A07 TE 4.23 RIA Asbestos Management Plan.pdf

Rock Island Arsenal Garrison Asbestos Management Plan

May 2016

Prepared by:

U.S. Army Garrison, Rock Island Arsenal Directorate of Public Works Rock Island, IL 61299-5000

TE 4.23 RIA Asbestos Management Plan i

NOTE: for Emergency Response Actions, see page 44 (Chapter 7, Section 5).

Contents

Chapter Page

Abbreviations and Acronyms ........................................................................................................................ iii

1 The Installation Asbestos Management Program

1-1 Purpose 1-2 Objectives 1-3 Scope 1-4 Installation Description 1-5 Applicability 1-6 Regulatory Perspective

1-7 Summary of OSHA Exposure Standards and Regulations 1-8 Summary of USEPA Exposure Standards and Regulations 1-9 Summary of DOT Exposure Standards and Regulations

1-10 Applicable Regulations and Guidance Materials 1-11 Sources of Information on Regulations and AHERA Training Courses

1-12 Illinois Regulations

2 Asbestos: Types, Uses, and Health Effects

2-1 What is Asbestos?

2-2 Exposure to Asbestos

2-3 Health Effects of Asbestos Exposure 2-4 Prevention of Asbestos-Related Illness 2-5 Cause and Effects of Damaged ACM

2-6 Asbestos Identification

3 Implementing an Installation Asbestos Management Plan

3-1 Authority and Responsibility for the Rock Island Arsenal Asbestos Management Plan ... 13

4 Qualifications and Training

4-1 Asbestos Management Team Training Requirements 4-2 Training of Custodians and Maintenance Workers for O&M Programs

4-3 Additional Training Material 4-4 Recommended Training Requirements for Department of the Army Personnel

Involved with Asbestos Management or Abatement

5 The Installation Asbestos Survey and Assessment

5-1 Surveys and Inspections

6 Asbestos Controls and Abatement Alternatives

6-1 Determination of the Need for Abatement 6-2 In Place Management 6-3 Asbestos Control Actions ii

Contents (continued)

Chapter Page

7 Health and Safety During Asbestos Abatement

7-1 Air Monitoring 7-2 Personal Protective Equipment 7-3 Respiratory Protection 7-4 Medical Surveillance 7-5 Emergency Response Action 7-6 Housekeeping Practices 7-7 Disposal 7-8 Equipment 7-9 Record Keeping

Tables

Table 4-1. Recommended Training for Department of the Army Personnel Engaged in Asbestos Management or Abatement

Table 7.1. Respiratory Protection for Asbestos Fibers

Table 7.2. Frequency of Chest Roentgenograms

Appendices

Appendix A – Figures Figure 1 Flow Chart Appendix B - Applicable Regulatons 40 CFR 763 Subpart E: Asbestos-Containing Building Materials in Schools (AHERA) 40 CFR 61 Subpart M: National Emission Standard for Asbestos (NESHAP) iii

ABBREVIATIONS and ACRONYMS

ACM

Asbestos-Containing Materials

ACO

AEIS

Asbestos Control Officer Army Environmental Information Service

AFOSH Air Force Occupational Safety and Health AHERA Asbestos Hazard Emergency Response Act AIHA American Industrial Hygiene Association AMP Asbestos Management Plan AMT Asbestos Management Team ANSI American National Standards Institute AR Army Regulation ARPP Army Respiratory Protection Program ASHARA Asbestos School Hazard Abatement Reauthorization Act ASPI Arsenal Support Program Initiative Center AWP Annual Work Plan CAA Clean Air Act CFR Code of Federal Regulations COR Contracting Officer’s Representative DOT Department of Transportation f/cc Fibers/Cubic Centimeter FEV Forced Expiratory Volume FVC Forced Vital Capacity GRADE Guidance for Rating Assessing Damage and Exposure HEPA High-Efficiency Particulate Air IDPH Illinois Department of Public Health IEPA Illinois Environmental Protection Agency IAW In Accordance With IJO Individual Job Order lf Linear Feet MAP Model Accreditation Program MSHA Mine Safety and Health Administration MCA Management Control Activity NBS National Bureau of Standards NDAAC National Directory of AHERA Accredited Courses NESHAP National Emission Standards for Hazardous Air Pollutants NIOSH National Institute for Occupational Safety and Health NVLAP National Voluntary Laboratory Accreditation Program O&M Operations and Maintenance OSHA Occupational Safety and Health Administration PACM Presumed Asbestos-Containing Material PAT Proficiency Analytical Testing PCM Phase Contrast Microscopy PEL Permissible Exposure Limit iv

ABBREVIATIONS and ACRONYMS (Continued)

PLM Polarized Light Microscopy PPE Personal Protective Equipment PPM Parts Per Million PWTB Public Works Technical Bulletin RACM Regulated Asbestos-Containing Material REARM Project Renovation of Armament Manufacturing RIA Rock Island Arsenal RPP Respiratory Protection Program sf Square Feet SO Service Order TEM Transmission Electron Microscopy TOC Task Order Contract TSCA Toxic Substances Control Act TSI Thermal System Insulation TWA Time-Weighted Average U.S. United States USAEC US Army Environmental Center

USEPA

WO

U.S. Environmental Protection Agency Work Order

CHAPTER 1

THE INSTALLATION ASBESTOS MANAGEMENT PROGRAM

1-1. Purpose

The primary purpose of the Rock Island Arsenal (RIA) Asbestos Management Plan (AMP) is to provide a practical plan to manage confirmed and suspect asbestos-containing materials (ACM) present in RIA facilities. The plan is intended for use by local operation and maintenance (O&M) plan managers, who may have little, if any, previous experience working with asbestos. This document is generic but also includes information specific to the RIA facilities in accordance with:

The overall Army policy governing the RIA and asbestos related activities as follows:

(1) Comply with all federal, state, and local laws and regulations.

(2) Exclude asbestos from all procurements and uses where asbestos-free substitute materials exist.

(3) Minimize asbestos releases to the utmost extent possible.

(4) Establish and execute AMPs.

(5) Establish Asbestos Management Team (AMT).

(6) Program and budget resources to identify, manage, and control exposure to asbestos.

(7) Conduct installation surveys to identify the existence, extent, and condition of all asbestos.

(8) Perform an exposure assessment and risk assessment for all locations containing asbestos.

(9) Take immediate corrective action where a possible asbestos related health hazard has been identified.

(10) Notify facility occupants of any asbestos related health hazard identified in their work environment.

(11) Assess the relative health risks for alternative control actions. Asbestos should not be removed for the sole purpose of eliminating asbestos.

(12) Follow the regulations contained in the Asbestos Hazard Emergency Response Act (AHERA) and related U.S. Environmental Protection Agency (USEPA) Regulations when dealing with elementary and secondary schools operated by the Army.

(13) Use all feasible and safe methods to control ACMs in accordance with established federal, state and local laws. The Local Staff Judge Advocate is available to interpret the obligations and applications of the relevant laws. Army installations are encouraged to establish a small, in-house capability using properly equipped, trained, and certified civilian personnel to accomplish emergency projects or small projects not cost effective to contract. Installations should continue to use contractors to perform large asbestos abatement projects.

Installations in the same geographic area should establish capabilities that complement each other. Specific steps will be taken to ensure compliance with federal, state, and local regulations and to assure proper contract development and surveillance, medical support, and oversight.

1-2. Objectives

The Asbestos Management Program is the mechanism for implementing actions necessary to:

Control health hazards to personnel and to ensure protection from airborne asbestos fibers.

Provide key personnel with asbestos awareness training so they are more prepared to fulfill their roles and responsibilities safely and effectively.

To identify, record and assess existing ACM.

To properly manage identified ACM (through abatement and O&M actions).

To comply with applicable laws and regulations pertaining to asbestos.

To ensure that identified ACM shall not be removed for the sole purpose of eliminating asbestos.

This plan provides guidelines for the effective management of ACMs in RIA facilities. The plan is consistent with federal, state, and local requirements.

It is the policy of the RIA to control asbestos (including all ACMs, friable and non-friable) and to minimize environmental release of airborne asbestos fibers and subsequent occupational and incidental exposures.

The following policies have been adopted:

Asbestos shall be excluded from all RIA procurements and uses where asbestos-free substitutes exist.

Asbestos shall be handled, stored, transported and disposed of in accordance with (IAW) federal, state, local and U.S. Army requirements.

Occupational exposure to asbestos shall be minimized by properly implemented work practices, including the use of appropriate personal protective equipment (PPE) and engineering controls.

Employees having the potential of occupational exposure to asbestos will be enrolled in the RIA medical surveillance program and shall be informed of hazards associated with potential exposures as required by laws and regulations.

RIA shall provide PPE and clothing, including respirators, to RIA workers IAW federal regulations.

RIA will program and budget adequate resources to identify, manage and control exposure to asbestos.

1-3. Scope

The AMP addresses management of ACM and suspect ACM at RIA. The AMP has been prepared in accordance with the Department of the Army, U.S. Army Center for Public Works Technical Bulletin (PWTB) 23, March 1998, No. 420-70-8 which requires development of adequate procedures to manage existing ACM and Army Regulation (AR) 200-1, Environmental Protection and Enhancement, August 2007.

Intact and undisturbed ACM does not pose a significant risk of exposure when properly managed.

Damaged or disturbed ACM poses an increased risk of exposure depending on both the nature and quantity of the damaged material disturbed. Inhalation of airborne asbestos fibers poses a potential health hazard to exposed personnel and constitutes a recognized health hazard. Since asbestos is a known carcinogen, which is regulated by federal, state, and local governments, ACM must be managed in a manner that protects human health. Therefore, an AMP was developed to provide oversight of asbestos-related issues and to manage ACM in place.

USEPA, Occupational Safety and Health Administration (OSHA), and Department of Transportation (DOT) regulations are amended frequently. The AMT is advised to review this document to understand Army Policy and to implement it at the installation level. It will be necessary for the AMT to keep abreast of regulatory developments thru its review of any changes in Title 29 Code of Federal Regulations (CFR) (Department of Labor), Title 40 CFR (Protection of Environment), and Title 49 CFR (DOT) contained in the Federal Register. Having facility AMT members attend training classes and seminars on asbestos management is an excellent way to keep current with the new regulations.

The AMP encompasses all activities involved in the management and control of ACM at RIA. The program consists of the following elements:

A. On-going review of schedules, design plans, and specifications.

B. Surveys/Identification: the identification and documentation of ACM at RIA is critical to gaining a comprehensive understanding of the scope and magnitude of the asbestos problem. This is done through the review of facility records, visual inspections, surveys, and bulk sampling. Samples are analyzed by an approved, National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory, to determine if material contains asbestos.

C. Assessment/Prioritization and Planning: areas where survey results confirm the presence of asbestos will be assessed by a person trained as an EPA certified Inspector/Management Planner to determine the potential health hazard. The need for asbestos control by a special O&M program depends on the likelihood of fiber release that could create a condition that would require abatement. Evaluating the material’s condition, physical characteristics and locations can assess the possibility of fiber release. The results of this assessment, along with the professional judgment of the evaluator, will be used to identify and sequence the order of the required asbestos control measures. ACM documented by surveys will be inspected annually.

D. Asbestos Control Measures: the ultimate control measure for friable ACM is the removal and proper disposal of the material. To the extent that this is not practical or possible given physical and budgetary constraints, other control measures must be considered. These measures generally consist of repair and encapsulation or enclosure. These lesser measures serve to minimize or eliminate the potential for disturbance under normal operations until such time as the ACM can be removed.

E. O&M Awareness: to the extent that any ACM remains in a facility, building occupants, housekeeping personnel and Government contractor personnel will be made aware of any actions which may disturb the ACM. The following procedures will be used:

(1) Building occupants, visitors and outside contractors will be notified of areas where their normal activities could disturb ACM and be advised of precautionary measures.

(2) Housekeeping and maintenance personnel will be notified of areas where their normal activities could disturb ACM. The AMT will ensure that all housekeeping and maintenance personnel who work in these areas are trained in accordance with the USEPA AHERA standards and that they are informed of the proper procedures for working in these areas.

F. New Facility/Renovation: Government/contractor design personnel will ensure that the scope of work for all construction projects states that no ACM is to be used. Project engineers or architects are to ensure that ACM is not used during the construction process.

G. Planning and Programming: In order to avoid costly delays or accidental exposure to asbestos fibers, reviews will be made during the planning stages of all O&M, renovation, and demolition activities to determine the involvement of ACM. Projects, which will disturb or are likely to disturb ACM, will be identified as such on planning and programming documents and the precautions outlined in this plan will be followed. The fact that a project involves ACM is not cause for assigning a higher priority to the project. Projects involving asbestos abatement will be prioritized on individual merit and mission requirements.

H. In-House Capability: The Asbestos Control Officer (ACO) will ensure that RIA has the capability to conduct all asbestos abatement activities necessary for the completion of routine and emergency work orders (WO), service orders(SO), individual job orders (IJO), and O&M activities in areas where ACM is present. The ACO will ensure that all asbestos work is supervised by a properly trained competent person in accordance with laws and regulations.

The RIA will not conduct abatement activities with Government personnel.

1-4. Installation Description

RIA is situated on 946 acres on an island in the upper Mississippi River between the cities of Rock Island and Moline, Illinois, and Davenport and Bettendorf, Iowa. RIA is located in Sections 29 to 32, Township 18 North, Range 1 West, and Sections 25, 26, 35, and 36, Township 18 North, Range 2 West of Rock Island County, Illinois. This location is shown on a facility layout map on Figure 1 in Appendix A. The geographic coordinates of RIA are 41°31’ north latitude and 90°32’ west longitude.

The island is commonly known as Arsenal Island. The surrounding Illinois and Iowa communities, with a population of approximately 375,000, form an area known as the Quad Cities. The largest employer in the bi-state region; the RIA has a workforce strength of more than 8,500 employees, including; military and civilian federal employees, and more than 70 federal and commercial tenants.

RIA has three distinct missions: (1) to manufacture artillery, gun mounts, recoil mechanisms, small arms, and spare parts; (2) to perform tool set and basic issue item fabrication and assembly; and (3) to provide administrative, logistical, and facility support services for RIA operations and tenant activities.

In the 1990s, RIA completed an extensive modernization program called Project REnovation of ARmament Manufacturing (REARM). As a result of REARM, RIA now has a modern manufacturing complex equipped with state-of-the-art computerized machining centers. This renovation of its manufacturing operations has improved RIA’s productivity and effectiveness and has made it one of the premier facilities of its type in the defense establishment.

RIA’s logistics mission includes fabrication of shop sets, tool sets, kits and outfits, and basic issue items. These items, consisting of tools, parts, and accessories, are used in the field to maintain and repair vehicles and weapons. RIA also packages and ships these items to their destinations. In addition, RIA maintains a depot operation to store and distribute supplies.

1-5. Applicability

The AMP limits its scope to the management of ACMs, and applies to RIA. All military, civil service, and contractor personnel working at any of these facilities must adhere to the provisions of the AMP. Responsibilities have been delegated to individuals or organizations as identified throughout the various sections of the AMP.

1-6. Regulatory Perspective

In accordance with Army policy, this AMP complies with federal, state, and local regulations and U.S.

Army Center for Public Works instructions and directives. This section lists only the regulations that are most applicable to management of asbestos at RIA. Other federal and state regulations that are not listed below regulate storage, handling, and disposal of hazardous waste. Appendix B includes specific portions of the regulations presented in the following sections applicable to renovation and/or demolition activities at RIA involving ACMs.

Since on-site personnel will not work directly with suspect and confirmed ACM, these regulations may not directly affect employees other than management of projects that involve asbestos. However, license and registration affect contractors hired to repair and abate suspect and confirmed ACM at the RIA facilities. Therefore, only properly licensed, registered, and trained contractors should be inspecting, handling, remediating, overseeing, disposing of, or working with suspect or confirmed ACM material at the RIA facilities.

The control of airborne asbestos-containing dusts in the workplace and to the public has been regulated by both OSHA and the USEPA for the past 25 years. The regulatory history of this substance by these two agencies with regard to building materials has always been somewhat diverse. OSHA’s concerns relate to the control of asbestos dusts in the workplace whereas the USEPA was concerned about non-occupational exposures among building occupants from deteriorating ACMs. The USEPA’s concern focused principally on school children culminating in the passage of AHERA in 1986.

On August 10, 1994, (with corrections issued in the Federal Register dated June 29, 1995), OSHA published the final rule on the Occupational Exposure to Asbestos. This rule is applicable to Army activities since it includes specific requirements for building construction involving asbestos as well as custodial or maintenance activities which may result in the disturbance of asbestos.

A number of states have enacted varying statewide and local regulations affecting asbestos abatement contractors, environmental laboratories, and industrial hygiene and architect/engineering consultants. Permits and licenses are required for these entities to operate within a particular state after meeting certain training approvals and payment of fees; some states grant reciprocity for firms operating in neighboring states. Since state requirements are so highly variable, the offices should be contacted individually.

A review of the current OSHA, DOT and USEPA documents (actual citations) on asbestos is a mandatory requirement.

1-7. Summary of OSHA Exposure Standards and Regulations

The first exposure standard passed under OSHA, on May 29, 1971 established a permissible exposure limit (PEL) of 12 fibers/cubic centimeter (f/cc) for an 8-hour time-weighted average (TWA).

Over the years, OSHA continued to reduce the occupational exposure level to the present value.

These reductions were designed to protect employees from asbestosis and asbestos related diseases. Changes covered all asbestos related industries including construction, emergency temporary standards, medical monitoring, respiratory protection, work practices, unique hazards associated with asbestos removal and demolition projects, training and prohibition of workplace smoking in areas where occupational exposure to asbestos may occur.

The current OSHA standard is 0.1 f/cc per 8-hour - TWA, which went into effect on August 10, 1994 and had an impact on asbestos abatement activities at all levels including the following:

(1) The standard addresses in detail the types of worker activity and the materials that are regulated. There are specific regulations on control conditions, specific training requirements for asbestos workers have been expanded, and there are expanded hazard communication procedures especially for multi-employer work sites.

(2) Building materials are either ACM or non-ACM if they have been analyzed by an appropriate method. In the case of materials installed before 1980, they may be classified as presumed asbestos-containing material (PACM) for certain materials.

(3) The strategy for worker protection is based on the fact that the worker is dealing with asbestos rather than on the possibility that the PEL is exceeded. This important change provides much greater worker protection because, in the majority of cases, a significant exposure occurs before air monitoring results is available.

(4) The regulation holds building owners responsible for informing all who work in a building from outside service personnel, maintenance workers and custodians that ACM or PACM is present.

(5) This regulation reclassifies asbestos related work into four categories:

Class I activities involving the removal of thermal system insulation (TSI), and sprayed on or troweled on or otherwise applied surfacing ACM or PACM.

Class II removal of ACM or PACM which is not TSI or surfacing ACM or PACM.

Class III repair and maintenance operations which are likely to disturb ACM or PACM.

Class IV custodial and housekeeping operations where minimal contact with ACM and/or

PACM will occur.

(6) This new designation replaces the older large scale, small scale, short duration system followed in the 1986 OSHA regulation.

(7) The classification of activities is treated uniformly in the general industry standard, the construction standard and the shipyard standard of this regulation. OSHA has established several standards to protect workers from exposure to asbestos. The following regulations apply:

29 CFR 1910.1200, Occupational Safety and Health Standards, Hazard Communication.

29 CFR 1910.1001, Occupational Safety and Health Standards, Asbestos.

29 CFR 1926.1101, Safety and Health Regulations for Construction, Asbestos.

Construction work, as defined in 29 CFR 1910.12(b), is the primary activity at RIA that may expose facility personnel to asbestos. These activities include:

Demolition or salvage of structures where asbestos is present.

Removal or encapsulation of materials containing asbestos.

Construction, alteration, repair, maintenance, or renovation of structures, substrates, or portions thereof that contain asbestos.

Installation of products containing asbestos.

1-8. Summary of USEPA Exposure Standards and Regulations

The USEPA, under the authority of the Clean Air Act (CAA) of 1970, and specifically in the Toxic Substances Control Act (TSCA), introduced regulations to minimize building occupants’ exposure to asbestos dust derived from building materials. All of the USEPA regulations concerning airborne asbestos are derived from the asbestos standard issued under the National Emission Standards for Hazardous Air Pollutants (NESHAP), and in 1973 the use of asbestos in sprayed-on fireproofing for buildings was banned. NESHAP was further amended in 1978 to prohibit the use of asbestos in architectural decorative plasters. The emphasis in the USEPA’s program shifted at about this time to the issues of asbestos in schools. A series of guidance documents was issued to superintendents of elementary and secondary schools explaining potential health hazards and the methods available to minimize them. In 1982, the Asbestos Identification and Notification Act was passed directing that all public and private elementary and secondary schools be inspected for ACM. Regulations passed under this Act required local school authorities to maintain the school asbestos surveys at each school and make them available for public inspection. Compliance with this regulation lacked uniformity across the country and, in 1986 the USEPA introduced regulations under the AHERA which were far more rigorous in application and contained substantial penalties for noncompliance.

Some highlights of the regulation are as follows:

(1) Training is required for all individuals who remove asbestos, inspect buildings for ACM, monitor asbestos abatement projects, supervise asbestos abatement projects, and design asbestos abatement projects. The details of training are contained in the Model Accreditation Program (MAP) portion of the regulation.

(2) Reinspection is required for all elementary and secondary public and private schools. The regulation also specifies a schedule of additional inspections to make certain that any remaining ACM is not deteriorating.

(3) If an asbestos abatement project is undertaken in a school, a detailed protocol must be followed with regard to air sampling, its collection and analysis by transmission electron microscopy (TEM).

On November 28, 1990, the Asbestos School Hazard Abatement Reauthorization Act (ASHARA) was enacted to amend certain portions of AHERA to extend certain elements of the school program to public and commercial buildings. For example, an individual conducting inspections and assessments in public and private buildings must have the same training certifications as required under AHERA. ASHARA also requires the USEPA to revise the MAP to increase its hands-on training requirements and to make other changes necessary to extend the MAP to public and commercial buildings. From the earliest days of this technology, most in the field defined asbestos abatement to include one or a combination of: removal, enclosure, encapsulation, and management in place. The latter, more passive, approach became known as O&M, and the USEPA issued a guidance document on this alternative in 1988. The USEPA's sanctioning of the O&M approach greatly tempered the urge on the part of building owners and operators to rush into asbestos removal projects. The O&M option has been adopted by the Army and is an important component of the asbestos management program. Situations will arise, however, where ACM must be disturbed such as in the course of renovation or demolition operation. The more active asbestos abatement options will have to be followed in these cases.

EPA has established several standards to protect the public from exposure to asbestos. The following regulations apply:

40 CFR 61, Subpart M, NESHAP.

40 CFR 260-265, Hazardous Waste Management Regulations.

40 CFR 302, Designation, Reportable Quantities Notification.

40 CFR 373, Reporting Hazardous Substance Activities When Selling or Transferring Federal Real Property.

40 CFR 141, National Primary Drinking Water Standards.

If asbestos is present, construction will require compliance with 40 CFR 61, which regulates fugitive emission from work sites.

1-9. Summary of DOT Exposure Standards and Regulations

In the 1970s and 1980s, DOT passed regulations for the packaging, placarding and hauling asbestos and other hazardous materials. The regulations also include a manifest system to account for the amounts of material hauled. These DOT regulations are found within 49 CFR Sections 171, 172, and 173, and specify the packaging and shipping requirements for asbestos-containing debris.

1-10. Applicable Regulations and Guidance Materials

Applicable federal regulations are listed in in Sections 1-7 and 1-8, but it should be borne in mind that these regulations occasionally change. The AMT is advised to monitor the Federal Register to ensure that compliance in this area remains up to date for the purposes of the AMP.

1-11. Sources of Information on Regulations and AHERA Training Courses

Questions regarding the interpretation of federal regulations and questions concerning requirements at the state level should be addressed to the appropriate offices and personnel listed in Chapter 3, Section 3-1.

The USEPA provides a list, updated quarterly, of AHERA-accredited training programs. This list is entitled the National Directory of AHERA Accredited Courses (NDAAC) and is available through the NDAAC Clearinghouse at (202) 554-1404 (the TSCA Hotline). Additional USEPA documents, such as the current guidance documents are also available by contacting the TSCA hotline.

1-12. Illinois Regulations

The Illinois Environmental Protection Agency (IEPA) is delegated authority by the USEPA to enforce NESHAP regulations. NESHAP regulates asbestos during demolition, renovation and disposal.

Certain parts of the IEPA also regulate asbestos. Some municipalities have permit fees or other regulations regarding asbestos abatement and/or demolition activities. Please check with local authorities prior to demolition/renovation activities.

Illinois Department of Public Health (IDPH) also has regulations for asbestos. For information regarding asbestos training, or licensure, please contact IDPH at (217) 782-3517. IDPH also has regulations regarding schools, and commercial and public buildings.

The following regulations apply:

Title 35: Environmental Protection, Subtitle B: Air Pollution, Chapter I: Pollution Control Board, Subchapter C: Emission Standards and Limitations for Stationary Sources, Part 228 Asbestos.

Professions and Occupations (225 ILCS 207/) Commercial and Public Building Asbestos Abatement Act.

Title 77: Public Health, Chapter i: Department of Public Health, Subchapter p: Hazardous and Poisonous Substance, Part 855 Asbestos Abatement for Public and Private Schools and Commercial and Public Buildings in Illinois

CHAPTER 2

ASBESTOS: TYPES, USES, AND HEALTH EFFECTS

2-1. What is Asbestos?

“Asbestos” is a general term that refers to a group of six naturally occurring fibrous minerals. These minerals are primarily composed of magnesium and silica. They are chemically inert, resist the flow of heat and electricity, and have high tensile strength and favorable acoustical properties. For these reasons, asbestos has been mined in many international locations. The asbestos-containing ore typically is refined to break down the mineral into loose, inexpensive bulk fiber that is added to products to improve their physical properties. The use of asbestos in building materials did not become common until the beginning of the 20th century, and use of asbestos peaked during World War II.

Asbestos fibers have been used in TSI (pipe, tank, and boiler insulation), fireproofing, other surfacing materials, vinyl floor tile, roofing materials, cement asbestos products, clothing, gaskets, machinery, electrical insulation, and friction products such as brakes. This list does not include all uses of asbestos, because asbestos was valued and used in many human-made building products at the discretion of manufacturers. The use of asbestos was so common that practically any manmade product that contains fibers could contain asbestos.

There are two federal definitions for ACM. The USEPA defines a material to be asbestos-containing if there is one percent or more by weight or area of one or more of the six minerals described below.

OSHA, on the other hand, sets the limit at 0.1 percent by weight or area for these six minerals.

Products containing more than 0.1 percent by weight asbestos must have warning labels affixed to the outside wrapper or package to meet OSHA regulations. Curiously, the regulations define asbestos-containing on a by weight or area basis; and yet the USEPA-approved polarized light microscopy (PLM) method for the analysis of both samples determines asbestos content on a by area basis. This disparity has been used successfully in challenging this regulation in the courts. The USEPA NESHAP regulations also use the term regulated asbestos-containing material (RACM) for construction products that are not friable under conditions of normal use; but can become friable under certain conditions. Category I includes, asbestos-containing roofing felt, vinyl asbestos floor tile, gaskets, and valve packing materials. Category I materials become RACM because they become friable through sanding, grinding, aging, weathering or chemical attack, drilling, or sawing.

Category II includes asbestos-containing shingles, transite, or other asbestos board. Category II materials become RACM when they are rendered friable through pulverizing or other similar force.

By the late-1970s, several uses of asbestos had been banned in the U.S. by the USEPA. Among the banned uses were a limited number of applications including surfacing materials such as fireproofing, soundproofing, acoustical and decorative finishes, and TSI. Many other products that may contain asbestos can be manufactured legally. For example, asbestos is still used in construction mastics, roofing materials, and some drywall joint compounds. The most common type of asbestos encountered in the U.S. is called chrysotile. Chrysotile in bulk has a white, cottony appearance. The fibers tend to twist and curl. It is commonly associated with floor tile, TSI, and surfacing materials.

Amosite and crocidolite are less commonly encountered types of asbestos. Amosite is also known as “brown asbestos” because of its yellow-brown coloration in bulk. Crocidolite, or “blue asbestos,” is easily recognized because of its characteristic navy-blue color. Both amosite and crocidolite have straight needle-like fibers. Both of these types are commonly encountered (but not always) in TSI and surfacing materials.

Three other types of asbestos exist including tremolite, actinolite, and anthophyllite. These minerals are encountered infrequently as contaminants of other mineral products such as talc and vermiculite.

These asbestos types are rarely encountered in buildings. They are listed here primarily for informational purposes.

2-2. Exposure to Asbestos

Asbestos fibers are primarily an inhalation hazard. For a person to inhale asbestos, the fibers must become airborne through physical disturbance of an ACM. Typically, ACM that is friable — meaning it can be reduced to a powder by hand pressure — poses the greatest risk because of the ease of which friable materials can release fibers into the air when disturbed.

The OSHA defines the PEL for airborne asbestos fibers as 0.1 f/cc of air for an 8-hour TWA. When ACM is properly maintained, this exposure level is rarely, if ever, exceeded during a typical workday.

However, disturbances such as maintenance, renovation, demolition, or abatement may elevate airborne fiber levels. Therefore, it is important to ensure that the PEL is not exceeded during these activities. Sensitivity to the presence and potential hazard of asbestos is essential to maintain and operate buildings properly.

2-3. Health Effects of Asbestos Exposure

Microscopic asbestos fibers are hazardous to health when inhaled because they can become trapped deep within the lungs. The natural movement of the human body causes the fibers to penetrate cells deep within the lungs. Some of these microscopic penetrations may induce the cells to create scar tissue or possibly to grow irregularly (that is, to become cancerous).

Asbestos is a known health hazard, but the risk of contracting an asbestos-related disease depends on exposure to airborne asbestos fibers. Friable asbestos is the only form that poses a health hazard. Friable ACM is defined as ACM that can be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable asbestos is not crumbled, pulverized, or reduced to a powder by hand pressure. However, damage to non-friable ACM caused by an external disturbance (such as drilling or chiseling) can potentially release asbestos fibers to the air. Individuals can be exposed to asbestos through dermal contact, ingestion, or inhalation. The greatest risk to health is inhalation of asbestos particles, followed by ingestion, and then dermal contact. The toxic effects of asbestos stem from particle size and shape more than from chemical composition.

If inhaled, asbestos can cause diseases that disrupt normal lung function. Three diseases have been linked to asbestos exposure: asbestosis (a fibrotic scarring of the lung); lung cancer; and mesothelioma (a cancer of the chest lining or abdominal cavity). The risk of contracting one of these diseases depends on the level of exposure over a lifetime. The greater the exposure to asbestos, the greater the risk of developing an asbestos-related disease will be. Generally, a latency period of 20 or more years of exposure is necessary to develop an asbestos-related illness. Although not an immediate health risk, worker education is necessary to minimize unwarranted exposure.

Dermal exposure to asbestos is not believed to produce dangerous or irreversible effect; still, protective clothing is universally recommended and used when working with or around asbestos. The purpose of protective clothing is to facilitate worker decontamination and prevent the spread of fibers outside the work area, thereby exposing other individuals.

Smoking can compound the harmful effects of asbestos exposure. For example, a person working with asbestos is five times more likely to contract lung cancer than a person who does not work with asbestos. A person who smokes is 10 times more likely to contract lung cancer than one who does not smoke. A person who works with asbestos and smokes is more than 50 times more likely to contract lung cancer than a person who does neither, known as a “synergistic effect.” Because of this synergistic effect, OSHA regulations require employers to provide information on smoking cessation programs to employees exposed above the OSHA PEL.

Exposure = Risk

Asbestos Exposure + Smoking = Risk of Illness

2-4. Prevention of Asbestos-Related Illness

Asbestos-related illnesses are preventable. Following this RIA AMP is an important step for preventing asbestos-related illnesses. The use of appropriate asbestos work practices, including combined administrative and engineering controls that require respiratory protection and protective clothing, reduces the risk of exposure to asbestos to negligible levels. Everyone must avoid uncontrolled disturbances of suspect and confirmed ACM and must be watchful for damaged suspect and confirmed ACM to protect personnel. Damaged suspect and confirmed ACM should be reported to the RIA ACO.

2-5. Cause and Effects of Damaged ACM

ACM can become damaged by human contact that includes the following:

Wear and deterioration of building finishes through years of normal use and accessibility

Maintenance or janitorial activities (scrubbing an ACM floor tile with an abrasive pad) without appropriate asbestos-control procedures

Grinding or sanding

Drilling or coring ACM for placement of electrical conduit or telephone or computer systems

Dragging or rolling heavy loads across flooring that is not designed to support the load

Vandalism

ACM can also become damaged by the following environmental exposures:

Air erosion

Water erosion from leaks through faulty roofing or piping, delaminating surfacing materials or piping insulation

Vibration erosion from mechanical equipment, fans, and traffic

Building construction, renovation, or demolition

Actions that damage or disturb ACM release airborne asbestos fibers, creating a potentially hazardous situation through increased exposure to asbestos fibers for employees and other personnel near the activity.

2-6. Asbestos Identification

Asbestos is identified using microscopic analytical techniques. The analytical method used is a function of the type of sample submitted for analysis, either bulk or air.

PLM, an analytical method established by the National Bureau of Standards (NBS), is used to analyze bulk samples. PLM involves using dispersion staining to distinguish between the different types of asbestos in a sample. Sensitivity of this method is one percent by weight (1,000 parts per million [ppm]), and leads to the definition of an ACM. A material that is found to contain asbestos in concentrations greater than 1 percent is defined by the USEPA as an ACM. The worker and employee notification and training must be implemented when a material that contains 1 percent or more asbestos is found in an area where workers or employees work. Analytical laboratories used to analyze asbestos samples must be accredited pursuant to Section 206(d) of TSCA. The PLM method for detection of asbestos in bulk samples has a detection limit of 1 percent. Quantification of asbestos in bulk samples at a level below 1 percent is not technically possible with a high degree of confidence when PLM is used.

Other analytical methods such as PLM point counting, TEM, and x-ray diffraction microscopy can be used to quantify a material below 0.1 percent. It is recommended for major renovation or demolition work that the TEM analytical method be used to quantify materials reported to contain less than 1 percent asbestos under PLM. The more accurate results achieved from the TEM analytical method at low levels can result in a significant savings in removal costs.

Air samples are analyzed using either phase contrast microscopy (PCM) or TEM. The sensitivity of PCM is limited, making asbestos fibers difficult to distinguish from non-asbestos fibers. The National Institute for Occupational Safety and Health (NIOSH) Method 7400 is used to analyze air samples by PCM. Any fiber with a length-to-width ratio of 3:1 is considered an asbestos fiber when using PCM. TEM is used to distinguish between asbestos and non-asbestos fibers. TEM can detect particles orders of magnitude smaller than are seen using light microscopes.

Air samples are collected to monitor airborne asbestos fibers levels in a work area. Samples are collected using personal monitoring pumps or larger-volume floor pumps. The samples are used to establish the respiratory protection requirements for workers. Air samples are also collected after a response action or abatement project to evaluate whether the work area has been adequately cleaned.

NIOSH Method 7400 is used to analyze both personal and clearance air samples.

CHAPTER 3

IMPLEMENTING AN INSTALLATION

ASBESTOS MANAGEMENT PLAN

3-1. Authority and Responsibility for the Rock Island Arsenal Asbestos

Management Plan

The following presents the roles and responsibilities of the AMT personnel in implementing the RIA AMP. Appendix A includes a flow chart (Figure 2) depicting protocols to be followed during an ACM or PACM disturbance during renovation/demolition activities or accident that created an emergency release.

Program Responsibility: The RIA Garrison Manager is responsible for the overall management of the AMP. The Garrison Manager will:

Establish an AMT and use the team to prepare, coordinate and execute the AMP in support of U.S. Army asbestos management policies.

Program and budget for adequate resources to execute effective asbestos management programs.

Appoint an ACO and alternate to ensure that the goals and objectives of the RIA asbestos policies are carried out.

Asbestos Management Team: The AMT prepares, coordinates, and executes the AMP to include:

Management of daily and long-range asbestos related actions.

Review proposed AMP changes prior to incorporation into the AMP.

Review changes in laws and regulations and their impact to the RIA facilities and AMP.

The AMT shall meet annually or as required and consist of personnel representing as a minimum the following:

(1) Engineering and Services Division

(2) Environmental Division

(3) Base Operations Personnel

(4) Safety Office

(5) Civilian Personnel Office

(6) Public Affairs Office

(7) Legal Service

(8) Contracting Office

(9) Joint Munitions and Technology Center (ad hoc)

Authority and Responsibility:

Director, Directorate of Public Works will:

(1) Organize and oversee the activities of the AMT, coordinating efforts and expertise of various personnel to maximize the effectiveness of asbestos control measures at RIA.

(2) Assume overall responsibilities and authority for asbestos related matters.

(3) Oversee the activities of the ACO.

Asbestos Control Officer (Chase Burns, IMRI-PWM-M, Ext. 2-0362) will:

(1) Report to the Directorate of Public Works on matters relating to the status of the RIA AMT and identify changes in U.S. Army, state, or federal statutes or regulations which would impact the program.

(2) Maintain and update the RIA Asbestos Building Surveys and installation-Wide Asbestos

Database after each facility survey, periodic inspection, and asbestos control actions.

(3) Sequence and prioritize asbestos control actions.

(4) Maintain current certification as an Asbestos Inspector, Management Planner, and Contractor Supervisor through training in an EPA-accredited course.

(5) Ensure that AMT members remain current with regulatory, scientific, technological, and engineering advances in their respective discipline.

(6) Review the RIA AMP annually or more frequently, as appropriate to determine compliance with the latest federal, state, local, and U.S. Army requirements. Recommend necessary changes to the AMT.

(7) Respond to reports of asbestos problems and coordinate with safety and industrial hygiene offices to determine appropriate control measures for reducing exposure potential.

(8) Arrange for analysis of bulk samples by an approved, NVLAP accredited laboratory using PLM or TEM as required.

(9) Coordinate emergency cleanup efforts in compliance with applicable laws and regulations.

(10) Ensure that appropriate personnel review design plans, contract specifications, and contracts for asbestos abatement activities on renovation, demolition, and building excessing processes.

(11) Conduct periodic surveys of asbestos projects to determine compliance with all applicable laws and regulations.

(12) Ensure that asbestos waste generated by abatement projects is properly documented and disposed of in an approved landfill.

(13) Coordinate a program to manage identified ACM in buildings until removal action occurs.

This program shall serve the following purposes:

To clean up asbestos fibers released during building use.

To minimize disturbance of or damage to ACM.

To prevent the release of asbestos fibers.

To periodically monitor the condition of ACM in buildings.

To inform building employees of the proper methods of working with and in the vicinity of

ACM.

Provide planning for O&M and abatement work.

(14) Ensure that annual asbestos training for RIA personnel involved in asbestos related operations is provided. Training shall comply with all federal, state, local, and U.S. Army requirements, including but not limited to 40 CFR Part 763.

(15) Ensure that proper notification of the intent to start an asbestos abatement or building demolition project is sent to state regulatory agencies. The notification shall be at least 10 days prior to the start of non-emergency projects. In cases of emergency, the IEPA/IDPH emergency notification procedures shall be followed (see Figure 2).

(16) Ensure that an analysis contract is in place with an IEPA-approved laboratory to expedite analysis of air and bulk asbestos samples, thereby minimizing potential work stoppage due to asbestos projects and asbestos hazardous situations. Credentials of the laboratory shall be current and shall be maintained on file.

(17) Ensure that all contract asbestos workers have been properly trained, certified, and licensed. Inspect contractor performance and immediately report discrepancies, deficiencies, and/or lack of performance to appropriate management personnel.

(18) Ensure that annual re-inspection of ACM areas is conducted and inspection results are forwarded to the Directorate of Public Works.

(19) Ensure that warning signs and containment barriers are in place around asbestos contact work.

(20) Forward copies of air testing results to the Industrial Hygiene Officer.

(21) Advise the Garrison Manager on asbestos-related matters.

(22) Ensure that the internal operating budget process includes requests for adequate funding of the projected asbestos program expenses.

(23) Serve as a liaison between RIA and regulatory agencies for asbestos activities.

(24) Ensure that trained and licensed base operations contractor personnel determine if ACM (friable or non-friable) will be disturbed during construction, repair, and maintenance activities. These activities include routine and emergency WOs, SOs, IJOs, and O&M activities.

(25) Ensure that a comprehensive Asbestos Survey and Inventory is conducted and updated annually.

Directorate of Public Works Designers (Architects, Engineers, Architectural & Engineering firms, Corps of Engineers, etc.) and Base Operations Estimators will:

(1) Prior to any work, compare Arsenal Support Program Initiatives (ASPI), Annual Work Plans (AWP), IJOs, Management Control Activities (MCA), SOs, and Task Order Contracts (TOC) maintenance/repair/construction project designs and scopes of work to existing asbestos survey information.

(2) Notify the ACO and Environmental Officer if ACM is expected to be present at a project site, type of asbestos material(s), and quantity in square footage or linear feet.

(3)…