Appendix O - AMOP2021 docx.pdf

ASBESTOS MANAGEMENT

& OPERATIONS PLAN

MacDill Air Force Base (MacDill AFB), FL

September 2020

Prepared By: 6 CES/CEIE

7621 Hillsborough Loop Drive MacDill AFB, FL 33621

Record of Annual Review

Review Date Reviewer Notes/Remarks

8/1/2008 R. Ritch (APO) No Revisions Required

1/29/2009 R. Ritch (APO) Minor Revisions Made

8/1/2009 R. Ritch (APO) No Revisions Required

8/1/2010 R. Ritch (APO) No Revisions Required

8/1/2011 R. Ritch (APO) Revised to Reflect New Support Contract

8/1/2012 R. Ritch (APO) No Revisions Required

8/1/2013 R. Ritch (APO) No Revisions Required

8/1/2014 R. Ritch (APO) No Revisions Required

8/1/2015 R. Ritch (APO) Minor revisions made

8/1/2016 R. Ritch (APO) No Revisions Required

8/1/2017 R. Ritch (APO) No Revisions Required

8/1/2018 R. Ritch (APO) No Revisions Required

8/1/2019 R. Ritch (APO) No Revisions Required

8/1/2020 R. Ritch (APO) Administrative Revisions Made

9/2/2021 R. Ritch (APO) Administrative Revisions Made

Table of Contents Executive Summary .............................................................................................. i Regulations .......................................................................................................... ii Acronyms and Abbreviations ............................................................................. iv Purpose Statement ............................................................................................... v Section 1.0 Introduction

1.1 Background

1.2 Medical Concerns

Section 2.0 Designation of Duties

2.1 Wing Commander - 6 ARW/CC

2.2 Base Civil Engineering Director - 6 CES/CL

2.3 Asbestos Program Officer (APO) - 6 CES/CEIE

2.3.1 APO Training

2.3.2 APO Duties

2.4 Asbestos Operations Officer (AOO) - 6 CES/CEO

2.5 Engineering Flight- 6 CES/CEC

2.6 Bioenvironmental Engineering (BEE) - 6 AMDS/SGPB

2.7 Military Family Housing (MFH) – Privatized

2.8 Contracting Officer - 6 CONS/CC

2.9 Quality Control Inspector (CE Support Contractor) – 6 CES/CPQI

2.10 Facility Managers

2.11 Public Health (PH) - 6 AMDS/SGPM

2.12 Public Affairs (PA) - 6 AMW/PA

2.13 Environmental Legal Adviser - 6 AMW/JA

2.14 Safety Officers - 6 AMW/SE and 6 CES/CPQS

2.15 Flight Medicine

2.16 Aerospace Medicine Council - 6 MG

Section 3.0 Asbestos Investigation

3.1 Survey Methods

3.2 Hazard Evaluation

3.3 Ranking

Section 4.0 Asbestos Management Activities

4.1 In-Place Management

4.2 Monitoring and Surveillance

4.3 Signs and Labeling Requirements

4.5 General Custodial Activities

4.6 ACM Abatement in Renovation, Construction, and Demolition

Projects

4.7 Long-Term Abatement Plan

4.8 Emergency Response Procedures

Section 5.0 Notification Requirements

5.1 Asbestos Removal Notification Requirements

Section 6.0 Medical Surveillance

6.1 Personnel Requiring Medical Surveillance

6.2 Medical Examinations

Section 7.0 Training

7.1 Training Requirements

Section 8.0 Record Keeping

8.1 Training Records

8.2 Outside Contractor requirements

8.3 Public Awareness

8.4 Comprehensive Asbestos Surveys

8.5 Maintenance Records

8.6 Abatement Records

8.7 Waste Manifest and Disposal Records

8.8 Worker Protection Records

8.8.1 Fit Testing (where applicable for active duty personnel)

8.8.2 Exposure Monitoring

Section 9.0 Worker Protection

9.1 Engineering and Work Practice Controls

9.2 Exposure Monitoring

9.3 Respiratory Protection

9.4 Respirator Program

9.5 Protective Equipment

i

Executive Summary

This plan has been prepared to fulfill the requirements of AFI 32-1001 that requires Air Force

Bases to develop and implement an Asbestos Management and Operations Plan (AMOP). All policies herein regarding asbestos management and operations must be observed and enforced in all installation facilities on MacDill AFB, with the exception of privatized housing that maintains their own Asbestos Management Plan and records.

The objective of the asbestos management plan is to maintain a permanent record of the current status and condition of all asbestos containing material (ACM) in an installation's facility inventory. The management plan provides the documentation for all asbestos management efforts and procedures for overseeing the entire facility asbestos management program. The asbestos operations plan dictates how an installation will carry out asbestos-related projects. The plan will assign responsibilities; establish inspection and repair capabilities; and provide repair procedures and personnel protection instructions. Collectively, both plans (AMOP) will ensure

MacDill AFB is in compliance with applicable Occupational Safety and Health Administration

(OSHA), Environmental Protection Agency (EPA), Department of Defense (DoD), Air Force, and state and local rules and regulations while protecting our environmental and occupational communities.

The AMOP addresses all the requirements associated with the management and operation of asbestos. These requirements include:

Organizational structure for carrying out asbestos-related work

Training requirements for individuals working with or in an area that contains asbestos

Identification of worker manuals or other written procedures

Procedures for investigation, in-place management, and abatement

Procedures for interim control measures and extraordinary precautions

Requirements for emergency response and in-house inspection

Requirements for contractor asbestos analysis and abatement

With effective communication and teamwork between installation organizations, asbestos on

MacDill AFB can be properly managed and the potential health hazard to base personnel can be eliminated or controlled. Implementation of the AMOP will ensure asbestos is maintained and properly managed, so any asbestos situation can be handled quickly and efficiently, thus providing base personnel with a safe environment to live, work, and play.

ii

Regulations

Copies of key regulations and Air Force policies that are pertinent to the Asbestos

Management/Operating Plans are summarized by agency below.

Occupational Safety and Health Administration (OSHA) 29 CFR 1926.1101 Construction

Standard for Asbestos (formerly 1926.58)

Applies to individuals involved in construction, renovation, and demolition activities.

Established a Permissible Exposure Limit (PEL) of 0.1 fibers per cubic centimeter of air (f/cc) as an eight-hour time-weighted average (TWA) and an Excursion Level of 1.0 f/cc as averaged over a sampling period of 30 minutes.

Dictates engineering controls and personal protective equipment requirements for individuals involved with asbestos-related work and establishes requirements for medical surveillance and record keeping.

29 CFR 1910.1001 General Industry Standard for Asbestos

Establishes the same PEL and Excursion Limit as outlined in 29 CFR 1926.1101 (Construction

Standard). Scope applies to all occupational exposures to asbestos not specified in the

Construction Standard.

Environmental Protection Agency (EPA)

40 CFR Part 61 – National Emissions Standards for Hazardous Air Pollutants (NESHAP), Subpart M – National Emission Standard for Asbestos

Establishes standards for renovation or demolition activities which will impact a combined quantity of asbestos-containing material in excess of 260 linear feet, 160 square feet, or 35 cubic feet. Standards address notification requirements, work practices, and waste disposal requirements.

40 CFR 763, Subpart E Asbestos Hazard Emergency Response Act (AHERA)

Establishes standards for conducting asbestos assessment and abatement activities in schools.

Requires schools to develop management plans and conduct periodic re-inspections of asbestos-containing materials.

Appendix C of the regulation (Asbestos Model Accreditation Plan) extends accreditation requirements for asbestos workers, contractor/supervisors, inspectors, and project designers to public and commercial buildings as well as schools.

40 CFR 763, Subpart G Worker Protection Rule

This regulation applies the OSHA standards to government employees who are not covered by the OSHA Asbestos Standards.

iii

Department of Transportation Regulations 49 CFR 171, 172, and 173

This regulation establishes labeling, packaging, and transportation requirements for asbestos-containing materials.

State of Florida Statue Chapter 469

Establishes accreditation and certification requirements for asbestos contractors, workers, supervisors, inspectors, management planners, and project designers working in public and commercial buildings in the State of Florida.

Florida Administrative Code Section 62-257

Establishes notification requirements and a fee schedule for asbestos abatement projects.

United States Air Force (USAF)

AFI 32-1001, Civil Engineer Operations, Chapter 15 – Facility Asbestos Management

Requires Air Force Bases to conduct facility asbestos surveys and develop an Asbestos

Management Plan and an Asbestos Operating Plan.

AFMAN 32-7002, Environmental Compliance and Pollution Prevention, Chapter 7 –

Toxics Management

Requires compliance with all of the Federal regulations regarding asbestos.

AFMAN 48-146, Occupational & Environmental Health Program Management

Prohibits job rotation administrative controls for asbestos in accordance with 29 CFR 1910.1001.

AFMAN 91-203, Air Force Occupational Safety, Fire and Health Standards

Requires asbestos safe handling procedures in accordance with 29 CFR 1910.1001.

iv

Acronyms and Abbreviations

ACM - Asbestos Containing Material

AFI - Air Force Instruction

AFMAN – Air Force Manual

AFOSH - Air Force Occupational Safety and Health

AHERA - Asbestos Hazard Emergency Response Act

AMC - Aerospace Medicine Council

AMOP - Asbestos Management and Operations Plan

AOO - Asbestos Operations Officer

APO - Asbestos Program Officer

BEE - Bioenvironmental Engineering

BCE - Base Civil Engineer

CFR - Code of Federal Regulations

EPA - Environmental Protection Agency f/cc - fibers per cubic centimeter

FSO - Flight Surgeon’s Office

HEPA - High Efficiency Particulate Air

MFH - Military Family Housing

NESHAP - National Emissions Standards for Hazardous Air Pollutants

OSHA - Occupational Safety and Health Administration

PA - Public Affairs

PEL - Permissible Exposure Limit

PH - Public Health

TSI - Thermal System Insulation

TWA - Time-Weighted Average

USAF - United States Air Force v

Purpose Statement

This Asbestos Management and Operations Plan (AMOP) is designed to meet the intent of Air

Force Instruction (AFI) 32-1001, Civil Engineer Operations, Chapter 15 – Facility Asbestos

Management, which requires all Air Force installations to develop and implement asbestos management programs. With the AMOP, MacDill AFB has a framework for preventing asbestos exposure to facility occupants and maintenance personnel.

The Air Force recognizes that asbestos-containing materials do not pose an inherent hazard, and that for a hazard to exist there must be some mechanism by which asbestos fibers become entrained in the breathing environment. This AMOP provides guidance in identifying potential asbestos hazards, prioritizing abatement activities, and managing asbestos-containing materials in place in such a way as to minimize potential exposures to base personnel, their families, and maintenance workers (both in-house and contracted).

The approach of this AMOP is to outline the responsibilities of key players involved with asbestos management and to provide guidelines to assist them in identifying potential asbestos hazards; managing and updating asbestos survey data; prioritizing abatement activities;

scheduling periodic training, medical surveillance and re-inspections; and managing the often cumbersome documentation associated with these activities.

Section 1.0 Introduction

1.1 Background

Asbestos is a naturally occurring mineral whose crystals form long, thin fibers. There are three types of asbestos that were commonly used in building materials:

• Chrysotile: The most commonly used form of asbestos, chrysotile accounts for approximately 95 percent of the asbestos used in building materials in the United

States. Chrysotile is commonly referred to as "white asbestos."

• Amosite: This is the second most common form of asbestos and represents approximately 4 percent of the asbestos used in building materials in the United

States. Amosite is commonly referred to as "brown asbestos."

• Crocidolite: The least common form of asbestos, crocidolite accounts for only about 1 percent of the asbestos products used in the United States. Crocidolite is commonly referred to as "blue asbestos."

Asbestos became widely used in a variety of products in the late 1800s because of its insulating properties, its ability to withstand heat and chemical corrosion, and its soft, pliant nature.

Asbestos was used in a variety of building materials, including sprayed-on fireproofing, acoustical plaster, pipe, boiler and mechanical equipment insulation, drywall joint compound, asbestos cement siding, roofing shingles and tars, floor tiles and mastic, and even electrical wire insulation.

In 1989, the EPA promulgated its "Ban and Phase Down Rule," which prohibited the manufacture, importation, processing and commercial distribution of approximately 95 percent of all commercially available asbestos-containing materials used in the United States.

1.2 Medical Concerns

Over the past 20 years, there has been a growing awareness and consensus within the medical community of the adverse health effects associated with exposure to airborne asbestos.

Asbestos becomes a health hazard when fibers become airborne and are inhaled. Because of the small size of asbestos fibers, they can avoid the body's defense mechanisms and become trapped in the lungs.

There are three main diseases associated with asbestos exposure, all of which have latency periods of 10-40 years. Asbestosis is the most common asbestos-related disease and is prevalent among workers with long-term occupational exposures to large doses of asbestos. This disease is characterized by a fibrotic scarring of the lung tissue which results in decreased lung capacity.

The second most common asbestos-related disease is lung cancer. As with asbestosis, lung cancer is also linked with high-dose asbestos exposures, and it has been determined that cigarette smoking and asbestos exposure contribute synergistically toward causing lung cancer.

The least common but most fatal asbestos-related disease is mesothelioma, which is a cancer of the membrane that lines the lungs or abdominal cavity. Mesothelioma differs from asbestosis and lung cancer in that there does not appear to be the same dose-response relationship. It is primarily this disease that has led the EPA to conclude that there is no safe level of asbestos exposure.

Section 2.0 Designation of Duties To maintain an effective asbestos management program at MacDill AFB, several organizations and functional positions must form a working relationship in order to effectively communicate and carry out asbestos management activities.

This section assigns specific responsibilities to key individuals and groups. Each is summarized below and listed in greater detail later in this section.

Wing Commander - 6 ARW/CC. Maintains responsibility for compliance with the AMOP.

• The Civil Engineer Director- 6 CES/CL. Ensures the AMOP is implemented and managed successfully.

• Asbestos Program Officer (APO) - 6 CES/CEIE. Implements and oversees the day-to-day activities of the AMOP.

• Asbestos Operations Officer (AOO) - 6 CES/CEO. Informs the APO of any maintenance activities conducted by 6 CES/CEO that will potentially disturb or take place in the immediate area of asbestos containing material.

• Engineering Design and Construction - 6 CES/CEN. Performs facility modifications, design, renovation, and construction using work practices to protect base personnel, employees, and contractors from asbestos exposure as discussed in this plan. With assistance from the

Asbestos Program Officer, determine if asbestos will be affected during their projects and how the material shall be handled. Also, clearly informs the contractors or base personnel performing the work of potential hazards.

• Bioenvironmental Engineering - 6 AMDS/SGXB - Conducts environmental and personal sampling, performs respirator fit testing, and assists in asbestos inspections.

• Family Housing - 6 CES/CEIH - Ensures that newcomers to base housing are informed of potential asbestos hazards within MFH.

• Contracting Officer - 6 CONS/CC - Ensures all contracting documents contain appropriate contract language for those projects which the BCE has identified as having potential for encountering asbestos.

Quality Control Inspector (CE Support Contractor) – 6 CES/CPQL- Inspects, reviews, and provides guidance for all in house projects and maintenance activities involving asbestos.

• Facility Managers - Report signs of potential asbestos hazard problems to the Asbestos

Program Officer.

• Public Health - 6 AMDS/SGPM - Provides occupational health education and training on asbestos awareness for federal employees.

• Public Affairs (PA) - 6 ARW/PA - Informs base residents and employees of asbestos management activities.

• Environmental Legal Adviser - 6 ARW/JA - Reviews activities involving asbestos to ensure regulatory compliance and to advise on legal conflicts.

• Wing Safety/CE Support Contractor Safety Office - 6 ARW/SE and 6 CES/CPQS -

Advises the Asbestos Program Officer regarding safety concerns. Provide awareness training as required

Flight Medicine - 6 AMDS/SGPF - Coordinates physical examinations for selected maintenance workers and also coordinates the maintenance of their records.

Aerospace Medicine Council - Establishes medical surveillance protocols.

An effective asbestos management program requires that these key personnel and organizations communicate with each other effectively to carry out the management activities. The Asbestos

Program Officer is responsible for developing the program and enforcing its operation through the AMOP.

2.1 Wing Commander - 6 ARW/CC

The Wing Commander is ultimately responsible for the activities of the Base Civil Engineer and ensures compliance with and implementation of the AMOP. The Wing Commander is the approval authority for the activities assigned by the asbestos management and operating plans and will advocate that sufficient resources are assigned to the program.

2.2 Base Civil Engineering Director - 6 CES/CL

The BCE is tasked with the primary responsibility for the AMOP. The BCE has the responsibility to develop and implement the base asbestos program (reference AFI 32-1001, Section 15.2). The program shall be managed so that asbestos materials are thoroughly controlled at the lowest possible cost to the Air Force. Specifically, the BCE must appoint the

APO and the AOO and ensure that they receive training and resources to administer the AMOP.

2.3 Asbestos Program Officer (APO) - 6 CES/CEIE

The APO is the focal point for the administration of the AMOP. As such, the APO is required to fulfill a wide range of responsibilities. In order to properly implement the AMOP, the APO will need to dedicate the majority of their time to the task of managing asbestos.

2.3.1 APO Training

The individual should possess the technical ability to successfully complete the training requirements outlined in Section 7.0.

2.3.2 APO Duties

Direct the maintenance of all records for the program, including asbestos surveys, lab results, inspections, abatement actions, waste manifests, and other pertinent information.

Update and revise the asbestos files as necessary.

Identify priority facilities for remedial actions in coordination with BEE.

Assist Engineering in determining if their proposed projects will affect asbestos and, if so, determine an appropriate response action.

Assist Military Family Housing and Public Affairs in developing an informational package for base residents addressing asbestos hazards.

Advise Civil Engineering and the AOO in coordinating and supervising abatement and interim maintenance activities.

Maintain an inventory of updated, applicable regulations on file.

Review asbestos abatement specifications and other contract documents.

Assist Engineering in the review of asbestos abatement contractor submittals, including training certifications, respirator fit test records, and medical records, this is to be coordinated with BEE.

Review work orders identified and submitted for review by the AOO that will affect

ACM and recommend appropriate response actions such as asbestos surveys, sampling and abatement.

Provide technical assistance to Engineering, related to asbestos, during asbestos abatement contracts.

2.4 Asbestos Operations Officer (AOO) - 6 CES/CEO

Since 6 CES/CEO is responsible for managing all in-house maintenance and repair activities, close coordination with the APO by the AOO is essential to ensure all necessary asbestos sampling requirements are forwarded to the APO in a timely manner. The responsibilities of the

AOO are listed below:

Help develop, implement, and maintain the asbestos operating portions of this plan.

Ensure that adequate and timely surveillance is performed to examine ACM for damage or deterioration on base buildings during routine maintenance operations and notify the

APO of the areas of concern.

Inform APO of any known or suspected exposures to asbestos by operations personnel. Ensure all maintenance personnel working with or disturbing ACM have required training, physical examinations and respiratory fit testing.

Ensure facility maintenance personnel have received adequate asbestos training to work in and around buildings that contain ACM and to recognize asbestos hazards they might encounter.

2.5 Engineering Flight- 6 CES/CEN

The Engineering Flight must coordinate all projects involving renovation and demolition with the APO, AOO and BEE to ensure proper procedures are taken to avoid asbestos exposure to workers and personnel. The Flight duties are listed below.

Assemble abatement contracts for base facilities as required.

Ensure asbestos surveys are conducted by a Florida state licensed inspector as required.

Coordinate bidding abatement contracts (including attending pre-bid and preconstruction meetings) with the Base Contracting office for procuring contractors to perform ACM abatement from base buildings when required.

Review contract submittals for abatement contracts.

Ensure that project engineers have clearly identified asbestos hazards to contractors in bid documents.

Develop contract documents for acquisition of asbestos abatement contractors and monitor acquisition process for contracting.

Inspect abatement contractor’s work and all contractor activities on asbestos abatement contracts.

Additional duties: include previous asbestos building survey information for abatement actions into all design, construction, demolition and renovation contracts that will affect ACM. Include a requirement for an asbestos survey and abatement recommendations in the work plans, contract documents and all requests for proposals for projects. Request input from the APO and BEE as necessary to accomplish this.

2.6 Bioenvironmental Engineering (BEE) - 6 AMDS/SGPB

The AMOP requires periodic environmental and employee exposure monitoring.

Bioenvironmental engineering will be responsible for the following:

Assisting the APO in visually inspecting all base facilities spaces with a GRADE Priority of 1 or 2 to identify those which require remediation. Make recommendations for any building space that may potentially expose building occupants or workers to friable ACM

Conduct or manage semiannual air sampling in areas considered high priority

Perform final visual inspection of asbestos abatement work areas to ensure that adequate cleanup has been accomplished

Confirm clearance air sampling in areas where abatement work has been completed to determine whether re-occupancy standards have been achieved

Develop a respiratory protection program for the AMOP and conduct respirator fit testing and training

Coordinate required medical clearance testing through Base Clinic for those base employees cleared to wear respirators

Assist with ongoing informal asbestos awareness and work practice training with maintenance personnel

Monitor any in-house maintenance, repair, or minor construction activities that could result in exposure to asbestos

Provide all project generated asbestos documents to the APO for proper record keeping

2.7 Military Family Housing (MFH) – Privatized

Recommended responsibilities of the MFH lease holding contractor include the following:

Develop and maintain their own Asbestos Management Plan

Permanently maintain all current and past asbestos records for the housing

Shall train or provide asbestos awareness training to its employees as required

Shall develop and provide an informational package on asbestos, to be distributed to families that will include steps they can take to reduce exposure

Ensure all base housing occupants have been properly informed of ACM in base housing

Notify the MacDill AFB, Environmental Flight of any asbestos emergency situations and/or prior to the initiation of work that involves removal or disturbance of ACM

2.8 Contracting Officer - 6 CONS/CC

The Contracting Officers play a key role in the AMOP. They are responsible for the following:

In conjunction with the BCE Director, develop standard contract language to inform contractors of the potential to disturb asbestos. It will be the project designer's responsibility to consult with the APO to determine where the hazards may exist and what steps the contractors must take to protect base personnel and families

Inform all base contractors that they may encounter asbestos-containing materials while conducting their work and that they must take precautions to protect their workers.

Require that all base contractor personnel are properly trained for conducting asbestos related work

Develop contract language for asbestos abatement specifications, statements of work and other contract documents

Work closely with Civil Engineering Construction Management to ensure that contractors adhere to contract specifications to avoid noncompliance with the regulatory statutes and AFOSH standards.

2.9 Quality Control Inspector (CE Support Contractor) – 6 CES/CPQI

Quality Control Inspector is responsible for the following:

Conducts worksite inspections, and provides guidance for all 6 CES projects and/or maintenance activities involving asbestos materials

Verify that maintenance personnel (contracted or otherwise) working with or disturbing

ACM has had the required training, physical examinations and respiratory fit testing

Consults with CE Support contractor Safety Office to ensure that safe asbestos work practices are being used during maintenance and abatement activities carried out by contractors. And may stop work due to unsafe working conditions or improper area preparation

2.10 Facility Managers

Facility managers shall:

Be cognizant of how maintenance and renovation activities may affect asbestos and the control methods that should be used. Most construction and maintenance activities that disturb asbestos will be planned and coordinated by the BCE and the APO. During daily routines, the Facility Manager has the opportunity to check on worker progress and ensure that if any ACM is disturbed, and the APO is notified

Report any maintenance activities that are not being performed using safe methods designated in the AMOP to the APO immediately

Aid Public Affairs (PA) and Public Health (PH) in preparing briefings for building occupants on the location and appearance of ACM in the building

During routine inspections and operations of a building, the Facility Manager will:

Inform the APO of any conditions that could cause asbestos-containing materials to be disturbed

Inform the APO of ACM in disrepair so that the APO can evaluate and prioritize abatement/repair actions

2.11 Public Health (PH) - 6 AMDS/SGPM

The PH office is responsible for the following:

Develop and implement an asbestos exposure questionnaire

Develop an educational pamphlet for maintenance workers discussing the potential health concerns associated with asbestos exposure, as well as, the relationship between asbestos exposure and smoking

In conjunction with Public Affairs, develop public awareness plan

Provide occupational health education/training on asbestos awareness for federally employed maintenance and custodial personnel who may work in buildings that contain

ACM

2.12 Public Affairs (PA) - 6 ARW/PA

Public awareness and education of asbestos issues are important so that base employees and family members can understand the potential hazards and the steps they can take to protect themselves. Public Affairs will:

With coordination of 6 CES/CEIE, publish periodic newspaper articles to keep base personnel informed of asbestos and other environmental activities at the base. The articles shall stress the importance of asbestos, and although common on all Air Force installations, is not a health hazard unless in poor condition or is disturbed

2.13 Environmental Legal Adviser - 6 ARW/JA

The Environmental Legal Adviser, located in the office of the Staff Judge Advocate, is responsible for reviewing activities brought to their attention involving asbestos to ensure regulatory compliance and to advise on legal conflicts. The Environmental Legal Adviser will coordinate the following:

Propose base actions for compliance with the 29 and 40 CFR series requirements, AFI’s, state and local requirements

All plans and programs that have been developed to meet environmental protection laws

Criteria, standards, performance, specifications, and compliance schedules developed to ensure compliance with applicable laws regarding asbestos

Requests for monitoring data by federal, state, and local agencies to determine whether the data are required by applicable law or regulation

Inspections by federal, state, and local regulatory agencies and the results of these inspections

Any notice of violation served upon the base for noncompliance of federal, state, or local law

Log all litigation records concerning asbestos

2.14 Safety Officers - 6 ARW/SE and 6 CES/CPQS

The Wing Safety Office performs the following tasks:

Remains cognizant of asbestos abatement activities and safety precautions, procedures, and policies related to the AMOP

Provide awareness training to Wing Staff, (as described in table 7-1 of section 7.0) that play a role in asbestos management but do not require formal EPA or state accredited training

Assists and advises the APO regarding physical safety concerns as they pertain to the in-house operations and maintenance activities performed by base personnel

CE Support Contract, Safety Officer - 6 CES/CPQS

Conduct asbestos awareness training for 6 CES staff as described in table 7-1 of section

7.0

Maintain training records for 6 CES personnel

Ensure that 6 CES maintenance personnel have received adequate training to work in and around buildings that contain ACM and to recognize asbestos hazards they may encounter

Immediately inform APO and BEE of any known or suspect exposures to asbestos

2.15 Flight Medicine

The following duties are applicable to active duty personnel only.

Coordinate annual occupational physical examinations of maintenance workers to determine whether individuals are medically qualified for duties requiring respirator use

Maintain medical records for in-house maintenance and asbestos workers

2.16 Aerospace Medicine Council - 6 MDG

The Aerospace Medicine Council will:

Establish medical surveillance protocols that meet the requirements of 29 CFR

1910.1001, paragraph (l), or 29 CFR 1926.1101, paragraph (m) and applicable appendices

Annually review the status of the asbestos program (ambient and bulk monitoring, education, medical monitoring, etc.) for compliance with Air Force, OSHA, and EPA standards

Section 3.0 Asbestos Investigation

This section discusses the methods to be used during an investigation of asbestos containing materials. The procedures for evaluating the hazard associated with the ACM are also discussed.

3.1 Survey Methods

In the event that a facility or area has not previously been surveyed, or additional sampling is required prior to renovation or demolition, the presence of asbestos containing material must be investigated. All bulk samples of suspected ACM will be taken in accordance with 40 CFR 763, Asbestos Hazard Emergency Response Act (AHERA), as described therein, by BEE and/or by an outside contractor hired through the Base Contracting office.

3.2 Hazard Evaluation

Once a material has been identified as ACM, a determination will be made by BEE and the APO as to its hazard potential towards military and civilian personnel. The factors that will be considered are: the condition of the material, and type of work to be done in the area of concern.

After evaluating the material using these criteria BEE and the APO will determine whether to abate, encapsulate, or monitor in place.

3.3 Ranking

Based on the GRADE rating rationale, appropriate treatment will be identified for each item.

The options include: maintaining in place, for ACM that is undamaged and does not pose a health risk; repair, which involves sealing, encapsulation, or enclosing ACM to prevent release of asbestos fibers; and removal for materials damaged beyond repair. The BEE and the APO will be responsible for the ranking of all asbestos projects. All projects will be ranked as follows:

1. ACM is damaged and presents a current hazard of exposure. It shall be scheduled for immediate removal.

2. ACM is damaged but does not pose an immediate exposure risk. It should be treated as soon as possible.

3. ACM is in good condition and does not pose a threat. However ACM should be removed when an opportunity arises, such as a part of regular maintenance or repair projects.

4. ACM is in good condition and should pose no threat as long as it remains undisturbed.

Section 4.0 Asbestos Management Activities

This section presents various considerations and techniques for in-place management and abatement. The purpose for in-place management and abatement is to minimize potential asbestos exposure to base personnel, their families, and maintenance and construction personnel.

The main purpose is to manage or eliminate the hazard, which will reduce the risk of exposure to airborne asbestos fibers.

4.1 In-Place Management

Materials not categorized as requiring immediate abatement or abatement as soon as feasible, should be classified for in-place management. These materials can be effectively managed in-place until conditions require their removal, or when renovation or demolition activities warrant their removal. In-place management is oriented largely toward maintaining ACM in good condition, preventing or controlling activities that damage or disturb ACM, timely and effective implementation of response actions to prevent further release of asbestos fibers from subsequently damaged ACM, and monitoring (through periodic re-inspections) the condition of the ACM.

4.2 Monitoring and Surveillance

All locations with friable asbestos must be monitored on an ongoing basis, until the material has been abated. This will ensure that the friable asbestos does not pose a risk of exposure to base personnel. The BEE will determine the requirements for taking air samples and will conduct monitoring for airborne asbestos fibers when there is a high potential for fiber release from deteriorating friable asbestos. Each occupied facility in which friable ACM is identified will be evaluated using the GRADE methodology as part of the survey. In addition, each occupied location in which damaged friable ACM has been found will be monitored monthly for further deterioration until the damage has been adequately abated and the area has been cleared by the

BEE. The monitoring will be accomplished by the facility manager or CE personnel (craftsmen or planners) as deemed most appropriate by the APO. Child-care facilities, family housing, recreation facilities, medical facilities and unaccompanied personnel housing containing friable asbestos will be monitored according to the GRADE requirements until the asbestos has been removed and the facility cleared by the BEE.

The APO will work with the AOO to institute a program of periodic surveillance to check the condition of friable ACM and to identify damage. A surveillance of all friable ACM locations should be conducted consistently with GRADE requirements, and surveillance should be scheduled as a routine part of CE activities. The date of the next scheduled surveillance should be included in the asbestos facilities database.

To the extent practicable, surveillance should be scheduled in conjunction with other facility visits conducted by planners, design engineers, or shop personnel. When CE personnel are able to check the condition of friable ACM as part of a facility visit, they will report the results of the surveillance to the APO, who reschedules the next surveillance for that location. This process can effectively reduce the requirement for scheduling site visits specifically for surveillance of

ACM and at the same time ensure ongoing monitoring of potential asbestos hazards.

4.3 Signs and Labeling Requirements

Under AHERA (Asbestos Hazard Emergency Response Act) and OSHA (Occupational Safety and Health Administration) the posting of warning signs is mandatory.

AHERA requires signs to be placed immediately adjacent to any friable and non-friable ACM, as well as suspect ACM, located in routine maintenance area. All signs must be prominently displayed in clearly visible locations. The Signs and/or labels will state:

CAUTION ASBESTOS –HAZARDOUS

DO NOT DISTURB WITHOUT PROPER TRAINING AND EQUIPMENT

The OSHA standards require the establishment of regulated areas where the airborne concentrations of asbestos exceed or are expected to exceed the permissible exposure limit

(PEL). These are areas where friable asbestos has been or will be disturb, such as abatement work areas. Warning signs must be displayed at each regulated area and at the approach to regulated areas. The information prescribed by OSHA on the signs must state:

DANGER ASBESTOS

CANCER AND LUNG HAZARD AUTHORIZED PERSONNEL ONLY

4.4 Facility Maintenance Procedures

If a worker, whether in-house or contractor, works with or disturbs ACM they are required to have asbestos training which is outlined in Section 7 and utilize the following procedures.

The AOO, with input from the APO, shall provide the maintenance worker with the quantities, locations, and conditions of all ACM which might be encountered in the work areas

If information is not available, the maintenance worker should assume that any suspected ACM in the work area is asbestos-containing

Maintenance workers should never disturb ACM

If disturbance, repair, or removal of ACM is required to facilitate the intended maintenance work, the APO and AOO will decide on the appropriate response action for the situation

After any abatement activities are complete and the clearance criterion has been achieved, the

APO and AOO should give authorization for the intended maintenance work to proceed

Special work practices such as wet wiping, area isolation, HEPA vacuuming, and the use of personal protective equipment such as respirators and protective clothing, may be needed where disturbance of ACM is likely. ACM may readily release fibers into the air when certain mechanical operations are performed directly on it, such as drilling, cutting or sanding.

4.5 General Custodial Activities

Special cleaning practices are appropriate for any building with exposed surfacing or thermal system insulation ACM, especially if the ACM is friable. If gradual deterioration or damage of

ACM has occurred or is occurring, asbestos-containing dust or debris could be present. For buildings where such materials have been identified, custodial and/or operations personnel should notify the AOO immediately of any residual asbestos dust. The AOO will then be responsible for making sure that the area of concern is decontaminated of all suspect dust. This is to be accomplished by an individual who has taken and passed the 3 day AHERA Inspectors

Course within the last twelve months and who has been medically cleared and fit tested and is wearing a properly maintained and appropriate respirator. The individual is then to use a HEPA vacuum to clean up any residue or dust in the area. If the material causing the dust/debris has not been identified as ACM or non-ACM, the APO should be notified. And the area surveyed immediately for asbestos containing material. If the material causing the dust/debris is in a state of disrepair the APO and BEE should be notified to make a determination on future management such as abatement or encapsulation. Routine cleaning of floors using wet methods should be performed in these areas. Custodial and Maintenance workers in the course of normal work must also identify and report to the APO any areas which are in need of special cleaning or repair.

Special cleaning techniques shall supplement, not replace, repair or abatement actions for damaged, friable ACM. The cleaning program shall include an initial cleaning followed, as needed, by subsequent periodic cleanings.

4.6 ACM Abatement in Renovation, Construction, and Demolition Projects

Future renovation, construction, and demolition projects will need to include ACM abatement.

All asbestos abatement on MacDill AFB will be performed under contract by a state licensed asbestos consultant prior to any renovation or demolition activity begins. During the project planning phase, it will be necessary to inform the APO of the intended scope of work. The APO will then conduct an ACM investigation specifically for the particular project. The investigation will include:

Review of available data on ACM that will be affected by planned work

If the presence or absence of ACM is not known, an asbestos survey must be performed to determine the presence or absence of asbestos

If the project will involve demolition or renovation, the contractor may need to conduct some intrusive testing of concealed materials behind permanent walls or above permanent ceilings which might be disturbed during the work

The APO shall prepare a report inventorying known ACM accordingly

Planners and designers should review the report and determine if the project is feasible or should be reconsidered

The APO must be included in the preliminary development of renovation and demolition projects in order to avoid costly delays which can occur when unexpected asbestos is encountered during a project. Precautions must be taken to protect facility occupants, workers, and the environment when disturbing ACM during maintenance, repairs, modifications, renovation, and demolition activities. Personnel performing these activities must be trained to recognize hazards and how to protect themselves and others.

Note: Except as specifically set forth in condition 10.7.2, executive copy of the Lease of

Property (i.e. Ground Lease), Military Family Housing Privatization Initiative, for “Leased

Premises Improvements,” the Govt. shall not be responsible for any handling, removal, disposal, or containment of ACM located on, in or attributable to the Leased Premises Improvements

(including buried utility lines) or to the extent consistent with environmental requirements for any liability.

4.7 Long-Term Abatement Plan

The comprehensive asbestos surveys will provide the APO with the information needed to develop a long-term abatement plan. The APO will develop a plan that is based on the resources available and the hazards identified in the facilities surveys. Most of the work will be incorporated into renovation and demolition projects.

4.8 Emergency Response Procedures

When an emergency response situation occurs, it is important for the APO, AOO, and BEE to be notified immediately. Once notified, the APO, AOO, and BEE must proceed with the following procedures.

The BEE must immediately evacuate and isolate the affected area and request a shut down and lock out all HVAC systems in the area

BEE must conduct ambient air monitoring to ensure that asbestos contamination has not migrated from the isolated area

Depending on the size of the fiber release, the BEE must contact the EPA and/or the state, as necessary

The APO, AOO and BEE will provide oversight and monitoring during the work to ensure that the hazard has been effectively mitigated

If necessary, PA shall become involved to ensure that accurate information regarding the incident has been disseminated to facility and base occupants

Section 5.0 Notification Requirements

5.1 Asbestos Removal Notification Requirements

Federal regulations (40 CFR Part 61; Subpart M – National Emissions Standards for Asbestos) require that the EPA or authorized state agencies be notified of asbestos removal projects. For

MacDill AFB, the Environmental Protection Commission of Hillsborough County (EPCHC) has been delegated the authority to enforce the asbestos regulation locally. Therefore, the abatement contractor must notify the EPCHC 10 working days prior to beginning any demolition or renovation activities involving the disturbance of more than 160 square feet, 260 linear feet, or

35 cubic feet of regulated asbestos-containing materials.

For projects completed by outside contractors, compliance with asbestos laws and regulations is the responsibility of the contractor. However, it will be the responsibility of the APO or AOO to notify the contractor of any known ACM that they may encounter in the areas where they will be working.

Contractors are responsible for providing notification and project information directly to the state. They are also responsible for the occupational health protection of their personnel under 29

CFR 1926.1101, and for complete control of asbestos fibers during removal.

The contractor will notify the state at least 20 days before work commences. In this notification, the contractor will describe procedures to be used to minimize release of fibers and to ensure that fibers do not escape the work area. A copy of this notification will be provided to the APO at least 10 days before the project commences. The APO shall ensure that no work begins until this notification has been received.

Section 6.0 Medical Surveillance

6.1 Personnel Requiring Medical Surveillance

All asbestos related work on MacDill AFB that includes the disturbance of positively identifies building materials, will be conducted by trained and certified, outside contractors only. At no time are USAF employees, active duty or reserve airmen permitted to conduct asbestos removal or ACBM disturbing activity. The medical surveillance requirements apply to trained and certified, outside contractors covered by any of the following categories:

Personnel who have worked for a combined total of 30 days or more per year engaged in removal of ACM, or repair and maintenance operations where ACM is likely to be disturbed

Personnel exposed at or above the PEL (0.1 f/cc) or the Excursion Limit (1.0 f/cc), as determined by the Aerospace Medicine Council

Employees who wear negative-pressure respirators while working with ACM

6.2 Medical Examinations

In the event of asbestos fiber exposure to active duty or reserve facility occupants on MacDill

AF, medical examinations will be administered by the Flight Surgeon's Office (FSO) in accordance with 29 CFR 1926.1101(m) and AFI 91-202 Section 1.5 (AFOSH Guidance) guidance as referenced in AFI 91-202

Medical examinations shall be scheduled by Public Health (PH) and administered by the FSO.

Additionally, work histories, medical histories, and patient questionnaires shall be initiated at the time of the first physical examination and updated at subsequent annual physical examination by

PH. Work histories, medical histories, and patient questionnaires referred to above are those specified by AFI 91-202 Section 1.5 (AFOSH Guidance).

Flight surgeons will review the results of the physical examinations and make determinations as to whether the personnel are medically certified. The FSO will ensure that the APO, AOO and

BEE are notified in writing as to whether workers have been medically certified to wear a respirator during asbestos abatement work.

Written documentation shall be maintained of the dates that personnel received respiratory protection training, respirator fit tests, physical examinations, and the examining physicians' certification as to whether personnel are able to work while wearing respirators.

Section 7.0 Training

7.1 Training Requirements

Individuals responsible for managing, planning, designing, inspecting, controlling, removing, or supervising the control or removal of asbestos require training, accreditation, and certification. A person may qualify for state certification by successfully completing an EPA or Florida approved training program and registering with the state.

The APO is responsible for identifying appropriate training courses for each person conducting asbestos- related work. Six types of training courses are currently available:

Worker

Supervisor

Inspector

Management planner

Project designer

Air monitor

In addition, awareness training must be provided by the Wing Safety and CE Support Contract, Safety officers (as described in section 2.13) to personnel who have a role in asbestos management and do not require formal EPA or state-approved training. As a minimum, the asbestos awareness training shall cover the following topics:

Background information on asbestos

Health effects of asbestos exposure

Typical locations of ACM on-base

Recognition of ACM damage and deterioration

Response actions

Worker protection

Table 7-1 indicates the training requirements for personnel with asbestos-related responsibilities.

Table 7-1

Asbestos Training Requirements

Personnel

Worker

Supervisor

Inspector

Mgmt.

Planner

Awareness

Air

Monitoring

Wing Commander

X

BCE X

Public Affairs

Office

X

Safety

Officers

X

Environmental

Legal Adviser

X

Bioenvironmental Engineer

X X X X

Bioenvironmental Engineering Staff

X X X

APO X X

AOO X

Project Planners X

Project Design Engineers

X

Maintenance Personnel X

Asbestos Contractor

Supervisors

X

Custodial X

Worker - 4-day course

Supervisor - 5-day training course Inspector - 3-day course Management planner - 2-day course

Awareness training – Minimum 2 hours annually

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