Asbestos_Management_Plan.PDF

ASBESTOS MANAGEMENT PLAN

TENNESSEE AIR NATIONAL GUARD

MCGHEE TYSON, TENNESSEE

September 2014

RECORD OF REVIEW

The AMP should be reviewed bi-annually by the EMO. The Record of bi-annual review provides a mechanism for documenting when, and by whom, the review was conducted.

Date Of Review Date Posted Name/Office

August 2013 August 29, 2013 K. Grayson/EMO

September 2014 September 8, 2014 J. Carley/EMO

RECORD OF CHANGE/CORRECTION

The Record of Change provides a mechanism for recording changes made to the AMP as a result of the Bi-Annual Review or when a regulatory, operational, or policy change occurs. The record includes the name of the person responsible for entering the change, the date the change became effective, and the change number and/or applicable section in the SWMP where the change was made.

Number/Change Date Posted Name/Office

2014/Demo B241 20140731 Jack Carley/CEV

2014/Abate B100 20131001 Jack Carley/CEV

2014/Abate B262 20121106 Jack Carley/CEV

134th ARW McGhee Tyson ANGB Asbestos Management Plan September 2014

September 8, 2014 3

BASE SPECIFIC CONTACTS

The following list provides emergency phone numbers for personnel who may be required to furnish assistance in case of an emergency.

Contact: Phone #

Base Commander 865-336-4080

Vice Wing Commander 865-336-3444

Support Group Commander 865-336-3204

Installation Emergency Coordinator (Command Post) 911

Base Fire Department 911

Security Police 911

Base Clinic 865-336-4275

Base Civil Engineer (BCE) 865-336-4213

Environmental Management Officer (EMO) 865-336-4256

State Environmental Protection Specialist 865-336-4020

September 8, 2014 4

1.0 INTRODUCTION

1.1 Overview

1.2 Objectives

1.3 Background

1.4 Organizational Roles and Responsibilities

2 ASBESTOS MANAGEMENT PLAN

2.1 Asbestos Survey

2.1.1 Identification of ACM

2.1.2 Surfacing Materials no less than:

2.1.3 Thermal System Insulation

2.2 Hazard Assessment

2.3 Asbestos Register

2.4 Monitoring and Surveillance:

2.5 Scheduling and Planning:

2.6 Information Dissemination:

3 ASBESTOS OPERATION PLAN (AOP)

3.1 Introduction

3.2 Work Control Procedures

3.3 Awareness Training & Precautionary Measures

3.4 In-house abatement

3.4.1 General

3.4.2 Training Requirements

3.4.3 Respiratory Protection

3.4.4 Medical Surveillance

3.4.5 Abatement Equipment and Supplies

3.4.6 Air Monitoring

3.4.7 Record Keeping

3.4.8 Abatement Alternatives

3.4.9 Abatement Procedures

3.4.12 Emergency Asbestos Operations

3.4.11 Transportation and Disposal

3.5 Contract Abatement

3.5.1 General

3.5.2 Contract Abatement

4.0 FACILITY LIST

5.0 ASBESTOS REGISTER

6.0 LABORATORY RESULTS

7.0 PREVIOUS FACILITY DATA

8.0 FACILITY DRAWINGS

9.0 CERTIFICATIONS

Appendix A - References

Appendix B - Glossary

1.0 INTRODUCTION

Environmental Consulting & Testing, LLC (ECT) conducted an asbestos survey and created an

Asbestos Management Plan (AMP) which includes supplements from the previous Asbestos

Management Plan. The survey covered a total of 66 buildings and facilities with 252 samples obtained and analyzed as outlined herein.

Our survey and review is in accordance with industry standards and contains elements described in the U.S. Environmental Protection Agency (EPA) Rule, 40 Code of Federal

Regulations (CFR), Part 763, Air Force Instruction (AFI) 32-1052, Tennessee Code Annotated

(TCA) Chapter 1200-3-1 through Chapter 1200-3-37, and the National Emission Standard for

Hazardous Air Pollutants (NESHAP), Asbestos Construction Standards 29 CFR 1926.1101. This

AMP was developed by an EPA-accredited management planner and Inspector and State of

Tennessee Licensed Inspector and Management Planner.

This AMP contains inserts from the previously collected data for purposes of organization, inclusion, and ease of informational dissemination.

The following is required for completion of this document:

The activities of any persons, who perform inspections, re-inspections, and periodic surveillance, develop and update management plans, and develop and implement response actions, including operations and maintenance, are carried out in accordance with OSHA 29 CFR

1926.1101 and other Federal and State regulations and requirements.

All custodial and maintenance employees are properly trained as required and all other applicable Federal and State regulations (e.g., the Occupational Safety and Health

Administration Asbestos Standard for Construction, the EPA Worker Protection Rule or applicable State regulations).

All workers and building occupants are informed at least once each calendar year about inspections, response actions, and post-response action activities, including periodic re-inspection and surveillance activities, that are planned or in progress.

All short-term workers (e.g., telephone repair workers, utility workers, or exterminators) who may come in contact with asbestos are provided information regarding the locations of asbestos-containing materials (ACM).

All warning labels are posted in accordance applicable Federal and State regulations.

All management plans are available for inspection and notification of such availability has been provided as specified in the applicable Federal and State regulations.

The undersigned person designated by the BCE has received adequate training as stipulated in applicable Federal and State regulations.

http://www.epa.gov/asbestos/pubs/2003pt763.pdf AFI%2032-1052.pdf http://www.lexisnexis.com/hottopics/tncode/ http://www.epa.gov/compliance/monitoring/programs/caa/neshaps.html 29%20CFR%201926.1101.pdf 29%20CFR%201926.1101.pdf 29%20CFR%201926.1101.pdf

September 8, 2014 6

Government has and will consider whether any conflict of interest may arise from the interrelationship between the Management Planner and other accredited persons performing asbestos activities.

1.1 Overview

The survey and AMP covers a total of 66 buildings and facilities. Air Force Instruction (AFI) 32-

1052, Facility Asbestos Management outlines procedures for developing a base asbestos management program. The base asbestos management program consists of an Asbestos

Management Plan (AMP) and an Asbestos Operation Plan (AOP).

1.2 Objectives

The overall objective of the asbestos management program is to ensure that the health and welfare of all base personnel are protected from the potentially harmful effects of asbestos containing material.

The AMP is designed to be a permanent record on the current status and condition of all asbestos containing material (ACM) in this installation's facility inventory. This document provides a single location for the documentation of all asbestos management efforts and the mechanism for oversight of the entire facility asbestos management program.

The AOP is designed to implement the policy established in the AMP and establish procedures for accomplishing asbestos related projects. The focus of both the AMP and AOP is on taking positive action to deal with current and near-term asbestos management needs, rather than on planning solely for future removal of asbestos containing material (ACM) from base facilities.

Air Guard policy is to manage ACM in place as long as practical; ideally until a facility with ACM is scheduled for disposal (except in residences, medical facilities, and facilities used by children where any friable asbestos that might lead to exposure should be removed). This requires that installations have specific procedures for managing facilities with ACM and protecting personnel from the hazards associated with airborne fibers from damaged ACM. It is the intention of the Air Guard to remove ACM whenever it is opportune to do so, whenever it is a potential threat to personnel health, and as necessary to comply with applicable regulations.

The AOP will provide guidance and procedures for removal of asbestos when the situation warrants. Additionally, it will outline procedures and practices to operate, maintain and repair base facilities in a manner that minimizes releases of asbestos fibers into the air.

1.3 Background

Asbestos is a group of naturally occurring minerals that separate into fibers. Asbestos that is capable of being crumbled, pulverized, or reduced to powder by hand pressure is described as

"friable." Inhalation of asbestos fibers has been linked to cancer and other diseases in humans.

Asbestos is regulated by the Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), the Department of Transportation (DOT) and by each state.

AFI%2032-1052.pdf AFI%2032-1052.pdf

September 8, 2014 7

EPA regulations concerning asbestos are contained in the Code of Federal Regulations (CFR) at

40 CFR Part 61 and 40 CFR Part 763. OSHA regulations are contained at 29 CFR 1926.1101 and

DOT regulations are contained at 49 CFR 171 and 172. These regulations govern control of asbestos fiber emissions to protect the environment and public health.

1.4 Organizational Roles and Responsibilities

An effective asbestos management program requires the participation and interface of several base organizations to ensure that the health and welfare of all personnel are protected from the potentially harmful effects of friable asbestos containing material. The office of BCE has primary responsibility for developing and implementing the asbestos program. Other base organizations must assist the BCE in identification of asbestos, asbestos sampling programs, quality control, legal implications, and protecting the health and well-being of all personnel.

http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=0fb6af18ddb63c530dddea1713283da3&rgn=div6&view=text&node=40:9.0.1.1.1.13&idno=40 http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=2afb234332baaa3b5987a7586b35b66f&ty=HTML&h=L&n=40y32.0.1.1.19&r=PART https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10862&p_table=STANDARDS http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&tpl=/ecfrbrowse/Title49/49cfr171_main_02.tpl http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&tpl=/ecfrbrowse/Title49/49cfr172_main_02.tpl

2 ASBESTOS MANAGEMENT PLAN

2.1 Asbestos Survey

ECT conducted an asbestos survey that covered 66 buildings and facilities. Records and plans for each building were reviewed, compared to the existing AMP for omissions and/or errors, and inspections of each building were performed including bulk sampling of suspected asbestos containing materials. The objectives of the survey were to update the current plan and identify and document the locations of asbestos containing materials (ACM) in designated facilities, to document the current condition of the ACM and to assess the current and potential hazards of exposure to existing asbestos containing materials.

2.1.1 Identification of ACM: The initial identification procedures consisted of a review of existing sample data and a visual inspection of each building. During the visual inspection, the team evaluated suspect ACM which generally falls into one of the following four major categories:

a. Surfacing materials such as sprayed on fireproofing.

b. Thermal system insulation such as insulation on steam lines.

c. Miscellaneous materials such as suspended ceiling tiles.

d. Non-friable materials such as floor tile.

Any suspect material that could not be visually determined to be non-asbestos containing was sampled. Samples of suspect ACM were taken using procedures outlined in 40 CFR Part 763.

This sampling protocol consisted of taking the following number of samples of each type of material:

2.1.2 Surfacing Materials no less than:

a. <1,000 sq. ft. take 3 statistically random samples

b. >1,000 sq. ft. to <5,000 sq. ft. take 5 statistically random samples

c. >5,000 sq. ft. take at least 7 statistically random samples

2.1.3 Thermal System Insulation

a. Three random samples per homogeneous area that were more than

6 sq. or lin. ft. Insulation around fittings such as valves and elbows different from straight runs of pipe.

*If the material was fiberglass or rubber, no samples were obtained.

A homogeneous area is defined as an area, which contains material that is uniform in texture and appearance and was installed at one time, and is unlikely to consist of more than one type of formulation of material.

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In order to determine that a suspect material is not ACM, all samples must be negative for asbestos. In order to determine that a suspect material is ACM, only one of the samples has to be positive for asbestos.

All samples were analyzed using the polarized light microscopy and dispersion staining identification technique as required by EPA regulations by an independent lab AmeriSci laboratories in Midlothian, VA.

As our survey is a nondestructive survey, walls, etc. were not penetrated to determine whether or not there is hidden ACM. In addition, due to the type of destructive sampling required to sample roofing materials, no roof sampling was conducted. Therefore, if the above areas are involved in major renovation or demolition, additional sampling for the presence of asbestos may be required.

2.2 Hazard Assessment

The hazard assessment was performed in accordance with 40 CFR Part 61 and Part 763.

Material Hazard Assessment Condition Chart

Hazard Rank ACBM Condition ACBM Disturbance Potential

7 Significant Damage Any

6 Damaged Potential for Significant Damage

5 Damaged Potential for Damage

4 Damaged Low Potential for Damage

3 Good Condition Potential for Significant Damage

2 Good Condition Potential for Damage

1 Good Condition Low Potential for Damage

RESPONSE ACTIONS BASED ON HAZARD RANKING

Asbestos Response Action Chart

Hazard Rank

Removal Priority

Categories Response Actions Required

7 1 Significantly Damaged

Evacuate or restrict the area if needed.

Remove the ACBM (or enclose or encapsulate it if sufficient to contain fibers). Repair of TSI allowed if feasible and safe. O&M required for all ACBM.

6 2 Damaged with Potential for Significant Damage

Evacuate or restrict the area if needed.

Remove, enclose, encapsulate, or repair to correct damage. Take steps to reduce potential for disturbance. O&M required for all ACBM.

5 3 Damaged with Potential for Damage

Remove, enclose, encapsulate, or repair to correct damage. O&M required for all

ACBM.

http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=0fb6af18ddb63c530dddea1713283da3&rgn=div6&view=text&node=40:9.0.1.1.1.13&idno=40 http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=f5f1df0394bd44f2475618e24404ad7d&rgn=div8&view=text&node=40:32.0.1.1.19.2.1.7&idno=40

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4 4 Damaged with low potential for damage

Same as Hazard Rank 5

3 5 Good with Potential for Significant

Evacuate or restrict the area if needed.

Take steps to reduce Damage potential for disturbance. O&M required for all ACBM.

2 6 Good with Potential for Damage

O&M required for all ACBM. Take steps to reduce potential for damage

1(O&M) 7 Good with low potential for disturbance

O&M required for all ACBM.

ACBM – Asbestos Containing Building Material

TSI – Thermal System Insulation

O&M = Operations and Maintenance

2.3 Asbestos Register

The register contains a list of all ACM on the base, its location, the type and condition of the material.

The Environmental Management Officer (EMO) should keep the register updated to reflect the current condition of ACM in each facility. Any change in the condition of the ACM and any repairs, removal or enclosure of the ACM should be documented on the "changes that affect sample summary'' sheets included in the Appendix. If additional samples are taken, the results should also be documented on the attached form and the sample report should be attached end of the AMP.

2.4 Monitoring and Surveillance:

All locations with friable ACM must be monitored on an on-going basis to ensure that the ACM does not become damaged or deteriorate and pose a risk of exposure to base personnel. The

EMO should develop a log and institute a program for semi-annual surveillance to check the condition of the ACM and to identify damage and deterioration. Any changes to the condition of the ACM should be documented and reported to the BCE by the EM or his/her representative; and if necessary, changes to the abatement priority list and hazard assessment should be made and the ACM should be repaired and/or removed.

2.5 Scheduling and Planning:

The EMO shall insure that the asbestos register is reviewed prior to the start of any work in buildings containing ACM. The register should also be reviewed prior to the design of any project involving buildings containing ACM. These procedures are further discussed in the

EMO.

The EMO should develop a program for scheduling asbestos abatement activities based on the resources available and the hazards identified in the building survey. Any activity involving the

ACM should be performed in accordance with the procedures identified in the Asbestos

Operation Plan.

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2.6 Information Dissemination:

Asbestos potentially affects all personnel who use base facilities containing ACM. The general base population should have a good understanding of the potential asbestos health hazards.

They also need to understand that undamaged asbestos in good condition poses no inherent hazard. The EMO shall attempt to increase general base knowledge and awareness of asbestos concerns by disseminating general information to the base population using appropriate base procedures.

3 ASBESTOS OPERATION PLAN (AOP)

3.1 Introduction

This AOP focuses primarily on the in-house asbestos abatement procedures. These are the procedures that will most often be used in an ongoing proactive base level asbestos management program. Abatement procedures used are only described in a general nature in this plan.

3.2 Work Control Procedures

Every project, which consists of repair or renovation of all or some portion of a facility, must be reviewed for the presence of asbestos. Upon receiving a work request, the BCE, project manager, and/or environmental manager is responsible for reviewing work requests should determine if ACM is present in the area where the work will be performed. The initial evaluation shall involve a review of the AMP. If the review of AMP indicates that no ACM is present, the work request should be processed thru the normal review channels. If the review of the AMP indicates that ACM is present or if the employee believes that ACM may be present even though it is not shown on the AMP, the work request should be routed to the BCE for further review. All work requests for contract work must be evaluated for the presence of ACM by the EMO and/or BCE prior to submitting the request to the facilities board. Verification of the presence of asbestos early in the programing stage will aid immeasurably in the planning and design of asbestos abatement activities.

Upon verification that ACM abatement will be required as part of a work request, the EMO and the BCE should evaluate the extent of the abatement effort required and determine if the asbestos abatement work will be performed in-house or by contract.

3.3 Awareness Training & Precautionary Measures

The BCE and the EMO should work together to provide awareness training to maintenance and custodial workers and all building occupants who work in buildings containing ACM. The training program should describe methods of handling ACM as well as routine maintenance activities that are prohibited when ACM’s are involved. For example, employees should be instructed:

Not to drill holes in asbestos containing materials;

Not to hang plants or pictures on structures covered with asbestos containing materials;

Not to sand asbestos containing floor tile;

Not to damage asbestos containing materials while moving furniture or other objects;

Not to install curtains, drapes, or dividers in such a way that they damage asbestos containing materials;

September 8, 2014 14

Not to dust floors, ceilings, moldings or other surfaces in asbestos contaminated environments with a dry brush or sweep with a dry broom;

Not to use an ordinary vacuum to clean up asbestos containing debris;

Not to remove ceiling tiles below asbestos containing materials without wearing the proper respiratory protection, clearing the area of other people, and observing asbestos removal waste disposal procedures.

The BCE and the EMO should coordinate the installation of asbestos warning signs. These signs should be posted on boilers, tanks and pipes with insulation containing asbestos. Care should be taken not to disturb the asbestos while posting the signs.

3.4 In-house abatement

3.4.1 General

The base should have at least one person trained to perform asbestos abatement. The worker/workers should be used for relatively small-scale abatement projects and for handling emergency asbestos removal such as removing asbestos from a ruptured steam line. Large scale and non-emergency abatement should be performed by contract.

3.4.2 Training Requirements

In order to conduct asbestos related work on base, workers must complete an EPA approved asbestos worker or supervisor course and pass an examination for the course.

Additionally, on base workers need to be certified for asbestos abatement operations as required by local and/or state laws. Since certification requirements vary from state to state, the BCE must be familiar with the specific state certification requirements. All certifications require that individuals pass an examination and participate in annual refresher courses. Asbestos abatement should never be performed by an employee who is not trained and certified. The EMO and BCE should attend an EPA approved supervisor's course in order to properly manage the asbestos program.

3.4.3 Respiratory Protection

Air Force Manual 48-155, Occupational and Environmental Health Exposure Controls, outlines general respiratory protection requirements to be followed. Workers are required to wear a respirator when performing tasks that result in the potential of exposure to asbestos above the permissible exposure limit (PEL) of <0.1f/cc (fibers per cubic centimeter of air). Half face piece air purifying respirators that have been fit tested and are equipped with a High Efficiency Particulate Air (HEPA) filter can be used for most small-scale abatement work as long as air monitoring indicates that airborne concentrations of asbestos fibers do not exceed levels, which allow the use of this type of respiratory protection. Workers shall not enter an area where respiratory protection airforce_manual_48-155.pdf

September 8, 2014 15 equipment is required unless the person has been trained in the selection, use, care and limitations of the respirator and the proper respirator has been selected for the task.

3.4.4 Medical Surveillance

OSHA regulation 29 CFR 1926.1101 requires employers to institute a medical monitoring program for all asbestos workers. Specific exam requirements can be found in the OSHA regulations. In general, the regulations require an initial exam and follow-up yearly exams. The exams must include a chest x ray, pulmonary function testing, and completion of a standardized medical questionnaire and a complete medical and work history.

3.4.5 Abatement Equipment and Supplies

As a minimum, the EMO should purchase and maintain an adequate inventory of the following asbestos abatement supplies and equipment. NOTE: Only if you have a certified Asbestos worker or supervisor.

(1) Rolls of polyethylene sheeting.

(2) Rolls of gray duct tape or clear plastic tape.

(3) Asbestos glove bags.

(4) A HEPA filtered vacuum.

(5) A wetting agent.

(6) An airless sprayer.

(7) Warning signs and labels.

(8) Pre-printed disposal bags.

(9) Half face piece air purifying respirators (as a minimum).

(10) Disposable coveralls.

(11) Disposable gloves.

3.4.6 Air Monitoring

Air monitoring must be performed to determine airborne fiber concentration before, during and after abatement activities. The EMO shall coordinate air sampling requirements with the base bioenvironmental personnel even if the bioenvironmental personnel have not had specific asbestos air sampling training. If the base bioenvironmental personnel cannot provide air monitoring, the EMO shall have to procure air monitoring services from a private firm. The procurement action should also be coordinated with the base bioenvironmental personnel.

Detailed information concerning air sampling requirements can be found in OSHA regulations (29 CFR 1926.1101). In general, samples should be taken before any work is started, on a daily basis for the entire project duration and upon completion of the project in order to ensure that the area has not been contaminated by airborne asbestos fibers.

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10862&p_table=STANDARDS https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10862&p_table=STANDARDS

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3.4.7 Record Keeping

A critical aspect of the asbestos program on base is assurance that project paperwork will be maintained on file for future liability concerns. EPA and OSHA regulations require that asbestos related documents be maintained for at least 30 years.

The EMO and BCE should work together to establish a record keeping system. Since

OSHA could requisition these records in defense of potential future litigation, the system should be coordinated with and accepted by the base legal officer. The types of documents, which should be kept in the records, include the following:

(1) Detailed reports of bulk sampling data.

(2) Air monitoring exposure data.

(3) Medical surveillance information.

(4) Contractor employee training records.

(5) Employee/contractor/public/occupant notification procedures.

(6) Construction contract documents.

(7) Certifications of EPA approved landfills.

(8) Contractor industrial hygiene reports.

(9) Landfill receiving documents.

(10) Any correspondence dealing with asbestos.

3.4.8 Abatement Alternatives

Since the number of trained workers on base is limited, in house abatement activities are limited to those procedures which can be used for small scale, short-duration renovation and maintenance projects. The regulations define these small scale projects as tasks similar to, but not limited to, removal of ACM insulation on pipes, removal of small quantities of ACM insulation on beams or above ceiling, replacement of an ACM gasket on a valve, installation or removal of a small section of drywall, installation of electrical conduits through or proximate to ACM and repair of a valve where asbestos removal is incidental to the actual repair. The encapsulation of ACM by spraying the

ACM with a sealant to bind the ACM fibers and other material components is an additional abatement alternative, which is not described below. Encapsulation is not described because it generally requires full containment of the work site and should rarely if ever be used. A brief description of the three main asbestos abatement alternatives is listed below followed by the abatement procedures for these alternatives, which would most often be used by the in house worker/workers. All asbestos abatement activities described below must be performed by trained asbestos workers.

(1) Repair: The repair of ACM is accomplished by utilizing non-asbestos plaster or encapsulant to reseal open joints, damaged insulation wrapping or damaged plastered areas around valves and flanges. Duct

September 8, 2014 17 tape should not be used because it becomes brittle after exposure to high temperatures.

The repair of damaged ACM should be limited to thermal insulation on pipes, pipe elbows, tanks and boilers. Repairs should only be attempted on insulation with limited damage.

(2) Removal: Several control methods and work practices, used either singly or in combination, can be used to effectively reduce asbestos exposure during small-scale removal operations. These include the use of glove bags, the removal of entire asbestos insulated pipes or structures and the construction of mini-enclosures.

(3) Enclosure: The enclosure of ACM involves the construction of a solid structure (airtight walls and ceilings) around the asbestos covered pipe or structure to prevent the release of ACM into the area outside the enclosure and to prevent disturbing these materials by casual contact during future maintenance operations.

Enclosure should only be used on a limited basis and when no other option is feasible since it does not completely eliminate the potential hazard. If the enclosed area is ever involved in a renovation project, the asbestos will still have to be removed.

3.4.9 Abatement Procedures

(1) Repair Procedure

The following procedures should be used for repairing ACM:

a. The work area should be secured in order to keep all personnel the area that is not connected with the operation.

b. The work area should be vacuumed with a HEPA vacuum in order to remove any ACM that may have been previously disturbed.

c. Polyethylene sheeting should be placed under the work area.

d. Respirators and protective clothing should be used by the worker/workers.

e. Non asbestos plaster, encapsulant or other suitable materials should be used to reseal the open joints, damaged insulation wrapping or other damaged areas. Pre glued lag cloth is an excellent material to use for this purpose.

f. Air samples should be taken in order to insure that asbestos fibers are not being released.

g. If sample results indicate concentrations above the action level of

<0.1f/cc, additional steps outlined under the removal procedures must be implemented. If sample results indicate concentrations below the

September 8, 2014 18 action level, these results should be used to document that the repair procedures being utilized do not create an asbestos hazard and, therefore, future repairs utilizing the same procedures should not require air sampling.

h. Upon completion of the work, the work area should be cleaned utilizing wet methods and a HEPA vacuum. All waste including disposable protective clothing should be double bagged and disposed of as asbestos waste. Disposable protective clothing should be removed by turning them inside out .in order to minimize any potential fiber release.

(2) Removal Procedures

a. Preparation of the Work Area:

The first step in preparing to perform a small-scale, short-duration asbestos renovation or maintenance task, regardless of the abatement method that will be used, is the removal from the work area of all objects that are movable to protect them from asbestos contamination. Objects that cannot be removed must be covered completely with a 6-mil-thick polyethylene plastic sheeting before the task begins. If objects have already been contaminated, they should be thoroughly cleaned with a

High Efficiency Particulate Air (HEPA) filtered vacuum or be wet wiped before they are removed from the work area or completely encased in the plastic.

During the preparation of the work area, the area must be blocked off with appropriate warning signs to keep all personnel out of the area that is not connected with the operation.

b. Wet Methods:

Wet methods must be used during small-scale, short duration maintenance and renovation activities that involve disturbing asbestos containing materials. Handling asbestos materials wet is one of the most reliable methods of ensuring that asbestos fibers do not become airborne, and this practice should therefore be used whenever feasible.

Only in cases where asbestos work must be performed on live electrical equipment, on live steam lines, or in other areas where water will seriously damage materials or equipment may dry removal be performed. Amended water or another wetting agent should be applied by means of an airless sprayer to minimize the extent to which the asbestos containing material is disturbed. Asbestos containing materials should be wetted from the initiation of the maintenance or renovation operation and wetting agents should be used continually throughout the

September 8, 2014 19 work period to ensure that any dry asbestos containing material exposed in the course of the work is wet and remains wet until final disposal.

c. Removal Methods:

Several methods can be used to remove small amounts of asbestos containing materials during small-scale, short-duration renovation or maintenance tasks. These include the use of glove bags, the removal of an entire asbestos-covered pipe or structure, and the construction of mini-enclosures.

d. Glove Bags:

Gloves bags shall not be used for renovation of large areas; however, the regulation does allow for the use of a glove bag for short duration and small-scale projects, such as a repair of a valve where asbestos removal is incidental to the actual repair. Glove bags are readily available from safety supply stores or specialty asbestos removal supply houses. Glove bags come pre labeled with the asbestos warning label prescribed by

OSHA and EPA for bags used to dispose of asbestos waste. These bags are single use control devices that are disposed of at the end of each job.

Supplies and materials that are necessary to use glove bags effectively include:

(1) Tape to seal the glove bags to the area from which asbestos is to be removed;

(2) Amended water or other wetting agents;

(3) An airless sprayer for the application of the wetting agent;

(4) Bridging encapsulant (a paste-like substance for coating asbestos.)

to seal the rough edges of any asbestos containing materials that remain within the glove bag at the points of attachment after the rest of the asbestos has been removed;

(5) Tools such as razor knives, nips, and wire brushes (or other tools suitable for cutting wire, etc.);

(6) A HEPA filter-equipped vacuum for evacuating the glove bag (to minimize the release of asbestos fibers) during removal of the bag from the work area and for cleaning any material that may have escaped during the installation of the glove bag;

(7) HEPA-equipped dust cartridge respirators for use by the employees involved in the removal of asbestos with the glove bag;

September 8, 2014 20

(8) Disposable coveralls and other necessary protective equipment.

(9) Glove bags must be installed so that they completely cover the pipe or other structure where asbestos work is to be done. Glove bags are installed by cutting the sides of the glove bag to fit the size of the pipe from which asbestos is to be removed.

The glove bag is attached to the pipe by folding the open edges together and securely sealing them with tape. All openings in the glove bag must be sealed with duct tape or equivalent material. The bottom seam of the glove bag must also be sealed with duct tape or equivalent to prevent any leakage from the bag that may result from a defect in the bottom seam.

*The employee who is performing the asbestos removal with the glove bag must utilize a half mask dual-cartridge HEPA-equipped respirator (as a minimum) and disposable coveralls; respirators and disposable coveralls should be worn by employees who are in close contact with the glove bag and who may thus be exposed as a result of small gaps in the seams of the bag or holes punched through the bag by a razor knife or a piece of wire mesh.

(10) Once the asbestos material has been thoroughly wetted, it can be removed from the pipe, beam or other surface. The choice of tool to use to remove the asbestos containing material depends on the type of material to be removed. Asbestos containing materials are generally covered with painted canvas and/or wire mesh. Painted canvas can be cut with a razor knife and peeled away from the asbestos containing material underneath. Once the canvas has been peeled away, the asbestos containing material underneath may be dry, in which case it should be re-sprayed with a wetting agent to ensure that it generates as little dust as possible when removed. If the asbestos containing material is covered with wire mesh, the mesh should be cut with nips, tin snips, or other appropriate tools and removed. A wetting agent must then be used to spray any layer of dry material that is exposed beneath the mesh, the surface of the stripped underlying structure, and the inside of the glove bag.

(11) The removed asbestos material from the pipe or other surface that has fallen into the enclosed bag must be thoroughly wetted with a wetting agent (applied with an airless sprayer through the

September 8, 2014 21 precut port provided in most glove bags or applied through a small hole cut in the bag).

(12) After removal of the layer of asbestos containing material, the pipe or surface from which asbestos has been removed must be thoroughly cleaned with a wire brush and wet wiped with a wetting agent until no traces of the asbestos containing material can be seen.

(13) Any asbestos containing insulation edges that have been exposed as a result of the removal or maintenance activity must be encapsulated with bridging encapsulant to ensure that the edges do not release asbestos fibers to the atmosphere after the glove bag has been removed. When the asbestos removal and encapsulation have been completed, a vacuum hose from a HEPA filtered vacuum must be inserted into the glove bag through the port to remove any air in the bag that may contain asbestos fibers. When the air has been removed from the bag, the bag should squeezed tightly (as close to the top as possible), twisted, and sealed with tape, to keep the asbestos materials safely in the bottom of the bag. The HEPA vacuum can then be removed from the bag and the glove bag itself can be removed from the work area to be disposed of properly. Air samples should be taken before, during and after the removal operation to insure that asbestos fibers are not being released.

e. Mini-Enclosures:

In some instances, such as removal of asbestos from a small ventilation system or from a short length of duct, a glove bag may not be either large enough or of the proper shape to enclose the work area. In such cases, a mini-enclosure can be built around the area where small-scale, short-duration asbestos maintenance or renovation work is to be performed.

Such an enclosure should be constructed of 6-mil thick polyethylene plastic sheeting and can be small enough to restrict entry to the asbestos worker.

For example, a mini-enclosure can be built in a small utility closet when asbestos containing duct covering is to be removed. The enclosure is constructed by:

(1) Affixing plastic sheeting to the walls with spray adhesive and tape;

(2) Covering the floor with plastic and sealing the plastic covering the floor to the plastic on the walls;

September 8, 2014 22

(3) Sealing any penetrations such as pipes or electrical conduits with tape;

(4) Constructing a small change room (approximately 3 feet square) made of 6-mil-thick polyethylene plastic supported by 2'x-4' (the plastic should be attached to the lumber supports with staples or spray adhesive and tape).

*The change room should be contiguous to the mini-enclosure, and is necessary to allow the worker to vacuum off his protective coveralls and remove them before leaving the work area. While inside the enclosure, the worker should wear disposable coveralls and use the appropriate

HEPA filtered dual cartridge respiratory protection. The advantages of mini-enclosures are that they limit the spread of asbestos contamination, reduce the potential exposure of bystanders and other workers who may be working in adjacent areas, and are quick and easy to install. The disadvantage of mini-enclosures is that they may be too small to contain the equipment necessary to create a negative pressure within the enclosure; however, the double layer of plastic sheeting will serve to restrict the release of asbestos fibers to the area outside the enclosure.

A HEPA vacuum can be used to provide the negative pressure within the enclosure by locating the vacuum outside the enclosed area and connecting its hose to the enclosed area.

Air samples should be taken before, during and after the removal operation to insure that asbestos fibers are not being released.

f. Removal of Entire Structures:

When pipes are insulated with asbestos containing materials, removal of the entire pipe may be more protective, easier, and more cost effective than stripping the asbestos insulation from the pipe. Before such a pipe is cut, the asbestos containing insulation must be wrapped with 6-mil polyethylene plastic and securely sealed with duct tape or equivalent.

This plastic covering will prevent asbestos fibers from becoming airborne as a result of the vibration created by the power saws used to cut the pipe. If possible, the pipes should be cut at locations that are not insulated to avoid disturbing the asbestos. If a pipe is completely insulated with asbestos containing materials, small sections should be stripped using the glove-bag method described above before the pipe is cut at the stripped sections.

g. Enclosure:

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The enclosure should be built of new construction materials and should be impact resistant and airtight. Enclosure walls should be made of tongue-and-groove boards, boards with spine joints, or gypsum boards having taped seams. The underlying structure must be able to support the weight of the enclosure. (Suspended ceilings with laid in panels do not provide airtight enclosures and should not be used to enclose structures covered with asbestos containing materials.) All joints between the walls and ceiling of the enclosure should be caulked to prevent the escape of asbestos fibers. During the installation of enclosures, tools that are used (such as drills or rivet tools) should be equipped with HEPA-filtered vacuums. Before constructing the enclosure, all electrical conduits, telephone lines, recessed lights, and pipes in the area to be enclosed should be moved to ensure that the enclosure will not have to be re-opened later for routine or emergency maintenance. If such lights or other equipment cannot be moved to a new location for logistic reasons, or if moving them will disturb the asbestos containing materials, removal rather than enclosure of the asbestos containing materials is the appropriate control method to use.

While constructing the enclosure workers should wear disposable coveralls and use the appropriate HEPA filtered dual cartridge respiratory protection. Air samples should be taken before, during and after the enclosure operation to insure that asbestos fibers are not being released.

3.4.12 Emergency Asbestos Operations

MINOR RELEASES: Minor emergency fiber release episodes are events where visible emissions or production of debris involving less than 3 square feet or 3 linear feet of friable ACM occur.

One example would be a ruptured ACM insulated valve, which has caused the ACM insulation to fall to the floor. The base Asbestos Worker I workers should provide the necessary cleaning activities.

(1) Procedures to be followed for minor release episodes include:

a. Restrict access to the area.

b. Wet debris with amended water (utilize proper protective clothing and respiratory protection).

c. Collect debris into marked 6 mil disposable bags.

d. Clean the area with wet cleaning or HEPA vacuuming techniques.

e. Collect contaminated cleaning materials and place in marked 6 mil disposal bags.

f. Repair the damaged area.

g. Evaluate the source of the release (determine if additional repairs are required).

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h. Make additional repairs as required.

i. Take air samples to insure safe working environment. Major Emergency

Fiber Release

MAJOR RELEASES: Major emergency fiber release episodes are the falling or dislodging of more than 3 square feet or 3 linear feet of friable ACM. The base asbestos worker/workers should provide the necessary cleaning activities if the scope of the project is within the base worker/workers capability.

(2) Procedures to be followed for a major fiber release episode include:

a. Immediately restrict access to the area:

If the episode occurs while occupants are in the building but not in the area of the fiber release, the area must be isolated even if building occupant activity or mobility is restricted.

An episode where the building occupants are in the area of the fiber release presents a major problem. The first priority is to maintain order, prevent panic and stay calm. Non-contaminated occupants should be removed from the area. Contaminated occupants should be HEPA vacuumed or wet cleaned and showers should be taken, if possible. All clothing should be disposed of as asbestos waste or properly laundered.

1. Post warning signs.

Shut down or modify air handling equipment servicing the area. Design and execute a response action.

2. Notify appropriate officials.

3.4.11 Transportation and Disposal

(1) Transportation Requirements:

a. Transportation is defined as all activities involving asbestos waste from the time it leaves the work site until it has been unloaded at the disposal site. Current EPA regulations state that there must be no visible emissions to the outside air during transportation. Because of the hazards and liabilities associated with exposure, the following additional precautions are recommended.

b. Record Keeping:

The EMO will ensure that the asbestos waste is properly wetted and containerized before the transporter accepts the waste. The EMO must also ensure a chain-of-custody form is completed and signed. This form will include the (1) name and address of the generator (EMO), (2) the address of the pickup site and the address of the facility where the

September 8, 2014 25 asbestos was removed, (3) the estimated quantity of asbestos waste, (4) types of containers used, and (5) the final destination (disposal site) for the waste. The chain-of-custody form should then be signed over to a disposal site operator to transfer responsibility for the asbestos waste.

A copy of the form signed by the disposal site operator should be maintained in the asbestos file as evidence of receipt of the waste at the site.

c. Waste Transport:

There are no specific regulatory requirements regarding the transport vehicle; however, it is recommended that the vehicles used for transporting containerized asbestos waste have an enclosed carrying compartment or utilize a canvas covering sufficient to contain the transported waste, prevent damage to containers and prevent fiber release. The enclosed compartment also helps reduce the potential public hysteria associated with asbestos. Vehicles that use compactors to reduce waste should not be used since these will cause the waste containers to rupture.

d. Packaging Asbestos for Transportation and Disposal:

All asbestos containing materials, which includes protective clothing, disposable respirators, brooms, wiping rags, vacuum filters, floor sweepings, etc., will be collected and placed in double sealed impermeable 6 mil plastic bags. Some states also require that these bags be placed in leak-tight drums and these drums properly marked with an approved asbestos caution label. Condition of the waste should not allow fiber release and improper packaging is a violation of the NESHAP regulations. For any problems or questions regarding transportation, the

EMO should contact the appropriate EPA Regional Asbestos NESHAP coordinator.

e. Asbestos Disposal Arrangements:

Disposal involves the isolation of asbestos waste material in order to prevent fiber release to air or water. Land-filling is recommended as the environmentally sound isolation method because asbestos fibers are virtually immobile in soil. When the asbestos has been properly containerized and stored in a secure area, which has been marked with warning signs, the EMO will arrange for transportation and disposal at the designated landfill. Procedures for hauling and disposal shall comply with 40 CFR 61 (subpart M) and state and local standards. In accordance with EPA/NESHAP (40 CFR 61.146), the BCE will notify the state http://www.epa.gov/compliance/monitoring/programs/caa/neshaps.html http://www2.epa.gov/aboutepa/stanley-meiburg-stan-acting-regional-administrator-epas-southeast-region http://www2.epa.gov/aboutepa/stanley-meiburg-stan-acting-regional-administrator-epas-southeast-region http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=0fb6af18ddb63c530dddea1713283da3&rgn=div6&view=text&node=40:9.0.1.1.1.13&idno=40 CFR-2011-title40-vol8-sec61-146.pdf

September 8, 2014 26 regulatory agencies prior to disposal at an approved landfill. An approved landfill will be used for disposal.

3.5 Contract Abatement

3.5.1 General When the EMO and/or BCE have determined that a required asbestos abatement action is beyond the capability of the in-house worker/workers, the work must be performed either by contract.

General procedures to be followed when utilizing a contractor is described below.

Federal regulations (40 CFR Part 61) require that the EPA or an authorized state agency be notified of any asbestos removal projects that exceed certain minimum removal quantities.

The EMO should contact the state agency responsible for the asbestos program and coordinate the asbestos activities with this agency. The EMO should also coordinate the required air monitoring support with the base bioenvironmental personnel and/or a private air monitoring firm.

3.5.2 Contract Abatement If the decision is made to perform the required abatement project by contract, the EMO and/or the BCE should initiate actions to obtain the necessary design services. Only those firms, which have experience with the design of asbestos abatement projects, should be considered for selection to accomplish the design.

The design of the abatement project should be based upon the current EPA and OSHA regulations. The specifications should require the contractor to perform all tasks associated with the abatement activities such as EPA notification and air monitoring.

The EMO should obtain copies of all records maintained by the contractor such as air monitoring results, employee respirator fit testing results, medical records, etc.

These records should be incorporated into the base asbestos program. The asbestos register should also be updated to include the work performed by the contractor.

4.0 FACILITY LIST

ACBM Present?

Facility Number

Facility Name Drawing Photograph YES NO

M001 Front Traffic Check House M01 X

M013 Sanitary Latrine (DEMOLISHED) M013 X

M015 Pavilion X

M090 Base Exchange/Mini Mall M090 X

M100 Base Operations (ABATED JULY 2013) M100 M100 1x1 X

M101 Maintenance Control M101 M101 12x12 X

M102 CSO –…