Attachment 4 - NFARS_Asbestos Mgt Plan revised 2025-10.pdf

ASBESTOS MANAGEMENT PLAN

(AMP)

914th Air Refueling Wing

Niagara Falls Air Reserve Station Niagara Falls, New York 14304

October 2025

Asbestos Management Plan

Revised By:

8 October 2025

Kevin J. McGovern, PG, CPG, CHMM

Date

Original By:

14 March 2013

Kevin J. McGovern, PG, CPG, CHMM

Original Approved By:

14 March 2013

Danielle Schaefer (NYS Certified Asbestos Management Planner, Cert# 88-13120, expires October 2013

Revision Approved By:

8 October 2025

Mark Connors (NYS Certified Asbestos Management Planner, Cert# 24-6TZ36-SHAB , expires August 2026

New Plan

Title Change

X Plan Revision

Plan Rewrite

Effective Date 8 October 2025

Niagara Falls ARS iii

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Purpose

1.2 Background

1.2.1 Health Risk Classification

1.2.2 Hazard/Risk Assessment

1.2.2.1 Recognition

1.2.2.2 Evaluation

1.2.2.3 Control

1.3 Regulatory Review

1.3.1 Federal Laws

1.3.2 Federal Regulations

1.3.3 State and Local Regulatory Review

1.3.4 Department of Defense Directive Review

1.3.5 Department of Air Force Regulatory Review

1.3.6 Glossary of Terms Definitions, and Acronyms

2.0 GENERAL INFORMATION

2.1 Asbestos Operating Plan

3.0 ASBESTOS MANAGEMENT ACTIVITIES

3.1 Scheduling

3.2 Identifying and Evaluating Hazards

3.2.1 Inspections

3.2.2 Surveillance

3.2.3 Testing and Analytical

3.2.4 Facility Assessments

3.3 Corrective Actions

3.3.1 Procedure

3.3.2 Documentation

4.0 RECORDS OF ASBESTOS-CONTAINING MATERIALS

4.1 Data Collection

4.2 The Asbestos Record

4.2.1 Asbestos Database

4.2.2 The Asbestos Survey Reports

4.2.3 O&M Activities File

4.2.4 Asbestos Project File

iv

4.2.5 Asbestos Certification File

4.2.6 Asbestos Awareness and Training File

LIST OF APPENDICES

A Asbestos Operating Plan..................................................................................................................... A-1

B Terms, Definitions, and Acronyms .................................................................................................... B-1

C Asbestos Database .............................................................................................................................. C-1

D Exposure Assessment-Numerical System .......................................................................................... D-1

E Asbestos Assessment Form ................................................................................................................ E-1

F Information Sources ........................................................................................................................... F-1

G Asbestos Clearance Request ............................................................................................................... G-1

H Pre-Abatement Checklist, Glovebag Removal Checklist, Daily Report, Final Cleaning Inspection Checklist, Certificate of Completion, and Certificate of Re- Entry ................................................................................................................................................... H-1

I Asbestos Work Management Flow Diagram...................................................................................... I-1

J Minor/Major Asbestos Fiber Release Episode Report ....................................................................... J-1

K Procedures for Asbestos Hazard Response ........................................................................................ K-1

L Emergency Telephone Numbers ........................................................................................................ L-1

1.0 INTRODUCTION

1.1 Purpose

Department of the Air Force Instruction (DAFI) 32-1001, Chapter 16, direct installations with an Asbestos-Containing Material (ACM) Program to develop written Asbestos Management Plan (AMP) and Asbestos Operating Plan (AOP). This AMP, which contains the AOP (Appendix A), establishes procedures for accomplishing asbestos-related activities. This AMP provides references and guidance documents to Niagara Falls Air Reserve Station (ARS), 914th Air Refueling Wing (ARW). The AMP comprises the following components:

Section 1 Program Introduction;

Section 2 General Information;

Section 3 Asbestos Management Activities; and, Section 4 Records of Asbestos Containing Materials

1.2 Background

Asbestos is a term that describes six naturally occurring, fibrous minerals found in certain types of rock formations. Of these naturally occurring minerals, the minerals chrysotile, amosite, and crocidolite have been most commonly used in building materials. When mined and processed, asbestos is typically separated into very thin fibers, which are then combined with other materials to make a variety of products.

Asbestos will not burn, resists corrosion, and insulates well. Therefore, asbestos products are widely used for thermal insulation and fireproofing and in various building materials, e.g., floor coverings, adhesive mastics, window caulking, roofing felts and flashings, ceiling tiles, cement pipe and sheeting, corrugated paper pipe wrap, and acoustical and decorative treatment for walls and ceilings. In addition, asbestos has been widely used in automotive brake linings.

Asbestos presents a significant risk to human health. Asbestos is a much greater concern in the friable condition. Friable ACM is defined as ACM that can be crumbled, pulverized, or reduced to powder by hand pressure. The adverse health effects of asbestos are respiratory diseases such as asbestosis, lung cancer, and mesothelioma, and it is believed to be linked to cancers of the larynx, esophagus, stomach, and colon-rectum.

Regulations for asbestos control are promulgated by the United States Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), the Department of Transportation (DOT), and state and local government agencies. The National Institute of Standards and Technology (NIST) and the National Voluntary Laboratory Accreditation Program (NVLAP) establish standards and protocols for laboratory and analytical procedures and accreditation. Regulations are intended to protect the environment and the public from airborne asbestos fibers.

The Congress, EPA, and state and local agencies have developed complex and extensive laws and regulations addressing the past, present, and future environmental problems of the nation. These laws and regulations apply to most federal agencies.

https://static.e-publishing.af.mil/production/1/af_a4/publication/afi32-1001/dafi32-1001.pdf

1.2.1 Health Risk Classification

In their publication “Current Intelligence Bulletin 62, Asbestos Fibers and Other Elongate Mineral Particles: State of the Science and Roadmap for Research, Revised Edition” (April 2011), the National Institute for Occupational Safety and Health (NIOSH) has designated asbestos to be a “Potential Occupational Carcinogen”. OSHA regulation 29 Code of Federal Regulations (CFR) 1990.103 states:

"Potential occupational carcinogen" means any substance, or combination or mixture of substances, which causes an increased incidence of benign and/ or malignant neoplasms, or a substantial decrease in the latency period between exposure and onset of neoplasms in humans or in one or more experimental mammalian species as the result of any oral, respiratory or dermal exposure, or any other exposure which results in the induction of tumors at a site other than the site of administration. This definition also includes any substance which is metabolized into one or more potential occupational carcinogens by mammals."

1.2.2 Hazard/Risk Assessment

Organizations such as the American Conference of Governmental Industrial Hygienists (ACGIH), which establishes threshold limit values (TLVs), sets exposure limits for confirmed or suspected human carcinogens. An exposure limit, such as a TLV, does not necessarily define a biological threshold. A logical approach to assessing exposure to potentially carcinogenic substances, such as asbestos, is to use the standard industrial hygiene process of surveillance. The major objective of this process is to determine whether exposures pose a potential health risk. The three phases of surveillance programs include recognition, evaluation, and control.

1.2.2.1 Recognition

Since most surveys use a nondestructive strategy (sampling only that which is readily accessible), the potential asbestos content on internal components of structures or inaccessible areas is unknown. This means future surveys may be needed when a building undergoes demolition or other major construction activity. Prior to planning and design of all projects involving existing facilities, the Base Civil Engineer (BCE), along with the Asbestos Program Officer (APO) or Surgeon General of Public Health and Bioenvironmental (SGPB), shall determine if asbestos is present or if asbestos will be exposed during the project. Inspections and surveys must be conducted in all buildings prior to undergoing demolition, renovation, or removal to identify all ACM in the demolition or renovation areas.

1.2.2.2 Evaluation

Chapter 16 of DAFI 32-1001 requires ACM to be evaluated for friable condition and, if necessary, a response action established. Rating and ranking of ACM is performed as part of the evaluation to define those facilities with the worst health hazard exposure or the potential for exposure to harmful ACM. The APO is responsible for ensuring the evaluation is performed.

1.2.2.3 Control

The National Emission Standards for Hazardous Air Pollutants (NESHAP) specifies the requirements for non-friable and friable ACM. NESHAP covers regulated asbestos-containing material (RACM).

RACM includes all friable asbestos material; Category I non-friable ACM that has become friable;

Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading;

and Category II non-friable ACM that has a high probability of becoming crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation.

Decisions for managing existing locations where friable or non-friable ACM is present should be based on the potential for exposure to airborne asbestos fibers. The exposure potential should consider the condition of, and the potential for damage to, the ACM. In some cases, repair, encapsulation, or encasement techniques may be acceptable and considerably more cost-effective than removal. Actual or significant potential exposure to asbestos fibers generally requires immediate abatement activities. The APO and SGPB determines when corrective actions are needed.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=11368

1.3 Regulatory Review

The federal government has enacted laws for asbestos control from both environmental and occupational standpoints through such acts as the Air Quality Act of 1967 (amendments 1970, 1977), the Occupational Safety and Health Act (1970), the Toxic Substances Control Act (TSCA; 1976, 1983, 1986), and the Clean Air Act (CAA; 1967, 1971). Titles 29, 40, and 49 CFR establish standards, which are intended to protect public health and the environment. Local and state regulatory agencies have enacted regulations that are equal to, if not more stringent than, federal regulations.

Federal agencies have developed comprehensive environmental programs, orders, and directives to prescribe appropriate actions in response to, and in compliance with, environmental regulations. Federal facilities were initially required to comply only in substance with federal and applicable state regulations.

Now, however, executive orders require federal facilities to comply with applicable federal, state, and local standards for controlling asbestos exposure to employees and surrounding environs (Executive Orders 12088 and 12196) substantively and procedurally.

1.3.1 Federal Laws

The following are the major federal laws pertaining to asbestos:

• Asbestos Hazard Emergency Response Act (AHERA) AHERA was enacted by Public Law 99-519 as Title II of TSCA and amended by Public Law 100-368. This act directs EPA to establish rules and regulations to address the issues of identifying, evaluating, and controlling ACM in schools. The EPA developed the final AHERA regulations in 40 CFR 763, Subpart E Section 763.80-763.99, under TSCA.

• Occupational Safety and Health Act (OSHA 1970, 1971). This regulation, enacted as Public Law 91-596, states that the United States Department of Labor (DOL) will administer responsibilities assigned by the act. The Secretary of Labor has the authority to set standards, conduct inspections and investigations, and impose site violation penalties. The act requires all companies and employees to comply with OSHA standards and that occupational exposure limits be set for asbestos.

1.3.2 Federal Regulations

The EPA and OSHA have put in place regulations addressing exposures to asbestos and their negative effect on people and the environment. These exposures pose significant health risks, and the regulations seek to substantially reduce those risks.

The following are the major federal regulations dealing with asbestos:

• 29 CFR 1910.1001 - OSHA Health Standard for Asbestos This section applies to all occupational exposures to asbestos in all industries except construction industry workers who are covered by 29 CFR 1926.1101. This section sets the Permissible Exposure Limit (PEL) and excursion limits. It mandates the respiratory protection program, ACM notification, monitoring, and medical surveillance requirements. Revisions to the standard lowered the PEL to 0.1 fibers/cc on 11 October 1994.

• 29 CFR 1926.1101 - OSHA Construction Standards for Asbestos This section applies to construction workers involved in asbestos demolition, removal, encapsulation, construction, repair, maintenance, renovation, transportation, disposal, or storage activities. In addition to covering all activities in 29 CFR 1910.1001, this section defines wet removal, glovebag, enclosures, removal, and maintenance activities. Revisions to the standard lowered the PEL to

0.1 fibers/cc on 11 October 1994.

https://www.archives.gov/federal-register/codification/executive-order/12088.html https://www.archives.gov/federal-register/codification/executive-order/12196.html https://www.congress.gov/99/statute/STATUTE-100/STATUTE-100-Pg2970.pdf https://www.congress.gov/99/statute/STATUTE-100/STATUTE-100-Pg2970.pdf https://www.congress.gov/100/statute/STATUTE-102/STATUTE-102-Pg829.pdf http://www.gpo.gov/fdsys/pkg/CFR-2012-title40-vol32/pdf/CFR-2012-title40-vol32-part763-subpartE.pdf http://www.gpo.gov/fdsys/pkg/CFR-2012-title40-vol32/pdf/CFR-2012-title40-vol32-part763-subpartE.pdf https://www.osha.gov/laws-regs/oshact/completeoshact https://www.osha.gov/laws-regs/oshact/completeoshact http://www.gpo.gov/fdsys/pkg/CFR-2012-title29-vol6/pdf/CFR-2012-title29-vol6-sec1910-1001.pdf http://www.gpo.gov/fdsys/pkg/CFR-2012-title29-vol8/pdf/CFR-2012-title29-vol8-sec1926-1101.pdf

• 40 CFR 61, Subpart M - NESHAP This regulation covers the EPA's rules concerning the application, removal, and disposal of ACM as well as manufacturing, spraying, and fabrication of ACM. It also prohibits visible emissions of dust to the outside air during any activities. An amendment to this standard, issued on 20 November 1990 (55 FR 48406), enhances enforcement and promotes compliance with the current standard without altering the stringency of existing controls.

• 40 CFR 763, Subpart E - AHERA requires schools to designate a person to maintain compliance; inspect and identify friable and non-friable ACM; monitor and reinspect ACM;

develop and update management plans; determine and implement response actions; develop and implement operation and maintenance programs; notify parents, building occupants, and outside contractors of ACM in the building; and ensure that accredited persons perform these activities. This regulation has been amended to mandate public and private building owners to control airborne hazardous substances within their respective properties. (This regulation does not directly apply to Niagara Falls ARS (because it is not a school as defined by 40 CFR Part 763.83) but may be referenced in project specifications.)

• 49 CFR Chapter 1, DOT Regulations According to DOT 49 CFR 173, 174, 175, 176, and 177, asbestos cannot be transported for commerce without certain precautions. Proper labeling, handling, storage, and packaging are required. Rigid, leak-proof packaging, such as metal or fiber drums, is specified. Bags or other non-rigid packaging in closed freight containers, motor vehicles, or rail cars can also be used if there is no possibility of fiber release during transportation.

• 40 CFR 763, Subpart E Asbestos School Hazard Abatement Reauthorization Act (ASHARA) This law expanded the training and accreditation requirements under AHERA to apply to persons who work with asbestos in public or commercial buildings and schools.

Appendix C of this subpart, Asbestos Model Accreditation Plan, replaces the accreditation plan under AHERA and identifies who must be accredited to work with asbestos in schools and public and commercial buildings. The new rules took effect 4 April 1994, and the plan was implemented 4 October 1994.

1.3.3 State and Local Regulatory Review

The State of New York defers to federal OSHA regulations for dealing with occupational exposure to asbestos. Under EPA regulations, the State of New York regulates the transportation and disposal of asbestos. In New York, the following agencies provide regulatory review of asbestos removal projects and transportation of asbestos wastes:

• New York State Labor Law Article 30 Safety and Health, Section 900-911 Β Asbestos or Products Containing Asbestos Licensing regulates the certification process for companies, individuals, and the contractor-licensing process.

• New York State Title 12 Industrial Code of Rules and Regulations (NYCRR) Industrial Code Rule (ICR) 56. The Intent of the ICR is to reduce the risk to the public associated with the exposure to asbestos and to conform to federal requirements set forth in AHERA regulations by requiring appropriate training and certification of persons employed in all aspects of asbestos-related projects and their supervisors and employers. This regulation sets standards and procedures to follow when removing, enclosing, encapsulating, or disturbing http://www.gpo.gov/fdsys/pkg/CFR-2012-title40-vol9/pdf/CFR-2012-title40-vol9-part61-subpartM.pdf http://www.gpo.gov/fdsys/pkg/CFR-2012-title40-vol32/pdf/CFR-2012-title40-vol32-part763-subpartE.pdf http://www.gpo.gov/fdsys/pkg/CFR-2011-title49-vol2/pdf/CFR-2011-title49-vol2-part173.pdf http://www.gpo.gov/fdsys/pkg/CFR-2011-title49-vol2/pdf/CFR-2011-title49-vol2-part174.pdf http://www.gpo.gov/fdsys/pkg/CFR-2011-title49-vol2/pdf/CFR-2011-title49-vol2-part175.pdf http://www.gpo.gov/fdsys/pkg/CFR-2011-title49-vol2/pdf/CFR-2011-title49-vol2-part176.pdf http://www.gpo.gov/fdsys/pkg/CFR-2011-title49-vol2/pdf/CFR-2011-title49-vol2-part177.pdf http://www.gpo.gov/fdsys/pkg/CFR-2012-title40-vol32/pdf/CFR-2012-title40-vol32-part763-subpartE.pdf http://www.gpo.gov/fdsys/pkg/CFR-2012-title40-vol32/pdf/CFR-2012-title40-vol32-part763-subpartE-appC.pdf https://www.nysenate.gov/legislation/laws/LAB/A30 https://dol.ny.gov/system/files/documents/2023/12/icr56.pdf friable asbestos or handling asbestos or asbestos-containing materials in a manner that may result in the release of asbestos fibers.

• New York State 6 NYCRR Section 360.2.17(p) regulates landfill permitting and operations for the disposal of asbestos-containing materials.

1.3.4 Department of Defense Directive Review

To comply with Executive Order 12088, "Federal Compliance with Pollution Control Standards”, the Department of Defense (DOD) issued DOD Directive 4175.1. This directive, "Environmental Security”, mandates that all DOD activities establish environmental pollution programs. These programs recognize the need for comprehensive regulations to establish objectives, policies, and responsibilities at the installation level.

DOD issued Instruction 6055.5, requiring its agencies worldwide to comply both conceptually and operationally with EPA and OSHA requirements for controlling airborne hazardous substance exposure to personnel and surrounding environs.

1.3.5 Department of Air Force Regulatory Review

The Department of the Air Force develops instructions based on applicable federal requirements for its facilities. Each command or installation may develop more specific instructions based on state and local regulatory requirements. The following Air Force directives apply to the Niagara Falls ARS asbestos program:

• DAFI 91-202, Department of the Air Force Mishap Prevention Program;

• DAFI 32-1001, Chapter 16, Facility Asbestos Management;

• Air Force Policy Directive (AFPD) 32-70, Environmental Considerations in Air Force Programs and Activities;

• DAFI 48-137, Respiratory Protection Program; and

• United States Air Force Occupational and Environmental Health Laboratory (USAFOEHL) Report 86-072EH0021HGA Air Force Asbestos Guidance for Rating and Assessing Damage and Exposure (GRADE) System.

1.3.6 Glossary of Terms Definitions, and Acronyms

Appendix B provides a glossary of terms, definitions, and acronyms pertaining to the Niagara Falls ARS.

https://www.archives.gov/federal-register/codification/executive-order/12088.html https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodd/47151Ep.PDF https://static.e-publishing.af.mil/production/1/af_se/publication/dafi91-202/dafi91-202.pdf https://static.e-publishing.af.mil/production/1/af_a4/publication/afi32-1001/dafi32-1001.pdf https://static.e-publishing.af.mil/production/1/saf_ie/publication/afpd32-70/afpd32-70.pdf https://apps.dtic.mil/sti/tr/pdf/ADA174875.pdf

2.0 GENERAL INFORMATION

An effective asbestos management program requires each of the positions and organizations at Niagara Falls ARS to have a close working relationship and excellent communication. The AMP must clearly delineate roles and responsibilities.

At Niagara Falls ARS, the 914th ARW Civil Engineering Environmental Flight (CEV) APO has the primary responsibility for developing and implementing the AMP. Other organizations must assist the APO in areas such as detailed sampling efforts, information dissemination, legal concerns and interpretations, and project technical design activities. Specific roles and responsibilities are outlined in the AOP.

2.1 Asbestos Operating Plan

The AOP, located in Appendix A, dictates how the base will carry out asbestos-related projects. This includes, but is not limited to, the following:

• Organizational Roles and Responsibilities;

• Project Coordination and Communication;

• Training;

• Equipment and supply requirements;

• Identification of worker manuals or other written procedures and procedures for asbestos certification and asbestos disposition statements on programming documents;

• Yearly budget estimates;

• Procedures for interim control measures and extraordinary precautions;

• Requirements for a special response team and in-house inspection; and,

• Requirements for contractor asbestos analysis and abatement.

Terms, definitions, and acronyms are defined in Appendix B. References to Appendices C, D and F through L are located throughout this AOP.

3.0 ASBESTOS MANAGEMENT ACTIVITIES

The primary components of asbestos management are budgeting, scheduling, work classification, notification, and direct oversight of abatement and construction activities.

3.1 Scheduling

The facility surveys and hazard ranking are used to establish the priority list for asbestos abatement. When determined by the SGPB, existing acute hazards will be abated immediately, and potential hazards will be corrected as project funds and resources become available.

The priorities for planning and scheduling of routine maintenance and repair should be determined at the work task review meetings. This determination will be based on the risk priority assigned in the Asbestos Database and any recent changes in the condition of ACM discovered during required surveillance.

3.2 Identifying and Evaluating Hazards

The Air Force policy to manage ACM in place presents opportunities for ACM to be damaged or to change in physical condition. Periodic surveillance and re-inspections are required to maintain up-to-date information.

3.2.1 Inspections

Since Air Force Reserve Command (AFRC) bases do not operate primary or secondary schools, 40 CFR 763 regulations do not apply. Thus, there is no mandatory frequency for ACM inspections by an EPA-accredited building inspector. Performing an inspection every three years is not required at AFRC bases, unless it is needed for other reasons. Inspections may be necessary prior to building renovation or demolition when ACM data is not available for that site. EPA-accredited visual inspection and sampling will determine whether ACM is present and may be disturbed by the project.

3.2.2 Surveillance

DAFI 32-1001, Chapter 16, Facility Asbestos Management, requires periodic ACM surveillance (i.e., inspections). Surveillance shall be performed by the APO with the assistance from SGPB as needed.

Facilities that are known or suspected to have ACM shall be reviewed for material damage or deterioration.

As facilities are reviewed, the surveillance results will be added to the Asbestos Database. Base ACM surveillance every 6 months (per 40 CFR 763) is not required at AFRC bases, unless it is needed for other reasons. For example, if an ACM health hazard cannot be properly controlled or abated in a timely manner, then it may be necessary to inspect that site every 6 months. Routine periodic visual surveillance shall be performed to evaluate the physical condition of ACM as follows:

• Friable ACM (thermal systems insulation [TSI], surfacing, and sprayed-on materials) shall be inspected every 3 years, and

• Non-friable ACM (e.g., floor tile, roofing materials, etc.) shall be inspected every 3 years.

When requested, a certified contractor will test for asbestos in areas of suspected ACM, areas where a potential health hazard exists, areas that are scheduled for renovation or demolition where personnel may be exposed to asbestos dust or debris, or areas where a hazardous or regulated waste exists. The sampler will take bulk material samples and send them to an NVLAP-approved laboratory for appropriate microscopic analyses. The test results will be added to the Asbestos Database in Appendix C.

3.2.3 Testing and Analytical

If asbestos is suspected in friable materials, such as TSI or sprayed-on materials, or non-friable materials such as old floor tiles with mastic, old flat roofing panels, or window caulk, then the certified contractor will take bulk samples to determine any asbestos content. Samples will be sent to an NVLAP-approved laboratory for analysis. OSHA standard 29 CFR Part 1926.1101(b) defines ACM as “any material containing more than one percent asbestos”. Bulk samples should normally be analyzed for asbestos using

Polarized Light Microscopy (PLM) methods. However, Non-friable Organically Bound (NOB) materials such as floor tiles, adhesive mastic, window caulk, fire-rated cements, and roof flashing may have extremely small fibers, which cannot be detected by PLM. Therefore, NOB materials should only be analyzed for asbestos using Transmission Electron Microscopy (TEM) or PLM methods with point counting. Point counting with PLM analysis will provide more accurate results.

All surfaces shall be restored or repaired to the best extent possible after sampling has been completed.

3.2.4 Facility Assessments

The Exposure Assessment Numerical System and asbestos assessment forms are located in Appendices D and E.

The Exposure Assessment Numerical System will be used for priority ranking of ACM at Niagara Falls ARS. The asbestos hazard is calculated and issued a numerical rating that can be used to make decisions on how to perform the abatement actions.

For those facilities that have confirmed locations of damaged or deteriorated friable ACM, the SGPB and Safety Office (SE) will complete a hazard assessment to determine if an ACM health hazard for personnel exists. The APO will determine which management or maintenance programs are needed to control the ACM hazard.

3.3 Corrective Actions

Corrective actions are classified according to type of actions, asbestos removal, encapsulation, enclosure, or administrative (administrative would include the evacuation of facility personnel to eliminate exposure).

The decision to issue the work is primarily based on the level of effort and the quantity of asbestos to be abated. A work task, AF Form 332 or DD Form 1391 must be initiated for each location where damaged friable ACM is found.

• Corrective actions will be initiated by an AF Form 332. The ACM priority listing may be used to determine the priority of work.

• Contractor Actions: Based on the scope of the corrective action, large-scale abatement may also be prioritized and summarized on a DD Form 1391 or AF Form 332 for disposition.

Prioritization is based on the ACM priority assessment rating from the information generated on the form in Appendix E.

• Urgent or small-scale corrective actions may be accomplished through a service contract on an AF Form 9, Request for Purchase, or through the Air Force Government-Wide Purchase Card Program (AFGWPC). The use of the Air Force Government-Wide Purchase Card Program system for corrective actions on asbestos work is only authorized by the Base Civil Engineer or the APO.

3.3.1 Procedure

The Asbestos Database should be reviewed by the APO annually for corrective action progress and modifications to established priorities. Each DD Form 1391 and AF Form 332 may be considered an independent project. Where there is a cost benefit in undertaking simultaneous projects, the appropriate actions should be made to combine them. Imminent health hazards require that prompt corrective actions be taken.

3.3.2 Documentation

Complete corrective action must be adequately documented so appropriate modification can be made to the Asbestos Database. The process is dynamic as new surveys and assessments are completed; changes in priorities for other projects may result. Scheduled facility inspections may also alter priorities. This cyclic process will ensure funds are allocated on a worst first basis.

https://www.kadena.af.mil/Portals/40/Housing/AF%20FORM%20332.pdf?ver=1lJHOWHcN30WAMbhb2hPtA%3D%3D https://www.esd.whs.mil/Portals/54/Documents/DD/forms/dd/dd1391.pdf https://www.esd.whs.mil/Portals/54/Documents/DD/forms/dd/dd1391.pdf https://www.kadena.af.mil/Portals/40/Housing/AF%20FORM%20332.pdf?ver=1lJHOWHcN30WAMbhb2hPtA%3D%3D https://static.e-publishing.af.mil/production/1/saf_aq/publication/dafi64-117/dafi64-117.pdf https://www.esd.whs.mil/Portals/54/Documents/DD/forms/dd/dd1391.pdf https://www.kadena.af.mil/Portals/40/Housing/AF%20FORM%20332.pdf?ver=1lJHOWHcN30WAMbhb2hPtA%3D%3D

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4.0 RECORDS OF ASBESTOS-CONTAINING MATERIALS

4.1 Data Collection

The 914th ARW maintains an asbestos database for 914th facilities. The Asbestos Database (see Appendix C) is the single source of reference for a consolidated summary of information on the status of ACM in Reserve buildings at Niagara Falls ARS. It contains data on the location of the ACM within a facility, the type of asbestos, the percentage of asbestos composition in the ACM, the condition of the ACM, and whether it has sustained damage. The importance of maintaining accurate, up-to-date information in the Asbestos Database makes it essential to have a standardized process to acquire information on any facility activity, which may affect the status of ACM. The most recent version of the Asbestos Database will be maintained by the APO. To the extent possible, electronic accessible versions of the plan and database will be continually updated and made available to the required users by the 914 MSG/CEV (APO). The 914 MSG/CEV (APO) will maintain historical information of individual inspection surveys and lab reports.

Facilities that contain ACM will be visually evaluated in accordance with Section 3.3 of the AMP to update the condition of ACM and, if necessary, the priority assessment will be revised. These inspections, and surveillance, will be noted in the Asbestos Database. The APO will ensure the Asbestos Database will be updated every time an activity involving asbestos is undertaken.

4.2 The Asbestos Record

The APO will maintain and update these asbestos records as required. The asbestos record may be comprised of the following components as necessary:

• Asbestos Database,

• The Asbestos Survey Reports,

• Operation and Maintenance (O&M) Asbestos Activities File,

• Asbestos Project File,

• Asbestos Certification File, and

• Asbestos Training File.

4.2.1 Asbestos Database

Each Asbestos Database lists all areas where material was sampled, and asbestos was found to be present.

The APO will maintain the Asbestos Database. This information should be used by base personnel to determine the location of asbestos. Procedures should be established to keep the database up to date. The Asbestos Database does not list every location of ACM on the base. The APO or SGPB must be contacted if there is any doubt whether the material contains asbestos. The asbestos database requires the following information:

• Location,

• Name of inspector,

• Date of inspection,

• Building, room number,

• Sample identification number,

• Description of material sampled,

• Amount of ACM,

• Priority ranking of identified ACM,

• Exposure Hazard Assessment, and

• Type and percentage of asbestos in the ACM.

4.2.2 The Asbestos Survey Reports

Asbestos surveys and assessments shall be maintained. A bulk sample log, floor plan, and photo log shall be included to identify the location of ACM and the sample locations. These documents will identify areas which were sampled and help to resolve any conflicts in the Asbestos Database.

4.2.3 O&M Activities File

Asbestos management and operations performed on base will be documented in a file maintained by the APO. This file will include historical files from previous asbestos work and will be maintained indefinitely.

The APO will update the asbestos database if any of the activities affect this information, enabling all asbestos database users to have current information. The asbestos activities file will contain the following information:

• Work task number,

• Date,

• Facility number,

• Location (within facility),

• Description of activity performed,

• Personnel involved in activity, and

• Air sampling as accomplished.

4.2.4 Asbestos Project File

The APO will maintain a permanent file of detailed documentation of asbestos projects. The file will be maintained indefinitely and will include the following:

• Certifications and licenses of contractor personnel conducting asbestos work;

• Descriptions of all asbestos abatement activities performed, including dates, type of remediation, personnel involved, quantity of asbestos involved, disposal method and location, and results of post-control activity inspection and sampling;

• Copies of notification forms sent to the EPA and New York State Department of Labor (NYSDOL) regarding asbestos activities;

• Documentation and correspondence related to disposal (e.g., landfill receipts);

• Copies of daily inspection logs and industrial hygiene reports from contractors who have performed work involving ACM;

• Detailed reports of bulk sampling data accomplished by a contractor;

• Air monitoring exposure measurement data;

• Employee, contractor, public, and occupant notification procedures;

• Work schedule and abatement plan;

• Contract drawings and specifications;

• Certifications of EPA acceptance of landfill locations;

• Correspondence dealing with asbestos on the project; and,

• Other relevant reports, studies, and information such as fiber release episode documentation as deemed necessary by the APO or SGPB.

4.2.5 Asbestos Certification File

The APO will maintain a permanent file of asbestos certifications for base personnel who conduct or potentially oversee asbestos work. Records for EPA and state certifications will be maintained in this permanent file. Respirator fit testing records will be maintained by SGPB for base personnel.

4.2.6 Asbestos Awareness and Training File

The 914 MSG/SGPB will provide asbestos awareness training at Niagara Falls ARS. The APO will maintain a permanent file of all asbestos-related training performed on the base.

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A-1

Appendix A

Asbestos Operating Plan

ASBESTOS OPERATING PLAN

(AOP)

October 2025 i

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Purpose

1.2 General Information

1.3 Wing Commander (CC) / Environmental Safety and Occupational Health (ESOH)

Council

1.4 Base Civil Engineer (BCE)

1.5 Asbestos Program Officer (APO)

1.6 Civil Engineering Environmental Flight (CEV)

1.7 Civil Engineering Construction Flight (CEC)

1.8 Safety Office (SE)

1.9 Civil Engineering Resources (CER)

1.10 Bioenvironmental Engineering Services (SGPB)

1.11 Judge Advocate (JA)

1.12 Public Affairs (PA) Officer

1.13 Contracting (LGC) Officer

1.14 Air Force Civil Engineer Center - Operations Directorate, Engineer Division

(AFCEC/COS) and Environmental Center of Excellence (AFCEC/CZ)

2.0 PROJECT COORDINATION AND COMMUNICATION

2.1 Response Actions and Notifications

2.1.1 Work Review

2.1.2 Response to Notification of Material Potentially Containing Asbestos

2.1.2.1 Material and Location Previously Evaluated and Documented

2.1.2.2 Material and Location Not Previously Evaluated

2.1.2.3 Response to Damaged ACM

2.1.3 Notification of Asbestos Abatement

2.1.4 Emergency Project Notification

2.1.4.1 Initial Notification: ICR 56-3.5(a)

2.1.4.2 Emergency Approval: ICR 56-3.5(b)

2.1.4.3 Follow-up Notification: ICR 56-3.5(c)

2.1.5 Building Occupant Notification: ICR 56-3.6(a)

2.2 Communication and Warnings

3.0 TRAINING PROGRAM

ii

3.1 Training Requirements

3.2 AWARENESS TRAINING

4.0 EQUIPMENT AND SUPPLY REQUIREMENTS

5.0 WORKER MANUALS/ WRITTEN PROCEDURES

5.1 Pre-Work Submittals

5.2 Submittals During Project

5.3 Closeout Submittals:

6.0 BUDGETING

7.0 ASBESTOS ABATEMENT, RESPONSE AND CONTROL PROCEDURES

7.1 Abatement Contracts

7.2 Other Abatement Contracting Services

7.2.1 Survey/Assessment and Air Monitoring Services

7.2.2 Air Monitoring Services

7.2.3 Architect/Engineer Design Services

7.2.4 Bulk Sampling and Accredited Laboratory Services

7.3 Review Procedures for Construction Projects

7.3.1 Programming (MILCON Projects Only)

7.3.2 Design

7.4 Contractor Prequalification

7.5 Regulatory Compliance Responsibilities

7.6 Contract Responsibilities (Contractor)

7.6.1 Project Air Monitoring

7.6.2 Pre-abatement Air Monitoring

7.6.3 Abatement Area Air Monitoring

7.6.4 Exterior Abatement Area Air Monitoring

7.6.5 Differential Pressure Measurements of the Negative Pressure Enclosure

7.6.6 Final Clearance Air Monitoring

7.6.7 On-Site Documentation

7.6.8 Respiratory Protection

7.6.9 Safety

7.6.10 Personal Protective Equipment

7.6.11 Close-out Documentation

iii

7.7 Contract Responsibilities (Government)

7.7.1 Monitoring During Contract Performance

7.7.1.1 Inspection of the Abatement Area

7.7.1.2 Post-project Inspection

7.7.1.3 Final Clearance Procedures

7.7.2 Health and Safety

7.7.2.1 Health and Safety Operations

7.7.2.2 Respiratory Protection (29 CFR 1926.1101[H])

7.7.2.3 Emergency Safety Response on the Job Site

7.7.3 Waste Handling

7.7.3.1 ACM Waste Containerization

7.7.3.2 ACM Waste Transport Trailer and Dumpsters

7.7.3.3 ACM Waste Manifest

7.8 Disposal of Buildings Containing Asbestos

LIST OF TABLES

Table 1-1 - Asbestos Management Key Roles

Table 3-1 – Asbestos Personnel Classifications

Table 3-2 - Training and Medical Requirements for ACM Work Classes

Table 7-1 - Asbestos Project Air Sampling Requirements

1.0 INTRODUCTION

1.1 Purpose

Department of the Air Force Instruction (DAFI) 32-1001, Section 16.2.2, directs installations with an Asbestos-Containing Material (ACM) Program to develop written Asbestos Operating Plan (AOP).

This AOP dictates how the base will carry out asbestos-related projects. The plan will assign responsibilities, establish inspection and repair capabilities, and provide repair procedures and personnel protection instruction. This AOP provides references and guidance documents to Niagara Falls Air Reserve Station (ARS), 914th Air Refueling Wing (ARW). The AOP comprises the following components:

Section 1 Organizational Roles and Responsibilities;

Section 2 Project Coordination and Communication;

Section 3 Training;

Section 4 Equipment and supply requirements;

Section 5 Identification of worker manuals or other written procedures and procedures for asbestos certification and asbestos disposition statements on programming documents;

Section 6 Yearly budget estimates; and, Section 7 Procedures for interim control measures and extraordinary precautions. Requirements for a special response team and in-house inspection. Requirements for contractor asbestos analysis and abatement.

1.2 General Information

An effective asbestos management program requires each of the positions and organizations at Niagara Falls ARS to have a close working relationship and excellent communication. The AOP must clearly delineate roles and responsibilities. The key roles of asbestos management are summarized in Table 1-1.

At Niagara Falls ARS, the 914th ARW Civil Engineering Environmental Flight (CEV) APO has the primary responsibility for developing and implementing the AOP. Other organizations must assist the APO in areas such as detailed sampling efforts, information dissemination, legal concerns and interpretations, and project technical design activities.

TABLE 1-1

ASBESTOS MANAGEMENT KEY ROLES

Task

Civil Engineering

(CE)

Bioenvironmental Engineering Services

(SGPB)

On-site Inspections Evaluating Friable Situations Bulk Sampling Record Bulk Sample Test Results Record Air Monitoring Results Recommend Control Measures Project Development and Abatement Cost Estimating Develop Permanent Inspection Program Update AOP Review and Coordinate Operation and Maintenance (O&M) Tasks

Maintain Training and Awareness Programs Maintain Asbestos Database

The following sections describe the organizational roles and responsibilities for executing the AOP.

1.3 Wing Commander (CC) / Environmental Safety and Occupational Health (ESOH) Council

The 914th ARW Commander is responsible for compliance with this plan for facilities owned, operated or maintained by the 914 ARW. Tenant organizations are responsible for implementing their own asbestos management program for facilities owned and maintained by their units. The CC is the approval authority for the Asbestos Operating and Management Plan and holds chairperson status on the ESOH Council on all issues pertaining to environmental matters at Niagara Falls ARS.

It is the responsibility of the ESOH Council to ensure the appointment of the APO to manage the AOP for each individual unit at Niagara Falls ARS. In addition, the ESOH Council is responsible for ensuring that each base office is directly involved in its functional area of the plan.

1.4 Base Civil Engineer (BCE)

The BCE is responsible for ensuring development and implementation of the asbestos program. The duties of the BCE include the following:

• Making decisions on the methods and timeliness of removal and/or repairs of ACM;

• Overseeing the overall progress of the program;

• Ensuring the proper training of Civil Engineering personnel to handle tasks assigned in the AOP, in accordance with the requirements set forth in Section 4.0 of this AOP;

• Making information from the Asbestos Database available to New York State certified asbestos project designers and management planners so they may verify the presence or absence of asbestos at a project site;

• Ensuring work requirements are properly reviewed and identified for asbestos projects and maintenance;

• Appointing the APO; and,

• Budgeting for asbestos sampling.

1.5 Asbestos Program Officer (APO)

The APO will be appointed by the BCE from the Environmental Engineering flight. The duties of the APO include the following:

• Successfully completing an asbestos training course with an EPA-approved curriculum, in accordance with the requirements set forth in Section 4.0 of this AOP (it is recommended that certificates for either inspecting for asbestos, asbestos management planning or asbestos project design are obtained);

• Documenting the location and type of all ACM in base facilities in the asbestos database and keeping the records current and complete;

• Reviewing the Asbestos Database - (see Appendix C) to determine if an area of concern is known to contain ACM; if no information is available in the Asbestos Database - (see Appendix C), verifying that samples will be taken to determine if asbestos is present;

• Receiving information from asbestos abatement projects and inspections for input into the Asbestos Database;

• Retaining all files, reports, studies, and other documents pertaining to asbestos management activities;

• Informing facility managers about the location of ACM within their buildings as appropriate;

• Conducting periodic facility surveys for ACM and notifying SGPB where damaged, friable ACM is found;

• Reviewing the AOP every 5 years and updating as required

• Acting as the overall manager for oversight of all activities affecting locations containing ACM;

• Attending work task and facility project review board meetings, and reviewing projects for potential asbestos exposures;

• Ensuring that federal and state notifications concerning renovations or demolition involving asbestos material are submitted for projects not managed by CEC;

• Reviewing contract statements of work (SOW) on asbestos abatement actions;

• Reviewing designs and contractor submittals to ensure asbestos abatement is appropriately performed;

• Obtaining copies of all contractor asbestos closeout documentation for the permanent asbestos file;

• Resolving problems that may adversely affect the efficiency of the program; and,

• Assisting SGPB with the development of training for personnel involved in the program.

1.6 Civil Engineering Environmental Flight (CEV)

The duties of the CEV include the following:

• Maintaining waste/disposal records;

• Ensuring all ACM removed from a facility is properly containerized, stored in a secure area, and disposed of according to applicable regulations; and

• Updating this AMP.

1.7 Civil Engineering Construction Flight (CEC)

The role of the CEC is to evaluate and review construction projects where asbestos abatement is a part of the work. The duties and responsibilities of the CEC include the following:

• Have the person in the CEC that is charged with asbestos abatement oversight successfully complete an asbestos project designer training course with an EPA-approved curriculum, in accordance with the requirements set forth in Section 4.0 of this AOP (it is also recommended that certificates for either inspecting for asbestos or asbestos supervision are obtained and maintained);

• Reviewing and assessing design projects where asbestos abatement is a part of the project;

• Reviewing contract SOWs for adequate asbestos management and work practices;

• Reviewing all post-construction activities where asbestos remains and where O&M of the remaining ACM must be performed;

• Coordinating with APO and SGPB on asbestos abatement and O&M projects;

• Overseeing the construction contractor on O&M projects involving asbestos abatement;

• Ensuring that contract asbestos abatement projects are carried out per the contract and the technical specifications;

• Ensuring that all construction management personnel are properly trained to oversee or manage construction and O&M projects involving asbestos abatement;

• Ensuring that federal and state notifications concerning renovations or demolition involving asbestos material are submitted (for CEC managed projects);

• Reviewing contractor submittals and asbestos-related contract documentation on projects involving asbestos abatement;

• Providing all closeout asbestos records and changes to the database to the APO; and,

• Acting as the primary COR or equivalent on asbestos-related sampling contracts, blanket purchase agreements, or other contracts involving asbestos.

1.8 Civil Engineering Resources (CER)

The role of the CER is to evaluate and review Base Operating Services (BOS) Work Tasks for the potential to encounter ACM. The duties and responsibilities of the CER include the following:

• Have the person in the CER that is charged with evaluating Work Task scopes complete asbestos awareness training;

• Reviewing and evaluating Work Tasks for the potential to encounter ACM;

• Coordinating with the APO and SGPB to evaluate whether asbestos exists at the facility location where the renovation is proposed and whether sampling is recommended;

• Submitting a request for sampling if no sampling has been performed for a PACM;

• Transferring a Work Task to CEC as an asbestos abatement project if ACM is detected;

• Providing sampling results to the APO for inclusion in the Asbestos Database;

• Acting as an alternate COR or equivalent on asbestos-related sampling contracts, blanket purchase agreements, or other contracts involving asbestos; and,

• Supporting SGPB and/or APO with asbestos awareness training for facility managers where ACM is present.

1.9 Safety Office (SE)

The Safety Office will be involved in monitoring asbestos abatement activities and safety precautions, procedures, and policies per OSHA and Air Force safety guidelines. The duties and responsibilities of the Safety Office include the following:

• Including asbestos-related problems with a risk assessment code (RAC) of 1, 2, or 3 on the Hazard Abatement Plan, AF Form 3, and in the Base Master Hazard Abatement Program per

DAFI 91-202;

• Monitoring workplaces and practices to ensure adherence to established procedures and the prompt correction of unsafe acts and conditions, contractor workplaces and activities will be monitored, as required, to protect occupants;

• Developing safety briefings for personnel involved in the AOP program;

• Investigating accidents to determine causes and prevent recurrence; and

• Reviewing and approving confined…