J-10b_SEA TRACON O-M Plan 2015 1.pdf

FEDERAL AVIATION ADMINISTRATION

Asbestos Operations & Maintenance (O&M) Plan

SEA TRACON

Seattle, Washington

Contents

1. INTRODUCTION:

2. PURPOSE:

3. DEFINITIONS:

4. ASBESTOS LOCATIONS:

5. EMPLOYEE TRAINING:

6. NOTIFICATION:

7. MONITORING ACM:

8. JOB SITE CONTROLS FOR WORK INVOLVING ACM:

9. SAFE WORK PRACTICES:

10. WORKER PROTECTION:

11. RECORDKEEPING:

Attachments:

Periodic Surveillance Summary Sheet

Asbestos Control and Work Permit Request

1. INTRODUCTION:

In accordance with the Federal Aviation Administration Order 1050.20A, Airway Facilities Asbestos Control Program, and JO 3900.19B, Occupational Safety and Health Program, Chapter 15 Asbestos, this site-specific Operations and Maintenance (O&M) Plan is required when an asbestos inspection reveals the presence of asbestos containing material (ACM) in a facility, and the ACM is in good condition. Although the plan may be appropriate and sufficient for managing asbestos in place and assuring compliance with construction and exposure regulations, in some cases the Plan is not enough and abatement will be necessary.

This plan is meant to be used in conjunction with the Western Services Area’s (WSA) Asbestos Control Program and the Seattle District’s O&M Program. Information on Roles and Responsibilities, as well as regulatory requirements and definitions can be found in those documents. Definitions pertinent to this document are contained below.

2. PURPOSE:

The primary objective of this O&M plan is to control building occupant and employee exposure to asbestos fibers. In addition, the procedures in this plan attempt to minimize any potential hazard posed by ACM/presumed ACM (PACM) during cleaning, maintenance, and general operation activities. This will be accomplished by:

1. Maintaining the ACM/PACM in good condition

2. Ensuring proper cleanup of debris resulting from damage to ACM/PACM

3. Minimizing future release of asbestos fibers and ensuring appropriate response

4. Monitoring condition of known ACM/PACM.

This plan applies to employees, tenants, other building occupants, and contractors.

3. DEFINITIONS:

A. Asbestos. Includes chrysotile, amosite, crocidolite, tremolite, anthophylite, actinolite, and any of these minerals that have been chemically treated or altered.

B. Asbestos Containing Material (ACM). Any material or product that contains more than 1% asbestos.

C. Category I Non-friable ACM. Material such as packing, gaskets, resilient floor covering, and asphalt roofing products containing more than 1% asbestos.

D. Category II Non-friable ACM. Any material containing more than 1% asbestos that is not category I non-friable ACM, and that, when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure. Category II ACM includes, but is not limited to:

(1) Asbestos cement siding and shingles,

(2) Transite panel boards, and

(3) Asbestos cement pipe (asbestos cement pipe may not be limited to buildings).

E. Class I Asbestos Work: Activities involving the removal of Thermal System Insulation (TSI) and sprayed-on, trowelled-on, or otherwise applied surfacing ACM/PACM.

F. Class II Asbestos Work: Activities involving the removal of ACM/PACM which is not TSI or surfacing materials

G. Class III Asbestos Work: Repair and maintenance operations which are likely to disturb

ACM/PACM.

H. Class IV Asbestos Work: Custodial and housekeeping operations where minimal contact with ACM/PACM may occur.

E. Friable ACM. Any material containing more than 1% asbestos that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure.

G. High-Efficiency Particulate Air (HEPA) Filter. A filter capable of trapping and retaining at least 99.97% of monodispersed particles of 0.3 micrometers or larger in diameter.

H. Presumed Asbestos Containing Material (PACM). Thermal System Insulation (TSI) and surfacing material found in buildings constructed before 1981 and floor tile installed in buildings through 1981 may contain asbestos. Although it is unlikely, some flooring installed after 1981 may contain asbestos. Until sampling demonstrates that the material has 1% or less asbestos, we consider these materials PACM.

I. Regulated Asbestos Containing Material (RACM). RACM includes:

(1) Friable asbestos material;

(2) Category I non-friable ACM that has become friable, or has been subjected to sanding, grinding, cutting, or abrading; and

(3) Category II non-friable ACM that has a high probability of becoming crumbled, pulverized, or reduced to powder during the course of demolition or renovation operations.

J. Vinyl Asbestos Floor Tile. When vinyl floor tile, and in some cases its mastic, contains more than 1% asbestos, it must be handled as ACM.

4. ASBESTOS LOCATIONS:

A baseline survey of SEA TRACON was conducted in 2015, which identified 1assumed asbestos containing material at the site. The asbestos in these materials is non-friable and does not constitute a health hazard if left undisturbed and is maintained in good condition. The material and location identified at the facility are the following:

• Gaskets – Various locations at flange or valve (PACM)

5. EMPLOYEE TRAINING:

Building occupants, as well as personnel who engage in Class IV operations only and housekeeping where ACM/PACM is present but contact is minimal need only complete asbestos awareness training. This training is typically 2 hours in length and requires and annual refresher.

Awareness training should include such topics as:

• Background information on asbestos,

• Health effects of asbestos,

• Worker protection programs,

• Locations of ACM and PACM at the facility,

• Recognition of ACM and PACM damage and deterioration,

• The O&M plan for the facility, and

• Proper response to fiber release episodes.

Also, all maintenance, custodial, and other employees who may disturb asbestos during their regular job duties (Class III or IV Work) must complete a minimum of 16 hours of asbestos operations and maintenance training BEFORE they begin duties where there is a potential for disturbance. These duties include, but are not limited to, drilling holes in floor tiles, cement panels, wallboard, and replacing filters in HVAC units with ACM. An annual refresher is required for this training.

In addition to the topics covered in Asbestos Awareness training, this training should also include such topics as:

• Federal, State, and Local regulations

• Proper asbestos-related work practices

• Description of the proper methods for handling ACM, including storage and disposal

• Respirator use, care, and fit-testing

• Protective clothing donning, use, and handling

• Hands-on exercise that mimic the work technicians are expected to perform

• Appropriate/proper tool and technician decontamination procedures

6. NOTIFICATION:

The SSC Manager must:

• Notify the following personnel of the presence, location, and physical condition of the ACM, and stress the need to avoid disturbing the material:

- Building employees,

- Tenants who will occupy the areas,

- Contractors bidding work in the building, and

- Contractors working in adjacent rooms.

• Distribute written notices, post signs or labels on ACM where employees can see them, and make the O&M plan available to anyone who might work on or disturb the ACM. All warning signs and labels posted in areas containing asbestos must comply with OSHA regulations in 29 CFR 1910.1001(j) (3) and (4).

• Make sure contractors who may come in contact with ACM or PACM are aware of this material by having them review the O&M plan provide documentation that their employees are trained to the required level (awareness/O&M) necessary for the work to be performed.

7. MONITORING ACM:

The ACM identified in the inventory is subject to deterioration with age, the effects of building occupancy, and accidental damage. To monitor the condition of the ACM, the SSC Manager ensures that they visually inspect the material at regular intervals (at least annually for staffed facilities/tri-annually for remote, unstaffed locations), and immediately report any ACM damage or deterioration to the SECM. For facilities containing friable asbestos, area air monitoring shall be performed during the periodic inspection to ensure fiber levels remain at acceptable levels.

The SSC Manager keeps a written record of these periodic inspections, and forwards a copy to the SECM. The record must include:

• Date of inspection;

• Inspector;

• Locations inspected, such as floor level, room names, or numbers, etc.;

• Nature of ACM (pipe wrap, transite board, etc.) and friability;

• Whether adequate labeling is still intact;

• Changes of status since last inspection (e.g., new damage, water damage, etc.);

• Results of periodic air monitoring (if applicable); and

• Any recommended action(s).

The most recent inspection/risk assessment should be used as the basis for this survey. The SSC Manager may use the Periodic Surveillance Summary Sheet attached to this document to complete this task.

8. JOB SITE CONTROLS FOR WORK INVOLVING ACM:

Whenever maintenance, custodial, or other employees perform work in areas where ACM or PACM is present, they must use appropriate work practices and protective measures to minimize the potential to disturb the ACM/PACM. This work does NOT include all Class I, Class II, and Class III asbestos work that require the usage of a respirator, which shall be done by an Asbestos Abatement Contractor.

The Federal Aviation Administration developed a set of SOPs to follow for a limited amount of Class III work that may disturb asbestos. Technicians may only perform work for which an SOP is written and a Negative Exposure Assessment was done. All other work must be performed by contractors that have been Asbestos O&M trained, or by State Certified Asbestos Abatement Contractors.

In order to perform work, the technician performing work or Resident Engineer (RE) overviewing the project involving Class III work must complete the Asbestos Control and Work Permit Request (Attachment) and submit to the SECM. This form must be filled out and submitted for any work being done in a facility containing asbestos, regardless of if the ACM will be disturbed. The SECM will review and include the applicable SOPs that must be followed to complete the work (if work involves disturbance of ACM).

This includes:

• Use of wet methods (such as applying water or to ACM with a low pressure sprayer or shaving cream);

• Use of mini-enclosures;

• Use of a HEPA vacuum to collect dust and fibers produced from work

• Area isolation;

• Avoidance of certain activities such as sawing, sanding, or drilling around ACM/PACM.

9. SAFE WORK PRACTICES:

It is important to minimize the disturbance of ACM and the subsequent release of asbestos fibers.

You can accomplish this by staying out of physical contact with materials that contain, or are presumed to contain, asbestos.

All personnel at SEA TRACON must observe the following work practices to avoid or minimize fiber release during activities that may affect ACM/PACM:

• Do not drill holes into material containing asbestos without following proper SOP;

• Do not hang pictures, signs (except asbestos warning signs), clothing, plants, or any other articles on structures covered with materials containing asbestos;

• Do not sand, saw, or grind floor tiles, hard board panels, or other materials that may contain asbestos;

• Do not damage materials containing asbestos while moving furniture or other objects;

• Do not install curtains, drapes, or dividers in a way that will damage materials containing asbestos;

• Do not dust floors, ceilings, moldings, or other surfaces with a dry brush or sweep with a broom in an environment containing asbestos;

• Do not use an ordinary vacuum to clean up debris containing asbestos;

• Do not remove ceiling tiles below materials containing asbestos without wearing proper respiratory protection, clearing the area of other people, and observing asbestos waste disposal procedures;

• Do not remove ventilation system filters in a dry state; and

• Do not shake ventilation system filters.

10. WORKER PROTECTION:

FAA employees must not participate in any asbestos abatement activities unless they are in full compliance with State AHERA certification and licensing standards and follow OSHA and EPA requirements and the requirements in FAA Order 1050.20A and JO 3900.19B. As a means to protect workers, the Seattle District does not allow its technicians to perform Class I or Class II Abatement activities, or any Class III for which a negative exposure assessment (NEA) has not been performed. For further information on Worker Protection and NEAs, refer to the Western Service Area’s (WSA) Asbestos Control Plan (ACP).

11. RECORDKEEPING:

In addition to record keeping requirements of the WSA ACP and the facility O&M Plan, the SECM must ensure that the staff retains all facility asbestos management documents, including:

• Copies of Asbestos Hazard Emergency Response Act (AHERA) inspection and assessment reports;

• Written O&M plan;

• Periodic Surveillance Summary Sheet;

• Work practices and procedures

• Awareness training records (tracked through eLMS); and

• Changes to location, condition, or quantity of the ACM/PACM.

Federal Aviation Administration

Seattle District

Asbestos Facility Re-inspection Summary

Facility LOC and ID:_____________ Date of Re-Inspection:_______

Inspector’s Name:_______________ Type: __Annual __Triennial

Instructions: If a change in ACM condition is noted, the following information must be filled out for each ACM type where it is noted. NOTE: Include specific locations (e.g.

room number, room description, floor, etc.) and quantities (e.g. square/linear footage, number of tiles, etc.). Once completed, return a copy to the SECM.

Results:

Has condition of any ACM changed?: ___Yes ___No. If yes, complete the following section for each type of ACM which the condition has changed.

ACM Type: ____________ Location: ____________ Amount affected:______

Physical Damage? (Y/N); Water Damage? (Y/N); Deterioration? (Y/N) Comments:____________________________________________________________

Accessible (Y/N); Activity Level near ACM? (H/M/L); Location in Airstream? (Y/N)

Comments:____________________________________________________________

ACM Type: ____________ Location: ____________ Amount affected:______

Physical Damage? (Y/N); Water Damage? (Y/N); Deterioration? (Y/N) Comments:____________________________________________________________

Accessible (Y/N); Activity Level near ACM? (H/M/L); Location in Airstream? (Y/N)

Comments:____________________________________________________________

ACM Type: ____________ Location: ____________ Amount affected:______

Physical Damage? (Y/N); Water Damage? (Y/N); Deterioration? (Y/N) Comments:____________________________________________________________

Accessible (Y/N); Activity Level near ACM? (H/M/L); Location in Airstream? (Y/N)

Comments:____________________________________________________________

ACM Type: ____________ Location: ____________ Amount affected:______

Physical Damage? (Y/N); Water Damage? (Y/N); Deterioration? (Y/N) Comments:____________________________________________________________

Accessible (Y/N); Activity Level near ACM? (H/M/L); Location in Airstream? (Y/N)

Comments:____________________________________________________________

ACM Type: ____________ Location: ____________ Amount affected:______

Physical Damage? (Y/N); Water Damage? (Y/N); Deterioration? (Y/N) Comments:____________________________________________________________

Accessible (Y/N); Activity Level near ACM? (H/M/L); Location in Airstream? (Y/N)

Comments:____________________________________________________________

WESTERN SERVICE AREA

WORK REQUEST REVIEW FORM

PART I – PROJECT INFORMATION

(To be Completed by Project Initiator)

NAME OF PROJECT:

PROJECT LOCATION:

SCOPE OF WORK: (Attach Plans and Specifications, Hazardous Materials Communication Plan and MSDS if Hazardous

Materials are to be used.)

PROJECT SCHEDULE: START DATE STOP DATE

WHO WILL BE PERFORMING THE WORK?

x FAA PERSONNEL CONTRACTOR

IF CONTRACTOR, COMPANY NAME

NAME OF PERSON SUPERVISING WORK

IF FAA PERSONNEL ARE PERFORMING WORK, LIST NAMES BELOW:

IF CONTRACTOR PERSONNEL ARE PERFORMING WORK, LIST NAMES BELOW:

PRINTED NAME, TITLE, AND SIGNATURE OF PERSON MAKING REQUEST DATE

PART II – WORK REQUEST STATUS

(To be Completed by the FAC)

Work Request #:

Will there be impacts to LCC or LBP?

YES

NO

If yes, Project ID#:

Will hazardous materials be used?

If yes, HAZCOM Plan & SDS Attached?

Is Asbestos present at the facility?

If yes, Project ID#:

Status: APPROVED DISAPPROVED

See Attached Asbestos Survey Report Do not impact asbestos

See Attached Lead Survey Report Do not impact lead coatings

A Lead Survey has not been performed at this facility, all paint must be assumed LCC / LBP Additional Remarks:

SIGNATURE OF FAC OR SECM DATE

REVISED FAA FORM WSA 1050-6B

HAZARDOUS MATERIALS WORK PERMIT

MUST BE POSTED AT WORK SITE

PART I – PROJECT INFORMATION

(To be Completed by Project Initiator)

PERMIT REQUESTED BY: DATE:

PHONE NUMBERS:

LOCATION OF WORK:

Building Name and #:

Street Address: City, State, Zip:

SCOPE OF WORK: (Attach Plans and Specifications, Hazardous Materials Communication Plan & MSDS if Hazardous Materials are to be used.)

PROJECT SCHEDULE: Start Date Stop Date

PART II – HAZARDOUS MATERIALS INFORMATION

(To be Completed by the FAC or SECM)

ASBESTOS IMPACTS:

Quantity Of ACM To Be Disturbed (Linear/Square/Cubic Feet):

Impacts: Friable Non-Friable Classification: Demolition Renovation Routine Maintenance Emergency Response Engineering Controls: Glove Bag Mini Containment Full Containment Other

* Date of EPA Notification: Date Approval Received:

** Date of State Notification: Date Approval Received:

*NESHAP regulations, 40 CFR 61, requires notification to the EPA if disturbance of ACM exceeds 260 linear feet, 160 square feet, or 35 cubic feet during a project; OR at the time annual accumulation of disturbed ACM will exceed these quantities.

**Notification in accordance with appropriate State Regulations.

LEAD IMPACTS:

Lead-Containing Coating Lead-Based Paint OSHA Trigger Task Non-OSHA Trigger Task

HAZARD COMMUNICATION:

HAZCOM Plan Attached SDS Attached HAZCOM/MSDS to be Provided by Initiator Incorporated to DO HAZCOM Program

REMARKS:

WORK PERMIT NUMBER:

(Provided by SECM)

PERMIT APPROVED BY:

TITLE:

PHONE:

This permit is issued with the understanding that those workers involved have received the appropriate training and all certifications, medical, and respiratory documentation has been reviewed and is current.

REVISED FAA Form WSA 1050.13B

WSA SOP-3900.19C-12.2

Final – August 6, 2014

FEDERAL AVIATION ADMINISTRATION

FAA Occupational Safety and Health Program – FAA Order 3900.19C

WSA Standard Operating Procedure (SOP) 12.2

Drilling Asbestos-Containing Floor Coverings and Mastics

NEA Data Available for this Tasking PPE and Air Monitoring May be Required by FAC

This SOP provides guidance for drilling through asbestos-containing floor coverings and mastics.

Equipment Required HEPA vacuum, spray bottle with amended water, drill, sponges, shaving cream, disposable towels/rags, waste disposal bags, barrier tape and warning signs.

Prior to Commencement of Work

1. At least 30 days prior to the scheduled start date, submit Work Control System (WCS) documentation to the Facility Asbestos Coordinator (FAC).

2. When the signed Work Permit is returned, it must be posted at the work site for the duration of tasking.

Negative Exposure Assessment (NEA)

1. A FAA NEA has been performed for this type of work. Personal and area air monitoring data collected during the drilling procedure presented in this SOP indicate that there is a high degree of certainty that employee exposure will not exceed the OSHA Permissible Exposure Limit (PEL) or Excursion Limit (EL).

2. Individuals with appropriate training who follow work procedures identified in this SOP are not required to wear respiratory protection or protective clothing (i.e., Tyvek suit).

Dependent on tasking, eye, foot, hand and/or hearing personal protective equipment (PPE) will be required.

3. The “Work Practices” section provides for two methods to drill; either with a HEPA equipped drill or holding the nozzle of a HEPA vacuum near the marked area. A NEA must be present for the method chosen to accomplish the task.

Work Practices

1. Demarcate the work area with asbestos warning signs and other barriers as necessary to prevent unauthorized access.

2. Mark the floor tile(s) to be drilled.

3. Clean the marked area by HEPA vacuuming thoroughly misting.

4. Position the drill.

5. Use a HEPA equipped drill or attach/hold the nozzle of a HEPA vacuum near the marked location while drilling.

WSA SOP-3900.19C-12.2

Final – August 6, 2014

6. Ensure the HEPA vacuum is running for the duration of work, vacuuming any dust and debris that is generated.

7. Use the following wetting/control methods to prevent generation of airborne asbestos fibers:

Wet the area throughout the work. Keep water away from electrical cords and equipment.

Place a wet sponge on the tile and drill the hole through the sponge.

Spray shaving cream on the area to be drilled. If using this procedure, shaving cream must be disposed of as ACM.

8. Operate the drill at low speed. If slivering occurs during the operation, stop immediately and

HEPA vacuum the area where any debris is present.

9. Once the hole is drilled, slowly pull the bit out, ensuring that the HEPA vacuum nozzle is still positioned adjacent to the drill bit.

10. Wet wipe the floor and drill bit.

11. Cover the end of the HEPA vacuum nozzle with duct tape.

12. Decontaminate all tools and equipment.

Decontaminate tools and equipment using HEPA vacuuming and wet wiping procedures.

Special attention should be given to cleaning extension cords, equipment wheels, vacuum hoses and other items that could pick up debris during the work.

Tools and equipment should be placed outside of the work area as soon as cleaning is completed.

13. Properly dispose of all debris as directed by the FAC.

14. Notify the FAC of completion of work.

Lance Kiblinger Typewritten Text HEPA vacuum must be designed and certified for use for asbestos/Lead abatement activities

Lance Kiblinger Typewritten Text The PVC "T" method is recommended when drilling through asbestos tile. Attach the one end of the PVC "T" to the HEPA Vacuum and place the drill through the straight part of the "T". This is the best way to collect generated dust while drilling your hole.

Lance Kiblinger Typewritten Text