Attachment 4_Asbestos Operations and Maintenance Plan.pdf

U.S. Army Fort Buchanan

Puerto Rico

Asbestos Operations and Maintenance Plan

34 South Gate Road DPW Environmental Division

Fort Buchanan PR 00934

Updated Version - February 2016

Asbestos Operations And Maintenance Plan Title Sheet

User Agency:

Facility Name:

Address:

City and Zip:

Date of O&M Plan:

Consultant:

Address:

City and Zip

Department of the Army Fort

Buchanan

Fort Buchanan (RQ327)

Directorate of Public Works

Building 34

South Gate Road

For Buchanan, Puerto Rico 00934-

February 2016

J.J. Sosa and Associates, Inc. (JJSA)

5811 Memorial Highway, Suite 207

Tampa, Florida 33615

Phone: (813) 888-6525

Fax: (813) 881-1285

I hereby certify that this Operations and Maintenance (O&M) Plan was compiled in accordance with the applicable Federal, State and DOD Regulations and satisfies the intent to provide Fort Buchanan with an

Asbestos Management Program, to the best of my ability and knowledge.

________________________________________________________ Dated: 02/11/2016

Mr. Anibal Negron

Chief Environmental Division

USAG Fort Buchanan PR 00934

Executive Summary

In 2003, J. J. Sosa & Associates, Inc. was retained by the U.S. Army Corps of Engineers, Mobile District to develop an

Asbestos Operation and Maintenance (O&M) Plan to address the management of all asbestos remaining in Fort

Buchanan structures. This O&M Plan was prepared by J. J. Sosa and Associates, Inc. (JJSA). The management plan objectives involve defining the requirements to protect building occupants, workers performing asbestos abatement activities and maintenance personnel at Fort Buchanan.

Fort Buchanan is an Army installation located in San Juan, Puerto Rico, under the major command of the U.S. Army

South (USARSO). Existing structures at Fort Buchanan date back to the 1940s. Most of the facilities have been renovated or replaced over the years. More than 230 operational buildings and more than 360 housing units for soldiers and their families stationed at Fort Buchanan currently exist at the installation. Asbestos survey data indicates that a large quantity of asbestos-containing building materials (ACBM) has been removed since implementation of regulations controlling the use of asbestos. However, asbestos is still present in various operational buildings as well as in some family housing.

It is the desire of Fort Buchanan to prevent unnecessary exposure to asbestos by employees, tenants, and other visitors to the facility. No employees, tenants, outside contractors, or visitors shall engage in any activity that will disturb ACBM within the facility. Any activity that could disturb ACBM must be approved by the Fort Buchanan Asbestos Program

Manager (APM). Disturbance of ACBM will be conducted in accordance with the Administrative Procedures and Work

Practices contained herein or by independent licensed asbestos abatement contractors working pursuant to contract agreements.

The APM for Fort Buchanan is Mr. Anibal Negron. The APM will have responsibility for this Asbestos O&M Plan. The asbestos management program will remain in force as long as asbestos-containing materials remain in the facilities at

Fort Buchanan.

Contents

Executive Summary 111

Contents v

Asbestos Operations And Maintenance Plan Title Sheet ix

Assumptions, Limitations, and Conditions xi

List of Acronyms xiii

Introduction 1-1

Description of Asbestos 1-1

Identifying Asbestos 1-1

Health Concerns 1-1

Overview of Applicable Federal and State Regulations 1-2

EPA Regulations for Public Protection from Asbestos 1-3

OSHA Regulations for Worker Protection from Asbestos 1-4

Puerto Rico Environmental Quality Board Regulations 1-5

Program Description 2-1

EPA Guidance Documents 2-1

Program Management Responsibilities 2-1

Asbestos Program Manager 2-2

Inspector 2-2

Antilles Consolidated School System Environmental Officer 2-3

Design Engineer 2-3

O&M Division Chief 2-3

Industrial Hygienist 2-3

Location of ACBM 2-4

Administrative Procedures 3-1

AP1-Worker Training, Respiratory Protection, and Medical Surveillance 3-2

General 3-2

Training Requirements 3-2

Training at Fort Buchanan 3-3

Respiratory Protection Program 3-4

Medical Surveillance Program 3-5

AP2-Notifications and Labeling 3-7

Warning 3-7

Labels 3-7

Warning Signs 3-7

Notifications 3-9

AP3-Periodic Surveillance and Re-inspection 3-11

Periodic Surveillance 3-11

Re-inspection Program 3-11

AP4-Work Permit Program 3-12

AP5-Recordkeeping and Forms 3-15

Form 1 3-49

Form 2 3-20

Form 3 3-21

Form 4 3-24

Form 5 3-25

Form 6 3-27

Form 7 3-28

Form 8 3-29

Form 9 3-30

AP6-Selection of Personal Protective Equipment and 3-31

Decontamination Procedures

Protective Clothing and Equipment 3-31 Decontamination 3-31

AP7-Developing the Air Monitoring Program 3-32 Design and Validation of an O&M Program 3-32 Periodic Monitoring and Observation of Monitoring 3-34

Termination of Monitoring 3-34

Settled Dust Sampling 3-35

APS-Selection of Materials 3-37 Polyethylene 3-37

Lockdown Encapsulants 3-37

AP9-Emergency Responses 3-38 General Response to a Fiber Release 3-38

Work Practices 4-1

General Custodial Practice 4-2

Worker Checklists 4-2

WP1-Wet Strip Floor Wax from Resilient Asbestos Flooring 4-9

Summary 4-9

Work Practice 4-9

WP2-Dry or Spray Buffing Resilient Asbestos Flooring 4-10

Summary 4-10

Work Practice 4-10

WP3-Cleaning Resilient Asbestos Flooring 4-11

Summary 4-11

Work Practice 4-11

WP4-Cut or Drill Asbestos Cement Panels 4-12

Summary 4-12

Examples of Level B 4-12

WP5-Remove Asbestos Cement Panels 4-14

Summary 4-14

Example of Level A 4-14

Example of Level B 4-14

WP6-Remove Asbestos-Containing Built-Up Roofing 4-16

Summary 4-16

Example of Level A 4-16

Example of Level B 4-16

WP 7-Clean Up Debris 4-18

Summary 4-18

Examples of Level B 4-18

WP8-Replace Asbestos-Containing Gaskets/Packing 4-20

Summary 4-20

Example of Level A 4-20

Example of Level B 4-20

WP9-Remove Asbestos-Containing Caulking and Glazing Compound 4-23

Summary 4-23

Example of Level A 4-23

Examples of Level B 4-23

WP1O-Clean Room that has Asbestos-Containing Dust 4-25

Summary 4-25

Examples of Level A 4-25

WP11-Attach Item to Ceiling Finished with ACBM 4-27

Summary 4-27

Example of Level A 4-27

Examples of Level B 4-27

WP12-Repair or Replace Item in Surface Finished with ACBM 4-29

Summary 4-29

Example of Level A 4-29

Example of Level B 4-29

WP13-Replace Bulbs in Light Fixture Attached to or in Surface Finished 4-31 with ACBM

Summary 4-31

Examples of Level A 4-31

Examples of Level B 4-31

WP14- Clean Room with Exposed Surfaces Finished with ACBM 4-33

Summary 4-33

Examples of Level A 4-33

WP15-Repair Damaged Surfacing ACBM 4-34

Summary 4-34

Examples of Level A 4-34

Examples of Level B 4-34

WP16-Accessing through an ACBM Finished Surface 4-36

Summary 4-36

Example of Level A 4-36

Examples of Level B 4-37

WP17-Painting Surfacing ACBM 4-38

Summary 4-38

Example of Level A 4-38

WP18-Remove Asbestos-Containing Insulation Inside HVAC Unit for 4-40

Maintenance Work

Summary 4-40 Example of Level B 4-40

Examples of Level C 4-41

WP19-Replacement of Resilient Asbestos Floor Tiles 4-42 Summary 4-42

Examples of Level A 4-42

WP20 -Install New Resilient Flooring or Carpet Over Resilient 4-46

Asbestos Flooring

Summary 4-46

Example of Level A 4-46

WP21-Install Partition Over Resilient Asbestos Flooring 4-47

Summary 4-47

Example of Level A 4-47

WP22-Remove Carpet Over Resilient Asbestos Flooring 4-48

Summary 4-48

Example of Level A 4-48

Example of Level B 4-49

References 5-1

EPA Publications 5-1

OSHA Regulations 5-2

Commonwealth of Puerto Rico Publications 5-2

U.S. General Services Administration (PMSE) 5-2

Military Policy, Directives and Guidance 5-2

Miscellaneous References 5-2

O&M Program Elements References 5-3

Life-Cycle Cost Analysis 6-1

List of Appendixes

A Glossary

B Asbestos Material Location

List of Exhibits 2-1 Asbestos Program Management Personnel 2-1

3-1 Employee Notification Sign 3-8

3-2 Work Permitting Program Checklist 3-14

6-1 List Cycle Cost Analysis 6-1

Assumptions, Limitations, and Conditions

O&M Program Assumptions The O&M Plan assumes that all elements of the O&M program listed below are considered and all applicable elements have been established and the programs in place.

Asbestos Program Manager appointment and training

Building inspection and assessment

Copies of applicable regulations and guidance documents

Hazard communication program

Historical air monitoring data

Confined space entry program

Safety program for other hazards

All O&M related programs should be reviewed periodically and revised if necessary. Regulatory and guidance documents should also be reviewed periodically to ensure that they are current.

Limitations and Conditions

This Plan was developed as reference for persons responsible for performing and/or directing approved O&M Work

Practices. Use of this Plan will assist in providing response actions required to manage asbestos in-place. Use of the Plan does not guarantee that the quality of work will be equal to or better than if completed by a qualified independent contractor. JJSA make no warranty or guarantee, expressed or implied, with respect to work performed by Fort

Buchanan workers or contractors using the Plan. Neither does JISA assume any liability for the use of any information, methods, or materials contained herein, or for damages arising from such use; nor does JJSA assume any responsibility for any injury to individuals or property, or for any financial loss, sustained as a result of the use or application of this document.

Note that:

O&M activities involving asbestos-containing building materials (ACBM) may involve health risks to those performing them or those performing unrelated work near the activities.

Experts from the building, scientific, and environmental communities have different views as to the proper management of ACBM in-place. This document attempts to bring together information and viewpoints from several sources reflecting current knowledge and technology.

This O&M Plan shall be considered solely as a resource document representing the expert opinion of professionals in this field. This Plan does not represent the view, policies, or position of the U.S. Environmental Protection Agency

(EPA), the Occupational Safety and Health Administration (OSHA), or any other agency of the federal, state, or local governments.

The O&M Plan should serve as a guide to implement the Fort Buchanan asbestos management program and instruct workers who execute the required tasks. The user bears all risks associated with reliance on these work practices and shall have the sole responsibility to evaluate the information contained herein and to make independent judgments on the use of the practices outlined in this O&M Plan.

List of Acronyms

ACBM Asbestos-Containing Building Material

ACM Asbestos-containing material

ACSS Antilles Consolidated School System

AHERA Asbestos Hazard Emergency Response Act

AP Administrative Procedures

APM Asbestos Program Manager

ASHARA Asbestos Schools Hazard Abatement Reauthorization Act

CAA Clean Air Act

CFR Code of Federal Regulations

DENIX Defense Environmental Network Information Exchange

DOT Department of Transportation

DPW Directorate of Public Works

FEG Environmental Enterprises Group

EPA Environmental Protection Agency

HEPA High Efficiency Particulate Air

HVAC Heating Ventilating and Air Conditioning

JJSA J. J. Sosa and Associates

MAP Model Accreditation Plan

NTEA Negative Exposure Assessment

NESHAP National Emission Standards for Hazardous Air Pollutants

NIBS National Institute of Building Sciences

MOSH National Institute for Occupational Safety and Health

O&M Operations and Maintenance

OSHA Occupational Health and Safety Administration

PACM Presumed asbestos-containing material

PAPR Powered Air Purifying Respirators

PCM Phase Contract Microscopy

PEL Permissible Exposure Limit

PPE Personal Protective Equipment

PREQB Puerto Rico Environmental Quality Board

RACM Regulated Asbestos-Containing Material

RFCM Resilient Floor Covering Manufactures

TEM Transmission Electron Microscopy

TSCA Toxic Substance Control Act

TSI Thermal System Insulation

TWA Time-weighted Average

USARSO U.S. Army South

WPM Work Practices Micrometers

Section 1

Introduction

This Operations and Maintenance (O&M) Plan is designed to establish a set of policies, procedures, and work practices intended to minimize occupant exposure to asbestos-containing building materials (ACBM). This plan was prepared to aid in safely maintaining the remaining ACBM throughout Fort Buchanan.

Description of Asbestos Asbestos is the name for a group of natural minerals that separate into strong, very fine fibers. The fibers are heat-resistant and extremely durable, and these qualities have made asbestos very useful in the construction industry.

Although several different types of asbestos exist, nearly 95 percent of all asbestos used in commercial products today is a type of asbestos called chrysotile. In the 1970s, the EPA began banning the manufacture of products containing asbestos because of growing concerns over health effects.

Identifying Asbestos Asbestos may be found in many different products and many different places. Examples of products that might contain asbestos are:

Sprayed-on insulation in buildings

Fire proofing materials

Insulation for pipes and boilers

Wall and ceiling insulation

Ceiling tiles

Floor tiles

Putties, caulks, mastics, and cements (such as in chemical carrying cement pipes)

Roofing shingles

Siding shingles on old residential buildings

Wall and ceiling texture in older buildings and homes

Joint compound in older buildings and homes

Automotive brake linings and clutch pads

Interiors of fire doors

Health Concerns Despite the beneficial uses of asbestos, exposure to ACBMS that release fibers into the air can produce adverse health effects. The potential of an asbestos-containing product to release fibers is dependent upon several factors, including its location and its degree of friability. Friable means that when dry, it can be crumbled with hand pressure and therefore is likely to emit fibers when disturbed. The fibrous or fluffy spray-applied asbestos materials found in many buildings for fire-proofing, insulating, or decorative purposes are generally considered friable. Some materials, such as vinyl floor tiles, are likely to emit fewer airborne fibers unless they become worn from abrasion, weather, physical damage, or chemical exposure, or are subjected to sanding and cutting operations. Because of their size and shape, these tiny fibers, invisible to the human eye, can remain suspended in the air for long periods of time and can easily penetrate body tissues when inhaled or ingested with food. Due to their durability, these fibers can remain in the body, primarily the respiratory tract, for many years.

Asbestos is known to cause asbestosis and various forms of cancer. Asbestosis is a serious chronic respiratory disease caused by scarring of the lung tissue from inhaled asbestos fibers. Breathing becomes progressively more difficult, and this disease can lead to death.

Cancer can result from breathing asbestos fibers. Smoking significantly increases the potential for lung cancer, the most common asbestos-related disease. Asbestos exposure has also been linked to mesothelioma, a cancer of the chest and abdominal membranes. Mesothelioma almost never occurs without exposure to asbestos, and is currently incurable.

Other cancers, primarily of the digestive tract, also have been associated with exposure to asbestos.

These diseases have a long latency period and may not appear until 20 to 40 years after exposure. Right now, for example, the medical community is seeing the results of exposure that occurred among asbestos workers during World

War II.

Overview of Applicable Federal and State Regulations The U.S. Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) are the primary agencies responsible for regulating asbestos exposure. EPA is responsible for developing and enforcing regulations that protect the general public from exposure, whereas OSHA is responsible for protecting workers who could be exposed to asbestos in the workplace or as part of their jobs. The commonwealth of Puerto Rico has also promulgated regulations addressing asbestos.

The specific regulations addressing asbestos consist of:

Asbestos containing materials in schools (40 CFR 763)

Asbestos Schools Hazard Abatement Reauthorization Act (ASHARA)

National emission standards for asbestos (40 CFR 61, Subpart M)

Construction standards for asbestos (29 CFR 1926.1101)

General industry standards for asbestos (29 CFR 1910.1001)

Atmospheric Emissions Regulations, Section 422 (Puerto Rico Environmental Quality Board

[PREQBJ)

Solid Waste Regulations (PREQB)

EPA Regulations for Public Protection from Asbestos EPA has promulgated the following major regulations for protection of the general public from asbestos exposure:

The Asbestos Hazard Emergency Response Act (AHERA), which was amended by the ASHARA, to manage asbestos in schools and other buildings.

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for public protection from airborne asbestos

The following paragraphs present important features of these regulations.

AHERA/ASHARA. In May 1982, EPA first issued regulations to control asbestos in schools under authority of the

Toxic Substance Control Act (TSCA). A school is an elementary or secondary school as defined by Section 198 of the

Elementary and Secondary Education Act of 1965 (20 United State Code [U.S.C.] 2854). In response to the need for more stringent control, Congress enacted AHERA as Title II of TSCA on October 22, 1986. This act required EPA to establish a more defined program to control ACBMs in schools. As a result, the EPA Rule entitled Asbestos Containing

Materials in Schools (40 CFR 763) was promulgated on October 30, 1987. The new rule required schools to inspect for asbestos, prepare asbestos management plans, and develop and implement O&M plans. AHERA also required school authorities to inform parents, teachers, and others of the management plans.

On November 28, 1990, EPA enacted ASHARA, which amended AHERA by extending accreditation requirements to people who perform inspections or design or execute response actions in public and commercial buildings. This accreditation must occur through AHERA's Model Accreditation Plan (MAP), which is cited in 40 CFR 763, Subpart E, Appendix C, and outlines the required training courses for affected workers. Accreditation does not extend to management planners. ASHARA required the MAP to include more hands-on training.

NESHAP. The Clean Air Act (CAA) of 1970 required EPA to develop and enforce regulations to protect the public from exposure to airborne contaminants known to be hazardous to human health. On March 31, 1971, EPA identified asbestos as a hazardous air pollutant. On April 6, 1973, EPA promulgated the NESHAP standard for asbestos (40 CFR 61, Subpart M).

In outlining requirements for asbestos exposure during work performance, NESHAP uses a classification called RACM

(regulated asbestos-containing material). A RACM is a friable ACBM or a non-friable ACBM that has become, or has the potential to become, friable from physical actions such as demolition and renovation activities.

NESHAP specifies work practices, notifications, and training requirements for a variety of operations involving

RACMs. For building demolitions and renovations, specific notification requirements (40 CER 61.145), emission control procedures (40 CFR 61.145), and waste disposal procedures (40 CFR 61.150) apply if either of the following conditions are met:

The amount of friable asbestos-containing material (ACM) in a facility being demolished or being disturbed in a renovation is at least 260 linear feet on pipes, or at least 160 square feet (ft2) on other facility components.

Where measurement before stripping is not possible, the friable ACM from all sources totals at least 35 cubic yards

(yd3).

Standards also may apply for RACMS in lesser quantities (see 40 CFR 61, Subpart M).

SECTION 2

Program Description

The O&M Plan is an integral part of the Fort Buchanan Asbestos Management Program. The three basic elements of the

Asbestos Management Program are:

Survey and Assessment - identify and characterize ACBM

O&M - safely manage ACBM until removal

Planned Removal - eliminate ACBM which may be disturbed

EPA Guidance Documents This plan is intended to be used in conjunction with the guide Managing Asbestos in Place ("Green Book") issued by the EPA in July 1990, Information presented in the "Green Book" is not repeated in this Plan, but is referenced where appropriate. Additional references might be made to other guidance documents, including:

1. Asbestos in Buildings: Simplified Sampling Scheme for Friable Asbestos Materials ("Pink Book")

2. Guidance for Controlling Asbestos-Containing Materials in Buildings ("Purple Book")

3. A Guide to Respiratory Protection for the Asbestos Abatement Industry ("White Book")

A list of references and guidance documents is given in Section 5 of this Plan.

Program Management Responsibilities The following section describes the responsibility of each member of the organization for the management of remaining asbestos at Fort Buchanan. Exhibit 2-1 lists individuals with assigned responsibilities to ensure the protection of all base personnel from the potential exposure to asbestos.

EXHIBIT 2-1

Asbestos Program Management Personnel

Name Position Organization

Anibal Negron Asbestos Program Manager Environmental Division, Directorate of Public Works

Pedro Lopez QA Inspector Engineering Division

Rafael Negron Facility Engineer Antilles Consolidated School System

Luis Torres Chief Engineering Engineering

Jesus M. Galvez Chief O&M Division O&M Division

Ms. Maria Cifredo Occupational Nurse Health Clinic and Preventative Medicine

Mr. Alfredo Nogueras Safety Officer Installation Safety Office

Asbestos Program Manager The Asbestos Program Manager (APM) is the focal point for the administration of the asbestos program and will reside in the Environmental Division at the Directorate of Public Works. The APM fulfills a wide range of responsibilities. The

APM is responsible for developing the program and coordinating its operations. The APM:

Implements and oversees activities of the asbestos program

Directs the maintenance of all records for the program including asbestos surveys, lab results, inspections, abatement actions, waste manifests, and so on.

Updates and revises the asbestos inventory (Appendix A) as necessary and provides copies to Contracts, Engineering, Inspection, and others divisions as appropriate

Reviews and authorizes Maintenance Work Authorization Forms

Ensures that proper agency notification occurs and serves as point of contact for regulatory agency communications

Maintains a current asbestos certification and required training

Coordinates an awareness training session for designated employees

Maintains a copy of training records and training resources

Informs all base contractors that they may encounter ACBM while conducting their work and that they must take precautions and advise their workers

Communicates the Asbestos Management Program to tenant facilities who shall be responsible for disseminating information to their employees and outside contractors

Communicates routinely with personnel regarding the Asbestos O&M Plan

Provides briefings to senior management as to the status of the program

Inspector The Fort Buchanan Inspectors:

Serves as the point of contact for asbestos contractors and reviews emergency response procedures with them in the event of an emergency situation

Ensures that asbestos work is conducted in controlled areas as appropriate

Ensures that air monitoring is conducted as appropriate by properly trained personnel

Evaluates air monitoring results

Confirms that asbestos contractor personnel onsite are those whose training records and certifications were provided in the contractor's proposal

Confirms that the asbestos contractor's actions in the field occur in accordance with work practices and specifications stated for the project

Confirms that waste tracking and disposal arrangements are made and that waste manifests are received from the disposal facility

Ensures that forms provided to document activities of the O&M Plan are being used

Antilles Consolidated School System Environmental Officer The Antilles Consolidated School System (ACSS) is a tenant organization at Fort Buchanan. The environmental officer for the school system serves as the Asbestos Program Manager for the school facilities. The Environmental Officer:

Develops and coordinates the asbestos management program for the ACSS

Notifies the Fort Buchanan APM of planned asbestos abatement activities in the schools

Submits an updated asbestos inventory for the school system as changes occur

Design Engineer The Fort Buchanan Design Engineer:

Reviews the inventory to determine whether potential asbestos related design issues exist

Maintains a list of approved asbestos abatement contractors for O&M activities of a routine or emergency nature

Makes this O&M Plan available to asbestos contractors

Ensures that contractors either follow Work Practices presented herein or site specific work practices developed in compliance with the regulations

Reviews asbestos contractor submittals, including training certifications, respirator fit test records, and medical records

Determines where ACBM hazards may exist and what steps the contractors must take to protect base personnel and families

Reviews post-job submnittals and written deliverables

O&M Division Chief The Chief of the Operations and Maintenance Division:

Receives Job Request Form for Maintenance Work

Confirms with the APM that requested work will not impact or disturb ACBM

Completes the Maintenance Work Authorization Form

Maintains a supply of personnel protective equipment (PPE) for Fort Buchanan personnel

Industrial Hygienist Fort Buchanan Industrial Hygienist:

Maintains the medical surveillance monitoring program

Administers the respiratory protection program and schedules respiratory fit testing and training

Confirms PPE requirements for Fort Buchanan personnel

Coordinates personnel health and safety training

Maintains records of PPE and respirators issued to Fort Buchanan personnel

Location of ACBM Fort Buchanan retained the services of Pickering Environmental Consultants in 1991 and Environmental Enterprises

Group (EEG) in 1993 to complete post-wide surveys. The results of the survey confirmed the presence of asbestos in most of the operational buildings and housing units. Copies of the survey reports can be found in the Environmental

The

Office located in the Public Works building at Fort Buchanan. The inventory or summary table with the remaining

ACBM throughout the Fort Buchanan operational buildings is provided in Appendix A. Following the identification of the ACBM, a comprehensive abatement program was started. Since the start of the abatement activities at the Fort

Buchanan, various operational buildings have been rid of ACBM. The drawings in Appendix B show the buildings where ACBM remain and those that are ACBM-free at the time of the publication of this O&M Plan.

ACBM previously identified in the interior of the 364 housing units at Fort Buchanan has been abated, except in unit 823 located in the Las Colinas housing area. The ceiling in this unit has been treated with acoustical finish containing asbestos. In addition, the roof treatment of 22 buildings in Buchanan Heights Family Housing (demolished) contained asbestos. This represents approximately 65,000 square feet of roofing material that contain asbestos. Abatement of these roofs was scheduled to be completed by FY03.

SECTION 3

Administrative Procedures

This section presents the administrative elements of the asbestos program operation. In contrast, Section 4 presents work practices or instructions for specific activities involving asbestos. The following Administrative Procedures (AP) are presented in this section:

AP1 Worker Training, Respiratory Protection, and Medical Surveillance

AP2 Notifications and Labeling

AP3 Periodic Surveillance and Re-inspection

AP4 Work Permitting Program

APS Recordkeeping and Forms

AP6 Selection of Personal Protective Equipment & Decontamination Procedures

AP7 Developing the Air Monitoring Program and Assigning Air Monitoring Personnel

AP8 Selection of Materials AP9 Emergency Responses

AP1-Worker Training, Respiratory Protection, and Medical Surveillance

General Training Requirements Workers assigned to perform O&M work must receive training and experience in the skills and techniques required for the type of work to be performed, training in applicable asbestos O&M procedures, this O&M Plan, and building conditions at Fort Buchanan.

OSHA Regulations 29 CFR 1926.1101 and 29 CFR 1910.1001 established four classifications of asbestos work and requirements for the amount and type of training required to perform the four classes of work. The classification of work and training requirements per OSHA defimtion are as follows:

Class I Asbestos Work - activities involving the removal of ThI and surfacing ACBM and presumed asbestos-containing material (PACM). To perform this work, workers are required to complete 32 hours of training equivalent to the EPA Model Accreditation Plan asbestos abatement worker training. The training provider must be certified by the PREQB.

Class II Asbestos Work - activities involving the removal of ACBM which is not TSI (?) or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tiles and sheeting, roofing and siding shingles, and construction mastic. To perform this work, workers are required to complete 32 hours of training equivalent to the EPA Model Accreditation Plan asbestos abatement worker training.

Class III Asbestos Work - repair and maintenance operations where ACBM, including TSI and surfacing material, is likely to be disturbed. Requires 16 hours of training equivalent to the 16-Hour O&M course developed by the EPA for maintenance and custodial workers who conduct activities that will result in the disturbance of ACBM.

Class IV Asbestos Work - maintenance and custodial activities during which employees contact ACBM and PACM and activities to clean up waste and debris containing ACBM and PACM. Requires 2 hours of training equivalent to the awareness training course developed by the EPA for maintenance and custodial workers who work in buildings containing ACBM.

Depending upon applicable regulations (such as PREQB Section 422, NESHAP, and OSHA 29 CFR 1926.1101/29 CFR

1910.1001), a designated trained or "competent person" might be required to perform or supervise certain aspects of the work.

Competent Person means, in addition to the definition in 29 CFR 1926.32, one who is capable of identifying existing asbestos hazards in the work place and selecting appropriate control strategies for asbestos exposure, who has the authority to take prompt corrective measures to eliminate them, as specified in 29 CFR 1926.32(f). In addition, for Class

I and Class II work, a Competent Person is one who is specially trained in a training course which meets the criteria of

EPA's Model Accreditation Plan (40 CFR 763) for project designer or supervisor, or its equivalent. For Class III and

Class IV work, a Competent Person is one who is trained in an O&M course developed by EPA under 40 CFR 763.92

(a)(2).

Training at Fort Buchanan Effective implementation of the Asbestos O&M Plan requires specific training of select personnel. The amount and content of training depends on the specific duties of each individual and the likelihood of potential contact with ACBM in the buildings at Fort Buchanan. Fort Buchanan shall institute a training program for employees engaged in asbestos-related work or who may be potentially exposed to asbestos fibers from ACBM. Training shall be conducted at the time of initial assignment and at least annually thereafter.

Fort Buchanan personnel shall not conduct abatement of Class I, II, or III asbestos work. These classes of work must be performed by an Asbestos Contractor utilizing personnel certified by the PREQB and following applicable federal regulations and PREQB Rule 422 for asbestos-containing material management.

The APM should have formal training sufficient to:

1. Perform inspections and identify where asbestos will be encountered

2. Assess the condition of ACBM

3. Evaluate potential exposure, building components, building systems, building usage patterns

4. Design and conduct O&M activities

5. Be familiar with cleaning and maintenance tasks

6. Understand applicable laws and regulations

7. Be aware of other crucial factors associated with an O&M program

Maintenance and custodial workers shall receive asbestos awareness training to perform their duties safely. This training may be performed in house by the APM or by contract training programs. The asbestos awareness training shall address the following topics:

Location of ACBM at Fort Buchanan and potential sources of exposure

Health effects of asbestos exposure and the increased dangers from cigarette smoking

Recognizing asbestos hazards

Modifications to typical maintenance activities to prevent asbestos exposure

Form 1 in AP5, entitled Record of 2-Hour Asbestos Training, should be used to document Class TV work training.

Annual refresher training course will be provided to reinforce, clarify, and update asbestos awareness information and work practices.

Additional training might be desirable for performing frequent O&M work or certain O&M tasks. Before workers are assigned to O&M work, the APM should verify that their training, respirator fit tests, and medical surveillance are current and in compliance with regulations (where applicable) and the requirements of work practices to be used.

Respiratory Protection Program Respirators shall be used whenever personnel have a potential to be exposed to asbestos. Respirators used for O&M activities must be selected based on the requirements of regulations and a Respiratory Protection Program developed in accordance with 29 CFR 1910. 134 and 40 CFR 763.120-121. Appendix E of the "Green Book" includes EPA's recommendations on the types of respirators to be used for custodial and maintenance tasks. Liability concerns, historical data, and management policies might also influence whether respirators are used, and if so, the type of respirators for

O&M activities. The National Institute for Occupational Safety and Health (NIOSH) recommends minimizing occupational exposure to cancer-producing substances such as asbestos to the lowest feasible level. In practice, an exposure level of 0.01 fibers/cm3 of air inside the respirator is commonly used for planning purposes. OSHA has stated that the OSHA PEL was selected as a technical and economic compromise for industry, and is not designed to totally prevent cancer-causing exposures. The EPA's "White Book" and the Introduction and Section 01562 of the National

Institute of Building Sciences (NIBS) Asbestos Abatement Guide Specifications contain information regarding respirator selection that might be helpful to the APM. Review of this additional information is strongly encouraged.

Respiratory protection for asbestos work requires the use of High Efficiency Particulate Air (HEPA) filter cartridges. In certain situations, full-face respirators might be desirable to provide additional eye and face protection for workers.

Powered Air Purifying Respirators (PAPRs) are preferred by many workers instead of negative pressure respirators.

Regulations in 29 CFR 1910.1001 and 29 CFR 1926.1101 require that an employer provide a PAPR instead of a negative pressure respirator if an employee chooses to use this type of respirator. Depending upon the type of work and work practices to be used, combination respirator filter cartridges or a different type of respirator might be necessary to protect workers from other contaminants or hazardous substances.

At a minimum, the following levels of respiratory protection are recommended for custodial and/or maintenance activities. Single use disposable dust masks shall not be used for protection against asbestos.

Type of Activity

Routine maintenance where disturbance of ACBM is unlikely.

Routine maintenance where accidental disturbance of ACBM is likely.

Maintenance or repair activities involving intentional small-scale disturbance of ACBM.

Maintenance or repair activities involving intentional small-scale disturbance of ACBM supplemented by the use of a glove-bag.

Any activity involving large-scale disturbance of ACBM (as in abatement).

Decontamination after a minor (small-scale) fiber release episode.

Decontamination after a major (large-scale) fiber release episode.

Recommended Respiratory Protection

No respiratory protection. Half-face HEPA-filtered air purifying respirators should be available if needed.

Half-faced HEPA-filtered air-purifying respirator.

Full-face PAPA with HEPA filters.

Half-face HEPA-filtered air purifying respirator.

Supplied air respirator (Type C) or full-face PAPR with HEPA filters.

Half-face HEPA filtered air-purifying respirator.

Type C respirator or full-face PAPR with HEPA filters.

In conjunction with the selection of respirators for use, all employees required to use such respirators must be trained in proper fit-testing procedures. Fit testing, especially when using one-half face HEPA filtered air purifying respirators, is essential to ensure that maximum protection is provided to custodial and maintenance personnel. OSHA (29 CFR

1926.1101 and 29 CFR 1910.134, respectively) requires initial and biannual fit testing for employees required to -use negative pressure respirators.

Medical Surveillance Program The employer is required to institute a Medical Surveillance Program for all employees whom:

Are engaged in Class I, II, and III asbestos work for a combined total of 30 or more days per year

Are exposed at or above the PEL or Excursion Limit for 30 or more days

Wear negative pressure respirators

The surveillance program consists of many steps. To maintain a good surveillance program, it is recommended that the program consist of the following elements (minimum requirements):

Initial examination

Annual examination

Termination examination

Medical history provided to the physician

Written opinion by the physician

Employee medical records

OSHA requires that before the examination, the employer provide to the examining physician the following information:

A copy of the OSHA Standard (29 CFR 1910.1001) which includes: the mandatory medical questionnaire, the mandatory interpretation and classification of chest roentgenograms, and the non-mandatory Medical Surveillance

Guidelines

A description of the affected employee's duties as they relate to the employee's exposure level

The employee's representative exposure level or anticipated exposure level

A description of any personal protective and respiratory equipment used or to be used

Information from previous medical examinations of the affected employee that is not otherwise available to the examining physician

The employee's medical records will be maintained and will contain at a minimum the following information:

The name of the employee

The social security number of the employee

A copy of the employee's medical examination results

A copy of the employee's medical history

The medical questionnaire responses

A copy of all medical test results

The physicians' recommendations

Any employee medical complaints related to asbestos exposure

The physicians' written opinion

A copy of the information provided to the physician by the employee

OSHA provides a broad spectrum of specific tests physicians must perform as part of the medical surveillance program.

Certain tests are required by OSHA as a minimum in order to be in compliance with regulations. These minimum requirements for medical examination are as follows:

A report of the employee's medical and work history

A complete physical examination with emphasis on the respiratory and cardiovascular systems and digestive tract

(to be performed at least annually)

Completion of the medical questionnaire

A pulmonary function test whose purpose is to assert not only the state of the employee's respiratory health, but also his/her ability to use a negative pressure respirator

DANGER

CONTAINS ASBESTOS FIBER

AVOID CREATING DUST

CANCER AND LUNG DISEASE HAZARD

AP2-Notifications and Labeling

Warning Labels 29 CFR 1926.1101 and 1910.1001 require that labels be affixed to all products containing asbestos and to all containers containing such products, including waste containers. Where feasible, all asbestos products shall contain a visible label.

Labels shall be printed in large bold letters on contrasting background in accordance with the requirements of 29 CFR

1910.1200(f) of OSHA's Hazard Communication Standard, and shall contain the following information:

Warning Signs The building owner shall post warning signs at the entrance to rooms or areas (which contain ACBM) into which employees can reasonably be expected to enter. Warning signs are also required to indicate regulated work areas. The warning sign shall identify the ACBM material which is present, its location, and appropriate work practices which, if followed, will ensure that the ACBM or PACM will not be disturbed. The warning signs shall state the following information:

In addition, where the use of respirators and protective clothing is required, the warning signs shall include the following:

In addition, a more site-specific warning sign could be developed from the example provided as Exhibit 3-1.

ASBESTOS

CANCER AND LUNG DISEASE HAZARD

AUTHORIZED PERSONNEL ONLY

CONTAINS ASBESTOS FIBERS

AVOID CREATING DUST

CANCER AND LUNG DISEASE

HAZARD

RESPIRATORS AND PROTECTIVE

CLOTHING

ARE REQUIRED IN THIS AREA

EXHIBIT 3-1

Employee Notification Sign

THE FOLLOWING MATERIALS AT BUILDING___________________________________

FORT BUCHANAN HAVE BEEN IDENTIFIED AS ASBESTOS-CONTAINING OR ARE

PRESUMEDASBESTOS-CONTAINING:

Flooring materials and adhesives located throughout the building

Drywall, mud and tape located through out the building

HVAC duct mastic materials

Cove base and adhesives

Transite panels on laboratory hoods

Window caulking material on north-side aluminum windows insulating materials on boiler lines, domestic water lines, HVAC lines

Cementitious Transite panels on the cooling towers

Sink undercoating

Roofing materials

Please review the Asbestos Operations and Maintenance Plan located in the Environmental office regarding the care of these materials.

NOTE: MODIFY THIS SIGN AND POST NEAR ACBM IN BUILDINGS AS APPROPRIATE.

Notifications The APM is responsible for informing building occupants and those who may come in contact with asbestos-containing materials about its location in order to prevent inadvertent disturbances. This includes employees, facility maintenance employees, tenants, and outside contractors. Section 4 of the "Green Book" includes information on occupant, tenant, and worker notification of the presence of ACBM.

Employee Awareness Notification Employees and tenants should be informed about the location of ACBM, instructed to avoid disturbance of these materials, and told to report damage or suspected releases to the APM. This notification can be written or communicated verbally.

In addition, facility maintenance employees should be prohibited from conducting activities that would disturb ACBM without prior authorization from the APM. Facility maintenance employees working in areas with ACBM are required to complete the asbestos awareness training mentioned in AP1 and should be familiar with the general Work Practices presented in Section 4 of this O&M Plan. Form 1 in AP5 should be completed as documentation of facility maintenance awareness training session.

Outside Contractor Notification Outside contractors need to be informed of the location of ACBM if present in the buildings they will be working in. The

Contractor Notification form (Form 2 in AP5) should be used to inform all contractors of potential asbestos hazards they may encounter at Fort Buchanan.

Asbestos Abatement Contractor Notification The asbestos abatement contractor retained to perform operation and maintenance activities will be notified in the contract documents or separate letter about the location and content of ACBM. When asbestos abatement work is being planned, the employees working in and near the area of the abatement should be provided information about:

The specific work to be performed

The abatement work schedule

Precautions being taken

What will be visible during the work

That posted warning signs must be obeyed

Form 3 in AP5, titled Employee Notification of an Asbestos Abatement Project, can be used to document this notification.

Agency Notifications The APM, or his designee, should file all notices required by federal, state, and local regulations prior to the start of any

O&M activities that are governed by these regulations. Federal requirements for notification are established by the

NESHAP rules, EPA Worker Protection Rule, and OSHA regulations. Written notification to EPA is required for demolition or renovation work involving asbestos above certain quantities per 40 CFR 61.145, (a) and (b). If the combined amounts of regulated asbestos-containing material (RACM) to be stripped, removed, dislodged, cut, drilled or similarly disturbed is over 260 linear feet (80 linear meters), 160 square feet (15 square meters), or 35 cubic feet (1 cubic meter) for any single project, notice must be given at least 10 working days prior to beginning work. Also, if the combined estimated quantities of RACM to be removed or stripped in individual non-scheduled operations during a calendar year (January 1 through December 31) exceed the amounts listed above, a NESHAP notice must be submitted at least 10 working days before the end of the calendar year (e.g., December 15), preceding the year for which notice is being given. A new written notice must be filed with the EPA if the start date for a project is revised (earlier or later) from the date filed in the original or a previous notice. A notice must be updated if the amount of asbestos affected changes by 20 percent or more. Form 4 in AP5, entitled Notification of Demolition and Renovation, can be used for EPA notification.

If wetting of RACM during removal would unavoidably damage equipment or present a safety hazard, written approval from the EPA is required for alternative emission control methods (dry removal).

The EPA notification requirements for emergency renovation work are established by 40 CFR 61.145 (a) and (b). More information on emergency work is included in AP9.

PREQB Rule 422 for managing materials containing asbestos also requires agency notification. In accordance with this rule, a work plan must be submitted to the PREQB 30 days prior to starting work on materials containing asbestos. In addition, local Law Number 9, titled the Environmental Public Policy Act of June 18, 1970, requires the evaluation of the project to determine the potential environmental impact. Once the project is evaluated and found not to adversely affect the environment, the proper air emission and special waste disposal permits must be obtained prior to the start of abatement activities.

AP3-Periodic Surveillance and Re-inspection Visual monitoring of ACBM should be accomplished at set intervals. The purpose of this monitoring is to ensure that personnel discover any damaged or deteriorated ACBM as soon as possible. This allows management to take the appropriate corrective actions. Both the custodial and maintenance staff should monitor the condition of asbestos in their work areas. In the event of a problem, such as the deterioration of insulation around a pipe, the staff should contact their supervisor and the APM as soon as possible.

Periodic Surveillance Periodic surveillance should be conducted at least every 6 months. The surveillance should include visual observations recorded on a periodic surveillance form (refer to AP5, Form 5) that should be turned in to the APM.

No formal training requirements exist for conducting this surveillance program. It is recommended, however, that the personnel who will conduct the periodic surveillance attend an EPA-accredited training class for an asbestos

Inspector/Management Planner. When conducting periodic surveillance, it is important to note key information such as:

Building number

Building name

Location of the facility

Location of the specific area

Number of the area (if applicable)

Any changes to the condition of the area, e.g., type of work that is being conducted in area

Any changes in the condition of the ACBM

All of this information is important, but the most important information is the location of the ACBM and its condition.

Re-inspection Program A complete re-inspection of the facility should be conducted at least every 3 years and completed by a certified asbestos Inspector/Management Planner. A re-inspection form is located in AP5 (Form 6). During a re-inspection, the majority of the information is the same as in the periodic surveillance. The primary difference when conducting a re-inspection is that in addition to noting the condition of the material and the friability, the inspector must also note the potential for disturbance and give a response action to the material. At this time, The O&M Plan and asbestos inventory should be updated to show the newest changes found during the re-inspection. These re-inspections ensure that the O&M Plan can be kept current to show any changes in the response actions, condition of the

ACBM, and the use of the functional space in which the ACBM exists. Any of these areas can be used to identify the possibility of a new hazard in the facility.

AP4-Work Permit Program This procedure is used as the basis for determining the proper response by the APM to ensure that ACBM is handled in a manner that minimizes the potential for exposure. A work permit program is implemented by the APM to control and prevent disturbances of ACBM during maintenance, renovation, and remodeling work. The APM requires that a Job

Request Form for Maintenance Work (Form 7 in AP5) be submitted prior to any work occurring which may impact building materials within the facility.