J-17 Asbestos Location OM Program.pdf

Washington Headquarters Services Department of Defense

Asbestos Location O&M Program

March 4, 2021

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Asbestos Location O&M Program i

TABLE OF CONTENTS

INTRODUCTION

1.1 Background Asbestos Information

1.2 Washington Headquarters Services’ Asbestos Policy

ASBESTOS IDENTIFICATION

KEY PERSONNEL

TRAINING

OPERATIONS AND MAINTENANCE GUIDELINES

5.1 Specific O&M Procedures

5.2 Notification of Outside Contractor

NOTIFICATION OF OUTSIDE CONTRACTOR FORM

RECORD KEEPING

OTHER PROCEDURES

APPENDIX A – FLOOR PLAN

APPENDIX B – PHOTOGRAPHIC DOCUMENTATION

Asbestos Location O&M Program 1

INTRODUCTION

1.1 BACKGROUND ASBESTOS INFORMATION

Asbestos is a mineral, mined from the earth in much the same way as other minerals such as iron, lead and copper. There are two general types of asbestos rock: serpentine and amphibole. Chrysotile asbestos is derived from serpentine rock. Chrysotile, sometimes called white asbestos, has very thin fibers that are soft and flexible. Approximately 95 percent of the asbestos used in the United States are the chrysotile type, and its primary applications are in textile, high-strength cement products, and insulating materials.

Amphibole asbestos, which has thicker, harder fibers than chrysotile asbestos, includes several subcategories: amosite, crocidolite, anthophyllite, actinolite, and tremolite. Amosite asbestos, sometimes called brown asbestos, is used widely in insulating materials, plastics, textiles, and construction products. It has the longest fibers of all types of asbestos, and its resistance to acid and heat is particularly high. For that reason, amosite is often found in buildings as insulation on high-temperature heating equipment such as boilers and exhaust stacks. Crocidolite or “blue” asbestos is also very resistant to acid and to the effects of outdoor exposure. It is used in textiles and high-strength cementitious products.

Anthophyllite, actinolite, and tremolite asbestos have brittle fibers and, therefore, limited applications.

Asbestos was not used extensively in building materials until the 1940's. During the post WWII building boom, from 1950-1970, use of asbestos as a building material increased substantially. The decline in use did not start until 1973-1978 when the Environmental Protection Agency (EPA) instituted bans on several asbestos-containing materials (ACM), including:

Most spray-applied Surfacing ACM.

Sprayed-on application of materials containing more than 1% asbestos to buildings, structures, pipes, and conduits unless the material is encapsulated with a bituminous or resinous binder during spraying and the materials are not friable after drying.

Wet-applied and pre-formed asbestos pipe insulation, and pre-formed asbestos block insulation on boilers and hot water tanks.

Corrugated paper, rollboard, commercial paper, specialty paper, flooring felt, and new uses of asbestos.

The EPA Purple Book (controlling Asbestos-Containing Materials in Buildings) has concluded, "The presence of asbestos in a building does not mean that the health of building occupants is endangered. If ACM remains in good condition and is unlikely to be disturbed, exposure will be negligible." Asbestos can become an airborne hazard if improperly handled. According to the experts, the health risks associated with asbestos arise when fibers become airborne and are inhaled.

The purpose of this Asbestos Location Operations and Maintenance (O&M) Program is to reduce risks associated with ACM by identifying locations, addressing existing and potential hazards, and outlining a set of work procedures to follow when ACM is disturbed.

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1.2 WASHINGTON HEADQUARTERS SERVICES’ ASBESTOS POLICY

The long-term goal for all buildings occupied or controlled by Washington Headquarters Services (WHS) is to remove all ACM. WHS is committed to maintaining a safe and healthy building environment for its employees, tenants, contract workers and the public. WHS has therefore established this O&M Program for the United States Pentagon, Arlington, Virginia.

This O&M program will remain in effect as long as ACM remains at the facility. It is the policy of WHS that:

No employee, tenant, contractor, or contractor’s employee shall intentionally disturb known or suspect ACM without the prior permission of the WHS building management;

All asbestos related work will be authorized by WHS or the designated Asbestos Program Manager;

All asbestos related work shall be performed by an accredited asbestos contractor or accredited asbestos worker, project designer (if necessary) and monitored by accredited asbestos personnel;

ACM will be periodically inspected to identify change in conditions/ assessments;

and, Contractors performing work in the building will be notified of the presence of ACM if their work activities could potentially disturb ACM.

ACM will not be disturbed or removed, without prior approval of the Asbestos Program Manager and the Pentagon Occupational Safety and Health Branch (OSHB). Asbestos abatement will be conducted in accordance with EPA, Occupational Safety and Health Administration (OSHA), local asbestos removal requirements and/or local regulations.

Building maintenance employees and contractors shall not perform maintenance, repair, construction, or renovation work that may disturb or damage ACM or presumed asbestos-containing material (PACM) unless properly accredited. This work shall be performed by properly trained asbestos abatement personnel. These personnel are part of the Pentagon Structural Systems Program (PSSP) or other identified trades.

Summary of Asbestos Location O&M Program: This program has been developed with input from WHS and is based upon normal work activities necessary to maintain the facilities in good condition without disturbing ACM. This O&M Program consists of a number of components, which include:

Identification of known ACMs;

Identification of a responsible party for O&M program coordination;

Outlining necessary training requirements for employees;

Establishment of a system of operation and maintenance guidelines and protocols for the property; and, Establishment of record keeping requirements.

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ASBESTOS IDENTIFICATION

Asbestos-containing materials are classified into three distinct categories including surfacing materials, thermal system insulation and miscellaneous materials. Surfacing materials may include, but are not limited to: sprayed-on fire proofing, troweled-on decorative plastering, and textured ceiling material (popcorn). Thermal system insulation may include, but is not limited to: insulating jacketing for boilers, tanks, ductwork, piping, pump houses, etc.

Miscellaneous materials include all other materials not classified as surfacing or thermal system insulation including, but not limited to: vinyl flooring, ceiling panels, sealants, mastics, roofing, gaskets, insulators, joint compound associated with sheetrock wall/ceiling systems, etc. A summary of previous survey information is included below.

Asbestos Containing and Presumed Asbestos Containing Material Summary:

a. ACM has been identified within the Pentagon Building Museum area located on the 3rd

Floor, Corridor 2 between B and C Rings. Within the museum, original building materials remain for a typical pre-renovation hallway, mechanical space and office area(s). Prior to the renovation of the Pentagon, these building materials had been sampled and analyzed for asbestos content. The following materials were identified to contain asbestos:

1) Electric wire insulation wrap found on the wiring in the Museum Hallway display cabinet. The actual asbestos content and quantity is not known. This material was identified to be intact and in a non-friable condition. See Appendix B, Photograph 1.

2) Fire door insulation packing materials were found in the doors in the Museum Hallway, Mechanical Space and Office area. Approximately 6 doors were determined to exist throughout this area. The actual asbestos content is not currently known. These materials were enclosed but were assumed to be intact and in a non-friable condition. See Appendix B, Photographs 1 and 2.

b. ACM has been identified within the Pentagon Steam Tunnels by sampling conducted in

March of 2012. During this sampling the following thermal systems insulation was identified: White Block Pipe Support Insulation material (Saddle) – 65% Chrysotile Asbestos - Identified under a cloth/fiberglass wrapped 36” Water Pipe in Wedge 4, Corridor 10, Mezzanine level. The exact location of additional block pipe supports is unknown due to the cloth/fiberglass wrapping on the pipes, but approximately 52 blocks are assumed to exist throughout Corridor 10. The materials that were identified were in an intact condition and normally inaccessible due to the cloth/fiberglass wrap that surrounds the support. Because the location(s) of the ACM continues to be explored, any unknown material encountered should be assumed to be asbestos and treated as such until sampling identifies otherwise. As these areas are discovered, this O&M Plan will be updated with additional information. See Appendix B, Photograph 3.

1) Compromised areas of pipe support insulation should be encapsulated or enclosed if the material is to be left in place. Removal of all ACM is recommended. However, if remediation is not performed due to concerns related to the integrity of piping, then necessary signage and disturbance prevention measures should be implemented.

c. ACM has been identified within the Pentagon Steam Tunnels by sampling conducted in

October of 2010. During this sampling the following thermal systems insulation was identified: Black Fibrous Tar-Like Pipe Support Insulation material (Saddle) – 3% Chrysotile Asbestos - Identified under the metal jacket covering and fibrous glass insulation of two 72” Water Pipes in the North Tunnel which runs to the Heating and Refrigeration Plant (HRP) from Corridor 10. These materials are inaccessible due to the metal jacket and insulation that surrounds the pipe, however approximately 200 pipe supports are known exist. See Appendix B, Photograph 4.

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1) The material noted above is related to two continuous runs of approximately 1000’ of piping. Compromised areas of pipe support insulation material should be encapsulated or enclosed if the material is to be left in place. Removal of all ACM is recommended. However, if remediation is not performed due to concerns related to the integrity of legacy piping, then necessary signage and disturbance prevention measures should be implemented.

d. PACM is believed to exist in several inaccessible locations throughout the Pentagon, these include, but are not limited to:

1) The A-Ring stairs area at the corridor 9 – 10 drive tunnel. Thermal systems insulation PACM is believed to be on a vertical riser(s) found within a wall cavity and are considered inaccessible under the full demolition condition of the renovation.

The approximate length and condition of this pipe insulation is unknown.

2) The E-Ring, Stair 64 area. Thermal systems insulation PACM is believed to be on a vertical riser(s) found within a wall cavity and are considered inaccessible under the full demolition condition of the renovation. The approximate length and condition of this pipe insulation is unknown.

3) The A-Ring, 8/9 half corridor area. Thermal systems insulation/miscellaneous PACM is believed to be on a vertical riser(s) found within a wall cavity (that vented at the roof level) and was considered inaccessible under the full demolition condition of the renovation. The approximate length and condition of this pipe insulation/cementitious piping is unknown.

4) Exterior of the building, South side, Old Heliport area. Miscellaneous PACM is believed to be underground throughout this area and is considered inaccessible unless excavated. The approximate length and condition of this cementitious piping is unknown.

5) Should future construction/excavation activities impact the areas in question, it’s recommended that all materials impacted within be treated and handled as ACM, until sampling and analysis identifies otherwise.

e. PACM and ACM pipe gaskets reside in the Pentagon. Gaskets found in pre-renovation

(prior 1999) locations are considered PACM. The exact locations and asbestos content of said gaskets are unknown; however suspected locations include, but are not limited to, the North HRP Tunnel and the Legacy Steam Tunnel area. In April 2012, a gasket manufacturer reported that ACM has been identified in gaskets that were installed in piping during the renovation/ construction of Wedges 3, 4, 5 and the Pentagon Memorial.

The number of gaskets in these areas has been identified as 505 in Wedge 3, 440 in Wedge 4, 37 in Wedge 5 and 10 in the Pentagon Memorial. The exact locations and asbestos content of said gaskets is unknown. Originally the manufacturer listed the gaskets as non-asbestos containing; sampling of this material by the manufacturer has proven otherwise. The manufacturer listed the gasket as being light green in color, 2 to 24-inches in diameter, and either full face or ring type gaskets. These PACM/ACM gaskets are normally enclosed between two pipe flanges or ball valves, are assumed to be intact and are non-friable (in original condition). The following is manufacturer specific information regarding the ACM gaskets.

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Location Model Diameter of Gasket

Full Face (FF) or Ring

(RNG)

Class (150 or 300)

Nut/Bolt Gasket Set (NBG) or Gasket (GSKT) Quantity

Pentagon Wedges 3-5 Warrantee

7128 2” RNG 150 NBG 1

3” RNG 150 NBG 2

6” RNG 150 NBG 2

Pentagon Memorial 7114563 3” RNG 150 GSKT 2

4” RNG 150 NBG 8

Pentagon Wedge 3 7115750 2” RNG 150 NBG 12

2.5” RNG 150 NBG 40

2.5” 300 NBG 1

2.5 RNG 150 GSKT 16

24” RNG 150 GSKT 2

3” RNG 150 NBG 70

3” FF 150 GSKT 20

3” FF 150 GSKT 34

3” RNG 150 GSKT 10

4” RNG 150 NBG 51

4” FF 150 GSKT 20

4” FF 150 GSKT 12

4” RNG 150 GSKT 12

5” RNG 150 NBG 18

5” FF 150 GSKT 22

5” RNG 150 GSKT 6

6” RNG 150 NBG 46

6” FF 150 GSKT 30

6” RNG 150 GSKT 16

8” RNG 150 NBG 33

8” FF 150 GSKT 28

8” RNG 150 GSKT 6

Pentagon Wedge 4 7116860 10” RNG 150 NBG 7

10” RNG 150 GSKT 2

1.5” RNG 150 NBG 2

1.25” RNG 150 NBG 2

12” RNG 150 NBG 0

16” RNG 150 GSKT 2

18” RNG 150 GSKT 2

2” RNG 150 NBG 3

2” RNG 150 GSKT 9

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Location Model Diameter of Gasket

Full Face (FF) or Ring

(RNG)

Class (150 or 300)

Nut/Bolt Gasket Set (NBG) or Gasket (GSKT) Quantity

2.5” RNG 150 NBG 22

2.5” FF 150 GSKT 2

2.5” FF 150 GSKT 20

2.5” RNG 150 GSKT 17

3” RNG 150 NBG 85

3” FF 150 GSKT 41

3” RNG 150 GSKT 43

4” RNG 150 NBG 33

4” FF 150 GSKT 8

4” FF 150 GSKT 13

4” RNG 150 GSKT 13

5” RNG 150 NBG 29

5” FF 150 GSKT 6

5” FF 150 GSKT 21

5” RNG 150 GSKT 29

6” RNG 150 NBG 10

6” FF 150 GSKT 3

6” RNG 150 GSKT 4

8” RNG 150 NBG 12

Pentagon Wedge 5 7118200 37

Because the ACM gaskets cannot be distinguished from the non-ACM gaskets, any gasket material identified should be assumed to be asbestos and treated as such until sampling identifies otherwise. See Appendix B, Photographs 5 and 6.

f. ACM has been identified in the Heating and Refrigeration Plant (HRP) breaker/switch building by sampling conducted in March of 2016. During this sampling 9” x 9” pink vinyl floor tile with white streak and associated black mastic was underlying a switchgear breaker bank in this building. Approximately 630 Sq. Ft. of this material was identified.

The floor tile contained 22% Chrysotile Asbestos and the black mastic contained 7% Chrysotile Asbestos. This material was identified to be intact and in a non-friable condition. See Appendix B, Photograph 7.

g. ACM and PACM has been identified in the Pentagon Modular Office Complex (MOC) chemical lab. This structure has been out of use for many years, and in 2011, was deemed unsafe for entry due to significant structural degradation and condemned. The following materials were identified to contain asbestos by sampling that was able to be conducted through doors/windows of the structure in March of 2016, or were observed and presumed to contain asbestos:

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1) Stone colored/textured 12” x 12” vinyl floor tile and associated black mastic on the first floor of the chemical lab. Approximately 21 Sq. Ft. of this material was identified.

The floor tile contained 14% Chrysotile Asbestos and the black mastic contained 5% Chrysotile Asbestos. This material was identified to be intact and in a non-friable condition where portions of the floor had not collapsed into the basement.

2) Blue 9” x 9” vinyl floor tile and associated black mastic on the first floor of the chemical lab. Approximately 180 Sq. Ft. of this material was identified. The floor tile contained 29% Chrysotile Asbestos and the black mastic contained 4% Chrysotile Asbestos. This material was identified to be intact and in a non-friable condition where portions of the floor had not collapsed into the basement.

3) Grey 12” x 12” vinyl floor tile and associated brown mastic on the first floor of the chemical lab. Approximately 518 Sq. Ft. of this material was determined to exist in this area. While the brown mastic contained no detectable asbestos, the floor tile contained “Trace” Chrysotile Asbestos. “Trace” asbestos content indicates that the concentration of asbestos in the tile is less than 1%, and is therefore not considered to be an ACM, for abatement/disposal purposes. However, this does not waive requirements for worker protection during any future disturbance of this material.

This material was identified to be intact and in a non-friable condition where portions of the floor had not collapsed into the basement.

4) One (1) approximately 50 Sq. Ft., fume hood was observed in the central portion of the chemical lab and appeared to be constructed of cementitious panels (i.e.

Transite). The fume hood was not accessible during the March 2016 inspection due to structural degradation of surrounding materials, but was observed to be intact and in a non-friable condition.

5) Thermal systems insulation PACM consisting of three (3) pipe elbows and approximately 24 Ft. of pipe insulation was observed throughout the chemical lab, and were observed to be intact at the time of the March 2016 inspection. However, due to structural degradation of the surrounding materials, these materials were not accessible for sampling, and additional material may exist in interstitial spaces or other portions of the chemical lab that were not observable from the perimeter of the structure.

h. Undocumented reports indicate that throughout the Pentagon facility, renovation activities have abandoned ACM in places that were deemed inaccessible. Inaccessible during renovation (in this case), has been defined as enclosed areas that are unable to be reached without considerable damage to historical structures and/or the building super structure during renovation activities. Because the location(s) of the undocumented ACM continues to be explored, any unknown material identified should be assumed to be asbestos and treated as such until sampling identifies otherwise. As these areas are discovered, this O&M Plan will be updated with the necessary information.

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KEY PERSONNEL

All notices, reports and other information related to activities involving ACM and PACM at this facility should go through the Occupational Safety and Health Branch, Asbestos Program Manager, who can be reached at 703-693-3683.

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TRAINING

Management. The Asbestos Program Manager, and other management level PBMO personnel who may encounter asbestos related issues, should attend a two-hour asbestos awareness program.

Building Operations and Design Personnel (e.g. maintenance, custodial, and design employees). Building Operations Personnel who may come into contact with ACM should attend a two-hour asbestos awareness program.

Non-Maintenance Occupants. Non-maintenance personnel working in the facility who will not come into contact with ACM while performing their assigned duties do not require any level of asbestos training.

Asbestos Abatement Workers. Personnel, whose job responsibilities require the removal of ACM, are required to maintain an EPA and State certification/license for asbestos worker and/or supervisor.

Records of employee training should be maintained by the Asbestos Program Manager.

This program shall include information for:

Asbestos Awareness Trained Employees Abatement workers.

Abatement Supervisors

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OPERATIONS AND MAINTENANCE GUIDELINES

The following paragraphs describe general guidelines for asbestos-related activities. The general approach for any maintenance or housekeeping activity should take into account the following goals:

Maintenance or custodial activities will be conducted so as not to disturb or damage materials that are ACM or PACM.

A qualified person must assess the condition of ACM or PACM in the building annually. Contractors, whose work activities will disturb ACM, shall be licensed asbestos workers and shall provide appropriate proof of employee licensing and training to WHS prior to commencing the work.

Removal of ACM or PACM will only be performed by certified personnel that are properly trained.

5.1 SPECIFIC O&M PROCEDURES

Pipe support insulation material (saddle) (Steam Tunnels, Corridor 10 and North Tunnel to HRP): The following procedures must be followed to protect building occupants if the pipe support insulation material requires maintenance or repair. These maintenance and repair procedures apply only to activities involving three square feet or less. Larger repair activities must be designed by qualified personnel. When working overhead, personnel must wear personal protective equipment.

Prepare work area by placing one layer of polyethylene on the floor directly below the repair area and tape or weight it in place.

Negative pressure glove bags should be used on all projects. Remove ACM using glove bag procedures as specified in 29 CFR 1926.1101 (OSHA’s Asbestos in Construction Standard).

Place all needed tools inside of glove bag and attach glove bag to area of pipe support insulation to be removed.

Adequately wet removal area frequently during removal of the bulk material. Seal exposed ends of the insulation before removing glove bag.

Thoroughly clean entire area in accordance with asbestos-containing material cleaning procedures.

Dispose of all debris and contaminated material in accordance with Federal and State disposal requirements.

Pipe Insulation/cementitious piping (A-Ring stairs, Corridor 9-10 Drive Tunnel; E-Ring, Stair 64 area; A-ring, 8/9 half corridor area and the exterior of the building, south side, Old Heliport area (Inaccessible Areas), and Chem Lab): The following procedures must be followed to protect building occupants if pipe insulation/cementitious material requires maintenance or repair. These maintenance and repair procedures apply only to activities involving three square feet or less. Larger repair activities must be designed by qualified personnel. When working overhead, personnel must wear personal protective equipment.

Prepare work area by placing one layer of polyethylene on the floor directly below the repair area and tape or weight it in place.

Negative pressure glove bags should be used on all projects. Remove ACM using glove bag procedures as specified in 29 CFR 1926.1101 (OSHA’s Asbestos in Construction Standard).

Place all needed tools inside of glove bag and attach glove bag to area of pipe insulation to be removed.

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Adequately wet removal area frequently during removal of the bulk material. Seal exposed ends of the insulation before removing glove bag.

Thoroughly clean entire area in accordance with asbestos-containing material cleaning procedures.

State disposal requirements.

Vinyl Floor Tiles (HRP and Chem Lab) - Strip asbestos-containing or presumed asbestos-containing floor tiles as infrequently as possible – once or twice a year at most. Damaged vinyl floor material should be replaced rather than repaired. It may also be covered over.

The procedures listed below must be followed to protect occupants if vinyl floor tiles require removal. These procedures apply only to activities involving three square feet or less.

Larger removal activities must be designed by qualified personnel.

Soak material with hot water.

Remove tile or sheet with hand tools, being careful not to break tile excessively.

Clean work area in accordance with asbestos-containing material cleaning procedures.

Dispose of all debris in accordance with Federal and State disposal requirements.

Electrical Wiring Wrap (Pentagon Museum) - The following procedures must be followed to protect building occupants if the electrical wire insulation requires repair. These procedures apply only to the repair of minor damage.

To repair minor damage, patch damaged area with non-asbestos-containing insulation.

Thoroughly clean work area with a HEPA vacuum in accordance with asbestos-containing material cleaning procedures.

Dispose of all debris in accordance with Federal and State disposal requirements.

Mastics and Adhesive Materials (HRP and Chem Lab) - The following procedures must be followed to protect occupants if materials require maintenance or repair. These procedures apply only to activities involving three square feet or less.

Small damaged areas of material should be covered over with new compatible non-asbestos-containing materials.

Clean work area in accordance with asbestos-containing material cleaning procedures.

State disposal Requirements.

Fire Door Insulation Packing (Pentagon Museum) - The following procedures must be followed to protect building occupants if the fire doors require maintenance or repair. These procedures apply only to the repair of minor damage. Fire doors with extensive damage require replacement to maintain fire protection standard.

To repair minor damage, fill hole with non-asbestos-containing fire rated patching cement.

Thoroughly clean work area with a HEPA vacuum in accordance with asbestos-containing material cleaning procedures.

Dispose of all debris in accordance with Federal and State disposal requirements.

Paint affected area with latex paint.

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Gaskets and cementitious (Transite) panels (Pentagon, Pentagon Memorial, Chem Lab) - The following procedures must be followed to protect occupants if materials require maintenance, repair or removal. Gaskets will not be exposed unless pipe flanges are removed.

All work activities shall be in compliance with 29 CFR 1910.1101, OSHA’s Asbestos in Construction Standard for Class II work activities, prior to completing a Negative Initial Exposure Assessment (NEA). Respiratory PPE shall be utilized until an NEA has determined that airborne exposures are continuously below OSHA’s Permissible Exposure Limit (PEL) (0.1 f/cc) for airborne asbestos concentrations.

Begin the removal process with a NEA and regulate the area where the maintenance, repair or removal is to be performed by posting signs and restricting access.

Wet the gasket with amended water, remove the gasket with hand tools (putty knife or stiff blade), being careful not to break the gasket excessively. Wipe the fitting clean with a cloth and amended water.

If brushing is required to remove the residue, use a stiff bristle brush. Do not use a wire brush or mechanical methods. Should mechanical removal methods be required for removal, personnel shall follow all OSHA Class II removal methods requirements as identified in 29 CFR 1910.1101 regardless of NEA results.

Promptly contain the removed gasket while adequately wet in a sealed leak-tight container, along with the cleaning cloths and any other waste.

Dispose of all debris and contaminated material in accordance with Federal and State disposal Requirements.

Clean the immediate work area with a HEPA filtered vacuum or by wet wiping with amended water. Dry sweeping or other dry clean-up methods are prohibited.

5.2 NOTIFICATION OF OUTSIDE CONTRACTOR

The building’s Asbestos Program Manager shall be contacted prior to engaging any outside contractor or building maintenance personnel to perform any maintenance, repair, or renovation work inside the building that may disturb known or presumed ACM for any reason. If that work requires the disturbance of known ACM, no work will be performed until WHS determines if abatement of the asbestos is necessary. Facilities personnel and outside contractors should be provided with information about the confirmed and suspected locations of ACM. If work on any project reveals suspect materials work shall stop, measures to prevent disturbance of material shall be taken and the Asbestos Project manager shall be notified. A signed Notification of Outside Contractor form will be maintained in a permanent file at the building. All outside contractors must sign this form and be given a copy of it prior to commencing any work in the building.

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NOTIFICATION OF OUTSIDE CONTRACTOR FORM

(Date)

(Contractor Name) (Contractor Address) (Contractor Address)

RE: Notification of Asbestos-Containing Material The Pentagon Reservation 1155 Defense Pentagon Washington, DC20301

Dear (Contractor Point of Contact):

Per 29 CFR 1910.1101, the Occupational Safety and Health Administration’s Asbestos in Construction Industry Standard, this correspondence is intended to inform you of the locations of asbestos-containing materials and presumed asbestos-containing materials on the Pentagon Reservation. This information is enclosed.

Your signature below is acknowledgment that you have received the information, and pledge to pass it on to your employees who work at the property before they do work there that might disturb asbestos-containing materials or presumed asbestos-containing materials.

Also, you are required to pass on any information concerning asbestos at this property to your subcontractors, if any, who may do work at this property. Please return a signed copy of this letter to my attention at your earliest convenience.

If you have any questions, please do not hesitate to contact me.

Sincerely, (Signature of Asbestos Coordinator) (Name of Asbestos Coordinator)

(Signature of Authorized Official)

(Job Title of Authorized Official)

(Date)

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RECORD KEEPING

Records that relate to any asbestos-related matter shall be maintained indefinitely in an asbestos file maintained by the Building Asbestos Program Manager. These records are to include, but not limited to:

Employee Awareness Training;

Employee Abatement Training and Licensing;

Notification to Outside Contractor;

Periodic Surveillance Reports; and, Summary of Improvement surveys and abatement activities.

Periodic Surveillance Reports - Periodic Surveillance Inspection Report form(s) will be maintained in a permanent file. The Asbestos Program Manager will coordinate with building maintenance employees to confirm locations, conditions and monitor any subsequent changes in identified ACM or suspect building materials as part of daily routine operations. Building engineers will report any changes in condition of ACM via Periodic Surveillance Report form.

Floor Plans – Appendix A contains a floor plan designating the areas of concern for ACM and PACM.

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OTHER PROCEDURES

Periodic Surveillance - The condition of all ACM in the building should be re-evaluated and documented on a routine basis (typically completed by WHS building maintenance employees who have been trained with the 2-hour asbestos awareness training). The Asbestos Program Manager will coordinate the execution of periodic surveillance for changes in condition from visual observations reported by the building maintenance employees. Increased activity in and around the materials, evidence of deterioration, damage, delamination, water damage and other factors, which might increase the potential for disturbance, should be noted. This re-evaluation should be documented, with pictures for example, for each material. Marked plans and any photographs should also be maintained in the asbestos file. The Asbestos Program Manager shall maintain records of re-evaluations. If a problem is encountered, the follow-up activity should be documented and kept in files. The Asbestos School Hazard Abatement Reauthorization Act (ASHARA) re-inspection requirements will be followed.

Emergency Situations - The first priority in an incident or emergency situation is the safety of the building employees and occupants. The following procedures shall be initiated immediately by designated building personnel:

Stop the cause of the contamination (renovation work, coring, etc.);

Evacuate the affected area, if necessary;

Isolate power to the HVAC system supplying the affected area;

Isolate the affected area by closing all doors leading to the area;

Post appropriate signage or locking mechanism to prevent inadvertent entry; and Immediately notify appropriate personnel including the Asbestos Program Manager and/or Washington Headquarters Services.

Asbestos is a hazardous substance under the provisions of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA). The Asbestos Program Manager should be contacted immediately if large-scale disturbance of ACMs or airborne releases of asbestos fibers are discovered.

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APPENDIX A – FLOOR PLAN

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APPENDIX B – PHOTOGRAPHIC DOCUMENTATION

Photograph 1: Photo of a typical fire door (with packing insulation) and wire insulation wrapping found in the Pentagon Museum Hallway (3rd Floor, 2nd Corridor, Between the B and C Ring).

Photograph 2: Photo of the Olive colored fire doors with packing insulation found in the Pentagon Museum Hallway (3rd Floor, 2nd Corridor, Between the B and C Ring).

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Photograph 3: Photo of the Cloth/Fiberglass Material wrapped around the pipe support insulation material on the 36” water pipe located in Wedge 4, Corridor 10.

Photograph 4: Photo of the pipe support insulation material on the 72” water pipe located in North Tunnel (Note: The metal jacket and insulation have been removed).

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Photograph 5: Picture of the identified ACM gaskets (although labeled as non-asbestos) found in the piping for Wedges 3, 4, 5 and Pentagon Memorial.

Photograph 6: Photo of a typical 24-inch non-asbestos containing gasket (notice the similarities to the identified asbestos-containing gaskets in photo 9).

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Photograph 7: Photo of the Pink with white streaks 9”x9” Vinyl Floor Tiles (and associated black mastic underlying tile) found in the HRP breaker/switch building.