Attachment 11 - HAFB Asbestos Management and Operating Plan - April 2023.pdf

UNCLASSIFIED

HEADQUARTERS 75TH AIR BASE WINGS HILL

AIR FORCE BASE, UTAH 84056-5206

HILL AIR FORCE BASE

ASBESTOS MANAGEMENT AND OPERATING

PLAN

SHORT TITLE: HILL AFB AMOP-1

April 2023

OPR: 75 ABW CEG/CEIE

HEADQUARTERS 75TH AIR BASE WING

Hill Air Force Base, Utah 84056-5206

April 2023 i

ACRONYMS AND OFFICE SYMBOLS

75 ABW/CC Hill Air Force Base Installation Commander

75 ABW/JA Hill Air Force Base Judge Advocate

75 ABW/PA Hill Air Force Base Office of Public Affairs

75 ABW/PA Base Office of Public Affairs

75 ABW/SEG Hill Air Force Base Occupational Safety Office

75 CEG Civil Engineering Group

75 CEG/CEFT Civil Engineering Fire Training

75 CEG/CEIA Hill Air Force Base Real Property Office

75 CEG/CEIE Hill Air Force Base Environmental Quality Branch

75 CEG/CEN Civil Engineering Division

75 CES/CEOHA Hill Air Force Base Abatement Shop

(formerly the Asbestos and Lead-Based Paint Shop)

75 CES/CEOS Hill Air Force Base Operations Support Flight

75 OMRS/SGXB Hill Air Force Base Bioenvironmental Engineering

75 OMRS/SGXO Hill Air Force Base Occupational Medicine

ACFT Asbestos Cross Functional Team

ACM Asbestos Containing Material

AF Air Force

AFB Air Force Base

AFCEC Air Force Civil Engineer Center

AFMC Air Force Materiel Command

AMOP Asbestos Management and Operating Plan

CFR Code of Federal Regulations

DOEHRS Defense Occupational and Environmental Health Readiness System

EPA Environmental Protection Agency

Hill Air Force Base, Utah 84056-5206

April 2023 ii

UNCLASSIFIED

IAW In Accordance With

IDIQ On-Call Indefinite Delivery Indefinite Quantity

IH Industrial Hygienist

MACC Multiple Award Construction Contract

NESHAP National Emission Standards for Hazardous Air Pollutants

OSHA Occupational Safety and Health Administration

PEL Permissible Exposure Limit

SABER Simplified Acquisition of Base Engineer Requirements

SOP Standard Operating Procedure

UAC Utah Administrative Code

Hill Air Force Base, Utah 84056-5206

April 2023 iii

DEPARTMENT OF THE AIR FORCE

75th CIVIL ENGINEER GROUP (AFMC)

HILL AIR FORCE BASE UTAH

MEMORANDUM FOR ALL HILL AFB PERSONNEL

FROM: 75 CEG

SUBJECT: Letter of Transmittal for Hill Air Force Base Asbestos Management and Operating Plan

1. The long title of this plan is Hill Air Force Base (AFB) Asbestos Management and Operating Plan.

The short title is Hill AFB AMOP-1. This plan provides additional information concerning the management and handling of asbestos-containing material. Send change requests to the 75 CEG/CEIE Environmental Branch.

2. This plan is effective for implementation and action when directed by the 75 ABW/CC or designee.

This Hill AFB AMOP-1 supersedes Hill AFB AMOP-1 dated April 2021. This plan includes Hill AFB control center operations.

3. Elements of Hill AFB AMOP-1 were coordinated with the appropriate agencies and affected organizations as listed in Annex A.

4. 75 CEG/CEIE will conduct an annual review of Hill AFB AMOP-1. Action organizations coordinating this plan must forward review comments, changes and distribution requests to 75

CEG/CEIE.

5. Review and update supporting documents such as checklists when changes are made to Hill AFB AMOP-1. Destroy superseded portions of this plan. Changes must include the date and classification of the plan.

TIMOTHY M. STONE, NH-IV, DAF

Deputy Director

Hill Air Force Base, Utah 84056-5206

April 2023 iv

SECURITY INSTRUCTIONS, CLASSIFICATION GUIDANCE AND RECORD OF CHANGES

1. The long title of this plan is Hill Air Force Base (AFB) Asbestos Management and Operations Plan (AMOP). The short title is Hill AFB AMOP-1.

2. This document is unclassified. Disclosure of information concerning implementation of this plan will only be made to authorized personnel. Refer media requests for information on emergency operations to Public Affairs (75 ABW/PA).

3. Law prohibits the transmission or revelation of information contained herein, in any manner to an unauthorized person. Espionage Laws, Title 18, U.S.C., Sections 793 and 794.

4. Identify annexes with the proper classification authority and declassification or review instructions as required by Department of Defense 5200.1-R/Air Force Policy Directive 31-4.

5. The Installation Commander (75 ABW/CC) has authorized organizations to extract or reproduce those portions of Hill AFB AMOP-1 essential to the development of their supporting documents (i.e., annexes, appendices, operating instructions, or execution checklists).

RECORD OF CHANGES

CHANGE NUMBER CHANGE DATE DATE POSTED POSTED BY

1—Full Staffing Review 31 January 2014 31 January 2014 Emily Lindquist 2—Full Staffing Review 01 February 2015 01 February 2015 Emily Lindquist 3—Pen and Ink Changes December 2016 March 2017 Scott Stoddard 4—Full Staffing Review December 2017 April 2018 Scott Stoddard 5—Full Staffing Review February 2019 April 2019 Erik Dettenmaier 6—Full Staffing Review February 2020 April 2020 Erik Dettenmaier 7—Pen and Ink Changes November 2020 April 2021 Erik Dettenmaier 8—Pen and Ink Changes December 2021 January 2022 Erik Dettenmaier 9—Full Staffing Review December 2022 April 2023 Erik Dettenmaier

Hill Air Force Base, Utah 84056-5206

April 2023 v

TABLE OF CONTENTS

ACRONYMS AND OFFICE SYMBOLS ................................................................................................... i

MEMORANDUM FOR ALL HILL AFB PERSONNEL ......................................................................... iii

FROM: 75 CEG ......................................................................................................................................... iii

SECURITY INSTRUCTIONS, CLASSIFICATION GUIDANCE AND RECORD OF CHANGES ...... iv

RECORD OF CHANGES .......................................................................................................................... iv

TABLE OF CONTENTS ............................................................................................................................ v

HILL AIR FORCE BASE ASBESTOS MANAGEMENT AND OPERATING PLAN

1. OBJECTIVE

2. APPLICABILITY

3. ORGANIZATION STRUCTURE / RESPONSIBILITIES

3.1. INSTALLATION COMMANDER (75 ABW/CC)

3.2. ENVIRONMENTAL BRANCH (75 CEG/CEIE)

3.3 CIVIL ENGINEERING (75 CEG) UTILITY/STRUCTURAL SHOPS

3.4 CIVIL ENGINEERING DIVISION (75 CEG/CEN)

3.5. ABATEMENT SHOP (75 CES/CEOHA)

3.6. BIOENVIRONMENTAL ENGINEERING (75 OMRS/SGXB)

3.7. OCCUPATIONAL MEDICINE (75 OMRS/SGXO)

3.8. JUDGE ADVOCATE (75 ABW/JA)

3.9. OCCUPATIONAL SAFETY OFFICE (75 ABW/SEG)

3.10. OFFICE OF PUBLIC AFFAIRS (75 ABW/PA)

3.11. REAL PROPERTY OFFICE (75 CEG/CEIA)

3.12. CONTRACTING OFFICE (AFSC/PZ)

3.13. BUILDING MANAGERS, UTILITIES SHOP SUPERVISORS, AND CUSTODIAL

SUPERVISORS

3.14 GENERAL CONTRACTORS

3.15 UTILITY SYSTEM OWNERS

3.16. ASBESTOS CROSS FUNCTIONAL TEAM (ACFT)

4. ASBESTOS SURVEILLANCE AND CONTROL MEASURES IN FACILITIES

4.1 INFORMING FACILITY OCCUPANTS ABOUT ASBESTOS RISKS IN THE WORK

AREA

4.2 REPORTING DAMAGED ACM

4.3. ASBESTOS SAMPLING

5. ASBESTOS WORK PRACTICES FOR CONSTRUCTION AND MAINTENANCE PROJECTS

5.1 PROCESS OVERVIEW

5.2 ASBESTOS INSPECTIONS

5.3 WORKER PROTECTION PROGRAM / PERSONAL PROTECTIVE EQUIPMENT

5.4 ABATEMENT CONTRACTING

5.5 ROUTINE WORK TASKS

Hill Air Force Base, Utah 84056-5206

April 2023 vi

UNCLASSIFIED

5.6 IN-HOUSE PERFORMANCE OF ASBESTOS WORK

5.7 WORK ORDER, IN-HOUSE:

5.8 WORK ORDER, CONTRACTOR (75 CEG/CEN):

5.9 ENVIRONMENTAL OVERSIGHT OF ASBESTOS WORK

5.10 NOTIFICATIONS

5.11 UTILITY PRIVATIZATION

6. PERSONNEL TRAINING

6.1. ASBESTOS AWARENESS TRAINING

6.2 FACILITY MANAGERS TRAINING

6.3. BUILDING MAINTENANCE AND CUSTODIAL WORKER TRAINING

6.4. ASBESTOS INSPECTOR TRAINING

6.5. CONTRACTOR / SUPERVISOR / ASBESTOS WORKER TRAINING

6.6. ASBESTOS PROJECT DESIGNER TRAINING

7. RECORDKEEPING

7.1. EMPLOYEE-SPECIFIC RECORDS

7.2. PROJECT-SPECIFIC RECORDS

TABLE 1: ASBESTOS TRAINING REQUIREMENTS

TABLE 2: SUMMARY OF PROJECT DOCUMENTATION

TABLE 3: PROJECT COMPLETION REPORT DOCUMENTATION

TABLE 3: PROJECT COMPLETION REPORT DOCUMENTATION, CONTINUED

TABLE 3: PROJECT COMPLETION REPORT DOCUMENTATION, CONTINUED

TABLE 3: PROJECT COMPLETION REPORT DOCUMENTATION, CONTINUED

APPENDIX A: ASBESTOS / LEAD BASED PAINT (LBP) ABATEMENT CONTRACTOR

QUALIFICATION REQUIREMENTS

REFERENCES

ANNEX A ............................................................................................................................................... A-1

Hill Air Force Base, Utah 84056-5206

HILL AIR FORCE BASE ASBESTOS MANAGEMENT AND OPERATING PLAN

1. OBJECTIVE

The objective of this Asbestos Management and Operating Plan (AMOP) is to track the status and condition of all asbestos-containing material (ACM) on Hill Air Force Base (AFB) properties by directing how Hill AFB will manage and conduct asbestos-related projects. This plan assigns responsibilities and explains the requirements for all work relating to asbestos under Occupational Safety & Health Administration (OSHA), Environmental Protection Agency (EPA), State of Utah Division of Air Quality (UDAQ), and United States Air Force (AF) regulations.

2. APPLICABILITY

This plan applies to maintenance, repair, and renovation work performed at Hill AFB with the potential to disturb asbestos-containing building materials. This plan does not apply to any Comprehensive Environmental Response, Compensation, and Liability Act cleanup projects whereby asbestos has or may be identified and included in cleanup efforts.

3. ORGANIZATION STRUCTURE / RESPONSIBILITIES

The Environmental Branch (75 CEG/CEIE), the Abatement Shop (75 CES/CEOHA) (formerly the Asbestos and Lead-Based Paint Shop), and Bioenvironmental Engineering (75 OMRS/SGXB) coordinate Hill AFB asbestos activities. A 75 CEG/CEIE-appointed asbestos program manager has the responsibility for overall management of the AMOP per the AF’s Environmental Management System.

75 CEG/CEIE will maintain required communication with 75 CES/CEOHA and 75 OMRS/SGXB points of contact for asbestos-related activities, as well as with the other organizations listed below.

The responsibilities of these organizations are detailed below.

3.1. INSTALLATION COMMANDER (75 ABW/CC)

The Hill AFB Installation Commander (75 ABW/CC) has the ultimate responsibility for compliance with all applicable asbestos regulations.

3.2. ENVIRONMENTAL BRANCH (75 CEG/CEIE)

The Hill AFB Environmental Branch (75 CEG/CEIE) provides environmental compliance guidance for the base asbestos program. 75 CEG/CEIE will:

- Oversee the Hill AFB Asbestos Program.

- Ensure that Hill AFB stays in compliance with federal, state, and AF rules and regulations.

- Accomplish all negotiations with federal and state regulatory authorities.

- Notify the Air Force Civil Engineer Center (AFCEC) within 24 hours of any asbestos incidents, citations, notices of violation, or litigation using the Enforcement Actions, Spills and Inspections database.

- Notify the base chain of command of any asbestos-related compliance issues.

- Ensure that the Hill AFB Contracting Office (PZ) requires asbestos awareness training and

AMOP training for custodial service contracts.

- Maintain, update and implement the AMOP as needed.

Hill Air Force Base, Utah 84056-5206

- Coordinate with 75 CES/CEOHA on contractor qualification requirements (Appendix A) in accordance with (IAW) Section 5.4.

- Review training documentation and ongoing projects IAW Section 5.9.

- Chair the Hill AFB Asbestos Cross Functional Team (ACFT).

3.3 CIVIL ENGINEERING (75 CEG) UTILITY/STRUCTURAL SHOPS

The 75 CEG Utility/Structural Shops fielding work requests will:

- Adhere to the requirements of the Hill AFB Worker Protection Program (Section 5.3).

- Use the on-call asbestos removal contract through 75 CES/CEOHA whenever possible (Section

5.4).

- Ensure demolition/renovation contractors are certified to perform asbestos work (Section 5.4).

- Obtain the proper level of asbestos training prior to performing site visits for both routine work tasks and Work Order projects (Sections 5.5, 5.7).

- Determine whether routine work tasks will potentially disturb ACM (Section 5.5).

- Notify 75 CES/CEOHA if ACM is potentially to be disturbed. (Sections 5.5, 5.7).

- Ensure an AF Form e332 or 299 has been submitted for each renovation/demolition project to be completed via Work Order IAW the requirements outlined in Section 5.7.

- Document the decision to have 75 CES/CEOHA perform the site survey and ACM removal estimate for in-house asbestos work completed via Work Order in a memo to the project file (Section 5.7).

- Maintain asbestos training and employee medical surveillance records supplied by 75 CES/CEOHA (Section 7.1).

3.4 CIVIL ENGINEERING DIVISION (75 CEG/CEN)

The Civil Engineering Division (75 CEG/CEN) supervisors and project managers responsible for construction and maintenance projects will:

- Arrange for outside prime contractor to perform asbestos removal (Section 5.1).

- Obtain asbestos inspection reports and abatement estimates from 75 CES/CEOHA (Section 5.2).

- Adhere to the requirements of the Hill AFB Worker Protection Program (Section 5.3).

- Use the on-call asbestos removal contract through 75 CES/CEOHA whenever possible (Section

5.4).

- Ensure demolition/renovation contractors are appropriately certified to perform the specified scope of asbestos work (Sections 5.4 and Appendix A).

- Request 75 CES/CEOHA to perform the site survey and estimate for ACM removal completed via Work Order and document the decision in a memo to the project file (Section 5.8).

- Schedule with 75 CES/CEOHA for both in-house and on-call contractor asbestos work completed via Work Order (Section 5.8).

- Adhere to the 75 CES/CEOHA Asbestos Survey/Air Sampling and Standard Operating

Procedure for 75 CEG/CEN Work Orders requiring asbestos sampling (Section 5.8).

- Ensure asbestos inspections are accomplished and posted on site at all times (Section 5.8).

- Document contractor ACM work completed via Work Order IAW Section 7 and Tables 2 and 3, (Section 5.8).

- Ensure 75 CES/CEOHA reviews the contractor’s final industrial hygiene report documenting site clearance is complete before paying for ACM removal (Section 5.8).

- If 75 CES/CEOHA confirms the likely disturbance of ACM for the project, ensure removal contracts include standard asbestos removal language and that the contractor provides removal

Hill Air Force Base, Utah 84056-5206 plans, state notifications, and work commencement 24-hour advance notice to 75 CES/CEOHA (Section 5.8).

- Ensure contractors comply with 75 CES/CEOHA Pre-Qualification Requirements (Appendix A).

- SABER Supervisors and Project Managers Only:

o Request a formal evaluation from 75 CES/CEOHA if the Asbestos Inspection Report does not adequately address areas to be impacted by the project and whether ACM will be potentially disturbed (Section 5.8).

o Coordinate with 75 CES/CEOHA for pre- and post- abatement visual inspections (Section 5.8).

o Obtain the proper level of training IAW Section 6 and Table 1.

3.5. ABATEMENT SHOP (75 CES/CEOHA)

The Hill AFB Abatement Shop (75 CES/CEOHA) was formed under the Civil Engineering Group (CEG) to perform inspections, develop project designs, oversee asbestos removal projects and contracts, and perform in-house asbestos removal and emergency tasks.

75 CES/CEOHA has overall responsibility for implementation of asbestos-related activities performed on Hill AFB. 75 CES/CEOHA will:

- Assist building, custodial, and shop supervisors to compliantly manage and maintain ACM (Section 4).

- Ensure periodic monitoring of friable/damaged asbestos is performed (Section 4).

- Ensure that building managers are notified of all impending asbestos-related demolition or renovation work upon submission of notification to the State of Utah (Section 4).

- Perform all sampling and site inspections involving disturbance of potential ACM (Sections 4.2, 4.3, and 5.1).

- Provide all relevant current sampling information as required to 75 CEG/CEIA (Section 4.3).

- Maintain data on facilities containing ACM on the network drive and update 75 CEG/CEIE as needed (Sections 4.3, 7.2).

- Ensure that inspection and sampling of presumed ACM is performed (Section 4.3).

- Coordinate on all construction and maintenance projects requiring asbestos removal (Section

5.1).

- Ensure that all in-house demolition/renovation projects comply with all federal, state, local, and

AF asbestos regulations IAW Section 5.

- Ensure that all projects are coordinated with 75 CEG for identification of all presumed ACM in buildings prior to being funded and prior to commencement of a project (Section 5.1).

- Perform asbestos work in-house or arrange for IDIQ contractor removal (Section 5.1).

- Provide inspection reports and abatement estimates for renovation or demolition projects

(Section 5.2).

- Maintain the Hill AFB Asbestos Inspection Report (Sections 5.2, 7.2).

- Adhere to the requirements of the Hill AFB Worker Protection Program while performing Class

I, II, III, and/or IV asbestos work (Section 5.3).

- Oversee contracted inspectors / abatement contractors (Section 5.4).

- Ensure contractors meet the qualification requirements prior to performing any asbestos abatement activities (Sections 5.4, 5.8).

- Ensure that contractors comply with all federal, state, local and AF asbestos regulations and all additional requirements in the AMOP (Sections 5.4, 5.8).

Hill Air Force Base, Utah 84056-5206

- Perform or contract out routine asbestos work tasks that will potentially disturb ACM upon notification from the 75 CEG Utility/Structural Shop (Section 5.5).

- Perform and document in-house asbestos work IAW Section 5.6.

- Update the Hill AFB Asbestos Survey based on the task report, perform oversight and clearance sampling, and document in-house asbestos work completed via Work Order IAW Section 7 and Tables 2 and 3 (Section 5.7).

- Perform site surveys and estimates for ACM removal for both in-house asbestos work completed via Work Order, and Work Orders completed by contractor, at the request of the 75 CEG Utility/Structural Shop, or 75 CEG/CEN respectively (Sections 5.7, 5.8).

- Ensure that the requirements of asbestos removal contracts are completed and documented in the project file (Section 7.2).

- Review and approve all asbestos work plans IAW Sections 5.5, 5.6, 5.7, 5.8, and Tables 2 and 3.

- Review the final contractor’s industrial hygiene report documenting site clearance provided by

75 CEG/CEN (Section 5.8, and Table 2).

- Perform pre- and post-abatement visual inspections at the request of the SABER project manager (Section 5.8).

- Ensure all required notifications are made to the State of Utah for all renovation and demolition projects and maintain them IAW Section 5.10, and Table 2.

- Coordinate with 75 ABW/SEG and 75 OMRS/SGXB annually on updates to the Hill AFB

Asbestos Awareness Training (Section 6.1).

- Obtain the proper level of training IAW Section 6 and Table 1.

- Ensure project-specific hires and all other abatement contractors have the required level of asbestos training and medical surveillance documentation IAW Sections 6 and 7.1, and Table 3.

- Maintain project-specific records including building surveys, inspection reports, state notifications, and monitoring records IAW Section 7.2.

- Manage asbestos waste manifests IAW Section 7.3 and Table 3.

- Participate in the Hill AFB ACFT.

3.6. BIOENVIRONMENTAL ENGINEERING (75 OMRS/SGXB)

Hill AFB Bioenvironmental Engineering (75 OMRS/SGXB) works in conjunction with 75 CES/CEOHA to ensure compliance with OSHA-related asbestos regulations and guidance to include 29 Code of Federal Regulations (CFR) 1910.1001 and 29 CFR 1926.1101. 75 OMRS/SGXB will:

- Assume the role of the site industrial hygienist and perform oversight review for 75 CES/CEOHA projects involving ACM or presumed ACM.

- Work with 75CEG/CEOHA to determine if recommended actions are necessary (e.g., frequent monitoring, remove personnel from area, temporary controls, etc.).

- Respond to employee claims of possible asbestos exposure and perform health risk appraisals for abatements IAW Section 4.1.

- Adhere to the requirements of the Hill AFB Worker Protection Program (Section 5.3).

- Review all project control forms and final design drawings supplied by 75 CEG/CEN for contractor completion of Work Order projects (Section 5.8).

- Coordinate with 75 ABW/SEG and 75 CES/CEOHA annually on updates to the Hill AFB

Asbestos Awareness Training (Section 6.1).

- Maintain personnel exposure records IAW Section 7.1.

- Participate in the Hill AFB ACFT.

Hill Air Force Base, Utah 84056-5206

3.7. OCCUPATIONAL MEDICINE (75 OMRS/SGXO)

Hill AFB Occupational Medicine (75 OMRS/SGXO) is responsible for maintaining employee-specific medical records pertinent to the Hill AFB Asbestos Program and ensuring that personnel surveys are continued IAW Section 7.1. 75 OMRS/SGXO will participate in the Hill AFB ACFT.

3.8. JUDGE ADVOCATE (75 ABW/JA)

The Hill AFB Judge Advocate (75 ABW/JA) is responsible for providing advice and guidance on all legal aspects of asbestos program management, reviewing requests for information, interpreting laws and regulations and apprising 75 CEG/CEIE, 75 CEG, and 75 OMRS/SGXB of existing and proposed regulations. 75 ABW/JA will participate in the Hill AFB ACFT.

3.9. OCCUPATIONAL SAFETY OFFICE (75 ABW/SEG)

The Hill AFB Occupational Safety Office (75 ABW/SEG) is responsible for reviewing work practice information on project activities, safety precautions/procedures for military and civilian government employees, and validating policies comply with both Federal and National Concensous standards. 75 ABW/SEG will participate in the Hill AFB ACFT.

3.10. OFFICE OF PUBLIC AFFAIRS (75 ABW/PA)

The Hill AFB Office of Public Affairs (75 ABW/PA) will provide advice and guidance on communicating information about asbestos management and abatement activities to AF employees and the public. 75 ABW/PA will participate in the Hill AFB ACFT.

3.11. REAL PROPERTY OFFICE (75 CEG/CEIA)

The Hill AFB Real Property Office (75 CEG/CEIA) is responsible for maintaining asbestos sampling information provided by 75 CES/CEOHA IAW Section 4.3 and will assume all facilities constructed prior to 2007 contain asbestos and will update and maintain the Accountable Property System of Record accordingly. 75 CEG/CEIA will participate in the Hill AFB ACFT.

3.12. CONTRACTING OFFICE (AFSC/PZ)

The Hill AFB Contracting Office (PZ) will coordinate with 75 CEG/CEIE to require asbestos awareness training and AMOP training for custodial service contracts and will participate in the Hill AFB ACFT.

3.13. BUILDING MANAGERS, UTILITIES SHOP SUPERVISORS, AND CUSTODIAL

SUPERVISORS

Building Managers, Utilities Shop Supervisors, and Custodial Supervisors play a crucial role in ensuring that asbestos is properly managed and maintained within their areas. They will:

- Coordinate with 75 CES/CEOHA on responsibilities under 29 CFR 1926.1101 (Section 4).

- Notify building occupants of pending renovation/demolition projects (Section 4).

- Maintain and offer the latest asbestos building survey (Section 4.1).

- Inform building occupants of the presence of ACM (Section 4.1).

- Properly label areas of known or potential ACM (Section 4.1).

- Provide training to potentially exposed employees and maintain training certificates/files

(Section 4.1).

- Report damaged ACM to 75 CES/CEOHA and conduct visual inspections (Section 4.3).

- Abide by the Hill AFB Asbestos Sampling Protocol outlined (Section 4.3); Do NOT perform any OSHA Class I, II, and/or III asbestos work (to include sampling and

Hill Air Force Base, Utah 84056-5206 inspections)!

- Adhere to the requirements of the Hill AFB Worker Protection Program (Section 5.3).

- Obtain the proper level of training IAW Section 6 and Table 1.

3.14 GENERAL CONTRACTORS

General contractors working on base that have discovered suspected asbestos will stop work immediately and contact 75 CES/CEOHA to analyze and take samples if necessary IAW Section 5.4.

3.15 UTILITY SYSTEM OWNERS

Utility system workers that have discovered suspected asbestos will stop work immediately and contact 75 CES/CEOHA to analyze and take samples if necessary IAW Section 5.11.

3.16. ASBESTOS CROSS FUNCTIONAL TEAM (ACFT)

The purpose of the Asbestos Cross Functional Team (ACFT) is to provide a recurring venue to facilitate communication amongst team members on issues related to asbestos management at Hill AFB. The ACFT meets on an as-needed basis during periods of high activity.

Hill Air Force Base, Utah 84056-5206

4. ASBESTOS SURVEILLANCE AND CONTROL MEASURES IN FACILITIES

This section addresses asbestos monitoring and control measures to be taken for facilities on Hill AFB.

Housekeeping of ACM or potential ACM must be performed according to authorized procedures. 75 CES/CEOHA will provide oversight to all building supervisors, custodial supervisors, and utilities shop supervisors to support compliance with their responsibilities under 29 CFR 1926.1101.

75 CES/CEOHA will provide oversight to ensure that periodic monitoring is accomplished for areas identified as having friable or damaged asbestos. The frequency of routine inspections is based on the location, condition and accessibility of the friable asbestos-containing building material.

Once notified of programmed asbestos-related demolition or renovation, the building manager is responsible for giving proper notification and instructions to the building occupants and appropriate personnel, and ensuring that proper signs and labels are posted (per 29 CFR 1910.1001).

4.1 INFORMING FACILITY OCCUPANTS ABOUT ASBESTOS RISKS IN THE WORK

AREA

Building owners and supervisors of building maintenance personnel to include all utilities shops and custodial services, must maintain availability of the most current copy of the asbestos survey for their buildings. Only the portions of the survey applicable to the individual building(s) in question need to be maintained. See Section 7.2, “Project-Specific Records” for recordkeeping requirements associated with building surveys.

In order to limit the potential for employee exposure to asbestos in facilities, building managers are responsible for ensuring supervisors of employees working or residing within the building are informed of the presence of ACM. This should be accomplished via signage, training, cordons, etc. Building owners and supervisors of building maintenance personnel, to include all utilities shops and custodial services, must properly label areas of known or potential ACM.

Supervisors must also provide training to potentially-exposed employees and maintain training certification(s)/file(s).

Hill AFB employee claims of possible asbestos exposure will be directed to 75 OMRS/SGXB. 75 OMRS/SGXB personnel are the only staff qualified and trained to perform sampling associated with government employee health risk assessments.

4.2 REPORTING DAMAGED ACM

Building owners and supervisors of building maintenance personnel to include all utilities shops and custodial services, must also ensure that custodial and maintenance personnel report any damaged ACM identified during or caused by their work to their supervisor, who will report it to 75 CES/CEOHA.

Such personnel should know the location of all ACM in the building (based on the latest copy of the building survey) and should conduct a visual inspection whenever they are in an area. 75 CES/CEOHA will perform site ACM inspections involving sampling or disturbance of potential ACM.

4.3. ASBESTOS SAMPLING

Materials sampling will be performed by 75 CES/CEOHA in accordance with (IAW) the Hill AFB Asbestos Sampling Standard Operating Procedure (SOP) maintained by 75 CES/CEOHA. 75 CES/CEOHA personnel are the only Hill AFB (in-house) workers trained and certified to perform 29 CFR 1926.1101 OSHA Class I, II or III asbestos work. This includes sampling of presumed ACM

Hill Air Force Base, Utah 84056-5206 building materials and inspection tasks, with the exceptions included in Section 5, “Asbestos Work Practices for Construction and Maintenance Projects.” No 75 CEG Utility/Structural Shop, 309th Maintenance Shop, or building custodial personnel will perform Class I, II or III asbestos-related work, including collecting building samples for asbestos inspection or identification purposes.

75 CES/CEOHA will provide all relevant current sampling information as required to 75 CEG/CEIA, and include all information currently contained for each sample test within the current survey, to include a full description of the material sampled. 75 CES/CEOHA will provide to 75 CEG/CEIA and other customers any asbestos sample information from the sampling database regarding ACM. This information will include sample results and specific verbal descriptions of all sample locations.

Hill Air Force Base, Utah 84056-5206

5. ASBESTOS WORK PRACTICES FOR CONSTRUCTION AND MAINTENANCE

PROJECTS

This section defines the responsibilities within Hill AFB for the identification of construction and maintenance projects which will involve asbestos removal and establishes responsibilities and documentation associated with the proper completion of asbestos removal. A brief overview of the project initiation, planning, and execution process will identify the Hill AFB organizations with responsibilities under this section.

5.1 PROCESS OVERVIEW

Each construction and maintenance project is generated by one of three actions: 1) a routine CEG Work Task, 2) an emergency phone call to 75 CES/CEOHA, or 3) via a formal Work Order (i.e., Work Orders and AF Forms 332, 299, or DD1391 [for large projects]).

When a project requires asbestos removal, it will be coordinated through 75 CES/CEOHA whether the work will be accomplished through the asbestos On-call Indefinite Delivery Indefinite Quantity (IDIQ) contract, by a subcontractor, by the in-house 75 CES/CEOHA Abatement Team, or managed by 75

CES/CEOS.

For routine Work Tasks, Customer Service will pass the request to a 75 CEG Utility/Structural Shop who determines whether a Work Order is required or perform the work themselves. If emergency response is required, 75 CES/CEOHA either performs the work themselves or contracts the work.

Work Orders go through the coordination cycle, and are reviewed by the 75 CEG Work Order Review Board. 75 CES/CEOHA will perform site ACM inspections involving sampling or disturbance of potential ACM. If the Work Order is complete and funded, one of the following paths will be applied:

- In-house performance—75 CES/CEOHA will be the only shop that performs the work using Hill AFB personnel. Asbestos removal will be performed under supervision of 75 CES/CEOHA. All asbestos repairs by 75 CES/CEOHA will be conducted IAW their locally prepared instructions that are based on current Federal, State and local rules and guidance.

- Performance by IDIQ Contractor—The 75 CES/CEOHA IDIQ Contract Manager assigned to the project will arrange for the on-call contractor to perform the asbestos removal.

- Management by 75 CES/CEOS—Note this path is generally reserved for single, scope-specific projects (e.g., carpet, paint, roofing, paving, etc.).

- Performance by contractor—The Hill AFB Civil Engineering Division (75 CEG/CEN) project manager assigned to the project will arrange for an outside prime contractor (selected through a bid process) to perform the work. The subcontractor may only perform asbestos work if they are licensed and certified with the State of Utah as an asbestos contractor and prequalified by 75 CES/CEOHA (Appendix A). The contractor must be on the approved asbestos contractor list maintained by 75 CES/CEOHA.

Hill Air Force Base, Utah 84056-5206

Figure 1. Overview of Construction and Maintenance Project Process

5.2 ASBESTOS INSPECTIONS

Renovation or demolition of ACM or potential ACM will be performed only after an asbestos inspection has been accomplished as required by EPA and OSHA regulations and IAW proper work practices and procedures. Any project that may have a need for asbestos removal or a disturbance to ACM must have the cost of said removal or disturbance estimated in the project. If asbestos removal is necessary, funding for the asbestos project comes directly from the project requiring asbestos removal. 75 CES/CEOHA will provide all inspection reports and abatement estimates. Individual organizations will maintain certifications, as appropriate, as required under Utah Administrative Code (UAC) R307-801 with respect to the organization’s requirements under this plan. 75 CES/CEOHA will provide 75 CEG/CEN and SABER project managers with a cost estimate for asbestos removal in support of any renovation or demolition projects.

5.3 WORKER PROTECTION PROGRAM / PERSONAL PROTECTIVE EQUIPMENT

For both asbestos workers and non-asbestos workers potentially exposed to asbestos near or above the Permissible Exposure Limits (PELs) or Excursion Limit, the Hill AFB Worker Protection Program will include respiratory program requirements, protective clothing requirements, and monitoring

Hill Air Force Base, Utah 84056-5206 requirements. Protective clothing will be provided by Hill AFB and worn, removed, stored, cleaned, and replaced for employees exposed to asbestos near the PEL or Excursion Limit. Respirators will be provided by Hill AFB and selected to properly fit employees exposed to asbestos near the PEL or Excursion Limit according to the Hill AFB Respirator Program. Workers engaged in Class I, II, III, or IV asbestos work, shall meet respirator protection requirements.

5.4 ABATEMENT CONTRACTING

75 CEG will use the Hill AFB Asbestos IDIQ Contract through 75 CES/CEOHA whenever possible so that 75 CES/CEOHA can manage asbestos removal on Hill AFB and maintain proper control.

75 CES/CEOHA and 75 CEG/CEIE will review and approve the Hill AFB prequalification package (Appendix A) required for all asbestos removal contractors prior to those contractors performing asbestos-related work on Hill AFB properties. 75 CEG will ensure that all contractors performing demolition and/or renovation are state-certified to perform asbestos work where ACM or potential ACM is to be disturbed. Asbestos contractors on base will follow the asbestos guidelines and regulations listed in Table 3, “Project Completion Report Documentation.” 75 CES/CEOHA will maintain abatement contractor qualification requirements and review/verify that submitted documentation meets qualification requirements prior to the contractor performing abatement work on base. 75 CES/CEOHA will provide oversight of any contracted inspectors and/or abatement contractors.

General contractors working on base that have discovered suspected asbestos will stop work immediately and contact 75 CES/CEOHA to analyze and take samples if necessary.

5.5 ROUTINE WORK TASKS

Routine Work Tasks are typically reserved for simple construction and maintenance activities.

However, all work requests must be properly evaluated for the potential to disturb asbestos. The 75 CEG Utility/Structural Shop receiving the Work Task from Customer Service will ensure that:

- The worker assigned to visit the site and estimate the level of effort required will have received Asbestos Awareness Training IAW Section 6, “Personnel Training,” of this

AMOP.

- If the request will be met via routine maintenance (i.e., no Work Order), the worker visiting the site will decide whether the requested job will potentially disturb ACMs.

- If ACM is potentially to be disturbed, the 75 CEG Utility/Structural Shop will notify 75 CES/CEOHA to perform or contract out the asbestos removal work. For routine maintenance, no documentation is required for this decision and transferal.

5.6 IN-HOUSE PERFORMANCE OF ASBESTOS WORK

When 75 CES/CEOHA is asked to perform work that potentially involves disturbance of ACM, the worker assigned to the task will:

- Perform work assuming that material is ACM.

- Perform work using the procedures in Sections 4 and 5 of this plan.

- Document work completion per Section 7, “Recordkeeping.” Table 2, “Summary of

Project Documentation,” Table 3, “Project Completion Report Documentation” of this plan.

Note: 75 CES/CEOHA will follow the same practices for emergency calls involving work that potentially involves disturbance of ACM.

Hill Air Force Base, Utah 84056-5206

5.7 WORK ORDER, IN-HOUSE:

More complex construction and maintenance activities will be performed via Work Order. The 75 CEG Utility/Structural Shop receiving the Work Order form will ensure that:

- All renovation/demolition projects have submitted an AF Form e332 or 299 which will be routed for approval through 75 CEG/CEIE, 75 OMRS/SGXB, Civil Engineering Fire Training (75 CEG/CEFT), 75 ABW/SEG, 75 CES/CEOHA, 75 CEG, and Customer Service.

The required asbestos inspection must be completed prior to any renovation, construction, or demolition project being started. The Work Order should have a detailed outline of the scope of work for this specific project.

- The worker assigned to visit the site and plan the effort required will have received Asbestos Awareness Training IAW Section 6, “Personnel Training,” of this AMOP.

75 CES/CEOHA should only execute tasks from a Work Order following notification from the 75 CEG Utility/Structural Shop that ACM is present and removal is required. Task performance can be with in-house personnel only, or with the addition of project hires. For ACM removal jobs performed by in-house personnel only, 75 CES/CEOHA will:

- Perform oversight and clearance sampling.

- Perform a site survey and estimates requirement for ACM removal as part of subject project at the request of the 75 CEG Utility/Structural Shop. This decision is documented in a memo to a Work Order file in Customer Service.

- Document that the training and medical monitoring of project hires complies with "worker" categories of this AMOP.

- Update the Hill AFB Asbestos Survey based on the task report (also prepared by 75

CES/CEOHA).

- Perform work using procedures in Section 4, “Asbestos Control Measures.”

- Document work IAW Table 2, “Summary of Project Documentation,” Table 3, “Project Completion Report Documentation,” and Section 7, “Recordkeeping.”

5.8 WORK ORDER, CONTRACTOR (75 CEG/CEN):

At the request of 75 CEG/CEN, 75 CES/CEOHA will perform the site survey and estimate the requirement for ACM removal as part of subject project. This decision is documented in a memo to a project file in 75 CEG.

When 75 CEG/CEN has a project requiring removal, they will coordinate through 75 CES/CEOHA for scheduling of an asbestos IDIQ contractor or 75 CES/CEOHA if it stays in-house. If sampling is performed on a CEN project, the work must be reviewed/monitored, and/or conducted according to the Hill AFB 75 CES/CEOHA Asbestos Survey/Air Sampling Protocol and SOP. 75 CEG/CEN project managers assigned to a project should have training per Section 6, “Training” of this AMOP.

The 75 CEG/CEN project managers will:

- Ensure that all renovation and demolition projects have an asbestos inspection accomplished and that the contractor/workers have that inspection “posted” on site at all times. This check will be documented on the project control form. A copy of this form will accompany the copy of the final design drawing provided to 75 OMRS/SGXB for review.

- Document work per Table 2, “Summary of Project Documentation,” Table 3, Hill Air Force Base, Utah 84056-5206

“Project Completion Report Documentation,” and Section 7, “Recordkeeping.”

- Ensure that the 75 CES/CEOHA review of the final contractor's industrial hygiene report

(documenting site clearance) is completed prior to releasing full payment for the removal.

If 75 CES/CEOHA confirms the likely disturbance of ACM by the project, the 75 CEG/CEN project manager will ensure:

- The contract with the removal contractor (or with the removal contractor as a subcontractor to prime contractor) includes standard asbestos removal language as per 29 CFR 1926.1101 and UAC R307-801 and review the statements of qualifications of the abatement contractor. The prequalification packages (Appendix A) are currently being reviewed on an annual basis (i.e., within one year) by 75 CES/CEOHA.

- The contractor (or removal subcontractor) performs work per this contract language. Of particular importance are the requirements for the contractor to: 1) copy 75 CES/CEOHA with the asbestos removal plan prior to work initiation, 2) copy 75 CES/CEOHA when the state notification is submitted, 3) notify 75 CES/CEOHA within 24 hours of work commencement, and 4) copy 75 CES/CEOHA with the industrial hygiene report for site clearance.

Additionally, the SABER project manager will:

- Check the Hill AFB Asbestos Inspection Report to estimate whether it adequately assesses the area(s) to be impacted by the project and if so, estimate whether ACM is potentially disturbed by the project. If the presence of ACM is uncertain or un-indicated by the survey, the supervisor will notify 75 CES/CEOHA and request a formal assessment.

- Coordinate with 75 CES/CEOHA for pre- and post- abatement visual inspections.

5.9 ENVIRONMENTAL OVERSIGHT OF ASBESTOS WORK

For asbestos removal construction and maintenance projects, 75 CEG/CEIE will:

- Perform an annual, announced review of the documentation required in Table 1, “Asbestos Training Requirements.” A written copy of this review will be provided to 75 OMRS/SGXB, CEFT, 75 ABW/SEG, 75 CES/CEOHA, 75 CEG, and Customer Service.

Perform a semi-annual, unannounced review of ongoing projects supervised by 75 CES/CEOHA, 75 CEG/CEN. The review will be for compliance with this AMOP. File copies of the above reviews in 75 CEG/CEIE.

5.10 NOTIFICATIONS

75 CES/CEOHA is responsible for ensuring all state, 75 CEG/CEIE and 75 OMRS/SGXB notifications are made for all in-house, SABER, on-call contracting, prime contracting and sub-to-prime contracting projects. Entities performing asbestos work on behalf of Hill AFB must notify the State of Utah prior to performing such work. Copies of all notifications to the State of Utah will be made available to 75 CEG/CEIE and 75 OMRS/SGXB upon request; but will otherwise be maintained by 75 CES/CEOHA for both in-house work and work performed on the IDIQ Contract. Refer to Section 7, “Recordkeeping,” for more information on the filing protocol for State notifications.

5.11 UTILITY PRIVATIZATION

Hill AFB conveyed ownership of potable water, sanitary sewer and electrical systems to private companies. The system owners are responsible for maintaining these systems IAW this AMOP. If

Hill Air Force Base, Utah 84056-5206

ACM is identified or suspected during maintenance activities, the system owners will not disturb it until contacting 75 CES/CEOHA for further guidance.

5.11.1. Water

The water and wastewater utility system owner is responsible for maintenance associated with culinary water piping infrastructure and equipment through to the point of building demarcation, and fire suppression systems through to the point of the post indicator valve. The system owner is also responsible for water systems testing, sampling, float-testing of fire hydrants, sewer lines, sewage stations, septic/holding tanks, and emergency generators for water sources. Sites covered under this contract include Hill AFB and the following geographically-separated units: Little Mountain, Pinedale, Utah Test and Training Range (excluding sewer), and Wendover Field (excluding sewer). Military family housing is excluded from this and the electrical contracts. Possible locations for asbestos containing materials include well houses, booster pump houses and underground piping.

5.11.2. Electrical

The electrical utility system owner is responsible for maintenance associated with high voltage electrical systems through the point of the secondary cutoff transformer (high to low). The same sites listed above, under the water contract privatization, apply to the electrical privatization. Possible sources of ACM include shielding, cables and conduits.

Hill Air Force Base, Utah 84056-5206

6. PERSONNEL TRAINING

The following categories of training are required as outlined in Table 1, “Asbestos Training Requirements.”

6.1. ASBESTOS AWARENESS TRAINING

Per 29 CFR 1926.1101, asbestos awareness training is required for building managers and their alternates who oversee projects involving their buildings, project managers, engineers, architects, shop personnel, and contractors. Building managers will attend the Air Force Materiel Command Asbestos Awareness Course, MHPSAF9800700DL, offered by the Hill AFB Center Training Office and will be familiar with the asbestos pertaining to their building(s). Personnel who conduct maintenance, installation, or repair work in Hill AFB buildings are also required to attend asbestos training annually (and must document it on an AF Form 55). The awareness training can take many forms depending on the situation; however, it will contain the following information:

- The types of building materials that are likely to contain asbestos.

- The condition of ACM and the response appropriate to that condition.

- Asbestos only becomes a health hazard when asbestos fibers become airborne and are inhaled.

- Locations in buildings where ACM would most likely be found.

- Asbestos warning signs.

- Reporting requirements regarding any evidence of disturbance or damage to the ACM giving name, location, and telephone number.

- Reporting requirements regarding any dust or debris that may come from ACM or any improper action of building personnel that may disturb ACM.

- Requirements for cleaning and maintenance personnel to take special precautions to guard against disturbing ACM.

- Requirements regarding initial and periodic asbestos inspections.

- Additional measures requiring the protection of the health of building occupants during emergency cleanup operations.

75 CES/CEOHA will coordinate with 75ABW/SEG and 75 OMRS/SGXB annually on updates to the course material.

6.2 FACILITY MANAGERS TRAINING

Building managers are required to attend the 75 CEG facility managers’ training, which addresses all asbestos regulations and requirements for renovation/demolition work and for submitting Work Order requests.

6.3. BUILDING MAINTENANCE AND CUSTODIAL WORKER TRAINING

This training is designed for building maintenance and custodial employees who potentially perform OSHA Class IV asbestos work. This population includes employees from the 75 CEG Utility/Structural Shops who have to decide whether maintenance operations could potentially disturb ACM.

6.4. ASBESTOS INSPECTOR TRAINING

Inspector training is designated for Hill AFB employees who perform asbestos inspections and generate the required Hill AFB Asbestos Inspection Report. These inspections could potentially disturb suspected ACM. 75 CES/CEOHA employees must attend the asbestos inspector course annually.

Hill Air Force Base, Utah 84056-5206

6.5. CONTRACTOR / SUPERVISOR / ASBESTOS WORKER TRAINING

This training applies to site supervisors or asbestos workers. Contractor/supervisor or asbestos worker training is required for employees who perform OSHA Class I, II, and III asbestos work. The in-house worker population from 75 CES/CEOHA who perform repairs involving ACM must attend one of these two courses.

6.6. ASBESTOS PROJECT DESIGNER TRAINING

This training applies to project designers. 75 CES/CEOHA must attend the project designer course annually. 75 CEG/CEIE could also attend the project designer course.

Hill Air Force Base, Utah 84056-5206

7. RECORDKEEPING

This section lists the recordkeeping requirements to be followed under the Hill AFB Asbestos Program.

7.1. EMPLOYEE-SPECIFIC RECORDS

Each individual organization is responsible for maintaining the following records:

- Asbestos worker, site supervisor, and project designer training records, and

- Employee certifications.

Responsible agencies for different classifications of employees are described below. Required employee-specific records are kept by the following organizations:

For Hill AFB employees, the employee's supervisor is responsible to ensure that the employee enters the training and/or surveillance program prior to exposure. Personnel exposure records to include all government personnel exposure sampling data from 1994 to present will be maintained electronically by 75 OMRS/SGXB, in the Defense Occupational and Environmental Health Readiness System (DOEHRS). 75 OMRS/SGXO ensures personnel surveys are continued once the employee enters the program and maintains medical records.

For 75 CES/CEOHA project-specific hires, 75 CES/CEOHA is responsible for ensuring that permanent hires or temporary employees have the proper training and/or medical surveillance documentation.

Documentation from personnel exposure sampling is provided to 75 OMRS/SGXB.

For all abatement contractors, 75 CES/CEOHA is responsible for ensuring asbestos contractor employees have the proper training and/or medical surveillance documentation. Documentation is provided to 75 CEG for file maintenance.

For asbestos workers with on-call IDIQ asbestos contractors, prime contractors or subcontractors to prime contractors; 75 CES/CEOHA is responsible for ensuring the contractor provides documentation that asbestos worker employees have the proper training and/or medical surveillance documentation.

Documentation is provided to 75 CEG for file maintenance IAW regulations.

75 CES/CEOHA stores records electronically in accordance with Air Force record keeping requirements in Building 593 South, the 75 CES/CEOHA office. Each employee has his or her own file, which is maintained by the Hill AFB 75 CES/CEOHA Asbestos Supervisor.

Personnel exposure monitoring records also fall under the category of project-specific records outlined in the following section.

7.2. PROJECT-SPECIFIC RECORDS

Project-specific records are the responsibility of 75 CES/CEOHA. Required project-specific records include but are not limited to:

- Building surveys,

- State notifications,

- Exposure monitoring records (See Section 7.1, “Employee-Specific Records”),

- Asbestos inspection by state-certified inspector (See Section 5.2, “Asbestos Inspections” for additional information), and

- Completion records of asbestos removal projects (See Section 7.2.3 “Disposal Records,” Table 2

“Summary of Project Documentation,” and Table 3 “Project Completion Report Documentation” for details).

Hill Air Force Base, Utah 84056-5206

7.2.1 Building Surveys

75 CES/CEOHA maintains the Hill AFB Asbestos Building Survey for ACM. Both the building survey and supplemental presumed ACM sampling data provide…