FA9301-15-R-0005 _Attachment_2 _Appendix_D_EAFB_Asbestos_Management_Plan.pdf

EDWARDS AIR FORCE BASE

ASBESTOS MANAGEMENT PLAN

February 2015

412th Civil Engineer Directorate Environmental Management Division Edwards Air Force Base, California

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 1 of 54

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 2 of 54

Revision History

Date Name Description 27 Feb 2014 Ron Czarnecki, Jeanette Van Norden, Michele LaComb

Complete overhaul of AMP

April 2014 Ron Czarnecki, Jeanette Van Norden, Michele LaComb

Complete overhaul of AOP

3 Feb 2015 Ron Czarnecki, Jeanette Van Norden, Michele LaComb

1. Section 3.1.1.7.3 – NESHAP Notification revisions were addressed.

2. Section 8.1 work plan review timelines included

3. Section 8.1 wording added that requires Contracting

Office to ensure work plans are written/signed by CAC prior to submitting for review.

4. Section 8.1; included wording that ensures AMP/AOP and ACM Specification is included in contract as an applicable requirement.

5. AOP Section 12.1; work plan template and information required are included.

6. AOP Section 12.2; NESHAP Notification information and procedures are updated.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 3 of 54

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 4 of 54

TABLE OF CONTENTS

Section No. Title Page No.

1.0 INTRODUCTION

1.1. Personnel Responsibilities

2.0 FACILITY MANAGERS

2.1. Responsibilities

2.1.1. Monitoring

2.1.2. Notifications

2.1.3. Records

2.1.4. Base Civil Engineer Work Requests (Air Force Forms 332)

3.0 BASE CIVIL ENGINEERING OFFICE/ENVIRONMENTAL MANAGEMENT

3.1. Responsibilities

3.1.1. AMP and AOP Implementation, Review, and Updating

3.1.2. Installation Asbestos Facility Inventory

3.1.3. Construction Planning and Design Considerations

3.1.4. Support Emergency Situations

3.1.5. ACM Waste Shipments

3.1.6. Implement Regulations/Guidance

3.1.7. Training

3.1.8. Support the Environmental, Safety, and Occupational Health Compliance and Assessment Management Program

3.1.9. AMP and the Asbestos Operating Plan

3.1.10. Asbestos Operation Plan

3.1.11. Training

3.1.12. Facility Manager Program

3.1.13. Asbestos Monitoring

3.1.14. Installation Asbestos Facility Inventory

3.1.15. Work Requirements

3.1.16. Budgeting

3.1.17. Project Work

4.0 412 AMDS/BIOENVIRONMENTAL ENGINEERING (BE)

4.1. Responsibilities

4.1.1. AMP Coordination

4.1.2. Asbestos Operation Plan

4.1.3. Base Asbestos Data

4.1.4. Budgeting

4.1.5. Review Responsibilities

4.1.6. Support Emergency Situations

4.1.7. Determine Health Considerations

4.1.8. Maintain Regulations/Guidance Files

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 5 of 54

5.0 PUBLIC HEALTH/FORCE HEALTH MANAGEMENT

5.1. Responsibilities

5.1.1. Health Examination List

5.1.2. Occupational Health Medical Examination

5.1.3. Examinations

5.1.4. Health Trends

6.0 FLIGHT MEDICINE/OCCUPATIONAL MEDICINE

6.1. Responsibilities

6.1.1. Respirator Medical Certification

6.1.2. Occupational Health Medical Examinations

6.1.3. Physician’s Written Opinion

6.1.4. Medical Records

7.0 MILITARY FAMILY HOUSING

8.0 CONTRACTING ORGANIZATIONS

8.1. Construction, Demolition and Abatement Responsibilities

8.1.1. Supplies and Services Responsibilities

APPENDIX A: LIST OF GUIDING INSTRUCTIONS, REGULATIONS, AND

POLICIES ...................................................................................................... A-1

APPENDIX B DESCRIPTION OF REQUIRED BASE PERSONNEL TRAINING .........B-1

APPENDIX C CE ASBESTOS OPERATIONS PLAN ........................................................ C-1

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 6 of 54

LIST OF ABBREVIATIONS AND ACRONYMS

ACBM Asbestos-Containing Building Material ACM Asbestos-Containing Material A-E Architect-Engineer AF IMT Air Force Information Management Tool AFB Air Force Base

AFCEC Air Force Civil Engineer Center AFFTC Air Force Flight Test Center AFI Air Force Instruction AFMC Air Force Materiel Command AFOSH Air Force Occupational Safety and Health AHERA Asbestos Hazardous Emergency Response Act AMP Asbestos Management Plan AOO Asbestos Operations Officer AOP Asbestos Operating Plan BAC Base Asbestos Coordinator BCE Base Civil Engineer

BE Bioenvironmental Engineering CAC Certified Asbestos Consultant CBR Contract By Request CCR California Code of Regulations

CE Civil Engineering CFR Code of Federal Regulations COTR Contracting Officer’s Technical Representative CSST Certified Site Surveillance Technician DTSC Department of Toxic Substances Control EIAP Environmental Impact Analysis Process

EIS

EM

Environmental Impact Statement

Environmental Management

GRADE Guidance For Rating And Assessing Damage And Exposure IAW In Accordance With KCAPCD Kern County Air Pollution Control District

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 7 of 54

LIST OF ABBREVIATIONS AND ACRONYMS (Concluded)

LOTD Letter of Technical Direction

MFH Military Family Housing NESHAP National Emissions Standard for Hazardous Air Pollutants O&M Operations and Maintenance

OHME Occupational Health Medical Examination OHWG Occupational Health Working Group OSHA Occupational Safety and Health Administration PH Public Health PM Project Manager POC Point of Contact PPE Personal Protective Equipment PRIME Process, Records, and Information Management

QAE Quality Assurance Evaluator R Recommended Training

RAC Risk Assessment Code RWP Recurring Work Program SABER Simplified Acquisition of Base Engineering Requirements

SOW Statement of Work

U.S. EPA United States Environmental Protection Agency

USACE United States Army Corps of Engineers

X Required Training

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 8 of 54

1.0 INTRODUCTION

Air Force Instruction (AFI) 32-1052, Facility Asbestos Management 4 January 2013, implements, establishes requirements, and assigns responsibility for facility asbestos management at AFMC installations to account for its unique organizational structure. This Asbestos Management Plan (AMP) outlines the responsibilities of the Edwards Air Force Base (AFB) 412th Civil Engineer Directorate (CE); Environmental Management Division (EM); 412th Aerospace Medicine Squadron (AMDS)-Bioenvironmental Engineering (BE); Public Health, and Flight Medicine; facility managers; and the Air Force Test Center (AFTC) Contracting, Purchasing, and Safety Offices.

The base asbestos inventory is a component of this AMP. The inventory will exist in an electronic format within the electronic records management, asbestos section, and in the centralized paper files within the CE Asbestos Operations Officer’s (AOO) office. This AMP is to be used in conjunction with the current Asbestos Operating Plan (AOP) (AFTC Plan 32-1052, Part I). Additional responsibilities, procedures, and guidance are identified in the AOP.

Civil Engineering has the primary responsibility in the facilities asbestos management program; but in order to work properly, the asbestos management process must also be a multifunctional team approach involving other Edwards AFB functions such as EM, elements of 412 AMDS, and other base functional activities, including the building users.

The asbestos management team (assembled from the various base functions) is responsible for ensuring that the AMP, as originally agreed upon by the group, is implemented and revised as necessary to meet the goals and objectives stated within the plan or changing conditions. This plan will guide implementation of the AMP at Edwards AFB. Updates to the AMP were accomplished through coordination between CE, BE, and EM, with input from other asbestos-responsible organizations.

The personnel responsibilities noted in this AMP are a consensus of the responsible organizations as to how AFI 32-1052 will be implemented at Edwards AFB. Guiding instructions, regulations, and policies used for preparing this AMP are provided in Appendix A.

1.1. Personnel Responsibilities

The success of the Edwards AFB AMP depends on the active involvement and understanding of all parties. This will include CE, EM, facility managers, and BE. The base must ensure that all asbestos related activities are performed in compliance with relevant federal, state, and local laws. To achieve this, the base will designate a person to ensure compliance with relevant regulations and laws, and the relevant policies and procedures. The designated person will be known as the Base Asbestos Program Manager (Base Asbestos Coordinator [BAC]) and shall be located in the EM office.

The base will also provide support staff, which includes consulting staff, to assist the BAC in conducting the necessary responsibilities.

Job responsibilities assigned to key organizations or jobs related to developing and implementing the AMP are specified in the following sections.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 9 of 54

2.0 FACILITY MANAGERS

Facility managers represent the first line of defense in protecting facility occupants and visitors from asbestos exposure. They ensure in place management of asbestos-containing material (ACM) is accomplished effectively, and expeditiously report any change in ACM condition to the appropriate organization. The organization commander appoints the facility manager.

Facility managers must attend, as a minimum, the facility manager training offered by CE.

The facility manager training will address the facility manager’s responsibilities related to monitoring the condition and maintenance of ACM, monitoring frequency, what to look for, what to do if there is damage or potential damage, and who to call for issues or questions.

Facility managers also should obtain Class IV Asbestos Awareness training required by the Occupational Safety and Health Administration’s (OSHA) Title 29, Code of Federal Regulations (CFR), Section 1926.1101.

2.1. Responsibilities

The facility manager’s responsibilities are outlined in the following subsections.

2.1.1. Monitoring

The facility manager will schedule facility reviews with the CE maintenance function as required to identify and accomplish all recurring work, minor maintenance, and repair; and to validate building conditions and work requirements at the time of the reviews.

2.1.1.1. Conduct Maintenance Check Monitoring

a. In public areas, inspect all exposed insulating material and other exposed asbestos-containing building material (ACBM) for damage as part of the daily, weekly, or monthly maintenance check. Semiannually inspect these materials in nonpublic areas like boiler and maintenance rooms, attics, and crawl spaces; the semiannual inspection can conveniently be done as part of the Recurring Work Program (RWP) when changes are made to the heating-cooling-heating cycles.

b. Submit Air Force Form 332, Base Civil Engineer Work Request, through MAXIMO, or call CE for repair or removal.

c. Include EM and BE as part of the facility review/inspection when friable asbestos is present in a facility.

d. Annotate observations and keep records with facility manager information and report instances of damage.

e. In the event of re-inspection, the frequency shall be coordinated with CE, and EM.

f. Work with CE to determine when damaged ACM can be repaired or removed by qualified personnel.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 10 of 54

2.1.2. Notifications

a. Notify tenants, occupants, employees, and outside contractors of information related to ACM present in the subject building.

b. Notify tenants when asbestos-related work is scheduled in a facility.

2.1.3. Records

Maintain all asbestos-related records in the facility manager log indefinitely as per the Edwards AFB Instruction 32-1001, Facility Manager (located in each facility).

2.1.4. Base Civil Engineer Work Requests (Air Force Forms 332)

Develop and submit any requests for repair, renovations, or demolition (e.g., work impacting surfaces, building materials, or fixtures) on Air Force Forms 332. Note: Repair, removal, or cleaning of any damaged or disturbed ACM is not allowed unless personnel conducting the work are properly trained in accordance with (IAW) asbestos rules and regulations and authorized by the Asbestos Operations Officer (AOO) to do so. This includes high-speed buffing of tile floors;

however, normal cleaning of intact ACM surfaces is allowed.

3.0 BASE CIVIL ENGINEERING OFFICE/ENVIRONMENTAL MANAGEMENT

Civil Engineering has overall responsibility to operate and maintain facilities at their lowest life-cycle costs and conducts these activities IAW applicable laws, regulations, and federal policies to support the Air Force mission. The decision to repair (which includes replacement of facility components), renovate, or demolish a building is made by CE. Asbestos is a facility component and, as such, the maintenance, repairs (which includes repair by replacement), or removal is a CE responsibility. Civil Engineering’s responsibilities encompass identifying initial requirements, planning, programming, budgeting, operations and maintenance of asbestos, and maintenance of the central asbestos database, which includes facility inventory, history, abatement plans, sample results, or any other asbestos related project documents.

Civil Engineering will designate an AOO. The AOO maintains the central file database of all ACM information by facility (includes installation facility asbestos inventory). Any organization which gathers asbestos-related information shall forward copies to the AOO for centralized storage.

EM specific requirements are outlined in the following section as well as in shared responsibilities. The EM office has the responsibility, in coordination with CE and BE, of implementing and updating the AMP. EM is responsible for the coordination of environmental regulatory compliance. EM acts as the point of contact (POC) between the base and federal, state, and local environmental regulatory agencies. (AFTC Safety [Safety] interfaces with OSHA and California OSHA.)

EM designates a BAC to perform the task of asbestos management. The BAC, or designee, will coordinate updating and assist with implementing the AMP. The BAC and technical staff shall obtain, as a minimum, AHERA-accredited training for building inspection, management

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 11 of 54 planning, contractors/supervisors, and project design, and shall have an individual certified with California as a CAC on staff, and it is highly encouraged that the BAC also be a California certified CAC.

3.1. Responsibilities

3.1.1. AMP and AOP Implementation, Review, and Updating

Implement the AMP/AOP including review and updating, as needed.

3.1.2. Installation Asbestos Facility Inventory

Ensure all information required for asbestos management (e.g., facility surveys, asbestos updates, submitted work plans and comments, and NESHAP notifications) are documented and current in the Civil Engineering AOO central file database and/or, when applicable, in the Electronic Records Management system asbestos files.

Using records and field verification, determine if a NESHAP threshold amount of asbestos is being removed on projects (260 linear feet on piping and 160 square feet on facility components).

3.1.3. Construction Planning and Design Considerations

Assist programmers, designers, and contract inspectors in identifying environmental requirements and work practices necessary to provide a complete project to include:

a. Incorporate wording in Air Force Forms 813, Environmental Impact Analysis Process (EIAP), and environmental impact statements (EIS) requiring programmers, designers, and contract inspectors to notify EM prior to the start of project development. Review and comment on Air Force Forms 813, EIAPs, and EISs for asbestos/toxics issues.

b. Review contractor-provided asbestos sampling plan or asbestos abatement plan (i.e., asbestos removal, asbestos emissions control, and training records) for compliance with environmental rules and regulations and approve or require necessary changes to the contractor’s submittal. These contractor plans shall be detailed and comprehensive.

c. Prior to any work that would disturb asbestos, review and approve the contractor waste disposal plan or required changes. The waste disposal plan will include at a minimum:

(1) Methods to control the discharge of visible emissions to the outside.

(2) Methods to seal all wet asbestos waste into containers or leak-tight wrapping.

(3) Plans for labeling containers or wrapping material using warning labels specified by OSHA, U.S. EPA, Department of Toxic Substances Control (DTSC), and Department of Transportation requirements (as applicable).

(4) Plans to mark vehicles used to transport asbestos-containing waste during loading and offloading to meet applicable rules and regulations.

(5) Identification of the U.S. EPA and/or DTSC-approved landfill; Edwards AFB must use base-approved landfills. Coordinate with EM for a list of base-approved landfills.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 12 of 54

d. Ensure notification is provided to KCAPCD at least 10 working days before start of work, when threshold amounts of ACM are removed.

e. Ensure the SOW includes a clause that requires the contractor to provide EM with a copy of the notification for review and approval 5 days before submittal to KCAPCD.

f. Review revised notification prior to submittal to the NESHAP agency.

g. Ensure, when design is done by contract, that the SOW for the A-E includes that AOP inspection requirements are met and verify location, quantity, and condition of asbestos as part of the site investigative study. (EM and CE will provide the A-E with all the data that are available to minimize the cost of the site investigation.)

h. Review the designer’s/A-E completed (and stages of design) design drawings, specifications, and asbestos surveys to determine that all requirements have been met.

i. Review CE work orders (Air Force Forms 332), plans, and projects to ensure ACM environmental issues are addressed.

j. Review any new project specification for contract work involving ACM that has not been previously reviewed or approved by EM (e.g., Air Force Center for Engineering and the Environment [AFCEC] and United States Army Corps of Engineers [USACE]).

k. In coordination with CE and BE, update the Edwards AFB asbestos specifications, as needed, to meet the base/project needs.

3.1.4. Support Emergency Situations

Support, as needed, CE and BE implementation of AOP procedures for emergency response and in-house inspections to mitigate asbestos emergency situations.

3.1.5. ACM Waste Shipments

Review waste shipments for compliance.

a. Review waste shipment records (hazardous and nonhazardous ACM) for completion and accuracy before shipment.

b. Verify shipment labeling and packaging to meet applicable rules and regulations.

c. Sign all ACM hazardous and nonhazardous waste manifests before shipment.

d. Hazardous Waste Support Facility shall follow the applicable recordkeeping and exception reporting requirements as described in 40 CFR 262, Standards Applicable to Hazardous Waste Generators, and Title 22, California Code of Regulations, Division 4.5, Chapter 12, Standards Applicable to Hazardous Waste Generators.

e. Keep copies of waste shipment records for at least 2 years per regulations (Edwards AFB requires records to be kept indefinitely).

3.1.6. Implement Regulations/Guidance

a. Coordinate regulatory requirements and serve as the POC for all regulatory agencies.

b. Ensure the most current environmental regulations are on file at EM.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 13 of 54

3.1.7. Training

Train and/or advise CE, BE, Contracting Offices (Edwards AFB, U.S. Navy, USACE, General Services Administration, and AFCEC), facility managers, and other interested parties on the AMP, as necessary or requested.

3.1.8. Support the Environmental, Safety, and Occupational Health Compliance and Assessment Management Program

Annually evaluate the AMP and implement changes based on findings using the Environmental, Safety, and Occupational Health Compliance and Assessment Management Program process IAW AFI 90-803.

3.1.9. AMP and the Asbestos Operating Plan

Coordinate with BE on the AMP and AOP.

3.1.10. Asbestos Operation Plan

Implement the AMP/AOP including review and updating, as needed.

3.1.11. Training

The AOO must obtain and maintain, as a minimum, the Asbestos Hazardous Emergency Response Act (AHERA) (40 CFR 763) accredited training for building inspection, management planning, contractors/supervisors, and project design. If there is additional AOO staff, they shall have the same training as the AOO.

Project Management office engineers, system project engineers, engineering technicians, programmers, Simplified Acquisition of Base Engineering Requirements program technicians, contract quality assurance evaluators (QAEs), and shop personnel should take a shortened asbestos course (Appendix B).

Full AHERA-accredited training for the BAC as described in Section 3.0 Base Civil Engineering Office/EM, of this report, and Appendix B, with annual refresher training and California CAC license, when applicable.

3.1.12. Facility Manager Program

a. Maintain a quality Facility Manager Program.

b. Provide Facility Manager Training to include:

(1) Information on general facility maintenance requirements.

(2) Copies of Section 2.0, Facility Managers, of this AMP are distributed to ensure facility managers are familiar with their asbestos responsibilities. Training should also include, but not be limited to: what to look for, the frequency of inspections, and who to contact for assistance.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 14 of 54

(3) Annual refresher training regarding their responsibilities under this AMP.

3.1.13. Asbestos Monitoring

a. Participate with the facility manager in ACM monitoring, when requested.

b. Note changes to ACM during RWP inspections and whenever performing maintenance activities in areas like boiler rooms, maintenance rooms, attics, and crawl spaces.

c. Craftsmen will notify work lead, controller, or facility manager of any damaged friable conditions existing.

(1) Occupied spaces shall be considered emergencies and responded to immediately.

(2) Unoccupied spaces (e.g., mechanical and boiler rooms) shall be considered urgent and responded to within 7 calendar days.

(3) Work orders, job orders, and emergencies will be routed to AOO for evaluation, response, and abatement, as required.

d. Determine when damaged ACM can be repaired or replaced, and notify facility manager.

e. Ensure damaged ACM is quickly repaired or removed by qualified personnel.

3.1.14. Installation Asbestos Facility Inventory

a. Ensure documentation to reflect changes in quantity, condition, and location of ACM in facilities resulting from renovations and repair work are provided to the AOO for incorporation into the centralized filing system.

b. Ensure contract and in-house asbestos surveys are provided to the AOO.

c. Ensure contracted-work compliance.

(1) Contractor will submit updated drawings/floor plans showing where and how much ACM the project affected. This will be submitted to the project manager and AOO.

(2) Work accomplished under an asbestos contract (e.g., Indefinite Delivery/Indefinite Quantity) or credit card will be updated by the AOO.

(3) Project managers/engineers are responsible for ensuring asbestos project information updates are submitted to the AOO.

(4) New contracts should specify that closeout documents are required at the end of the project and reflect any changes made to ACM within the facility. Those closeout documents must also be submitted to the AOO.

d. Material safety data sheets for all new materials put into facilities or new facility construction will be submitted to the AOO for inclusion in the installation facility inventory to substantiate to the Kern County Air Pollution Control District any non-ACM conditions for future renovations/demolition.

3.1.15. Work Requirements

a. Any work to be accomplished on a facility, whether by contract or self-help, is started by the initiator submitting an Air Force Form 332 to CE.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 15 of 54

b. Civil Engineering, upon acceptance, routes the Air Force Form 332 through the AOO for coordination.

c. For emergency situations, ensure work requests are routed through the AOO for coordination.

3.1.16. Budgeting

a. The AOO shall identify and submit a budget for facility asbestos activities to include:

(1) Projects with environmental health hazard deficiencies,

(2) Maintenance and repair,

(3) ACM emergencies, and

(4) Manpower to accomplish program including further LOTD contractor support positions and personnel.

(5) Equipment, supplies, and sample analysis for project quality assurance and control inspection(s).

b. The BAC shall identify and submit a budget for facility asbestos activities to include:

(1) Provide operational and technical support for asbestos and lead programs,

(2) Provide surveillance and oversight of Toxics Program,

(3) Maintain the ERM filing system for the asbestos and lead programs,

(4) Provide support to interpret, apply and consult with CEV and CE personnel on cost effective, environmentally compliant management of toxic substances such as asbestos,

(5) Guide integration of environmental requirements for toxics into CE operational plans, oversee implementation and monitor compliance and

(6) Assist in the review of plans and policies concerning base-wide toxic material management.

3.1.17. Project Work

Accomplish and support project work.

3.1.17.1. Asbestos Operations Officer

a. Classify any demolition, renovation, self-help, or maintenance activities where ACM might be disturbed to include amounts and locations identified through the review of drawings, asbestos inventories/surveys, and site visits.

b. In conjunction with the programmers, determine if asbestos would be disturbed and recommend if removal is optional or mandatory, and consider removing asbestos as part of the project alternative, even if renovation would not disturb asbestos.

c. Ensure facilities with damaged asbestos or assigned RAC for ACM are effectively managed, and priority facility removal actions are completed promptly.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 16 of 54

d. Consult BE for any work requiring a Health Risk Assessment of a work center with potential exposure to ACM, as necessary.

e. Respond to and mitigate emergency situations and submit an Air Force Form 332, or call in a job order for damaged or out-of-place ACM.

f. Notify EM and BE of actions taken as applicable.

g. Coordinate Civil Engineering ACM inspector/sampler worker protection with BE and environmental requirements with EM to include annual medical examinations, respirator fit tests, and ACM training in their discipline.

3.1.17.2. Programmers

a. In conjunction with the AOO/BAC, determine if asbestos would be disturbed and recommend if removal is optional or mandatory, and consider removing asbestos as part of the project alternative, even if renovation would not disturb asbestos.

b. Determine special requirements contributing to cost (e.g., negative air containment, special worker protection, special handling or disposal, and survey requirements). Consult with AOO/BAC as needed.

c. Ensure adequate funding for asbestos requirements (e.g., third-party monitoring, abatement, specification development, and surveys) is requested during the budgeting process.

b. Ensure funding is allocated to identify all ACMs and removal requirements prior to any Request for Proposal being sent out for contract bid proposals.

3.1.17.3. Project Managers/Engineers (CE or Design-Build Contractors)

a. Ensure the statement of work (SOW) contains a requirement to verify location, quantities, and condition of ACM that could be disturbed, IAW OSHA 1926.1101 (k) Communication of Hazards. Ensure full-time third party oversight/inspection (CAC or CSST as described in paragraph “o” of this section) are included in SOW requirements.

b. Ensure when design is done by contract that the SOW for the architect-engineer (A-E) includes that AOP inspection requirements are met. The A-E shall verify location, quantity, and condition of asbestos as part of the site investigative study, if a comprehensive survey has not been completed. If no survey data exists, ensure a comprehensive survey or the appropriate type of survey for the proposed project (i.e., if a demolition or a demolition-type survey is done) is accomplished by an outside contractor not affiliated with the general or abatement contractor (i.e., an independent third-party consultant) or government personnel. A sampling plan is required prior to any contractor survey (see requirement k.). See the AOP for survey requirements.

c. Ensure specifications require all submittals and facility changes to asbestos are submitted to the government project manager (PM) and AOO.

d. Work with EM and AOO to provide the A-E with all available asbestos data to minimize cost of, or eliminate need for, site investigation.

e. Ensure proper specifications are written through the design process by an AHERA-accredited government person, or a California Certified Asbestos Consultant (CAC).

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 17 of 54

f. Ensure specifications include a requirement for the National Emissions Standards for Hazardous Air Pollutants (NESHAP) notification and associated revisions—required for all demolition projects (regardless of presence or absence of asbestos) and for renovations where regulated ACMs over 160 square feet or 260 linear feet will be disturbed—to be submitted to EM for review and approval 5 working days prior to contractor submission of the notification to Kern County Air Pollution Control District (KCAPCD); revisions shall be submitted to EM for approval before the revised work commences. In addition, after review by EM, a courtesy notification is required to be sent to KCAPCD for any abatement project, no matter what size.

g. Ensure specification requirement for safe handling, transportation, and disposal of ACM, and manifesting paperwork is done properly through EM.

h. Ensure all contracted asbestos project designs are accomplished by California licensed Asbestos Project Designers (also a CAC), to include asbestos removal/abatement plans.

i. Ensure the completed design drawings, specifications, and any asbestos surveys are provided electronically to EM for review and determination that all requirements have been met (e.g., OSHA, NESHAP, or state and local requirements) before contracting and/or final acceptance.

j. Submit final design package to EM for review to determine all asbestos requirements are included (e.g., OSHA, NESHAP, or state and local requirements).

k. Ensure contractor Asbestos Removal Plan (abatement plan) and/or sampling plan submittals are provided to EM for review and approval prior to work commencing on the project.

l. When applicable, ensure contractor Health and Safety Plan submittals are provided electronically to the AOO/EM for review prior to work commencing on asbestos projects, or is incorporated into the Asbestos Removal Plan.

m. Act as interface between design engineer, EM, and contractor accomplishing the contract to ensure asbestos compliance on the project.

n. Act as the contracting officer’s technical representative (COTR).

o. Ensure all project construction inspectors overseeing asbestos work are:

(1) If contracted: licensed California CAC, or a Certified Site Surveillance Technician (CSST) under the direct supervision of a CAC.

(2) If government: United States Environmental Protection Agency (U.S. EPA) accredited for the asbestos jobs they are performing.

p. Present copy of CAC project documentation to EM for review at scheduled periods during the project or as requested by EM.

q. Update or ensure facility update information is provided to AOO for inclusion in the installation facility inventory.

r. Contract by Request (CBR) will not be allowed if any asbestos or suspect-asbestos materials are present.

s. On all construction projects involving asbestos, per Air Force Pamphlet 32-1005, Working in the Engineering Flight, (Paragraphs 2.6.4.2 and 3.5.13), as part of the closeout procedures, the CE project manager shall ensure the following statement is posted on the front of project folders:

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 18 of 54

“Asbestos involved. This folder must be maintained for a period of 30 years IAW OSHA 1910 and 1916.” Note: These records may be retained by the Air Force indefinitely.

4.0 412 AMDS/BIOENVIRONMENTAL ENGINEERING (BE)

a. IAW 48-145, Occupational and Environmental Health Program, 15 September 2011:

Works directly with the BCE to determine if recommended actions are necessary (e.g. frequent monitoring, removal of personnel from the area, temporary controls, or other protect measures) in order to protect human health.

b. With the BCE, conducts direct evaluation of facilities containing ACM, which cannot be reliably maintained, repaired, or isolated and that is likely to become friable or not remain intact.

c. Provides advice to the installation commander regarding health issues associated with “Must remove” mandates. Where there is no mandate to remove asbestos BE will provide advice to the BCE regarding the health risk to facility occupants.

4.1. Responsibilities

4.1.1. AMP Coordination

Coordinate on the AMP, which is developed by the asbestos management team and updated in coordination with CE and EM.

4.1.2. Asbestos Operation Plan

Review and comment to CE on AOP responsibilities for potential future updates.

4.1.3. Base Asbestos Data

All BE-generated data (e.g., asbestos hazard assessment information), inspections, and air monitoring results will be provided to the AOO when requested.

4.1.4. Budgeting

Ensure budget is allocated for base asbestos support (i.e., AMP requirements, air monitoring, and sampling).

4.1.5. Review Responsibilities

Review work orders, plans, or projects through the MAXIMO database (AF Form 332 submission) for occupational/environmental health issues, including self-help projects.

4.1.6. Support Emergency Situations

Advise the BAC and AOO of potential hazards involved with ACM incidents.

a. Determine when controlled/restricted areas need to be established.

b. Advise the building manager and unit commander when a dangerous situation warrants relocation of personnel.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 19 of 54

c. Perform air and bulk sampling and evaluate the analytical results of the collected samples.

d. Report results of air and bulk sampling to affected parties, the AOO, and EM.

e. Ensure AMP guidelines are followed when damaged ACM is discovered or reported.

(1) Promptly respond to call.

(2) Evaluate the situation.

(3) Notify CE and EM of an ACM-related incident and develop an evaluation of health risk.

(4) Coordinate with EM and CE on required action(s) to take to protect health and achieve compliance.

(5) Notify facility manager of results and actions taken.

4.1.7. Determine Health Considerations

Evaluate facility asbestos for health risk to occupants.

a. In consultation with CE, determine best method for management of the deficiency.

b. Ensure procedures for protection of workers engaged in ACM activities are in compliance with AFOSH and OSHA requirements (as applicable).

c. Conduct occupational and environmental health evaluations as required.

d. Accompany Department of Labor and OSHA inspectors during any occupational health inspections and attend all in briefs and out briefs.

e. Determine personal protective equipment (PPE) requirements for government industrial workers working with or around ACM based on occupational health evaluation.

f. Provide occupational health evaluation data to the base Occupational Health Working Group (OHWG) to determine requirement for occupational health physical exams.

(1) Accomplish respiratory protection fit testing for governmental personnel.

(2) Evaluate industrial and occupational health matters as they relate to asbestos.

(3) Maintain all occupational and health asbestos records indefinitely.

4.1.8. Maintain Regulations/Guidance Files

Maintain applicable master file of OSHA and AFOSH standards, other regulations, and guidelines pertaining to asbestos.

5.0 PUBLIC HEALTH/FORCE HEALTH MANAGEMENT

The base Public Health (PH) office is a flight of the 95th Aerospace Medicine Squadron.

The base PH is a key player in the base occupational health surveillance program, which is managed through the PH Force Health Management element. The Force Health Management element ensures the appropriate individuals requiring examinations and training obtain the

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 20 of 54 appropriate level needed. The base PH looks at and evaluates current situations and projects future potential to assist in adapting the workforce processes to protect them from ACM.

5.1. Responsibilities

5.1.1. Health Examination List

Maintain a list of all personnel requiring health examinations and provide the list of personnel requiring the examinations to the Force Health Management element on a monthly basis.

5.1.2. Occupational Health Medical Examination

Perform Occupational Health Medical Examination (OHME) scheduling, reporting, and follow-up on authorized base industrial workers as determined through the base OHWG.

5.1.3. Examinations

Along with the BEE and the Flight Surgeons Office, ensure that proper examination is given to affected employees in order to comply with applicable regulations.

5.1.4. Health Trends

Evaluate health trends of workers and make recommendations to the supervisors, if needed.

6.0 FLIGHT MEDICINE/OCCUPATIONAL MEDICINE

The Occupational Medicine element of Flight Medicine of the 95th Aerospace Medicine Squadron is responsible for administering occupational physical examinations IAW AFI 48-145, Occupational Health Program, and other Air Force policies. These policies ensure the base workforce who are required to work with or around ACM can wear the appropriate PPE to protect them from ACM-related health hazards.

6.1. Responsibilities

6.1.1. Respirator Medical Certification

Determine whether base asbestos workers (e.g., AOO, BEE, and EM inspectors) are medically certified to wear a respirator to accomplish asbestos-related duties.

6.1.2. Occupational Health Medical Examinations

Perform OHME on authorized base industrial workers as determined through the base

OHWG.

6.1.3. Physician’s Written Opinion

Provide a physician’s written opinion.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 21 of 54

6.1.4. Medical Records

Maintain the medical records IAW the Air Force and OSHA policies.

7.0 MILITARY FAMILY HOUSING

The MFH is now privatized and is managed by Corvias who serves as the property manager for the Air Force and must work with other organizations on base to ensure appropriate action is taken to protect residents from environmental hazards in their homes; reference NESHAP.

8.0 CONTRACTING ORGANIZATIONS

Contracting organizations include: Base Contracting, USACE, U.S. Navy, AFCEC, and all other contracting agencies and avenues.

Contracting organizations and their contracting officers are responsible, as an acquisition team member, for ensuring the contractor is in compliance with the specifications for ACM renovation and demolition projects that include:

a. Reviewing and awarding contracts,

b. Overseeing accomplishment of contracted work, and

c. Ensuring compliance with specifications, terms, and conditions, as well as all federal, state, and local regulations referenced in the contract.

Contracting personnel assigned acquisitions with ACM requirements, as a minimum, must contact subject matter experts (CE/EM) prior to awarding contract to assist in understanding the processes of asbestos project design and abatement.

8.1. Construction, Demolition and Abatement Responsibilities

Responsibilities of the Contracting Office for construction, demolition, and abatement requirements include the following:

a. Review contract documents for compliance with federal, state, local, and Air Force regulations and guidance, to include ensuring the Edwards AFB AMP/AOP and associated Asbestos Specification Section 02080 is referenced as applicable requirements in contract language.

b. Provide contractor submittals by e-mail simultaneously to Project Manager, BE, and EM for review and approval.

c. Award asbestos-related contracts to qualified asbestos contractors/consultants.

d. Set the timeframe required for turnaround of review (e.g., contractor’s abatement plans, medical surveillance and training programs, licenses, insurance bonds, qualifications, and fit-testing records). Typically at least 5 work days for electronic submittals and 10 days for hard copy.

e. Ensure the inspection of contractors’ work or refer inspections to qualified, accredited, licensed individuals not affiliated with the general or abatement contractor.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 22 of 54

f. Enforce contract terms and conditions to stop any inappropriate work practices or breach-of-contract requirements, and notify PM, EM, and BE for corrective actions.

g. Ensure asbestos hazards have been clearly identified to contractors in bid documentation;

consult with AOO, EM, and BE for assistance.

h. Ensure the contract provides for a full time CAC, certified by the California Division of Occupational Safety and Health to oversee the project as the government representative, if this is not being accomplished in-house.

i. Ensure the work plan(s) (remediation/abatement plan) is authored and signed by a CAC, certified by the California Division of Occupational Safety and Health, prior to submitting for review/approval by Base Asbestos Personnel.

j. Ensure records are submitted by the contract CAC that include, but are not limited to, contract daily activities log, air-monitoring results, and visual clearance certificates.

k. Ensure in contract wording that no ACMs are purchased or used.

l. Ensure that any contract asbestos sampling accomplished shall be done by an independent third-party not affiliated with the prime or abatement contractor and ensure these inspections are done IAW this Edwards AFB AMP and AOP.

8.1.1. Supplies and Services Responsibilities

Contracts for services have the potential to impact ACM during any activities; therefore, special precautions must be observed.

a. Ensure all contracts and orders that may impact ACM or suspect materials (e.g., walls, ceilings, above ceilings, and flooring), whether they are for services or supplies, have had ACM review and incorporate ACM considerations into the SOW and other requirements.

b. Custodial SOWs must inform all contract custodial personnel of the potential for disturbing ACMs in conjunction with their daily duties and ensure OSHA requirements are adhered to. If a custodial practice will disturb or damage an ACM, then work must cease. Particular concern must be paid to ACM flooring (i.e., all 9- by 9-inch floor tiles, some 12- by 12-inch floor tiles). The ACM flooring cannot be buffed at high speeds; all flooring should be assumed to be ACM unless confirmed otherwise by testing.

c. Carpet removal/replacement must always be initiated with an Air Force Form 332 (either hardcopy or via a web-based process such as Process, Records, and Information Management [PRIME] at Edwards AFB or Maximo) and must be coordinated with the AOO to annotate any potential asbestos issues. When floor tiles are removed prior to laying carpet, any ACM mastic below the floor tile shall be completely removed before the carpet is installed.

d. Refuse SOWs must include the requirement that contractor personnel manning the Edwards AFB Landfill have OSHA asbestos awareness training. And, if a material is suspected of containing asbestos, the AOO is to be contacted to perform sampling and abatement if necessary. Suspect material will not be buried prior to sampling and analysis.

e. Any equipment purchase where installation or removal of equipment will require changes in the facility building components must be initiated with an Air Force Form 332 (either

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 23 of 54 hardcopy or via a web-based process such as PRIME or Maximo) and must be coordinated by the AOO to annotate any potential asbestos issues.

f. Any furniture purchase requiring installation (e.g., attachment to walls or floor, or requiring cable/wiring through floors, walls, or ceilings) will be coordinated through the AOO to determine whether any ACM issues exist and what steps must be taken to prevent exposure to occupants and workers.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 24 of 54

This page intentionally left blank.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 25 of 54

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 26 of 54

APPENDICES

February 2014

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 27 of 54

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 28 of 54

APPENDIX A

LIST OF GUIDING INSTRUCTIONS,

REGULATIONS, AND POLICIES

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 29 of 54

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 30 of 54

LIST OF GUIDING INSTRUCTIONS,

REGULATIONS, AND POLICIES

Air Force Flight Test Center Instruction 32-1052, Air Force Flight Test Center Asbestos Management Plan, December 2013.

Civil Engineering Asbestos Operations Plan, February 2014

Air Force Forms

332, Base Civil Engineer Work Request.

813, Environmental Impact Analysis Request.

Air Force Information Management Tool 1219, BCE Multi-Craft Job Order.

Air Force Instruction (AFI)

32-1001, Operations Management, 1 September 2005.

32-1052, Facility Asbestos Management,4 January 2013.

48-145, Occupational and Environmental Health Program, 15 September 2011

Air Force Manual 48-155, Occupational and Environmental Health Exposure Controls, Aerospace Medicine, 1 October 2008

Air Force Pamphlet 32-1005, Working in the Engineering Flight, 1 October 1999.

Air Force Policy Directive 32-70, Environmental Quality, 20 July 1994.

California Code of Regulations (CCR)

Title 8, Division 1, Chapter 4, Section 1529, Asbestos.

Title 22, Division 4.5, Chapter 12, Standards Applicable to Hazardous Waste Generators.

Code of Federal Regulations (CFR) 29 CFR 1926.1101, Asbestos.

40 CFR 61, National Emission Standards for Hazardous Air Pollutants.

40 CFR 262, Standards Applicable to Hazardous Waste Generators.

40 CFR 763, Subpart E, Asbestos in Schools, which implements the Asbestos Hazardous Emergency Response Act.

Edwards Air Force Base Instruction 32-1001, Facility Manager

United States Code, Title 15, Part 2641 et seq., Asbestos Hazard Emergency Response Act.

United States Environmental Protection Agency (U.S. EPA), 1982, Interim Method for the Determination of Asbestos in Bulk Insulation Samples (EPA 600/M4-82-020).

U.S. EPA, 1985, Asbestos in Buildings: Simplified Sampling Scheme for Surfacing Materials

(EPA 560-5-85-030A)

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 31 of 54

U.S. EPA, 1993, Method for the Determination of Asbestos in Bulk Building Materials (EPA/600/R-93/116), July.

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 32 of 54

APPENDIX B

DESCRIPTION OF REQUIRED BASE PERSONNEL TRAINING

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 33 of 54

FA9301-15-R-0005, Attachment 2, Appendix D EAFB Asbestos Management Plan Page 34 of 54

DESCRIPTION OF REQUIRED BASE PERSONNEL TRAINING

Personnel involved with asbestos-related work are required to be trained in accordance with (IAW) the United States Environmental Protection Agency (U.S. EPA), California Occupational Safety and Health Administration (OSHA), and federal OSHA regulations. Accredited training shall be IAW U.S. EPA’s Asbestos Model Accreditation Plan (Title 40, Code of Federal Regulations [CFR], Section 763). At Edwards Air Force Base (AFB), these accredited courses are required for contractors hired for asbestos-related work and key Edwards AFB personnel responsible for asbestos-related projects and technical support activities; contractors are required to have applicable California licenses. They are as follows:

a. Worker Accredited Training: This is a 4-day course for asbestos abatement workers or workers who disturb asbestos in amounts of more than one glove bag or one standard waste bag that does not exceed 60 by 60 inches.

b. Contractor/Supervisor Accredited Training: This is a 5-day course for personnel with Competent Person abatement supervision responsibilities. ‘Competent person’ per California OSHA means:

(1) Capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees;

(2) Capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure; and

(3) Authority to take prompt corrective measures to eliminate them.

In addition, for Class I and Class II work, a competent person is specially trained in a training course which meets the criteria of 40 CFR 763 for supervisor, or its equivalent. For Class III and Class IV work, a competent person is trained in a manner consistent with U.S. EPA requirements for training of local education agency maintenance and custodial staff as set forth in 40 CFR 763.92(a)(2).

c. Building Inspector Accredited Training: This is a 3-day course required for personnel who inspect buildings to determine the presence, location, and friability of asbestos-containing material…