Robins AFB Asbestos Management Plan - January 2015.pdf

ROBINS AIR FORCE BASE, GEORGIA

ASBESTOS MANAGEMENT PLAN (AMP)

JANUARY 2015

PRINTED ON 30% RECYCLED PAPER

Environmental Management Branch (78 CEG/CEIE) Asbestos Management Plan Robins Air Force Base, Georgia 1/30/2015

THE PAGE LEFT BLANK

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Printed on 30% Recycled Paper

TABLE OF CONTENTS

Section Page No.

List of Acronyms............................................................................................................................ vi Distribution .................................................................................................................................. viii Security Instructions/Record of Changes/Annual Review ............................................................. ix Definitions....................................................................................................................................... x

1.0 INTRODUCTION

1.1 THE ASBESTOS HAZARD EMERGENCY RESPONSE ACT (AHERA)

1.2 ASBESTOS OPERATING PLAN

1.3 ASBESTOS CONTAINING MATERIAL IN BUILDINGS

2.0 ASBESTOS PROGRAM POLICY

2.1 BACKGROUND

2.2 REGULATORY REVIEW

2.2.1 Federal Regulations, Codes, and Standards

2.2.2 State Regulations, Codes, and Standards (including latest changes)

2.2.3 Air Force and Base Regulations and Standards

2.3 SCOPE

2.3.1 Roles and Responsibilities

2.3.2 Notification Procedures

2.3.3 Training

2.3.4 Medical Surveillance

2.3.5 Surveillance and Monitoring

2.3.6 Recordkeeping Requirements

2.3.7 Response Action

2.3.8 Work Order Process

3.0 ROLES AND RESPONSIBILITIES

3.1 AIR FORCE CIVIL ENGINEER CENTER – OPERATIONS DIRECTORATE, ENGINEER

DIVISION (AFCEC/COS)

3.2 ENVIRONMENTAL CENTER OF EXCELLENCE (AFCEC/CZ)

3.3 78TH AIR BASE WING, ROBINS AFB

3.3.1 Base Civil Engineer Group (78 CEG) Responsibilities

3.3.2 Facility Manager Responsibilities

3.3.3 Environmental Management Responsibilities (78 CEG/CEIE):

3.3.4 Medical Services

3.4 AFSC CONTRACTING (AFSC/PZ)

3.5 MAINTENANCE SUPPORT GROUP (402 MXSG)

4.0 NOTIFICATION

4.1 ASBESTOS POINTS OF CONTACT

4.2 CONTRACTORS

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4.3 FACILITY/BUILDING MANAGERS

4.4 REGULATORY AGENCIES

5.0 TRAINING REQUIREMENTS

5.1 PROGRAM ADMINISTRATORS TRAINING

5.2 CUSTODIAL AND MAINTENANCE PERSONNEL TRAINING

5.3 ABATEMENT WORKERS AND SUPERVISORS TRAINING

5.4 BUILDING INSPECTOR TRAINING

6.0 MEDICAL SURVEILLANCE AND PERSONAL PROTECTION

6.1 RESPIRATORY PROTECTION PROGRAM

6.2 OCCUPATIONAL PHYSICAL EXAMINATION PROGRAM

6.3 RECORDS OF MEDICAL SURVEILLANCE

7.0 REASSESSMENT, SURVEILLANCE, AND ANNUAL AIR MONITORING

7.1 REASSESSMENT

7.2 ANNUAL AIR SAMPLING

8.0 RECORDKEEPING - GENERAL REQUIREMENTS

8.1 DATA COLLECTION

8.2 THE ASBESTOS RECORD

8.3 ASBESTOS MANAGEMENT PLAN CHANGE CONTROL

8.4 ASBESTOS DATABASE

8.5 ASBESTOS PROJECT FILE

8.6 RECORDS RETENTION

9.0 EMERGENCY RESPONSE PLAN

9.1 EMERGENCY RESPONSE

9.2 MINOR FIBER RELEASE EPISODE (40 CFR 763.91(F)(1))

9.3 MAJOR FIBER RELEASE EPISODE (40 CFR 763.91(F)(2))

9.4 ECONOMIC CONSIDERATIONS

10.0 ASBESTOS WORK ORDER PROCESS

10.1 WORK REQUESTS

10.2 WORK REQUESTS REVIEW PROCESS

10.3 WORK REQUESTS TRACKING SYSTEM

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LIST OF APPENDICES

Appendix

A Forms/ Documents

Robins AFB Building Inspection Form Special Waste Acceptance Application (SWAA) State of Georgia—Project Notification for Asbestos Renovation, Encapsulation or Demolition State of Georgia—Asbestos Disposal Manifest Form Asbestos Operations Plan (January 2015) Air Force Instruction 32-1052, Facility Asbestos Management

ASBESTOS POINTS OF CONTACT

POC/Organization Telephone Base Asbestos Program Officer (BAPO), Environmental Management (78 CEG/CEIEC)

327-3976

Base Asbestos Operations Officer (BAOO), Civil Engineering (78 CES/CEOE)

327-8935

Bioenvironmental Engineering (78 MDG/SGPB) 927-7555 Public Health (78 MDG/SGPM) 927-7618 v

LIST OF ACRONYMS

ACBM Asbestos Containing Building Materials ACM Asbestos Containing Material AF Air Force AFB Air Force Base AFI Air Force Instruction AFMC Air Force Materiel Command AFPAM Air Force Pamphlet AHERA Asbestos Hazard Emergency Response Act AMP Asbestos Management Plan AOP Asbestos Operating Plan ASHARA Asbestos School Hazard Abatement Reauthorization Act BAOO Base Asbestos Operations Officer BAPO Base Asbestos Program Officer BCE Base Civil Engineer CEG Civil Engineer Group CEN Engineering Division CES Civil Engineer Squadron CEOE Operations Engineering Flight CEIE Environmental Management Branch CF Cubic Feet CFR Code of Federal Regulations DOT Department of Transportation GA EPD Georgia Environmental Protection Division HEPA High Efficiency Particulate Air ID/IQ Indefinite Delivery/Indefinite Quantity LF Linear Feet MXSG Maintenance Support Group NESHAP National Emission Standards for Hazardous Air Pollutants OSHA Occupational Safety and Health Administration POC Point of Contact RAC Risk Assessment Codes RACM Regulated Asbestos Containing Material SE Safety Office SGPB Bioenvironmental Engineering SOW Statement of Work SWAA Special Waste Acceptance Application TSI Thermal System Insulation US EPA United States Environmental Protection Agency WO Work Order WR-ALC Warner Robins Air Logistics Complex WTD Waste Tracking Document vi

DISTRIBUTION

Office No. of Copies

78 ABW/SE

WR-ALC/SE/402 MXSS 4

78 CEG/CL 1

78 CES/CL 1

78 CEG/CEI 1

AFSC/PZIOC 1

78 AMDS/SGPB/SGPM 1

78 SPTG/FSD 1

78 CEG/CEN 1

116 MSG/CE 1

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SECURITY INSTRUCTIONS/RECORD OF CHANGES/ANNUAL

REVIEW

1. The title of this plan is Robins Air Force Base Asbestos Management Plan.

2. The overall classification of the document is UNCLASSIFIED.

3. This document is designated "Unclassified" and will be handled in accordance with AFI 37-131.

Reproduction and distribution of this plan is not restricted.

4. Review of this plan will be conducted annually.

Record of Changes

Change Number Change Date Date Posted Posted By 1 11/17/2014 11/17/2014 Darryl Mercer 2 January 2015 January 2015 Casey Lucas

Record of Annual Review

Date Reviewed Reviewed By Remarks 11/17/2014 Darryl Mercer Updated Office symbols and Records Locations.

Reviewed to incorporate new requirements of AFI- 1052 (Rev Jan 13) to detail management efforts and procedures to oversee the entire facility asbestos management program

January 2015 Casey Lucas Updated plan based on comments received from Cynthia Alligood and Toni Hurley in Bioenvironmental. See comment matrices for details.

Robins Air Force Base (AFB) Asbestos Management Plan January 2015

OPR: 78 CEG/CEI

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DEFINITIONS

1. ABATEMENT. A method, including removal, encapsulation, enclosure, repair, and periodic monitoring that protects human health and the environment from friable Asbestos Containing Building Materials (ACBM).

See also response action.

2. AREA AIR SAMPLING. Air sampling conducted in work areas to determine the concentration of airborne asbestos fibers. Area air sampling is conducted in areas where there is a potential for the release of asbestos fibers.

3. ASBESTOS. A group of naturally occurring minerals that separates into small thin fibers. There are six asbestos minerals used commercially: Chrysotile, amosite, crocidolite, anthophyllite, tremolite, and actinolite.

4. ASBESTOS CONTAINING MATERIAL (ACM). A material that contains greater than one percent asbestos by weight.

5. ASBESTOSIS. A disease characterized by fibrotic scarring of the lung. This is a restrictive lung disease, which reduces the capacity of the lung. The common symptom is shortness of breath. Asbestosis is prevalent among workers who have been exposed to large doses of asbestos fibers over a long period of time.

6. BASE ASBESTOS OPERATIONS OFFICER (BAOO). (78th Civil Engineer Group, 78th Civil Engineer Squadron (78 CES) Function). 78 CES is responsible for the base asbestos program operations. This support shall include trained personnel to perform abatement of asbestos found in conjunction with all facilities, except aircraft and non-real property systems, located at Robins AFB. 78 CES is also responsible for bulk sampling, program budgeting and funding, and asbestos removal either with in-house workers or by means of an Indefinite Delivery/Indefinite Quantity (ID/IQ) contract.

7. BASE ASBESTOS PROGRAM OFFICER (BAPO). (78th Civil Engineer Group, Environmental Management Branch (78 CEG/CEIE) Function). CEIE is responsible for coordinating, maintaining, and providing regulatory guidance for the base asbestos program. The program shall be managed so that asbestos materials are thoroughly controlled at the lowest possible cost to the AF. The BAPO is also responsible for maintaining a current inventory of all known asbestos at Robins AFB.

8. CLEARANCE AIR SAMPLING. Sampling of air in a negative pressure enclosure at the completion of an abatement project. Clearance air sampling is used to determine if the enclosure has been adequately cleaned prior to being dismantled. Clearance air sampling is accompanied by aggressive agitation of the air in the negative pressure enclosure that dislodges settled fibers and ensures that fiber concentrations are measured accurately.

9. DEMOLITION. The wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations.

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10. ENCAPSULATION. The treatment of an ACM with a material that surrounds or embeds asbestos fibers in an adhesive matrix to prevent the release of fibers, as the encapsulant creates a membrane over the surface (bridging encapsulate) or penetrates the material and binds its components together (penetrating encapsulate).

11. ENCLOSURE. An airtight, impermeable, permanent barrier around ACMs to prevent the release of asbestos fibers into the air.

12. FACILITY. Any institutional, commercial, public, industrial, or residential structure, installation, or building.

13. FIBER. A particulate form of asbestos, five micrometers or longer, with a length-to-diameter ratio of at least three to one.

14. FIBER RELEASE EPISODE. Any uncontrolled or unintentional disturbance of ACM resulting in a release of ACM.

15. FRIABLE. Such material, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure, and includes previously nonfriable material which may become damaged to the extent that, when dry, it may be crumbled, pulverized, or reduced to powder by hand pressure.

16. HIGH EFFICIENCY PARTICULATE AIR (HEPA) FILTER. A trade name for a kind of tightly woven paper filter used in respirator cartridges, exhaust systems, vacuum cleaners, etc., that is at least 99.97% efficient at collecting all particulate matter that is at least 0.3 microns in size.

17. HOMOGENOUS AREA. An area that contains material that is uniform in color, texture, and appearance and was probably installed all at once, and is unlikely to consist of more than one type, or formulation of material.

18. IMMINENT HAZARD. An uncontrolled or unintentional disturbance of an ACM resulting in a visible emission or visible dust.

19. LATENCY PERIOD. The time period between the exposure to a harmful agent and the onset of recognized symptoms. For asbestos-related diseases, this can be anywhere from 20 to 40 years.

20. MESOTHELIOMA. A rare and deadly form of cancer that has been associated with asbestos exposures.

There are two forms. In pleural mesothelioma, tumors occur in the pleura or lining of the lung. In peritoneal mesothelioma, tumors occur in the peritoneum or lining of the abdomen.

21. NEGATIVE PRESSURE ENCLOSURE. An airtight enclosure constructed of polyethylene sheeting used to control asbestos fibers at abatement projects. Negative pressure is continuously blowing air to the outside of the enclosure. This results in uncontaminated air being drawn through the entrance from the outside of the enclosure. Fans used to create the negative pressure enclosure are equipped with HEPA filters that remove asbestos fibers from air being exhausted from the enclosure.

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22. NON-REAL PROPERTY. Areas of a facility by definition which Plant Services, Communications, or Transportation have responsibilities for operations, maintenance and repair activities.

23. PERSONAL AIR SAMPLING. The sampling of the breathing zone of a worker to determine the concentration of asbestos fibers to which the worker would be exposed without respiratory protection. Personal air sampling is used to determine the type of respiratory protection required for abatement workers.

24. PRESUMED ASBESTOS-CONTAINING MATERIAL (PACM). Thermal system insulation and surfacing material found in buildings constructed no later than 1980 that are assumed to contain greater than one percent asbestos but have not been sampled or analyzed to verify or negate the presence of asbestos.

25. REAL PROPERTY. Facilities and infrastructure for which CE is responsible to perform operations, maintenance, and repair activities as identified in the Air Force Instruction (AFI) 32-1XXX series.

26. RENOVATION. The altering, in any way, of one or more facility components. Operations in which load-supporting structural members are removed in conjunction with the act of restoring to a former or better state.

27. REPAIR. Returning damaged ACBM to an undamaged condition or to an intact state so as to prevent fiber release.

28. RESPONSE ACTION. A method, including removal, encapsulation, enclosure, repair, and periodic monitoring that protects human health and the environment from friable ACBM.

29. SURFACING MATERIAL. Material that is sprayed-on, troweled-on, or otherwise applies to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes.

30. SUSPECT MATERIAL. Material that, by the judgment of the inspector, may possibly contain asbestos.

Such determinations are based on the age, use, appearance, and texture of the material in question.

31. THERMAL SYSTEM INSULATION (TSI). Material applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain.

32. VISUAL INSPECTION. An inspection of a negative pressure enclosure after the completion of the abatement and prior to the dismantling of the enclosure. The purpose of the inspection is to ensure that abatement actions (removal, encapsulation, enclosure) were completed properly, and to ensure that the negative pressure enclosure is free of dust and debris.

33. WORK PLAN. A plan submitted by the abatement contractor that describes in detail all tasks required to complete the abatement project.

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1.0 INTRODUCTION

This Asbestos Management Plan (AMP) establishes requirements and assigns responsibility for facility asbestos management at Robins AFB. This AMP implements AFI 32-1052, Facility Asbestos Management. Requirements and responsibilities are established throughout this plan to incorporate asbestos management principles and practices at Robins AFB. This AMP has a two-fold purpose:

• Provide guidance for all asbestos management efforts and procedures for overseeing the entire facility asbestos management program; and

• Document our commitment to protect the health of personnel and establish procedures to ensure compliance with Federal, State, and AF environmental and occupational regulations pertaining to asbestos.

To fulfill each purpose, this AMP must be a dynamic document that is flexible to the changes in the mission of Robins AFB and clearly defines the roles of each organization.

1.1 THE ASBESTOS HAZARD EMERGENCY RESPONSE ACT (AHERA)

AHERA currently requires each elementary and secondary school to perform an inspection for ACBM and to prepare an asbestos management plan for managing asbestos in schools. The AHERA regulations further require a re-inspection of the ACBM at least once every 3 years.

The training requirements of this law extend to all commercial and government buildings as required by the Asbestos School Hazard Abatement Reauthorization Act (ASHARA).

1.2 ASBESTOS OPERATING PLAN

Additional guidance for the Asbestos Program is provided in the 78th Civil Engineer Squadron (78 CES) Asbestos Operating Plan (AOP). This plan provides the BAOO with specific guidance for accomplishing asbestos abatement and related work per AFI 32-1052, Facility Asbestos Management, dated 4 January 2013. The AOP can be found in Appendix A.

1.3 ASBESTOS CONTAINING MATERIAL IN BUILDINGS

Airborne asbestos contamination in buildings is a significant environmental problem. Various diseases have been linked with industrial exposure to airborne asbestos, and the extensive use of asbestos products in buildings has raised concerns about exposure to asbestos in non-industrial settings.

The presence of asbestos in a building does not mean that the health of building occupants is necessarily endangered. As long as ACM remains in good condition and is not disturbed, exposure is unlikely. When building maintenance, repair, renovation or other activities disturb ACM, or if it is damaged, asbestos fibers are released creating a potential hazard to the building occupants, Robins AFB will take steps to limit building occupants’ exposure to airborne asbestos.

Asbestos in buildings is found in three forms: (1) sprayed or troweled on ceilings and walls (surfacing material); (2) insulation around hot or cold pipes, ducts, boilers, and tanks (pipe and boiler insulation); and (3) in a variety of other products such as ceiling and floor tiles and wall boards (miscellaneous materials). In general, the first two categories are of greatest concern, especially if it is friable (friable material can be crumbled, pulverized, or reduced to powder by hand pressure.)

2.0 ASBESTOS PROGRAM POLICY

The objective of this plan is to maintain a permanent record and the current status of all friable and non-friable ACM in the center’s Installation’s inventory. Document all asbestos management efforts and provide guidance for the overall asbestos management program in accordance with AFI 32-1052. Establish policies and procedures to protect the health of personnel and comply with all applicable Federal, State, and AF regulations.

2.1 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. Due to its excellent fire protection and insulation properties, asbestos was used in a wide variety of building materials and building components (Table 2) during the twentieth century. The widest use occurred from 1940-1975. However, asbestos fibers have been shown to be a health hazard when humans are exposed to concentrations of fibers above the established Occupational Safety and Health Administration (OSHA) thresholds.

Personnel may become exposed to asbestos fibers in maintenance, renovation, or demolition activities where building materials that contain asbestos are involved. To protect human health, numerous federal, state, and AF regulations have been adopted. With strict adherence to these regulations and the procedures that they require, exposure of personnel to asbestos fibers should not occur.

Table 2 Building Materials Found to Contain Asbestos

Acoustical texture Wall texture Fire-proofing Spackle Plaster Attic and wall insulation Joint compound Resilient flooring Flooring tile/Mastic Fire Doors Recessed lighting fixtures Piping insulation Wiring Piping joints Elevator brakes Gaskets Valve packing & insulation Exhaust pipe Exhaust hoods Lab benches Blackboards Duct insulation Duct tape Boiler blocking Vibration damping cloth Building panels Siding Shingles Roofing felt Roofing tar Textured paint Flashing Water-proofing putty Window caulking

Door insulation Stucco Mortar Concrete Swimming pool plaster Brake Pads

2.2 REGULATORY REVIEW

Current regulations 1) ban outright or restrict the use of asbestos in new buildings or products, 2) specify work practices for the disturbance of asbestos-containing material, and 3) require the identification of asbestos in schools (AHERA) and in commercial and public buildings that are to be remodeled or demolished (OSHA, National Emission Standards for Hazardous Air Pollutants (NESHAP). Exposure standards exist for the workplace (OSHA) and to clear abatements in schools (AHERA). The following Federal, State, and AF regulations and laws apply to the asbestos program at Robins AFB.

2.2.1 Federal Regulations, Codes, and Standards

The federal government has enacted laws for asbestos control from both environmental and occupational health standpoints through such acts as the Occupational Safety and Health Act, as amended, the Toxic Substance Control Act, as amended, and the Clean Air Act, as amended.

The 29, 40, and 49 Code of Federal Regulations (CFR) series 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.

• Title 29 CFR, U.S. Department of Labor, OSHA Standards

- Part 1910.1020, Access to Employee Exposure and Medical Records

- Part 1910.134, Respiratory Protection

- Part 1910.147, Power Lock-Out/Tag-Out Procedures

- Part 1910.1001, General Industry Standard for Asbestos

- Part 1910.1200, Hazard Communications

- Part 1926.1101, Asbestos Standard for Construction

• Title 40, CFR, United States Environmental Protection Agency (US EPA) Standards

- Part 61, Subpart A, National Emission Standard for Hazardous Air Pollutants -

General Provisions

- Part 61, Subpart M, Air Pollutants - NESHAP for Asbestos

- Part 763, Subpart E, Asbestos Containing Materials in Schools

• Title 49, CFR, U.S. Department of Transportation (DOT) Standards.

- Part 171, Hazardous Substances

- Part 172, Hazardous Materials Tables and Hazardous Materials, Subparts B and C -

Communications Regulations

- Part 173, Shipments and Packaging

2.2.2 State Regulations, Codes, and Standards (including latest changes)

The State of Georgia generally follows federal OSHA and EPA regulations for dealing with occupational exposures, transportation, and disposal of asbestos using the Official Code of the State of Georgia Annotated as the basic statutory authorization. In Georgia, the following agency provides regulatory review of asbestos removal projects and transportation of asbestos wastes:

• Georgia Asbestos Safety Act, Georgia Code Title 12, Chapter 12

• Emission Standard for Asbestos, Chapter 391-3-1-.02(9)(b)7

• Asbestos Removal and Encapsulation Regulations, Chapter 391-3-14

• Solid Waste Management Regulation, Chapter 391-3-4

2.2.3 Air Force and Base Regulations and Standards

The Department of the AF 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 Robins AFB asbestos program:

• AFI 32-1052 Air Force Facility Asbestos Management

• AFI 48-137 Respiratory Protection Program

• AFI 90-821 Hazard Communication

• Robins AFB Instruction 48-137 Respiratory Protection Program

2.3 SCOPE

This AMP provides the documentation for all asbestos management efforts and the mechanism for oversight of the entire facility AMP. Also, describes how asbestos policies and procedures are to be implemented through the AOP in an efficient and cost-effective manner. This AMP is made up of the following components:

2.3.1 Roles and Responsibilities

In order for the plan to be effective, numerous personnel from different organizations require both input and actions. Section 3.0 defines the roles and responsibilities of designated personnel and organizations.

2.3.2 Notification Procedures

Various notifications must be made in order to keep all involved parties informed. This section explains which regulatory agencies must be notified for each type of project, how often building managers should be notified, and any other notifications that may be necessary. See Section 4.0.

2.3.3 Training

It is essential that personnel receive proper training for asbestos management. It is the responsibility of each organization to ensure that personnel receive the proper training, and refresher classes. The Base Asbestos Program Officer (BAPO) is responsible for overseeing that all training requirements are met. See Section 5.0.

2.3.4 Medical Surveillance

In accordance with 29 CFR 1910.1001, (I) Medical surveillance and Air Force Instruction (AFI) 48-137, if an individual has the potential to be exposed to airborne asbestos concentrations greater than the level established by the standards, they must wear negative pressure respirators and receive medical surveillance through the occupational physical examination program.

Individuals are required to receive Respiratory Protection Training. This will ensure that personnel are properly trained on the use of respirators and that respirators fit correctly. See Section 6.0.

2.3.5 Surveillance and Monitoring

Asbestos materials must be monitored to ensure that they have not been damaged or have deteriorated. Asbestos inspectors will make note of any areas that need to be repaired or abated.

BAPO, BAOO, and Bioenvironmental Engineering (SGPB) will determine monitoring and surveillance requirements. See Section 7.0.

2.3.6 Recordkeeping Requirements

Because of the long latency period of asbestos illnesses and possible legal liabilities, all recordkeeping must be held indefinitely. Guidance is provided on procedures for documenting notification, training, medical surveillance, and periodic reassessment and surveillance;

procedures for updating the asbestos data base when asbestos materials have been abated; and procedures to document previously unidentified asbestos materials. See Section 8.0.

2.3.7 Response Action

The response action will be determined by BAPO, BAOO, and SGPB. Many considerations must be reviewed to determine the order of response: building use and occupancy; occupancy by children; plans for renovation, demolition, or construction; and any other special circumstances that may arise. Asbestos is a facility component, and the maintenance, repair or removal is a Base Civil Engineer (BCE) responsibility.

2.3.8 Work Order Process

Work orders (WO) shall be submitted to CEG for abatement work to be accomplished. WO shall be approved by CEG and reviewed and coordinated by CEIE, SGPB, and the Safety Office (SE).

See Section 10.0.

3.0 ROLES AND RESPONSIBILITIES

3.1 AIR FORCE CIVIL ENGINEER CENTER – OPERATIONS DIRECTORATE,

ENGINEER DIVISION (AFCEC/COS)

Develops requirements and provides guidance necessary for base facility asbestos management programs.

3.2 ENVIRONMENTAL CENTER OF EXCELLENCE (AFCEC/CZ)

Provides the oversight to ensure facility asbestos management is effective at each base.

3.3 78TH AIR BASE WING, ROBINS AFB

3.3.1 Base Civil Engineer Group (78 CEG) Responsibilities

3.3.1.1 The 78 CES, in coordination with the Environmental Management Branch (CEIE) and SGPB, will develop an AOP that meets the requirements identified in paragraph 7.2 of AFI 32- 1052. The plan shall detail how 78 CES will implement the requirements of the Robins AFB Asbestos Management Plan.

3.3.1.2 The AFI 32-1052 identifies Civil Engineering operations, maintenance and repair activities responsibilities. A list of applicable publications including title and dates of issuance is found in Appendix A. The 78 CES in coordination with the Civil Engineer Group, Engineering Division (CEN) is responsible for the following activities associated with Facility Asbestos Management at Robins AFB:

a. Maintains, repairs, constructs, and demolishes Robins Air Force Base real property facilities. The 78 CES/CEOE will include provisions for the safe handling, transportation, and disposal of ACBM in performing these activities; the 78 CES/CEOE will coordinate worker protection requirements with SGPB and environmental protection requirements with the CEIE function.

b. Decides whether asbestos related work will be done with in-service resources or by contract. (AFI 32-1052)

c. Provides an effective facility manager program. An effective facility manager program includes training facility managers on facility maintenance requirements and the building manager’s responsibility. This will include training from the public health flight on asbestos and other potential health hazards and should include a briefing by CEIE on base environmental issues (AFI 32-1001)

d. Identifies and budgets for asbestos activities required for the safe execution of a facility project. The cost of asbestos removal and disposal is a project cost and therefore must be funded from the same source as the project (O&M, DMAG, MFH, etc.). The one exception is a non-appropriated fund (NAF) project that requires repair, replacement, or removal of ACBM as a result of a NAF funded facility project.

In this case, the asbestos repair or removal is funded with appropriated funds (APF).

The reason for this is that ACBM is part of the normal building systems and as such the maintenance and repair (M&R) of normal building systems (heat system, insulating system, etc.) is an O&M responsibility. (AFI 32-1052, AFI 32-1022, AFI 32-1032)

e. Maintains and updates drawings including as-builts. These drawings (non-design drawings) are commonly called “as-builts” and should account for all changes to components or utility systems and infrastructure. This includes location and quantity of ACBM. When facility renovations or repairs are made the as-builts should be updated to reflect changes in location of ACBM. As the bases convert to computer aided drafting and design (CADD) or geographical information system (GIS) the as-builts should also be converted (AFPAM 32-1004V1, AFPAM 32-1004V2)

f. Plans and programs facility projects. Planning and programming is the identification of facility work and the process of acquiring authority, resources, and funding necessary to accomplish the project. In order to ensure a project is adequately programmed the presence or absence of asbestos in a facility must be determined in the planning and programming stages. The programmer in coordination with 78 CES/CEOE must review “as-builts” and asbestos inventories and identify the amount and locations of asbestos in a facility scheduled for renovation, remodeling, or demolition. The planner should determine if friable asbestos would likely be disturbed as a result of the work and recommend if removal is optional or mandatory.

Although the asbestos may not be disturbed during a renovation activity in which case it would not need to be removed, this should be considered as an alternative to reduce future M&R costs. Whatever option is selected the programmer must work with SGPB and CEIE to identify special requirements that would contribute to the cost of the project. Examples of the requirements could include negative air containment, special worker protection, special handling, transportation, and disposal cost. These costs must be included in the programming stage. (AFPAM 32-1005, AFI 32-1023, AFI 32-1032)

g. Ensures the design or renovation or M&R projects, including demolition, meets all applicable standards. The design process will include review of pertinent as-built drawings, as well as preliminary and final surveys of the project site. The review and survey will include a review of the asbestos inventory and a determination of the presence or absence of asbestos. If it is decided that an Architectural-Engineering (A- E) firm will conduct the design, this initial data will be provided as part of the statement of work (SOW). The SOW must contain a requirement for the A-E to verify location and condition of ACM that could be disturbed as the result of this project. The site investigative studies to conduct field surveys, obtain design data, and prepare contract plans and specifications and cost estimates are Title I, A-E services. These studies are funded from the same fund source as the project. When the design drawings, specifications and cost estimate are complete, the designer will prepare a review package for appropriate organizations. The package will be sent to SGPB and CEIE for review and coordination. This will include a determination by SGPB that OSHA requirements are included and a determination by CEIE that the requirements of the asbestos NESHAP and any applicable State of local environmental requirements have been met. (AFPAM 32-1005, AFI 32-1023)

h. Provides facility project asbestos construction inspection. Asbestos construction inspection, including verifying the work is done in accordance with applicable health, safety, and environmental regulations is a 78 CES responsibility. The asbestos construction inspector must act as the interface between the team of the design engineer, SGPB and CEIE and the contractor doing the work. The inspector also acts as the contracting officer’s technical representative (COTR). The AF has an in-house construction inspection course that covers proper removal and management of asbestos related activities. The contract Construction Inspection course includes asbestos removal requirements in the non-resident course (J7AZT3E571 01AA) through the 364 Training Squadron at Fort Leonard Wood, Missouri. If the inspector has not attended the AF course the inspector shall attend an EPA approved asbestos inspection or supervisor course and be fully trained in the requirements of asbestos removal, transportation, and disposal requirements of the asbestos NESHAP.

(AFPAM 32-1005, Air Force Procedural Handbook for Managing Environmental Compliance Contracts by Construction Inspectors and Quality Assurance Evaluators)

3.3.2 Facility Manager Responsibilities

The facility managers or building manager represents the workplace supervisor for all M&R or health and safety issues related to the buildings structural condition. The organization commander assigns the facility manager. A part of an effective facility manager program is the facility review.

a. Schedule facility reviews. Schedule a facility review with the 78 CES maintenance function as required to identify and accomplish all recurring work, minor maintenance and repair, and validate building conditions and work requirements. (AFPAM 32-

1004VC, AFI 32-1052)

b. Include the SGPB and CEOE as part of the facility review process when friable asbestos is present in a facility. The EPA, under the AHERA, requires schools to be re-inspected once every three years. The inspection is not mandatory for AF buildings however; good facility management requires the building manager/custodian to inspect exposed insulating material and other exposed ACBM material for damage as part of the daily, weekly or monthly maintenance check. (AFPAM 32-1004V3, AFI 32-1052)

c. Establish a periodic schedule with the 78 CES maintenance function to inspect nonpublic areas such as mechanical rooms. This can conveniently be done as part of the recurring work program (RWP) when heating, ventilation, and air conditioning (HVAC) systems are changed from heating-cooling-heating cycles (routinely twice a year). Where friable asbestos may be damaged or is becoming deteriorated, more frequent inspections may be required. (AFPAM 32-1004V3, AFI 32-1052, AFI 91-301)

d. Work with the 78 CES maintenance function to determine if health risks are present and to determine when the material can be repaired or replaced. If the determination is made that asbestos are present, the manager/custodian should coordinate with SGPB to conduct a risk assessment. (AFPAM 32-1004V3, AFI 32-1052)

3.3.3 Environmental Management Responsibilities (78 CEG/CEIE):

3.3.3.1 CEIE, in coordination with SGPB and 78 CES/CEOE, will develop an asbestos management plan (AMP) to meet the requirements in paragraph 5 of AFI 32-1052. The plan shall identify the roles and responsibilities for each organization involved in facility asbestos management and the procedures for continued update of the plan and the asbestos inventory/survey.

3.3.3.2 CEIE is responsible for coordination of environmental regulatory requirements and acts as the point of contact between the base and federal, state, or local environmental regulatory agencies. When facility renovation, remodeling, or demolition work is performed, the work practices must be done in an environmentally safe fashion. The work must also be done in accordance with environmental regulations. The work practices and procedures prescribed by the US EPA are found at 40 CFR 61.145, “Standard for demolition and renovation” and 40 CFR 61.150, “Standard for waste disposal for manufacturing, fabricating, demolition, renovation and spraying operations”. The US EPA has delegated oversight for the program to most states. The state may implement some requirements differently. CEIE must assist the programmer, designer, and contract inspector in identifying environmental requirements and work practices necessary to provide a complete project. Prior to start of work on any project, the contractor will provide a submittal for the asbestos removal plan. The following are the minimum federal requirements that must be coordinated for each project:

a. Determine if a threshold amount of asbestos is being removed. When a building is being remodeled or renovated and 260 linear feet (LF) of asbestos on piping, 160 square feet (SF) on other facility components, or 35 cubic feet (CF) on facility components where the length or area cannot be measured, a written notification of intent to renovate or demolish must be submitted to the agency administrating the program (the administrator). (40 CFR 61.145(a) The administrator is Georgia EPD.

b. Ensure that when a design is conducted by contract, the SOW for the A-E includes a requirement to verify location and condition of asbestos as part of the site investigative study. CEIE must work with 78 CES to provide the A-E as much data as possible to minimize the cost of the site investigation (40 CFR 61.145(a))

c. Ensure notification is provided to the administrator when threshold amounts of asbestos are removed. CEIE will work with the design engineer and construction agent to ensure that notification of intent to demolish or renovate is prepared and submitted (postmarked) to the administrator at least 10 working days prior to start of work. When the work is contracted CEIE will review the SOW to ensure this requirement is included. The SOW will include a clause that requires the contractor to provide CEIE a copy of the notification for review prior to submittal to the administrator (40 CFR 61.145(b)).

d. Review change notices. When the date of stripping/removal will begin on a date other that the original notification, the contractor/in-house notification change notice will be provided to CEIE for coordination. The change notice must include the date of notification, how the notification was provided and the new start date of the operations.

Under no circumstances will the notification date of a planned operation be less than 10 days before the start of the planned work (40 CFR 61.145(b)(3).

e. Review asbestos emissions control plan. The contractor or in-house staff will provide a detailed and comprehensive plan detailing asbestos emissions control. The plan will describe how the material will be adequately wet during removal. If wetting is not used, the plan will describe local exhaust ventilation and collection system (negative air containment) designed to capture particulate asbestos material produced by the removal operation. The system must produce no visible emissions to the outside. Alternate methods that are allowed are a glove bag system designed and operated to contain particulate asbestos generated as the result of the removal operation or a leak-tight wrapping to contain all regulated asbestos-containing material (RACM) prior to dismantlement of building components. (40 CFR 61.145(c))

f. Review required environmental training records. The asbestos removal plan will include a requirement that at least one trained on-site supervisor be present during all asbestos operations. The onsite supervisor must have received training or refresher training within the last year. CEIE will review the required training records to ensure this requirement is met (40 CFR 61.145(c)(8).

g. Review waste disposal plan. The asbestos removal plan will include a standard for asbestos waste disposal under 40 CFR 61.150 including:

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

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

3. Plans for labeling containers or wrapping material using warning labels specified by OSHA under requirements of 29 CFR 1910 or 29 CFR 1926.

4. Plans to mark vehicles used to transport asbestos-containing waste during loading and offloading so that signs are visible and meet the standards of 40 CFR 61.150(c).

5. The plan shall identify the US EPA approved landfill operated in accordance with 40 CFR 61.150(b).

CEIE will review and approve the contractor’s submittal prior to any work that would disturb asbestos (40 CFR 61.145).

h. Special Waste Acceptance Application (SWAA). The submittal will include provisions for the contractor to provide CEIE with a completed SWAA Form along with the lab analysis results at least five days prior to waste disposal. Upon approval for the waste disposal CEIE will provide the contractor with a Waste Tracking Document (WTD). The waste hauler will provide a copy of the WTD to the landfill operator with each load of waste. Waste tipping fee receipts assigned to the waste profile number must be provided to the contracting officer and CEIE prior to final payment for the project. If the disposal records (tipping fee receipts) are not received within 35 days of the date the waste was accepted by the initial transporter, CEIE will notify the state regulator responsible for administering the asbestos NESHAP program (40 CFR 61.150 (d)(3) and (d)(4)).

i. Verify waste shipment completion. The waste shipment record is maintained in the project files and CEIE. The waste shipment record includes the location, amount, and type of asbestos (friable/nonfriable) removed. CEIE will work with 78 CES/CEOE to verify the quantity and type of asbestos shipped corresponds to the asbestos removed. (40 CFR 61.150(d)(5))

3.3.4 Medical Services

3.3.4.1 Bioenvironmental Engineering (78 MDG/SGPB)

Plays two important roles in the facilities asbestos program:

a. Evaluates facility asbestos and determines the health risk of asbestos to facility occupants;

b. In consultation with CEIE and 78 CES/CEOE determines the best method for effective asbestos management and ensures the procedures for protection of workers engaged in asbestos activities are in compliance with OSHA requirements.

Prior to start of work on any project that disturbs asbestos, the contractor or in-house team will provide a submittal for the Health and Safety Plan including measures for protecting workers and AF personnel from exposure to asbestos. The SGPB will review the submittal for compliance with OSHA rules and recommend approval or changes (if required) to the contractor’s submittal.

SGPB will coordinate with 78 CES/CEOE, CEIE and the facility manager on all asbestos related facility evaluations and projects. The following are the SGPB responsibilities in the asbestos management program:

a. Conduct occupational and environmental health evaluations, health risk, and health hazard assessments in the work place. The SGPB will assign Risk Assessment Codes (RAC) to occupational and environmental health hazard deficiencies. (AFI 91-301)

b. Review BCE WOs, plans, and projects to ensure occupational and environmental health issues are addressed. This includes any self-help projects. (AFI 91-301)

c. Perform an initial review of the AOP and perform periodic follow-ups on in-house procedures for asbestos removal.

d. Review construction/renovation health and safety plans (contractor submittals) to verify contractor employees are trained or accredited and that removal will be done IAW applicable federal, state, or local health regulations. The review will verify that measures to monitor worker exposure and clearance-sampling plans are adequate, that accredited laboratories will perform the asbestos analysis and that AF personnel are protected. (AFI 48-119)

e. Conduct or arrange and oversee sampling, analysis and monitoring (SAM) in support of the Installation Asbestos Facility Survey (inventory). (AFI 48-119)

3.3.4.2 Public Health 78 AMDS/SGPM

Provide asbestos awareness health education/training for military and civilian personnel that may require this type of training. Education is key to effective asbestos management. CEIE, 78 CES/CEOE and SGPB all receive state approved training in asbestos as part of their job. Other employees that do need training to the same level as these functions may work in buildings that contain asbestos. These employees are custodial or maintenance personnel, facility managers or work place supervisors. The method that Public Health accomplishes this training will be addressed in the operations and management plans.

3.4 AFSC CONTRACTING (AFSC/PZ)

Ensures that copies of all project notifications and required fees to the state are received as submittals, as required by Asbestos Abatement Guide Specification 01568. PZIOC (Construction Flight) and PZIOB (Services Flight) also manage architectural and engineering contracts plus all construction, demolition, and remodeling contracts.

3.5 MAINTENANCE SUPPORT GROUP (402 MXSG)

When Plant Services 402d Maintenance Support Squadron (402 MXSS) encounters materials suspected of containing asbestos, contact BAOO to initiate taking a sample and sending to the lab for analysis. If the results are positive for asbestos, MXSS will then proceed to procure a service contract with an approved contractor, after coordination with CEIE and the using organization, for asbestos abatement or encapsulation as required by the circumstances. Training and chain of custody requires the inspector for plant services to have special training and follow chain of custody rules to prevent mishandling of the material.

4.0 NOTIFICATION

This section delineates requirements for notification of contract workers, facility managers, and regulatory agencies. This guidance applies to all base buildings, work areas, recreational facilities, residences, or any other area that may contain asbestos.

4.1 ASBESTOS POINTS OF CONTACT

Points of Contact (RAC s) for the Base AMP are the BAPO and BAOO. All building renovation work must first be cleared by the BAPO. The BAPO is the point of contact for all abatement projects. This AMP will be posted on eDASH at: https://cs1.eis.af.mil/sites/edash-ins1/robins/Shared%20Documents/Toxics/Asbestos_Plan%202005.pdf

4.2 CONTRACTORS

Contract worker refers to off-base contractors or service vendors who occasionally work on base.

Cable company technicians and remodeling contractors are included in this group. These personnel may unknowingly disturb ACM in the course of their work, therefore, notification of the possibility of potentially hazardous asbestos containing materials will be included in the request for proposals.

4.3 FACILITY/BUILDING MANAGERS

The BAOO will ensure that building managers are aware of the requirement to contact CEIE prior to any renovation/demolition activities. The AF Form 332, CE Work Request, should be annotated if work being requested will disturb ACM.

Building managers will be trained by the BAOO in the building manager training meetings.

Building manager training meetings are scheduled and conducted by the Real Property Office.

The BAOO will coordinate building managers training with the Real Property Office.

4.4 REGULATORY AGENCIES

CEIE is responsible for ensuring all notifications to off-base regulatory agencies are completed.

Copies of these forms are maintained in the BAPO’s office. Under no circumstance should a demolition or abatement project begin without the BAPO having copies of the state notification on file. If the project involves abatement work in preparation for demolition, but the demolition work is to be performed by others, the project notification from the abatement contractor should address only the abatement activities, even if they know who the demolition contractor may be.

Demolition contractors must submit a separate project notification for the work they will perform, whether or not asbestos containing materials remain or there was no asbestos. If the project is a joint abatement/demolition project under the responsibility of one contractor, then one notification is sufficient. If the contractor makes the notification, copies of the completed notification form and certified mail receipt must be provided to the BAPO—prior to the start of https://cs1.eis.af.mil/sites/edash-ins1/robins/Shared%20Documents/Toxics/Asbestos_Plan%202005.pdf https://cs1.eis.af.mil/sites/edash-ins1/robins/Shared%20Documents/Toxics/Asbestos_Plan%202005.pdf project. The State of Georgia requires a 10-day notification for all demolition and abatement projects. The current state notification form is provided at Appendix A.

5.0 TRAINING REQUIREMENTS

This section specifies training requirements for each group of workers (Table 5). Personnel that require level 3 training requirements must attend EPA certified training courses approved by the Georgia Environmental Protection Division (EPD). Additionally, procedures for documenting training and the responsibilities of key offices are set forth.

Table 5 Asbestos Training Requirements

Inspector 3 Days Management Planner 5 Days Abatement Supervisor 5 Days Project Designer 4 Days Awareness 2 Hours O & M Worker 2 Days Abatement Worker 4 Days

5.1 PROGRAM ADMINISTRATORS TRAINING

Personnel who serve as the BAPO are required to attend a US EPA certified Asbestos Supervisor Course. The BAOO is required to attend both the US EPA certified Asbestos Inspector Course and US EPA certified Asbestos Supervisor Course. BAOO will designate an adequate number of personnel to provide supervision and inspection duties in support of Asbestos Abatement Team.

Personnel serving…