       EPA Headquarters
Percent or All Respondents Who Had Symptoms ORen or Always  Last Year that
Got Better Upon Leaving Work, by EPA Headquarters Building and by Group of
Symptoms
SYMPTOM
Indoor Air Quality Symptoms
Headache
Runny nose
Stuffy nose/sinus congestion
Dry, itching, or tearing eyes
Burning eyes
Dry throat
Unusual fatigue or tiredness
Sleepiness or drowsiness
Respiratory or Ru-lOce Symptoms
Cough
Wheezing or whistling in chest
Shortness of breath
Chest tightness
Fever
Aching muscles or joints
Erconomic Symptoms
Pain or stiffness in upper back
Pain or stiffness in lower back
Pain or numbness in shoulder/neck
Pain or numbness in hands or wnsts
BUILDING
WATERSIDE
MALL

16%
8%
16%
17%
10%
10%
15%
15%

4%
1%
2%
2%
1%
4%

6%
6%
6%
2%
CRYSTAL
MALL

11%
9%
17%
12%
8%
7%
14%
19%

5%
1%
1%
1%
1%
4%

6%
6%
5%
2%
FAIRCHILD

16%
7%
15%
15%
11%
9%
11%
13%

4%
2%
2%
2%
'0%
2%

6%
4%
5%
2%
Reference: Part II. Question 7.
                                         ES-6

-------
                                                                              vuiuiiic i  i .iii[ii»yi:i:
                                                                                      EPA Headquarters
       5-3:     Percent of All Respondents Who Had Symptoms Often or Always Last Year and that
                Got Better Upon Leaving Work, by Sector in Waterside Mall
SYMPTOM
: Headache
i Nausea
Runny nose
Stuffy oose/sinus congestion
^-.p^jring
Cough:
Wheezing or whistling in chest
Shortness of breath
I _._ «i_i_^_
i ([jncst tffiutness
irjryi ifrfrmg_ or tearing eyes
Sore/strained eyes
Blurry/double vision
burning eyes
re throat
Hoarseness
Dry throat
rjonsoal fatigue or tiredness
Sleepiness or drowsiness
; Chills,
i Fever
Aching muscles or joints
: Problems with contact lenses*
Difficulty remembering things
Bizaaess/lightheadedness
Feeling depressed
Tension or nervousness
Difficulty concentrating
Dry or itchy skin
P'ain or stiffness in upper back
Pain- or stiffness in lower back
Pain or numbness in shoulder/neck
Pain or numbness in hands or wrists
WATERSIDE MALL SECTOR
EAST
TOWER
14%
1%
1%
15%
6%
4%
1%
1%
1%
14%
15%
4%
9%
3%
3%
8%
12%
13%
2%
4%
3%
24%
2%
3%
5%
9%
6%
6%
4%
4%
4%
2%
WEST
TOWER
13%
1%
9%
13%
7%
5%
1%
2%
1%
15%
14%
4%
10%
3%
3%
9%
15%
14%
5%
0%
4%
25%
2%
2%
5%
10%
6%
6%
8%
7%
5%
2%
MALL
2ND FLOOR
18%
1%
9%
16%
7%
6%
1%
3%
3%
21%
22%
7%
13%
7%
5%
15%
17%
18%
5%
0%
5%
45%
3%
5%
4%
12%
10%
8%
5%
4%
6%
4%
MALL
3RD FLOOR
19%
2%
10%
21%
8%
6%
2%
3%
2%
18%
18%
3%
11%
5%
3%
12%
17%
17%
5%
1%
5%
38%
3%
4%
5%
10%
10%
8%
7%
6^0
7^c
2%
NE
MALL
16%
2%
8%
16%
7%
4%
1%
3%
2%
13%
14%
3%
9%
3%
2%
8%
12%
14%
6%
1%
4%
31%
3%
3%
6%
9%
6%
6%
6%
7%
6%
\%
SE
MALL
18%
14%
8%
16%
6%
2%
2%
2%
2%
20%
19%
3%
10%
9%
4%
14%
15%
20%
4%
5%
6%
29%
1%
4%
5%
12%
10%
5%
4%
6%
4%
2%
   3e percentages are *3ased upon only the people who wear contact lenses at work 'sometimes, often or always" (Pan II. Question
    i. i* opposed to aH respondents in the budding.
Reference  P:irt II, Question 7.

-------
                                                                                EPA Headquarters
Exhibit 5-9:     Number and Percentage or Responding Employees Indicating Impact of Symptoms on
               Ability to Work Last Year, by EPA Headquarters Building

Symptoms Reduced
Ability to Work
Waterside Mall
Crystal Mall
Fairchild
Symptoms Resulted
In Staying Home or
Leaving Work Early
Waterside Mall
Crystal Mall
Fairchild
NUMBER

2,999
430
393

2,967
429
387
PERCENT RESPONDING
NEVER

32%
32%
38%

44%
46%
50%
RARELY

32%
31%
34%

30%
28%
28%
SOMETIMES

29%
31%
23%

23%
22%
21%
OFTEN

6%
6%
4%

2%
3%
1%
ALWAYS

1%
1%
1%

•
•
•
 'Always' was not a possible answer in Question 9.

Reference:  Part II, Questions 8 and 9.
                                            5-19

-------
                                                                  Volume I: Emplovec Survcv

                                                                         EPA Headquarters
Exhibit 5-10:   Percentage of Responding Employees Associating Symptoms with Building Last Year, by
              EPA Headquarters Building
                              WATERSIDE MALL   CRYSTAL MALL
                                    FAIRCHILD
   Percent Associating
   Symptoms with Building
 62%
56%
49%
   Symptoms Improved
   over the Last Year
 11%
 8%
 8%
   Symptoms became Worse
   over the Last Year
29%
26%
24%
   Symptoms Remained
   the Same
60%
66%
68%
   Employees Responding
2,922
418
379
Reference:  Part II, Question 11.
                                        5-21

-------
Exhibit 5-12:
                                                    Volume I- Employee Survev
                                                            EPA Headquarters
Percent of Responding Employees Reporting Increased Frequency and Duration
or Infection  Since Beginning Work at Building

Percent Having Infections:
More Frequently
Less Frequently
Same Frequency
Employees Responding
Percent Whose Infections:
Last Longer
Last Shorter
Last the Same
Employees Responding
BUILDING
WATERSIDE
MALL
39%
5%
56%
2,989
36%
3%
61%
2,935
CRYSTAL
MALL
31%
7%
62%
433
31%
4%
65%
428
i
FAJRCHILD
23%
9%
67%
396
23%
4%
72%
382
 "Infections" refer to colds, flu, bronchitis, etc.

Reference: Part II, Question 17.
                                            5-24

-------
         &  The University ol Arizona
         >™ i             *
             "CGI " "'}• i'lK>
              i"" 5" irr;
                   .                             ^^
             Occu5a-.onai Sa'e-v anr; Kc-ai'i                   p ^.O  6 ""
             Mecca Technology
       y  31,  1
Jeff Davidson. PhD
Section Chief
Existing Chemical Assistance Group
Division Office  of Toxic Substances
U.S. Environmental Protection Agency, Mail Code TS-778
East Tower  409
401 M St.,  SW
Washington, DC 20460

Dear Dr. Davidson:

    . I appreciate the  opportunity to be of assistance to the
U.S. Environmental Protection Agency, Office of Toxic
Substances, in evaluating several matters relating to indoor
air pollution including an episode of building related
illness at  EPA headquarters at Waterside Mall in Washington,
DC as well  as a  citizen's petition regarding "Control of Risk
Associated  With  Certain Carpeting."  Since the indoor air
pollution episode at Waterside Mall precipitated the
citizen's petition which relies,  to a considerable extent,
upon research conducted at the University of Arizona, School
of Health Related Professions, Tucson, Arizona, the
interpretation of pertinent data  in that petition and our
experience  with  indoor air pollution situations may be of
value to your office in addressing issues in the petition.

     In July of  1988,  I was requested by Mr. David Weitznan,
CIH. Industrial  Hygiene Programs  Manager with the U.S. EPA to
provide a scientific seminar on indoor air quality to EPA
employees at the Waterside Mall faculty.  At the same time, I
conducted a walk-through survey of various office areas
whare specific individuals had reported a variety of symptoms
Ccllowing the initiation of renovation activities in October
of 1937. including the installation of new carpet.

     This survey revealed rnau the- office renovation program
         installation  of  carpeting,  divider partitions and
office furnishings.  The  nylor  pile  carpet,  _n most areas,
:isd been installed with a  f^i-r-c^.-:  wadding,  whereas in hign
traffic a:cds, vhc carper '.n>;  A.-.S  . ::^t.-.llcd  with adnesivcs.
Other facility improvements  .:.-•! :dcd cleaning and paintinq.

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 .'ne pr until1/  c:c"iOi.ai;i •_ j  ox.pur ^o.'ic. u-d cy '••_i:"-ci^:: ornpioyocs
 - n •-J-dca  vyc aia  ndiSdi  ^rr itrit:ijn,  nsiujcsi.  ncjcichcs and 3k4.ri
 »• a sr.es.   Interestingly,  thcue ^ynproms aro  characteristic of
 r.hose  reported  *n otnci  cases ci  cuildir.g-related illness and
 ridvc; been associated with a variety of indoor air pollutants
 including chemical and  biological agents.   In other indoor
 -i-r toil-tioii scenarios,  r»o suspect source  or agent has ocen
 L.ic-Tir i £ied.

     Over the past ten  years I have had the opportunity to
 evaluate  numerous cases  of building-related illness in homes,
 office workplaces and schools.  Although the source of the
 problem was  frequently  linked to  an offending agent or source
 of which  there  were many,  interestingly the symptoms
 expressed by affected individuals in this environment were
 quite s'imilar to  those described  by certain individuals at
 the EPA.   This  observation of commonality in symptomatology
 with multiple causes indicates that when a  variety of
 pollutant sources contribute to an indoor episode,  stating
 that a causal relationship exists between just one agent and
 the onset of  health problems is difficult,  if not impossible.
 This particular point was  expressed at the  seminar I
 presented to  the  employees at EPA headquarters.   The myriad
 of compounds  introduced  into the  air of the EPA facility
 during the course of the  renovation would preclude
 establishing  an association between any one compound and the
 onset of  health problems  in certain individuals.   My
 experience in evaluating  such episodes reveals that several
 of  the materials  employed  during  renovation activities at the
 EPA could have -potentially contributed to the onset of ..
 problems  in some  individuals.   These materials include paint,
 carpet adhesive,  particle  board based furniture  and certain
 carpets.  In  practice, I have'questioned an association
 between these individual materials-and the  onset of the
 "tight building"  syndrome,  although no specific  chemical
 agent was targeted  as causative.  The air quality of the EPA
 facility was  certainly further compromised  by inadequate
 ventilation in  certain areas  as well as the presence of the
 odor of mold  in some stairwells which could be indicative of
 potential biological problems.

     The citizens' petition  submitted by the National
 Federation of Federal Employees (NFFE)  seeks to  protect its
members and the public from  potentially injurious  agents.
Unfortunately,  the petition  focjses  almost  entirely on the
 compound,  4-phenylcyclohexene  (4-PCH),  a known by-product
produced  in the manufacture  c:  carboxylated styrene-butadienc
 rubcer  (5BR)   latex employed  ro  adhere  the secondary carpet
beicking to the carpet tuft.   :~\ research at  tne  University of
Arizona,  4-PCH was discoveroc  ~.o  bo  a  unique and  odifcrous
r:cnnpounc comnon to many SBr-r-   ••.•-•"-  carpets  and,  therefore,
          of   f ;rtner roses:""

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 '*:  /M 1'^or.a riccivcc a number o: CdlLb i i -:~i .-ono-k-a:iLo
 Lhc general public pertaining to new 'jarpct odor -i:-> well cis
 rrq'.icbtis tor analysis.   IP. many instances, r.o 4-PCH w«s
 dore::tcd in carpet samples suomittcd for  analysis;  in ocvcral
 -^scs,  Lhe adhesive employed to glue down the carpets, rather
 • hrin t-hc- carper,  itself,  was found to be particularly
 of f CMS i'":.   In other  instances, carpeting several years old
 was cited ss a cause  of  ill-health althougn this situation
 was not  consistent with  our observation that only some new
 carpets  contribute to an odor problem.

      As  health specialists and toxicologists, we appreciate
 that most health effects are dose-dependent and. at the same
 time, there are  varying  degrees of susceptibility within the
 population.   These concepts are applicable to 4-PCH as well
 as  other chemicals.   Recent studies aimed at elucidating the
 acute toxicity cf 4-PCH, with which you are familiar, reveal
 a compound that  Is not particularly toxic.  At the same_time,
 animal inhalation studies at concentrations several orders of
 magnitude greater (16,000 ppb to 60,000 ppb) than those
 levels experienced by the public following installation of
 new carpet (4 ppb to  50  ppb), .demonstrated no indication of
 irritant effects.   Although the results of animal studies
 cannot be directly extrapolated to humans, this information
 suggests that 4-PCH should not serve as a irritant, at least
 for the  majority of the  public. . It is  also noteworthy -that
 our indoor  measurements  of 4-PCH levels suggest that only
 higher initial levels (greater than 5 ppb) may be associated
 with possible health  effects.  A review of the EPA Task Force
 study of t'-e indoor air  quality authored  by Highsmith et al
 (July 7,  i  38) revealed  4-PCH levels of only 1.5 ppb in a
 newly renovated  mall  office,  with lower levels measured
 elsewhere.   Based on  our experience, such levels are below
 those measured in "problem"  environments.

     With  regard to the  issue of multiple chemical
 sensitivity  (MCS),  I  would agree with the petitioner that
 evidence of  an association with 4-PCH is  lacking.   In the
medical  community, MCS is a controversial issue.  Having had
 the  opportunity  to assist medical toxicologists and other
 physicians  in evaluating such cases, I  can relate that
 numerous types of  exposures  have been linked to the onset of
 such a syndrome.

     The  issue of  indoor air  pollution  is a complex one that
deserves  tne  attention of our health community.   I  share with
 the petitioner his concerns  regarding the EPA episode of
 •ouildi:icj-r°latcd  illness.   The  causels) of this illness,
 however,   are  difficult to rosoivo on the  basis of  our currcr.t
 I'.vcl of  kr.owlodge  rogardir.u  rho offccrs  of low level
•j'-'nrd.tiip.ar.rs  on  human hcaltr..   The presence of 4-PCH -it
 ocii't ocular ly  low  level:;  durirj  '.nc period of tnc renovation
 i'.  EPA,   ':o-pled  ^i.th  the faor  tna*. so nany other factors

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 .ndo-r j.illution b Ltudt ion3, romj^.^^  on'j  to  'jonoi^'lo  that  no
 5-.11LC ^?cnt can be Mnrjlo'i o.- ai  -iav..r,g  ca ^e-a  tnc  cpisocc


     0/_-r the pAsr. several ycs.rs, I nave  cncc-Jiaged  the S5R
 latcix jr.d carpet rnanufacturinc; industry to explore -"GLhods to
 reduce1 tne level of voldtile organic  compounds  (VOGs),
 including 4-PCH, from their products.  Both  Lndustry  groups
 have responded, even in the absence of definitive data  that
 demonstrates a causal relationship  between 4-PCH  or  other
 products and the onset of health prcbiezns, ay supporting
 research at the University of Arizona and  elsewhere,  to
 alleviate potential problems with their products.  Based upon
 research efforts to date, I would expect  that the level of 4-
 ?CH and other VOCs in carpet should significantly decrease.

   -  As professionals interested in the health_of the public,
 I can assure you that we will continue to  investigate
 situations relevant to indoor air pollution.  I would
 encourage your office to support additional  research  which
 will help elucidate the causes of indoor  air pollution  and
methods for their control.

   " If I can be of further assistance, please-do not
hesitate to call.

Sincerely,       £


Mark Van Ert, PhD
Director, Occupational Safety
 and Health Program

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            APPENDIX '•>



Revised:  March 26, 1990

                           Attachment A

                          WORK STATEMENT

PURPOSE;

     It is the intention of the US EPA Headquarters Operations to
have the Town Center Management Corporation secure all labor,
material, equipment, and supervision for the thorough and
complete cleaning of heating, ventilating, and air conditioning
(HVAC) systems servicing the EPA within spaces that it leases at
the Waterside Mall complex in Washington, D.C.

KEY EPA PERSONNEL;

     Title                Name/Address         Responsibility

     Project Officer      Jim Engleka          Overall Project
                          EHSD                 Management
                          401 M St., SW
                          Washington, DC
                          20460
                          (202) .382-3640

     Contracting Officer      xxxx              xxxx
GENERAL DESCRIPTION;

1.   Independently, and not as an agent of the United States
     government, the contractor shall furnish to the Town Center
     Management Corporation all labor, materials and equipment
     required to power brush and vacuum clean (and/or steam
     clean, as needed) all of the HVAC systems servicing the EPA
     at Waterside Mall. Such cleaning is to effect the removal of
     dirt, dust, mold, and other contaminants from the HVAC
     systems. It is the intent of this Statement of Work that the
     meaning of the term heating, ventilating and air-
     conditioning (HVAC) systems as used herein includes: heating
     and cooling coils, reheat coils, filters, housings, air
     supply and return chambers and plenums,  make-up air ducts,
     motors, fans, deflectors, dampers,  baffles, drain pans,
     blower wheels, return air ducts and air supply ducts.

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2.   All work shall be performed by the Contractor in accordance
     with accepted industry standards.  Monitoring of the
     Contractor's performance of work may be conducted without
     notice to the Contractor,  and at any time,  by EPA
     representatives designated by the Contracting Officer.
     Additionally, the affected HVAC systems may be inspected at
     any reasonable time during the performance  of this cleaning
     work by EPA representatives designated by the Contracting .
     Officer. Representatives of the Town Center Management
     Corporation may elect to be present during  such monitoring
     and/or inspections; the EPA will advise the Town Center
     Management Corporation in advance of its intent to conduct
     monitoring and/or inspections.

3.   The Contractor must not change, alter,  damage or modify the
     mechanical, electrical, pneumatic or other  components
     of the HVAC system.  However, the contractor may cut
     access openings in sheet metal ducts as needed to
     facilitate cleaning. The Contractor shall use the same
     gauge sheet metal as the original construction to cover
     access openings.  Such openings shall be securely sealed
     with permanent gasketing material and fastened in place
     with screws to insure against subsequent air leakage.
     If dampers or other components of the system must be.
     moved by the Contractor in order to effect  proper
     cleaning, they must be returned to their proper
     position by the Contractor prior to the start of the
     following EPA business day. Any damage,  accidents,  or
     incidents that occur during the performance of work
     must be immediately reported verbally and in writing to
     the Town Center Management Corporation and  to the EPA.
     The Contractor is also requested to promptly notify
     Town Center Management Corporation and the  EPA of any
     problems or deficiencies noted concerning the HVAC
     systems.

4.   The Contractor shall take appropriate steps to prevent the
     dissemination of dust,  dirt,  and other contaminants within
     the building during the performance of work.  Prior to
     cleaning any ductwork,  it shall first be placed under
     negative pressure with respect to  surrounding spaces.   A
     vacuum system shall be used in this regard  which shall be
     arranged to capture debris and contaminants and to ensure
     maximum cleaning efficiency and results.  All debris and
     contaminants collected during the  cleaning  process shall be
     discarded into appropriate collection containers outside of
     the building. The Contractor is responsible for properly
     disposing of all  collected dust and dirt, as  well as debris
     and wastes, off of the premises.

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     The Contractor shall take appropriate measures to prevent
     the disturbance of, or damage to, asbestos containing
     building materials; the Contractor shall take necessary
     action to prevent the release of asbestos fibers into
     the air. Special attention is called to the asbestos
     areas located on the second ..floor of the Mall.
     Information about the location of asbestos containing
     building materials that are,  or likely to be, in the
     Contractor's work areas shall be provided to the
     Contractor by the Town Center Management Corporation.
     [This includes ceiling tiles, if any.] The Project
     Officer may arrange for an Asbestos Monitor to be
     present to observe the Contractor's work in certain
     locations where such surveillance is indicated by the
     EPA Headquarters asbestos management plans. If any
     asbestos containing building materials are disturbed or
     damaged, the Contractor must immediately notify the
     Town Center Management Corporation and the Project
     Officer. The Contractor is fully responsible for
     complying with all applicable asbestos related
     regulations.

     The contractor shall use drop cloths or other
     appropriate means to protect office furniture,
     fixtures, and equipment from dust and other
     contaminants. Floors, floor coverings and other
     surfaces within EPA work areas shall be immediately
     cleaned if dirtied or soiled by the Contractor.

5.   The Contractor shall use electric augured rope brushes, or
     equivalent means, to clean the interior of ductwork.
     If cleaning is required prior to the removal of
     insulation lining the ductwork,  portable shakers, or
     equivalent means, may be used.

6.   The Contractor shall remove from the interior of HVAC
     systems all fiberglass and other fibrous or porous
     sound insulating materials capable of trapping dust,
     dirt, or other particulate contaminants. Such
     insulating materials shall be replaced by the
     Contractor using methods and  materials approved in
     advance by both the EPA and Town Center Management
     Company. Replacement sound insulation shall be a non-
     fibrous type that has extremely  low potential for
     trapping and retaining dust,  dirt,  and other
     contaminants.

7.   The Contractor shall use only methods and materials approved
     in advance by the EPA and the Town Center Management
     Corporation.  Methods or materials may only be changed
     with the written permission of the EPA and the Town
     Center Management Corporation.

8.   The Contractor shall adhere to at least the following

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cleaning methods for ductwork,  which represent the minimum
approach acceptable to the EPA. However,  more efficient
methods may be used, provided the cost of performing such
alternative methods do not add to the cost of the contract.
If alternative methods are to be used, advance approval from
the EPA and the Town Center Management Corporation must be
obtained by the Contractor.

RETURN AIR DUCTWORK -

A.   the Contractor shall remove, wash,  and clean return air
     grills.  Upon removal, such grills shall be covered
     with plastic bags and taken to the loading dock area
     outside of the building for washing and cleaning;

B.   the Contractor shall connect a portable vacuum to the
     most remote point of the return air duct system, to
     place it under negative pressure;

C.   the Contractor shall clean the interiors of the
     individual ducts starting from the main trunk down to
     the return openings in the individual rooms;

D.   this process shall be repeated for each room serviced
     by the individual HVAC system before cleaning the
     associated horizontal main return trunk line;

E.   the Contractor shall reinstall all return grills;

F.   where possible, the interiors of the main return lines
     shall be cleaned by individuals within the duct line.

SUPPLY DUCTWORK -

A.   Since there may be reheat  coils in runouts,  the
     horizontal sections of runouts shall be vacuumed
     prior to vacuuming of the  vertical  sections;

B.   the main trunk supply lines shall be cleaned out prior
     to the supply runouts;

C.   the supply diffuser grills shall be  removed, cleaned
     and washed.   Upon removal,  the grills shall  be covered
     with plastic bags and taken to the  loading dock area
     outside of the building for washing  and cleaning;

D.   vacuum shall be applied to appropriate points of the
     ductwork during cleaning and power brushing;

F.   filter media shall be temporarily installed  immediately
     upstream of the supply air diffusers to prevent the .
     dissemination of residual  particulates into  workspaces
     when the air handling unit is turned on.   The filter
     media shall remain in the  system for a period of 24

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          hours after cleaning while the AHU operates. The
          contractor shall follow-up 24 hours later to remove
          filter media;

     H.   the contractor shall reinstall supply air diffusers
          after the filter media is removed.
9.   The Contractor shall thoroughly clean the interiors of all
     return air chambers and plenums.

          RETURN AIR PLENUMS AND CHAMBERS -

     A.   All surfaces within return air chambers and above-the-
          ceiling plenums shall be thoroughly cleaned.
          Where such plenums are separated from work
          areas by suspended acoustic ceiling tiles,
          the upper surfaces of ceiling tiles shall be
          vacuum cleaned;

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     B.   the Contractor shall promptly notify the designated
          representatives of the EPA and the Town
          Center Management Corporation whenever
          acoustic ceiling tiles are damaged or broken/
          so that replacements can be promptly
          installed by the Contractor.  A stock of
          replacement tiles shall be maintained by the
          EPA and/or the Town Center Management
          Corporation for use by the Contractor.
          Damaged or broken acoustic ceiling tiles, up
          to 1% of the total number of tiles cleaned,
          shall be provided to the Contractor at no
          cost to the Contractor. The Contractor shall
          be responsible for replacing at. his/her own
          expense all tiles damaged or broken in excess
          of 1% of the total number of tiles cleaned.
Submittals;

     Not later than fifteen (15)  business days prior to the
initiation of work under this contract,  the Contractor shall
submit a brief history of comparable work previously performed
together with a list of at least three (3)  local references to
the Town Center Management Corporation and the EPA Contracting
Officer. (The name and address of the referenced company and the
name of a contact person with phone number must be included.)
Prior to the initiation of work under this contract, the
Contractor shall meet for one hour with the members of the EPA's
Indoor Air Quality Subcommittee,  at a time and place convenient
to all parties. The purpose of this meeting is to facilitate a
labor/management interview of the Contractor,  and to provide an
opportunity for a dialogue between the Contractor and the NFFE
and AFGE Unions.

     Not later than ten (10)  working days prior to the initiation
of work under this contract,  the Contractor shall submit to the
EPA Project Officer a written statement detailing all of the
methods and materials proposed for use,  including Material Safety
Data Sheets (MSDS) for chemicals proposed for  use.  The EPA
Project Officer shall review the methods and materials proposed
for use by the Contractor,  within five working days of receipt.
The EPA Project Officer shall then advise the  Contracting'
Officer, the Town Center Management Corporation,  and the
Contractor in writing as to their acceptability.  In the event any
method(s)  or material(s)  are determined by the EPA to be
unacceptable,  the Contractor shall make appropriate modifications
acceptable to the EPA.


Coordination and Scheduling;

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     Contractor shall perform w^rk within the building only
between the hours of 5:00 pm and 6:30 am. All EPA occupied spaces
and Contractor work areas shall be left clean at the end of each
Contractor work day.  The HVAC units that have been cleaned each
night by the Contractor shall be left in operable condition for
use beginning on the following EPA work day. The Town Center
Management Corporation will make every effort to start each.
cleaned HVAC unit as soon as possible after the Contractor's work
is completed. Each unit should then be run for a period of at
least two hours prior to reoccupancy of the affected work areas
by EPA employees.

     The EPA's Facilities Management and Services Division (FMSD)
is responsible for coordinating, through the Environmental Safety
and Health Division (EHSD) Project Officer, those security and
internal' housekeeping matters that may arise during the course of
work under this contract.

     The Contractor's work shall be conducted in three separate
phases, and conducted in concert with the EPA's "Operation
Cleansweep" efforts. The EPA's management and staff are
undertaking a comprehensive cleaning of their work areas
beginning on "EARTH DAY" -  April 22, 1990. Following the EPA's
own cleanup of its work areas beginning on this date, HVAC system
cleaning can commence. The Contractor shall perform HVAC system
cleaning in accordance with the following schedule:

               1) the "Hall" systems  - beginning on June 4,
                  1990, after completion of EPA's "Operation
                  Cleansweep" activities in this area;

               2) the "West Tower" systems - beginning on June
                  18,  1990, after completion of EPA's "Operation
                  Cleansweep" activities in this area;

               3) the "East Tower" systems - beginning on July 2,
                  1990, after completion of EPA's "Operation
                  Cleansweep" activities in this area.


Competitive Technical Evaluation Criteria:

     Contractor selection will be based on the technical quality
of cleaning methods and materials proposed, and upon verification
of satisfactory past performance. Contractor selection shall  not
be exclusively based on cost considerations.

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Reports Required and Description:

     The Contractor shall submit, on a daily basis, a written
report to the Project Officer concerning status of work
performed,  any deficiencies, and any problems preventi-ng
execution of daily work. Additional information must be  included
in such reports, as described previously in this Statement of
Work (e.g., damage to EPA or TCM property, incidents, accidents,
or problems or deficiencies involving the HVAC system that are
noted)..


Recommended- Sources List;

     Riteway
     Pritz
Environmental and Safety Reo/uirements!

     Contractor shall comply with all District of Columbia and
Federal fire, occupational safety and health, and other safety
and environmental standards and regulations. Such regulations and
standards include, but are not limited to,  those promulgated by:
the National Fire Protection Association,  the federal
Occupational Safety and Health Administration, the federal
Environmental Protection Agency, the District of Columbia Fire
Department.

Warranty of Service:

     The Contractor's warranty with respect to all work performed
and all materials provided shall run for a period of one (1)
year.  The warranty period shall commence on August 1, 1990 and
end at midnight on July 31, 1991.
FILE:
C:\WP50\SHERRY\JE-SOW.DUCT

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        \    APPEND! '.  I

        -' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         WASHINGTON DC 20460
                                     0 ?389
                                                       ADMINISTRATION
                                                       AND RESOURCES
 MEMORANDUM                                             MANAGEMENT


 SUBJECT:   Guidance Regarding Employee Requests  for Alternative
           Workspace or Work Assignments
 FROM:      Ch.-rles L.  Grizzle
           Assistant Administrator

 TO:        All Headquarters Managers and Supervisors


     The  following 'is  provided as  guidance to  help  you make
 decisions  regarding employee requests for alternative workspace or
 work assignments  as a result -of health related problems.

     First,  a determination must  be  made that the employee  is
 unable  to remain  in  their current work location.   The  attached
 agreement  specifies how this will be accomplished.   Briefly, this
 agreement  . provides that the determination  will  be  made by  the
 physician  at the  Waterside Mall  Health Unit.   This will be .done
 based on either the  EPA physician's  personal examination of  the
 employee or  the. .documented results  of  a personal examination from
 the  employee's private physician.  If the EPA physician determines
 that the employee  should not remain in the current workspace,  the
 physician  will notify the employee's immediate supervisor.

     If  you  receive notification from  the Health  Unit that your
 employee  should  not  remain  in  the  current workspace,  several
 decisions  must be  made.   The first  is whether or not the  employee
 can perform the current job from another location.   Of course, this
 decision may be  impacted by where  the new workspace is  located.
While an employee may be  able  to perform the job satisfactorily
 from down  the hall;  this may  not  be  possible from a different
building.  Some jobs, such  as receptionist, can only be performed
 in their current location.  If  you decide that the employee cannot
perform  the  job from  another  location, it will generally  be  in
everyone's best interest  to reassign the employee to a new job  in
a  new  location.    If this  cannot be  accomplished  within  your
 immediate  organization,   you and your  er.ployee  should  seek   out
possible  reassignnents  within  your AA-ship  and  throughout  the
Agency.    The Office  of  Hur.an  Resources Management will make a
special   effort    to  assist you  in matching  these  people  with
available ^obs in other parts of  the Agency.

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      If  you  decide  that the employee can perform the current job
 from  another  location,  you  should  again  look  within  your own
 organization, to see if there is acceptable  alternative space.  If
 there is not,  there  are several  other options.   These include
 working  in  other  space assigned  to the AA-ship,  working  at a
 contractor's facility,  or in  some instances, working at home.  If
 none  of  these are suitable, as a last resort, your AA nay ask the
 Office  ef Administration (OA) to  provide alternative workspace.
 Because  the  space that OA  has  available for this  purpose  is so
 limited,  I  an  asking you  to  make  every  effort: to  find  an
 alternative  workspace without resorting to requesting it from OA.
 If you find  that you must request alternative work space from OA,
 the   request  should   come   from   an  Assistant   or  Associate.
 Administrator  to assure that the  issue has been  raised  to an
 appropriate  level within your  organization  before you seek an
 outside  solution.  Requests from an AA to the Director, Office of
 Administration  for  alternative workspace must certify that there
 is no suitable alternative • other than the one requested and should
 detail any known  restrictions or necessary  special  requirements.
 OA will  respond promptly with information on whether  or not the
 request  can be granted.

     As  you  know, every situation will  be different.   However, X
 believe  that by. working with other managers and  our employees and
 the  alternatives discussed  here,  we -will  be   able  to  satisfy
 everyone's needs.

    •It you have any questions or require additional information,
 please  call  Marita.  A. -Llaverias,  OHBM,  en  382-3319.    This
 memorandum is intended as. intra-nanagenent guidance to supervisory
 personnel within the meaning of  Section 7114(b)(4)(c)  and 7132 (a)
 of Title 5, U.S. Code.

Attachment

cc:   John C.  Chanberlin
     Kenneth F. Dawsey

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FOR THE UNION
FOR THE AGENCY
Rufus Morison,
 oXnn Batsi

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                   ALTERNATIVE WORKSPACE POLICY

      Employees  desiring  to  be  considered  for  relocation  to
 alternative  workspace  are  required  to  submit  the  following
 documentation:

      1)  A  narrative  explanation of  the medical  basis  for any
      conclusion  which  indicates  the  likelihood  that the employee
      is  or  is not expected to experience subtle incapacitation;
                                       •
      2)  A  narrative  explanation of  the medical  basis  for any
      conclusion that, duty  restrictions or accoaaodations are or are
      not warranted;

      3)  A  narrative  explanation of  the medical  basis  for any
      conclusion which indicates the likelihood that an individual
      is  or  is not expected to suffer harn by carrying out his/her
      normal duties.

      This process is voluntary, and esployees say use the services
 of  the  Health  Unit  or  a  private  physician  to  obtain  this
 documentation.

      Any medical information provided by an employee in connection
 with' this  process  shall  be kept  confidential  and  will not  be
 released to any person or-organization without the written consent
 of the employee, except as provided in law or regulation.

      All pertinent medical documentation shall be submitted to the
 physician in  attendance at the Waterside Kail Health Unit.   The
 physician  will  at  the  employee's written  option,  ei'ther:  1)
 translate the medical documentation into layman's terwr to that the
 employee's  supervisor. can act on  the request  for  alternative
 workspace;  or 2) certify  to the  supervisor that the employee  is
 eligible for  alternative workspace. . The supervisor  shall notify
 the employee of the  disposition of the request within a reasonable
 time.  If a request is denied, the supervisor shall provide the
 employee written reasons for the  denial.

     An  employee cay determine,  after moving  into  alternative
workspace,  that  the space is  not appropriate and request  that
 further  action  be  taken.   The Agency  shall   sake  reasonable
 accommodations-for  employees making such requests.

     Kothing  in this policy supercedes 5 CFR Part 339,  the title
 of which is, "Kedieal Determinations Related to Erployability",  or
the collective bargaining agreement between KFFE Local 2050 and the
Agency.

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         APPENDIX  !5
                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         AIR AND ENERGY ENGINEERING RESEARCH LABORATORY
                                   RESEARCH TRIANGLE PARK
                                    NORTH CAROLINA 27711
                               December 18, 1989
SUBJECT:   Testing Indoor Materials

FROM:      W. Gene Tucker, Chief
            Indoor Air Branch (MD-54)
TO:         Julius Jimeno, Acting Director
            Environmental Health and Safety Division
            Office of Administration  (PM-273)
As discussed with Gail Kleiner the other day, the purpose of this memo is to provide
guidance on how you might deal with manufacturers and suppliers of materials and
furnishings for EPA office buildings.  This guidance is based on interpretations by
ORD/AEERL's Indoor Air Branch, of EPA and other research to date on source testing
and indoor air quality modeling. I believe the materials testing approach described
below, coupled with appropriate attention to ventilation system design and operation,
aesthetic and ergonomic factors, and building maintenance will provide an attractive
and healthy work environment for EPA employees.

We recommend that you require emission testing data from manufacturers or suppliers
of certain types of materials and products.  Based on our work to  date, we would
include the following types:

      o Coatings (paints, varnishes, waxes),

      o Flooring or wall covering materials made of plastics,
        fibers, or fabrics

      o Adhesives (e.g.,  for floor or wall coverings),

      o Furniture or furnishings with substantial amounts of
        pressed wood or fabrics,

      o Non-merallic materials used in the ductwork of the
        ventilation  system,

      o Office machines  and supplies (e.g.,  coated papers), and

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      o Maintenance materials  (e.g., floor waxes, rest room
        odorizers).

All of these materials have the potential to cause concerns when a building is new, or
when it is renovated, or when it is maintained.   Some of them can  also become
problem sources as they age, because they absorb and re-emit pollutants or support
the growth of microorganisms.  Some also have the potential to contain toxic
substances that would be of concern for effects other than sensory irritation-based
symptoms.

The emission testing that we recommend is mostly for vapor-phase organic
compounds.  In the case of office machines like copiers and electronic air cleaners,
testing for ozone emissions would also be appropriate.  It is most important that
emission rates be determined.  The most suitable methods for conducting such tests
are flow-through chambers. Enclosed is an EPA report  (EPA-600/8-89-047),  "INDOOR
AIR SOURCES:   Using Small Environmental Test  Chambers to Characterize Organic
Emissions from Indoor Materials and Products".  It provides technical guidance on how
to test materials, and gives details on test methods, experimental procedures, and data
analysis techniques.

We recommend that the manufacturer or supplier provide Material Safety Data Sheets
(MSDS's) for chemicals used in the manufacture of the product, along with an
emission rate testing report.  The report should:

      o Identify and report emission factors for the 5 major
        organic  compounds emitted (i.e., the 5 compounds with the
        largest  emission factors)

      o Identify the presence (or absence) of and report emission
        factors  for any specified compounds (for  example, you may
        request data on 4-PC  from carpet with a latex backing and
        data on formaldehyde from furniture and furnishings); if
        absence is  claimed, the detection limit should be
        reported

      o Report emission factors for total  measured organic
        compounds, in units of toluene equivalents

      o Report emission factors as milligrams/hour per m2 for
        surface materials and  coatings;  milligrams/hour per kg for
        sealants and adhesives; and milligrams/hour per unit for
        furniture, machines, and other items

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       o Report emission factors at three "ages" of the product:

             -  For coatings, adhesives, and caulks: approximately
               1, 10, and 100 hours after application to a surface

             -  For solid materials:  approximately 0-1, 10, and 50
               days  after production

       o Report ozone emission rates for office machines in
        units of milligrams/hour

       o Report chamber testing conditions (temperature,  air
        exchange rate, humidity, and product loading), and
        storage and handling procedures used

If you chose to follow these recommendations, we would  be glad to help you design a
standard reporting format.

Given  the above information,  we will be able to help you in the following ways:

       o Predicting indoor concentrations and employee inhalation
        exposures, as a function  of time, for the  building
        conditions and product applications you are considering

       o Evaluating (by IAQ modeling scenarios) the likely benefits
        of product conditioning before use, or ventilation options
        for the building

Your office will have to be responsible for assessing  (or having someone else such as
ECAO-RTP assess) the health  and comfort effects  associated with the predicted
exposures.  Others will also have to oe involved in selecting the "specified compounds"
mentioned above, although the Indoor Air Branch can certainly contribute to the
selection. For  starters, I suggest  you consider specifying compounds known to be in
the product that are also known  to be toxic or irritating at an air  concentration  of 5 -
mg/m3 or less.

Dr. Bruce Tichenor of my staff will be available to consult with you and the
manufacturers and suppliers on the testing procedures discussed  in the enclosed  EPA
report.  Our laboratory can also conduct limited chamber  studies to check  the quality
of results submitted  by the manufacturers or suppliers.

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Testing of emissions from indoor materials and products is not yet widely practiced
Few manufacturers have  their own testing facilities, although  many have talked with
us and visited our laboratory.  Carpet manufacturers represented by the Carpet and
Rug Institute have recently begun such testing, and some office furniture
manufacturers are having some of their products tested. We know of two testing
laboratories in this country that accept commercial clients.  Several other companies
are considering getting into this business; we will keep you apprised  of any new
entries. The two labs we know, of are:

             Air Quality  Sciences, Inc.
             1331 Capital Circle - D
             Atlanta, GA  30067
             Contact:  Dr. Marilyn Black
                       (404)-933-0638

             Georgia Tech Research Institute
             Emerson A-112
             Georgia Institute of Technology
             Atlanta, GA  30332
             Contact:  Dr. Charlene Bayer
                         (404)-894-3825
Feel free to call me (FTS 629-2746) or Bruce (629-2991) if you have any questions
or need additional information.
Enclosure

cc:    Mike Berry
      Kevin Teichman
      Bob Axelrad
      Bruce Tichenor

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