Appendix I - Asbestos Management Plan.pdf

Contract No. FA2523-15-C-0001 Supersedes A067 (1 Dec 17) Asbestos Management Plan.

1 May 2023

A067 ASBESTOS MANAGEMENT PLAN

Pituffik Space Base, Greenland

A067 Asbestos Management Plan

Supersedes A067 (1 Dec 17) Asbestos Management Plan.

2 1 May 2023

INSTALLATION IMPLEMENTING INSTRUCTION

Date: This plan is considered a draft, until approval by the Installation Commander and Peterson ESOHC.

Requiring Office: 21 CES/CEIE

OPR: Vectrus Services, Environment Safety and Health (VS/ESH)

Subject: Asbestos Management Plan (AMP).

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

Purpose: To implement an Asbestos Management Plan for Pituffik Space Base (Pituffik SB), Greenland.

Discussion: The Asbestos Management Plan provides procedures and guidelines to ensure continuity of operations and criteria to control and abate threats to human health and the environment from asbestos and describes management of asbestos during removal and disposal. Policy requirements for a comprehensive Occupational Health and Safety program are not covered by this plan.

Applicability: The requirements of this plan apply to all base operations.

Approved by:

Rasmus Mouridsen Vectrus Services Environmental specialist

David D. Schoenhardt, Lt Col, USAF, P.E.

Commander, 821st Support Squadron

Supersedes A067 (1 Dec 17) Asbestos Management Plan.

3 1 May 2023

TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

1.2 Regulatory requirements

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 ASBESTOS INFORMATION SIGNS

APPENDIX 3: ASBESTOS ASSESSMENT

APPENDIX 4: PROCEDURE FOR COMMUNICATION AND WORK CONTROL

APPENDIX 5: WORK PRACTICES

APPENDIX 6: PITUFFIK SB SIMPLIFIED MAP – ASBESTOS WASTE LANDFILL

APPENDIX 7: ASBESTOS AWARENESS PAMPHLET

APPENDIX 8: LIST OF ABBREVIATIONS

APPENDIX 9: SUMMARY OF CHANGES TO THE ASBESTOS MANAGEMENT PLAN 31

4 1 May 2023

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: Vectrus Services, Environment Safety and Health (VS/ESH) 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 Pituffik SB. 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: This plan is updated within 30 days of changes occurring.

Distribution: The Final plan is distributed IAW the Deliverable distribution list, to tenant units, US/Danish Contractors and other organizations performing work at Pituffik SB.

1.2 Regulatory requirements

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

40 CFR 763.80 to 763.95, Appendix A and Appendix E (clearance standards).

AFI 32-1001 Civil Engineer Operations.

AFMAN 32-7002 Environmental Compliance and Pollution Prevention.

The Greenlandic Working Environment Authority (GWEA) has the jurisdiction concerning all working environmental issues affecting employees working for Greenlandic or Danish companies on Pituffik SB.

5 1 May 2023

2 REQUIREMENTS

2.1 Asbestos Program Manager

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

The APM is the Base Civil Engineer. The Civil Engineering (VS/CE) is responsible for facility ACM and work order documentation and record keeping. Environment, Safety and Health (VS/ESH) is responsible for the notification and educational program and ACM surveillance.

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

The term references the role of the APM.

2.2 Asbestos Containing Material Inventory

An inventory of Asbestos Containing Material (ACM) in active Pituffik SB facilities is maintained by the Base Maintenance Contractor (BMC). 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 based on information from a database (ADAM) with historical survey information and from current AUTOCAD files with as-built information.

The infrastructure surveyed in Appendix 1 covers 171 of the 176 buildings in the Pituffik SB Facility Inventory. ACM knowledge concerning the remaining five buildings is absent. A comprehensive base-wide update of the 30-year-old survey is recommended.

Any changes to the ACM inventory due to abatement, maintenance, renovation, or demolition must be forwarded as as-built documentation to BMC Civil Engineering.

2.3 Notification and education program

The Pituffik SB notification and education program consists of the following elements and focuses on informing building occupants where potentially friable ACM may be located, and how and why to avoid disturbing ACM.

Building Signs Signs are posted at the main entrance to buildings that contain ACM. 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. Additional notices are posted to remind personnel that they are obligated to act when observations of damage to asbestos containing materials are made.

Asbestos Awareness Pamphlet The BMC, Environment, Safety and Health (ESH) 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 Pituffik SB

6 1 May 2023

Community Center and ESH and included in Appendix 7 (English version only). Asbestos awareness in also included in the Pituffik-specific ESH-pamphlet for new arrivals included in the BMC personnel Newcomer introduction package.

Asbestos Awareness Training Asbestos awareness training is required for BMC 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 protective equipment requirements to work with asbestos, disposal regulations, signage, work practices, and emergency procedures used when working with asbestos.

The awareness training is not a replacement for dedicated asbestos worker training (Section 2.8) which is required to work with asbestos at Pituffik SB.

ESH has developed Pituffik specific training material in Danish and conduct asbestos awareness training in Danish and English for BMC personnel. Pituffik specific asbestos awareness training for all personnel is also available through The Environmental Awareness Course Hub (TEACH) site https://usaf.learningbuilder.com/.

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 ACM condition on boiler systems, mechanical rooms, and HVAC systems is noted, assessed, and documented on a continuous basis including thermal insulation materials found on steam- and hot-water pipes throughout the base.

ACM may also be included in floor tiles, mastic under floor tiles, ceiling tiles, roofing tiles, concrete pipes, outdoor siding, and fabrics, and “fire wall” paneling (normally gray or white). Their condition is monitored by the BMC.

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 the APM without delay.

The ESH will assess the observation, collect samples as required and ship for external verification, and then prioritize identified hazards for abatement, i.e., 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.

https://usaf.learningbuilder.com/account/login/?ReturnUrl=%2f

7 1 May 2023

2.5 Work Control/Permit systems

Prior to any work involving ACM the APM, the facility manager, and the 821 SPTS/CEO must be informed. If no objections to the work are proposed the work is considered permitted. Prior to work initiation, the GWEA must be informed according with Executive Asbestos Order No. 133 of 5 February 2010 issued by the GWEA (in Danish only).

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

Final clearances 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 micros-copy (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 clearance measurement, is a concentration of fibers for each sample 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 the APM office. For work in limited enclosures (glove bag procedure; Appendix 5) air sampling is not required (unless a release is suspected).

Access restrictions can only be lifted after successful air testing or after approval from the APM or designated person based on a walk-through inspection. DoD employees should not occupy or re-occupy abated area until clearance levels are acceptable IAW this plan. APM will provide a copy of clearance results to 21 CES/CEIE upon request.

The BMC is using the procedures in Appendix 4 to ensure work control. Third party contractors will coordinate all work control through the APM, including the results of final clearance measurements and are subject to final approval by inspection by the APM.

2.6 Operation and Maintenance Work Practices

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

2.7 Recordkeeping of O&M Activities

The APM office maintains permanent records of identified asbestos in the Asbestos Inventory (Section 2.2).

Maintenance job orders involving asbestos abatement are registered by the BMC. Notification regarding the completion of such job orders must be forwarded to the APM office.

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

8 1 May 2023 methods. BMC asbestos workers must have documented special asbestos worker training approved according to current legislation by GWEA that include 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 BMC Pavement & Grounds Supervisor must ensure that personnel working on the asbestos landfill have been sufficiently 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 APM and await instructions.

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

The APM and supervisors responsible for abatement projects must, to the extent possible, have the same qualifications as asbestos workers.

In addition, the APM, custodial and maintenance staff shall receive asbestos awareness training.

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.

No DoD schools, family housing, or Child Development Centers are located on Pituffik SB.

9 1 May 2023

3 DEMOLITION OR RENOVATION OF FACILITIES

Before disturbing or demolishing a facility or part of a facility, all friable ACM, or ACM likely to become friable once disturbed during demolition, must be removed. Typically, removal will involve consulting the ACM inventory (Appendix 1) and conduct a survey/walkthrough of the facility. The results of any supplemental asbestos analysis will be kept on permanent file in the project documentation and by ESH.

Prior to demolition or renovation of a facility, a determination whether 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 APM and the Installation Commander. Such assessments will be kept on permanent file by the APM and ESH.

The USSF point of contact is 821 SPTS/CEO.

The BMC will identify potential disturbances of ACM involved in work requests (AF Form 332 Civil Engineering Work Request) through the Work Request Review Board (WRRB) review process.

All demolition projects will be coordinated by the Base Civil Engineer.

10 1 May 2023

4 PROJECTING PROCEDURES

4.1 Project prioritization

The 821 SBG 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.

• Record keeping

Furthermore, contractors, including the BMC, will also maintain documentation of real property records on all demolition and renovation projects of facilities with known asbestos-containing materials, demonstrating regulatory compliance according to contract with the building owner. Among other this includes information about disposal site, air sample collector personnel, analyzing laboratory, asbestos personnel training certification, surveillance personnel, operations, and maintenance activities, and in the event of major asbestos activity. The APM will obtain copies of all pertinent documentation required for permanent filing.

4.3 Monitoring During Contract Performance

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

It is prohibited to allow unsafe conditions to exist on base facilities. Violations are to be immediately reported to the APM. The APM will coordinate further actions with 821 SPTS/CEO and 821 SBG/SE as appropriate.

It is the responsibility of the contractor to conduct any air sampling required during a project, including final clearance sampling. Samling must be conducted by a qualified person (UFM) and final clearance approved by the AMP. Final Clearance results must be made available to the APM 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 APM will inspect the facility following any final clearances 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.

11 1 May 2023

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

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 asbestos fibers do not migrate to such adjacent areas.

12 1 May 2023

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 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. 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.

To ensure the asbestos waste is covered with soil, an appointment must be arranged with the BMC 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 the surface of the containers is not contaminated with asbestos debris adhering to the container.

If there is reason to believe 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 BMC 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 VS 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.

5.3 Asbestos Landfill Operations

At Pituffik SB, 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

13 1 May 2023

Authorities. The BMC Operations Manager has the overall responsibility for the proper disposal of asbestos waste at the asbestos waste landfill. The BMC Pavements & Grounds section 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 BMC 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. Documented, unannounced inspections will be conducted by ESH. Deficiencies will be corrected immediately.

• 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. During closure and post-closure operations, installations will prepare a written Closure Plan, to include a 5-year monitoring and maintenance activities.

• 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 Pituffik SB.

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 BMC Pavement and Grounds supervisor and be available upon request.

14 1 May 2023

APPENDICES

15 1 May 2023

APPENDIX 1: ASBESTOS INVENTORY

Asbestos containing material (ACM) can potentially be present in older facilities at Pituffik SB. The use of asbestos at Pituffik SB 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, even though removal and small-scale abatement have been performed to some degree.

The ADAM database is based on analysis results from a large survey conducted at Pituffik SB (Thule Air Base) in 1993. The samples analyzed were taken by experienced personnel from a private asbestos analysis laboratory, hired by Greenland Contractors (the BMC at the time), to find all possible sites for asbestos containing material at Pituffik SB. 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 ADAM inventory was transferred and updated to a new database (MDOC) and drawings updated to AUTOCAD files with as-built information by the BMC Engineering section.

Currently the Pituffik SB facility inventory constitute of 495 facilities. This include 176 buildings of which 171 are included in the ADAM and MDOC database (see below). ACM knowledge concerning the remaining five buildings is absent. A comprehensive base-wide update of the 30-year-old survey is recommended

The distribution of asbestos free and asbestos containing facilities on Pituffik SB as of May 2023 are listed below.

Information for facilities marked with an asterisk (*) are based on visual determination, construction year and/or as-built documentation. Information for the remaining unmarked facilities is obtained by sample analysis. On facility information signs (Appendix 2 in the APM), the word "may" is included in the absence of analysis results even though the information available is very reliable (e.g., a facility constructed in FY15). For buildings not listed below, no reliable information exists.

A walkthrough inspection may have been conducted and no thermal insulation materials (potential friable ACM) found in a facility, and while this fulfills the regulatory 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. # 97*

Area & Fac. # 101-103* 107* 118*

Fac. # 200* 206* 236*

555* 562* 564*

622* 631*

Area & Fac. # 780*

Area & Fac. # 937*

1105* 1117* 1118*

Area &

1391*

1412*

1701*

16 1 May 2023

1951*

II: Asbestos Containing Facilities:

Fac. # 98-99*

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

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

972* 974*

1090* 1091*

1128* 1190*

Area & Fac. #

Area & Fac. #

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

17 1 May 2023

APPENDIX 2: FACILITY ASBESTOS INFORMATION SIGNS

Facilities containing asbestos will have information/warning signs at the entrance. Signs serve as an information to the workers who perform facility repair and maintenance.

Below are examples of the information signs placed in asbestos containing 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.

Danger signs are used to emphasize the presence of friable asbestos materials. Note that build-ings confirmed to be free of asbestos will not have any sign posted.

If obsolete yellow asbestos information signs are encountered on Pituffik SB if must reported to ESH for replacement.

Example of asbestos information sign in building with non-friable asbestos (no danger symbol).

Example of asbestos information sign in building with friable asbestos (with danger symbol).

18 1 May 2023

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 repair action will be selected from among the following: removal, encapsulation, enclosure, or other. 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.

19 1 May 2023

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.

20 1 May 2023

21 1 May 2023

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.

Environment, Safety and Health 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 airtight 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.

22 1 May 2023

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:

23 1 May 2023

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 inside of the poly for cutting the poly in an emergency. 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.

24 1 May 2023

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:

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:

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.

25 1 May 2023

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.

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.

26 1 May 2023

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 project supervisor 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 footwear, hard hats, and eye protection is the responsibility of the assigned supervisor prior to any asbestos response action.

27 1 May 2023

APPENDIX 6: PITUFFIK SB SIMPLIFIED MAP – ASBESTOS WASTE LANDFILL

APPENDIX 7: ASBESTOS AWARENESS PAMPHLET

30 1 May 2023

APPENDIX 8: LIST OF ABBREVIATIONS

21 CES/CEIE Environmental Management (of 21st Space Wing Civil Engineering Squadron) 821 SBG 821st Space Base Group ACM Asbestos Containing Material AFI Air Force Instruction AMP Asbestos Management Plan APM Asbestos Program Manager APO Asbestos Program Officer BCE Base Civil Engineer BMC Base Maintenance Contractor CE Civil Engineering CFR Code of Federal Regulations DoD Department of Defense EPA Environmental Protection Agency ESH Environment, Safety and Health ESOHC Environmental, Safety, Occupational Health Council FGS Final Governing Standards FY Fiscal Year GWEA Greenland Working Environment Authority HEPA High-Efficiency Particulate Air IAW In Accordance With OSHA Occupational Safety and Health Administration PPE Personal Protective Equipment PWS Performance Work Statement SB Space Base VS Vectrus Services USAF United States Air Force USSF United States Space Force

31 1 May 2023

APPENDIX 9: SUMMARY OF CHANGES TO THE ASBESTOS MANAGEMENT PLAN

(From A067 (1 Dec 17) Asbestos Management Plan).

• Throughout document: Names and acronyms changed throughout document to reflect name change to Pituffik Space Base from Thule Air Base on 6 Apr 2023.

• Throughout document: Names and acronyms changed throughout document to reflect mis-sion organization within United States Space Force.

• Throughout document: The Asbestos Program Manager (APM) is changed to the Base Civil engineer (VS/CE) from the Environmental Engineering (VS/CE)

• Chapter 1.2 – Revised, text added: AFI 32-1001 Civil Engineer Operations, AFMAN 32- 7002 Environmental Compliance and Pollution Prevention.

• Chapter 2.1 – Revise, text added: The APM is the Base Civil Engineer. The Civil Engineering (VS/CE) is responsible for facility ACM and work order documentation and record keeping.

Environment, Safety and Health (VS/ESH) is responsible for the notification and educational program and ACM surveillance.

• Chapter 2.2 –Revised, text added: The inventory is summarized in Appendix 1. The inven-tory is based on information from a database (ADAM) with historical survey information and current AUTOCAD files with as-built information. The infrastructure surveyed in Appendix 1 covers 171 of the 176 buildings in the Pituffik SB Facility Inventory. ACM knowledge concern-ing the remaining five buildings is absent. A comprehensive base-wide update of the 30-year-old survey is recommended.

• Chapter 2.3 – Revised, text added: Building Signs - Asbestos awareness in also included in the Pituffik-specific ESH-pamphlet for new arrivals included in the BMC personnel Newcomer introduction package. Asbestos Awareness Training - ESH has developed Pituffik specific training material in Danish and conduct asbestos awareness training in Danish and English for BMC personnel. Pituffik specific asbestos awareness training for all personnel is also available through The Environmental Awareness Course Hub (TEACH) site https://usaf.learn-ingbuilder.com/.

• Chapter 2.4 – Revised, text consolidated: The ACM condition on boiler systems, mechanical rooms, and HVAC systems is noted, assessed, and documented on a continuous basis includ-ing thermal insulation materials found on steam- and hot-water pipes throughout the base.

ACM may also be included in floor tiles, mastic under floor tiles, ceiling tiles, roofing tiles, con-crete pipes, outdoor siding, and fabrics, and “fire wall” paneling (normally gray or white). Their condition is monitored by the BMC.

• Chapter 2.5 – Revised, text added: Prior to work initiation, the GWEA must be informed ac-cording with Executive Asbestos Order No. 133 of 5 February 2010 issued by the GWEA (in Danish only). For work in limited enclosures (glove bag procedure; Appendix 5) air sampling is not required (unless a release is suspected).

• Chapter 2.8 – Revised: BMC asbestos workers must have documented special asbestos worker training approved according to current legislation by GWEA that include abatement and disposal techniques (repair, maintenance, encapsulation, enclosure, and removal of ACM).

BMC personnel working with asbestos containing materials are protected under the Executive Asbestos Order No. 133 of 5 February 2010 issued by the GWEA. The APM and supervisors responsible for abatement projects must, to the extent possible, have the same qualifications as asbestos workers.

In addition, the APM, custodial and maintenance staff shall receive asbestos awareness train-ing.

• Chapter 3 – Revised: The results of any supplemental asbestos analysis will be kept on per-manent file in the project documentation and by ESH. All demolition projects will be coordi-nated by the Base Civil Engineer.

32 1 May 2023

• Chapter 4.2 – Revised, text added: “Record keeping” added to compliance list. Text added:

Furthermore, contractors, including the BMC, will also maintain documentation of real property records on all demolition and renovation projects of facilities with known asbestos-containing materials, demonstrating regulatory compliance according to contract with the building owner.

Among other this includes information about disposal site, air sample collector personnel, ana-lyzing laboratory, asbestos personnel training certification, surveillance personnel, operations, and maintenance activities, and in the event of major asbestos activity.

• Chapter 4.3 – Revised, text added: Samling must be conducted by a qualified person (UFM) and final clearance approved by the AMP.

• Chapter 5.3 – Revised: When permanently closed, the asbestos waste landfill will be covered with a 2–3-foot layer of soil over the entire area. During closure and post-closure operations, in-stallations will prepare a written Closure Plan, to include a 5-year monitoring and maintenance activities.

• Appendix 1 – Revised: Text amended, and Inventory Tables updated.

• Appendix 2 – Revised: Figure descriptions amended.

• Appendix 7 – New: Asbestos Awareness Pamphlet.

• Appendix 9 – New: Summary of changes to the Asbestos Management Plan.