robins air force base, georgia asbestos management...

ROBINS AIR FORCE BASE, GEORGIA

ASBESTOS MANAGEMENT PLAN (AMP)

JANUARY 2015

PRINTED ON 30% RECYCLED PAPER

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

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Printed on 30% Recycled Paper


TABLE OF CONTENTS Section Page No. List of Acronyms............................................................................................................................ vi Distribution .................................................................................................................................. viii Security Instructions/Record of Changes/Annual Review ............................................................. ix Definitions....................................................................................................................................... x

1.0 INTRODUCTION..............................................................................................................1 1.1 THE ASBESTOS HAZARD EMERGENCY RESPONSE ACT (AHERA) ..........1 1.2 ASBESTOS OPERATING PLAN ...........................................................................1 1.3 ASBESTOS CONTAINING MATERIAL IN BUILDINGS ...................................1

2.0 ASBESTOS PROGRAM POLICY ..................................................................................3 2.1 BACKGROUND .....................................................................................................3 2.2 REGULATORY REVIEW ......................................................................................4

2.2.1 Federal Regulations, Codes, and Standards .................................................4 2.2.2 State Regulations, Codes, and Standards (including latest changes) ...........5 2.2.3 Air Force and Base Regulations and Standards ...........................................5

2.3 SCOPE .....................................................................................................................5 2.3.1 Roles and Responsibilities ...........................................................................5 2.3.2 Notification Procedures ...............................................................................6 2.3.3 Training ........................................................................................................6 2.3.4 Medical Surveillance ...................................................................................6 2.3.5 Surveillance and Monitoring ........................................................................6 2.3.6 Recordkeeping Requirements ......................................................................6 2.3.7 Response Action ..........................................................................................6 2.3.8 Work Order Process .....................................................................................7

3.0 ROLES AND RESPONSIBILITIES ................................................................................8 3.1 AIR FORCE CIVIL ENGINEER CENTER – OPERATIONS DIRECTORATE, ENGINEER

DIVISION (AFCEC/COS) .......................................................................................8 3.2 ENVIRONMENTAL CENTER OF EXCELLENCE (AFCEC/CZ) .......................8 3.3 78TH AIR BASE WING, ROBINS AFB ..................................................................8

3.3.1 Base Civil Engineer Group (78 CEG) Responsibilities ...............................8 3.3.2 Facility Manager Responsibilities ..............................................................10 3.3.3 Environmental Management Responsibilities (78 CEG/CEIE): ................11 3.3.4 Medical Services ........................................................................................13

3.4 AFSC CONTRACTING (AFSC/PZ) .....................................................................14 3.5 MAINTENANCE SUPPORT GROUP (402 MXSG) ...........................................14

4.0 NOTIFICATION .............................................................................................................15 4.1 ASBESTOS POINTS OF CONTACT ...................................................................15 4.2 CONTRACTORS ..................................................................................................15

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4.3 FACILITY/BUILDING MANAGERS ..................................................................15 4.4 REGULATORY AGENCIES ................................................................................15

5.0 TRAINING REQUIREMENTS .....................................................................................17 5.1 PROGRAM ADMINISTRATORS TRAINING ...................................................17 5.2 CUSTODIAL AND MAINTENANCE PERSONNEL TRAINING .....................17 5.3 ABATEMENT WORKERS AND SUPERVISORS TRAINING .........................19 5.4 BUILDING INSPECTOR TRAINING ..................................................................19

6.0 MEDICAL SURVEILLANCE AND PERSONAL PROTECTION ...........................20 6.1 RESPIRATORY PROTECTION PROGRAM ......................................................20 6.2 OCCUPATIONAL PHYSICAL EXAMINATION PROGRAM ..........................20 6.3 RECORDS OF MEDICAL SURVEILLANCE .....................................................20

7.0 REASSESSMENT, SURVEILLANCE, AND ANNUAL AIR MONITORING ........21 7.1 REASSESSMENT .................................................................................................21 7.2 ANNUAL AIR SAMPLING ..................................................................................21

8.0 RECORDKEEPING - GENERAL REQUIREMENTS ...............................................22 8.1 DATA COLLECTION ...........................................................................................22 8.2 THE ASBESTOS RECORD..................................................................................22 8.3 ASBESTOS MANAGEMENT PLAN CHANGE CONTROL .............................22 8.4 ASBESTOS DATABASE .....................................................................................22 8.5 ASBESTOS PROJECT FILE ................................................................................23 8.6 RECORDS RETENTION ......................................................................................23

9.0 EMERGENCY RESPONSE PLAN ...............................................................................24 9.1 EMERGENCY RESPONSE ..................................................................................24 9.2 MINOR FIBER RELEASE EPISODE (40 CFR 763.91(F)(1)) .............................24 9.3 MAJOR FIBER RELEASE EPISODE (40 CFR 763.91(F)(2)) ............................24 9.4 ECONOMIC CONSIDERATIONS .......................................................................25

10.0 ASBESTOS WORK ORDER PROCESS ......................................................................25 10.1 WORK REQUESTS ..............................................................................................25 10.2 WORK REQUESTS REVIEW PROCESS ...........................................................26 10.3 WORK REQUESTS TRACKING SYSTEM ........................................................26

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LIST OF APPENDICES Appendix A Forms/ Documents

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

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

327-3976

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

327-8935

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

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

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DISTRIBUTION Office No. of Copies 78 ABW/SE WR-ALC/SE/402 MXSS 4 78 CEG/CL 1 78 CES/CL 1 78 CEG/CEI 1 AFSC/PZIOC 1 78 AMDS/SGPB/SGPM 1 78 SPTG/FSD 1 78 CEG/CEN 1 116 MSG/CE 1

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SECURITY INSTRUCTIONS/RECORD OF CHANGES/ANNUAL REVIEW

1. The title of this plan is Robins Air Force Base Asbestos Management Plan. 2. The overall classification of the document is UNCLASSIFIED. 3. This document is designated "Unclassified" and will be handled in accordance with AFI 37-131.

Reproduction and distribution of this plan is not restricted. 4. Review of this plan will be conducted annually. Record of Changes

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

Record of Annual Review

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

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

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

Robins Air Force Base (AFB) Asbestos Management Plan January 2015 OPR: 78 CEG/CEI

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DEFINITIONS 1. ABATEMENT. A method, including removal, encapsulation, enclosure, repair, and periodic monitoring that protects human health and the environment from friable Asbestos Containing Building Materials (ACBM). See also response action. 2. AREA AIR SAMPLING. Air sampling conducted in work areas to determine the concentration of airborne asbestos fibers. Area air sampling is conducted in areas where there is a potential for the release of asbestos fibers. 3. ASBESTOS. A group of naturally occurring minerals that separates into small thin fibers. There are six asbestos minerals used commercially: Chrysotile, amosite, crocidolite, anthophyllite, tremolite, and actinolite. 4. ASBESTOS CONTAINING MATERIAL (ACM). A material that contains greater than one percent asbestos by weight. 5. ASBESTOSIS. A disease characterized by fibrotic scarring of the lung. This is a restrictive lung disease, which reduces the capacity of the lung. The common symptom is shortness of breath. Asbestosis is prevalent among workers who have been exposed to large doses of asbestos fibers over a long period of time. 6. BASE ASBESTOS OPERATIONS OFFICER (BAOO). (78th Civil Engineer Group, 78th Civil Engineer Squadron (78 CES) Function). 78 CES is responsible for the base asbestos program operations. This support shall include trained personnel to perform abatement of asbestos found in conjunction with all facilities, except aircraft and non-real property systems, located at Robins AFB. 78 CES is also responsible for bulk sampling, program budgeting and funding, and asbestos removal either with in-house workers or by means of an Indefinite Delivery/Indefinite Quantity (ID/IQ) contract. 7. BASE ASBESTOS PROGRAM OFFICER (BAPO). (78th Civil Engineer Group, Environmental Management Branch (78 CEG/CEIE) Function). CEIE is responsible for coordinating, maintaining, and providing regulatory guidance for the base asbestos program. The program shall be managed so that asbestos materials are thoroughly controlled at the lowest possible cost to the AF. The BAPO is also responsible for maintaining a current inventory of all known asbestos at Robins AFB. 8. CLEARANCE AIR SAMPLING. Sampling of air in a negative pressure enclosure at the completion of an abatement project. Clearance air sampling is used to determine if the enclosure has been adequately cleaned prior to being dismantled. Clearance air sampling is accompanied by aggressive agitation of the air in the negative pressure enclosure that dislodges settled fibers and ensures that fiber concentrations are measured accurately. 9. DEMOLITION. The wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations.

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

11. ENCLOSURE. An airtight, impermeable, permanent barrier around ACMs to prevent the release of asbestos fibers into the air. 12. FACILITY. Any institutional, commercial, public, industrial, or residential structure, installation, or building. 13. FIBER. A particulate form of asbestos, five micrometers or longer, with a length-to-diameter ratio of at least three to one. 14. FIBER RELEASE EPISODE. Any uncontrolled or unintentional disturbance of ACM resulting in a release of ACM. 15. FRIABLE. Such material, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure, and includes previously nonfriable material which may become damaged to the extent that, when dry, it may be crumbled, pulverized, or reduced to powder by hand pressure. 16. HIGH EFFICIENCY PARTICULATE AIR (HEPA) FILTER. A trade name for a kind of tightly woven paper filter used in respirator cartridges, exhaust systems, vacuum cleaners, etc., that is at least 99.97% efficient at collecting all particulate matter that is at least 0.3 microns in size. 17. HOMOGENOUS AREA. An area that contains material that is uniform in color, texture, and appearance and was probably installed all at once, and is unlikely to consist of more than one type, or formulation of material. 18. IMMINENT HAZARD. An uncontrolled or unintentional disturbance of an ACM resulting in a visible emission or visible dust.

19. LATENCY PERIOD. The time period between the exposure to a harmful agent and the onset of recognized symptoms. For asbestos-related diseases, this can be anywhere from 20 to 40 years. 20. MESOTHELIOMA. A rare and deadly form of cancer that has been associated with asbestos exposures. There are two forms. In pleural mesothelioma, tumors occur in the pleura or lining of the lung. In peritoneal mesothelioma, tumors occur in the peritoneum or lining of the abdomen. 21. NEGATIVE PRESSURE ENCLOSURE. An airtight enclosure constructed of polyethylene sheeting used to control asbestos fibers at abatement projects. Negative pressure is continuously blowing air to the outside of the enclosure. This results in uncontaminated air being drawn through the entrance from the outside of the enclosure. Fans used to create the negative pressure enclosure are equipped with HEPA filters that remove asbestos fibers from air being exhausted from the enclosure.

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22. NON-REAL PROPERTY. Areas of a facility by definition which Plant Services, Communications, or Transportation have responsibilities for operations, maintenance and repair activities. 23. PERSONAL AIR SAMPLING. The sampling of the breathing zone of a worker to determine the concentration of asbestos fibers to which the worker would be exposed without respiratory protection. Personal air sampling is used to determine the type of respiratory protection required for abatement workers. 24. PRESUMED ASBESTOS-CONTAINING MATERIAL (PACM). Thermal system insulation and surfacing material found in buildings constructed no later than 1980 that are assumed to contain greater than one percent asbestos but have not been sampled or analyzed to verify or negate the presence of asbestos. 25. REAL PROPERTY. Facilities and infrastructure for which CE is responsible to perform operations, maintenance, and repair activities as identified in the Air Force Instruction (AFI) 32-1XXX series. 26. RENOVATION. The altering, in any way, of one or more facility components. Operations in which load-supporting structural members are removed in conjunction with the act of restoring to a former or better state. 27. REPAIR. Returning damaged ACBM to an undamaged condition or to an intact state so as to prevent fiber release. 28. RESPONSE ACTION. A method, including removal, encapsulation, enclosure, repair, and periodic monitoring that protects human health and the environment from friable ACBM. 29. SURFACING MATERIAL. Material that is sprayed-on, troweled-on, or otherwise applies to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes. 30. SUSPECT MATERIAL. Material that, by the judgment of the inspector, may possibly contain asbestos. Such determinations are based on the age, use, appearance, and texture of the material in question. 31. THERMAL SYSTEM INSULATION (TSI). Material applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain. 32. VISUAL INSPECTION. An inspection of a negative pressure enclosure after the completion of the abatement and prior to the dismantling of the enclosure. The purpose of the inspection is to ensure that abatement actions (removal, encapsulation, enclosure) were completed properly, and to ensure that the negative pressure enclosure is free of dust and debris. 33. WORK PLAN. A plan submitted by the abatement contractor that describes in detail all tasks required to complete the abatement project.

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

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

• Document our commitment to protect the health of personnel and establish procedures to

ensure compliance with Federal, State, and AF environmental and occupational regulations pertaining to asbestos.

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

1.1 THE ASBESTOS HAZARD EMERGENCY RESPONSE ACT (AHERA) AHERA currently requires each elementary and secondary school to perform an inspection for ACBM and to prepare an asbestos management plan for managing asbestos in schools. The AHERA regulations further require a re-inspection of the ACBM at least once every 3 years. The training requirements of this law extend to all commercial and government buildings as required by the Asbestos School Hazard Abatement Reauthorization Act (ASHARA).

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

1.3 ASBESTOS CONTAINING MATERIAL IN BUILDINGS Airborne asbestos contamination in buildings is a significant environmental problem. Various diseases have been linked with industrial exposure to airborne asbestos, and the extensive use of asbestos products in buildings has raised concerns about exposure to asbestos in non-industrial settings. The presence of asbestos in a building does not mean that the health of building occupants is necessarily endangered. As long as ACM remains in good condition and is not disturbed, exposure is unlikely. When building maintenance, repair, renovation or other activities disturb ACM, or if it is damaged, asbestos fibers are released creating a potential hazard to the building

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

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2.0 ASBESTOS PROGRAM POLICY The objective of this plan is to maintain a permanent record and the current status of all friable and non-friable ACM in the center’s Installation’s inventory. Document all asbestos management efforts and provide guidance for the overall asbestos management program in accordance with AFI 32-1052. Establish policies and procedures to protect the health of personnel and comply with all applicable Federal, State, and AF regulations. 2.1 BACKGROUND Asbestos is a term that describes six naturally occurring, fibrous minerals found in certain types of rock formations. Of these naturally occurring minerals, the minerals chrysotile, amosite, and crocidolite have been most commonly used in building materials. When mined and processed, asbestos is typically separated into very thin fibers, which are then combined with other materials to make a variety of products. Due to its excellent fire protection and insulation properties, asbestos was used in a wide variety of building materials and building components (Table 2) during the twentieth century. The widest use occurred from 1940-1975. However, asbestos fibers have been shown to be a health hazard when humans are exposed to concentrations of fibers above the established Occupational Safety and Health Administration (OSHA) thresholds. Personnel may become exposed to asbestos fibers in maintenance, renovation, or demolition activities where building materials that contain asbestos are involved. To protect human health, numerous federal, state, and AF regulations have been adopted. With strict adherence to these regulations and the procedures that they require, exposure of personnel to asbestos fibers should not occur. Table 2 Building Materials Found to Contain Asbestos

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

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Door insulation Stucco Mortar Concrete Swimming pool plaster Brake Pads

2.2 REGULATORY REVIEW Current regulations 1) ban outright or restrict the use of asbestos in new buildings or products, 2) specify work practices for the disturbance of asbestos-containing material, and 3) require the identification of asbestos in schools (AHERA) and in commercial and public buildings that are to be remodeled or demolished (OSHA, National Emission Standards for Hazardous Air Pollutants (NESHAP). Exposure standards exist for the workplace (OSHA) and to clear abatements in schools (AHERA). The following Federal, State, and AF regulations and laws apply to the asbestos program at Robins AFB. 2.2.1 Federal Regulations, Codes, and Standards The federal government has enacted laws for asbestos control from both environmental and occupational health standpoints through such acts as the Occupational Safety and Health Act, as amended, the Toxic Substance Control Act, as amended, and the Clean Air Act, as amended. The 29, 40, and 49 Code of Federal Regulations (CFR) series establish standards, which are intended to protect public health and the environment. Local and state regulatory agencies have enacted regulations that are equal to, if not more stringent than, federal regulations.

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

- Part 1910.1020, Access to Employee Exposure and Medical Records - Part 1910.134, Respiratory Protection - Part 1910.147, Power Lock-Out/Tag-Out Procedures - Part 1910.1001, General Industry Standard for Asbestos - Part 1910.1200, Hazard Communications - Part 1926.1101, Asbestos Standard for Construction

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

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

General Provisions - Part 61, Subpart M, Air Pollutants - NESHAP for Asbestos - Part 763, Subpart E, Asbestos Containing Materials in Schools

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

- Part 171, Hazardous Substances - Part 172, Hazardous Materials Tables and Hazardous Materials, Subparts B and C -

Communications Regulations - Part 173, Shipments and Packaging

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

• Georgia Asbestos Safety Act, Georgia Code Title 12, Chapter 12 • Emission Standard for Asbestos, Chapter 391-3-1-.02(9)(b)7 • Asbestos Removal and Encapsulation Regulations, Chapter 391-3-14 • Solid Waste Management Regulation, Chapter 391-3-4

2.2.3 Air Force and Base Regulations and Standards The Department of the AF develops instructions based on applicable federal requirements for its facilities. Each command or installation may develop more specific instructions based on state and local regulatory requirements. The following Air Force directives apply to the Robins AFB asbestos program:

• AFI 32-1052 Air Force Facility Asbestos Management • AFI 48-137 Respiratory Protection Program • AFI 90-821 Hazard Communication • Robins AFB Instruction 48-137 Respiratory Protection Program

2.3 SCOPE This AMP provides the documentation for all asbestos management efforts and the mechanism for oversight of the entire facility AMP. Also, describes how asbestos policies and procedures are to be implemented through the AOP in an efficient and cost-effective manner. This AMP is made up of the following components: 2.3.1 Roles and Responsibilities In order for the plan to be effective, numerous personnel from different organizations require both input and actions. Section 3.0 defines the roles and responsibilities of designated personnel and organizations.

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

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

2.3.4 Medical Surveillance In accordance with 29 CFR 1910.1001, (I) Medical surveillance and Air Force Instruction (AFI) 48-137, if an individual has the potential to be exposed to airborne asbestos concentrations greater than the level established by the standards, they must wear negative pressure respirators and receive medical surveillance through the occupational physical examination program. Individuals are required to receive Respiratory Protection Training. This will ensure that personnel are properly trained on the use of respirators and that respirators fit correctly. See Section 6.0. 2.3.5 Surveillance and Monitoring Asbestos materials must be monitored to ensure that they have not been damaged or have deteriorated. Asbestos inspectors will make note of any areas that need to be repaired or abated. BAPO, BAOO, and Bioenvironmental Engineering (SGPB) will determine monitoring and surveillance requirements. See Section 7.0.

2.3.6 Recordkeeping Requirements Because of the long latency period of asbestos illnesses and possible legal liabilities, all recordkeeping must be held indefinitely. Guidance is provided on procedures for documenting notification, training, medical surveillance, and periodic reassessment and surveillance; procedures for updating the asbestos data base when asbestos materials have been abated; and procedures to document previously unidentified asbestos materials. See Section 8.0.

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

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2.3.8 Work Order Process Work orders (WO) shall be submitted to CEG for abatement work to be accomplished. WO shall be approved by CEG and reviewed and coordinated by CEIE, SGPB, and the Safety Office (SE). See Section 10.0.

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3.0 ROLES AND RESPONSIBILITIES 3.1 AIR FORCE CIVIL ENGINEER CENTER – OPERATIONS DIRECTORATE, ENGINEER DIVISION (AFCEC/COS) Develops requirements and provides guidance necessary for base facility asbestos management programs. 3.2 ENVIRONMENTAL CENTER OF EXCELLENCE (AFCEC/CZ) Provides the oversight to ensure facility asbestos management is effective at each base. 3.3 78TH AIR BASE WING, ROBINS AFB 3.3.1 Base Civil Engineer Group (78 CEG) Responsibilities 3.3.1.1 The 78 CES, in coordination with the Environmental Management Branch (CEIE) and SGPB, will develop an AOP that meets the requirements identified in paragraph 7.2 of AFI 32-1052. The plan shall detail how 78 CES will implement the requirements of the Robins AFB Asbestos Management Plan. 3.3.1.2 The AFI 32-1052 identifies Civil Engineering operations, maintenance and repair activities responsibilities. A list of applicable publications including title and dates of issuance is found in Appendix A. The 78 CES in coordination with the Civil Engineer Group, Engineering Division (CEN) is responsible for the following activities associated with Facility Asbestos Management at Robins AFB:

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

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

c. Provides an effective facility manager program. An effective facility manager

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

d. Identifies and budgets for asbestos activities required for the safe execution of a

facility project. The cost of asbestos removal and disposal is a project cost and therefore must be funded from the same source as the project (O&M, DMAG, MFH,

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etc.). The one exception is a non-appropriated fund (NAF) project that requires repair, replacement, or removal of ACBM as a result of a NAF funded facility project. In this case, the asbestos repair or removal is funded with appropriated funds (APF). The reason for this is that ACBM is part of the normal building systems and as such the maintenance and repair (M&R) of normal building systems (heat system, insulating system, etc.) is an O&M responsibility. (AFI 32-1052, AFI 32-1022, AFI 32-1032)

e. Maintains and updates drawings including as-builts. These drawings (non-design

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

f. Plans and programs facility projects. Planning and programming is the identification

of facility work and the process of acquiring authority, resources, and funding necessary to accomplish the project. In order to ensure a project is adequately programmed the presence or absence of asbestos in a facility must be determined in the planning and programming stages. The programmer in coordination with 78 CES/CEOE must review “as-builts” and asbestos inventories and identify the amount and locations of asbestos in a facility scheduled for renovation, remodeling, or demolition. The planner should determine if friable asbestos would likely be disturbed as a result of the work and recommend if removal is optional or mandatory. Although the asbestos may not be disturbed during a renovation activity in which case it would not need to be removed, this should be considered as an alternative to reduce future M&R costs. Whatever option is selected the programmer must work with SGPB and CEIE to identify special requirements that would contribute to the cost of the project. Examples of the requirements could include negative air containment, special worker protection, special handling, transportation, and disposal cost. These costs must be included in the programming stage. (AFPAM 32-1005, AFI 32-1023, AFI 32-1032)

g. Ensures the design or renovation or M&R projects, including demolition, meets all

applicable standards. The design process will include review of pertinent as-built drawings, as well as preliminary and final surveys of the project site. The review and survey will include a review of the asbestos inventory and a determination of the presence or absence of asbestos. If it is decided that an Architectural-Engineering (A-E) firm will conduct the design, this initial data will be provided as part of the statement of work (SOW). The SOW must contain a requirement for the A-E to verify location and condition of ACM that could be disturbed as the result of this project. The site investigative studies to conduct field surveys, obtain design data, and prepare contract plans and specifications and cost estimates are Title I, A-E services. These studies are funded from the same fund source as the project. When

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the design drawings, specifications and cost estimate are complete, the designer will prepare a review package for appropriate organizations. The package will be sent to SGPB and CEIE for review and coordination. This will include a determination by SGPB that OSHA requirements are included and a determination by CEIE that the requirements of the asbestos NESHAP and any applicable State of local environmental requirements have been met. (AFPAM 32-1005, AFI 32-1023)

h. Provides facility project asbestos construction inspection. Asbestos construction

inspection, including verifying the work is done in accordance with applicable health, safety, and environmental regulations is a 78 CES responsibility. The asbestos construction inspector must act as the interface between the team of the design engineer, SGPB and CEIE and the contractor doing the work. The inspector also acts as the contracting officer’s technical representative (COTR). The AF has an in-house construction inspection course that covers proper removal and management of asbestos related activities. The contract Construction Inspection course includes asbestos removal requirements in the non-resident course (J7AZT3E571 01AA) through the 364 Training Squadron at Fort Leonard Wood, Missouri. If the inspector has not attended the AF course the inspector shall attend an EPA approved asbestos inspection or supervisor course and be fully trained in the requirements of asbestos removal, transportation, and disposal requirements of the asbestos NESHAP. (AFPAM 32-1005, Air Force Procedural Handbook for Managing Environmental Compliance Contracts by Construction Inspectors and Quality Assurance Evaluators)

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

a. Schedule facility reviews. Schedule a facility review with the 78 CES maintenance function as required to identify and accomplish all recurring work, minor maintenance and repair, and validate building conditions and work requirements. (AFPAM 32-1004VC, AFI 32-1052)

b. Include the SGPB and CEOE as part of the facility review process when friable asbestos

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

c. Establish a periodic schedule with the 78 CES maintenance function to inspect nonpublic

areas such as mechanical rooms. This can conveniently be done as part of the recurring work program (RWP) when heating, ventilation, and air conditioning (HVAC) systems

10



are changed from heating-cooling-heating cycles (routinely twice a year). Where friable asbestos may be damaged or is becoming deteriorated, more frequent inspections may be required. (AFPAM 32-1004V3, AFI 32-1052, AFI 91-301)

d. Work with the 78 CES maintenance function to determine if health risks are present and

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

3.3.3 Environmental Management Responsibilities (78 CEG/CEIE): 3.3.3.1 CEIE, in coordination with SGPB and 78 CES/CEOE, will develop an asbestos management plan (AMP) to meet the requirements in paragraph 5 of AFI 32-1052. The plan shall identify the roles and responsibilities for each organization involved in facility asbestos management and the procedures for continued update of the plan and the asbestos inventory/survey. 3.3.3.2 CEIE is responsible for coordination of environmental regulatory requirements and acts as the point of contact between the base and federal, state, or local environmental regulatory agencies. When facility renovation, remodeling, or demolition work is performed, the work practices must be done in an environmentally safe fashion. The work must also be done in accordance with environmental regulations. The work practices and procedures prescribed by the US EPA are found at 40 CFR 61.145, “Standard for demolition and renovation” and 40 CFR 61.150, “Standard for waste disposal for manufacturing, fabricating, demolition, renovation and spraying operations”. The US EPA has delegated oversight for the program to most states. The state may implement some requirements differently. CEIE must assist the programmer, designer, and contract inspector in identifying environmental requirements and work practices necessary to provide a complete project. Prior to start of work on any project, the contractor will provide a submittal for the asbestos removal plan. The following are the minimum federal requirements that must be coordinated for each project:

a. Determine if a threshold amount of asbestos is being removed. When a building is being

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

b. Ensure that when a design is conducted by contract, the SOW for the A-E includes a

requirement to verify location and condition of asbestos as part of the site investigative study. CEIE must work with 78 CES to provide the A-E as much data as possible to minimize the cost of the site investigation (40 CFR 61.145(a))

c. Ensure notification is provided to the administrator when threshold amounts of asbestos

are removed. CEIE will work with the design engineer and construction agent to ensure

11



that notification of intent to demolish or renovate is prepared and submitted (postmarked) to the administrator at least 10 working days prior to start of work. When the work is contracted CEIE will review the SOW to ensure this requirement is included. The SOW will include a clause that requires the contractor to provide CEIE a copy of the notification for review prior to submittal to the administrator (40 CFR 61.145(b)).

d. Review change notices. When the date of stripping/removal will begin on a date other

that the original notification, the contractor/in-house notification change notice will be provided to CEIE for coordination. The change notice must include the date of notification, how the notification was provided and the new start date of the operations. Under no circumstances will the notification date of a planned operation be less than 10 days before the start of the planned work (40 CFR 61.145(b)(3).

e. Review asbestos emissions control plan. The contractor or in-house staff will provide a

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

f. Review required environmental training records. The asbestos removal plan will include

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

g. Review waste disposal plan. The asbestos removal plan will include a standard for

asbestos waste disposal under 40 CFR 61.150 including:

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

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

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

4. Plans to mark vehicles used to transport asbestos-containing waste during loading and

offloading so that signs are visible and meet the standards of 40 CFR 61.150(c).

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

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

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

i. Verify waste shipment completion. The waste shipment record is maintained in the

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

3.3.4 Medical Services 3.3.4.1 Bioenvironmental Engineering (78 MDG/SGPB) Plays two important roles in the facilities asbestos program:

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

b. In consultation with CEIE and 78 CES/CEOE determines the best method for effective

asbestos management and ensures the procedures for protection of workers engaged in asbestos activities are in compliance with OSHA requirements.

Prior to start of work on any project that disturbs asbestos, the contractor or in-house team will provide a submittal for the Health and Safety Plan including measures for protecting workers and AF personnel from exposure to asbestos. The SGPB will review the submittal for compliance with OSHA rules and recommend approval or changes (if required) to the contractor’s submittal. SGPB will coordinate with 78 CES/CEOE, CEIE and the facility manager on all asbestos related facility evaluations and projects. The following are the SGPB responsibilities in the asbestos management program:

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

13



b. Review BCE WOs, plans, and projects to ensure occupational and environmental health

issues are addressed. This includes any self-help projects. (AFI 91-301) c. Perform an initial review of the AOP and perform periodic follow-ups on in-house

procedures for asbestos removal.

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

e. Conduct or arrange and oversee sampling, analysis and monitoring (SAM) in support of

the Installation Asbestos Facility Survey (inventory). (AFI 48-119) 3.3.4.2 Public Health 78 AMDS/SGPM Provide asbestos awareness health education/training for military and civilian personnel that may require this type of training. Education is key to effective asbestos management. CEIE, 78 CES/CEOE and SGPB all receive state approved training in asbestos as part of their job. Other employees that do need training to the same level as these functions may work in buildings that contain asbestos. These employees are custodial or maintenance personnel, facility managers or work place supervisors. The method that Public Health accomplishes this training will be addressed in the operations and management plans. 3.4 AFSC CONTRACTING (AFSC/PZ) Ensures that copies of all project notifications and required fees to the state are received as submittals, as required by Asbestos Abatement Guide Specification 01568. PZIOC (Construction Flight) and PZIOB (Services Flight) also manage architectural and engineering contracts plus all construction, demolition, and remodeling contracts. 3.5 MAINTENANCE SUPPORT GROUP (402 MXSG)

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

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4.0 NOTIFICATION This section delineates requirements for notification of contract workers, facility managers, and regulatory agencies. This guidance applies to all base buildings, work areas, recreational facilities, residences, or any other area that may contain asbestos. 4.1 ASBESTOS POINTS OF CONTACT

Points of Contact (RAC s) for the Base AMP are the BAPO and BAOO. All building renovation work must first be cleared by the BAPO. The BAPO is the point of contact for all abatement projects. This AMP will be posted on eDASH at: https://cs1.eis.af.mil/sites/edash-ins1/robins/Shared%20Documents/Toxics/Asbestos_Plan%202005.pdf 4.2 CONTRACTORS

Contract worker refers to off-base contractors or service vendors who occasionally work on base. Cable company technicians and remodeling contractors are included in this group. These personnel may unknowingly disturb ACM in the course of their work, therefore, notification of the possibility of potentially hazardous asbestos containing materials will be included in the request for proposals. 4.3 FACILITY/BUILDING MANAGERS

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

Building managers will be trained by the BAOO in the building manager training meetings. Building manager training meetings are scheduled and conducted by the Real Property Office. The BAOO will coordinate building managers training with the Real Property Office. 4.4 REGULATORY AGENCIES

CEIE is responsible for ensuring all notifications to off-base regulatory agencies are completed. Copies of these forms are maintained in the BAPO’s office. Under no circumstance should a demolition or abatement project begin without the BAPO having copies of the state notification on file. If the project involves abatement work in preparation for demolition, but the demolition work is to be performed by others, the project notification from the abatement contractor should address only the abatement activities, even if they know who the demolition contractor may be. Demolition contractors must submit a separate project notification for the work they will perform, whether or not asbestos containing materials remain or there was no asbestos. If the project is a joint abatement/demolition project under the responsibility of one contractor, then one notification is sufficient. If the contractor makes the notification, copies of the completed notification form and certified mail receipt must be provided to the BAPO—prior to the start of

15


https://cs1.eis.af.mil/sites/edash-ins1/robins/Shared%20Documents/Toxics/Asbestos_Plan%202005.pdf

https://cs1.eis.af.mil/sites/edash-ins1/robins/Shared%20Documents/Toxics/Asbestos_Plan%202005.pdf


project. The State of Georgia requires a 10-day notification for all demolition and abatement projects. The current state notification form is provided at Appendix A.

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

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

5.1 PROGRAM ADMINISTRATORS TRAINING

Personnel who serve as the BAPO are required to attend a US EPA certified Asbestos Supervisor Course. The BAOO is required to attend both the US EPA certified Asbestos Inspector Course and US EPA certified Asbestos Supervisor Course. BAOO will designate an adequate number of personnel to provide supervision and inspection duties in support of Asbestos Abatement Team. Personnel serving as management planners (e.g., Managers, Operations and Maintenance Planners, and Squadron Commanders) or their designated personnel shall attend a US EPA certified Asbestos Inspector Course and Management Planner Course.

Personnel who plan or design asbestos-related projects shall attend a US EPA certified Asbestos Supervisor Course and an annual refresher. In addition, they must attend an initial Project Design course and a Project Designer annual refresher. 5.2 CUSTODIAL AND MAINTENANCE PERSONNEL TRAINING

With proper training, custodial and maintenance staff can successfully deal with ACM in place, and greatly reduce the release of asbestos fibers. Training sessions provide basic information on how to deal with all types of maintenance activities involving ACM. However, building owners should also recognize that O&M workers in the field often encounter unusual, “non-textbook” situations. As a result, training should provide key concepts of asbestos hazard control. If these concepts are clearly understood by workers and their supervisors, workers can develop techniques to address a specific problem in the field. Maintenance personnel include carpenters, plumbers, electricians, and other craftsmen. Since these personnel are not trained in abatement and repair procedures, the purpose of the training is to aid them in recognizing and avoiding potential asbestos hazards. Properly trained custodial and maintenance workers is one of the

17



keys to a successful O&M program. 78th FSS/FSDETA will provide asbestos awareness training for custodial workers, unit environmental coordinators, facility managers, and workplace supervisors requiring level 1 training. Employees requiring level 2 and 3 training will attend a Georgia Environmental Protection Division (GA EPD) approved training facility and provide the BAPO with a copy of the employee’s training certificate. There are three levels of training based on the following information:

• Level 1: Awareness training for custodians involved in cleaning and simple maintenance

tasks where ACM may be accidentally disturbed. For example, fixing a light fixture in a ceiling covered with surfacing ACM. Training may range from two to eight hours and will include such topics as:

- Background information on asbestos; - Health effects of asbestos; - Worker protection programs; - Locations of ACM in the building; - Recognition of ACM damage and deterioration; - The O&M program for that building; and - Proper response to fiber release episodes.

• Level 2: Special O&M training for maintenance workers involved in general

maintenance and incidental ACM repair tasks. For example, a repair or removal of a small section of damaged pipe and boiler insulation, or the installation of electrical conduit in an air plenum containing ACM or ACM debris. Training generally involves at least 16 hours. This level of training usually involves more detailed discussions of the topics included in Level 1 training as well as:

- Federal, state, and local asbestos regulations; - Proper asbestos-related work practices; - Descriptions of the proper methods of handling ACM, including waste handling and

disposal; - Respirator use, care, and fit-testing; - Protective clothing donning, use, and handling; - Hands-on exercises for techniques such as glove bag work and HEPA vacuum use

and maintenance; and - Appropriate and proper worker decontamination procedures.

• Level 3: Abatement worker training for workers who may conduct asbestos abatement.

This work; involves direct, intentional contact with ACM. “Abatement worker” training courses that involve 24 to 32 hours of training fulfill this level of training. This level of training is much more involved than Levels 1 and 2, although it should include some of the same elements (e.g., health effects of asbestos). It will typically include a variety of specialized topics, such as: - Pre-asbestos abatement work activities; - Work area preparation;

18



- Establishing decontamination units; - Personal protection, including respirator selection, use, fit-testing, and protective

clothing; - Worker decontamination procedures; - Safety considerations in the abatement work area; - A series of practical hands-on exercises; and - Proper handling and disposal of ACM wastes.

In summary, good training is crucial to the success of an O&M program. Strong support for O&M training by the building owner should convince custodial and maintenance workers that following the appropriate work procedures is critical to protecting their own health as well as the health of other building occupants. 5.3 ABATEMENT WORKERS AND SUPERVISORS TRAINING

All personnel who supervise asbestos abatement/repair will be certified as abatement supervisors. This certification is obtained by receiving and passing the 40-hour US EPA certified supervisor training. All personnel engaging in asbestos abatement or repair will be certified as abatement workers. This certification is obtained by receiving and passing the 32-hour US EPA certified training. Personnel who complete these courses will receive certification of training. Copies of government personal training certificates will be given to the BAPO. Additionally, each organization will maintain and provide to the BAPO a log of all training showing the name of the person trained, type of training received, and date of training. These training records will be maintained indefinitely. A refresher course is required for asbestos abatement workers and asbestos abatement supervisors and inspectors each year. Each base organization will identify personnel who need to attend US EPA certified courses. For personnel to retain their certification, the training center providing the refresher training must be US EPA approved. As with the original certificate of training, a photocopy of the refresher course certificate will be given to the BAPO. 5.4 BUILDING INSPECTOR TRAINING

Personnel serving as Building Inspectors shall attend a US EPA certified Asbestos Inspector Course and an annual refresher.

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6.0 MEDICAL SURVEILLANCE AND PERSONAL PROTECTION Personnel who are exposed to airborne asbestos concentrations greater than the action level and/or the excursion limit, or as determined by SGPB, or who are required to wear negative pressure respirators, will receive medical surveillance through the occupational physical examination program (AFI 48-123; AFI 48-137, and OSHA). 6.1 RESPIRATORY PROTECTION PROGRAM The respiratory protection program will be administered by SGPB in accordance with AFI 48-137 and 29 CFR 1926.1101(h). Administration of the Respiratory Protection Program includes work area evaluation, respiratory protection selection, respiratory protection training, and respiratory fit testing. SGPB will perform these functions. 6.2 OCCUPATIONAL PHYSICAL EXAMINATION PROGRAM

The occupational physical examination program will be administered by Occupational Medicine in accordance with AFI 48-123, AFI 48-137 and 29 CFR 1926.1101(m). Work histories, medical histories, and patient questionnaires (DD Form 2493-1 and 2493-2) will be initiated at the time of the first physical examinations. Work histories, medical histories, and patient questionnaires referred to above are those specified by AF policy. 6.3 RECORDS OF MEDICAL SURVEILLANCE

To aid the BAOO in the management of the Base Asbestos Program, a Medical Surveillance Log showing the dates of respiratory protection training, respiratory fit testing, physical examinations, and the medical certification of the employee will be kept by Occupational Medicine. A copy of these records will be retained by BAOO.

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7.0 REASSESSMENT, SURVEILLANCE, AND ANNUAL AIR MONITORING As ACBM deteriorates or become damaged through routine maintenance, an asbestos hazard may be created. Reassessment, surveillance, and area air monitoring are required to identify these types of hazards so that control actions can be taken. 7.1 REASSESSMENT

SGPB, 78 CES/CEOE, and CEIE will reassess friable ACM annually. The BAPO will be responsible for preparing a list to be reassessed. There is an option available as needed to contract out the reassessments. Inspectors performing these reassessments must be trained as building inspectors.

During the reassessment, the inspector will:

• Visually re-inspect and re-assess the condition of all known or assumed friable ACM; • Document any changes to the previous assessment; • Ensure asbestos is labeled with an asbestos danger label; and • Document changes to the Base Register and the case file folder in CEIE.

7.2 ANNUAL AIR SAMPLING

29 CFR 1910.1001 requires air sampling in areas where exposure to asbestos may occur. SGPB will perform the air sampling. Area air sampling will be conducted in work areas containing material with friable ACM with a potential for release.

The Annual Area Air Sampling Report Form will contain the following information:

• Building number • Room number • Condition of ACM • Method of analysis • Result of the area samples

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8.0 RECORDKEEPING - GENERAL REQUIREMENTS 8.1 DATA COLLECTION The asbestos database is the single source of reference for a consolidated summary of information on the status of ACM in buildings at Robins AFB. It contains data on the location of the ACM within a facility, the type of asbestos, the percentage of asbestos composition in the ACM, the condition of the ACM, and whether it has sustained damage. The importance of maintaining accurate, up-to-date information in the database makes it essential to have a standardized process to acquire information on any facility activity, which may affect the status of ACM. The most recent version of the database will be maintained by the BAPO. The BAPO will maintain historical information of individual inspection surveys and SGPB maintains analytical reports. 8.2 THE ASBESTOS RECORD The BAPO will maintain and update the asbestos records as required. These records are located in filing cabinets on the west wall in the AFCEC area and in the Toxics Data Base located at this link: https://geobase.robins.af.mil/toxics/ . The asbestos records are comprised of the following components :

• Asbestos Database, • O & M asbestos activities file, • Asbestos project file, • Asbestos certification file, and • Asbestos training file.

8.3 ASBESTOS MANAGEMENT PLAN CHANGE CONTROL This Robins AFB AMP must be accurately maintained to show all measures are taken to control exposure to airborne asbestos fibers. Therefore, when changes in policy are required, the plan must be revised accordingly. The Toxics Integrated Process Team (IPT) will review and approve the proposed changes. Key personnel such as the BAPO, BAOO, and representatives from SGPB shall be included. 8.4 ASBESTOS DATABASE The asbestos database documents all areas where material was sampled and asbestos was found to be present. The BAPO will maintain the asbestos database. The information will be used by base personnel to identify the location of asbestos. Procedures will be established to keep the database up to date. The asbestos database lists every known location of ACM on the base. The BAPO, BAOO, and/or SGPB must be contacted if there is any doubt whether a material contains asbestos. The asbestos database requires the following information--as collected via the building inspection form:

• Building number

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https://geobase.robins.af.mil/toxics/


• Location in building • Name of inspector • Inspector EPA # • Date of inspection; • Building number, room number, specific location • Sample identification number • Description of material samples • Amount of ACM • Priority ranking of identified ACM • Type and percentage of asbestos in ACM.

8.5 ASBESTOS PROJECT FILE The BAPO will maintain permanent “facility” asbestos files containing detailed documentation of asbestos activities performed on base. These files will be maintained indefinitely and will include the following:

• Certifications and licenses of contractor personnel conducting asbestos work; • Descriptions of all asbestos abatement activities performed, including dates, type of

remediation, personnel involved, quantity of asbestos involved, disposal method and location, and results of post-control activity inspection and sampling;

• Copies of notification forms sent to the GA EPD regarding asbestos activities; • Documentation and correspondence related to disposal (e.g., landfill receipts, manifests); • Copies of daily inspection logs and industrial hygiene reports from contractors who have

performed work involving ACM; • Detailed reports of bulk sampling data if accomplished by a contractor; • Air monitoring exposure measurement data; • Employee, contractor, public, and occupant notification procedures; • Work schedules and abatement plans; • Contract drawings and specifications; • Correspondence dealing with asbestos on the project; and • Other relevant reports, studies, and information such as fiber release episode

documentation as deemed necessary by the BAPO, BAOO, or SGPB.

8.6 RECORDS RETENTION

All records will be maintained for 40 years by the using organization with copies distributed to appropriate offices.

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9.0 EMERGENCY RESPONSE PLAN Exposure conditions can occur as long as ACM is present in a building. The potential exists for the release of asbestos fibers from physical damage to the asbestos, deterioration of the ACM, and the actual separation of the ACM from the structure, resulting in potential exposure to the building occupants. Local education agencies are required to identify asbestos-containing materials in their school buildings and take appropriate actions to control releases of asbestos fibers and describe their activities in a management plan, and reports under the Department of Defense Education Activity. The purpose of providing emergency response procedures is to outline basic steps necessary to clean up and dispose of the problem. Where minor or major fiber release episodes, as defined below are found, they shall be reported to the BAPO. The episode will be documented on the appropriate form at Appendix A. 9.1 EMERGENCY RESPONSE When a contractor or base personnel disturb asbestos materials unknowingly, notify 78 CEG/CES, SGPB, and CEIE. Immediate response from CE (BAOO) is necessary to document incident, initiate repair and/or removal actions per the AOP. 9.2 MINOR FIBER RELEASE EPISODE (40 CFR 763.91(F)(1)) A minor fiber release episode is the falling or dislodging of 3 square or linear feet or less of friable ACM. The following procedures will be followed in the event of a minor fiber release episode:

• Immediately evacuate the area of concern and turn off HVAC • Thoroughly saturate the debris using wet methods. • Clean the area, using asbestos cleanup standards as described in 40 CFR Part 763. • Place the asbestos debris in a sealed, leak-tight container. • Repair the area of damaged ACM with materials such as asbestos-free spackling, plaster,

cement, or insulation, or seal with latex paint or encapsulant. 9.3 MAJOR FIBER RELEASE EPISODE (40 CFR 763.91(F)(2)) A major fiber release episode is the falling or dislodging of more than 3 square or linear feet of friable ACM. The following initial procedures will be followed in the event of a major fiber release episode:

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

• Shut off or temporarily modify the air-handling system to prevent the distribution of fibers to other areas in the building.

• The response action for any major fiber release episode must be designed by persons accredited to design response actions and conducted by persons accredited to conduct response actions.

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9.4 ECONOMIC CONSIDERATIONS Removal is justified. When budget allows, removal should be the option chosen. Complete removal should also be chosen when a building will be completely renovated. Removal can be accomplished either in-house or by an abatement removal contractor. Environmental Compliance Program funds can only be used for emergency health related projects. If asbestos removal is only coincidental to a renovation or demolition project, the asbestos removal cost must be included in the contract cost. The removal cannot be funded with ECP funds. Because asbestos removal can be very expensive, it is important to include cost of asbestos removal so that adequate funds will be available to prevent project delay. 10.0 ASBESTOS WORK ORDER PROCESS The building manager/custodian generates the AF Form 332, Base Civil Engineer Work Request and forwards to CE when construction projects and/or asbestos removal are necessary within their facility. If the presence of asbestos is known by the building manager/custodian it should be documented on the Form 332. 10.1 WORK REQUESTS Work requests are for the purpose of facility maintenance/updates or removing asbestos. Once the work request is received, CEOE/BAOO will establish procedures for identifying potential asbestos issues related to the project. Should the project have a potential to disturb ACM, CEOE will:

• Initiate the building inspection tour (78 CES/CEOE, CEIE, SGPB, and building custodian);

• Document on Asbestos Building Inspection Worksheet; • Gather samples of material suspected to contain asbestos; • Obtain a sample number from the CEIE tracking system; • Send samples to certified lab for analysis—if results are positive for asbestos;

o Decide whether the removal will be done in-house or by contract; o Provide CEIE with project information for state notification or the certified mail

receipt where the notification has been made by the abatement contractor—at least 10 days prior to start of project;

o Forward revision information should changes be made to project; o Provide completed Special Waste Acceptance Application form along with lab

analysis for Toxic Characterization Leachate Procedure results to the CEIE Solid Waste Program Manager for disposal approval at least 5 working days prior to disposal;

o Ensure disposal manifest along with disposal receipts are returned in a timely manner or notify CEIE Asbestos Program Manager if not received; and

o Enter project information and track on excel spreadsheet.

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10.2 WORK REQUESTS REVIEW PROCESS Work requests shall be coordinated by CEIE, SGPB, and SE, and then approved by CEOE. 10.3 WORK REQUESTS TRACKING SYSTEM All work requests are assigned a WO Number by CEOE and then tracked through a data base so the project status is available at all times.

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APPENDIX A

A-1



A-2



A-3



A-4



A-5



A-6



A-7



A-8



A-9



A-10



A-11



A-12



ASBESTOS MANAGEMENT PLAN (DEC 2014)

A-13


78th CIVIL ENGINEER

GROUP

ASBESTOS OPERATING

PLAN

ROBINS AIR FORCE BASE

OPR: 78 CES/CEOE

January 2015

Table of Contents

SECTION I. PURPOSE OF THE PLAN. ............................................................ 5

1. The purpose ......................................................................................................................... 5 2. This operating plan applies to ............................................................................................. 5 3. Permissible Exposure Limits .............................................................................................. 5

SECTION II. ORGANIZATIONAL RESPONSIBILITIES ............................... 6

2. The 78 ABW Commander .................................................................................................. 6 2.1 AFI 32-1052 Facility Asbestos Management ..................................................................... 6 2.2 The Base Civil Engineer (BCE) 78 CEG ............................................................................ 6 2.3 Bioenvironmental Engineering (SGPB) 78 MDS/SGPB .................................................... 6 2.4 Environmental Management (CEIE) .................................................................................. 7 2.5 Ground Safety (SEG) .......................................................................................................... 7 2.6 Record Keeping .................................................................................................................. 7

SECTION III. CONTRACTING AND IN-HOUSE PROCEDURES ................ 9

3. Contract procedures. ........................................................................................................... 9 3.1 In-house procedures ............................................................................................................ 9 3.2 AFTER Duty Hours Emergencies. ..................................................................................... 9 3.3 Routine asbestos abatement activities ............................................................................... 10 3.4 Self-Help Procedures ........................................................................................................ 10 3.5 Asbestos disposal procedures. .......................................................................................... 10 3.6 Labor Utilization Codes for Asbestos Work ..................................................................... 10

SECTION IV: ASBESTOS ABATEMENT PROCEDURES AND EQUIPMENT .........................................................................................................11

4. Controls and Work Practices ............................................................................................ 11 4.1 ACM: Friable ................................................................................................................... 11 4.2 Non-Friable ....................................................................................................................... 11 4.3 Small-Scale, Short-Duration ............................................................................................. 11 4.3.1 Pipeline & Fitting Insulation ............................................................................................. 12 4.3.2 Boiler, Breeching or Tank Insulation................................................................................ 12 4.3.3 Surfacing Material (Plaster, Drywall, Fireproofing) ......................................................... 13 4.3.4 Floor covering: .................................................................................................................. 14 4.3.5 Transite: ............................................................................................................................ 14 4.4 Large-Scale Asbestos Abatement: .................................................................................... 14 4.5 Equipment and Supplies ................................................................................................... 15

SECTION V: ANNUAL BUDGET REQUIREMENTS ....................................16

5. Operating Budget .............................................................................................................. 16

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5.1 Training ............................................................................................................................. 16 5.2 Equipment ......................................................................................................................... 17 5.3 Budget request process ..................................................................................................... 17

SECTION VI: TRAINING REQUIREMENTS .................................................18

6. EPA and OSHA ................................................................................................................ 18 6.1 Asbestos Abatement Worker ............................................................................................ 18 6.2 Supervisor/Competent Person ........................................................................................... 18 6.3 Project Designer: ............................................................................................................... 18 6.4 Management Planners: ...................................................................................................... 18 6.5 Building Inspectors : ........................................................................................................ 18 6.6 Asbestos Awareness: ........................................................................................................ 18 6.7 The onsite supervisor ........................................................................................................ 19 6.8 Topics ................................................................................................................................ 19 6.9 Training Coordination ....................................................................................................... 20 APPENDIX

APPENDIX A Asbestos Survey Funding.............................................................21

APPENDIX B Air Force Instruction ...................................................................30

APPENDIX C ACRONYMS ................................................................................38

References

Title 29, 40, and 49 Code of Federal Regulations (CPR) series establish standards, which are intended to protect public health and the environment. Local and state regulatory agencies have enacted regulations that are equal to, if not more stringent than, federal regulations. • Title 29 CPR, U.S. Department of Labor, Occupational Safety and Health Administration

(OSHA) Standards - Part 1910.1020, Access to Employee Exposure and Medical Records - Part 1910.134, Respiratory Protection - Part 1910.147, Power Lock-Out/Tag-Out Procedures - Part 1910.1001, General Industry Standard for Asbestos - Part 1910.1200, Hazard Communications - Part 1926.1101, Asbestos Standard for Construction

• Title 40 CFR (Code of Federal Regulations) United States Environmental Protection Agency (US EPA) Standards - Part 61, Subpart A, National Emission Standard for Hazardous Air Pollutants - General

Provisions

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- Part 61, Subpart M, Air Pollutants - National Emission Standards for Hazardous Air Pollutants (NESHAP) for Asbestos

- Part 763, Subpart E • Title 49, CFR, U.S. Department of Transportation (DOT) Standards.

- Part 171, General Information. Regulations, and Definitions - Part 172, Hazardous Materials Tables, Special Provisions, Hazardous Materials

Communications, Emergency Response Training Information and Requirements. - Part 173, Shippers-General Requirements for Shipments and Packaging

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

• Georgia Asbestos Safety Act, Georgia Code Title 12, Chapter 12 • Emission Standard for Asbestos, Chapter 391-3-l-.02(9)(b)7 • Asbestos Removal and Encapsulation Regulations, Chapter 391-3-14 • Solid Waste Management Regulation, Chapter 391-3-4

The Department of the Air Force (AF) develops instructions based on applicable federal requirements for its facilities. Each command or installation may develop more specific instructions based on state and local regulatory requirements. The following AF directives apply to the Robins Air Force Base (AFB) asbestos program:

• AFI 32-1052, Air Force Facility Asbestos Management, • Air Force Occupational Safety and Health Standard (AFOSH STD), 48-137 Respiratory

Protection Program, • AFI 90-821 Hazard Communication Facility Asbestos Management, • Robins AFB Instruction 48-137, Respiratory Protection Program,

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SECTION I. PURPOSE OF THE PLAN.

1. The purpose of this operating plan is to define organizational roles, responsibilities and procedures in training, Personal Protective Equipment (PPE), handling, repair, removal, and/or disposal of asbestos containing material (ACM) in Operations and Maintenance (O&M) procedures for 78 Civil Engineer Group (CEG).

2. This operating plan applies to real property. Emergency asbestos abatement projects involving non real property, i.e. brake shoes, file cabinets, aircraft parts or equipment must be coordinated through the Base Civil Engineer (BCE), Environmental Management (CEIE), and Bioenvironmental Engineering (SGPB). Emergencies are defined as immediate damage to or interruption of Air Force resources.

3. Permissible Exposure Limits (PELS) shall be maintained in accordance with OSHA 1926.1l0l(c). The employer shall ensure that no employee is exposed to an airborne concentration of Asbestos in excess of 0.1 fiber per cubic centimeter (0. lf/cc) of air in an eight hour time weighted average (TWA) or the excursion level (EL) of lf/cc in 3.

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SECTION II. ORGANIZATIONAL RESPONSIBILITIES

2. The 78 ABW Commander is responsible for the enforcement of Asbestos laws and regulations.

2.1 AFI 32-1052 Facility Asbestos Management, Section A Program Requirements, paragraph 3.3 provides for the implementation of organizational responsibilities as described below. The locations of detailed responsibilities are listed after each bullet.

2.2 The Base Civil Engineer (BCE) 78 CEG, as outlined in AFI 32-1052, has the following responsibilities:

• Maintain the organizational process for carrying out asbestos-related work. (See Section 3 of this plan for details)

• Ensure training programs for squadron personnel are maintained to comply with organizational mission requirements. (Sec Section 4 and 6 of this plan for details)

• Maintain an inventory of equipment and supplies for in-house asbestos abatement, sampling, and personnel protective equipment. (See Section 4 of this plan for details)

• Identify manuals and written documents for worker's safe removal and disposal of ACM. (Sec Section 6 of this plan for details)

• Provide for justification for yearly budget requirements. (Sec Section 5 of this plan for details)

• Establish procedures for asbestos-related control measures and emergency response actions. (See Section 3 of this plan for details)

• Provide disposition statements and certification on programming documents (See Section 2.5 of this plan for details).

• Supervise as needed a special response team known as the "A-Team"; team members will be made up of volunteers from squadron personnel. (See Section 3 of this plan for details)

• Conduct in-house inspections. (See Section 2.4 - CEIE of this plan for details) • Maintain contracts for analyzing, abating, and disposal of ACM. (Sec Section 3.5 of this

plan for details) • Shall establish an inspection, compliance, and enforcement program as necessary IAW

AFI 32-1052 par 6.

The BCE shall appoint a Base Asbestos Operations Officer (BAOO), to carry out these duties including corrective action and recommending disciplinary action as appropriate for the 78 CEG asbestos activities.

2.3 Bioenvironmental Engineering (SGPB) 78 MDS/SGPB, provides air-sampling support for CE in-house asbestos abatement personnel. This sampling consists of pre-abatement area sampling, personnel air sampling, abated area sampling, and final clearance sampling.

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SGPB works with CE supervisors to monitor all parts of the abatement process to ensure CE team members are following current industrial hygiene standards for asbestos workers. The SGPB shall be contacted prior to any O&M operation that will disturb ACM. A representative from SGPB should inspect all O&M projects to ensure:

• Required personal air monitoring is done per regulatory guidelines

2.4 Environmental Management (CEIE), 78 CEG/CEIE is the primary organization dedicated to assisting the base and its tenants with guidance and compliance for all environmental issues. This includes maintaining asbestos condition, location, and bulk sampling records; providing assistance in obtaining approved training for in-house personnel. To ensure accuracy, all asbestos abatement activity will be coordinated through CEIE. CEIE also provides limited funding for environmental compliance work. This organization will also provide an updated record of facilities with asbestos and the condition code of the material to the BAOO for the annual in-house inspection.

2.5 Ground Safety (SEG) will provide guidance to the BAOO and the site supervisor at the asbestos abatement site on ladders and scaffolding, confined spaces, lock-out/tag-out, and other safety related issues.

2.6 Record Keeping. Several federal, state, and local regulations apply to record keeping for asbestos- related operations. CEIE implements the system of documenting and recording all information relating to asbestos and asbestos abatement in the buildings under its control. The Asbestos Management Plan (AMP) describes in more detail the Record keeping responsibilities for CEIE. SGPB maintains records on all air monitoring performed on employees exposed to ACM. The records must include the following information:

• Date monitoring was performed • Operations involved causing exposure to asbestos • Sampling and analytical methods used and evidence of their accuracy • Number, duration, and results of samples taken • Type of respiratory protective devices worn by employees • Name and social security number of personnel monitored

All exposure measurements must be made available to the affected employees, their designated representatives, or OSHA for examination and copying. These records are to be maintained for the duration of employment plus 30 years. (Reference OSHA 1926.1101(n)(2)(iii)

All employee-training records are to be maintained for 1 year beyond the last date of employment by that employer. All records, upon request, shall be made available to designated federal state or employee's representatives as well as the employee for examination. (Reference OSHA 1926.1101(n) (4) & (7)

Medical monitoring and respirator fit testing are yearly requirements for abatement workers, supervisors (competent person), and inspectors. Under 1926.1101(n)(2)(iii) the employer shall maintain this record for at least thirty (30) years.

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ACM disposal forms will be submitted to CEIE for permit processing. Once the permit number is assigned; containerized asbestos waste is signed over to the transporter for waste acceptance. The form must then be signed over to a disposal site operator to transfer responsibility for the asbestos waste. A copy of the weight ticket, signed by the disposal site operator, shall be given to the BAOO and maintained in the asbestos file. (Reference Robins AFB Asbestos Management Plan)

BAOO will maintain all in-house asbestos abatement team records and all events associated with any asbestos project. Entries will include, at a minimum, time of arrival at site, starting and completion times of separate phases, the time and name of any individual who enters the abatement area, the types of respirators used, the type of decontamination system used, and any other significant event.

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SECTION III. CONTRACTING AND IN-HOUSE PROCEDURES

3. Contract procedures. NOTE: Contract procedures follow the same tracking line whether emergency or not. Authority for this procedure is located in AFI 32- 1052 Section B Program Management, par. 6. The 78 CES Customer Service Office (CSO) will receive AF Form 332, BCE Work Request (332), from the organization requesting work and then accomplish the following:

• Validate and approve work requests. • Determine how work will be funded. • Refer all asbestos work requests to Maintenance Engineering, BAOO. • The BAOO shall verify the presents of asbestos containing material (ACM). • Suspect material for asbestos will be sent by the BAOO to 802nd MXSS/M XDTD,

Chemical Analysis Flight, or Certified Laboratory. • Laboratory analysis is returned to BAOO. • BAOO assigns a con tractor or base engineers with instructions consistent with this plan.

Work will then be processed for a Contracting, or the SABER Contractor. The BAOO shall coordinate on all contracts to include but not limited to MILCON, Army Corps of Engineers or IDIQ work. If work is hated on a contract due to the discovery of ACM, the CE contracting official/inspector/engineer shall immediately contact the BAOO. The BAOO will advise them on recommended clean-up or abatement procedures. Funding for the additional expense will be determined on a case-by-case basis.

3.1 In-house procedures. Small scale, short duration emergencies for friable ACM are defined as removal of less than 160 square feet or 260 linear feet of ACM, where the ACM has contaminated and caused immediate damage to, or mission interruption of, Air Force Resources. CSO receives notification of friable ACM contamination from the facility custodian, generates an emergency work order, and CSU notify the following:

• The BAOO 6-3011. • The zone/shop that is responsible for the work location. • Environmental Management (CEIE) 7-3976 • Bioenvironmental Engineering (SGPB) 7-7555

The BAOO and shop foreman will decide the best course of action, concurrence with CEIE, SGPB, and SEG. 78 CEG resources are limited to render friable ACM emergencies to a safe environment until contract service can be obtained.

3.2 AFTER Duty Hours Emergencies. CSO opens a Job order and notifies the Duty Officer (DO). The following are also notified: the BAOO, SGPB and CEIE. The DO decides whether to notify the BCE and the Chief of Operations. CSO notifies the appropriate shop supervisors of the affected area. The Operations Flight Chief will make the determination as to whether in-house personnel or the on-call contractor will perform the abatement.

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3.3 Routine asbestos abatement activities. A Work request (AF Form 332) is submitted to the CSO. A work order number is assigned and the 332 is coordinated for signatures from health, fire, safety, and environmental sections. The BAOO then receives the work request, visits the site, and plans the project for performance by a contractor.

3.4 Self-Help Procedures. Individuals using self-help procedures to do remodeling will ensure an AF Form 332, is completed and submitted to CSO. CSO will review customer's request and coordinate with the BAOO to ensure ACM, if present, will not be disturbed during the course of the project. If asbestos will be disturbed, the BAOO will determine, based on funding, whether the abatement project will be contracted. If funding disallows the abatement project, the BAOO will suggest any available alternative options.

3.5 Asbestos disposal procedures. Asbestos will be thoroughly wet with amended water before being placed in a 6-mil bag, wrapped, or drummed. Plastic used shall be at least 6-mil in thickness. Contents of the bag will not exceed two-thirds full. Collapse bags with high efficiency particulate air (HEPA) vacuum and seal bags by twisting neck tight and wrapping with several layers of duct tape, utilizing the "Goose Neck" procedure. Double bag ACM and repeat sealing procedure (Methods of Compliance, OSHA 1926.ll0l (g). Deliver bags of ACM to the BAOO shop along with a completed waste manifest. The BAOO will ensure proper labeling (waste generator label, ACM signage, and DOT labeling) and disposal in an EPA approved site. All packaging must have the following information attached to the outside of the container:

• Date of removal, • Building number and location of removal, • Remover’s name and Robins AFB, GA 31098.

Likewise, the Other Regulated Material, E class, (ORM-E) IAW 49 CFR 173.500(a)(5), decal must be affixed to the outside of the container. ACM will be transported in an enclosed vehicle from the removal site to the temporary refuse storage container, normally located at Building 1348. ACM will not be allowed to stay in vehicles or buildings overnight. The service contract for the refuse storage container shall be the responsibility of 78 CES, Service Contract Flight.

3.6 Labor Utilization Codes for Asbestos Work. All asbestos abatement projects performed by in-house personnel will be assigned shop code 403, set up specifically to identify the hours spent on asbestos abatement work.

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SECTION IV: ASBESTOS ABATEMENT PROCEDURES AND EQUIPMENT

4. Controls and Work Practices: Maintenance personnel who will disturb ACM must be trained in accordance with (IAW) OSHA 1926.l10l (k)(9) and EPA 40 CFR 763 and Section VI. Respiratory protection will only be issued after medical approval. Personal Protective Equipment (PPE) is issued from the BAOO. The proper wear of PPE is required. Evidence suggests that the use of certain engineering and work practice controls can reduce exposure to asbestos. OSHA 1926.1l0l (g), Methods of Compliance and EPA 763.91 covers these requirements. The work practices and controls include:

• Wet methods • Removal methods • Use of glove bags • Removal of entire asbestos insulated pipes or structures • Use of mini-enclosures • Enclosure of asbestos materials • Maintenance programs

Use of glove bags, and regardless of the abatement method used, wet methods shall be used when disturbing ACM. Handling ACM wet is one of the most reliable methods of ensuring that asbestos fibers do not become airborne. Only in cases where asbestos work must be performed on live electrical equipment, on live steam lines, or i n other areas where water will seriously damage material or equipment may dry removal be performed. Amended water or other wetting agent should be applied by means of an airless sprayer to minimize the extent to which the ACM is disturbed. ACM should be kept wet from the start of the maintenance or renovation activity and should be re-wet continually through the course of work until final disposal.

4.1 ACM: Friable ACM means any material containing more than 1% asbestos that when dry can be crumbled, pulverized, or reduced to powder by hand pressure.

4.2 Non-Friable ACM. Non-friable ACM is defined as any material determined to contain 1% or more of asbestos using EPA prescribed analysis methods and when dry cannot be crumbled, pulverized, or reduced to powder by hand pressure. This definition has been broken into Category Non-friable ACM and Category II Non-friable ACM.

• Category Non-friable ACM: Asbestos-containing packing, gaskets, real tent flooring and asphalt roofing products containing l% or more asbestos.

• Category II Non-friable ACM: Any material excluding Category I non-friable ACM, containing 1% or more asbestos, that when dry cannot be crumbled, pulverized or reduced to powder by hand pressure

4.3 Small-Scale, Short-Duration: (Reference 40 part 763 Subpart E, I A Definitions 8.) Small-Scale, Short-Duration Asbestos Renovation and Maintenance Activities. The type of material and extent of damage will dictate the specific work practices to be utilized. The

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following arc general O&M procedures for the cleaning, repair, and removal of the common types of ACM's.

4.3.1 Pipeline & Fitting Insulation Cleaning procedures:

• Restrict access to work area • Do not disturb intact material • HEPA vacuum all surfaces • Mist area and wet wipe or wet mop area with disposable rags and/or mops and mop heads

Repair procedures for severely damaged material:

• Restrict Access to work area • Pre-clean immediate work area utilizing HEPA-vacuum and wet wipe methods on local

surfaces, not disturbing damaged material • Lay 6-rnil plastic sheeting under work area; 2 trained workers are required for this

operation • Install glove bag (6-mil thick) air tight around damaged area; insert spray wand and

HEPA-vacuum nozzle (Negative air removal should be used when possible) • Thoroughly wet all ACM with penetrating amended water via inserted spray wand • Utilizing enclosed tools remove damaged material, wetting thoroughly, place material at

the bottom of glove bag • Thoroughly clean surfaces of fixtures where ACM was removed • Clean interior of glove bag so that all material collects at bottom • Encapsulate entire work area • Twist, seal, and cut ACM containing portion of glove bag away from fixture • Collapse glove bag with HEPA-vacuum • Dispose of entire glove bag as ACM waste in a separate disposal bag

Repair Procedures for Minor Damaged Material:

• Pre clean area using HEPA-vacuum to remove all loose dirt and debris • Lay 6-mil plastic sheeting under work area • Mist and wet area with amended water • Encapsulate damaged areas with bridging encapsulant • Cover all exposed ACM with wetable cloth or equivalent • Fold up any debris in plastic sheeting and dispose of in labeled 6-rnil disposal bag

(double bag all ACM waste)

4.3.2 Boiler, Breeching or Tank Insulation Cleaning procedures:

• Restrict access to work area • Do not disturb intact material

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• HEPA vacuum all surfaces and loose debris • Mist area and wet-wipe or wet-mop area with disposable rags and mop heads

Repair Procedures for severely damaged material

• Restrict access to work area • Pre-clean work area utilizing HEPA-vacuuming and wet wiping • Lay 6-mil plastic sheeting under work area to act as a drop cloth • Thoroughly wet all damaged material with amended water • Carefully cut away and dispose of damaged material • HEPA-vacuum and wet wipe work area • Encapsulate all remaining ACM with bridging or penetrating encapsulant • Thoroughly clean work area • Dispose of all waste material in properly labeled 6-rnil disposal bag (double wrapped or

bagged) • Apply substitute non-ACM replacement materials

Repair Procedures for Minor Damaged Material:

• Pre clean area using HEPA-vacuum to remove all loose dirt and debris • Lay 6-mil plastic sheeting under work area • Mist area with amended water and HEPA-vacuum • Encapsulate damaged areas with bridging encapsulant • HEPA-vacuum and wet wipe work area

4.3.3 Surfacing Material (Plaster, Drywall, Fireproofing) Cleaning procedures:

• Do not disturb intact material • Restrict access to work area • Mist area with amended water and HEPA-vacuum • Wet wipe or wet mop area with disposable rags or mop heads • Dispose of all debris and cleaning materials that cannot be decontaminated in properly

labeled 6-mil disposable bags

Repair Procedures:

• Restrict access to the work area • Pre clean work area by HEPA-vacuuming and wet wiping • Lay 6-mil plastic sheeting as drop cloth • Thoroughly mist affected area with amended water • Utilizing a HEPA vacuum equipped with a cone attached, carefully mist and scrape

material into cone attachment • Clean and encapsulate work area • Fold up polyethylene sheeting and dispose of all waste as ACM • HEPA vacuum and wet wipe work area

Note: Contact the BAOO for guidance i f damaged surfacing materials are encountered.

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Repairing damaged surfacing material such as blowing on fireproofing or acoustical plaster, which is highly friable, exceeds the scope of O & M work. Due to its nature it is often difficult to control fiber releases without a negative pressure enclosure. Careful consideration must be given before repair of damaged surfacing material begins.

4.3.4 Floor covering: Repair and Cleaning:

• Restrict access to work area • Mist area of damage with amended water • Pick up loose broken pieces of material and place i n 6 mi l disposal bags and double bag • HEPA vacuum and wet wipe area • Replace removed material with non-ACM substitute material • Refrain from activity that would disturb the material such as drilling, sanding, grinding,

or high speed buffing. OSHA has approved chemical, dry ice, and similar types of Tile and mastic removal.

4.3.5 Transite: Repair and Cleaning:

• Restrict access to work area • Refrain from actions that would disturb the material such as drilling, sanding, grinding, or

high speed buffing. If pipe has to be cut or sawed, the task will be performed in side a glove bag using OSHA prescribed guidelines.

• Pick up loose broken pieces of material and place in ACM disposal bag • Coat damaged area with a bridging encapsulant • HEPA-vacuum and wet wipe work area

4.4 Large-Scale Asbestos Abatement: Reference 29 CFR 1926.1101 Full containment, negative pressure with a minimum of a three-stage decontamination unit will be used. Workers performing abatement work shall enter and exit the regulated area through the decontamination area. The clean room shall be equipped with a locker or appropriate storage container for each employee's use. Shower facilities shall be provided to comply with 29 CFR 1926.101l (g). See also 29 CFR 1910.14l (d) (3).

The equipment room should be fully supplied with impermeable, labeled bags and containers for the containment and disposal of contaminated protective clothing and equipment.

Decontamination area entry procedures shall be that all personnel enter the decontamination area through the clean room, remove and deposit street clothing within a locker provided for their use in the clean room, and put on protective clothing and respiratory protection before leaving clean room. Tight fitting swim suits and swim caps maybe worn underneath the PPE.

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Decontamination area exit procedures are as follows:

• Employees remove their protective clothing in the equipment room and deposit it in labeled impermeable bags or containers.

• Employees will remove their respirators in the shower after thoroughly washing their head, shoulder and exterior of the respirator.

• Employees will change into street clothes in the clean room.

4.5 Equipment and Supplies The BAOO will maintain and make available the following items IAW AFI 32-1052:

• Respirators, half and full face, negative pressure • Filters • HEPA filtered vacuum cleaners, wet/dry • Wire brushes • Portable water sprayers • Wire cutters • Utility knives • Scrapers • Paintbrushes • Scrub brushes • Tin snips • Electrical extension cords with G.F.I . • Ladders, wood or fiberglass • Negative air machines • Negative pressure manometers • Disposable coveralls • HEPA respirator cartridges • Gloves • Glove bags • Duct tape • Wetable cloth • Polyethylene plastic sheeting • Disposable rags • Wetting agents (surfactants) • Approved plastic disposal bags • Warning signs • Encapsulant - sealing, bridging and penetrating

Funding for the above listed items is IAW O&M funding for Civil Engineering found in AFI 65-601, Budget Guidance and Procedures.

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SECTION V: ANNUAL BUDGET REQUIREMENTS 5. Operating Budget. Asbestos abatement activities and required record keeping necessitate ongoing commitment of resources to meet applicable regulations. The cost of administering a facility-wide asbestos operations plan includes such items as:

• Training • Immediate response team (A-Team) • Medical monitoring • Centralized asbestos management center • Annual surveillance • Equipment and supply costs • Computer support • Re-inspection as needed of surveillance areas • Laboratory analysis • SGPB respirator fit testing and training (for asbestos operations) • Asbestos Containing Building Material (ACBM) repair documentation • ACBM removal documentation • ACBM-related construction monitoring • ACBM-related demolition monitoring • Contract specification review and preparation, and • Military Contract Projects and O&M contract surveillance on ACBM-related work.

Subsequent year operating budgets will decrease in terms of constant value dollars because high-priority hazard locations would already have been remedied. The time and money required will continue to decrease as the goal of the asbestos-hazard-free base is achieved. Management philosophies reflected in the estimates include:

• Abate or remove ACBM hazards based on USAF priority listing • Repair or remove ACBM unintentionally disturbed by routine O&M operations • Leave low-or no-risk ACBM unintentionally disturbed by routine O&M operations • Identify ACBM prior to initiating contract or in-house work • Comply with applicable employee and public health and safety regulations • Comply with federal, state, and local asbestos regulations.

Assumptions used in preparing the estimates include:

• Basic labor cost for government employees is skill dependent • Overhead for office space, office supplies, administrative support, leave, general

management, etc., is 33 percent of labor cost • Equipment used for abatement work is replaced on a regular basis • Health records will be maintained for duration of employment plus 30 years for defense

against potential employee disability or harm claims

The accidental ACBM disturbance rate from routine work and job orders will be 1 percent of all work orders.

5.1 Training: Funds for initial training will come from in-house organizational resources

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Funding requirements for training will be determined by 78 CES/CO

5.2 Equipment used for asbestos abatement projects will be purchased with Civil Engineering O&M funds according to Department of Defense Financial Management Regulation 7000.14-R and AFI 65-601. CEI will fund expendable items such as suits, filters and gloves used at an Environmental Compliance Program site.

5.3 Budget request process. Consult with 78 CES Material Control for paper work requirements and the assigned buyer for ordering supplies or equipment. Request for these items require the approval of the 78 CES Director. Six to eight months in advance of training classes, contact 78 CEG Civilian Training Manager for processing requirements. Resources available for training are available through the Base Training Office and Air Force Institute of Technology, Wright-Patterson AFB, OH.

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SECTION VI: TRAINING REQUIREMENTS 6. EPA and OSHA have directed the following training requirements for asbestos related work, supervision, inspection, and project managers. Classes will be conducted by an EPA and Georgia EPD accredited institution. A passing score is currently 70% for Certification. Certifications are good for one year and require re-certification yearly thereafter. Certifications are a requirement for employment. For workers there are 3 levels of training: the abatement worker, the single item worker, and the custodial worker.

6.1 Asbestos Abatement Worker (Includes all types of asbestos removal): 32-hour classes with hands-on training and exam; 1-day annual refresher.

Asbestos Worker (Single item removal such as roofing crews or floor removal only): 8-hour class with hands-on training and exam; 1-day annual refresher.

Custodial worker: 2-hour Asbestos Awareness training (this is not a certified removal course and no exam is required). 78 MDG Military Public Health provides 2-hour Awareness Annual Training.

6.2 Supervisor/Competent Person: 40-hour course with hands-on training and exam, 1-day annual refresher. Target employees are the direct supervisor of an abatement project (in-house or contracted); monitors or inspectors of contract projects; anyone who would sign-off the completions of abatement project. Contract monitoring of waste disposal for ACM or bulk or air sampling performed by contract are also required to have this certification.

6.3 Project Designer: 24-hour course with fieldwork and exam or Supervisor/Competent person, 1-day annual refresher. Target employees include planners or engineers of Asbestos Abatement projects.

6.4 Management Planners: 24-hour course plus 2 additional days (Building Inspector) and exam, 1 day annual refresher. Target employees are the BAOO, and O&M Planners and Managers.

6.5 Building Inspectors : 24-hour course with fieldwork and exam, 2 day annual refresher. Target employees are facility managers and contract monitors/technicians.

6.6 Asbestos Awareness: 2-hour class conducted by the 78th FSS/FSDETA, annual requirement, certificate of attendance given. Target employees are all maintenance, craftsman, custodial, and personnel who work in a building constructed before 1978. (If you are certified in any of the disciplines listed above attendance is not required.)

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6.7 The onsite supervisor of a contracted asbestos abatement must be Supervisor's Course trained (Section 6.2 the Competent Person). The "competent person on site" must have attended and successfully completed and passed an EPD accredited Asbestos Projects Supervisor's Course within the last 12 months. The Georgia EPD requires that a Competent Person be in charge of all abatement activities. These activities are defined as demolition or renovations that include the removal or disturbance of greater than 260 linear feet of pipe or 160 square feet of asbestos-containing material in the period of one year. It is also a requirement to have 2-trained asbestos workers when removing anything by glove bag method.

6.8 Topics: Each of the forgoing classes will cover the topic listed below i n debt consistent with the needs of the specific class.

• RECOGNITION OF ASBESTOS CONTAINING MATERIALS: A history of the use of the mineral, construction applications, and physical properties. MEDICAL ASPECTS OF ASBESTOS EXPOSURE: Mechanisms for disease occurrence, types of asbestos related disease, latency period, dose-response relationships, clinical signs of exposure, effects of smoking, populations at risk, and medical surveillance.

• RESPIRATORY PROTECTION: Elements of respiratory protection program, types, characteristics and l im1tallons of the respiratory classes, selection, use and maintenance of respirators, methods of fit testing, and HEPA filtration.

• PERSONAL PROTECTIVE EQUIPMENT (PPE): Types of disposable and non-disposable PPE (suits, booties, hoods, goggles, hard hats, footwear, gloves), including the requirements for use, purpose, selections, donning, removal, storage, handling, and disposal of protective clothing.

• MECHANISMS FOR EXPOSURE: Description of the physical means by which asbestos becomes airborne, fiber size, peak vs. ambient exposure, and maintenance operations that contributes to exposure.

• CORRECTIVE ACTION ALTERNATIVES: Description of asbestos remediation techniques, removal, encapsulation, enclosure and repair, and the advantages and disadvantages of each method.

• SAFE WORK PRACTICES: Electrical, fire and explosion hazards; safe use of scaffolds and ladders, walking and working surfaces; safe work practices in confined spaces.

• MATER IALS MONITORING: Discussion of systematic, periodic inspections; procedures and scheduling: maintenance of inspections records; labeling of materials: and change of status evaluation.

• EMERGENCY REPAIR TECIINJQUES: Hands-on training where participants perform simulated glove bag removal, spot patching/removal, and mechanical insulation wrapping and encapsulation. Particular work practices associated with the employee's job assignments arc discussed.

• CUSTODIAL MAINTENANCE: A discussion and hands on demonstration of wet cleaning methods to replace dusting and sweeping, disposal techniques, use of HEPA vacuums, and scheduling of custodial maintenance during non-occupied hours.

• REGULATORY REQUIREMENTS: A discussion of pertinent USAF, federal, state and local requirements particularly regarding employee information, training, and medical surveillance.

19

• WASTE DISPOSAL: Methods and requirements for bagging, storage, and transport of asbestos waste.

All personnel involved with the removal of asbestos must be enrolled i n a Medical Surveillance Program and pass an annual physical designed for asbestos workers. This program will be determined by Occupational Medicine (SGPFO) and include at a minimum:

• A report of medical and work history • Complete physical with emphasis on respiratory, cardiovascular systems, and digestive

tract • Completion of OSHA respiratory disease standardized questionnaire • Anterior and posterior chest X-rays • A pulmonary function test • Annual respirator fit test conducted by SGPB

Annual follow-up exams will be scheduled as long as the worker deals with ACM and deemed necessary by the physician

Additionally, all maintenance personnel involved in O&M operations will be monitored in an OSHA personnel monitoring program until sufficient historical data can be produced to discontinue sampling. SGPB will implement air-monitoring programs and determine when sampling is necessary.

6.9 Training Coordination: Training will be coordinated through the BAOO and monitored by CEIE.

20

APPENDIX A

Asbestos Survey Funding

21

APPENDIX B

Air Force Instruction 32-1052, Facility Asbestos Management

30

APPENDIX C

ACRONYMS

38

ACBM Asbestos Containing Building Materials ACM Asbestos Containing Material AF Air Force AFB Air Force Base AFI Air Force Instruction AFMC Air Force Materiel Command AFOSH STD Air Force Occupational Safety and Health Standard AMP Asbestos Management Plan AOP Asbestos Operating Plan BAOO Base Asbestos Operations Officer BCE Base Civil Engineer CEG Civil Engineer Group CEIE Civil Engineering, Environmental Management Division CFR Code of Federal Regulations DOT Department of Transportation HEPA High Efficiency Particulate Air NESHAP National Emission Standards for Hazardous Air Pollutants OSHA Occupational Safety and Health Administration PEL Permissible Exposure Limit PK Contracting Division PKO Operational Contracting Division PKOE Operational Construction Branch PKOS Operational Services Contracting Branch SGPB Bioenvironmental Engineering SGPFO Occupational Medicine TWA Time Weighted Average US EPA United States Environmental Protection Agency

39


AIR FORCE INSTRUCTION 32-1052 FACILITY ASBESTOS MANAGEMENT

A-14


BY ORDER OF THE SECRETARY OF THE AIR FORCE

AIR FORCE INSTRUCTION 32-1052

4 JANUARY 2013

Civil Engineering

FACILITY ASBESTOS MANAGEMENT

COMPLIANCE WITH THIS PUBLICATION IS MANDATORY

ACCESSIBILITY: Publications and forms are available for downloading or ordering on the e-Publishing website at http://www.e-publishing.af.mil.

RELEASABILITY: There are no releasability restrictions on this publication.

OPR: AFCEC/COS Supersedes: AFI32-1052, 22 March 1994

Certified by: AF/A7CO (Col Sanks) Pages: 7

This instruction implements Air Force Policy Directive (AFPD) 32-10, Installations and Facilities, and AFPD 32-70, Environmental Quality. It assigns responsibilities and establishes requirements to incorporate facility asbestos management principles and practices into all Air Force programs. It also establishes a program to ensure compliance with Title 29, Code of Federal Regulations (CFR) 1910.1001, Asbestos (Industry Standard); 29 CFR, 1926.1101, Asbestos (Construction Standard); 40 CFR Part 763, Subpart E, Asbestos-Containing Material in Schools; Title 15 United State Code (USC) Sections 2641-2656, Asbestos Hazard Emergency Response Act (AHERA); and 40 CFR Part 61, subpart M, National Emission Standard for Hazardous Air Pollutants, Asbestos (NESHAP). For overseas locations, applicable Air Force Occupational Health and Safety Standards (AFOSH) and Department of Defense (DoD) 4715.05-G, Overseas Environmental Baseline Guidance Document, or country-specific final governing standards (FGS), detail the minimum requirements for asbestos management actions. Privatized utilities and facilities need to refer to contracting or legal transfer documents for more guidance on required asbestos management. Unless otherwise indicated, requirements in this publication are mandatory and apply to all US Air Force organizations and personnel, including US Air Force Reserve Command (AFRC) units, all Air National Guard (ANG) personnel on duty status, with the exception of state employees. Ensure that all records created as a result of processes prescribed in this publication are maintained in accordance with Air Force Manual (AFMAN) 33-363, Management of Records, and disposed of in accordance with the Air Force Records Disposition Schedule (RDS) maintained in the Air Force Records Information Management System (AFRIMS) located at https://www.my.af.mil/afrims/afrims/afrims/rims.cfm. Users should send comments and suggested improvements on AF IMT 847, Recommendation for Change of Publication, through their MAJCOM and AFCEC/COS, 139 Barnes Drive, Suite 1, Tyndall AFB FL 32403-5319, to

2 AFI32-1052 4 JANUARY 2013

USAF/A7C, 1260 Air Force Pentagon, Washington, D.C., 20330-1260. This instruction may be supplemented at any level, but all direct supplements must be routed to the OPR for coordination prior to certification and approval.

SUMMARY OF CHANGES

This document has been substantially revised and must be completely reviewed. This revision addresses additional applicable regulations (29 CFR 1910.1001; 29 CFR 1926.1101; 40 CFR Part 763, subpart E, 15 USC 2641-2656; and 40 CFR Part 61, subpart M) and updates asbestos management program requirements, repair and abatement procedures.

Section A—Overview

1. Background. Asbestos is regulated by 15 USC 2601-2697, Toxic Substances Control Act (TSCA); 42 USC 7401-7671q, Clean Air Act (CAA); and regulations issued pursuant to 29 USC 651-678. This instruction focuses on each base’s development and implementation of asbestos management programs to reduce possible exposure to airborne asbestos fibers and satisfy regulatory requirements of 29 CFR 1910.1001; 29 CFR 1926.1101; 40 CFR Part 763, subpart E; 15 USC 2641-2656; and 40 CFR Part 61, subpart M. Past and current records addressed in this instruction must be maintained indefinitely, Ref Air Force Manual (AFMAN) 37-139 Records Disposition Schedule, Table 32-07, Rule 10.01. For more details on referenced regulations and specific Air Force environmental program requirements, please contact the Environmental Center of Excellence (AFCEC/CZ) and the Air Force Legal Operations Agency, Environmental Law and Litigation Division's Environmental Law Field Support Center (AFLOA/JACE-FSC).

Section B—Responsibilities

2. Air Force Civil Engineer Center - Operations Directorate, Engineer Division (AFCEC/COS):

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

2.2. Provides operational technical support to Environmental Center of Excellence (AFCEC/CZ) or MAJCOM Environmental Program Manager (for those areas that retained that function such as ANG and AFRC) overseeing facility asbestos management programs.

3. Environmental Center of Excellence (AFCEC/CZ) or MAJCOM Environmental Program Manager (for those areas that retained that function such as ANG and AFRC):

3.1. Provide oversight and environmental support to ensure facility asbestos management is effective at each base.

4. Base Civil Engineer (BCE): 4.1. Develops a base asbestos management plan (paragraph 7.1) and maintains an inventory of all facilities with known asbestos-containing materials (ACM) and ensure real property records are properly annotated. ACM is any material containing more than one (1) percent asbestos

AFI32-1052 4 JANUARY 2013 3

4.2. Develops and implements a comprehensive written asbestos operating plan (paragraph 6.2).

4.3. Examines ACM in base facilities ( any ACM that is non-friable or intact and any ACM that is friable or not intact), and decides whether repair, maintenance, or removal of the material is necessary. The BCE also determines whether extraordinary precautions are necessary to protect personnel until recommended actions are completed (e.g., frequent monitoring, removal of personnel from the area, temporary controls, or other protective measures). To accomplish these actions, the BCE will work together with base Bioenvironmental Engineering (BE).

4.4. Decides whether asbestos-related work will be accomplished with in-service resources or by contract.

5. Base Bioenvironmental Engineering (BE): 5.1. Works directly with the BCE to determine if recommended actions are necessary (e.g., frequent monitoring, removal of personnel from the area, temporary controls, or other protective measures) in order to protect human health.

5.2. With the BCE, conducts direct evaluation of facilities containing ACM, which cannot be reliably maintained, repaired, or isolated and that is likely to become friable or not remain intact. Provides advice to the installation commander regarding health issues associated with "Must remove" mandates.

5.3. Where there is no mandate to remove asbestos, BE will provide advice to the BCE regarding the health risk to facility occupants.

Section C—Program Requirements

6. Applicable Regulations. 29 CFR 1910.1001; 29 CFR 1926.1101; 40 CFR Part 763, subpart E; 15 USC 2641-2656; and 40 CFR Part 61, subpart M, prescribe requirements for identifying ACM, notifying building occupants of potential asbestos-related hazards, and acquiring specialized asbestos-related training. In addition, they provide specific guidance for asbestos identification, labeling, control, and abatement in schools, government, public, and commercial buildings. Planned asbestos abatement efforts must comply with these and other applicable federal, state, and local regulations prior to commencing work. Current and past records created pursuant to this instruction must be maintained indefinitely.

6.1. Asbestos Abatement. All damaged ACM, either friable or not intact, is presumed hazardous due to its potential to release asbestos fibers into the air. Damaged ACM must be repaired or removed to eliminate this potential hazard. Bases will abate hazardous ACM through inventory management, isolation, containment, and removal.

6.2. Asbestos Removal. 6.2.1. Bases must remove ACM which cannot be reliably maintained, repaired, or isolated and that is likely to become friable or not remain intact. "Must remove" mandates will be issued by the installation commander with advice from BE and the BCE, based on their direct evaluation of the material and the facility. If asbestos is present at any detectable level (determined by bulk sampling in accordance with 40 CFR

4 AFI32-1052 4 JANUARY 2013

Part 763, paragraphs 763.85-87) and is disturbed during maintenance, repair, or removal actions, then regulatory requirements of 29 CFR 1910.1001 and 29 CFR 1926.1101apply.

6.2.2. Where there is no mandate to remove asbestos, the BCE will consult with BE to determine health risk to facility occupants and will evaluate the material’s condition, use of the facility, the feasibility or frequency of repair, and cost-effectiveness when deciding whether to remove or repair non-friable, intact ACM.

6.2.3. When safety and budgetary considerations permit (e.g., if asbestos is non-friable and intact, encased, appropriately treated, or cost of asbestos removal is less than 10% of project cost), include complete removal of ACM when planning operations, maintenance, and military construction program facility projects.

6.2.4. Remove existing ACM at opportune times during minor construction or repairs (e.g., if wall sections are opened and ACM is exposed, or carpeting is replaced over vinyl asbestos flooring).

6.3. Facility Management. To ensure ACM does not become airborne, the BCE will closely monitor facilities in accordance with paragraphs 5.3.1 through 5.3.3.

6.3.1. Conduct asbestos surveys to identify all installed ACM. 29 CFR 1910.1001 requires installed Thermal System Insulation (TSI) and sprayed-on and toweled-on surfacing materials be classified as Presumed ACM (PACM) in buildings constructed no later than 1980. Asphalt and vinyl flooring material installed no later than 1980 also must be treated as asbestos-containing. To verify whether PACM and flooring material contains asbestos, complete an asbestos survey in accordance with 40 CFR Part 763, subpart E (sampling methods are specified in paragraphs 763.85-87). One commercially-available non-regulatory survey method is ASTM E2356-10, Standard Practice for Comprehensive Building Asbestos Surveys.

6.3.2. Determine if visibly-damaged TSI, existing spray- or toweled-applied surfacing or fireproofing, or miscellaneous ACM is in immediate danger of becoming friable or non-intact, and releasing airborne asbestos fibers; ensure such material is quickly repaired by personnel trained in accordance with 40 CFR Part 763, subpart E, Appendix C.

6.3.3. Routinely inspect identified ACM and PACM to verify that the material’s condition has not changed. Approved methods are specified in 40 CFR Part 763, paragraphs 763.85-87.

Section D—Program Management

7. Purpose and Scope. Each installation with maintenance responsibility must have a written management plan and operating plan to carry out the objectives of facility asbestos management. These plans serve two purposes: to detail how tasks are done; and to document the installation’s commitment to protect the health of personnel. They may be combined into one document if each section clearly delineates associated requirements. Current and past records created pursuant to this instruction must be maintained indefinitely.

7.1. Asbestos Management Plan. The objective of the asbestos management plan is to maintain a permanent record of the current status and condition of all ACM in an installation’s facility inventory. The management plan provides the documentation for all

AFI32-1052 4 JANUARY 2013 5

asbestos management efforts, and procedures for overseeing the entire facility asbestos management program, including procedures to ensure bases comply with applicable Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and state and local regulations.

7.2. Asbestos Operating Plan. The asbestos operating plan dictates how the base will carry out asbestos-related projects. The plan will assign responsibilities; establish inspection and repair capabilities; and provide repair procedures and personnel protection instructions. The plan will refer to and explain applicable OSHA and EPA rules, AFPD 32-70, and AFI 91202, The US Air Force Mishap Prevention Program (formerly AFI 91301), with provisions for enforcement. The operating plan addresses:

7.2.1. Organizational structure for carrying out asbestos-related work.

7.2.2. Project coordination and communication necessary for construction and renovation work involving facilities containing asbestos.

7.2.3. Personnel training programs.

7.2.4. Equipment and supply requirements.

7.2.5. Identification of worker manuals or other written procedures.

7.2.6. Yearly budget estimates.

7.2.7. Procedures for interim control measures and extraordinary precautions.

7.2.8. Procedures for asbestos certification and asbestos disposition statements on programming documents.

7.2.9. Requirements for a special response team and in-house inspection.

7.2.10. Requirements for contractor asbestos analysis and abatement.

JUDITH A. FEDDER Lieutenant General, USAF DCS/Logistics, Installations & Mission Support

6 AFI32-1052 4 JANUARY 2013

Attachment 1

GLOSSARY OF REFERENCES AND SUPPORTING INFORMATION

References 15 USC 2601-2697, Toxic Substance Control Act (TSCA), 11 October 1976

15 USC 2641-2656 Asbestos Hazard Emergency Response Act (AHERA), 7 January 2011

29 USC 651-678, Occupational Safety and Health Act (OSH Act), 29 December 1970

42 USC 7401-7671q, Clean Air Act (CAA), 31 December 1970

29 CFR 1910.1001, Asbestos (Standard for General Industry), 30 June 1993

29 CFR 1926.1101, Asbestos (Standard for the Construction Industry), 30 June 1993

40 CFR 61.140-157, subpart M, National Emission Standard for Hazardous Air Pollutants, Asbestos, 20 November 1990

40 CFR Part 763, subpart E, Asbestos-Containing Material in Schools, 30 October 1987

AFPD 32-10, Installations and Facilities, 4 March 2010

AFPD 32-70, Environmental Quality, 20 July 1994

AFI 91-202, The US Air Force Mishap Prevention Program, 5 August 2011

AFMAN 37-139 Records Disposition Schedule, 1 March 1996

AFMAN 33-363, Management of Records, 1 March 2008

ASTM E2356-10, Standard Practice for Comprehensive Building Asbestos Surveys, ASTM International, October 2010, DOI: 10.1520/E2356-10

DoD 4715.05-G, Overseas Environmental Baseline Guidance Document, 1 May 2007

Prescribed Forms None.

Adopted Forms None.

Abbreviations and Acronyms A7C—The Office of the Air Force Civil Engineer

A7CO—The Office of the Air Force Civil Engineer, Operations Division

ACM—Asbestos-Containing Materials

AFCEC—Air Force Civil Engineer Center

AFCEC/COS—Air Force Civil Engineer Center, Operations Directorate, Engineer

AFCEC/CZ—Air Force Civil Engineer Center, Environmental Center of Excellence

AFI—Air Force Instruction

AFI32-1052 4 JANUARY 2013 7

AFLOA/JACE—FSC—Air Force Legal Operations Agency, Environmental Law and Litigation Division's Environmental Law Field Support Center

AFMAN—Air Force Manual

AFPD—Air Force Policy Directive

AHERA—Asbestos Hazard Emergency Response Act

ASTM—American Society for Testing and Materials (now “ASTM International”)

BCE—Base Civil Engineer

BE—Bioenvironmental Engineering

CAA—Clean Air Act

CFR—Code of Federal Regulations

DCS—Deputy Chief of Staff

DoD—Department of Defense

EPA—Environmental Protection Agency

FGS—final governing standard

MAJCOM—Major Command

NESHAP—National Emission Standard for Hazardous Air Pollutants, Asbestos

OSH—Occupational Safety and Health (Act)

OSHA—Occupational Safety and Health Administration

PACM—Presumed Asbestos Containing Material

RDS—Records Disposition Schedule

TSCA—Toxic Substances Control Act

TSI—Thermal System Insulation

USC—United States Code