Atch 05 - FA2523-09-R-0001 CEV-15A Asbestos Mgmt Plan 01 July 08 Final

Contract No. FA2523-05-C-9001 01 July 2008

FINAL

ASBESTOS MANAGEMENT PLAN

Thule Air Base

CDRL CEV-15A

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629-3840 ext. 2698 Supersedes CDRL CEV-15A, 01 July 2007 edition

CDRL CEV-15A Asbestos Management Plan

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TABLE OF CONTENTS

1.0 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2.0 REGULATORY BACKGROUND

2.1 Purpose

2.2 Scope

2.3 Regulatory Overview

3.0 REQUIREMENTS

3.1 Asbestos Abatement

3.2 Asbestos Removal

3.3 Facility Management

3.4 Demolition or Renovation of Facilities

4.0 ORGANIZATIONS AND RESPONSIBILITIES

4.1 General

4.2 Installation Commander, 821 ABG/CC

4.3 Greenland Contractors, GC

4.3.1 Base Civil Engineer, GC/CE

4.3.2 Engineering Superintendent, GC/CEME

4.3.3 Asbestos Program Officer, GC/SE

4.3.4 Chief of Environmental Engineering, GC/CEE

4.3.5 Operations Manager, GC/OPS

4.3.6 Asbestos Operating Officer, GC/OJP

4.3.7 Asbestos Abatement Team Leader, GC/OPS

4.3.8 Base Hospital, GC/SG

4.3.9 Personnel & Administration, GC/DP

4.4 Asbestos Management Team

4.5 Seasonal Contractors

4.6 Multi-employer Worksites

5.0 ORGANIZATIONAL STRUCTURE

6.0 HISTORICAL SITUATION

7.0 CORRECTIVE ACTION AND DISPOSAL

7.1 Corrective Action

7.2 Disposal

8.0 EMERGENCY RESPONSE

8.1 Emergency Response Actions

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9.0 NOTIFICATION AND EDUCATION

9.1 Warning Signs

9.2 Asbestos Information

10.0 PERSONNEL QUALIFICATIONS, ASBESTOS OPERATION

10.1 Asbestos Work Classification

10.2 Asbestos Abatement Team Member Qualifications

10.3 Asbestos Abatement Team Leader Qualifications

10.4 Qualifications of Other On-Site Representatives

10.5 Training requirements for custodial and maintenance staff

11.0 WORK PRACTICES

12.0 TRANSPORTATION AND DISPOSAL

12.1 Disposal Arrangements

12.2 Transportation and Disposal of Asbestos Waste

12.3 Record Keeping

12.4 Data Management

12.5 Data Updates

12.5.1 Abatement Projects

12.5.2 Periodic Re-inspections

13.0 HEALTH AND SAFETY

13.1 Medical Surveillance

13.2 Personal Protective Equipment

14.0 WORK CONTROL PROCEDURES

14.1 Planning and Scheduling

14.2 Verification/Certification

14.3 Clearance sampling procedure

15.0 CONTRACTING PROCEDURES

15.1 Contracting Procedures and Provisions

15.2 Regulatory Compliance

15.3 Monitoring During Contract Performance

15.4 Post Project Inspection

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1.0 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The title of this document is Asbestos Management Plan. The acronym AMP will be used throughout the document.

Classification: This document is unclassified.

Responsibilities: Greenland Contractors, Environmental Engineering (GC/CEE) and Occupational Health & Safety (GC/OSH) are the offices of primary responsibility for developing and maintaining the AMP. The instructions given in this plan are applicable to all organizations and tenant units at Thule AB. Organizations are authorized to extract and reproduce those sections of the AMP that are essential in the accomplishment of necessary planning and in the preparation of supporting documents and reports.

Reviews/Changes: The AMP will be reviewed and updated annually IAW the CDRL and distributed accordingly. A draft is submitted to the requiring office, 21 CES/CEANN, by 1 Nov for review. Review comments, if any, will be provided by 21 CES/CEANN within 60 days. Review comments received will be incorporated in the final version of the plan within 30 days; thereafter the document will be submitted to 821ABG/CC for signature. The signed plan will then be submitted as the Final edition.

Furthermore, the plan is subject to change if any of the applicable laws, regulations, or requirements are altered.

References: References referred to in the AMP do not appear in the plan, but they may be accessed through GC/CEE or GC/OSH or the Air Force Electronic Publication Library (AFEPL).

Distribution: The plan is distributed IAW the CDRL Summary distribution list.

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2.0 REGULATORY BACKGROUND

2.1 Purpose

The purpose of the AMP is to document the progress of the Asbestos Management Program toward elimination of adverse affects of friable asbestos on human health and the environment.

The documentation will include:

Identification and enumeration of all asbestos containing material (ACM) at Thule Air Base.

Characterization of hazards associated with ACM according to the condition of the ACM.

Identification of all managerial tasks associated with the planning, conduct and documentation of abatement or removal of ACM.

Identification of survey requirements.

Identification and assignment of responsibilities for implementation of proper procedures associated with asbestos operations and emergency response actions to ensure maximum protection of human health and the environment.

2.2 Scope

The provisions of the AMP apply throughout Thule Air Base and to all personnel. Certain responsibilities are specifically assigned to selected individuals identified in the plan. Although the contents of the AMP are limited to asbestos management, the following related plan was developed to cover other functions and may need to be consulted:

Solid Waste Management Plan CDRL CEV-15E

2.3 Regulatory Overview

The Final Governing Standards (FGS) contains the criteria to control and abate threats to human health and the environment from asbestos, and describes management of asbestos during removal and disposal. The criteria within the FGS is included in the AMP, as are parts of the US Federal Laws, Danish Working Environment Act and regulations.

US Federal Laws: 40 CFR, Part 763.80 to 763.95 and Appendix A and E, Asbestos

Thule AB: Final Governing Standards for Environmental Protection by United

States Forces in Greenland (FGS), Chapter 15.

Environmental Protection Committee (EPC) Decisions

Danish Regulations: Den danske arbejdsmiljølov. (Danish Working Environment Act).

Arbejdstilsynets bekendtgørelse nr. 1502 af 21. december 2004 om asbest. (Executive Asbestos Order No. 1502 of 21 December 2004 by The Danish Working Environment Authority).

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Arbejdstilsynets bekendtgørelse nr. 993 af 1. december 1986 om registrering m.m. af asbest. (Executive Order No. 1502 of 1 December 1986 by The Danish Working Environment Authority, Registration etc. of asbestos.)

At-Vejledning C.2.2 Asbest, Juli 2005 (Asbestos Guideline C.2.2 Asbestos July 2005 by Danish Working Environment Authority).

At-Vejledning D.7.2 Arbejdshygiejniske dokumentationsmålinger, maj 2001 (Asbestose Guideline D.7.2 Occupational Hygienic Documentation Measuring, May 2001 by Danish Working Environment Authority).

Host Country: Greenlandic Working Environmental Authority has the jurisdiction concerning all working environmental issues on TAB.

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3.0 REQUIREMENTS

3.1 Asbestos Abatement

The FGS contains criteria to control and abate threats to human health and the environment from asbestos, and describes management of asbestos during removal and disposal. The FGS, Chapter 15, points out “Policy requirements for a comprehensive Occupational Health and Safety program are not covered in this Chapter”.

3.2 Asbestos Removal

ACM, which is likely to release airborne asbestos fibers that cannot be reliably maintained, repaired, or isolated, must be removed according to Danish Working Environment Act.

Assessments will be performed by the Greenlandic Authority or by the Asbestos Program Officer (APO) and the Base Civil Engineer (BCE), based on a direct evaluation of the facility.

When there is no mandate to remove or repair damaged friable asbestos containing material (ACM), the risk to facility occupants, use of the facility, feasibility of repair, frequency of repair and the cost-effectiveness must be evaluated when deciding whether to remove or repair damaged friable ACM.

In planning for maintenance and military construction activities and when safety and budgetary considerations permit, include complete removal of asbestos containing material in facility projects.

Existing ACM must be removed at opportune times during minor construction or repair.

3.3 Facility Management

Facilities where ACM is located must be monitored closely to ensure asbestos-containing materials do not become airborne by:

Promptly assessing visible damaged building materials in facilities to determine friable asbestos material content and ensure quick repair of such material by qualified personnel.

Assessing sprayed-on, toweled, and easily damaged building materials to determine friable asbestos content. Inspect friable asbestos containing material routinely and maintain the material in good condition.

3.4 Demolition or Renovation of Facilities

Prior to demolition or renovation of a facility that involves removing or disturbing friable ACM, a written assessment of the action will be prepared and furnished to the Installation Commander.

Before disturbing or demolishing a facility or part of a facility, installations must remove all friable ACM, or ACM that is likely to become friable once disturbed during demolition.

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4.0 ORGANIZATIONS AND RESPONSIBILITIES

4.1 General

An effective Asbestos Management Program at Thule Air Base (TAB) requires the participation of several organizations.

At base level the Base Civil Engineer (BCE) and Occupational Safety & Health (GC/OSH) have the primary responsibility for developing and implementing the asbestos management at TAB.

Other organizations must assist the BCE and GC/OSH in carrying out the objective of the Asbestos Management Program.

4.2 Installation Commander, 821 ABG/CC

The Installation Commander has the overall responsibility for the revision and coordination of asbestos management at TAB, and will chair the Environmental Protection Committee (EPC).

4.3 Greenland Contractors, GC

Greenland Contractors are responsible for the development and execution of an Asbestos Management Program. Furthermore, Greenland Contractors must, according to legislation, ensure that no one is exposed to asbestos fibers. This program includes the development of an Asbestos Management Plan (AMP).

4.3.1 Base Civil Engineer, GC/CE

The responsibilities of the Base Civil Engineer (BCE) include:

Appoint a Project Coordinator (PC), an Asbestos Program Officer (APO), and an Asbestos Operating Officer (AOO).

Outline the organizational structure for carrying out asbestos related work.

Examine the damaged ACM with the APO in order to decide whether repair, maintenance, or removal of the material is necessary; and whether removal of personnel from the area, temporary controls, or other protective measures are necessary to protect personnel until recommended actions are completed.

Develop procedures to ensure all work orders and projects developed by Thule AB Civil Engineering, which involve asbestos abatement or removal, are reviewed by the APO for compliance with the Work Practices, APPENDIX 4.

Determine whether asbestos-related work will be carried out with Base Maintenance Contract (BMC) resources or by contract.

Identify training requirements exceeding in-house capacity to the Administrative Contracting Officer (ACO).

4.3.2 Engineering Superintendent, GC/CEME

The responsibilities of the Engineering Superintendent (ES), in accordance with requests from the USAF, include:

Prepare an estimate of the quantity of ACM present.

Establish plans and/or procedures for abatement or removal of the ACM present.

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Prepare an estimate of the costs of abatement or removal of the ACM.

Act as focal point for all seasonal contractors performing asbestos work.

Ensure seasonal contractors observe contract specifications to avoid non-compliance with regulatory statutes and relevant standards for work performances, use of protective equipment, demands for worker and supervisor training, work place surveillance, and clearance sampling after conclusion of asbestos work.

Ascertain whether the seasonal contractors are in compliance with this plan, and ensure asbestos regulations are adhered to in accordance with the AMP.

Ensure a sufficient number of in-house technicians are trained.

4.3.3 Asbestos Program Officer, GC/SE

The responsibilities of the Asbestos Program Officer (APO) include:

Maintain and update the AMP.

Act as chairman of the Asbestos Management Team (AMT).

Act as the focal point of contact for asbestos related issues.

Review plans for modifications or altered use of existing facilities to ensure the plans involve no risk of friable asbestos release.

Review all project-material technical specifications.

Receive and file updated asbestos information in the ADAM database.

Develop and implement training programs for in-house personnel.

Examine visibly damaged ACM and presumed asbestos containing materials (ACM) to decide whether repair, maintenance, or removal of materials is necessary; and whether extraordinary precautions, such as frequent monitoring, removal of personnel from the area, temporary controls, or other protective measures are necessary to protect personnel until recommended actions are completed.

Determine the asbestos work classification and identifying the regulatory work procedures.

Ensure that all asbestos work is performed in accordance with current legislations.

Sample of suspected ACM within in-house capacity (not identified in the base-wide asbestos survey performed by Pacific Environmental Services (PES) in May-June 1993 or previous asbestos surveys), and submit samples to the USAF AFIOH Laboratory, Brooks AFB, Texas or other accredited laboratory – accredited by the National Bureau of Standards. In some cases GC have used the Danish laboratory company Eurofins A/S

Eurofins laboratories in Denmark are accredited by DANAK - The Danish Accreditation Scheme - to perform sampling, measurements and laboratory analysis in accordance with a comprehensive quality assurance system meeting the requirements of ISO 17025.

This accreditation is internationally accepted according to mutual agreements between the accreditation bodies in most countries in Europe and Asia as wll as USA, Canada, Australia, Brasil, Mexico, and South Africa. The company is among the group of laboratories in the European Community which certify reference materials for use in various environmental analyses. Eurofins also produces reference materials for sale to other laboratories.

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Perform area sampling for clearance purposes after asbestos abatement operations have been completed.

Prepare and coordinate the facility survey schedule with the implementing parties, as well as contacting the Real Property Officer to ensure all facilities are included.

Obtain asbestos information through the base wide asbestos survey performed by Pacific Environmental Services (PES) in May-June 1993, or through previous asbestos surveys for survey preparation purposes.

Identify all the asbestos-related work found during the survey on the Facility Inspection Record Form and stating whether or not the friable ACM is in good condition.

Inspect whether proper warning signs are posted. The signs must be posted near the main entrance to buildings where asbestos containing materials have been registered and at the entrance to mechanical rooms.

Carry out the day-to-day contact with the Asbestos Management Team.

In addition, for employees involved in asbestos work within the in-house capacity:

Identify medical surveillance requirements to be incorporated in the Respiratory Protection Program and in relation to asbestos-related work.

Identify required personal protective equipment (PPE) including proper respiratory protection, and providing fit testing of respiratory protective equipment.

Ensure that personnel monitoring is performed, by air sampling, in order to determine employees’ exposure to asbestos and non-asbestos fibers.

Maintain on file all work performed by Danish or Greenlandic employees for review by the Working Environment Authority of Greenland.

Notify the Asbestos Abatement Team Leader (AATL) of monitoring results that represent the Asbestos Abatement Team (AAT) members’ exposure.

4.3.4 Chief of Environmental Engineering, GC/CEE

The Chief of Environmental Engineering is responsible for:

Review all project-material technical specifications to ensure compliance with the AMP.

Conduct spot checks at the asbestos landfill in the summer months.

Evaluate the requirement for further environmental analysis based on AF Form 813 inputs.

Ensure that an AF Form 813 (Request for Environmental Impact Analysis) be prepared for any work requests involving removing or disturbing friable ACM during demolition or renovation of facilities.

4.3.5 Operations Manager, GC/OPS

The responsibilities of the Operations Manager include:

Appoint an Asbestos Abatement Team Leader (AATL), for in-house capacity asbestos removal, encapsulation, repair and clean up, for each shop within GC Operations. The AATL will be responsible for performance of asbestos related work.

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4.3.6 Asbestos Operating Officer, GC/OJP

The responsibilities of the Asbestos Operating Officer (AOO) include:

Act as a member of the AMT.

Identify worker manuals or written procedures based on the class identification of the asbestos work to be performed as determined by the APO.

Manage equipment and supply requirements.

Implement procedures for interim control measures and extraordinary precautions.

Manage requirements for special response actions and in-house capacity and capability.

Ensure appropriate document(s) (AF Form 332 and DD Form 1391) are prepared to initiate corrective actions for facilities where damaged friable asbestos has been identified and coordinated with the APO.

Assist the BCE and the APO during the examination of damaged ACM or presumed ACM to decide whether repair, maintenance, or removal of material is necessary.

Provide updated information to the APO when changes in asbestos status occur.

Promptly address any visibly damaged friable ACM or presumed ACM in facilities to the

APO.

4.3.7 Asbestos Abatement Team Leader, GC/OPS

The responsibilities of the GC asbestos abatement team leader (AATL) include:

Establish the Asbestos Abatement Team (AAT).

Manage the Asbestos Abatement Team.

Manage the asbestos equipment bench stock, in cooperation with the other GC/OPS shop AATLs.

Ensure the AAT members are scheduled for the required medical surveillance identified by the Health Services Director on an AF Form 2766, Clinical Occupational Health Examination Requirements.

Maintain training records for each AAT member for one year beyond the last date of employment.

Notify the GC Occupational Safety & Health (OSH) Coordinator on a GC/SG Form 4 prior to performance of any asbestos-related work.

Schedule and performing frequent and regular inspections of the job sites, materials, and equipment to meet the requirement in the Work Practices, APPENDIX 4.

Ensure worker safety and health.

Ensure all asbestos removed from a facility are properly contained and stored in a secured area.

Perform visual inspection with the APO after performance of any asbestos related work to determine whether the work was properly completed.

Notify the AAT members of the monitoring results, which are provided by the OSH Coordinator and represent the AAT members’ exposure.

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The AATL establishes regulated access to work areas where it was determined by the APO that employees are potentially exposed to airborne concentrations of asbestos fibers in excess of permissible exposure levels.

4.3.8 Base Hospital, GC/SG

The Base Hospital performs medical surveillance in relation to asbestos work and use of respiratory protection.

Personnel working under the BMC contract and seasonal contractors covered by the Danish Working Environment Authority Executive Order No. 1502, December 21 2004 will go through a health examination, which meets the relevant regulatory requirements.

4.3.9 Personnel & Administration, GC/DP

The responsibilities of the HR Manager include:

Registration of in-house technicians signed up for the asbestos work training required according to Danish regulations.

Plan and execution of the asbestos work training for in-house technicians in cooperation with the involved organizations.

4.4 Asbestos Management Team

An Asbestos Management Team is established to ensure effective management of asbestos at Thule AB. The team consists of the Asbestos Program Officer (APO), the Asbestos Operating Officer (AOO), and the OSH Coordinator.

The AMT is responsible for:

Ensure that the Thule Air Base Asbestos Management Program is implemented and properly managed.

Address updates to the AMP and the asbestos inventory in ADAM database.

Support the Asbestos Abatement Team (AAT).

Resolve any potential conflicts.

Meet the requirements for multi-employer worksites in accordance with the AMP.

4.5 Seasonal Contractors

Seasonal contractors performing asbestos work will comply with the directions in the AMP under the supervision of the building owner or their authorized representative. Seasonal contractors are responsible for the safety of their workforce, including individual training, identifying required personal protective equipment, ensuring proper respiratory protection, personnel monitoring, medical surveillance, and other legal requirements relating to worker protection, which apply to each seasonal contractor.

4.6 Multi-employer Worksites

On multi-employer worksites, an employer performing work requiring the establishment of a regulated area must inform other on-site employers of the nature of the employer’s work with

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The contractor who creates or controls the source of asbestos contamination must abate asbestos hazards at a multi-employer worksite.

In addition, all employers of personnel exposed to asbestos hazards shall comply with applicable protective provisions.

On a daily basis, all employers of personnel working adjacent to regulated areas established by another employer on a multi-employer worksite must take steps to ascertain the integrity of the enclosure and/or the effectiveness of the control method relied upon by the primary asbestos contractor to ensure that asbestos fibers do not migrate to such adjacent areas.

5.0 ORGANIZATIONAL STRUCTURE

Figure 1: Thule AB Asbestos Management Organization

821st ABG/CC - Installation Commander

821st ABG - Environmental Protection Committee821st SPTS/SG – Public Health QAE

GC/CC - Site Manager

GC/OPS - Operations Manager GC/SG - Health Services Director

GC/SE

OSH Superintendent Asbestos Program

Officer (APO)

GC/CE - Base Civil Engineer

Asbestos Operating Officer

(AOO)

GC/CEE

Chief of Environmental Engineering

GC/SEC

OSH Coordinator

Asbestos Abatement Team Leader

GC/CEME

Technical Dept Superintendent

Asbestos Abatement Team

6.0 HISTORICAL SITUATION

The use of asbestos at Thule was abandoned in 1972. However, as most of the facilities were constructed during the period 1951-1970, asbestos still causes exposure problems in the daily operation at Thule AB, even though removal and small-scale abatement have been performed to some degree over the last few years.

According to Danish laws (Bekendtgørelsen om asbest nr. 1502 af 21 December 2004 and At-vejledning C.2.2 juli 2005) effective at TAB). The use of construction materials containing asbestos in relation to heat, noise and vapor minimizing products was forbidden. In 1980 it became forbidden to use asbestos containing materials except from certain cement products, in 1986 this was prohibition was tighten up.

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From 1993 and up to today, only very few asbestos containing products been accepted from this prohibition. From 2005 it has been forbidden to manufacture, import, use or work with asbestos or asbestos containing materials. It is still allowed to use (to man-handle, remodel products, transport, install and use the material in old buildings) asbestos or asbestos containing materials if installed before 1 January 2005, but it is forbidden to re-use old asbestos containing materials.

At TAB there is no stock of asbestos containing materials, the old asbestos containing materials is not reused and according to the law no new construction materials containing asbestos is imported and used at TAB.

Surveys and sampling in 33 buildings were performed by 5099th CEOS/DEMM, Elmendorf AFB, Alaska, in July-August 1989.

Project WWCX 88-0068, Asbestos Abatement Phase I, covering design and project for 16 buildings, was design completed by Arctic Consultant Group on May 29, 1992, and the abatement took place from 15 July 1993 to 15 January 1994.

In August 1992, 21 CES/DES initiated a survey of 89 sterilized buildings, some of which are committed to demolition. Robert Trudell, 11 CEOS/ DEMM, 21885 2nd Street, Elmendorf AFB, Alaska performed the survey.

A complete base-wide asbestos survey for all facilities still in use was awarded to Pacific Environmental Service. The survey was carried out from 24 May to 25 June 1993. The final reports covering the survey were received in June 1994. The asbestos inventory, as of October 2007, is shown in APPENDIX 3.

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7.0 CORRECTIVE ACTION AND DISPOSAL

7.1 Corrective Action

Asbestos Abatement, Phase II to IV, is on the sustainment funding list for FY-13, under project

no. WWCX 88-0068, Asbestos Abatement, Phase 2 to 4 and currently scheduled for FY-13.

Specific facility numbers in which work will be accomplished will be decided in accordance with the Base General Plan.

Reference is made to Thule Air Base Project Status Report, CDRL CEE-11.

7.2 Disposal

ACM will be disposed of at the Asbestos landfill in the old gravel pit between South Mountain and the abandoned D-launch site, see APPENDIX 5. The ACM disposal landfill is operated according to the directives in the agreement with the Greenland Home Rule Authorities (GHRA).

In August 1993, two asbestos containing buildings scheduled for demolition were cut up and moved to an area southwest of HG-1 where test burning of the asbestos containing buildings was performed. The release of airborne asbestos fibers and asbestos remnants in the debris was monitored during the test burning to determine the feasibility of this way of disposal. The test results indicated that burning would not significantly affect the environment. During FY-95 to FY-97, 85 buildings were thus demolished by burning and the debris disposed of at the asbestos landfill. However, demolition by burning was discontinued after September 1996, as it does not comply with the FGS and GHRA waste disposal regulations.

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8.0 EMERGENCY RESPONSE

8.1 Emergency Response Actions

If ACM is damaged and presents a current hazard of exposure, the area in which it was found must be isolated and access must be restricted immediately. A response action will be selected from among the following: removal, encapsulation, enclosure, or other repair. For purposes of determining the least burdensome response action, local circumstances including occupancy and use patterns within the facility must be considered. A response action must be initiated as soon as possible.

At the conclusion of any action to remove, encapsulate, or enclose ACM, a visual inspection of the area must be conducted to determine whether or not the action was properly completed.

Collection of air samples using aggressive sampling to monitor air for clearance must be conducted to confirm completion of removal, encapsulation, and enclosure.

The action is considered complete when the results of samples analyzed by phase contrast microscopy (PCM), using the National Institute for Occupational Safety and Health (NIOSH) Method 7400, show that the concentration of fibers for each sample is less than or equal to a limit of quantity for PCM (0.01 fibers per cubic centimeter (0.01f/cm3) of air.

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9.0 NOTIFICATION AND EDUCATION

The Thule public’s asbestos awareness contributes to control and abate threats to human health and the environment from asbestos.

In order to notify workers, tenants, and building occupants where potentially friable ACM is located and how and why to avoid disturbing the ACM, warning signs and asbestos information sheets are posted, see APPENDIX 6.

9.1 Warning Signs

Warning signs are posted at the main entrance in all buildings at TAB. The warning signs are generated through the asbestos database (ADAM) and gives a total list of the ACM found in the building, and its placement. As given in Appendix 3: Asbestos inventory, some buildings have not been surveyed and may contain ACM although no warning signs have been posted. The normal practics at TAB regarding these buildings is that whenever construction and repair in these buildings are required the building is handled as containing asbestos material. The construction and repair is monitored closely by the Asbestos Program Manager, and if materials containing asbestos is found, correct handling procedures is put into action. In case of doubt, consult the Asbestos Program Officer (APO).

9.2 Asbestos Information

The asbestos information is distributed to all organizations on Thule AB. The asbestos information tells building occupants where information on ACM registered in the building is present; the health risk associated with asbestos exposure, procedures to control asbestos fibers releases, and the procedure for reporting damaged ACM.

Asbestos Awareness training for employees engaged in routine maintenance and custodial works follow the Danish Regulations: Danish Working Environmental Act, and Executive Order

no. 1502, 21 December 2004 by Danish Working Environmental Authority.

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10.0 PERSONNEL QUALIFICATIONS, ASBESTOS OPERATION

Personnel working under the BMC contract will be responsible for their workforce being adequately trained for asbestos work in accordance with Danish Working Environment Act, Danish Working Environment Authority, Executive Order No. 1502, 21 December 2004 and FGS requirements. Seasonal contractors not covered by the Danish Working Environment Act, Danish Working Environment Authority, Executive Order No. 1502, 21 December 2004 will themselves be responsible for their workforce being adequately trained for asbestos work in accordance with FGS requirements.

Training records of personnel working under the BMC contract are filed in the Environmental Engineering trainings database. The database is maintained and operated by Environmental Engineering and Occupational Health & Safety.

10.1 Asbestos Work Classification

Class I: activities involving the removal of Thermal System Insulation (TSI) and/or surfacing

ACM and presumed ACM.

Class II: activities involving the removal of ACM, which is not TSI, or surfacing material.

Class III: repair and maintenance operations where ACM, including TSI and surfacing ACM and presumed ACM, are likely to be disturbed.

Class IV: maintenance and custodial activities during which employees contact but do not disturb ACM and presumed ACM, and activities to clean up dust, waste and debris resulting from Class I, II, or III activities.

“Small-scale, short-duration activities (SSSD)” are tasks defined in 40 CFR part 763, Subpart E.

10.2 Asbestos Abatement Team Member Qualifications

Prior to any actual asbestos related work (repair, maintenance, encapsulation, enclosure and removal of ACM), qualified AAT member must successfully complete the following:

Special asbestos worker training.

A medical examination.

A respiratory fit-test.

Pre-activity safety briefings.

10.3 Asbestos Abatement Team Leader Qualifications

AATLs for asbestos work must receive training as mentioned for an Asbestos Abatement Team member and meet the criteria for a competent person.

A competent person is one who is capable of identifying existing asbestos hazards in the workplace, capable of selecting the appropriate control strategy, and having the authority to take prompt corrective measures.

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10.4 Qualifications of Other On-Site Representatives

The APO, OSH Coordinator, and AOO are managerial and inspection personnel working under the BMC contract, and must receive training to meet the qualifications to perform their assigned duties according to the AMP and regulations.

10.5 Training requirements for custodial and maintenance staff The Asbestos Program Manager or GC’s OSH Coordinator is giving asbestos awareness courses to the relevant staff groups on their requests. It is the different staff groups who own responsibility to contact the Asbestos Program Manager or GC’s OSH Coordinator when in need of a asbestos awareness courses. The course is given on request.

The Asbestos awareness course gives an introduction to

General information on asbestos Health effect when exposed to free asbestos fibers Presentation of ACM’s How to act when damage ACM’s is found

The Asbestos Program Manager has in December 2008 introduced a pamphlet also giving this information. The pamphlet has been distributed through out TAB December 2008, and is hereafter distributed to the participants at the asbestos awareness course.

11.0 WORK PRACTICES

There are five abatement options to consider:

Maintenance Repair Encapsulation Enclosure Removal

Regardless of exposure levels, required control methods apply to all activities.

To ensure that ACM is properly cared for and inspected, all personnel must be aware of ACM or have AMT to identify ACM in their work area. Early maintenance of ACM will minimize occupants’ and workers’ risk of exposure to airborne fibers.

For asbestos work performed without establishment of Negative Pressure Enclosure (NPE) systems, the asbestos work must to the extent feasible be performed using local exhaust ventilation with outlet through a HEPA filtration unit. The use of the HEPA filtration method is used by GC and external contractors. If the negative pressure method is in use it is a method used by a Seasonal contractors and therefore not a responsibility of GC/CEE.

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12.0 TRANSPORTATION AND DISPOSAL

12.1 Disposal Arrangements

At Thule Air Base, an area for asbestos waste disposal has been established on the southwest corner of South Mountain, APPENDIX 5. The GC/OPS Manager has the overall responsibility for the proper disposal of asbestos waste at the asbestos waste landfill. GC/OMPG, Pavements & Grounds, performs registration and daily operation of the asbestos landfill.

The following operational procedures apply for the asbestos waste disposal area:

The asbestos waste disposal landfill will receive only asbestos waste.

Signs will be placed around the perimeter of the area, warning the public of the location and the potential associated dangers. The area is marked on base maps and records.

Only trained and appropriately protected personnel will accomplish placement of asbestos waste. At the end of each day asbestos waste is placed in the landfill, and is covered with 6-12 inches of soil.

When permanently closed, the asbestos waste landfill will be covered with a 2-3 foot layer of soil over the entire area. Future maintenance of the landfill would then be turned over to GHRA in accordance with provisions of the Memorandum of Understanding.

12.2 Transportation and Disposal of Asbestos Waste

Asbestos is a material that represents a danger to human or animal life. Storage containers holding asbestos will be labeled in English and the host nation languages: “DANGER – CONTAINS

ASBESTOS FIBERS – AVOID CREATING DUST – CANCER AND LUNG DISEASE HAZARD.”

As according the Danish laws (Bekendtgørelsen om asbest nr. 1502 af 21 December 2004 and At-vejledning C.2.2 juli 2005) effective at TAB).

All asbestos waste, which includes protective clothing, disposable respirators, brooms, wiping rags, vacuum filters, floor sweepings, etc., must be collected and double bagged in air-tight and puncture resistant disposal bags. During this collection the ACM waste is adequately wet. The bags will be labeled and decontaminated by HEPA vacuuming and wet wiping.

During winter, soil will freeze and the asbestos waste cannot be covered as required in accordance with the Final Governing Standards. The asbestos waste landfill is therefore closed during the storm season from 15 September to 15 May. As soon as possible in the season, the asbestos waste will be properly disposed in a designated landfill that meets the requirements of the FGS.

Minor amounts of asbestos waste, generated during the winter season, are stored in leak-tight containers at Bldg. 571 until the end of the storm season.

The asbestos waste generators are responsible for the transportation of the asbestos waste to the asbestos waste landfill. In order to ensure that the asbestos waste is covered with soil, an appointment must be arranged with the GC/OMPG, Pavements & Grounds Supervisor, who will ensure that the asbestos waste is covered with soil by the end of each workday.

Contract No. FA2523-05-C-9001 22 01 July 2008

Prior to transportation, the employee who is transporting the asbestos waste must ensure it is properly contained in leak-tight containers with appropriate labels, and that the outside surface of the containers are not contaminated with asbestos debris adhering to the container.

If there is reason to believe that the condition of the asbestos waste may allow significant fiber release, the employee in charge of transporting it must not accept the waste for transport and disposal.

In order to ensure that the asbestos fibers are contained, the AOO must be contacted. The AOO will identify the proper control measures and ensure that the identified control measures are coordinated with the APO.

Once the employee transporting the asbestos waste is satisfied with the condition of the waste and agrees to handle it, the containers are loaded for transportation. Large amounts of asbestos waste (hot water generators, etc.) generated through in-house activities are transported to the asbestos waste landfill by GC/OMPG, Pavements & Grounds. Large amounts of asbestos waste will be transported on a tractor-trailer and secured by means of straps.

Contractors are responsible for transporting waste to the asbestos waste landfill and for ensuring the condition of the asbestos waste meets the above requirements. The Contractors must inform the Project Coordinator whenever asbestos waste is transported to the asbestos waste landfill and arrange for an appointment with the GC/OMPG, Pavements & Grounds Supervisor.

The employees in charge of transportation are responsible for ensuring the asbestos waste is sufficiently secured during transportation.

12.3 Record Keeping

The APO must ensure records are kept of the amount of asbestos waste disposed in the designated asbestos landfill.

GC/OMPG must ensure proper covering of the asbestos waste at the designated asbestos landfill.

The AATL will keep a log to register the type and amount of asbestos containing waste generated at each asbestos response action. The log must include the following information:

Name, facility no., and phone number of the generator.

The type of asbestos waste materials generated.

If from a demolition or renovation, indication of the amount (cubic meters/cubic yards) of asbestos that is friable or non-friable asbestos material.

The number of containers used to transport the asbestos materials, and the type of container used:

DM – Metal drums, barrels DP – Plastic drums, barrels BA – 6 mil plastic bags or wrapping

Date of disposal at the designated asbestos waste site: The AATL will forward a copy of the log to the APO. At the completion of the asbestos project the AATL for seasonal contractors will forward a copy of the log to GC Environmental Engineering, who in turn will forward a copy to the APO.

Contract No. FA2523-05-C-9001 23 01 July 2008

12.4 Data Management

Asbestos survey data is being managed electronically using the ADAM 7.1 software. The database organizes comprehensive information about ACM and sampled non-ACM for each facility in a form that is accessible and easily updated.

ADAM 7.1 is used in different ways and for different purposes. Some suggestions are listed below:

• Paper reports can be printed and distributed to facility managers to alert them to the ACM conditions and to assist them in their asbestos management efforts.

• Electronic versions of the database can be distributed to facility managers and maintenance coordinators so that prior to a repair or renovation action, the database can be queried to determine if ACM will be affected by desired or required plans. The standard menu interface can be used to request information from the system, or more experienced users can elect to use the custom reporting module to prepare custom search conditions and to print reports.

• As ACM is repaired or removed from a facility, the database can be updated to produce a dynamic record of the current material conditions.

• Determine high priority buildings to target for remediation.

ADAM 7.1 is the central database for information on asbestos and shall be consulted every time work is to be performed at a facility.

Maintaining ADAM 7.1 is the responsibility of APO, AOO, and the AMT. The database shall be updated each time a survey or inspection is conducted and whenever any asbestos removal or repair project is performed in a facility containing ACM. The database shall also be updated when asbestos sampling is conducted. At a minimum, the survey data shall be accessible to the APO and OSH.

12.5 Data Updates

12.5.1 Abatement Projects

Whenever an asbestos removal or repair project is completed, the Civil Engineering Superintendent will provide updated as-built drawings identifying all removed asbestos containing building materials to the APO; APO shall update the asbestos database. The APO shall retain a copy of this written notice to serve as a record of the work performed.

When necessary, the APO shall enter the data to update the ADAM 7.1 database. Once the data has been entered, the APO shall log or sign and date the update information form, indicating that the database has been updated, and retain it with other abatement records associated with that project.

12.5.2 Periodic Re-inspections

Before conducting any periodic re-inspections, the OSH shall generate a "Re-inspection Report" from the ADAM 7.1 database for the building to be inspected. This report lists all of the materials identified in the past surveys with their quantities and GRADE rankings for each of the GRADE factors. With the re-inspection report in hand, the trained asbestos inspector shall

Contract No. FA2523-05-C-9001 24 01 July 2008 inspect the facility, noting any GRADE factors that have changed since the last inspection.

These changes shall then be added to the ADAM 7.1 database.

13.0 HEALTH AND SAFETY

13.1 Medical Surveillance

A medical surveillance program must be established by the employer for all employees, who may be exposed to airborne concentrations of asbestos during work.

The Base Hospital performs medical surveillance for all employees who perform asbestos response actions within in-house capacity, and for employees employed by seasonal contractors, whose contract includes a Government Furnished On-Site Support Agreement for medical surveillance. Other contractors are responsible for the establishment of a medical surveillance program and for maintaining a record for each employee subject to medical surveillance in accordance with requirements set forth in the AMP.

The records from medical examinations must be maintained for the duration of employment plus 40 years.

The records from medical examinations will be kept on file indefinitely at the Base Hospital.

13.2 Personal Protective Equipment

Personal protective clothing such as coverall or similar full-body clothing, head coverings, gloves, and foot coverings are required:

For any employee that during work might be exposed to airborne concentrations of asbestos.

Where the possibility of eye irritation exists, face shields, vented goggles, or other appropriate protective equipment must be provided and worn.

No worker designated to work with asbestos must enter a work area without having received training in the selection, use, care, and limits of respirators. Only respirators approved by MSHA, NIOSH or the European Community may be used on asbestos work. HEPA filters must be used as a minimum protection.

Employees assigned to asbestos work are responsible for their own respirator.

It is the employer’s responsibility to ensure that the employees are fit-tested upon assignment to asbestos work and then every six months.

The OSH Coordinator will perform respiratory protection training and respirator fit-test for employees performing asbestos response actions within in-house capacity and determine the requirement for other personal protective equipment.

Seasonal contractors must ensure the safety and health of their employees performing asbestos response actions and ensure that the required personal protective equipment is used.

Contract No. FA2523-05-C-9001 25 01 July 2008

14.0 WORK CONTROL PROCEDURES

14.1 Planning and Scheduling

Any visible damaged friable ACM or presumed ACM in facilities must be reported to the APO immediately. The APO and the AOO will decide whether repair, maintenance, enclosure or removal of material is necessary, and whether extraordinary precautions, such as frequent monitoring, removal of personnel from the area, temporary controls, or other protective measures are necessary to protect personnel until recommended actions are completed.

The Air Force Asbestos Guidance for Rating and Assessing Damage and Exposure (GRADE) System in accordance with USAFOEHL Report 86-072EH0021HGA, Aug 86 is a helpful tool for classification of the asbestos-related work. The priorities are shown in Figure 2.

Figure 2: Priorities of Classification

No. R Value Condition Action

1 R < 6 ACM is damaged and presents a current hazard of exposure.

Must be scheduled for immediate removal or alternatively, abatement.

2 6 < R < 7 ACM is damaged but does not pose an immediate exposure risk.

Must be treated as soon as possible.

Inspect: Semiannually

3 7 < R < 10 ACM is in good condition and does not pose a threat.

Must be removed when opportune to do so as part of the regular maintenance and repair cycle.

Inspect: Semiannually

4 R > 10 ACM is in good condition and should not pose a threat as long as it remains undamaged.

There is no priority to remove it, and it may remain in place until the facility is scheduled for demolition (or until it can be efficiently removed as part of a repair or construction project).

Inspect: Annually

For example: Asbestos jobs identified as priority 1 must receive emergency attention, and priority 2 must receive urgent action.

The R-values to be used in figure 2 are found by using the AF Asbestos GRADE checklist.

Job Planning is responsible for the scheduling of repair, encapsulation, enclosure or removal of any ACM within in-house capacity.

Through the weekly Work Order coordination meetings, AF Form 332 Civil Engineering Work Request, which includes asbestos repair/encapsulation, enclosure or removal, will be identified.

All AF Forms 332, which have been identified to involve asbestos response actions, must be coordinated with the AOO.

Installations will remove friable ACM when it poses a threat to release airborne asbestos fibers and cannot be reliably repaired or isolated.

Contract No. FA2523-05-C-9001 26 01 July 2008

If exposure to asbestos is uncertain or asbestos exposures potentially exist, Civil Engineering planners must check for the presence of ACM and whether the type of work being performed on ACM may generate friable asbestos.

Before disturbing or demolishing a facility or part of a facility, installations will remove all friable ACM, and ACM with a high degree of probability of becoming friable once disturbed during demolition.

All asbestos work to be performed by seasonal contractors must be reviewed by the Contract Manager for compliance with the AMP.

The APO must review all project material technical specifications to ensure compliance with the

AMP.

The Facility Board is responsible for priority ranking of projects.

14.2 Verification/Certification

Every repair or renovation project of a facility must be reviewed for the presence of asbestos.

Pacific Environmental Service performed a base wide survey for the presence of asbestos in buildings at Thule AB in May - June 1993. The inventory was received in June 1994. The results are collected in an asbestos database located at the GC/OSH office. The registry is maintained at Thule AB for use in planning asbestos work. The database has not been updated, but as changes occur, the database is supplemented with hardcopies also filed at the office of GC/OSH. The APO receives the updated information from the AOO as changes occur.

The register will aid in the verification of the presence of asbestos early in programming projects and work requests. The register will also provide information to the AAT before starting asbestos jobs, to prevent any unforeseen exposure to asbestos.

In the event no asbestos information is available through the asbestos database ADAM or when the determination of the presence of asbestos is uncertain, the work must be planned as if asbestos be involved. Otherwise, a sample of the material must be collected and sent for analysis. The test result will provide information whether the work must be planned as an asbestos work or not.

14.3 Clearance sampling procedure

When necessary, The Asbestos Program Manager in GC/CEE or GC’s OSH Coordinator will perform a final clearance of the work site for asbestos containing material repair or removal. The effort is coordinated between the two offices GC/CEE and GC/OSH.

A final clearance is conducted using the…