Appendix_N_-_Asbestos_Mgmt_Plan.pdf

Contract No. FA2523-05-C-9001 FY-15

CDRL CEV-15A

ASBESTOS MANAGEMENT PLAN

Thule Air Base, Greenland

FINAL, FY-15

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629-3840 ext. 2698 Supersedes CDRL CEV-15A, FY-14

CDRL CEV-15A Asbestos Management Plan

Contract No. FA2523-05-C-9001 3 FY-15

TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

1.2 Regulatory Overview

2 REQUIREMENTS

2.1 Asbestos Program Manager

2.2 Asbestos Containing Material Inventory

2.3 Notification and education program

2.4 ACM surveillance

2.5 Work Control/Permit systems

2.6 Operation and Maintenance Work Practices

2.7 Recordkeeping of O&M Activities

2.8 Training Requirements

2.9 Prevention of the use of ACM in new construction

2.10 DoD Schools

3 DEMOLITION OR RENOVATION OF FACILITIES

4 PROJECTING PROCEDURES

4.1 Project prioritization

4.2 Regulatory Compliance

4.3 Monitoring During Contract Performance

4.4 Multi-organizational Worksites

5 TRANSPORTATION AND DISPOSAL

5.1 Asbestos waste disposal

5.2 Asbestos Transportation

5.3 Asbestos Landfill Operations

APPENDICES

APPENDIX 1: ASBESTOS INVENTORY

APPENDIX 2: FACILITY WARNING SIGNS

APPENDIX 3: ASBESTOS ASSESSMENT

APPENDIX 4: PROCEDURE FOR COMMUNICATION AND WORK CONTROL

APPENDIX 5: WORK PRACTICES

APPENDIX 6: THULE AB SIMPLIFIED MAP – ASBESTOS WASTE LANDFILL

APPENDIX 7: LIST OF ABBREVIATIONS

APPENDIX 8: DISTRIBUTION LIST

APPENDIX 9: 2014 REVIEW COMMENTS

Contract No. FA2523-05-C-9001 4 FY-15

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The title of this document is Asbestos Management Plan. The acronym AMP will be used throughout the document.

Classification: This document is unclassified.

Responsibilities: Greenland Contractors, Occupational Health & Safety (GC/OHS) is the office of primary responsibility for developing and maintaining the AMP. The instructions given in this plan are applicable to all organizations and tenant units at Thule AB. Organizations are authorized to extract and reproduce those sections of the AMP that are essential in the accomplishment of necessary planning and in the preparation of supporting documents and reports.

Reviews/Changes: The AMP will be reviewed and updated annually IAW the CDRL and distributed accordingly. A draft is submitted to the requiring office, 21 CES/CEIE, by 1 Nov for review. Review comments, if any, will be provided by 21 CES/CEIE within 60 days. Review comments received will be incorporated in the final version of the plan within 30 days; thereafter the document will be submitted to 821ABG/CC for signature. The signed plan will then be submitted as the Final edition.

Furthermore, the plan is subject to change if any of the applicable laws, regulations, or requirements are altered.

Distribution: The plan is distributed IAW the CDRL Summary distribution list.

1.2 Regulatory Overview

Thule AB: Final Governing Standards for Environmental Protection by United States Forces in Greenland (FGS-GL), Chapter 15.

Environmental, Safety, Occupational Health Council (ESOHC) decisions

Host Country: Greenlandic Working Environmental Authority has the jurisdiction concerning all working environmental issues affecting employees working for Greenlandic or Danish companies on TAB.

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2 REQUIREMENTS

2.1 Asbestos Program Manager

The installation must appoint an Asbestos Program Manager to serve as the single point of contact for all asbestos-related activities.

The OPR for the Asbestos Management Plan is also Asbestos Program Manager (GC Environmental Engineering, extension 2698). The appointment is confirmed through 821 ABG/CC signature of this plan.

The term Asbestos Program Officer (APO) can appear in other documents pertinent to asbestos.

The term reference the role of the Asbestos Program Manager.

2.2 Asbestos Containing Material Inventory

An inventory of Asbestos Containing Material (ACM) in active TAB facilities is maintained by GC/CE. The inventory is based on sampling and analysis, or in some cases, a visual determination.

The inventory is summarized in Appendix 1. The inventory is in the process of being transferred and updated from a dedicated database (ADAM) with historical survey information to current AUTOCAD files with as-built information.

Any changes to the Asbestos Containing Material inventory due to abatement, maintenance, renovation or demolition must be forwarded as as-built documentation to GC/CE.

2.3 Notification and education program

The notification and education program consists of the following elements and focuses on telling building occupants where potentially friable ACM is located, and how and why to avoid disturbing ACM.

Building Signs Signs are posted at the main entrance to buildings that contain ACM at Thule AB. The signs provide a total list of the ACM found in the building, and its location. If no ACM is present in the building there is no sign. The signs include brief warnings as well as points of contact for further information. An example of a sign is included in Appendix 2. Furthermore, additional notices are posted to remind personnel that they are obligated to take action when observations of damage to asbestos containing materials are made.

Asbestos Awareness Pamphlet The GC Occupational Health and Safety department distributes a pamphlet focusing on the health effects of asbestos, how to recognize asbestos, and how to act if you encounter asbestos. English and Danish versions of the Asbestos Awareness Pamphlet are available at the Thule AB Community Center or GC/OHS.

Newcomer Briefings Asbestos information is included in Arctic Start (presented by GC Environmental Engineering (GC/EE)) and GC Newcomer briefings.

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Asbestos Awareness Training Asbestos awareness training of employees engaged in routine maintenance work and custodial services. The training includes historical and background information on asbestos, how to recognize asbestos, how to react when encountering asbestos, education and personnel protection equipment requirements to work with asbestos, disposal regulations, signage, work practices and emergency procedures used when working with asbestos.

The awareness course is not a replacement for dedicated asbestos worker training which is required to work with asbestos at Thule AB.

2.4 ACM surveillance

Thermal insulation material is the most vulnerable type of Friable ACM to release airborne asbestos fibers due to wear and tear. Asbestos has been used for insulation purposes on a wide scale. Items which have been insulated include, but are not limited to: pipes, boilers, tanks, ducts and various other components of hot and cold water systems, heating and air conditioning (HVAC) systems.

The condition of ACM in boiler systems, mechanical rooms and HVAC systems is noted, assessed and documented as part of GCs preventive maintenance program. The surveillance frequency for these systems is variable but they are carried out at least annually.

Other Thermal Insulation, such as the material found on hot-water pipes, steam pipes and other items not included in the preventive maintenance program, will be assessed as part of mandatory safety rounds, performed by GC shop supported by GC/OHS. Furthermore, ACM condition is assessed as part of facility inspections in cold facilities carried out by GC/EE.

Other ACM may include floor tiles, mastic under floor tiles, ceiling tiles, roofing tiles, concrete pipes, outdoor siding and fabrics, and “fire wall” paneling (normally gray or white). The condition of such materials is monitored by Greenland Contractors as part of the facility baseline survey required by the Base Maintenance Contract.

Any potential changes in the condition of ACM observed during these inspections or as part of daily operation must be brought to the attention of GC/EE without delay.

GC/EE will assess the observation, collect samples as required and prioritize identified hazards for abatement. Furthermore, GC/EE will initiate emergency repairs or generate maintenance work orders as required. The procedure used to assess and prioritize is included in Appendix 3.

Friable ACM that cannot be reliably repaired or isolated must be removed when it poses a threat to release airborne fibers.

2.5 Work Control/Permit systems

Prior to any work involving ACM the Asbestos Program Manager and 821 SPTS/CEO must be informed. If there are no objections to the work proposed it is considered permitted.

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Access to work sites where ACM is handled must be restricted. Yellow-and-black Asbestos warning tape will be use to seal entrances.

A final clearance will be conducted using the National Institute for Occupational Safety and Health (NIOSH) Method 7400. Results will be obtained by analyzing samples by phase contrast microscopy (PCM). The analysis must be performed by qualified personnel. Whenever possible and IAW the BMC, clearance sample analysis should be conducted by personnel not otherwise involved with the abatement process.

The accepted value, for the final clearances measurement, is a result where the concentration of fibers for each sample is less than or equal to a limit of quantity for PCM 0.01 fibers per cubic centimeter (0.01f/cm3) of air. The clearance standards are determined IAW 40 CFR 763.80 to 763.95, Appendix A and Appendix E.

All results from air sampling are filed by GC/EE. For work in limited enclosures (bag method) no air sampling is required (unless a release is suspected).

Access restrictions can only lifted after successful air testing or after approval from the Asbestos Program Manager or designated person as a result of a walk-through inspection. DoD employees should not occupy or re-occupy abated area until clearance levels are acceptable IAW this plan. GC will provide a copy of clearance results to 21 CES/CEIE and 21 AMDS/SGPB upon request.

Greenland Contractors is using the procedures in Appendix 4 to ensure work control. Third party contractors will coordinate all work control through the Asbestos Program Manager, including the results of final clearance measurements and final approval by inspection.

2.6 Operation and Maintenance Work Practices

All operations and maintenance at Thule AB involving ACM will be performed IAW the work practices given in Appendix 5.

2.7 Recordkeeping of O&M Activities

GC/EE maintains a record of identified asbestos in the Asbestos Inventory (Section 2.2).

Maintenance job orders involving asbestos abatement are registered by Greenland Contractors.

Notification regarding the completion of such job orders must be forwarded to GC/EE.

2.8 Training Requirements

All personnel involved in asbestos related activities must maintain qualifications to carry out their duties safely including proficiencies for ACM condition assessment, sample collection and analytical methods. Educational backgrounds and experience are valid qualifications.

Asbestos workers must have documented special asbestos worker training approved by U.S. or Greenlandic Occupational Health authorities or a as a minimum a three day course in abatement and disposal techniques (repair, maintenance, encapsulation, enclosure and removal of ACM).

Transporting ACM waste is not considered work requiring any formal training. However, the GC P&G Supervisor must ensure that personnel working on the asbestos landfill have been sufficiently

Contract No. FA2523-05-C-9001 8 FY-15 instructed to carry out their duties safely, including the requirement to report mishaps resulting in torn waste bags or similar non-routine events to the Asbestos Program Manager and await instructions.

BMC personnel working with asbestos containing materials is protected under the Executive Asbestos Order No. 133 of 5 February 2010 issued by the Greenlandic authorities.

As a minimum, the Asbestos Program Manager and supervisors responsible for abatement projects must have the same qualifications as asbestos workers.

Maintenance Supervisors responsible for minor asbestos-related work as well as Employees engaged in routine (i.e. non-asbestos) maintenance work must receive Asbestos Awareness Training, a one-hour awareness course offered by GC/OHS. The training must be refreshed annually.

All employees in custodial services must receive the Asbestos Awareness once.

2.9 Prevention of the use of ACM in new construction

It is prohibited by law to use ACM in new construction. This applies to U.S., Danish and Greenlandic regulations equally. The use of ACM in new construction will be prevented through the project review process.

2.10 DoD Schools

DoD schools will comply with applicable requirements 15 U.S.C. 2643(l) and implementing regulations in 40 CFR Part 763, Subpart E.

There are currently no DoD schools on Thule AB.

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3 DEMOLITION OR RENOVATION OF FACILITIES

Before disturbing or demolishing a facility or part of a facility, all friable ACM, or ACM that is likely to become friable once disturbed during demolition, must be removed. Typically, this will involve consulting the ACM inventory (appendix 1) and conduct a survey/walkthrough of the facility. The results of any supplemental in-house or external analysis will be kept on permanent file in GC/EE.

Prior to demolition or renovation of a facility, a determination whether or not the activity will remove or disturb ACM will be made, and this determination will be recorded on the project authorization document (e.g. work order or project scope of work). A written assessment of any action that will disturb or remove friable asbestos will be prepared and furnished to the Asbestos Program Manager and the Installation Commander. Such assessments will be kept on permanent file in GC/EE.

The USAF point of contact is 821 SPTS/CEO.

GC/OHS and GC/EE will identify potential disturbances of ACM involved in work requests (AF Form 332 Civil Engineering Work Request) through participation in the Work Request Review Board (WRRB) coordination meetings.

The Base Civil Engineer (BCE, GC/CE) will coordinate all demolition projects with the Chief of Environmental Engineering (GC/EE).

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4 PROJECTING PROCEDURES

4.1 Project prioritization

The Facility Board is responsible for priority ranking of projects, including Asbestos abatement and demolition projects.

4.2 Regulatory Compliance

All contractors are responsible for compliance with all regulations governing their asbestos projects, including:

Regulations regarding safety and health.

Control of hazardous emissions.

Air sampling and analysis.

Proper labeling, posting and disposal.

Meeting the requirements for multi-organizational worksites in accordance with the AMP.

Asbestos training documentation and certifications.

Further, contractors, including the Base Maintenance Contractor, will also maintain documentation, demonstrating regulatory compliance according to contract with the building owner. The Asbestos Program Manager will obtain copies of all pertinent documentation required for permanent filing.

4.3 Monitoring During Contract Performance

Regardless of the provisions of the contract, the GC/EE office can perform asbestos sampling to ensure safety for all in-house base personnel groups at any time.

Occupational safety and health is the responsibility of the contractor, however, it is prohibited to allow unsafe conditions to exist on base facilities. Violations are to be immediately reported to the Asbestos Program Manager. The Asbestos Program Manager will coordinate further actions with 821 SPTS/CEO and 821 ABG/SE as appropriate.

It is the responsibility of the contractor to conduct any air sampling required during the project, including final clearance sampling. Final Clearance results must be made available to the Asbestos Program Manager who is authorized to request documentation on certification and/or technician qualifications for performing such clearances IAW section 2.5 of this plan. Furthermore, the Asbestos Program Manager will inspect the facility following any final clearances in order to verify the area is cleaned up properly.

4.4 Multi-organizational Worksites

On multi-organizational worksites, an organization performing work which requires the establishment of a regulated area must inform other on-site organizations of the nature of the work with asbestos and/or presumed ACM, including the existence of and requirements pertaining to regulated areas and measures taken to ensure personnel on-site are not exposed to asbestos.

The organization which creates or controls the source of asbestos contamination must abate asbestos hazards at a multi-organizational worksite.

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In addition, every organization having personnel who are exposed to asbestos hazards shall comply with applicable protective provisions.

On a daily basis, every organization having personnel working adjacent to regulated areas established by another organization on a multi-organizational worksite must take steps to ascertain the integrity of the enclosure and/or the effectiveness of the control method relied upon by the primary asbestos contractor to ensure that asbestos fibers do not migrate to such adjacent areas.

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5 TRANSPORTATION AND DISPOSAL

5.1 Asbestos waste disposal

All asbestos waste, including protective clothing, disposable respirators, brooms, wiping rags, vacuum filters, floor sweepings and thermal insulation material must be collected and double bagged in air-tight and puncture resistant disposal bags. During this collection, the ACM waste will be kept adequately wet. The bags will be labeled and decontaminated by HEPA vacuuming and wet wiping.

Storage containers holding asbestos waste will be labeled in English and the host nation languages: “DANGER – CONTAINS ASBESTOS FIBERS – AVOID CREATING DUST –

CANCER AND LUNG DISEASE HAZARD.”

Asbestos waste that is generated during the winter season must be stored in leak-tight containers until the end of the storm season. These containers will be labeled with warning signs and kept under padlock. If large amounts of asbestos waste is generated it will be at the DRMO yard. When the storm season ends, stored asbestos waste will be disposed as soon as practical.

5.2 Asbestos Transportation

Generators of asbestos waste are responsible for the transportation to the asbestos waste landfill.

In order to ensure that the asbestos waste is covered with soil, an appointment must be arranged with the Pavements & Grounds Supervisor or POC.

Prior to transportation, the employee who is transporting the asbestos waste must ensure it is properly contained in leak-tight containers with appropriate labels, and that the surface of the containers is not contaminated with asbestos debris adhering to the container.

If there is reason to believe that the condition of the asbestos waste may allow significant fiber release, the employee in charge of transporting it must not accept the waste for transport and disposal.

Once the employee transporting the asbestos waste is satisfied with the condition of the waste and agrees to handle it, the containers are loaded for transportation. Large amounts of asbestos waste (hot water generators, etc.) generated through in-house activities are transported to the asbestos waste landfill by Pavements & Grounds personnel. Large amounts of asbestos waste will be transported on a tractor-trailer and secured by means of straps.

Third-party contractors are responsible for transporting waste to the asbestos waste landfill and for ensuring the condition of the asbestos waste meets the above requirements. The third-party contractors must inform the GC Project Coordinator whenever asbestos waste is transported to the asbestos waste landfill and arrange for an appointment with the Pavements & Grounds Supervisor.

The employees in charge of transportation are responsible for ensuring the asbestos waste is sufficiently secured during transportation.

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5.3 Asbestos Landfill Operations

At Thule AB, an area for asbestos waste disposal has been established in a gravel pit between South Mountain and the abandoned D-launch site (a map is included in Appendix 6). The ACM disposal landfill is operated according to the directives in the agreement with the Greenland Authorities. The GC/OPS Manager has the overall responsibility for the proper disposal of asbestos waste at the asbestos waste landfill. GC/LGTT, Pavements & Grounds, performs registration and daily operation of the asbestos landfill.

The following operational procedures apply for the asbestos waste disposal area:

The asbestos waste disposal landfill will receive only asbestos waste.

Signs will be placed around the perimeter of the area, warning the public of the location and the potential associated dangers. The area is marked on base maps and records.

Only trained and appropriately protected personnel will accomplish placement of asbestos waste. At the end of each day where asbestos waste has been disposed in the landfill, it will be covered with 6-12 inches of soil.

The GC Pavements and Grounds Supervisor or POC must inspect the Asbestos Landfill every two weeks outside the storm season, or at the end of the working day, if new asbestos waste has been disposed of. GC/EE can conduct unannounced inspections at any time. Inspections must be documented.

During the winter, the soil will freeze and the asbestos waste cannot be covered as required in accordance with the Final Governing Standards. The asbestos waste landfill is therefore closed during the storm season from 15 September to 15 May. As soon as possible in the season, the asbestos waste will be properly disposed of in a designated landfill that meets the requirements of the FGS.

When permanently closed, the asbestos waste landfill will be covered with a 2-3 foot layer of soil over the entire area. Future maintenance of the landfill would then be turned over to Greenland in accordance with provisions of the Memorandum of Understanding.

Records must be kept of the amount of asbestos waste disposed of in the designated asbestos landfill. The record must include date, generator and estimated amount of disposed asbestos waste. Waste amount is an estimate, as there is no weight bridge at Thule AB. The waste includes building elements, on which the asbestos containing material is fixed on as part of the construction (tanks, rafters, pipes, floors etc.). The record will be maintained by the Pavement and Grounds supervisor and be available upon request.

Contract No. FA2523-05-C-9001 14 FY-15

APPENDICES

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APPENDIX 1: ASBESTOS INVENTORY

ACM can potentially be present in older facilities at Thule AB. The use of asbestos at Thule AB was abandoned in 1972. However, as most of the facilities were constructed during the period 1951-1970, asbestos still causes exposure problems in the daily operation at Thule AB, even though removal and small-scale abatement have been performed to some degree over the last decade.

The ADAM database is based on analysis results from a large survey conducted at TAB in 1993.

The samples analyzed were taken by experienced personnel from a private asbestos analysis laboratory, hired by GC, in order to find all possible sites for asbestos containing material at TAB. The ADAM database has been updated with observations and abatements performed since 1993. However, a major part of the available information is stored as drawings that cannot be modified within ADAM.

The inventory is therefore in the process of being transferred and updated to a different database (MDOC) and drawings updated with as-built information by GC/CE.

Thule Air Base – October 2014

Note that all hyphenated facility numbers also include all facility numbers in between these numbers.

Information for facilities marked with an asterisk (*) based on visual determination, construction year and/or as-built documentation. All other by analysis. On signs, the word "may" will be included in the absence of analysis results even though the information is very reliable (e.g. a facility constructed in FY13). For buildings not listed below, no reliable information exists. A walkthrough inspection may have been conducted and no thermal insulation materials found in a facility, and while this fulfills the FGS requirements of a visual inspection, this is not sufficient documentation to declare the facility free of asbestos without supporting documentation.

I: Asbestos Free Facilities:

Area & Fac. # 103* 107* 118*

Area & Fac. # 200* 206* 236*

555* 562* 564*

622* 631*

Area & Fac. # 780*

Area & Fac. # 937*

1105* 1117* 1118*

Area &

1391*

1701*

1951*

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II: Asbestos Contaminated Facilities:

Fac. # 98-99*

Area & Fac. # 104-106 112-117 121-127 131-135 142-145

205-206 211*-212 214-216 245-246 251-256

321-326 333-336 341-346 351-356 363*

Area & Fac. #

Area & Fac. # 569-571

604-606 623-624 628-630

Area & Fac. # 972* 974*

1090* 1091*

1128* 1190*

Area & Fac. #

Area & Fac. #

Area & Fac. # 4003* 4005* 4006* 4007* 4012* 4017*

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APPENDIX 2: FACILITY WARNING SIGNS

Signs are placed in asbestos contaminated buildings at or near the entrance. The purpose of these signs is to notify occupants and craftsmen regarding the risks associated with disturbing asbestos containing materials.

However, the typical yellow sign as shown below does not effectively communicate where the dangerous materials are located in the facility and if the material is potentially friable.

GC/EE is therefore in the process of changing all signs into more informative warnings. This ef-fort will continue throughout FY54 and until completed, both types of signs will be found on the base.

Asbestos sign in contaminated building (typical)

Below are examples of the improved information on the new signs. Note that facilities that have been confirmed free of asbestos will have no sign posted.

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Asbestos sign in contaminated building (example of new sign where the asbestos is not potentially friable)

Asbestos sign in contaminated building (example of new sign where the asbestos is potentially friable)

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APPENDIX 3: ASBESTOS ASSESSMENT

If ACM is damaged and presents a current hazard of exposure, the area in which it was found must be isolated and access must be restricted immediately. A response action will be selected from among the following: removal, encapsulation, enclosure, or other repair. For purposes of determining the least burdensome response action, local circumstances including occupancy and use patterns within the facility must be considered. A response action must be initiated as soon as possible.

The following flowchart outlines the criteria for assessing ACM and hazard.

Requester detect possible damaged abestos.

GC/EE is notified.

GC/EE will consult Asbestos Inventory and/ or assess the material physically

A material sample is needed

No asbestos is presentAsbestos is present

Work can continue undisturbed

Consult ’Potential ACM’ flowchart (Appendix 4)

Consult ’ACM confirmed’ flowchart

(Appendix 4)

Contract No. FA2523-05-C-9001 20 FY-15

Potential ACM

A material sample is needed

Is it possible to secure a representative material sample?

Is is possible to analyze the sample at Thule Air

Base?

GC/OEP decides if the sample is to be analyzed by an external lab

Does the sample contain asbestos?

Necessary precautions must be taken while waiting for the result

Yes No

YesNo

Result: Does the sample contain asbestos?

Inform GC/OEP and requester that work may continue as normal

Consult ’ACM confirmed’ flowchart

Yes

Yes

No

No

Asbest Program Manager and GC/OEP decide if the material should be treated as asbestos

APPENDIX 4: PROCEDURE FOR COMMUNICATION AND WORK CONTROL

The following checklist is used for work control and ensuring that communication to relevant of-fices is accomplished reliably and uniformly.

Contract No. FA2523-05-C-9001 21 FY-15

ACM Confirmed

GC/OHS contacts requester

Damage assessment:

Evacuation of building necessary?

Building occupants are relocated until area is Final Clearance IAW section 2.5 has been accomplished.

This action will be coordinated with the site manager of the affected personnel or 821 SPTS/CE in case military personnel are affected.

Asbestos Program Manager and GC/OEP decides how to best remove the asbestos

Asbestos Program Manager coordinates with 821 SPTS/CEO

Is a final clearance needed?

Perform air sampling IAW section 2.5

Is the amount of airborne fibres less than

0.01 f/ccm

The area must be cleaned again

No

Yes

No

No

Yes

Yes

Asbestos Program Manager releases area after final inspection.

Asbestos Inventory is updated as required.

Contract No. FA2523-05-C-9001 22 FY-15

APPENDIX 5: WORK PRACTICES

Repair Repair techniques should be considered where only minor damage was done to the ACM. Repair techniques for pipe and boiler insulation are often simple and have a low cost impact. Plastering of small damaged areas, around joints, valves, and flanges will easily restore the insulation. However, one should keep in mind that an encapsulation with sealant could in most cases be used instead of plastering.

Duct tape should not be used on damaged areas, as the tape does not seal the friable asbestos properly and since it is not heat resistant, it will eventually fall off, leaving the area even more damaged. By removing the tape, it is also a risk that the adhesive will pull off asbestos, producing a high level of airborne fibers.

GC/OHS has the authority to categorize required repairs as emergency repairs to be completed without delay.

Encapsulation Encapsulation is the treatment of ACM with a material that surrounds or embeds asbestos fibers in an adhesive matrix to prevent the release of fibers, as the encapsulation creates a membrane over the surface or penetrates the material and binds its components together to reduce the number of airborne fibers. The sealant should only be used on granular or cement materials and the encapsulated area must be able to withstand moderate impact, be flexible and flame resistant, resist deterioration over time and be non-toxic.

When performing the encapsulation, sealant will be applied twice with airless spray equipment.

Be aware of the condition of the ACM before applying sealant. Do not attempt to encapsulate ACM, which is delaminated, deteriorated or extensively damaged. If the ACM is delaminated, the additional weight of the sealant may pull down material. If deteriorated, the sealant will free ACM, and produce airborne fibers. If the ACM is extensively damaged, the sealant may not provide enough protection from further damage.

Enclosure Enclosure means sealing off an area containing asbestos to prevent human exposure. This can be done through construction of airtight ceilings and walls. Special techniques are utilized to prevent the potential release of asbestos fibers. Recommendations for constructing enclosures are listed below:

To minimize fiber release, drills or powered tools used during enclosure projects should be equipped with HEPA filters.

Due to the extra load of the enclosure, underlying structures must be able to support extra walls and ceilings.

New construction material should be impact resistant and assembled to be as air tight as possible. Gypsum panels must be taped at seams. Tongue and groove boards and boards with spline joints all qualify. Suspended ceilings with lay-in panels are not accepted. Joints between walls and ceilings must be caulked.

If lights are installed in ACM, they must be removed carefully to minimize fiber release.

Lights should be reinstalled beneath a new ceiling.

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Relocation of plumbing lines and computer cables, etc. may be necessary.

Maintaining a negative pressure inside the enclosure is recommended as a Best Management Practice.

Removal Removal is the process of taking out or stripping ACM in a predetermined way. Removal projects must be carefully planned to prevent the release of fibers, protect human health and the environment and to minimize damage to the structure being cleaned.

Special abatement methods for enclosure and removal projects:

Work area must be cleaned. Determine if removal project should include re-insulating or re-sound proofing with asbestos free materials.

Post warning signs or tape.

Shut down the Heating, Ventilating and Air Conditioning system (HVAC).

Seal off all vents and air ducts inside the area, with 2 layers of 6 mil polyethylene. Note that these should be left in place until the area has passed final inspection and air fiber clearance sampling.

Specific furniture and fixtures must be protected against contamination as described below:

Non-stationary items:

Clean/remove non-stationary items from the work area. All objects in the work area must be cleared, first vacuumed with a HEPA vacuum cleaner and then cleaned with amended water (water with wetting agent) or ordinary water. Non-stationary items should be moved from the area (e.g., desks, chairs, rugs and light fixtures). Drapes should be moved for dry cleaning or disposal.

Workers involved in the cleaning should at least wear a half mask, HEPA filter dual cartridge respirator, and disposable clothing.

Stationary items:

Cover and seal stationary items with 6 mil polyethylene. All items that cannot be moved from the work area (e.g., large pieces of machinery, black boards, water fountains, toilets) should be securely covered and sealed off with duct tape. Use of two layers of poly is a recommended practice.

Windows and doors:

Edges on windows and doors should be sealed off with at least 3" wide duct tape. After the edges have been taped, the windows should be covered and sealed with 6 mil poly and duct tape.

One entrance:

Choose a single entrance to the work area - most likely the entrance where the decontamination unit is located.

Extra entrances:

If there is more than one entrance, choose one of these as an emergency exit. This entrance should, however, also be covered and sealed off with poly and duct tape. Place a knife at the

Contract No. FA2523-05-C-9001 24 FY-15 inside of the poly for cutting the poly in an emergency situation. The exit must be clearly marked as an emergency exit.

Floors:

6 mil poly should be used to cover the floor in the work area. If necessary, several sheets are seamed together with spray adhesive and duct tape. To check the seam a chalk line (red or blue) is placed beneath the seam line. If water leaks during the project the seam line will change color.

The first layer of poly should extend 24” up the wall. When the first layer of poly has been secured in place, the walls are covered with poly and a second layer should be laid on the floor with the seams of the first and second layer offset. Note that the second layer should extend a few inches above the first layer. Also, note that potentially slippery spots (e.g., stairs and ramps) must be provided with some strips of duct tape or strips of thin wood on top of the poly.

Walls:

After the first layer of poly is placed on the floor, multiple layers of 4 mil poly are used to cover the walls. The 4 mil poly is lighter and is easier to hang and keep in place than the 6 mil poly. The poly should be hung from the top of the wall a few inches below the ceiling and should extend across the floor area until it meets in the center. Overlapping of the vertical sheets will be necessary and the seams should be sealed with duct tape.

Poly hanging from the top of walls is fairly heavy and during the project the poly will be exposed to different conditions, therefore duct tape alone cannot hold the poly in place. The sheets may be hung using a combination of nails and furring strips (small wood blocks), or adhesive and staples, and sealed with 4” duct tape.

Nails may cause minor damage to the interior finish. It is, however, more time efficient to repair the finish after a project than to repair fallen poly during a project.

Electrical System/Light Fixtures:

Locate and secure the electrical system. This includes identifying and de-energizing electrical circuits in the work area, locking the breaker box or parts of it going to the work area, placing a warning tag on the box, and supplying the work area with electricity from outside. If the electrical supply cannot be disconnected, insulate electrical parts or guard them from employee contact, other conductive objects, and water.

Light fixtures may have to be removed or detached and suspended to gain access to the ACM.

If light fixtures can be removed, it should be done after cleaning and wetting. If the fixtures cannot be removed, they should be wet down and covered with poly.

Miscellaneous

Install the proper number of negative air machines to ensure air renewal four times per hour.

The walls of poly plastic will bend visible inwards. Additionally smoke test may be used to confirm negative pressure in the room.

Contract No. FA2523-05-C-9001 25 FY-15

Provide the working area with scaffoldings.

Provide the decontamination unit to the designated entry.

If ripping or tearing of the poly occurs during the removal project, these must be repaired immediately with duct tape or adhesive sealant.

Mini Enclosure: The Glove Bag Procedure When smaller quantities of pipe and boiler insulation are to be removed, glove bags may be used as mini enclosures.

The following specifications apply:

Two persons are typically required to perform a glove bag removal. A third person may standby to help with tools and other equipment.

Glove bags used on elbows and other connections must be designed for this purpose and used without modifications.

Glove bags may be used only once and may not be moved.

Glove bags must not be used on surfaces where the temperature exceeds 150°F (65°C).

Before initiating the operation, loose and friable material adjacent to the glove bag operation must be wrapped and sealed in two layers of 6 mil plastic or otherwise rendered intact.

Glove bags are typically made of 3 to 12 mil polyethylene or polyvinyl.

The glove bag procedure can be performed as follows:

At least two persons are needed when performing glove bag removal operations.

Workers must use respirators with HEPA filters and disposable full-body suits when performing glove bag operations.

Mix the wetting agent and fill the sprayer.

Wrap 6 mil poly around the pipe, leaving the abatement area free. "Candy stripe" the poly with duct tape to fasten it. Do not apply duct tape directly onto the insulation surface, as this will tear up the insulation when pulled off.

Prepare the glove bag by following the manufacturers' instructions, as different glove bags have different mounting directions.

Place the necessary tools into the pouch located inside the glove bag.

Place the glove bag around the section of the pipe to be repaired. Seal pipe holes with duct tape on the pipe, which should already have been covered with poly.

Test the bag seal with a smoke tube by inserting the tube through the hole for the spray tip.

If the hole is not pre-made by the manufacturer, cut a hole in the bag, big enough to insert the spray tip, i.e., approximately 2 inches. Close the hole with your fingers and check for leaks on the glove bag. Leaks should be repaired with duct tape.

Insert the water spray tip in the hole and secure with duct tape.

Begin work by wetting the insulation properly.

After the work is carried out, spray tools thoroughly with water inside the bag.

Replace the water spray tip with the vacuum HEPA filter. Only vacuum until the bag collapses.

From outside the bag, pull the tools through the glove, turning the glove inside out. Twist the glove, and tape the twisted part so tools are separated from the bag. Cut the tools free, leaving the rest of the glove taped together. Note that rags and brushes used should be disposed of with the ACM.

With the removed ACM in the bottom of the bag, twist the bag and tape it. (Bag still on pipe) Slip a 6 mil disposal bag over the glove bag and loosen the glove bag at the pipe to let it slip into the disposal bag.

Contract No. FA2523-05-C-9001 26 FY-15

Twist the opening of the disposal bag and fold it (gooseneck style) and seal it with duct tape.

Clean the respirator with a damp cloth while still wearing the respirator.

Leave the work site and then remove the respirator.

A visual inspection should also be conducted before re-occupying the area. Air testing is only required if a mishap is suspected or confirmed.

Confining/Minimizing Airborne Fibers In the above sections, different methods of confining/minimizing ACM are presented. However, the importance of keeping a low number of airborne fibers during these work procedures should be noted. Measures to remember:

A thorough preparation of the work by all involved parties.

Use wet removal and negative air machines. Note that the supervisor should ensure asbestos waste is thoroughly wet down with amended water.

When ACM is removed it must be kept as damp as possible with a low-pressure water stream.

Waste should be double-bagged in 6 mil poly bags, marked with the label.

Other proper waste handling considerations:

ACM waste must always be handled in a careful manner.

Segregate sharp metal objects from waste as these can puncture the bags.

Remove excess air from the bags before sealing them with duct tape.

Minor Fiber Release Episode In the event of a minor fiber release episode (i.e., the falling or dislodging of 3 square or linear feet or less of friable ACM) the following control methods apply:

Thoroughly saturate the debris using wet methods (amended water).

Clean the area, use protective clothing, HEPA-vacuums, mini-enclosures, or glove bags, as necessary, to inhibit the spread of any released fibers.

Place the wetted asbestos debris in a sealed, leak-tight container.

Repair the area of damaged ACM, or immediately have the appropriate response action implemented.

Major Fiber Release Episode In the event of a major fiber release episode (i.e., the falling or dislodging of more than 3 square or linear feet of friable ACM), the following control methods apply:

Restrict entry into the area and post signs to prevent entry by persons other than those necessary to perform the response action.

Temporarily shut off the air-handling system (for modification) to prevent the distribution of fibers to other areas in the building.

The response action must be designed by the AOO or another person, who is sufficiently trained to design response actions.

Asbestos Abatement Equipment Equipment specifications to detail the performance requirements of units such as negative air filtration units, respirators and associated compressed air systems, protective clothing and safety equipment such as foot wear, hard hats, and eye protection is the responsibility of the assigned supervisor prior to any asbestos response action.

Contract No. FA2523-05-C-9001 27 FY-15

APPENDIX 6: THULE AB SIMPLIFIED MAP – ASBESTOS WASTE LANDFILL

Contract No. FA2523-05-C-9001 28 FY-15

APPENDIX 7: LIST OF ABBREVIATIONS

821 ABG 821st Air Base Group AB Air Base ACM Asbestos Containing Material AFB Air Force Base AFI Air Force Instruction AMP Asbestos Management Plan APO Asbestos Program Officer BCE Base Civil Engineer BLDG Building CDRL Contract Data Requirements List CE Civil Engineering CEIE Environmental Management (of 21st Space Wing Civil Engineering Squadron) CFR Code of Federal Regulations DET Detachment DoD Department of Defense ECD Estimated Completion Date EE Environmental Engineering EPA Environmental Protection Agency ESOHC Environmental, Safety, Occupational Health Council FGS Final Governing Standards FY Fiscal Year GC Greenland Contractors IAW In Accordance With OHS Occupational Health & Safety OSHA Occupational Safety and Health Administration PPE Personal Protective Equipment SG Surgeon General SOW Statement of Work

Contract No. FA2523-05-C-9001 29 FY-15

APPENDIX 8: DISTRIBUTION LIST

The PDF document is distributed via email IAW CDRL Summary list.

Distributed in PDF format

21 Space Wing Civil Engineering Squadron

21 CES/CEIE

21 SW/PMD

donald.chase@us.af.mil

21sw.pmd.thule@us.af.mil

821 Air Base Group 821 ABG/CC Commander

821SPTS.cc.wf@us.af.mil

821 Support Squadron 821 SPTS/CE Flight Commander

821SPTSCEDISTRO@US.AF.MIL

Greenland Contractors, Thule Air Base All GC organizations (on GC LAN) GC Intranet

Contract No. FA2523-05-C-9001 30 FY-15

APPENDIX 9: 2014 REVIEW COMMENTS