Attach 21e - TL OPLANS Combined 18 Jan 2022.pdf

Technical Library

Table of Contents

Operations Plans (OPLANS)

Non Controlled Unclassified Information

1. Asbestos Management and Operation Plan

2. Drought Contingency Plan

3. In-Garrison Expeditionary Site Plan (IGESP)

4. Integrated Natural Resources Management Plan

5. Integrated Solid Waste Management Plan

6. Pest Management Plan (Final Laughlin PMP)

7. Qualified Recycling Program Business Plan

8. Storm Water Pollution Preventive Plan

9. Sustainable Landscape Development Plan

Asbestos Management and Operation Plan Laughlin AFB, Texas

May 2019

Digitally signed by

KLEIN.JEFFREY.ROBERT.1266032

BERT.1266032575 575

Date: 2019.06.21 15:57:29 -05'00' 23 May 19

GALLEGOS.DANI

EL.M.1231028672

Digitally signed by

GALLEGOS.DANIEL.M.1231028672

Date: 2019.05.23 16:42:05 -05'00'

KLEIN.JEFFREY.RO

ii

Asbestos Management and Operations Plan Review Log

Plan Reviewed/Amended by:

Date

Action

47 CES/CEIE April 2020 Administrative Modification iii

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Asbestos Management Plan Purpose and Objectives

1.2 Asbestos Background

1.3 Medical Concerns

1.4 Regulatory Overview

1.4.1 Environmental Protection Agency

Asbestos Hazard Emergency Response Act Asbestos School Hazard Abatement Reauthorization Act

National Emission Standards for Hazardous Air Pollutants

1.4.2 Occupational Safety and Health Administration

Construction Standard for Asbestos General Industry Standard for Asbestos

1.4.3 Texas Department of State Health Services

2.0 ROLES AND RESPONSIBILITIES

2.1 Environmental, Safety, and Occupational Health Council

2.2 Base Civil Engineer (47 CES)

2.2.1 Training

2.2.2 Responsibilities

2.3 Environmental Element (47 CES/CEIE)

2.3.1 Training

2.3.2 Responsibilities

2.4 47 CES/CEO (Operations Element)

2.4.1 Training

2.4.2 Responsibilities

2.5 Bioenvironmental Engineering (47 MDOS/SGOJ)

2.6 47 CONF (Base Contracting)

2.6.1 Training

2.6.2 Responsibilities

3.0 MANAGEMENT PROCEDURES

3.1 Worker Training and Respiratory Protection

3.1.1 Training Requirements

Asbestos Awareness Training Class I through Class IV Asbestos Work Training Asbestos Inspector, Management Planner, Supervisor/Contractor Training ..12

3.1.2 Respiratory Protection Program

3.2 Selection of Personal Protective Equipment and Decontamination Procedures

3.2.1 Protective Clothing and Equipment

3.2.2 Decontamination

3.3 Work Request Program

3.4 Asbestos Surveys and Sampling

3.5 Notifications and Labeling

3.5.1 Warning Labels

3.5.2 Warning Signs

3.5.3 Notifications

Employee Awareness Notification Notification to Asbestos Abatement Contractors Notification of Other Contractors Notification to Regulatory Agencies

3.6 Periodic Surveillance

iv

3.7 Inspection of an Asbestos Abatement Project

3.8 Accidental Asbestos Release Response

3.9 Record-Keeping and Forms

3.10 Process for Disposal of Asbestos Wastes

3.10.1 Waste handling and packaging

3.10.1 Labeling

3.10.2 Shipping

3.10.3 Record Keeping

4.0 CONTRACTING

4.1 Contracting Provisions

4.2 Regulatory Compliance Responsibilities

4.3 Monitoring During Contract Performance

5.0 REFERENCES

LIST OF APPENDICES

APPENDIX A Asbestos Management Program Point of Contact Information APPENDIX B Laughlin AFB Record of 2-Hour Asbestos Awareness Training Attendance

Log APPENDIX C State of Texas Notification of Demolition and Renovation with Instructions APPENDIX D Asbestos Waste Shipment Record with Instructions APPENDIX E Asbestos Operating Plan with Attachment

LIST OF TABLES

TABLE PAGE

Table 3-1 EPA and OSHA Training Requirements for Asbestos Management

Laughlin Air Force Base Asbestos Management Plan

Table 3-2 Recommended Training for Asbestos Management

Laughlin Air Force Base Asbestos Management Plan

Table 4-1 ..... Statement of Objectives (SOO) Requirements for Asbestos Management Program

Laughlin AFB Asbestos Management Plan

LIST OF FIGURES

FIGURE PAGE

Figure 3-1 Warning Label

Figure 3-2 Warning Signs

Figure 3-3 Personal Protection Required Sign

Figure 3-4 Waste Labeling

Figure 3-5 Vehicle Sign Requirements v

LIST OF ACRONYMS AND ABBREVIATIONS

ABW Air Base Wing

ACM Asbestos-Containing Material AF Air Force

AETC Air Education and Training Command

AFB Air Force Base

AFI Air Force Instruction

AFOSH Air Force Occupational Safety and Health

AFPD Air Force Policy Directive

AHERA Asbestos Hazard Emergency Act

AMP Asbestos Management Plan

AOP Asbestos Operating Plan

APM Asbestos Program Manager ASHARA Asbestos School Hazard Abatement Reauthorization Act

BCE Base Civil Engineer

BEE Bioenvironmental Engineer(ing)

BOSS Base Operating and Support Services CAA Clean Air Act

CE Civil Engineering

CFR Code of Federal Regulations CO Contracting Officer

DOT Department of Transportation

DSHS Department of State Health Services (Texas)

EPA Environmental Protection Agency

ESOHC Environmental, Safety and Occupational Health Council

Ft

Square Feet

HEPA High Efficiency Particulate Air

JA Judge Advocate µm micrometer

MAP Model Accreditation Plan NESHAP National Emission Standards for Hazardous Air Pollutants

NIOSH National Institute for Occupational Safety and Health

OEEL Occupational or Environmental Exposure Limit

OPR Office of Primary Responsibility

OSHA Occupational Safety and Health Administration

PA Public Affairs

PACM Presumed Asbestos Containing Material

PAPR Powered Air Purifying Respirator

PEL Permissible Exposure Limit

PH Public Health PPE Personal Protective Equipment

RACM Regulated Asbestos Containing Material

SSD Small-Scale, Short-Duration

SOO Statement of Objectives TAHPR The Texas Asbestos Health Protection Rules TDSHS Texas Department of State Health Services TSCA Toxic Substances Control Act TSI Thermal System Insulation yd

Cubic yards

ASBESTOS MANAGEMENT PLAN SUMMARY

This Asbestos Management Plan (AMP) establishes procedures for the Laughlin Air Force Base (AFB) asbestos management program. It contains the procedures required to comply with the policies established in Air Force Instruction (AFI) 32-1001, Civil Engineer Operations, Chapter 15, Facilities Asbestos Management. In addition, this plan complies with all federal and state regulations regarding the identification and communication of presumed asbestos-containing materials (PACM) and asbestos-containing materials (ACM).

The primary objective of the AMP is to maintain a permanent record of the current status and condition of all ACM on Laughlin AFB. Knowledgeable personnel who are trained in the identification of ACM and/or PACM conduct a series of checks on the work request and survey process in order to identify ACM and/or PACM prior to any work that may disturb the material. This process is relied upon to avoid the release of asbestos into the environment rather than to perform a detailed survey of all materials on base. A comprehensive asbestos survey of base facilities was conducted by Galson, Inc. in 1993, and updated by URS in 2001. The Office of Primary Responsibility for this information is the Environmental Element (47 CES/CEIE).

1.0 INTRODUCTION

1.1 Asbestos Management Plan Purpose and Objectives

The purpose of the Laughlin Air Force Base (AFB) Asbestos Management Plan (AMP) is to establish procedures for the facility’s asbestos management program. This plan contains the policies and procedures that comprise the asbestos management program required by Air Force Instruction (AFI) 32-1001. This policy requires installations to have specific procedures for managing facilities with asbestos-containing material (ACM) and/or presumed asbestos-containing material (PACM); protecting personnel from hazards associated with ACM and/or PACM; and removing, encapsulating, or enclosing ACM at opportune times.

The objectives of this AMP include the following:

• Provide an overview of asbestos and health effects from exposure.

• Define the requirements for effective management of asbestos at Laughlin AFB.

• Establish accountability for compliance with legal, regulatory, and policy requirements concerning ACM and/or PACM by clarifying, defining, and assigning responsibilities.

• Ensure that all Laughlin AFB personnel who are involved in asbestos management, assessment, and other operations receive appropriate training.

• Disseminate information, as needed, to all Laughlin AFB personnel concerning potential health risks from airborne asbestos fibers.

• Establish a system of identification and evaluation of asbestos-based hazards so resources can be appropriately applied to address high-priority problems.

• Provide for the establishment and maintenance of a complete and usable asbestos database for recording information regarding the location and amount of ACM.

• Provide notifications in accordance with federal and state regulations.

• Present guidelines for Air Force (AF) personnel who inspect asbestos abatement operations conducted by licensed abatement contractors.

1.2 Asbestos Background

Asbestos is the generic name for six naturally occurring minerals whose crystals form long, thin fibers. These minerals are divided into two groups, serpentine and amphibole. Serpentine minerals have a layered structure, while amphibole minerals have a chain-like structure.

Chrysotile is the only mineral in the serpentine group and is commonly referred to as “white asbestos.” Chrysotile is the most commonly used form of asbestos and accounts for approximately 95 percent of the asbestos used in building materials in the United States.

There are five types of asbestos in the amphibole group, including amosite and crocidolite.

Amosite is the second most common form of asbestos and represents approximately 4 percent of the asbestos used in building materials in the United States. Amosite is commonly referred to as “brown asbestos.” Crocidolite accounts for approximately 1 percent of the asbestos products used in the United States and is commonly referred to as “blue asbestos.”

Asbestos became widely used in a variety of products because of its insulating properties, its ability to withstand heat and chemical corrosion, and its soft, pliant nature. As such, asbestos-containing building materials can be found in various products, including the following:

• Sprayed-on insulation in buildings;

• Fire-proofing materials;

• Insulation for pipes and boilers;

• Wall and ceiling insulation;

• Ceiling tiles;

• Floor tiles;

• Putties, caulks, mastics, and cements (including cement pipes);

• Roofing shingles;

• Siding shingles on old residential buildings;

• Wall and ceiling texture in older buildings and homes;

• Joint compound in older buildings and homes;

• Automotive brake linings and clutch pads;

• Interiors of fire doors; and

• Asbestos-lined safes and equipment.

For the purposes of this plan, ACM refers to any material containing more than 1 percent asbestos. PACM refers to thermal system insulation, surfacing material, and asphalt and vinyl flooring found in buildings constructed before 1981.

1.3 Medical Concerns

Over the past 30 years, there has been a growing awareness and consensus within the medical community of the adverse health effects associated with exposure to airborne asbestos, which becomes a health hazard when the airborne fibers are inhaled. The potential for an asbestos-containing product to release fibers is dependent upon several factors, including its location and its degree of friability.

Friable ACM is defined as material having more than 1 percent asbestos that can be “crumbled, pulverized, or reduced to powder by hand pressure when dry.” Friable ACM is thought to release fibers into the air more readily than non-friable ACM; however, many types of non-friable ACM may also release fibers if disturbed by mechanical forces such as those involved in sanding, scraping, or pulverizing. Because airborne asbestos fibers are small in size, they can by-pass the body’s defense mechanisms and become trapped in the lungs.

There are three main diseases associated with asbestos exposure, all of which have latency periods of approximately 10 to 40 years from exposure to onset of symptoms.

• Asbestosis is the most common asbestos-related disease and it is prevalent among workers with long-term occupational exposures to high levels of asbestos. This disease is characterized by a fibrotic scarring of the lung tissue, which results in decreased lung capacity and progressively more difficult breathing.

• The second most common asbestos-related disease is lung cancer. As with asbestosis, lung cancer is also linked with high levels of exposure to asbestos fibers. Asbestos exposure combined with cigarette smoking exponentially increases an individual’s chances of developing lung cancer.

• The least common but most fatal asbestos-related disease is mesothelioma, which is a cancer of the membranes that line the lungs or abdominal cavity. Mesothelioma differs from asbestosis and lung cancer in that there does not appear to be the same dose-response relationship; however, mesothelioma almost never occurs without exposure to asbestos. It is very difficult to treat and is currently considered incurable.

1.4 Regulatory Overview

The U.S. Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), and the Department of Transportation (DOT), are the primary federal agencies responsible for regulating asbestos. EPA is responsible for developing and enforcing regulations that protect the general public from asbestos exposure. OSHA is responsible for protecting workers who could be exposed to asbestos in the workplace or as part of their jobs.

DOT is responsible for ensuring the safe transportation of asbestos wastes. Regulations for these agencies are codified in the Code of Federal Regulations (CFR).

The State of Texas regulates asbestos through the Asbestos Programs Branch within the Department of State Health Services (DSHS). The authority to administer and enforce the Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations has been delegated to the DSHS. Texas state regulations are codified in the Texas Administrative Code (TAC). The DSHS has adopted by reference the federal requirements set forth for the handling of asbestos found in 40 CFR Part 61, Subpart M. Contractors working on Laughlin AFB are required to fully comply with Texas regulations regarding asbestos.

Additional regulation of asbestos is specified through Air Force Policy Directives (AFPD), Air Force Instructions (AFIs), and Air Force Occupational Safety and Health (AFOSH) standards.

These regulations are discussed below.

1.4.1 Environmental Protection Agency Asbestos Hazard Emergency Response Act In May 1982, the EPA first issued regulations to control asbestos in schools under the authority of the Toxic Substance Control Act (TSCA). In response to the need for more stringent control, Congress enacted the Asbestos Hazard Emergency Response Act (AHERA) as Title II of TSCA on October 22, 1986. This act required the EPA to establish a better-defined program to control ACM in schools. As a result, EPA promulgated the Asbestos Containing Materials in Schools rule on October 30, 1987 and codified it in 40 CFR 763. The new rule required schools to inspect for asbestos, prepare asbestos management procedures, and develop and implement operation and maintenance (O&M) plans. AHERA also required school authorities to inform parents, teachers, and others of the management procedures.

Asbestos School Hazard Abatement Reauthorization Act On November 28, 1990, Congress enacted the Asbestos School Hazard Abatement Reauthorization Act (ASHARA), which amended AHERA by extending accreditation requirements to persons engaged in asbestos inspections or the design and execution of asbestos response actions in public and commercial buildings. This accreditation must occur through AHERA’s Model Accreditation Plan (MAP), which is cited in 40 CFR 763, Subpart E, Appendix C, and outlines the required training courses for affected workers. Moreover, ASHARA also increased the minimum number of training hours and hands-on training required for accreditation of workers and supervisors.

National Emission Standards for Hazardous Air Pollutants The Clean Air Act (CAA) of 1970 required the EPA to develop and enforce regulations to protect the public from exposure to airborne contaminants known to be hazardous to human health. On March 31, 1971, the EPA identified asbestos as a hazardous air pollutant. On April 6, 1973, the EPA promulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP) standard for asbestos, which is codified in 40 CFR 61, Subpart M. NESHAP was revised in 1990 to clarify requirements regarding removal and disposal of ACM.

In outlining requirements for work performance in areas with potential asbestos exposure, NESHAP defined key terms, which include the following:

• Category I non-friable ACM: Asbestos-containing packing, gaskets, resilient floor covering, and asphalt roofing products containing more than 1 percent asbestos.

• Category II non-friable ACM: Any material, excluding Category 1 non-friable ACM, containing more than 1 percent asbestos that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

• Friable asbestos: Any material containing more than 1 percent asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

• Regulated asbestos-containing material (RACM): Friable ACM; Category 1 non-friable ACM that has become friable; Category 1 non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or Category II non-friable ACM that has a high probability of becoming or has become friable.

NESHAP specifies work practices, notifications, and training requirements for a variety of operations involving RACM. For building demolitions and renovations, specific notification requirements (40 CFR 61.145[b]), emission control procedures (40 CFR 61.145[c]), and waste disposal procedures (40 CFR 61.150) apply under two scenarios. First, the amount of friable ACM in a facility being demolished or being disturbed in a renovation is at least 260 linear feet on pipes or at least 160 square feet (ft2) on other facility components. The second scenario involves situations when measurement of the material before removal is not possible. In this case, the friable ACM from all sources totals at least 35 cubic yards (yd3). Standards also may apply for RACM in lesser quantities (see 40 CFR 61, Subpart M).

1.4.2 Occupational Safety and Health Administration

OSHA is required to protect workers as they perform their jobs. To accomplish this goal, OSHA instituted two primary asbestos requirements, the Construction Standard for Asbestos, which is codified in 29 CFR 1926.1101, and the General Industry Standard for Asbestos, which is codified in 29 CFR 1910.1001. These requirements cover medical examinations, personal and environmental air monitoring, reporting, protective equipment, safe work practices, and record keeping.

Construction Standard for Asbestos On August 10, 1994, OSHA issued 29 CFR 1926.1101 (formerly 29 CFR 1926.58), a revised standard for regulating all industrial exposures to asbestos in the construction industry. The provisions of this standard regulate asbestos exposure for virtually every type of activity, including asbestos abatement, removal, disposal, storage, repair, maintenance, cleanup, and transportation. This revised standard lowered the permissible exposure limit (PEL) for asbestos from 0.2 fibers per cubic centimeter (f/cm3) of air to 0.1 fibers f/cm3 over a time-weighted average (averaged over an 8-hour period). In addition, the rule required that no worker be exposed at any time to airborne concentrations of asbestos fibers in excess of 1.0 f/cm3 of air averaged over a 30-minute sampling period. This additional limit was termed an “excursion limit” (EL). If these levels are exceeded, special precautions for personal protection, such as wearing respirators and special work practices, must be followed.

The revised standard also created a new classification system for construction-related asbestos work that defines mandatory work practices to reduce worker exposure. The following four classes of asbestos work activity are identified in 29 CFR 1926.1101:

• Class I asbestos work: Includes removal of thermal system insulation (TSI) and sprayed-on or troweled-on surfacing ACM or PACM.

• Class II asbestos work: Includes removal of ACM that is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.

• Class III asbestos work: Includes repair and maintenance operations where “ACM,” including TSI and surfacing ACM and PACM, is likely to be disturbed.

• Class IV asbestos work: Includes maintenance and custodial activities where employees contact but do not disturb ACM or PACM, as well as activities to clean up dust, waste, and debris resulting from Class I, II, and III activities. Activities include, but are not limited to, vacuuming contaminated carpets, mopping floors, and dusting surfaces.

Since all asbestos-related work on Laughlin AFB will involve construction, the OSHA construction standard at 29 CFR 1926.1101 will apply.

General Industry Standard for Asbestos This standard, codified in 29 CFR 1910.1001, applies to all occupational exposures to asbestos in all industries covered by OSHA except construction work. The general industry standard for asbestos recognizes PELs as the levels required for respirator use. This standard also covers employee exposure monitoring, respiratory protection, protective clothing, hygiene facilities and practices, communication of hazards to employees, training, medical surveillance, and record keeping.

1.4.3 Texas Department of State Health Services

The Texas Asbestos Health Protection Rules (TAHPR) are codified at TAC Title 25, Chapter 295 (25 TAC 295). The EPA has delegated the inspection and enforcement authority for the NESHAPS rules to the Texas Department of State Health Services (TDSHS). TAHPR became effective October 20, 1992.

The purpose of the TAHPR is to minimize the public’s exposure to airborne asbestos fibers by regulating asbestos disturbance activities in buildings that afford public access or occupancy. The TAHPR require that a person must be appropriately licensed or registered to engage in asbestos abatement or any asbestos-related activity. Private residences and apartment buildings with no more than four dwelling units are excluded from these rules. Also excluded are industrial or manufacturing facilities, in which access is controlled and limited principally to employees therein because of processes or functions dangerous to human health and safety. Federal buildings and military installations are also excluded from coverage by these rules; however civilian contractors performing work on Laughlin AFB must comply with all EPA and Texas rules regarding asbestos, including licensing requirements.

2.0 ROLES AND RESPONSIBILITIES

An effective asbestos program at Laughlin AFB requires the participation and interface of all responsible organizations so that the health and welfare of Laughlin AFB personnel are protected from the potentially harmful effects of ACM. At base level, the Base Civil Engineer (BCE), Civil Engineering Environmental Element (CEIE), Bio-environmental Engineering (BEE), and Civil Engineering (CE) have the primary responsibility for developing and implementing the asbestos program. The following sections detail the training level and responsibilities of these and other key organizations. Training requirements are discussed further in Section 3.0.

Contact information for personnel involved in asbestos management efforts at Laughlin AFB is included in Appendix A.

2.1 Environmental, Safety, and Occupational Health Council

In addition to its other responsibilities, the Environmental, Safety, and Occupational Health

Council (ESOHC) will monitor the development of a base-specific plan to manage asbestos. The ESOHC will be responsible for:

• Monitoring the development of the AMP.

• Reviewing reports provided by BEE and/or CEIE.

• Directing modification or changes to the AMP when necessary to improve operations or to comply with new regulatory requirements.

2.2 Base Civil Engineer (47 CES)

2.2.1 Training

The BCE and/or his representative should stay abreast of any new regulatory requirements or revisions that have the potential to affect asbestos management at Laughlin AFB.

2.2.2 Responsibilities

• Designate 47 CES/CEIE as the Asbestos Program Manager and the Asbestos

Operations and Maintenance (O&M) Manager

• Maintain, repair, construct, and demolish AF real property facilities.

• Identify and budget for asbestos activities required for the safe execution of a facility project

2.3 Environmental Element (47 CES/CEIE)

2.3.1 Training

The Asbestos Program Manager will attend an asbestos hazard training course approved by the EPA for an asbestos inspector and management planner (including annual refresher courses).

2.3.2 Responsibilities

• Manage the base asbestos management program

• Develop an Asbestos Management Plan and a base Asbestos Operations and Management Plan in accordance with the requirements of AFI 32-1001, Civil Engineer Operations, Chapter 15, Facilities Asbestos Management.

• Conduct or oversee asbestos bulk sampling

• If sampling is performed by a contractor, review contractor submittals to ensure the sampling plan is adequate, the inspector has attended an accredited training course and possesses the required licenses, an accredited/licensed laboratory is utilized for sample analysis, and that Air Force personnel are adequately protected during sampling events.

• Act as the point of contact between the base and federal or state environmental regulatory agencies

• Communicate the base Asbestos Management Program to tenant organizations

• Review work orders, change orders, asbestos abatement contractor submittals, plans, and projects to ensure compliance with federal and state environmental regulations, including but not limited to 29 CFR 1926.1101, 40 CFR 763, Subpart E, and 40 CFR 61.145.

Ensure all regulatory notifications have been made prior to the commencement of any demolition, renovation, or asbestos abatement activity in accordance with 40 CFR 61.145.

• Review waste disposal procedures and reporting requirements in accordance with applicable state and federal environmental regulations.

• Maintain ownership of all records for the asbestos program, including asbestos surveys, laboratory results, inspections, abatement actions, waste manifests, and enforcement actions.

• Ensure facility managers receive training on asbestos health and environmental issues.

• Maintain and update the computerized asbestos database

2.4 47 CES/CEO (Operations Element)

2.4.1 Training

Operations Flight personnel responsible for overseeing the Base Operating Services and Support (BOSS) contractor will receive training regarding maintenance activities that may disturb asbestos-containing materials.

2.4.2 Responsibilities

• Coordinate all work orders to be performed by the BOSS contractor with the Asbestos

Program Manager prior to initiation of the project to ensure the planned work will not affect asbestos-containing materials.

• Ensure that BOSS contractor employees are instructed to suspend work and not disturb any materials suspected of containing asbestos.

• Ensure that the Asbestos Program Manager is notified immediately if BOSS contractor employees encounter materials suspected of containing asbestos.

2.5 Bioenvironmental Engineering (47 MDOS/SGOJ)

Bio-environmental Engineering (BEE) will provide advice to the APM regarding the health risk to facility occupants and will determine if specific actions are necessary in order to protect human health.

When requested, BEE will act as a consultant on any site evaluation involving maintenance, repair, or minor construction that could result in exposure to asbestos. When it is determined asbestos may be present and could be disturbed, BEE may be called upon to conduct a health risk assessment. If warranted, a health-related risk assessment code (RAC) will be assigned in accordance with AFI 91-202, U.S. Air Force Mishap Prevention Program.

2.6 47 CONF (Base Contracting)

2.6.1 Training

Base Contracting personnel should be made aware of the special requirements of projects that involve asbestos containing materials.

2.6.2 Responsibilities

• Ensure asbestos abatement contractors have current proof of license and training on file prior to beginning asbestos-related work on Laughlin AFB

• Ensure that contractor-submitted documents related to disposal of asbestos-containing materials are properly completed and the disposal site is licensed to accept asbestos waste.

3.0 MANAGEMENT PROCEDURES

This section presents the administrative elements of the asbestos program. The following management procedures are presented in the respective subsections:

1. Worker Training and Respiratory Protection

2. Selection of Personal Protective Equipment and Decontamination Procedures

3. Work Request Program

4. Asbestos Surveys and Sampling

5. Notifications and Labeling

6. Periodic Inspections of ACM

7. Inspection of Contractor Projects Involving ACM

8. Asbestos Release Response

9. Record Keeping

10. Process for Disposal of Asbestos Wastes

3.1 Worker Training and Respiratory Protection

3.1.1 Training Requirements

Effective implementation of the AMP requires specific training of select personnel. The amount and content of training depends on the specific duties of each individual and the likelihood of potential contact with ACM and/or PACM in the buildings at Laughlin AFB. The APM will assist Laughlin AFB supervisors by recommending suitable training for AF and government civilian employees engaged in asbestos-related work and/or who may be potentially exposed to asbestos fibers.

There are three categories of training available for Laughlin AFB personnel: asbestos awareness training, Class I through Class IV asbestos work training, and formal training with the goal of becoming accredited in one of the five asbestos disciplines: inspector, management planner, supervisor/contractor, project designer, and worker. Training should be conducted at the time of initial assignment and at least annually thereafter. The classification of work and various categories of training per EPA (40 CFR 763) and OSHA (29 CFR 1926.1101) definitions are summarized in Table 3-1. Recommended training for Laughlin AFB and government civilian personnel is summarized in Table 3-2.

Table 3-1 EPA and OSHA Training Requirements for Asbestos

Management Laughlin Air Force Base Asbestos Management Plan

Level Training

EPA Asbestos Model Accreditation Plan (MAP) (40 CFR 763 Subpart E, Appendix C)

Worker

All persons in contact with any asbestos activity in a public or commercial building, including a response action other than a

SSSD1 activity, a maintenance activity that disturbs friable

ACM other than a SSSD activity, or a response action for a major fiber release episode.

Contractor/Supervisor

Provides onsite supervision and direction to the workers engaged in asbestos projects involving any of the activities described for Worker.

Inspector

All persons whose purpose is to determine the presence or location, or to assess the condition of, friable or non-friable

ACM or PACM in a public or commercial building.

Management Planner All persons who prepare AMPs for schools or public building owners.

Project Designer

All persons who design any of the asbestos activities described for Worker.

OSHA Construction Industry Standard (29 CFR 19261101 [k][9])

Class I Asbestos Work

– activities involving the removal of thermal system insulation (TSI) and surfacing ACM and

PACM

To perform this work, workers are required to complete

32 hours of training equivalent to the EPA MAP asbestos abatement worker training.

Class II Asbestos Work

– activities involving the removal of ACM that is not TSI or surfacing material.

To perform this work, workers are required to complete

32 hours of training equivalent to the EPA MAP asbestos abatement worker training.

Class III Asbestos Work

– repair and maintenance operations where ACM, including TSI and surfacing material, is likely to be disturbed.

Requires 16 hours of training consistent with the 16 hours set forth in 40 CFR 763.92(a)(2) for maintenance and custodial who conduct activities that will result in the disturbance of ACM.

Class IV Asbestos Work – maintenance and custodial activities during which employees contact, but do not disturb, ACM and PACM. Also includes activities to clean up the waste and debris resulting from Class I, II, and III activities.

Requires 2 hours of training equivalent to the awareness training of local education agency maintenance and custodial staff as set forth in 40 CFR 763.92(a)(1).

Notes:

Small-scale, short-duration activities (SSSD) are defined in 40 CFR 763 as such tasks including

a) Removal of asbestos-containing insulation on pipes.

b) Removal of small quantities of asbestos-containing insulation on beams or above ceilings.

c) Replacement of an asbestos-containing gasket on a valve.

d) Installation or removal of a small section of drywall.

e) Installation of electrical conduits through or proximate to asbestos-containing materials.

f) Removal of small quantities of ACM only if required in the performance of another maintenance task.

g) Removal of asbestos-containing thermal system insulation not to exceed amounts greater than those which can be contained in a single glove bag.

h) Minor repairs to damaged thermal system insulation, which do not require removal.

i) Repairs to a piece of asbestos-containing wallboard.

j) Repairs, involving encapsulation, enclosure, or removal, to small amounts of friable ACM only if required in the performance of emergency or routine maintenance activity and not intended solely as asbestos abatement. Such work may not exceed amounts greater than those that can be contained in a single prefabricated mini-enclosure. Such an enclosure shall conform spatially and geometrically to the localized work area, in order to perform its intended containment function.

Laughlin AFB personnel shall not conduct Class I, II, or Class III asbestos work repair and maintenance operations. A licensed asbestos abatement contractor must be utilized to perform these classes of work.

Table 3-2

Recommended Training for Asbestos Management Laughlin Air Force Base Asbestos

Management Plan

Position Internal EPA-Certified Training

In

-H ou se

Aw ar en es s Ed uc at io n

W or ke r

Su pe rv is or

In sp ec to r

M an ag em en t

Pl an ne r

De si gn er

Asbestos Program Manager X X

Base Civil Engineer X

Bioenvironmental Engineering

BOSS Contractor Monitor X

Facility Managers X BOSS Contractor O&M Personnel (plumbers, electricians, etc.)1

X

Contracting Inspectors X

Environmental Protection Committee Members X

Safety Office X

Note:

The training specified for BOSS Contractor personnel is a recommendation only

Asbestos Awareness Training Personnel that may come in contact with, but do not disturb, asbestos or that require a general knowledge of asbestos in the performance of their duties (i.e., commanders, certain civilian and military staff personnel, and facility managers) should receive awareness training through seminars, EPC meetings, and self-study. Brochures, pamphlets, videos, or other educational materials may be utilized to obtain this training. The asbestos awareness training should address the following topics:

• Information regarding asbestos and its various forms and uses.

• Information on the health effects associated with asbestos exposure.

• Location of ACM at Laughlin AFB and potential sources of exposure.

• Name and phone number of the APM and location of the AMP.

Class I through Class IV Asbestos Work Training

OSHA regulations at 29 CFR 1926.1101[k][9] require that workers assigned to perform Class I, II, III, or IV asbestos work must receive training in the skills and techniques required for the type of work to be performed, applicable asbestos procedures, this AMP, and building conditions at Laughlin AFB. Laughlin AFB currently contracts out all O&M activities to a licensed asbestos contractor.

However, Laughlin AFB ensures appropriate Contract CE O&M personnel attend a 2-hour asbestos awareness course in accordance with training requirements for employees performing Class IV operations as described in 29 CFR 1926.1101(k)(9)(vi). This regulation requires training to be consistent with EPA requirements for training of local education agency maintenance and custodial staff as described in 40 CFR 763.92(a)(1).

Asbestos Inspector, Management Planner, Supervisor/Contractor Training Any person responsible for managing, planning, inspecting, treating, removing, supervising the treatment or removal of asbestos, or responding to releases of asbestos require formal training as required by 40 CFR 763, Subpart E, Appendix C. At Laughlin AFB, representatives from CEIE and BEE shall attend two EPA accredited courses and refreshers. The Asbestos Inspector and Asbestos Management Planner courses will prepare them to successfully conduct the following:

• Perform inspections and identify where ACM and/or PACM might be encountered.

• Assess the condition of ACM.

• Evaluate potential exposure, building components, building systems, and building usage patterns.

• Understand applicable regulations.

• Administer an asbestos management program.

• Respond to unplanned asbestos releases.

• Training records will be maintained in each respective individual’s offices.

3.1.2 Respiratory Protection Program

A respiratory protection program shall be available as required by 29 CFR 1910.134 and 29 CFR

1926.1101. The BEE will conduct respiratory protection fit-testing and training for Air Force personnel requiring respiratory protection. Contractor personnel are responsible for providing appropriate respiratory protection and compliance with OSHA respiratory protection rules at 29

CFR 1926.103.

Contract personnel are responsible for ensuring compliance with all applicable regulations.

3.2 Selection of Personal Protective Equipment and Decontamination Procedures Personnel potentially exposed to concentrations of asbestos that exceed a time-weighted average Occupational or Environmental Exposure Limit (OEEL) must be provided with clean protective work clothing and equipment and appropriate decontamination facilities. In the case where an OEEL is not known (e.g., during sampling activities), such protective measures should also be in place.

3.2.1 Protective Clothing and Equipment

Appropriate protective work clothing and equipment shall include coveralls or similar full-body work clothing, gloves, hard hats, safety shoes, or disposable shoe covers, face shields, vented goggles or other appropriate protective equipment where the possibility of eye irritation exists.

Signs must be placed in areas where the use of respirators and protective equipment is required.

47 MDOS/SGOJ is responsible for approving and selecting the required protective clothing, for DOD employees, during sampling operations and release response episodes.

Asbestos work and clean-up requires the use of a High Efficiency Particulate Air (HEPA) vacuum.

Each HEPA vacuum manufacturer requires slightly different maintenance procedures for disposing of dust and debris from the tank and for replacing filters. Instructions from each manufacturer must be followed for any particular type of HEPA vacuum. The following will apply to all HEPA vacuum maintenance, regardless of manufacturer:

• A properly fitted respirator and personal protective equipment (PPE) that includes gloves will be worn.

• A location will be selected that is not subject to crosswind or drafts.

3.2.2 Decontamination

At no time shall workers be allowed to leave a regulated work site wearing asbestos-contaminated clothing or equipment. All contaminated clothing or equipment shall remain in the change room where two separate lockers or storage facilities are available to the employee to separate clean clothes from asbestos-contaminated PPE. This is a significant requirement for preventing the movement of asbestos contamination from the regulated area to an uncontaminated area and the cross-contamination of employee clothing. Blowing or shaking of PPE shall be prohibited.

Employees who work in areas where the airborne exposure is above the OEEL shall shower in designated shower facilities at the end of the work shift.

Contaminated clothing that is to be cleaned, laundered, or disposed of should be placed in sealed impermeable bags or closed containers to prevent the dispersion of asbestos. The use of disposable whole-body coveralls is recommended. Persons responsible for handling contaminated clothing must be informed of the potential hazards. Warning labels must be placed on the containers (see Section 3.5).

At no time shall asbestos be removed from protective clothes or equipment by any means that entrains asbestos into air, such as brushing, shaking, blowing, or using a non-HEPA vacuum cleaner.

To decontaminate a HEPA vacuum, a wipe down will be performed with damp cloths, sponges, or towels that will be discarded with asbestos waste. All bags and filters will be misted with amended water (water to which a surfactant [wetting agent] has been added), if practical.

HEPA vacuum bags and filters will be double-bagged in labeled asbestos waste disposal bags and discarded in accordance with asbestos waste disposal practices, including notification of regulatory agencies and approved landfills.

For more information on protective clothing and hygiene, refer to OSHA rules at 29 CFR 1910.1001(h) and (i), and 1926.1101(i) and (j).

3.3 Work Request Program

Per AFI 32-1001, Operation Management, work requests are documented on AF Form 332, Base Civil Engineer Work Request. Work orders will be coordinated with the appropriate base organizations, including CEIE, Fire Protection, BEE, and Base Safety. The CEIE and BEE will evaluate work order requests for potential asbestos hazards. If asbestos-containing materials are present or suspected of being present in the proposed work area, a definitive survey by the BEE will be accomplished to clearly delineate the extent of asbestos-containing materials.

3.4 Asbestos Surveys and Sampling

Asbestos sampling shall be conducted by an accredited inspector from the BOS Contractor with consultation from BEE office in accordance with requirements set forth in 40 CFR 763, Subpart E. Samples will be submitted to a laboratory that is currently licensed by the State of Texas for analysis of asbestos samples.

Upon receipt of the laboratory results, the results of the survey shall be forwarded to 47th CES for archiving and input into the computerized asbestos database.

If ACM is determined to be present in the proposed work area, the proposed work will be delayed until the ACM can be abated, or the work redesigned to avoid the ACM.

3.5 Notifications and Labeling

OSHA regulations at 29 CFR 1926.1101 (k)(2)(ii) require that building and/or facility owners must notify all employers, employees, and tenants of the presence, location, and quantity of ACM and/or PACM.

3.5.1 Warning Labels

OSHA regulations at 29 CFR 1926.1101(k)(8) require that labels be affixed to all products containing asbestos and to all containers containing such products, including waste containers.

Where feasible, all asbestos products shall contain a visible label. Since multiple segments of the same pipe could contain both ACM and non-ACM insulation, it is not practicable to affix warning labels to this particular product. Therefore, all pipe insulation at Laughlin AFB shall be treated as ACM until sampling has been conducted by an accredited asbestos inspector.

Labels shall be printed in large bold letters on contrasting background in accordance with the requirements of 29 CFR 1910.1200(f) of OSHA’s Hazard Communication Standard, and shall contain the information shown in Figure 3-1.

Figure 3-1. Warning Label

3.5.2 Warning Signs

OSHA regulation 29 CFR 1926.1101(k)(6) requires warning signs to be posted at the entrance to mechanical rooms/areas in which employees reasonably can be expected to enter and which contain ACM and/or PACM. The signs will identify the material present, its location, and the appropriate work practices, which, if followed, will ensure that ACM and/or PACM will not be disturbed. These signs may be posted inside mechanical rooms as well.

Additionally, warning signs will also be placed to notify personnel of regulated areas. Per OSHA regulations, a regulated area is defined as an area established by the employer to demarcate areas where Class I, II, and III asbestos work is conducted, and any adjoining area where debris

DANGER

CONTAINS ASBESTOS

AVOID CREATING DUST

CANCER AND LUNG DISEASE HAZARD

and waste from such asbestos work accumulate, or a work area within which airborne concentrations of asbestos exceed the PEL or there is a reasonable possibility they may exceed the PEL. The warning signs shall state the information shown in Figure 3-2.

Figure 3-2. Warning Signs

Where the use of respirators and protective clothing is required, the warning signs shall include the information shown in Figure 3-3.

Figure 3-3. Personal Protection Required Sign

3.5.3 Notifications

The Asbestos Program Manager is responsible for informing those who might come in contact with ACM about its location in order to prevent inadvertent disturbances. This includes employees, O&M personnel, tenants, and outside contractors.

Employee Awareness Notification Facility managers should inform employees and tenants of the location of ACM, instruct them to avoid disturbance of these materials, and advise them to report damage or suspected release to the APM. This notification can be written or communicated verbally.

When asbestos abatement work is being planned or is in progress, Laughlin AFB personnel working in and near the area of the abatement should be provided information regarding the following:

• The specific work to be performed,

• The abatement work schedule,

• Precautions being taken,

• What will be visible during the work,

• Posted warning signs that must be obeyed, and

• The APM contact information.

Notification to Asbestos Abatement Contractors The asbestos abatement contractor retained to perform abatement work or construction affecting ACM will be notified in the contract documents or by separate letter regarding the location and content of ACM. In addition, the Laughlin AFB Asbestos Specifications are included as Attachment 1 to Appendix E, Asbestos Operating Plan. These specifications may be used as an

DANGER

ASBESTOS

AUTHORIZED PERSONNEL ONLY

RESPIRATORS AND

PROTECTIVE CLOTHING

ARE REQUIRED IN THIS AREA

attachment in the contract package when asbestos has been identified either in the project specifications or discovered as a differing site condition. This specification describes the requirements for asbestos abatement at Laughlin AFB.

Notification of Other Contractors Other contractors need to be informed of the location of ACM if it is present in the buildings they will be working in. The procedures described in Section 3.5.3.2 will be used to notify contractors as appropriate, prior to starting work. In addition, facility managers working with contractor shall also identify the location of PACM within their building prior to the start of work and notify the APM promptly if these materials are disturbed.

Notification to Regulatory Agencies Since all asbestos abatement/demolition activities on Laughlin AFB will be conducted under contract with licensed abatement companies, Texas Asbestos Health Protection Rules regarding notification of abatement activities will be followed. The abatement contractor is responsible for all notifications to the Texas Department of State Health Services.

Copies of all notifications shall be provided to the Base Contracting Office and the APM. The APM, in conjunction with the Base Contracting Office, shall verify that the contractor has filed all applicable notifications prior to the start of any ACM-related activities.

Written notification to the State of Texas is required for demolition or renovation work involving asbestos above certain quantities per 40 CFR 61.145(a) and 61.145(b). Notification to the State of Texas will satisfy the requirement to notify the EPA of abatement activities. If the combined amounts of RACM to be stripped, removed, dislodged, cut, drilled or similarly disturbed is over 260 linear feet (80 linear meters), 160 square feet (15 square meters), or 35 cubic feet (1 cubic meter) for any single project, notice must be given at least 10 working days prior to beginning work.

A new written notice must be filed if the start date for a project is revised (earlier or later) from the date filed in the original or a previous notice. In addition, a notice must be updated if the amount of asbestos affected changes by 20 percent or more. The Department of State Health Services Demolition/Renovation form combines the requirements of the NESHAP 40 CFR, Subpart M, and the TAHPR. This form can be obtained from the Department of State Health Services website at http://www.dshs.state.tx.us/asbestos/forms.shtm. A copy of this form is also found in Appendix C.

Both of these regulations require that written notification be submitted before beginning renovation projects that include the disturbance of any ACM in a building or facility, or before the demolition of a building or facility, even when no asbestos is present.

3.6 Periodic Surveillance

It is the responsibility of all personnel at Laughlin AFB, including O&M workers, to report damaged building materials and insulation to their facility manager. Personnel can also report damaged ACM and/or PACM to their supervisor, or directly to the APM. Notification via telephone or e-mail is acceptable. Appendix A, Asbestos Management Program Points of Contact, may be of assistance to all concerned.

3.7 Inspection of an Asbestos Abatement Project

Laughlin AFB’s contract inspectors are responsible for overseeing contractor compliance with contract provisions, including regulatory health and safety compliance requirements.