Attach__No__1B_-_Asbestos_Ops_Plan.pdf

45th Space Wing Asbestos Operations Plan

45th Space Wing

Patrick SFB, Florida Air Force Space Command

March 2021

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45 SW ASBESTOS OPERATIONS PLAN

SECURITY INSTRUCTIONS

1. The long title of this plan is 45th Space Wing Asbestos Operations Plan. The short title is 45 SW AOP. Both titles are unclassified.

2. This plan is unclassified and does not fall within the scope of directives governing the protection of information affecting national security as specified in Air Force Directives. It requires no specific safeguarding or protection.

3. This plan will be distributed to those organizations shown on the Distribution List. The plan will be controlled in accordance with established Air Force procedures for unclassified documents.

4. Reproduction of this plan in whole or part without the permission of the OPR is authorized as required in preparation of supporting plans, reports or checklists.

RECORD OF CHANGES

CHANGE

NUMBER

DATE OF

CHANGE

DATE

POSTED

POSTED BY DATE

CHECKLIST

REVIEWED

RECORD OF ANNUAL REVIEW

REVIEWED BY DATE REVIEWED REMARKS

03/18/2021

Table of Contents

1. PLAN SUMMARY……………………………………………………………………………..8

2. PURPOSE …………………………………………………………………………………

3. BACKGROUND ……………………………………………………………………………….8

4. OBJECTIVE…………………………………………………………………………………….9

5. APPROACH …………………………………………………………………………………

6. ROLES AND RESPONSIBILITIES ………………………………………………………….10

6.1. ASBESTOS OPERATIONS OFFICER (AOO) ………………………………………….10

6.2. ASBESTOS RESPONSE TEAM (ART) ………………………………………………...11

7. WORK CONTROL PROCEDURES …………………………………………………………11

7.1. SCHEDULING AND PLANNING ……………………………………………………...11

7.2. CLASSIFICATION AND RANK ……………………………………………………….12

7.3. CONTROL OF REMOVAL PROJECTS ……………………………………………….13

7.3.1. JOB SITE MONITORING ………………………………………………………..13

7.3.2. JOB SITE CONTROL …………………………………………………………….14

7.4. RECORD KEEPING ……………………………………………………………………..14

7.5. SURVEILLANCE PROGRAM ………………………………………………………….14

8. WORK PRACTICES OVERVIEW ………………………………………………………….15

8.1. FRIABLE ACM …………………………………………………………………………15

8.2. NON-FRIABLE ACM …………………………………………………………………..15

8.3 CHECKLIST ……………………………………………………………………………..15

8.4 ABATEMENT OPTIONS ………………………………………………………………..15

8.5 EMERGENCY RESPONSE TO AN ASBESTOS RELEASE INCIDENT ……………..16

8.6 TRANSPORTATION AND DISPOSAL ………………………………………………...16

8.7 RECORD KEEPING ……………………………………………………………………..16

8.8 WASTE TRANSPORT …………………………………………………………………..17

8.9 PACKAGING ASBESTOS FOR TRANSPORTATION AND DISPOSAL ……………17

8.9.1 ASBESTOS DISPOSAL ARRANGEMENT ……………………………………..17

8.9.2 DISPOSAL OF BUILDINGS CONTAINING ASBESTOS ……………………...18

8.10 IN-HOUSE EQUIPMENT ……………………………………………………………...18

9. HEALTH AND SAFETY ……………………………………………………………………..18

9.1 PROCEDURES …………………………………………………………………………...18

9.2 RESPIRATORY PROTECTION …………………………………………………………18

9.3 JOB SITE SAFETY AND REPORTING REQUIREMENTS ……………………………19

9.4 EMERGENCY RESPONSE DURING ABATEMENT ………………………………….19

9.4.1 ON SITE EMERGENCY EQUIPMENT ………………………………………….19

9.4.2 PERSONAL INJURY PROCEDURES …………………………………………...19

10. CONTRACTING PROCEDURES ………………………………………………………….19

10.1 CONTRACTING PROGRAMMING …………………………………………………..19

10.2 CONTRACTING PROVISIONS ……………………………………………………….20

10.3 REGULATORY COMPLIANCE RESPONSIBILITY ………………………………...20

10.4 MONITORING DURING CONTRACT PERFORMANCE …………………………...21

10.4.1 GOVERNMENT INSPECTION RESPONSIBILITIES …………………….…21

10.4.2 MONITORING RESPONSIBILITIES …………………………………………21

10.4.2. (a) PRE-ABATEMENT MONITORING ……………………………...22

10.4.2. (b) INSPECTION OF ABATEMENT AREA …………………………22

10.4.2. (c) AIR MONITORING ………………………………………………..22

10.4.2. (d) DIFFERENTIAL PRESSURE MESSUREMENTS ……………….23

OF NEGITIVE PRESSURE ENCLOSURE

10.4.2. (e) PERSONAL AIR MONITORING …………………………………23

10.4.3 ON-SITE DOCUMENTATION ………………………………………………. 23

10.4.4 PERSONAL PROTECTIVE EQUIPMENT …………………………………...23

10.5 POST-PROJECT INSPECTION ………………………………………………………..24

10.5.1 FINAL CLEARANCE PROCEDURES ………………………………………..24

10.5.2 SAFETY ………………………………………………………………………...25

10.5.3 CLOSE-OUT DOCUMENTATION …………………………………………...25

11. TRAINING REQUIREMENTS …………………………………..………………………….25

ANNEX:

A. Air Force GRADE System

APPENDIX:

A. Glossary …………………………………………………………………… E-40 B. 45 CES Asbestos Abatement Team Activity Log ………………………… E-45 C. Asbestos Removal Checklist ……………………………………………… E-46 D. Procedures for Area Air Monitoring ……………………………………… E-49 E. Procedures for Personal Air Monitoring …………………………………... E-51 F. Procedures for Final Air Monitoring ……………………………………… E-53 G. Asbestos Activity Final Inspection Checklist ………………………………E-55 H. Asbestos Activity Pre-work Inspection Checklist ………………………….E-56 I. Asbestos Daily Inspection Checklist………………………………………..E-57 J. Construction of a Negative Pressure Enclosure …………………………… E-58 K. Procedures for Glove Bag Abatement ……………………………………...E-61 L. Procedures for Asbestos Hazard Response …………………………………E-63 M. Job Site Emergency Equipment …………………………………………….E-64 N. Emergency Telephone Numbers ……………………………………………E-65 O. Equipment and Supply List …………………………………………………E-66 P. References …………………………………………………………………..E-69 Q. Notification Form & Waste Shipment Records …………………………….E-71 R. Bulk Sampling Procedures ………………………………………………… E-72

45 SW ASBESTOS OPERATION PLAN

1. PLAN SUMMARY

1. The purpose of this Asbestos Operations Plan (AOP) is to ensure that ACM at the 45th Space Wing (45 SW) installations are managed in a safe manner that complies with applicable environmental and safety regulations.

2. The medical community concluded that exposure to asbestos and ACM can have an adverse effect on health. Several medical studies show that the inhalation of asbestos fibers causes serious health problems. Asbestos is known to cause various forms of cancer. ACM may be a health hazard to military and civilian employees, their families, and contractors performing work in facilities containing asbestos. The Air Force policy on asbestos delineated efforts required to protect facility occupants and workers in the environment from hazardous exposures to asbestos.

2. PURPOSE

The purpose of the Asbestos Operating Plan (AOP) for Patrick Space Force Base (PSFB) is to implement the policy established in the Asbestos Management Plan (AMP) in accordance with AFI 32-1052 Facility Asbestos Management. Air Force policy is to manage ACM in place as long as practicable; ideally until a facility with ACM is scheduled for disposal (except in residences, medical facilities, and facilities used by children where any friable asbestos that might lead to exposure should be removed). This requires that installations have specific procedures for managing facilities with ACM and protecting personnel from the hazards associated with airborne fibers from damaged ACM. It is the intention of the Air Force to remove ACM whenever it is opportune and expedient to do so, whenever it is a potential threat to personnel health, and as necessary to comply with applicable regulations.

3. BACKGROUND

Asbestos in its bonded condition does not necessarily pose a health risk but asbestos that is capable of being crumbled, pulverized, or reduced to powder by hand pressure does pose a health risk and is described as “friable.” Inhalation of asbestos fibers has been linked to cancer and other diseases in humans. Appendix A contains a glossary of terms commonly used in asbestos operations.

The Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) regulate the use, handling and abatement of asbestos. EPA regulations concerning asbestos are contained in the Code of Federal Regulations (CFR) at 40 CFR 61. These regulations govern control of asbestos fiber emissions to protect the environment and the public safety. OSHA regulations are contained in 29 CFR 1910 and 1926 and set out requirements for protecting personnel potentially exposed to asbestos fibers in the work environment. AFI-32-1052, Facility Asbestos Management outlines the procedures for developing a facility asbestos program and provides general guidance for developing an AOP. The AOP for PSFB is to be consistent with this instruction. Regulations governing safe work practices are contained in the Air Force Occupational Safety and Health (AFOSH) publications.

4. OBJECTIVE

The PSFB AOP is designed to provide comprehensive program guidance for asbestos operations on PSFB, the objectives of the AOP are:

• To define requirements for effecting safe, efficient, and regulated operating procedures for asbestos removal/containment on PSFB and to ensure the health and safety of Air Force personnel, their families, and other occupants of base facilities.

• To outline an operating program that will provide for routine monitoring of ACM in base facilities to ensure that it is maintained in a good condition, making expedient repairs when there is damage, and taking all necessary precautions to ensure that personnel in base facilities are not exposed to airborne asbestos fibers.

• To ensure that decisions regarding particular circumstances involving ACM are based on a direct evaluation of conditions by qualified civil engineering and bioenvironmental engineering specialists.

• To incorporate routine asbestos management in the day-to-day operations of PSFB, thereby enabling the base asbestos management program to focus on a more proactive role.

• To provide for quality control of work performed at facilities with ACM, ensuring compliance with environmental regulatory, health and safety requirements.

• To minimize to the lowest possible level Asbestos Response Team (ART) worker exposure to airborne asbestos fibers. Personal protective equipment, engineering controls and abatement work practices will all be used to minimize exposure.

• To ensure that ACM is adequately addressed and provided for in the planning and design of projects to be accomplished in house and by contract.

• To establish and maintain an (ART) and to ensure that team members involved in assessment, treatment, repair, maintenance, removal, and disposal of ACM are adequately and appropriately trained and equipped.

• To define repair procedures to include interim control measures and extraordinary precautions.

• To outline the Occupational Health requirements for the ART.

• To define equipment and supply requirements.

• To ensure all contractors comply with contract specifications.

• To provide annual budget estimates for asbestos abatement.

5. APPROACH

The basic approach of the AOP is to define procedures so that the status of the asbestos activities can be clearly delineated each step of the way as the job progresses from identification to disposal.

The approach must be proactive in order that each organization understands its functions at each point of the process. The Asbestos Operations Officer (AOO) will act as the focal point of all activities identified in the AOP. The AOO will implement changes and ensure that this document is reviewed annually to ensure it is current and adequate.

Work requirements must be thoroughly reviewed before any job starts to ensure that craftsmen do not encounter ACM at the work site. If ACM is encountered or suspected on site, work will cease immediately until an abatement project is completed.

If asbestos is to be abated, team members must have safe operating procedures and follow these procedures. If ACM is to be maintained in place until identified for removal in a future project or left until facility demolition, then an adequate O&M planning and surveillance program must be undertaken to periodically verify ACM condition. Although work order screening is important, another method of preventing fiber release incidents by shop personnel is to ensure they are trained to recognize potential ACM.

The AOO is responsible for ensuring that the objectives of this plan are accomplished, and for integrating asbestos management procedures into the scheduling and authorization procedures used by the Civil Engineering Squadron (CES) to conduct routine operations activities. The AOO will work with the Wing Asbestos Program Officer (APO) to ensure that management actions are integrated into the AOP.

The AOO in charge of asbestos operations will coordinate with the management team members, including the APO, Bioenvironmental Engineer (BEE) and the Asbestos Management Team (AMT) whenever problems arise or management concerns need to be addressed. The interaction between these organizations as a “team” approach is important in accomplishing asbestos tasks and maintaining effective control.

6. ROLES AND RESPONSIBILITIES:

6.1. ASBESTOS OPERATIONS OFFICER

The BCE appoints the following as the Asbestos Operations Officer at the respective locations:

Patrick Space Force Base Chief, Operations Flight Cape Canaveral Air Station Chief, Cape Engineering Flight Ascension Auxiliary Airfield Chief, Engineering Flight

At Patrick SFB the AOO responsibilities are as follows:

• The AOO is responsible for establishing, maintaining, and equipping the Asbestos

Response Team (ART) who will handle all in house asbestos abatement. The AOO will select an appropriately trained individual as the ART supervisor, who will ensure that all personnel used as team members have completed all necessary training as required by state and federal agencies and will maintain all team members in full compliance with the annual re-certification and physical examinations.

• The AOO will ensure that all asbestos removed by in-house personnel is containerized and stored in a secure area with proper warning signs affixed. The AOO will be responsible for maintaining a chain of custody (manifest) for all waste generated and assuring that the asbestos is properly transported to an Air Force designated landfill for disposal.

• The AOO is responsible for establishing and equipping the ART.

• The AOO will ensure that all in house ART actions are properly documented and forwarded to the APO for inclusion in the permanent record.

• The abatement responsibility of the ART at PSFB is limited to small scale and emergency situations. All other abatement requirements provided for either within a project or by the IDIQ contract is the responsibility of the Chief, Engineering Flight.

• The AOO will ensure that in-house work orders, job orders, projects and work to be accomplished are thoroughly checked to determine if asbestos is present, exposed, or suspected. If a work request involves, or there is potential for involving asbestos, the AOO will notify the APO to request sampling support from the BEE. The AOO will ensure no project, maintenance, or repair operations are accomplished until the presence of asbestos has been determined or is presumed and all appropriate precautions are taken.

• The AOO will promptly respond to all situations identified as a potential health hazard (RAC I or II) ensuring rapid action to mitigate exposure of base personnel.

• The AOO will ensure that the APO and the BEE are informed in advance of all ART projects.

• The AOO will ensure that all in-house ART actions are documented, in 45 SW Electronic Asbestos Inventory format and forwarded to the APO for inclusion in the register.

• The AOO will contact the APO to notify the Environmental Legal Advisor immediately of any known or suspected human exposure to asbestos. The APO will notify the BEE.

6.2. ASBESTOS RESPONSE TEAM (ART)

The Asbestos Response Team (ART) at PSFB is the in-house asbestos abatement team. The supervisor for the ART is selected by the AOO. The team members are selected as required by the supervisor from qualified and available craftsmen. Team members will be required to complete an EPA approved training course, pass an examination and participate in annual refresher courses.

The ART will be used for emergency and small-scale, short duration removal/abatement projects only. Small-scale abatement shall not exceed 40 linear feet or 200 square feet. Personnel monitoring will be requested for ACM abatement when projects will extend beyond a 2-hour duration. Large-scale and non-emergency asbestos hazards will be removed/abated by contract.

7. WORK CONTROL PROCEDURES

7.1. SCHEDULING AND PLANNING

The schedule for ACM abatement is determined by the AOO or APO. The basis of this determination is derived from the survey database and concurrence of the AMT to ensure the latest priorities are being followed in the asbestos abatement program. The key to this determination is derived from the risk of potential for release of asbestos fibers. Renovations are factored into the schedule as time and resources allow. An asbestos removal checklist that includes notification and planning actions is provided in Appendix C.

All work requests (AF Form 332) received by CE will be screened against the register and/or the facility ACM survey records in CEI by the AOO or his designee, this will determine if ACM is involved in the work request. If ACM is present and affects a work request, the AOO will notify the APO who will submit the work request to the AMT for abatement prioritization.

When the Planning Section executes a work order and there is potential to disturb ACM, the planner will notify the AOO who will request sampling to verify if asbestos is present. Responding to job orders is normally one of the major factors in the unwarranted disturbance of ACM.

Personnel in the Operations Flight will use all available data at their disposal to identify the presence of known ACM locations in facilities when authorizing and scheduling work orders and job orders (45 SW Electronic Asbestos Inventory and ACM Survey records in CEI).

Work orders and job orders that require asbestos abatement will be flagged by the schedulers. The APO, when notified, will ensure update of the register, in 45 SW Electronic Asbestos Inventory format with the work/job order number, date and the type of abatement work to be accomplished.

The schedule for ACM abatement is determined by the AOO or APO. The basis of this determination is derived from the survey database and concurrence of the AMT to ensure the latest priorities are being followed in the asbestos abatement program. The key to this determination is derived from the risk of potential for release of asbestos fibers. Renovations are factored into the schedule as time and resources allow. An asbestos removal checklist that includes notification and planning actions is provided in Appendix C.

All work requests (AF Form 332) received by CE will be screened against the register and/or the facility ACM survey records in CEI by the AOO or his designee, this will determine if ACM is involved in the work request. If ACM is present and affects a work request, the AOO will notify the APO who will submit the work request to the AMT for abatement prioritization.

When the Planning Section executes a work order and there is potential to disturb ACM, the planner will notify the AOO who will request sampling to verify if asbestos is present. Responding to job orders is normally one of the major factors in the unwarranted disturbance of ACM.

Personnel in the Operations Flight will use all available data at their disposal to identify the presence of known ACM locations in facilities when authorizing and scheduling work orders and job orders (45 SW Electronic Asbestos Inventory and ACM Survey records in CEI).

Work orders and job orders that require asbestos abatement will be flagged by the schedulers. The APO, when notified, will ensure update of the register, in 45 SW Electronic Asbestos Inventory format with the work/job order number, date and the type of abatement work to be accomplished.

7.2. CLASSIFICATION RANKING

Based on the Air Force asbestos Guidance for Rating and Assessing Damage and Exposure (GRADE) rating for ACM has been assigned the following Air Force Priority (AFP):

AFP 1: Immediate Removal. This area of the graph represents the major concern. The situation is such in terms of both damage and exposure potential to warrant immediate removal in spite of the large potential for fiber release during abatement.

AFP 2: Removal As Soon As Possible. Like the area above, this is guidance to management that the ACM will be removed as soon as possible, not waiting for the normal repair and maintenance cycle. In a school, for instance, removal will be accomplished during the summer or during recess periods. In a commercial building, it can be accomplished at night over a period of days. Prior to actual removal, it is recommended that access to that part of the building be limited.

AFP 3: Planned Removal. The hazard involved in these areas is such that removal will take place as part of the normal maintenance and repair cycle of a facility. This approach minimizes cost and disturbance.

AFP 4: Repair. The most damaged areas will be abated to a commensurate level.

AFP 5: Monitoring. Periodic monitoring of these areas will be planned to ensure that no further damage takes place.

AFP 6: No Immediate Action. These cases show little damage to structure and little exposure. In most cases, the material is well protected so that fiber release is very unlikely. No current action should be undertaken.

AFP 7: Non-Friable. Work orders with a ranking of 1 or 2 will be flagged. Those with a 1 ranking will receive immediate attention and, as a minimum, the ACM will be repaired. Work orders with a 2 ranking will be accomplished as soon as scheduling and resources will allow.

7.3. CONTROL OF REMOVAL PROJECTS

The AMT is responsible for managing all asbestos removal projects and, therefore, abatement projects are initiated only after a thorough review of current Air Force, OSHA, FDEP, and EPA regulations, standards, and guidelines is conducted.

Since the potential exists for a release of asbestos fibers from any maintenance, repair, or demolition operation, BEE will be notified and given sufficient time for an abatement job review.

Each individual ART member is responsible for personal protection equipment and will thoroughly inspect it before each use and will clean and store it properly after use. The ART supervisor will inspect the equipment before each job to ensure that it is maintained in good condition and is functioning properly. The ART supervisor will keep a folder on all members of the ART. This folder will indicate:

• The most recent physical exam

• Current fit test.

• Current certification

7.3.1. JOB SITE MONITORING

Job sites located on PSFB involved with the in-house containment/removal of asbestos, will be monitored by the BEE. The ART supervisor will evaluate each site before starting any asbestos-related work. The BEE will be contacted and requested to assist in this site evaluation, if deemed necessary by the AOO. The AOO will present the BEE an abatement plan containing the following items:

• The removal procedures to be employed.

• The personal protective measures to be used.

The BEE will make recommendations for any additional personal protective equipment needed.

The monitoring accomplished by the BEE consists of personal breathing zone and area air sampling in and adjacent to the removal area. A negative pressure check will be performed when a negative air machine is used. When the project is complete, the BEE or consultant will conduct a visual inspection and air sampling to ensure that the area has not been contaminated by airborne asbestos fibers. Air sampling procedures for area, personnel and final air monitoring are contained in Appendices D, E, and F.

It will be the responsibility of the ART supervisor and AOO to ensure that safe and proper techniques are practiced during abatement and removed ACM is bagged, labeled and disposed of properly.

The BEE will also conduct final inspection, review air-sampling results and notify the AOO that the area is clean and suitable for re-occupancy. Appendix G contains the final inspection checklist.

7.3.2 JOB SITE CONTROL

Job site control is one of the most important aspects of the work activities. The area must be blocked off with appropriate warning signs and barrier tape to keep all uninvolved personnel out of the area. A decontamination area, if required, will be established at the job site with a dirty, change/shower, and clean room. Negative air must be applied to the dirty room to ensure that fibers are not allowed into the clean area. The BEE will perform verification and sampling to assure the job site has been thoroughly cleaned after completion of the job.

7.4. RECORD KEEPING

A critical aspect of the asbestos program on base is assurance that project paperwork will be maintained on file for future liability concerns. Project paperwork must and shall be maintained indefinitely. The Department of Labor and the Occupational Safety and Health Administration (OSHA) can requisition these records in defense of potential litigation.

The ART supervisor will complete a report on each asbestos abatement job. This report will be forwarded to the AOO at the conclusion of each abatement project. The AOO will submit monthly reports to the APO containing at minimum the following information:

• Date (start and completion)

• Facility number

• Location (within the facility)

• Work order/job order number

• Type of material removed and work area (square or lineal feet) involved

• Personnel involved

• Brief description of activities to include site containment used, signs posted, work practices, and protective equipment

• Sampling or monitoring performed

• ART supervisor signature

As noted in the AMP, the APO will maintain records in the Asbestos File on all asbestos-related activities. The APO must ensure that the AOO provides adequate reports on each asbestos abatement activity.

7.5. SURVEILLANCE PROGRAM

ACM with a 3 or 4 priority, or in cases where a 2 priority ACM is delayed awaiting funding, will be placed in an Annual Surveillance Program. The BEE will share responsibility with CEO for this program and they will assure that changes in the condition of ACM are reported to the APO for register updating. The AMT will review the surveillance program periodically.

Areas of ACM that are friable or in a highly accessible or frequently used area, as identified by the BEE, will be appropriately labeled. The Planning Section will incorporate inspection of a facility for asbestos and monitor known ACM locations when planning work orders.

The APO will ensure the Asbestos Register is updated whenever ACM located in an area identified in the surveillance program is removed. Any time an asbestos project is accomplished through abatement, a copy of the work order will be so annotated by the AOO in order for the APO to identify the area in the surveillance program. A listing of the surveillance locations will be provided by the BEE so that known ACM locations can be briefed to contract personnel.

CE work crews will notify the AOO if any site conditions are found which are different from what is noted in the register. The AOO will then notify the APO so the register can be updated.

8. WORK PRACTICES

8.1. FRIABLE ACM

Removal of existing friable ACM is not required unless its condition constitutes a potential health hazard. This hazard will be determined by the BEE in accordance with the current Air Force, OSHA, EPA and State standards and guidelines. Even though a potential hazard may not exist, the CE organization will program the abatement of friable ACM, in accordance with AFI 32-1052 and if feasible, with respect to product performance and life-cycle costs. If any possibility exists for asbestos exposure in residential, medical, and high use facilities for children, the asbestos must be totally removed.

8.2. NON-FRIABLE ACM

Non-friable ACM is defined as a material in which asbestos fibers are “locked in” or “encapsulated” by a matrix material, saturate, impregnate, or coating. This type of ACM does not release airborne asbestos fibers during routine handling. Other non-friable ACM, such as asbestos-cement (A-C) pipe, A-C sheets, resilient floor coverings, and roofing felts may release fibers during such operations as sanding, cutting, drilling, removal or demolition. Removal of existing non-friable ACM is not required unless its existence poses a health hazard as determined by current OSHA, EPA and State guidelines. Also, any operations involving non-friable ACM will proceed only in accordance with applicable AFOSH, OSHA, EPA and state work practices and requirements.

8.3. CHECKLIST

At the start of each project, the ART Supervisor will provide the AOO with the Asbestos Pre-Work Daily Inspection Checklists, see Appendix G and H. This checklist will provide a tracking mechanism to ensure proper work practices are accomplished for each project. Additionally, the checklist will indicate that the work site has been properly posted, barricaded (if required); sealed;

proper worker protective equipment has been used; and adequate cleanup has been accomplished.

If a negative pressure enclosure is required, procedures and a checklist for setting up the enclosure are provided in Appendix J.

8.4 ABATEMENT OPTIONS

Encapsulation, enclosure and removal are the abatement options available for the containment of asbestos fiber release. Of the three, only removal provides the complete elimination of asbestos fiber releases. Encapsulation and enclosure may be used depending on the situation. Factors such as funding, time, locations and risk assessment all determine the appropriate abatement action.

Repair is another option that is normally used on a temporary basis. Repair is applicable to pipe and boiler insulation and to non-friable ACM. These materials can be patched and covered due to their structural strength. Repair of areas containing sprayed-on or troweled-on ACM is not recommended.

If the ACM is friable, the application of sealant, paint, or other compounds may disturb previously undisturbed adjacent material. Friable surfacing materials will be removed or fully encapsulated.

Repaired, encapsulated, or enclosed asbestos surfaces must be identified in the surveillance program and listed in the register.

Every effort must be made to minimize any risk of releasing asbestos fibers during inspections, sampling, encapsulation, and enclosure or removal operations. The operations that have the greatest potential for release of asbestos fibers are enclosure and removal operations.

Intelligent design and prudent construction of containment structures will preclude releases to the outside during abatement activities. Most small-scale abatement activities will consist of glove bag abatement. Guidance for this abatement can be found in 29 CFR 1926.58. See procedures in Appendix K: Glove Bag Abatement.

8.5. EMERGENCY RESPONSE TO AN ABESTOS RELEASE INCIDENT

In the event of a potential release of asbestos fibers due to: (1) discovery of badly damaged asbestos, (2) disturbance of ACM during maintenance or repair by in-house personnel or, (3) disturbance of ACM during renovation or repair by a contractor, immediate action will be taken to contain the release. When a release is discovered, the AOO will be immediately notified. The AOO will activate the ART to contain the release and will contact the BEE and APO. The BEE will respond to the site and assess the potential for employees in the area to be exposed to asbestos fibers. The BEE will make recommendations as to how the fiber release will be contained.

Once the initial release is contained the APO with AOO input will decide whether repair work can be done in-house by the ART or must be contracted out for abatement as shown in Figure 6. This decision will be based on the size of the repair/removal, exposure potential, mission requirements, availability of in-house resources and contract capability.

Any in-house repairs will be planned and approved in the same manner as routine work to include coordination with the AOO, APO and BEE. All work completed by contract will be expedited through CE, Finance and Procurement channels as necessary to support mission requirements.

8.6. TRANSPORTATION AND DISPOSAL

Transportation is defined as all activities involving asbestos waste from the time it leaves the work site until it has been unloaded at the disposal site. Current EPA regulations state that there must be no visible emissions to the outside air during transportation. Additionally, because of the hazards and liabilities associated with exposure, the following additional precautions are recommended.

8.7. RECORD KEEPING

The ART supervisor will ensure that the asbestos waste is properly wetted and containerized before transporting the waste. The ART supervisor must ensure that a chain-of-custody form (manifest) is completed and signed. This form will include (1) the name and address of generator

(BCE), (2) the address of the pick-up site and address of the facility where the asbestos was removed, (3) the estimated quantity of asbestos waste, (4) types of containers used, and (5) the destination of the waste. The chain-of-custody form will then be signed over to a disposal site operator to transfer custody for the asbestos waste. A copy of the form signed by the disposal site operator will be maintained in the asbestos file by the APO as the evidence of receipt of the waste at the site.

8.8. WASTE TRANSPORTATION

Vehicles used for transporting containerized asbestos waste will have a covered carrying compartment sufficient to contain the transported waste, prevent damage to containers, and prevent fiber release.

8.9. PACKAGING ASBESTOS FOR TRANSPORTATION AND DISPOSAL

All asbestos and asbestos-contaminated materials, which includes protective clothing, disposable respirators, brooms, wiping rags, vacuum filters, floor sweepings, etc., will be collected and placed in double-sealed impermeable, 6 mil plastic bags. These bags will be clearly marked and stored until properly disposed of. Condition of the waste will not allow fiber release, and improper packaging is a violation of the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations.

8.9.1. ASBESTOS DISPOSAL ARRANGEMENT

Disposal involves the isolation of asbestos waste material to prevent fiber release to air or water.

Landfilling is the recommended method because asbestos fibers are virtually immobile in soil.

At PSFB the CE asbestos storage area is located in the fenced storage lot west of Building 681.

The area is properly labeled and demarcated as an asbestos storage area. Asbestos waste will not be stored in the area for periods longer than 30 days. The ART supervisor and AOO will assure that the waste is delivered for disposal as soon as possible.

When the asbestos has been properly containerized and stored in the secure storage area, the AOO will be notified to arrange for transportation and disposal to the Brevard County Disposal Facility.

The landfill must be notified 24 hours prior to disposal. If Brevard County Disposal Facility is unable to accept the asbestos waste. The CEIE Hazardous Waste Program Manager will find the next available landfill for disposal. Procedures for hauling and disposal shall comply with 40 CFR 61 (Subpart B), state, and local standards.

The ART supervisor, transporter, and landfill operator will sign a waste manifest form. A signed copy will be provided to the APO by the AOO. The approved EPA manifest is shown in Appendix Q.

Transportation is defined as all activities involving asbestos waste from the time it leaves the work site until it has been unloaded at the disposal site. Current EPA regulations state there must be no visible emissions to the outside air during transportation. Because of the hazards and liabilities associated with exposure, in-house and contractor specifications will require a transportation and disposal plan.

8.9.2 DISPOSAL OF BUILDINGS CONTAINING ABESTOS

Each facility will be surveyed prior to disposal and written certification will be prepared documenting the presence or absence of ACM. Additionally, whenever a facility is proposed for disposition by sale, an asbestos survey report will accompany the AF Form 300.

8.10. IN-HOUSE EQUIPMENT

The equipment to be used by the ART is identified in Appendix O. This equipment and supply items are recommended for small-scale, short duration projects, which would include fiber release situations, routine maintenance (cleaning), and glove bag removal. Asbestos removal operations will normally be relatively small-scale projects, and if larger projects are undertaken, equipment from the supplemental list in Appendix O will be used. The supplemental list includes those items recommended for large-scale asbestos abatement projects. These items will supplement the equipment/supply list as required depending on the size and scope of the project. The AOO will update their lists as new equipment and supplies become available and ensure that stock control levels and accounting procedures are set up for ordering items through Material Control.

9. HEALTH AND SAFETY

9.1. PROCEDURES

Both the BEE and the ART supervisor must be trained to meet the qualification of a “Competent Person”: (Worker Supervisor Course) as defined in 29 CFR 1926.58. The “Competent Person” designated would have to be the ART supervisor of the work project who remains at the work site full time, because the BEE would not normally have the managerial responsibility/authority over the job site. However, the BEE will be the Air Force authority on regulatory health compliance and OSHA/EPA asbestos requirements. Therefore, the BEE will be designated to:

• Assess health risks and determine appropriate protective equipment, and removal procedures to ensure worker protection and compliance with OSHA/AFOSH asbestos Exposure Standards. In unison with the AOO, the BEE shall review the proposed engineering controls.

• Maintain exposure assessment records for the ART

Occupational Health and Safety Regulations (29 CFR 1910.1001), referenced in Appendix P, provide proper work practices, protection required on the job site, site monitoring requirements, site markings, and medical examinations. No asbestos craftsman will be allowed to perform duties on the job site until they have completed an appropriate medical examination.

29 CFR 1926.58 requires asbestos workers to have an annual medical examination, which could be more frequent if the Aerospace Medicine Council deems it advisable for medical reasons.

Additionally, the asbestos worker will also require a termination medical examination within 30 days or less after the date of leaving the Air Force or Civil Service and for any individual who has been exposed at or above the permissible exposure level (0.1 fiber/cc).

9.2. RESPIRATORY PROTECTION

No individual shall enter an area where respiratory protective equipment is required unless the person has been trained in the selection, use, care, and limitations of the respirator, and the proper respirator has been selected for the task. Whenever respirators are deemed necessary by the ART supervisor or BEE, only equipment with HEPA filter cartridges shall be used. The Mine Safety and Health Administration (MSHA) and NIOSH must certify this equipment. Only parts approved for the specific respirator system are to be used for replacement. Modifications to respirators are not allowed. Only a person specifically trained will perform work on respirators. BEE or their designee will do training and fit testing and a certification card will be issued to the worker.

Commercial training as approved by the BEE may be substituted.

9.3. JOB SITE SAFETY AND REPORTING REQUIREMENTS

The ART Supervisor will be responsible for the job site safety. Wing Safety personnel may perform periodic checks of the job site to determine that the site is adequately blocked off and personnel not involved in the job are detoured away from the site. Additionally, signs will be posted that properly warn personnel that asbestos removal operations are in progress and to keep away from the site. The ART supervisor will also ensure all other normal safety requirements (e.g., hard hats, tools, etc.) are being adhered to at the site. Care must be exercised when applying wetting agents to remove asbestos to prevent potential safety hazards such as slipping and electrical shock.

All injuries and accidents (OSHA reportable and lost-time accidents) shall be reported promptly to the Squadron Safety officer and/or NCO. The ART Supervisor is responsible for preparing the incident report. Occupational injuries and illnesses will be investigated and reported in accordance with AFI 91-204.

9.4. Emergency Response during Abatement

9.4.1. On Site Emergency Equipment

Emergency equipment will be located near the job site in the support zone outside the contaminated work area. A list of on-site emergency equipment is itemized in Appendix M.

9.4.2. Personal Injury Procedures

The job supervisor will contact hospital (ambulance if required) in the event of personnel injury. A list of emergency telephone numbers is found in Appendix M. As much as practical, an ambulance will be used to transport the injured person. The work area will be stabilized to prevent further mishaps or release of asbestos fibers to the environment. Bodily injuries that occur as a result of an accident during the operations at the site shall be handled in the following manner:

• Decontaminate victim, if time and nature of injury permit.

• Administer first aid and/or CPR, using on-site emergency equipment.

• Transport to hospital for medical attention as quickly as possible.

10. CONTRACTING PROCEDURES

10.1. CONTRACT PROGRAMMING

Contract asbestos removal can be identified in several ways. A determination may be made by the AOO in concert with the ART supervisor that identified asbestos must be removed and is beyond the capability of the ART. A renovation or repair project identified by the AOO for contract may necessitate asbestos removal for project completion. In this case, an asbestos removal contractor will be required to remove the asbestos before the primary contractor can start work.

The AOO will advise the CES/CEIE when asbestos removal is required by contract (AF Form 332 submittal or in-house operations evaluation). The CES/CEIE will coordinate asbestos removal activities with the Asbestos Design Engineer. A project with known or suspected locations of asbestos will be thoroughly evaluated by the design engineer for potential ACM exposure. The CES/CEIE will approve the design review to ensure that asbestos abatement has been appropriately addressed.

10.2. CONTRACT PROVISIONS

The Air Force has as its goal the proper handling and disposal of hazardous substances and the health and safety of personnel on base. Therefore, provisions must be made to ensure that asbestos projects executed by contract must be in compliance with applicable laws and regulations and provide, as a minimum, the same degree of personnel safety as in-house projects.

The primary vehicle for ensuring contractor compliance is the statement of work prepared by Asbestos Design Engineer. The statement of work and contract specification for an asbestos project will specify the work to be performed, worker safety requirements, work area control requirements, and disposal requirements. In preparing a statement of work for contract projects, the Air Force must provide adequate notification of hazards associated with exposure to asbestos during the project.

It is important that the statement of work include an accurate description of the scope of asbestos work involved. Underestimating the scope of the asbestos projects will lead to time-consuming and expensive change orders. A complete asbestos survey of the project area must be performed to identify the form, condition, and quantity of asbestos involved; this information must then be included in the statement of work. The statement of work will specifically distinguish between friable asbestos and non-friable asbestos involved in the project.

The specifications will include performance requirements with respect to suspended fibers outside the work area through the duration of the project and residual levels of contamination at the end of the project. Invitations for bid will require contractors to submit plans specifying how they intend to control suspended fibers during the project performance and what cleanup procedure will be used. The evaluation of those plans adequacy will be part of the contractor selection process.

Invitations for bid involving asbestos will specify the contractor qualification requirements.

Contractors selected must be qualified and certified to work on asbestos projects. Firms must be licensed by the state of Florida and show proof that on-site personnel are certified to engage in an asbestos occupation, either as supervisors or workers. It will also require the contractor to make any and all regulatory notifications, prior to start, during and after project completion ensuring the government is copied on all notifications.

10.3. REGULATORY COMPLIANCE RESPONSIBILITIES

Contractors are responsible for compliance with all regulations governing their asbestos projects, including regulations regarding occupational safety and health, control of hazardous emissions, notification requirements, proper labeling and posting, and disposal. The contractor will notify the Florida Department of Environmental Protection before project start in accordance with NESHAP

(40 CFR 61) regulations. This notification will describe procedures to be used to minimize fiber suspension and to ensure that fibers do not escape the controlled area. Contractors shall provide documentation to the government/contracting officer’s representative demonstrating regulatory compliance, including copies of notification forms and disposal receipts.

10.4. MONITORING DURING CONTRACT PERFORMANCE

The licensed asbestos consultant is hired by the government to ensure contractor compliance with contract provisions, including regulatory and health and safety compliance requirements.

Throughout the duration of the project, the consultant will ensure that adequate provisions have been made to control the work area that warning signs are properly posted, that unauthorized entry is prohibited, and that contractor personnel are employing adequate protective measures. The asbestos consultant will perform final visual inspections and sign re-occupancy certification.

The air-sampling contractor under the direction of the consultant must monitor potential impacts from an asbestos project work site on adjacent occupied areas. The air monitor throughout the duration of the project will conduct air sampling. If asbestos fibers are found to be migrating to adjacent areas, the air monitor will prohibit the asbestos abatement contractor from proceeding with the project until adequate measures have been taken to contain the asbestos fibers and protect base personnel from exposure.

10.4.1. Government Inspection Responsibilities

Engineering Flight (CEN) will provide government inspection services. The inspector will perform the following inspection duties.

• Visit the job at least twice daily.

• Assure contractor and monitor are on the job and denote in daily log

• Check for any obvious discrepancies outside the containment and report to CONS and BEE.

• Try to resolve any disputes between contractor and air monitor.

• Coordinate any support or utility issues

• Review final documentation and assure all information is filed, ensuring the CES/CEIE receives copies of all regulatory required documentation, i.e., notifications and manifests

• Based upon the asbestos facility occupancy clearance inspection performed and signed as

“acceptable” by the consultant or his representative, the government inspector will sign Form 1155 that the job is acceptable to the government

10.4.2. Monitoring Responsibilities

Monitoring responsibilities for asbestos abatement projects occur in several phases. These phases include: pre-abatement air monitoring, inspection of abatement area, abatement area air monitoring, exterior abatement air monitoring, differential pressure measurements of the negative pressure enclosure, and personal air monitoring.

10.4.2. (a). Pre-abatement Monitoring The licensed asbestos consultant will review the abatement contractor employee records. Items to be checked are employee records that will include respirator training and fit testing, date of the last medical exam, asbestos abatement training, and experience levels/training of managers and laborers.

Pre-abatement air monitoring is used to establish background levels of fibers in the air. The data obtained will be used to ensure that the background level outside the containment or glove bag is not exceeded during abatement activities.

For background measurements, samples will be taken inside the area to be abated and outside the area of abatement. All pre-abatement samples will be collected prior to the construction of critical barriers or the use of glove bags.

10.4.2. (b). Inspection of Abatement Area The air monitor is on-site continuously and inspects the abatement areas. If an enclosure has been built, the critical barriers will be inspected for integrity, adequate seals, air locks, shower facilities, entrance and exit sign-in rosters, warning signs, decontamination change rooms, clean change rooms, disposal bags/bins for contaminated clothing and tools, etc., and general safety practices such as ground fault interrupters for electrical current, etc. Also, negative air measurements will be made to ensure that the required air changes are made and to ensure that enough machines are in place to provide the required negative pressure. For glove bag procedures, the use of sign-in and sign out procedures, the use of sign-in and sign- out rosters, decontamination procedures, and change areas will be checked. A check will be made to ensure that warning signs are in place at the entrance to the work area.

10.4.2. (c). Air Monitoring At least one sample shall be collected at the contaminated area air lock exit. The air monitor shall determine the other sampling locations. The sample shall be collected as “real-time” samples during the entire abatement process.

A minimum of three air samples shall be collected outside the abatement area in a “clean” location:

• One sample shall be collected at the air lock exit from the…