J-10d_SEA-ATCT Asbestos OandM Plan 3.20.2015 1.pdf

FEDERAL AVIATION ADMINISTRATION

Asbestos Operations & Maintenance (O&M) Plan

SEA ATCT

Seattle, Washington

3/20/2015

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:

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 ATCT was conducted in 2015, which identified 1 assumed 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 flanges and valves (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 ATCT 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.