03/27/19: Abatement of Hazardous Materials


TO: Board of Education
FROM: Randall Booker, Superintendent
Pete Palmer, Director of Facilities and H1 Bond Program Manager
DATE: March 27, 2019


The Alan Harvey Theater has been closed since the beginning of March.  Closing Alan Harvey Theater during the Spring of 2019, rather than waiting until the end of the school year, will help keep the STEAM project on schedule for completion before the 2020-21 school year. Nonetheless, there may be questions about how starting work during the school year may affect students, staff, and campus flow.

Once the theater is closed, and until the new STEAM building is completed, the theater site will be cordoned off from the rest of the campus. Initially, fixtures, lighting systems, and other features that can be reused in the new theater will be “salvaged” and removed. Next, a specialized contractor will abate any hazardous materials inside the theater (for example, removing old thermostats and light fixtures that contain mercury). This salvage and abatement will be inside the existing theater building and will proceed largely unnoticed by students and staff.

PUSD has hired Mark Milani, P.E., CAC, of Milani and Associates.  Mr. Milani is a Professional Engineer, a Certified Asbestos Consultant, and a Environmental Services Manager/Hygienist.  He was the Environmental Services Manager/Hygienist who managed the last PUSD Bond measure which included the abatement and demolition of the Havens Elementary School.  He has continued to work for the district as needed as a consultant/Hygienist.

PUSD has an existing AHERA Management Plan. Under AHERA, materials that are identified as containing asbestos at regulated levels (threshold is greater than 1% to be defined as an ACM) in the AHERA management plan, are to be re-inspected on a triennial basis (every three years). The purpose of the re-inspection is to assess any change in the condition of the specific ACMs identified in the management plan and to document areas where response actions (asbestos abatement removal) have been performed following the previous triennial review.

Milani & Associates has been working closely with PUSD facility personnel to conduct necessary pre-renovation surveys for all renovation work that will require demolition or removal of building materials and/or building components for the current bond related projects.  To comply with the National Emissions Standards for Hazardous Air Pollutants (NESHAP) regulations administered by the Bay Area Air Quality Management District, Milani & Associates conducted a thorough demolition-level hazardous material survey of Alan Harvey Theater (AHT) and the PHS Administration Building (the 10s building).  Based on these surveys, the firm determined that both buildings contain limited quantities of hazardous materials that must be removed prior to demolition.  These materials include asbestos at regulated levels, lead-based building components, and PCB/mercury-containing light fixtures.

The materials containing asbestos at regulated levels include resilient floor tile, sink coatings, and skylight sealant.  Please note that these materials are non-friable, and the planned abatement and removal will not make them friable.  Also, AHT has drywall that contains asbestos at below regulated levels (less than 1%), classified as asbestos-containing construction material (ACCM).

For complete information about about the survey results, please see Pre-Demolition Hazardous Material Survey Report (Administration Building) and Pre-Demolition Hazardous Material Survey Report (AHT).)  These reports have been posted on measureh1.org since October 2018, and are significantly more detailed than the forthcoming updated AHERA plans.

Milani & Associates’ pre-demolition hazardous material survey included assessment of building systems and components for asbestos, lead-containing paint coating systems, Universal Wastes and other regulated materials (ORMs), and treated wood waste:

  • Asbestos.  Visual inspection of the building interior, exterior and roof to identify suspect materials, and bulk sample selection of suspect building materials and/or components to determine the presence of asbestos. Analysis was performed to identify asbestos-containing materials (ACMs), asbestos-containing construction materials (ACCMs) and asbestos-containing construction debris waste streams. All ACMs were classified to comply with NESHAP for purposes of demolition permitting.


  • Lead.  Non-destructive X-Ray Fluorescence (XRF) survey to identify and classify paint based on lead content. This survey included bulk sampling of building components (such as ceramic tile and paint chips) for lead content for purposes of waste characterization.


  • Universal Wastes/ORMs.   Visual survey to identify universal wastes and ORMs including but not limited to: fluorescent lights (mercury); light ballast (PCBs); caulking (PCBs); thermostats (mercury/electronic waste); and HVAC equipment (refrigerants/compressor oils). This visual inspection was used to develop an inventory.


  • Treated Wood Waste. The trellis and some portions of the AHT and 10s building sunshade system were constructed with pressure-treated wood. This material will not be reused, so it is classified as Treated Wood Waste (TWW). A visual inspection was conducted to estimate the quantity of TWW for disposal.


The results of all pre-demolition surveys are included in the two Pre-Demolition Hazardous Material Survey Reports linked above.

The data from the pre-demolition survey report was used to develop project and building specific hazardous material specification and hazmat abatement drawings for use by the selected general contractor and hazmat subcontractors for the removal of hazardous materials from the building prior to demolition.  (Demolition Plan (Administration Building), Demolition Plan (AHT))  Milani & Associates will manage and monitor this work, and will have certified asbestos and lead personnel onsite conducting industrial hygiene monitoring during abatement.

Synergy Enterprises, a licensed, professional “hazmat” contractor, will perform the abatement work under Milani & Associates’ supervision.  Synergy has extensive experience working with schools, and ensures full compliance with all state and federal health and safety requirements.  All Synergy workers and supervisors will have completed training for both asbestos and lead abatement.  Specifically, Synergy will remove, handle, package, label and dispose of all asbestos-containing waste in compliance with CAL/OSHA asbestos standards (8 CCR 1529) and Federal NESHAP requirements.  Synergy will remove, handle, package, label and dispose of all lead-containing waste in compliance with CAL/OSHA lead standards (8 CCR 1532.1) and applicable Federal Regulations. In some cases, Synergy will go beyond what is legally required.  For example, Synergy will remove drywall identified as ACCM prior to demolition although this is not required.

Throughout the abatement and demolition phase, Milani & Associates will have certified environmental hygienists on site to observe and monitor the work.  The hygienists will perform daily inspections during the abatement phase, and negative air machines will filter the air inside the buildings and maintain a negative pressure environment.  In addition to the inspections, the hygienists will monitor air quality, conduct post-abatement testing, and confirm in writing that the abatement has been completed prior to demolition.  Even after the abatement is completed, the District will maintain air quality monitors around the site perimeter and measure air quality throughout demolition.

Milani & Associates will issue a release for demolition letter to the general contractor through PUSD following the completion of removal of all ACMs and other specified regulated materials that are scheduled to be removed from the building prior to start of demolition.

While the District plans to demolish the theater over Spring break when there are no students or staff on campus, if the demolition cannot be completed during that week, the District will develop a schedule for the remaining demolition, to minimize the campus impact to the greatest extent possible.


Review the safety measures for the demolition of the Alan Harvey Theater as outlined by Mr. Pete Palmer, Director of Facilities and H1 Bond Construction Manager.