Attach_I_-_SOW_Attachment_8.pdf

UNCLASSIFIED/FOR OFFICIAL USE ONLY

ASBESTOS MANAGEMENT AND

OPERATIONS PLAN

EAFB PLAN 32-3

April 2015

96TH TEST WING

EGLIN AIR FORCE BASE

(THIS PAGE INTENTIONALLY LEFT BLANK)

DEPARTMENT OF THE AIR FORCE

HEADQUARTERS 96TH TEST WING (AFMC)

EGLIN AIR FORCE BASE FLORIDA

SECURITY INSTRUCTIONS AND RECORD OF CHANGES

1. The long title of this document is Eglin Air Force Base (EAFB) Asbestos Management Plan. The short title is EAFB Plan 32-3. Both titles are unclassified.

2. This plan is unclassified and may be reproduced, in whole or in part, without written permission of the OPR.

3. Operations Security (OPSEC) has been considered in the development of this plan. All organizations tasked by this plan will ensure necessary action is taken to safeguard any operational and communications information that might fall within the scope of the OPSEC program in accordance with AFI 10-701, Operations Security (OPSEC).

4. Distribution Policy Change. In following Air Force and Air Force Materiel Command’s lead, hard copies will no longer be distributed. Plans will be located on the Emergency Network and the

Eglin Installation Plans SharePoint site. The plan OPR is responsible for providing copies of this plan to those customers with the need to know, but without access to these sites.

5. Plan Changes. If a change to the content of this plan is required, change requests will be submitted to the plan OPR.

RECORD OF PLAN CHANGES

Change No. Dated Date Posted Posted By

PLAN SUMMARY

1. PURPOSE: This plan establishes procedures for the Eglin Air Force Base facility asbestos management program. It contains the policies and procedures used in controlling the health hazards created by asbestos containing materials (ACM) and the procedures used in ACM removal required to protect the health of personnel and to comply with applicable federal, state and Air Force laws and inspections. This plan also incorporates an asbestos survey, which is continuously updated to identify the location of ACM that contains one percent or greater asbestos fibers. This survey is available for consultation and can only be accessed by 96th Civil Engineer Group, Engineering

Division (96 CEG/CENP), 96th Aerospace Medicine Squadron, Bioenvironmental (96 AMDS/

SGPB) and Environmental Management’s Environmental Compliance Office (96 CEG/CEIEC).

This plan also addresses health hazards to building occupants and maintenance personnel. The duties of all individuals and organizations that support the asbestos removal efforts are also incorporated in this plan.

2. EXECUTION:

2.1. Each building must be surveyed for the presence of asbestos containing materials prior to any renovation or demolition activity. The installation-wide asbestos survey is a continuous effort and not a process expected to be completed. The facility database is available for consultation from

96 CEG/CEIEC located in building 592 and can be accessed by personnel in building 690, 796 CES/CEOE and at building 635, 96 AMDS/SGPB.

2.2. Surveys for asbestos in child development centers will be conducted in accordance with EAFB

Plan 32-3, page 27.

2.3. ACM is managed in-place using approved removal or containment methods; for example, encapsulation, repair and/or inspection.

2.4. Removal of friable asbestos prior to renovation is an option. It is mandatory prior to demolition activities.

2.5. The installation-wide asbestos facilities inventory must be continually updated to ensure current ACM information is available when needed.

3. EMPLOYMENT. All persons inspecting for asbestos or designing or conducting asbestos response (removal) actions in public or commercial buildings must be properly trained and accredited through an applicable asbestos training program approved by the state of Florida.

4. OPERATIONAL CONSTRAINTS. Any deficiencies or inaccuracies noted in this instruction must be identified to the 96th Civil Engineer Group Environmental Compliance Office

(96 CEG/CEIEC) at 882-7665.

5. APPLICABILITY. This plan applies to all organizations that have responsibility for

5.1. Building custody.

5.2. Building maintenance.

5.3. Asbestos management/removal.

TABLE OF CONTENTS

CONTENTS PAGE NO

Security Instructions/Record of Changes

Plan Summary

Table of Contents and List of Effective Pages

Acronyms & Terms

Basic Plan

ANNEX A - Tasked Organizations

ANNEXES B - G ............................................................................................................Not Used

ANNEX H - Environmental Services

Appendix 1 - Asbestos Removal Program Management

Appendix 2 - Records Management

Appendix 3 - Federal and Regional Oversight

Appendix 4 - Asbestos Security Container

Appendix 5 – Operations Plan

ANNEXES I - Z................................................................................................................Not Used

ACRONYMS & TERMS

ABATEMENT - Procedures to control fiber releases from asbestos-containing materials to include encapsulation, repair and enclosure.

A-C - Asbestos Cement

AFI - Air Force Instruction

AFOSH - Air Force Occupational Safety and Health

AFOSH STD - Air Force Occupational Safety and Health Standard

AMP - Asbestos Management Plan

AOO- Asbestos Operations Officer

AOP - Asbestos Operations Plan

APM - Asbestos Program Manager

APO - Asbestos Program Officer

ART - Asbestos Removal Team

BAI - Base Asbestos Inspector

BCE - Base Civil Engineer

CFR - Code of Federal Regulations

CO - Contracting Officer

EPA - Environmental Protection Agency

FDEP - Florida Department of Environmental Protection

OI - Operating Instruction

OSHA - Occupational Safety and Health Administration

TPO – Toxic Program Officer

EAFB PLAN 32-4

BASIC PLAN

REFERENCES:

Code of Federal Regulations:

29 CFR:

Part 1910.20 - Access to Employee Exposure and Medical Records

Part 1926.58 - Construction Industry Standard

Part 1926.59 - Chemical Hazard Communication

Part 1926.1101 - Asbestos (Construction Industry Standard)

Part 1910.134 - Respiratory Protection

Part 1910.147 - The Control of Hazardous Energy (Lock-out/tag out)

Part 1910.1001 - Asbestos (General Industry Standard)

Part 1910.1200 - Hazard Communication

40 CFR:

Part 61.141 - Definitions

Part 61.145 - Standard for Demolition and Renovation

Part 61.146 - Standard for Spraying

Part 763.83 - Definitions

Part 763.84 - General Local Education Agency Responsibilities

Part 763.86 - Sampling

Part 763.90 - Response Actions

Part 763.91 - Operations and Maintenance

Part 763.92 - Training and Periodic Surveillance

Part 763.94 - Recordkeeping

Part 763.120-123 - Asbestos Worker Protection

49 CFR:

Part 171 - Hazardous Substances

Part 172 - Hazardous Materials Tables and Hazardous Materials

Part 173 - Shipment and Packaging

Subpart M

Part 173 - General Requirements for Shipment and Packaging

Part 177 - Carriage by Public Highway

Air Force:

AFI 32-1052 - Facility Asbestos Management

AFI 32-7001 - Environmental Management

AFI 32-7040 - Air Quality Compliance

AFI 32-7066 - Environmental Baseline Surveys in Real Estate Transactions

AFI 32-7086 - Hazardous Materials Management

AFI 32-9004 - Disposal of Real Property

AFI 48-101 - Aerospace Medicine Enterprise

AFI 90-821 - Hazard Communication

AFI 91-302 -

Air Force Occupational and Environmental Safety, Fire Protection and

Health (AFOSH) Standards

AFMAN 48-146 - Occupational and Environmental Health Program Management

AFMAN 48-154 - Occupational and Environmental Health Site Assessment

AFOSH Std 48-

- Respiratory Protection Program

Florida Department of Environmental Protection (FDEP)

Florida Statutes 255.551 - 255.565

Florida Statutes 469.01

TASKED ORGANIZATIONS: SEE ANNEX A

1. SITUATION:

1.1. Eglin Air Force Base has in excess of 3,000 buildings that may have various ACM installed or controlled during their lifetime and disposed of prior to any demolition. To prevent any accidental release of and exposure to ACM, all personnel, from building occupants to renovation and demolition workers, must be made aware that asbestos exposure is an important health issue. This plan provides the necessary guidance for occupants of buildings that contain asbestos and other personnel that may come in contact with asbestos in the course of their daily work. In addition, this plan outlines those measures necessary for compliance with the Code of

Federal Regulation (CFR), state laws and Air Force directives.

1.2. Assumptions:

1.2.1. Major or minor releases of friable asbestos may temporarily disrupt normal operations.

1.2.2. Acts of nature (hurricanes, tornadoes) may cause accidental releases of ACM that may directly affect Eglin AFB operations.

1.2.3. Eglin AFB will be required to institute clean-up actions for any release that occurs from a facility it controls or maintains.

2. MISSION:

2.1. This plan supports national and regional emission standards for asbestos, Air Force Facility

Asbestos Management, by providing for the discovery, notification, containment and clean-up of releases that may occur on Eglin AFB.

2.2. This plan provides information and procedures for response personnel that must control, contain, abate and/or remove ACM due to accidents, incidents or disasters.

2.3. The policies, responsibilities and procedures in this plan are applicable to base operations and private contractors. This plan has been developed in accordance with (IAW) federal, state and Air Force regulatory requirements.

3. EXECUTION:

3.1. Concept of Operations. Asbestos Management is envisioned to be a continuing process.

3.2. Tasks and Responsibilities:

3.2.1. The 96th Test Wing Commander, as the Installation Commander, has assigned responsibility for development and oversight of the Eglin AFB Asbestos Management Plan

(AMP) to 96 CEG Environmental Management (96 CEG/CEIE). The responsibility for execution of this plan is delegated to the 96th Civil Engineer Group Commander (96 CEG/CC).

3.2.2. The 96 TW/CC will ensure the guidance in this management plan is carried out and will delegate all operations associated with the management of ACM to the 96 CEG.

3.2.3. The 96 CEG/CEIE will provide the Asbestos Program Officer (APO). The APO is the primary individual responsible for oversight of the asbestos program. The APO will:

3.2.3.1. Prepare and maintain the 96 TW Asbestos Management Plan and act as the focal point for asbestos-related issues.

3.2.3.2. Inform the Toxic Program Officer (TPO) on matters related to the status of the

Asbestos Management Program. This includes both regulatory and MAJCOM related issues.

3.2.3.3. Coordinate all Eglin AFB related regulatory enforcement actions with the Florida

Department of Environmental Protection.

3.2.3.4. Coordinate the disposal of asbestos security containers. Note: Class 5 or 6 security containers used for the storage of classified materials/information do not contain asbestos.

3.2.3.5. Review and sign for all asbestos disposal shipping documents (manifests) or authorize, in writing, the Asbestos Operations Officer (AOO) or his designated representative to sign or initial the documents. If an individual other than the APO signs or initials the document, a copy of the document must be forwarded to 96 CEG/CEIEC no later than 5 days after shipment.

3.2.3.6. Each January, provide FDEP a blanket notification of asbestos projects the asbestos team will perform for the year. This is an estimation of the upcoming year.

3.2.4. The 96th Civil Engineer Group Commander will:

3.2.4.1. Develop and implement the asbestos program. Other base organizations must assist the 96 CEG in identification of asbestos in the work place, legal regulatory interpretation and media information and response.

3.2.4.2. Appoint the AOO by letter and ensure he/she is properly trained and supported to carry out assigned responsibilities.

3.2.4.3. Appoint the Base Asbestos Inspector (BAI) and the Asbestos Removal Team (ART) supervisor by letter.

3.2.4.4. Provide for management of the Base Asbestos Database.

3.2.4.5. Decide whether asbestos-related work will be done with in-service resources or by contract.

3.2.4.6. Ensure effective asbestos program participation and interface of various organizations on base.

3.2.4.7. Appoint the TPO.

3.2.4.8. Ensure that the TPO is properly trained and supported to carry out his/her designated responsibilities.

3.2.4.9. Resolve problems adversely affecting the efficiency of the program.

3.2.5. The AOO will:

3.2.5.1. Develop and implement the Asbestos Operations Plan.

3.2.5.2. In coordination with the Bioenvironmental Engineer (96 AMDS/SGPB), ensure the health and safety of all asbestos assigned employees in the organization.

3.2.5.3. Monitor the day-to-day operations of the asbestos program.

3.2.5.4. Ensure the asbestos facilities inventory and database are maintained and updated.

3.2.5.5. Ensure applicable 96 CEG personnel are properly trained and receive annual refresher training to carry out assigned tasks.

3.2.5.6. Serve as co-signature authority for the review and signing of asbestos disposal shipping documents (manifests).

3.2.5.7. Develop and comply with 96 CEG Asbestos Operating Instruction (OI).

3.2.5.8. Determine if removal will be accomplished by ART, on-call contractor, or through separate commercial removal project.

3.2.5.9. Be responsible for preparation of on-call asbestos removal contract.

3.2.5.10. Ensure funds are budgeted for on-call asbestos removal contracts.

3.2.5.11. Maintain effective coordination with other base organizations concerned with asbestos-related issues to include maintenance and disposal of ACM.

3.2.5.12. Resolve problems adversely affecting the efficiency of the program.

3.2.5.13. Ensure APO receives copies of manifests and "Notice of Asbestos Removal Project" that is sent to the state.

3.2.6. The BAI will:

3.2.6.1. Coordinate asbestos health issues with the base Bioenvironmental Engineer

(96 AMDS/SGPB) and other organizations.

3.2.6.2. Assist in developing plans and specifications for asbestos removal projects and construction projects where asbestos will be impacted.

3.2.6.3. In conjunction with the contracting officer, verify contractors and/or sub-contractor’s certification and license for each asbestos removal project prior to project commencement.

3.2.6.4. Comply with the Air Force Respiratory Protection Program.

3.2.6.5. Enroll in the prescribed occupational medical surveillance program.

3.2.6.6. Maintain necessary training certification and annual refresher re-certification.

3.2.6.7. Review projects, work orders and databases for presence of asbestos in buildings for which they are responsible.

3.2.6.8. Conduct ACM assessments with 96 AMDS/SGPB to support work orders and/or projects.

3.2.6.9. Provide database update information after completion of each work order or project to the APO or AOO.

3.2.6.10. Conduct site consultation and inspect asbestos removal sites.

3.2.6.11. Stop/suspend work immediately if contamination of workers and/or government assets is imminent.

3.2.6.12. As the Contracting Officer’s representative, notify the site supervisor and contracting officer immediately if emergency work stoppage/suspension has been imposed.

3.2.6.13. Ensure APO receives copies of manifests and "Notice of Asbestos Removal Project" that is sent to the state. This includes demolitions and renovations that include demolition of load supporting structures. Asbestos does not have to be present for this notification to be sent to the state.

3.2.6.14. Verify contractor and/or sub-contractor certification and license for each asbestos removal project before and at any time during contract performance.

3.2.6.15. Ensure worker protection through confirmation of proper selection of Personal

Protective Equipment (PPE) and enforcement of directives and procedures.

3.2.6.16. Ensure that Florida Department of Environmental Protection (FDEP) is properly notified of impending asbestos projects.

3.2.6.17. Monitor and document expenditures and labor hours consumed in asbestos related tasks.

3.2.6.18. Be available for onsite consultation and inspect asbestos removal sites/work.

3.2.6.19. Provide Bioenvironmental Engineering bulk and air sampling support.

3.2.6.20. Make site inspections to confirm presence of ACM.

3.2.6.21. Notify the site supervisor and contracting officer immediately if emergency work stoppage has been imposed.

3.2.6.22. Ensure necessary records of all asbestos jobs accomplished by separate commercial construction contracts are furnished to AOO to update the asbestos database within ten (10) workdays of asbestos removal project completion.

3.2.7 96 CEG, Engineering Division will:

3.2.7.1. Provide Asbestos Removal Team Supervisor.

3.2.7.2. Provide Base Asbestos Inspector (BAI).

3.2.7.3. Manage the asbestos database.

3.2.7.4. Provide the Asbestos Operations Plan (AOP).

3.2.8. 796th Civil Engineer Squadron may, at its own discretion, furnish the in-house ART.

This team will consist of at least a craftsman and a supervisor. The ART will:

3.2.8.1. Provide (in-house) Asbestos Removal Team (ART) supervisor and craftsmen.

3.2.8.2. Develop and comply with the 96 CEG Asbestos OI.

3.2.8.3. Be responsible for emergency and small job actions and encapsulation, enclosure, removal and disposal of asbestos in a safe and efficient manner as outlined in federal, state and local regulations and instructions.

3.2.8.4. Maintain proper training/accreditation and annual refresher re-certification.

3.2.8.5. Enroll in a medical surveillance and respirator fit program.

3.2.8.6. Select proper protective equipment and enforce its use.

3.2.8.7. Keep records of all asbestos-related jobs and furnish the AOO necessary information to update the facility inventory database.

3.2.8.8. 96 CEG does not currently have an ART. All asbestos abatement activities are contracted to the Indefinite Delivery and Indefinite Quantity asbestos abatement contractor.

3.2.9. The 96 CEG Division Designer/Planner (96 CEG/CEOE) will:

3.2.9.1. Provide engineering oversight and review of all programming, planning and design of asbestos removal projects and other construction projects where existing asbestos in facilities will be impacted.

3.2.9.2. Review and approve all submittals for separate commercial asbestos removal projects.

3.2.9.3. Provide data to the AOO for the asbestos database.

3.2.9.4. Assist the AOO in ACM assessment and in determination of best ACM removal method.

3.2.9.5. Ensure the asbestos designer/planner personnel obtain necessary initial and annual refresher training.

3.2.9.6. Ensure necessary records of all asbestos jobs accomplished by separate commercial construction contract are furnished to the AOO to update the asbestos database.

3.2.9.7. Monitor and document expenditures and labor hours consumed in asbestos-related tasks.

3.2.9.8. Keep records of all asbestos jobs accomplished by the on-call contractor and furnish necessary information to the AOO to update the facility inventory database.

3.2.9.9. For demolitions or renovations involving demolition of a load supporting structure, the state must be notified even when there is no asbestos in the facility. The designer/planner will ensure that 96 CEG/CEIEC receives copies of all notices sent to the state.

3.2.9.10. Review and approve all subcontractors for on-call asbestos removal contracts and separate commercial asbestos removal projects.

3.2.9.11. Provide engineering advice and consultation to TPO, BAI and ART.

3.2.9.12. Provide engineering oversight and assistance in preparation of and obtaining an on-call asbestos contract.

3.2.9.13. Assist the TPO in ACM assessment and in determination of best ACM removal method.

3.2.9.14. Ensure that asbestos design/planning/inspection personnel obtain necessary initial and annual refresher training.

3.2.9.15. Provide BAI for contract projects involving asbestos removal; BAI will comply with responsibilities identified in 2.6.

3.2.10. Toxic Programs Officer (TPO) will:

3.2.10.1. Develop and implement the AOP.

3.2.10.2. Ensure, in coordination with the BE, the health and safety of all asbestos-assigned personnel in the organization.

3.2.10.3. Monitor the day-to-day operations of the asbestos program.

3.2.10.4. Ensure the asbestos database is maintained and updated.

3.2.10.5. Ensure Civil Engineering personnel are properly trained and receive annual refresher training to carry out assigned tasks.

3.2.10.6. Select proper protective equipment and enforce its use.

3.2.10.7. Enroll assigned asbestos personnel in a medical surveillance program.

3.2.10.8. Develop and comply with Civil Engineering Asbestos Operating Instruction.

3.2.10.9. Determine if removal will be accomplished by ART, on-call contractor or through separate commercial removal project.

3.2.10.10. Be responsible for preparation of on-call asbestos removal contract.

3.2.10.11. Ensure funds are budgeted for on-call asbestos removal contract.

3.2.11. 96 AMDS/SGPB will:

3.2.11.1. Advise commanders on regulatory and policy matters and provide technical assistance.

3.2.11.2. Act as a consultant on any site evaluation that involves maintenance repair or minor construction that could result in exposure to asbestos.

3.2.11.3. Approve respirators for base asbestos workers used to protect against exposure and provide respirator fit testing as required by the Occupational Safety and Health Administration

(OSHA) regulations (29 CFR 1910.134).

3.2.11.4. In coordination with CE, obtain bulk and air samples as necessary to quantify potential exposures to DoD and Air Force workers.

3.2.11.5. Coordinate with the AOO.

3.2.11.6. Obtain necessary training certification and maintain annual refresher re-certification.

3.2.12. The 96 AMDS/SGPM will:

3.2.12.1. Enroll personnel engaged in asbestos work in a medical surveillance program per

OSHA regulations (29 CFR 1926.1101).

3.2.12.2. Act as the point of contact for occupational education and provide consultation on training and technical matters to work area/shop supervisors on the AF HAZCOM Program.

While primary responsibility for performing HAZCOM training rests with the work area/shop supervisor, Public Health will make the appropriate training available to work area/shop supervisors in accordance with Air Force Instruction 90-821, Hazard Communication.

3.2.12.3. Coordinate information required to maintain supervisors and workers in the medical surveillance program through the AOO.

3.2.13. The Staff Judge Advocate will:

3.2.13.1. Assess the potential liabilities of all parties involved in asbestos removal (including

Air Force, Air Force contractors and others, as applicable).

3.2.13.2. Advise 96 TW/CC, 96 CEG/CC, 96 CEG/CEIE and user organization commanders on possible claims against the Air Force.

3.2.13.3. Assist in accomplishing enforcement procedures, to include negotiations with FDEP regulators as well as government claims against contractors.

3.2.14. PK (AFLCMC-OL) will:

3.2.14.1. Provide contracting support, as required.

3.2.14.2. Serve as the official office for all contractual records.

3.2.15. Facility Managers will:

3.2.15.1. Stay informed of their building's conditions at all times and periodically inspect areas containing asbestos to ensure deterioration has not occurred. Information on the location of

ACM in a facility may be obtained by contacting 96 CEG/CENP or 96 AMDS/SGPB. An asbestos facility inventory is also located within 96 CEG/CENP.

3.2.15.2. Submit an emergency work order to their respective 96 CEG Service Call Desk if an incident has disturbed (damaged) ACM, or deterioration has occurred which may result in personnel exposure to airborne asbestos fibers.

3.2.15.3. Communicate to building occupants the status of ACM (if applicable) in their respective facility/work area.

3.2.15.4. Maintain a copy of their respective asbestos survey together with other building records.

3.2.15.5. Annually take the Facility Managers training located at the Civil Engineering web site

(https://96ceg.eglin.af.mil/FacMgr_v1.0/), which has the asbestos awareness training in it.

3.2.15.6. Ensure supervisors are kept informed of any conditions associated with asbestos exposure so that employees can be notified and informed of appropriate action to take regarding the filing of an appropriate occupational or traumatic injury claim under the Federal Employees'

Compensation Act (FECA) Program.

4. COMMAND AND CONTROL. In case of an asbestos release incident, notify the Eglin

Command Post at 883-4020.

Annexes:

A--Tasked Organizations

H--Environmental Services

Z--Distribution https://96ceg.eglin.af.mil/FacMgr_v1.0/

ANNEX A TO EAFB PLAN 32-3

TASKED ORGANIZATIONS

All Eglin Air Force Base assigned and attached associate units, tenant units and on-base contractors as required by contract, located on Eglin AFB. All organizations located on Eglin

Air Force Base that are allocated buildings by 96 CEG/CEIAP (Real Property Office) are assigned daily building oversight responsibilities. 96 CEG/CEO has project design oversight.

96 CEG/CEN has daily asbestos operations oversight and contract and inspection responsibilities and maintains the Asbestos Operations Plan and Facilities Inventory database. 96 CEG/CENP has emergency response and small asbestos removal job responsibilities. 96 AMDS/SGPB has sampling and analysis oversight. 96 AMDS/SGPM has medical monitoring program oversight.

96 CEG/CEIEC has overall program oversight responsibility and maintains the Asbestos

Management Plan.

ANNEX H TO EAFB PLAN 32-3

ENVIRONMENTAL SERVICES

REFERENCES: See Basic Plan

1. GENERAL. The purpose of this annex is to assist all affected organizations to successfully resolve asbestos issues. This annex establishes procedures, assigns specific responsibilities and reporting requirements for the accidental release of any asbestos containing material product as provided for in 29 CFR Parts 1910 and 1926, 40 CFR Parts 61 and 763 and AFI 32-1052.

2. SITUATION. Eglin Air Force Base personnel may be required to respond to accidental releases of asbestos and must be prepared to manage such events in a timely and effective manner. Elements of Eglin Air Force Base as well as elements of both federal and state agencies may be called upon depending on the severity of the issue.

APPENDIX 1 TO ANNEX H TO EAFB PLAN 32-3

ASBESTOS REMOVAL PROGRAM MANAGEMENT

1. GENERAL. The Occupational Safety and Health Administration and the Environmental

Protection Agency have promulgated most of the regulations governing asbestos control in the

United States. Responsible Eglin AFB personnel will continually monitor affected buildings, especially during phases of renovation or demolition, to ensure regulatory requirements are observed and accidental releases do not occur.

2. BACKGROUND. Asbestos is a group of naturally occurring minerals that separate into microscopic fibers. Friable asbestos is described as asbestos-containing material that can be crumbled, pulverized or reduced to a powder by mechanical action, such as hand pressure, sanding or cutting. Inhalation of asbestos fibers has been linked to cancer and other diseases in humans. The usage of asbestos is regulated by the EPA, OSHA and the Department of

Transportation (DOT) Codes of Federal Regulation, the Florida Department of Environmental

Protection and Air Force Instructions, Standards and Policies.

3. OBJECTIVES. This management plan is designed to provide a comprehensive program for asbestos management and control on Eglin AFB. The objectives of this plan are to:

3.1. Define requirements for the effective management of asbestos on Eglin AFB.

3.2. Establish a system of identification, evaluation and ranking of asbestos-related hazards so resources can be appropriately applied to address high-priority problems.

3.3. Outline a management program that will provide for routine monitoring of ACM in base facilities. This will ensure existing ACM is maintained in good condition, expedient repairs are accomplished when there is damage and all necessary precautions are taken to minimize the exposure to personnel in base facilities from airborne asbestos fibers.

3.4. Ensure decisions regarding specific conditions involving ACM are based on a direct evaluation of the conditions by qualified Civil Engineer and Bioenvironmental Engineering professionals. Qualified personnel are those that have received the appropriate EPA and/or state training.

3.5. Have an effective program for addressing asbestos problems at Eglin AFB.

3.6. Provide adequate and timely notifications to state for asbestos blanket notices and reports, in accordance with federal and state laws and regulations.

3.7. Integrate adequate documentation of ACM into information sources routinely used by the

96 CEG in planning and executing their work.

3.8. Have personnel that are involved in the management and assessment of ACM adequately and appropriately trained.

3.9. Bioenvironmental Engineering (96 AMDS/SGPB) will disseminate accurate information to all Eglin AFB personnel concerning potential health risks from airborne asbestos fibers.

4. ASBESTOS MANAGEMENT ACTIVITIES. The primary parts of asbestos management are budgeting (funding), scheduling and planning, monitoring and surveillance, notification, quality assurance and information dissemination. Each of these activities is described in the following sections:

4.1. Budgeting. Funding directly affects scheduling of asbestos removal.

4.1.1. In order to carry out asbestos removal, adequate resources must be provided. Obtaining resources to accomplish the tasks outlined in this plan requires that project managers and design engineers include asbestos removal as part of each project as applicable.

4.1.2. Budgeting must be addressed during each project development because Environmental compliance funds are not available for asbestos removal projects. Emergency situations will be considered on a case-by-case basis. Environmental compliance program funds may not be used for housing—Military Family Housing (MFH) funds must be used.

4.2. Cost Estimates. Cost estimates will be prepared by the ART chief for in-house work to be accomplished by the ART; by the BAI for work to be accomplished by the on-call contractor;

and by project design engineers for separate commercial contracts before completion of any project or work order design.

4.3. Work Scheduling and Planning.

4.3.1. Scheduling. The results of facility surveys are used to establish an orderly plan of action for asbestos removal or treatment. The AOO will determine if work is to be accomplished by the ART, on-call contractor or separate commercial removal project.

4.3.2. Work Stoppage/Suspension. In the event that previously unconfirmed ACM is found during the course of an actual project/work order, or under any other circumstances, the following steps must be taken to ensure worker safety as well as to minimize work stoppage:

4.3.2.1. Stop/suspend work immediately and evacuate all workers and equipment that might become contaminated with asbestos.

4.3.2.2. Notify the BAI and/or contracting officer immediately.

4.3.2.3. The BAI and/or contracting officer will determine what actions need to be taken and inform the contractor of such actions.

4.3.3. Monitoring. All locations with friable asbestos must be monitored regularly to ensure no risk to base personnel occurs. The 96 AMDS/SGPB will assign a Risk Assessment Code to an area to aid in the remediation or encapsulation when funds and resources are not available for timely resolution. The RAC will remain in place to protect workers and/or building occupants until area can be professionally remediated or the asbestos encapsulated and appropriate clearance samples are taken. Monitoring (usually visual inspections) will be accomplished by the facility manager with assistance from Civil Engineering and the 96 AMDS/SGPB, upon request. Child care facilities, family housing, recreation facilities, medical facilities and unaccompanied personnel housing facilities containing friable asbestos will be monitored according to the requirements described in 40 CFR 763, Subpart E until the asbestos has been removed.

4.3.4. Notification Requirements. Federal regulations (40 CFR Part 61) require that EPA or authorized state agencies be notified of asbestos removal projects. The notification requirements vary depending on the type of activity and amount of ACM involved. 40 CFR

61.145 should be consulted for specific notification requirements. Under normal conditions, notification forms must be post-marked or hand-delivered at least 10 work days before the commencement of work.

4.3.5. Work Incident Notification Procedures (In-House). When 96 CEG personnel first suspect that the job they are performing will involve potential exposure to ACM, the following actions will be taken:

4.3.5.1. Inform the TPO through the shop supervisor and/or flight superintendent or BAI for the specific area, type of ACM (e.g., pipe insulation, ceiling tiles) and nature of the work to be done in the area.

Note - All asbestos work orders will be sent to the AOO before the work begins. Also, inform the BAI of all asbestos projects including SABER and demolition. These need to be put into the database.

4.3.5.2. The 96 AMDS/SGPB will be notified by the AOO if a requirement for a records search exists. Records will then be reviewed to determine if bulk sampling has been accomplished within the area in question. If records cannot be found, or are inadequate to determine if the employees will be working on or around ACM in poor condition, the 96 AMDS/SGPB, in coordination with CE, will obtain a bulk or air sample, as appropriate, to determine if ACM is present.

4.3.5.3. If asbestos is confirmed in the area, the following steps will be taken:

4.3.5.3.1. The AOO will determine if the work can be accomplished in-house or by contract.

4.3.5.3.2. If in-house, the AOO will determine whether the asbestos should be removed, encapsulated, or otherwise secured.

4.3.5.3.3. All in-house asbestos-related work will be planned by the ART and coordinated with the AOO.

4.3.5.3.4. The TPO shall be advised of all impending asbestos projects and the associated CE

Project Manager shall notify the appropriate Facility Manager prior to the scheduled abatement.

4.3.5.3.5. The TPO will notify the Labor Relations Office (96 FSS/FSMC) of scheduled asbestos abatements in occupied facilities to address potential labor obligations before required employee notifications take place. The TPO will make available any required asbestos survey information on request.

4.4. Asbestos Removal and Disposal:

4.4.1. Removal. All asbestos (friable and non-friable) which requires removal shall be removed by personnel trained and certified in accordance with EPA, OSHA and FDEP regulations.

4.4.2. Disposal.

4.4.2.1. All friable asbestos will be disposed of in strict adherence with EPA standards (40 CFR

Parts 61 and 763).

4.4.2.2. Non-friable asbestos will be disposed of in Class 1 landfills to avoid any possible future disposal controversy.

4.4.2.3. Class 1 non-friable asbestos building materials, such as roofing materials, resulting from facility demolition projects, may be disposed of at permitted C&D landfills provided the landfill is made aware of the asbestos content of the debris. This will allow the landfill operators to have ample time to cover the material within 24 hours.

4.4.2.4. Eglin must remove asbestos-containing material likely to release airborne asbestos fibers which cannot be reliably maintained, repaired or isolated. "Must remove" mandates will be issued by the installation commander with advice from Bioenvironmental Engineering

Services and the 96 CEG, based on a direct evaluation of the facility. When there is no mandate to remove asbestos, evaluate the risk to facility occupants, use of facility, feasibility of repair, frequency of repair and cost-effectiveness when deciding whether to remove or repair damaged friable asbestos materials. Remove existing asbestos-containing material at opportune times during minor construction or repairs.

4.5. Asbestos Removal. All damaged ACM is presumed hazardous due to its potential to release airborne asbestos fibers. Damaged ACM must be repaired or removed to eliminate the potential hazard. Bases will abate the possibility of hazardous ACM through inventory management, isolation and containment.

4.6. Information Dissemination. Asbestos potentially affects all personnel who use base facilities that contain ACM. Therefore, the general base population should have a good understanding of the potential asbestos health hazards. This involves having accurate information, so people neither underestimate nor overestimate the health risks. General awareness of asbestos concerns can be improved through articles in the base newspaper, brochures and proper labeling. When performing asbestos-related work the ART and operations and maintenance personnel must identify areas where asbestos hazards exist and ensure that these areas are appropriately marked.

5. TRAINING. Anyone responsible for managing, planning, designing, inspecting, treating, removing, supervising the treatment or removal of asbestos or responding to emergency releases of asbestos requires formal training. Facility Managers (i.e., building custodians) must have the awareness training that is part of the CE website training for Facility Managers.

5.1. Formal Training Requirements. Formal training requirements are satisfied by attending an EPA-accredited school as determined by Florida Statute 455.

5.2. Continuation Training. Once initial training is completed, EPA-approved continuation training must be attended.

5.3. Training Certificate Files Maintenance. A copy of the most current training certificate will be maintained in personnel folders and is subject to inspection by the base, the FDEP and federal audit personnel. Certifications are not required for awareness training.

5.4. Training Requirements Chart:

Awareness * Worker Supervisor Inspector Mgt

Planning

Base CC X

CEG/CC/Deputy X

Hospital CC X

Public Affairs X

Safety X

Legal Advisor X

96 CEG/CEIE X

CE Shops X

Facility Mgrs X

ART Workers X

ART Leader X X

AOO X

BAI X X X

CE Design Eng X X

96 AMDS/SGPB X X

* A general briefing to make individuals aware that asbestos could be in their building and what to do before they disturb it.

APPENDIX 2 TO ANNEX H TO EAFB PLAN 32-3

RECORDS MANAGEMENT

1. SURVEYS. Managing asbestos in-place requires identifying locations that have ACM, determining its condition, determining whether or not it presents a health hazard, defining appropriate removal requirements and ensuring that priority attention is given to areas that are potentially the greatest hazard. Surveys are completed prior to each project by the base asbestos inspector, the 96 AMDS/SGPB or a commercial contractor. Surveys are the recommended tool for determining a schedule of removal, repair or other maintenance activities. The base-wide survey is an on-going process that is envisioned to continue as long as asbestos is present.

2. ASSESSMENT. ACM are classified according to the condition of the asbestos and the risk it poses to building occupants. Conditions are documented by the following category codes:

2.1. Category 1. Damaged or significantly damaged thermal system insulation. Material presents an exposure hazard. Isolate area and restrict access. Remove as soon as possible.

2.2. Category 2. ACM is damaged but does not pose an immediate exposure risk. Remove as soon as possible or reduce potential for disturbance.

2.3. Category 3. ACM is in good condition and does not pose a threat. Schedule removal when practical and cost effective or reduce potential for disturbance.

2.4. Category 4. ACM is in good condition and should pose no threat as long as it remains undamaged. No priority to remove but should be removed when practical and cost-effective during maintenance or renovation activities.

All Category 1 items will be scheduled for immediate removal. Categories 2 and 3 will be placed on a schedule of routine surveillance. Potential for disturbance should be reduced and potential for further deterioration should be eliminated. Category 4 requires routine surveillance. Preventive measures should be taken to prevent disturbance; schedule removal when practical and cost effective.

3. ASBESTOS FACILITIES INVENTORY. The asbestos facilities inventory is a management information system that contains information on the location and condition of

ACM previously identified at Eglin AFB. The system includes a database that identifies facility description, asbestos containing materials type, amount and other relevant information. The facility database is available for consultation at Building 690, 96 CEG/CENP, and at building 635, 96 AMDS/SGPB.

3.1. Facility Database Purpose. The purpose of the computerized database is to compile comprehensive information about ACM in a form that is readily accessible and easily updated. The database contains information on the location and condition of ACM in those facilities that have been surveyed. It is used in conjunction with the asbestos survey log and building files to record activities performed including surveys, maintenance, repair, encapsulation, enclosure and removal, as well as to indicate condition categories.

3.2. Database Information. The database includes information on each base building as the information is collected. The reports generated by the database contain the following information:

3.2.1. Environmental Assessment Status Report Item Codes.

3.2.2. Facility Use (type) Codes.

3.2.3. Summary Report of Bulk Sample Analysis.

3.2.4. Summary Report of Asbestos Containing Material.

3.2.5. Recommendations and Summary of Cost Estimates for Asbestos Response Actions.

3.2.6. Priority Response Areas.

3.3. Data Collection and Database Update. The AOO has overall database responsibility.

96 CEG/CENP will input all survey and removal information submitted by generators into the database. All CE sections/personnel (planners, foremen, inspectors, craftsmen and engineering designers, in addition to the 96 AMDS/SGPB) will coordinate all relevant information required to update the database with the AOO for input to the database to keep it as current as possible.

3.4. Asbestos Activities Documentation. All documents (logs or work sheets) relevant to the asbestos removal will become part of a permanent record maintained by the respective activity. All asbestos-related documentation must be maintained as a permanent record for 30 years. The asbestos registry serves as the master log. It is a compilation of activity logs/work sheets kept by the contract inspector, ART and the 96 AMDS/SGPB. Engineering provides data to the AOO at the end of each asbestos removal phase of a project. These offices will submit a copy of all records to the AOO after project completion. The database monitor will use the documents to update the registry. All surveys, surveillance, treatment and sampling will be entered into the log. Incidental inspections to identify the presence of asbestos as part of planning for a work order, job order, or contract will also be entered into the log.

3.5. Asbestos Files. Each section is responsible for maintaining work files pertaining to tasks accomplished by that activity or the contractor for which that activity is responsible.

Prior to destruction or transfer to a staging area, the files need to be reviewed by the AOO to see if the data is in the Asbestos Tracking System. The official contract maintained in the

Base Contracting Office will contain items specified in the contract and/or specification. It should contain some of the following information on contracts:

3.6. License.

3.7. Certificate of Insurance.

3.8. Waste Transportation Permit.

3.9. Asbestos Disposal Plan.

3.10. Notifications.

3.11. Daily Logs.

3.12. Asbestos Removal Contract.

3.13. Contract Specification/Addendum.

3.14. AF Form 9 Purchase Request.

APPENDIX 3 TO ANNEX H TO EAFB PLAN 32-3

FEDERAL AND REGIONAL OVERSIGHT

1. FEDERAL OVERSIGHT. To date, two federal agencies have been principally responsible for generating regulations for asbestos control. These two agencies are the Environmental

Protection Agency and Occupational Safety and Health Administration.

1.1. EPA regulations are primarily geared toward environmental issues.

1.1.1. EPA has encouraged the state of Florida through several provisions in the Asbestos

Hazard Emergency Response Act (AHERA) to develop its own asbestos program.

1.1.2. Eglin AFB is located within EPA’s Region IV at the following address:

EPA Region IV

345 Courtland Street, NE Atlanta GA 30365

Asbestos Phone Contact: (404) 347-5014

1.1.3. OSHA regulations are primarily geared toward health issues. The agency is located in the same region as stated above for EPA Region IV. Local OSHA representation is through the

Department of Labor.

2. REGIONAL OVERSIGHT. The state of FDEP enforces federal asbestos regulations through various district offices. The northwest district office at the following address services

Eglin AFB:

Florida Department of Environmental Protection

160 Government Center

Pensacola FL 32501-5794

Asbestos Phone Contact: (904) 444-8364

2.1. All 10-work-day asbestos renovation/demolition notices are forwarded to the district office by the activity initiating the action.

2.2. Blanket Notice of Asbestos Renovation or Demolition is filed annually with the district office by 96 CEG/CEIEC.

2.3. Fines or violation and associated litigation are coordinated with the district office by

96 CEG/CEIEC.

APPENDIX 4 TO ANNEX H TO EAFB PLAN 32-3

ASBESTOS SECURITY CONTAINER

1. GENERAL:

1.1. Security Container. The asbestos in Security Container were used as a fire retardant.

The disposal of asbestos-containing Security Container must be accomplished correctly. These

Security Containers are normally used for the storage of official personnel records, not classified materials/information.

1.2. Security Container in damaged condition:

1.2.1. Inspect the safe. If damaged, call the APO, 96 CEG/CEIEC, Mr. Kauffman, at 882-

7665 to have a sample analyzed to see if it contains asbestos. If the safe does not contain asbestos a letter will be generated saying the safe does not contain asbestos.

1.2.2. Security Container that does not contain asbestos may be processed through normal supply channels for re-issue or to Defense Reutilization & Marketing Office (DRMO) for resale or disposal.

1.2.3. Security Container that contains asbestos may be processed for disposal but will be stored in-place until a sufficient number of Security Containers have been identified to the

Toxic Programs Officer (TPO).

2. PROCEDURES FOR ASBESTOS-CONTAINING SAFE TURN-IN:

2.1. The User will:

2.1.1. Inspect safe for damage and call the APO, 96 CEG/CEIEC, to request analysis of safe.

If not damaged, safe will be assumed to have asbestos unless the user can get information from the manufacturer that the safe does not contain asbestos. The information from the manufacturer must be specific to that serial number.

2.1.2. When the APO issues a certificate that the safe contains asbestos, the user will arrange for turn-in with AOO, 96 CEG/CENPP, Mr. Berrong, at 882-6969.

2.1.3. Deliver the safe(s) to a place designated by the AOO.

2.2. The AOO will:

2.2.1. Inspect the safe with the user before it is placed in roll-off for disposal.

2.2.2. Arrange for roll-offs as necessary for the disposal of the asbestos safe.

2.3. 96 CEG/CEIEC (APO) will. Sign the disposal manifest.

APPENDIX 5 TO ANNEX H TO EAFB PLAN 32-3

OPERATIONS PLAN

1. INTRODUCTION:

2. PURPOSE. The purpose of the AOP for Eglin Air Force Base (AFB) is to implement the policy established in the Eglin AFB Asbestos Management Plan (AMP) and to outline procedures for accomplishing Eglin’s asbestos-related projects. The focus of both the AMP and the AOP is on taking positive action to address the identification and maintenance and/or removal of ACM within base facilities. The primary goal of this document is to establish procedures for all asbestos-related activities to ensure that asbestos contact is avoided, and if asbestos removal is required it will be carried out under controlled conditions so that the safety and health of all personnel are considered as the top priority. This will be accomplished by instituting work control procedures to ensure that work requests are adequately coordinated and authorized so approval is not given to a work request before the potential for asbestos disturbance is realized. The work control procedures for contractual removal of asbestos are also addressed. Work practices for routine asbestos activities are covered so that the overall management of asbestos can be addressed on a routine basis and minimize the chance of base or contractor personnel being exposed to asbestos.

2.1. BACKGROUND.

2.1.1. Asbestos in its bonded condition does not necessarily pose a health risk, but asbestos that is capable of being hand crumbled, pulverized, or reduced to powder when dry (friable) poses a potential health risk. Inhalation and ingestion of asbestos fibers have been linked to cancer and other diseases in humans.

2.1.2. Appendix A contains a glossary of terms commonly used in asbestos operations.

Appendix B contains a list of references for the AOP.

2.1.3. AFI 32-1052, Facility Asbestos Management, outlines the procedures for developing a facility asbestos program and provides general guidance for developing an AOP. Guidance governing safe work practices is contained in AFOSH publications.

2.2. POLICY.

2.2.1. Air Force Materiel Command (AFMC) General Policy is to:

2.2.1.1. Comply with federal and state requirement pertaining to activities involving asbestos-containing materials and asbestos-containing building materials. Should conflicts arise, Eglin

AFB will comply with the most restrictive requirements.

2.2.1.2. Comply with Air Force policy which is to manage asbestos in place as much as possible.

2.2.2. No person shall remove or repair any ACM unless trained in an EPA- or OSHA-certified course or by someone who is certified and has proper personal protective equipment, engineering controls and is medically monitored.

2.2.3. No work on any ACM shall commence without proper notifications, safeguards, warning signs, enclosures, monitoring, personal protection, etc.

2.2.4. HQ AFMC/CEIEC is the command program manager for asbestos policies relating to facilities. The Asbestos Program Manager (APM) will be designated from 96 CEG/CEIE.

The Toxic Programs Officer (TPO) will be designated from the CES staff as…