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					Roof Inspection, Repair & Maintenance at                   EN2-10389-8-J
Fort Buchanan Army Reserve Installation,                    October 2008
ARC, AFH and DDESS in Puerto Rico




                 Asbestos Operations
                 and Maintenance Plan
                             U.S. Army,
                           Fort Buchanan,
                                Puerto Rico




                    U.S. Army Corps of Engineers
                      PD Environmental Branch
                           Jacksonville, FL
                           Contract No. DACW17-00-D-0002
                                    Delivery Order 0004

                                    August 2003




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   Asbestos Operations And Maintenance Plan
                  Title Sheet


    User Agency:          Department of the Army Fort
                          Buchanan

    Facility Name:        Fort Buchanan

    Address:              Directorate of Public Works
                          Building 556
                          Columbus Street

    City and Zip:         For Buchanan, Puerto Rico 00934-
                          3400

    Date of O&M Plan:     August 2003

    Consultant:           J.J. Sosa and Associates, Inc. (JJSA)

    Address:              5811 Memorial Highway, Suite 207

    City and Zip          Tampa, Florida 33615


    Phone:                (813) 888-6525

    Fax:                  (813) 881-1285


I hereby certify that this Operations and Maintenance (O&M) Plan was compiled in accordance with the PD
Environmental Branch, U. S. Army Corps of Engineers’ Scope of Work and satisfies the intent to provide Fort
Buchanan with an Asbestos Management Program, to the best of my ability and knowledge.

Jose J. Sosa, P.E., CIH, LAC
Management Planner No. 7ME09099901MPR006
Project Manager

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                   ASBESTOS OPERATIONS AND MAINTENANCE PLAN
                          FORT BUCHANAN, PUERTO RICO



Fort Buchanan has developed this plan in cooperation with the United States Army Corps of Engineers, Mobile District.
The subject plan has been evaluated by the Fort Buchanan Garrison Commander and the above-mentioned agency. The
signature below indicates approval of this plan.




         PLAN APPROVAL


         Edward C. Short
         Colonel, U.S. Army                                             Date
         Commanding Officer
         Fort Buchanan, Puerto Rico


         PLAN REVIEW


         Alfredo J. Riera, P. E.
         Director of Public Works                                       Date
         Fort Buchanan, Puerto Rico


         Felix M. Mariani
         Chief, Environmental                                           Date
         Division
         Fort Buchanan, Puerto Rico




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                               Executive Summary
J. J. Sosa & Associates, Inc. was retained by the U.S. Army Corps of Engineers, Mobile District to develop an Asbestos
Operation and Maintenance (O&M) Plan to address the management of all asbestos remaining in Fort Buchanan
structures. This O&M Plan was prepared by J. J. Sosa and Associates, Inc. (JJSA). The management plan objectives
involve defining the requirements to protect building occupants, workers performing asbestos abatement activities and
maintenance personnel at Fort Buchanan.

Fort Buchanan is an Army installation located in San Juan, Puerto Rico, under the major command of the U.S. Army
South (USARSO). Existing structures at Fort Buchanan date back to the 1940s. Most of the facilities have been
renovated or replaced over the years. More than 230 operational buildings and more than 360 housing units for soldiers
and their families stationed at Fort Buchanan currently exist at the installation. Asbestos survey data indicates that a
large quantity of asbestos-containing building materials (ACBM) has been removed since implementation of regulations
controlling the use of asbestos. However, asbestos is still present in various operational buildings as well as in some
family housing.

It is the desire of Fort Buchanan to prevent unnecessary exposure to asbestos by employees, tenants, and other visitors to
the facility. No employees, tenants, outside contractors, or visitors shall engage in any activity that will disturb ACBM
within the facility. Any activity that could disturb ACBM must be approved by the Fort Buchanan Asbestos Program
Manager (APM). Disturbance of ACBM will be conducted in accordance with the Administrative Procedures and Work
Practices contained herein or by independent licensed asbestos abatement contractors working pursuant to contract
agreements.

The APM for Fort Buchanan is Mr. Anibal Negron. The APM will have responsibility for this Asbestos O&M Plan. The
asbestos management program will remain in force as long as asbestos-containing materials remain in the facilities at
Fort Buchanan.



                                               Contents
Executive Summary                                                                               111
Contents                                                                                         v
Asbestos Operations And Maintenance Plan Title Sheet                                            ix
Assumptions, Limitations, and Conditions                                                        xi
List of Acronyms                                                                               xiii
Introduction                                                                                     1-1
Description of Asbestos                                                                          1-1
Identifying Asbestos                                                                             1-1
Health Concerns                                                                                  1-1
Overview of Applicable Federal and State Regulations                                             1-2
EPA Regulations for Public Protection from Asbestos                                              1-3
OSHA Regulations for Worker Protection from Asbestos                                             1-4
Puerto Rico Environmental Quality Board Regulations                                              1-5

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Program Description                                                       2-1
EPA Guidance Documents                                                    2-1
Program Management Responsibilities                                       2-1
Asbestos Program Manager                                                  2-2
Inspector                                                                 2-2
Antilles Consolidated School System Environmental Officer                 2-3
Design Engineer                                                           2-3
O&M Division Chief                                                        2-3
Industrial Hygienist                                                      2-3
Location of ACBM                                                          2-4
Administrative Procedures                                                 3-1
AP1-Worker Training, Respiratory Protection, and Medical Surveillance     3-2
      General                                                             3-2
      Training Requirements                                               3-2
      Training at Fort Buchanan                                           3-3
      Respiratory Protection Program                                      3-4
      Medical Surveillance Program                                        3-5
AP2-Notifications and Labeling                                            3-7
      Warning                                                             3-7
      Labels                                                              3-7
      Warning Signs                                                       3-7
      Notifications                                                       3-9
AP3-Periodic Surveillance and Re-inspection                               3-11
      Periodic Surveillance                                               3-11
      Re-inspection Program                                               3-11
AP4-Work Permit Program                                                   3-12
AP5-Recordkeeping and Forms                                               3-15
         Form 1                                                           3-49
         Form 2                                                           3-20
         Form 3                                                           3-21
         Form 4                                                           3-24
         Form 5                                                           3-25
         Form 6                                                           3-27
         Form 7                                                           3-28
         Form 8                                                           3-29
         Form 9                                                           3-30
AP6-Selection of Personal Protective Equipment and                        3-31
     Decontamination Procedures
         Protective Clothing and Equipment                                3-31
         Decontamination                                                  3-31
AP7-Developing the Air Monitoring Program                                 3-32
         Design and Validation of an O&M Program                          3-32
         Periodic Monitoring and Observation of Monitoring                3-34
         Termination of Monitoring                                        3-34
         Settled Dust Sampling                                            3-35
APS-Selection of Materials                                                3-37
          Polyethylene                                                    3-37
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        Lockdown Encapsulants                                    3-37
AP9-Emergency Responses                                          3-38
        General Response to a Fiber Release                      3-38
        Work Practices                                           4-1
        General Custodial Practice                               4-2
        Worker Checklists                                        4-2
WP1-Wet Strip Floor Wax from Resilient Asbestos Flooring         4-9
         Summary                                                 4-9
         Work Practice                                           4-9
WP2-Dry or Spray Buffing Resilient Asbestos Flooring             4-10
         Summary                                                 4-10
         Work Practice                                           4-10
WP3-Cleaning Resilient Asbestos Flooring                         4-11
         Summary                                                 4-11
         Work Practice                                           4-11
WP4-Cut or Drill Asbestos Cement Panels                          4-12
         Summary                                                 4-12
         Examples of Level B                                     4-12
WP5-Remove Asbestos Cement Panels                                4-14
         Summary                                                 4-14
         Example of Level A                                      4-14
         Example of Level B                                      4-14
WP6-Remove Asbestos-Containing Built-Up Roofing                  4-16
     Summary                                                     4-16
     Example of Level A                                          4-16
     Example of Level B                                          4-16
WP 7-Clean Up Debris                                             4-18
     Summary                                                     4-18
     Examples of Level B                                         4-18
WP8-Replace Asbestos-Containing Gaskets/Packing                  4-20
     Summary                                                     4-20
     Example of Level A                                          4-20
     Example of Level B                                          4-20
WP9-Remove Asbestos-Containing Caulking and Glazing Compound     4-23
     Summary                                                     4-23
     Example of Level A                                          4-23
     Examples of Level B                                         4-23
WP1O-Clean Room that has Asbestos-Containing Dust                4-25
     Summary                                                      4-25
     Examples of Level A                                          4-25
WP11-Attach Item to Ceiling Finished with ACBM                    4-27
     Summary                                                      4-27
     Example of Level A                                           4-27
     Examples of Level B                                          4-27
WP12-Repair or Replace Item in Surface Finished with ACBM         4-29
     Summary                                                      4-29
     Example of Level A                                           4-29
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      Example of Level B                                                   4-29
WP13-Replace Bulbs in Light Fixture Attached to or in Surface Finished     4-31
      with ACBM
      Summary                                                              4-31
      Examples of Level A                                                  4-31
      Examples of Level B                                                  4-31
WP14- Clean Room with Exposed Surfaces Finished with ACBM                  4-33
      Summary                                                              4-33
      Examples of Level A                                                  4-33
WP15-Repair Damaged Surfacing ACBM                                         4-34
      Summary                                                              4-34
      Examples of Level A                                                  4-34
      Examples of Level B                                                  4-34
WP16-Accessing through an ACBM Finished Surface                            4-36
      Summary                                                              4-36
      Example of Level A                                                   4-36
      Examples of Level B                                                  4-37
WP17-Painting Surfacing ACBM                                               4-38
      Summary                                                              4-38
      Example of Level A                                                   4-38
WP18-Remove Asbestos-Containing Insulation Inside HVAC Unit for            4-40
      Maintenance Work
     Summary                                                                4-40
     Example of Level B                                                     4-40
     Examples of Level C                                                    4-41
WP19-Replacement of Resilient Asbestos Floor Tiles                          4-42
       Summary                                                              4-42
       Examples of Level A                                                  4-42
WP20 -Install New Resilient Flooring or Carpet Over Resilient               4-46
       Asbestos Flooring
      Summary                                                              4-46
      Example of Level A                                                   4-46
WP21-Install Partition Over Resilient Asbestos Flooring                    4-47
      Summary                                                              4-47
      Example of Level A                                                   4-47
WP22-Remove Carpet Over Resilient Asbestos Flooring                        4-48
      Summary                                                              4-48
      Example of Level A                                                   4-48
      Example of Level B                                                   4-49
References                                                                 5-1
    EPA Publications                                                       5-1
    OSHA Regulations                                                       5-2
    Commonwealth of Puerto Rico Publications                               5-2
    U.S. General Services Administration (PMSE)                            5-2
    Military Policy, Directives and Guidance                               5-2
    Miscellaneous References                                               5-2
    O&M Program Elements References                                        5-3
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Life-Cycle Cost Analysis                                                                     6-1


List of Appendixes
    A      Glossary
    B      Asbestos Material Location

List of Exhibits
  2-1 Asbestos Program Management Personnel                                                 2-1
  3-1 Employee Notification Sign                                                            3-8
  3-2 Work Permitting Program Checklist                                                     3-14
  6-1 List Cycle Cost Analysis                                                              6-1




                   Assumptions, Limitations, and
                           Conditions
O&M Program Assumptions
The O&M Plan assumes that all elements of the O&M program listed below are considered and all applicable elements
have been established and the programs in place.

       Asbestos Program Manager appointment and training

       Building inspection and assessment

       Copies of applicable regulations and guidance documents

       Hazard communication program

       Historical air monitoring data

       Confined space entry program

       Safety program for other hazards

All O&M related programs should be reviewed periodically and revised if necessary. Regulatory and guidance
documents should also be reviewed periodically to ensure that they are current.




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Limitations and Conditions
This Plan was developed as reference for persons responsible for performing and/or directing approved O&M Work
Practices. Use of this Plan will assist in providing response actions required to manage asbestos in-place. Use of the Plan
does not guarantee that the quality of work will be equal to or better than if completed by a qualified independent
contractor. JJSA make no warranty or guarantee, expressed or implied, with respect to work performed by Fort
Buchanan workers or contractors using the Plan. Neither does JISA assume any liability for the use of any information,
methods, or materials contained herein, or for damages arising from such use; nor does JJSA assume any responsibility
for any injury to individuals or property, or for any financial loss, sustained as a result of the use or application of this
document.

Note that:

   O&M activities involving asbestos-containing building materials (ACBM) may involve health risks to those
    performing them or those performing unrelated work near the activities.

   Experts from the building, scientific, and environmental communities have different views as to the proper
    management of ACBM in-place. This document attempts to bring together information and viewpoints from several
    sources reflecting current knowledge and technology.

This O&M Plan shall be considered solely as a resource document representing the expert opinion of professionals in
this field. This Plan does not represent the view, policies, or position of the U.S. Environmental Protection Agency
(EPA), the Occupational Safety and Health Administration (OSHA), or any other agency of the federal, state, or local
governments.

The O&M Plan should serve as a guide to implement the Fort Buchanan asbestos management program and instruct
workers who execute the required tasks. The user bears all risks associated with reliance on these work practices and
shall have the sole responsibility to evaluate the information contained herein and to make independent judgments on the
use of the practices outlined in this O&M Plan.



                                    List of Acronyms
ACBM          Asbestos-Containing Building Material
ACM           Asbestos-containing material
ACSS          Antilles Consolidated School System
AHERA         Asbestos Hazard Emergency Response Act
AP            Administrative Procedures
APM           Asbestos Program Manager
ASHARA        Asbestos Schools Hazard Abatement Reauthorization Act
CAA           Clean Air Act
CFR           Code of Federal Regulations
DENIX         Defense Environmental Network Information Exchange
DOT           Department of Transportation
DPW           Directorate of Public Works
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FEG           Environmental Enterprises Group
EPA           Environmental Protection Agency
HEPA          High Efficiency Particulate Air
HVAC          Heating Ventilating and Air Conditioning
JJSA          J. J. Sosa and Associates
MAP           Model Accreditation Plan
NTEA          Negative Exposure Assessment
NESHAP        National Emission Standards for Hazardous Air Pollutants
NIBS          National Institute of Building Sciences
MOSH          National Institute for Occupational Safety and Health
O&M           Operations and Maintenance
OSHA          Occupational Health and Safety Administration
PACM          Presumed asbestos-containing material
PAPR          Powered Air Purifying Respirators
PCM           Phase Contract Microscopy
PEL           Permissible Exposure Limit
PPE           Personal Protective Equipment
PREQB         Puerto Rico Environmental Quality Board
RACM          Regulated Asbestos-Containing Material
RFCM          Resilient Floor Covering Manufactures
TEM           Transmission Electron Microscopy
TSCA          Toxic Substance Control Act
TSI           Thermal System Insulation
TWA           Time-weighted Average
USARSO        U.S. Army South
WPM           Work Practices Micrometers




Section 1


Introduction
This Operations and Maintenance (O&M) Plan is designed to establish a set of policies, procedures, and work practices
intended to minimize occupant exposure to asbestos-containing building materials (ACBM). This plan was prepared to
aid in safely maintaining the remaining ACBM throughout Fort Buchanan.


Description of Asbestos
Asbestos is the name for a group of natural minerals that separate into strong, very fine fibers. The fibers are heat-
resistant and extremely durable, and these qualities have made asbestos very useful in the construction industry.
Although several different types of asbestos exist, nearly 95 percent of all asbestos used in commercial products today is
a type of asbestos called chrysotile. In the 1970s, the EPA began banning the manufacture of products containing
asbestos because of growing concerns over health effects.


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Identifying Asbestos
Asbestos may be found in many different products and many different places. Examples of products that might contain
asbestos are:

    Sprayed-on insulation in buildings

    Fire proofing materials

    Insulation for pipes and boilers

    Wall and ceiling insulation

    Ceiling tiles

   Floor tiles

   Putties, caulks, mastics, and cements (such as in chemical carrying cement pipes)

   Roofing shingles

   Siding shingles on old residential buildings

   Wall and ceiling texture in older buildings and homes

   Joint compound in older buildings and homes

   Automotive brake linings and clutch pads

   Interiors of fire doors

Health Concerns
Despite the beneficial uses of asbestos, exposure to ACBMS that release fibers into the air can produce adverse health
effects. The potential of an asbestos-containing product to release fibers is dependent upon several factors, including its
location and its degree of friability. Friable means that when dry, it can be crumbled with hand pressure and therefore is
likely to emit fibers when disturbed. The fibrous or fluffy spray-applied asbestos materials found in many buildings for
fire-proofing, insulating, or decorative purposes are generally considered friable. Some materials, such as vinyl floor
tiles, are likely to emit fewer airborne fibers unless they become worn from abrasion, weather, physical damage, or
chemical exposure, or are subjected to sanding and cutting operations. Because of their size and shape, these tiny fibers,
invisible to the human eye, can remain suspended in the air for long periods of time and can easily penetrate body tissues
when inhaled or ingested with food. Due to their durability, these fibers can remain in the body, primarily the respiratory
tract, for many years.

Asbestos is known to cause asbestosis and various forms of cancer. Asbestosis is a serious chronic respiratory disease
caused by scarring of the lung tissue from inhaled asbestos fibers. Breathing becomes progressively more difficult, and
this disease can lead to death.


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Cancer can result from breathing asbestos fibers. Smoking significantly increases the potential for lung cancer, the most
common asbestos-related disease. Asbestos exposure has also been linked to mesothelioma, a cancer of the chest and
abdominal membranes. Mesothelioma almost never occurs without exposure to asbestos, and is currently incurable.
Other cancers, primarily of the digestive tract, also have been associated with exposure to asbestos.

These diseases have a long latency period and may not appear until 20 to 40 years after exposure. Right now, for
example, the medical community is seeing the results of exposure that occurred among asbestos workers during World
War II.



Overview of Applicable Federal and State Regulations
The U.S. Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) are
the primary agencies responsible for regulating asbestos exposure. EPA is responsible for developing and enforcing
regulations that protect the general public from exposure, whereas OSHA is responsible for protecting workers who
could be exposed to asbestos in the workplace or as part of their jobs. The commonwealth of Puerto Rico has also
promulgated regulations addressing asbestos.

The specific regulations addressing asbestos consist of:

   Asbestos containing materials in schools (40 CFR 763)

   Asbestos Schools Hazard Abatement Reauthorization Act (ASHARA)

   National emission standards for asbestos (40 CFR 61, Subpart M)

   Construction standards for asbestos (29 CFR 1926.1101)

   General industry standards for asbestos (29 CFR 1910.1001)

   Atmospheric Emissions Regulations, Section 422 (Puerto Rico Environmental Quality Board
    [PREQBJ)

   Solid Waste Regulations (PREQB)



EPA Regulations for Public Protection from Asbestos
EPA has promulgated the following major regulations for protection of the general public from asbestos exposure:

   The Asbestos Hazard Emergency Response Act (AHERA), which was amended by the ASHARA, to manage
    asbestos in schools and other buildings.
   The National Emission Standards for Hazardous Air Pollutants (NESHAP) for public protection from airborne
    asbestos




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The following paragraphs present important features of these regulations.

AHERA/ASHARA. In May 1982, EPA first issued regulations to control asbestos in schools under authority of the
Toxic Substance Control Act (TSCA). A school is an elementary or secondary school as defined by Section 198 of the
Elementary and Secondary Education Act of 1965 (20 United State Code [U.S.C.] 2854). In response to the need for
more stringent control, Congress enacted AHERA as Title II of TSCA on October 22, 1986. This act required EPA to
establish a more defined program to control ACBMs in schools. As a result, the EPA Rule entitled Asbestos Containing
Materials in Schools (40 CFR 763) was promulgated on October 30, 1987. The new rule required schools to inspect for
asbestos, prepare asbestos management plans, and develop and implement O&M plans. AHERA also required school
authorities to inform parents, teachers, and others of the management plans.

On November 28, 1990, EPA enacted ASHARA, which amended AHERA by extending accreditation requirements to
people who perform inspections or design or execute response actions in public and commercial buildings. This
accreditation must occur through AHERA's Model Accreditation Plan (MAP), which is cited in 40 CFR 763, Subpart E,
Appendix C, and outlines the required training courses for affected workers. Accreditation does not extend to
management planners. ASHARA required the MAP to include more hands-on training.

NESHAP. The Clean Air Act (CAA) of 1970 required EPA to develop and enforce regulations to protect the public from
exposure to airborne contaminants known to be hazardous to human health. On March 31, 1971, EPA identified asbestos
as a hazardous air pollutant. On April 6, 1973, EPA promulgated the NESHAP standard for asbestos (40 CFR 61,
Subpart M).

In outlining requirements for asbestos exposure during work performance, NESHAP uses a classification called RACM
(regulated asbestos-containing material). A RACM is a friable ACBM or a non-friable ACBM that has become, or has
the potential to become, friable from physical actions such as demolition and renovation activities.

NESHAP specifies work practices, notifications, and training requirements for a variety of operations involving
RACMs. For building demolitions and renovations, specific notification requirements (40 CER 61.145), emission
control procedures (40 CFR 61.145), and waste disposal procedures (40 CFR 61.150) apply if either of the following
conditions are met:

   The amount of friable asbestos-containing material (ACM) in a facility being demolished or being disturbed in a
    renovation is at least 260 linear feet on pipes, or at least 160 square feet (ft2) on other facility components.

   Where measurement before stripping is not possible, the friable ACM from all sources totals at least 35 cubic yards
    (yd3).

Standards also may apply for RACMS in lesser quantities (see 40 CFR 61, Subpart M).




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SECTION 2


Program Description
The O&M Plan is an integral part of the Fort Buchanan Asbestos Management Program. The three basic elements of the
Asbestos Management Program are:

    Survey and Assessment identify and characterize ACBM
                              -




    O&M safely manage ACBM until removal
           -




    Planned Removal eliminate ACBM which may be disturbed
                       -




EPA Guidance Documents
This plan is intended to be used in conjunction with the guide Managing Asbestos in Place ("Green Book") issued by
the EPA in July 1990, Information presented in the "Green Book" is not repeated in this Plan, but is referenced where
appropriate. Additional references might be made to other guidance documents, including:

1.   Asbestos in Buildings: Simplified Sampling Scheme for Friable Asbestos Materials ("Pink Book")

2.   Guidance for Controlling Asbestos-Containing Materials in Buildings ("Purple Book")

3.   A Guide to Respiratory Protection for the Asbestos Abatement Industry ("White Book")

A list of references and guidance documents is given in Section 5 of this Plan.


Program Management Responsibilities
The following section describes the responsibility of each member of the organization for the management of remaining
asbestos at Fort Buchanan. Exhibit 2-1 lists individuals with assigned responsibilities to ensure the protection of all base
personnel from the potential exposure to asbestos.

EXHIBIT 2-1
Asbestos Program Management Personnel
Name                                Position                              Organization
Anibal Negron              Asbestos Program Manager        Environmental Division, Directorate of Public Works
Pedro Lopez                Inspector (COR)                 Inspection Branch
Ramon Moreno               Environmental Officer           Antilles Consolidated School System
Edgardo Hernandez          Chief O&M Division              O&M Division
Juan Oliveras              Industrial Hygienist            Health Clinic and Preventative Medicine



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Asbestos Program Manager
The Asbestos Program Manager (APM) is the focal point for the administration of the asbestos program and will reside
in the Environmental Division at the Directorate of Public Works. The APM fulfills a wide range of responsibilities. The
APM is responsible for developing the program and coordinating its operations. The APM:

   Implements and oversees activities of the asbestos program

   Directs the maintenance of all records for the program including asbestos surveys, lab results, inspections,
    abatement actions, waste manifests, and so on.

   Updates and revises the asbestos inventory (Appendix A) as necessary and provides copies to Contracts,
    Engineering, Inspection, and others divisions as appropriate

   Reviews and authorizes Maintenance Work Authorization Forms

   Ensures that proper agency notification occurs and serves as point of contact for regulatory agency communications

   Maintains a current asbestos certification and required training

   Coordinates an awareness training session for designated employees

   Maintains a copy of training records and training resources

   Informs all base contractors that they may encounter ACBM while conducting their work and that they must take
    precautions and advise their workers

   Communicates the Asbestos Management Program to tenant facilities who shall be responsible for disseminating
    information to their employees and outside contractors

   Communicates routinely with personnel regarding the Asbestos O&M Plan

   Provides briefings to senior management as to the status of the program

Asbestos Program Manager Additional Duties
 Reviews the inventory to determine whether potential asbestos related design issues exist
 Maintains a list of approved asbestos abatement contractors for O&M activities of a routine or emergency
  nature
 Makes this O&M Plan available to asbestos contractors
 Ensures that contractors either follow Work Practices presented herein or site specific work practices
  developed in compliance with the regulations
 Reviews asbestos contractor submittals, including training certifications, respirator fit test records, and
  medical records
 Determines where ACBM hazards may exist and what steps the contractors must take to protect base
  personnel and families
   Reviews post-job submittals and written deliverables

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Inspector (COR)
The Fort Buchanan Inspectors:

    Serves as the point of contact for asbestos contractors and reviews emergency response procedures with them in the
     event of an emergency situation

    Ensures that asbestos work is conducted in controlled areas as appropriate

    Ensures that air monitoring is conducted as appropriate by properly trained personnel

    Evaluates air monitoring results

    Confirms that asbestos contractor personnel onsite are those whose training records and certifications were provided
     in the contractor's proposal

    Confirms that the asbestos contractor's actions in the field occur in accordance with work practices and
     specifications stated for the project

   Confirms that waste tracking and disposal arrangements are made and that waste manifests are received from the
    disposal facility

   Ensures that forms provided to document activities of the O&M Plan are being used



Antilles Consolidated School System Environmental Officer
The Antilles Consolidated School System (ACSS) is a tenant organization at Fort Buchanan. The environmental officer
for the school system serves as the Asbestos Program Manager for the school facilities. The Environmental Officer:

 Develops and coordinates the asbestos management program for the ACSS
 Notifies the Fort Buchanan APM of planned asbestos abatement activities in the schools
   Submits an updated asbestos inventory for the school system as changes occur


O&M Division Chief
The Chief of the Operations and Maintenance Division:

 Receives Job Request Form for Maintenance Work
 Confirms with the APM that requested work will not impact or disturb ACBM
 Completes the Maintenance Work Authorization Form
   Maintains a supply of personnel protective equipment (PPE) for Fort Buchanan personnel




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Industrial Hygienist
The Fort Buchanan Industrial Hygienist:

   Maintains the medical surveillance monitoring program
   Administers the respiratory protection program and schedules respiratory fit testing and training
   Confirms PPE requirements for Fort Buchanan personnel
   Coordinates personnel health and safety training
   Maintains records of PPE and respirators issued to Fort Buchanan personnel


Location of ACBM
Fort Buchanan retained the services of Pickering Environmental Consultants in 1991 and Environmental Enterprises
Group (EEG) in 1993 to complete post-wide surveys. The results of the survey confirmed the presence of asbestos in
most of the operational buildings and housing units. Copies of the survey reports can be found in the Environmental
Office located in the Public Works building at Fort Buchanan. The inventory or summary table with the remaining
ACBM throughout the Fort Buchanan operational buildings is provided in Appendix A. Following the identification of
the ACBM, a comprehensive abatement program was started. Since the start of the abatement activities at the Fort
Buchanan, various operational buildings have been rid of ACBM. The drawings in Appendix B show the buildings
where ACBM remain and those that are ACBM-free at the time of the publication of this O&M Plan.

ACBM previously identified in the interior of the 364 housing units at Fort Buchanan has been abated, except in unit 823
located in the Las Colinas housing area. The ceiling in this unit has been treated with acoustical finish containing
asbestos. In addition, the roof treatment of 22 buildings in Buchanan Heights Family Housing contains asbestos. This
represents approximately 65,000 square feet of roofing material that contain asbestos. Abatement of these roofs was
scheduled to be completed before the end of fiscal year 2002.



SECTION 3


Administrative Procedures
This section presents the administrative elements of the asbestos program operation. In contrast, Section 4 presents work
practices or instructions for specific activities involving asbestos. The following Administrative Procedures (AP) are
presented in this section:

AP1           Worker Training, Respiratory Protection, and Medical Surveillance
AP2           Notifications and Labeling
AP3           Periodic Surveillance and Re-inspection
AP4           Work Permitting Program
APS           Recordkeeping and Forms
AP6           Selection of Personal Protective Equipment & Decontamination Procedures

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AP7            Developing the Air Monitoring Program and Assigning Air Monitoring Personnel
AP8            Selection of Materials
AP9            Emergency Responses


AP1-Worker Training, Respiratory Protection, and
Medical Surveillance

General Training Requirements
Workers assigned to perform O&M work must receive training and experience in the skills and techniques required for
the type of work to be performed, training in applicable asbestos O&M procedures, this O&M Plan, and building
conditions at Fort Buchanan.

OSHA Regulations 29 CFR 1926.1101 and 29 CFR 1910.1001 established four classifications of asbestos work and
requirements for the amount and type of training required to perform the four classes of work. The classification of work
and training requirements per OSHA definition are as follows:

     Class I Asbestos Work activities involving the removal of ThI and surfacing ACBM and presumed asbestos-
                                      -


      containing material (PACM). To perform this work, workers are required to complete 32 hours of training
      equivalent to the EPA Model Accreditation Plan asbestos abatement worker training. The training provider must be
      certified by the PREQB.

     Class II Asbestos Work activities involving the removal of ACBM which is not TSI (?) or surfacing material. This
                              -


      includes, but is not limited to, the removal of asbestos-containing wallboard, floor tiles and sheeting, roofing and
      siding shingles, and construction mastic. To perform this work, workers are required to complete 32 hours of
      training equivalent to the EPA Model Accreditation Plan asbestos abatement worker training.

     Class III Asbestos Work repair and maintenance operations where ACBM, including TSI and surfacing material, is
                                  -


      likely to be disturbed. Requires 16 hours of training equivalent to the 16-Hour O&M course developed by the EPA
      for maintenance and custodial workers who conduct activities that will result in the disturbance of ACBM.

     Class IV Asbestos Work maintenance and custodial activities during which employees contact ACBM and PACM
                                  -


      and activities to clean up waste and debris containing ACBM and PACM. Requires 2 hours of training equivalent to
      the awareness training course developed by the EPA for maintenance and custodial workers who work in buildings
      containing ACBM.

Depending upon applicable regulations (such as PREQB Section 422, NESHAP, and OSHA 29 CFR 1926.1101/29 CFR
1910.1001), a designated trained or "competent person" might be required to perform or supervise certain aspects of the
work.
Competent Person means, in addition to the definition in 29 CFR 1926.32, one who is capable of identifying existing
asbestos hazards in the work place and selecting appropriate control strategies for asbestos exposure, who has the
authority to take prompt corrective measures to eliminate them, as specified in 29 CFR 1926.32(f). In addition, for Class
I and Class II work, a Competent Person is one who is specially trained in a training course which meets the criteria of


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EPA's Model Accreditation Plan (40 CFR 763) for project designer or supervisor, or its equivalent. For Class III and
Class IV work, a Competent Person is one who is trained in an O&M course developed by EPA under 40 CFR 763.92
(a)(2).



Training at Fort Buchanan
Effective implementation of the Asbestos O&M Plan requires specific training of select personnel. The amount and
content of training depends on the specific duties of each individual and the likelihood of potential contact with ACBM
in the buildings at Fort Buchanan. Fort Buchanan shall institute a training program for employees engaged in asbestos-
related work or who may be potentially exposed to asbestos fibers from ACBM. Training shall be conducted at the time
of initial assignment and at least annually thereafter.

Fort Buchanan personnel shall not conduct abatement of Class I, II, or III asbestos work. These classes of work must be
performed by an Asbestos Contractor utilizing personnel certified by the PREQB and following applicable federal
regulations and PREQB Rule 422 for asbestos-containing material management.

The APM should have formal training sufficient to:

1.   Perform inspections and identify where asbestos will be encountered

2.   Assess the condition of ACBM

3.   Evaluate potential exposure, building components, building systems, building usage patterns

4.   Design and conduct O&M activities

5.   Be familiar with cleaning and maintenance tasks

6.   Understand applicable laws and regulations

7.   Be aware of other crucial factors associated with an O&M program

Maintenance and custodial workers shall receive asbestos awareness training to perform their duties safely. This training
may be performed in house by the APM or by contract training programs. The asbestos awareness training shall address
the following topics:

    Location of ACBM at Fort Buchanan and potential sources of exposure

    Health effects of asbestos exposure and the increased dangers from cigarette smoking

    Recognizing asbestos hazards

    Modifications to typical maintenance activities to prevent asbestos exposure




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Form 1 in AP5, entitled Record of 2-Hour Asbestos Training, should be used to document Class TV work training.
Annual refresher training course will be provided to reinforce, clarify, and update asbestos awareness information and
work practices.

Additional training might be desirable for performing frequent O&M work or certain O&M tasks. Before workers are
assigned to O&M work, the APM should verify that their training, respirator fit tests, and medical surveillance are
current and in compliance with regulations (where applicable) and the requirements of work practices to be used.

Respiratory Protection Program
Respirators shall be used whenever personnel have a potential to be exposed to asbestos. Respirators used for O&M
activities must be selected based on the requirements of regulations and a Respiratory Protection Program developed in
accordance with 29 CFR 1910. 134 and 40 CFR 763.120-121. Appendix E of the "Green Book" includes EPA's
recommendations on the types of respirators to be used for custodial and maintenance tasks. Liability concerns, historical
data, and management policies might also influence whether respirators are used, and if so, the type of respirators for
O&M activities. The National Institute for Occupational Safety and Health (NIOSH) recommends minimizing
occupational exposure to cancer-producing substances such as asbestos to the lowest feasible level. In practice, an
exposure level of 0.01 fibers/cm3 of air inside the respirator is commonly used for planning purposes. OSHA has stated
that the OSHA PEL was selected as a technical and economic compromise for industry, and is not designed to totally
prevent cancer-causing exposures. The EPA's "White Book" and the Introduction and Section 01562 of the National
Institute of Building Sciences (NIBS) Asbestos Abatement Guide Specifications contain information regarding respirator
selection that might be helpful to the APM. Review of this additional information is strongly encouraged.

Respiratory protection for asbestos work requires the use of High Efficiency Particulate Air (HEPA) filter cartridges. In
certain situations, full-face respirators might be desirable to provide additional eye and face protection for workers.
Powered Air Purifying Respirators (PAPRs) are preferred by many workers instead of negative pressure respirators.
Regulations in 29 CFR 1910.1001 and 29 CFR 1926.1101 require that an employer provide a PAPR instead of a
negative pressure respirator if an employee chooses to use this type of respirator. Depending upon the type of work and
work practices to be used, combination respirator filter cartridges or a different type of respirator might be necessary to
protect workers from other contaminants or hazardous substances.

At a minimum, the following levels of respiratory protection are recommended for custodial and/or maintenance
activities. Single use disposable dust masks shall not be used for protection against asbestos.

                          Type of Activity
                                                                 Decontamination after a minor (small-scale) fiber
        Routine maintenance where disturbance of ACBM            release episode.
        is unlikely.
                                                                 Decontamination after a major (large-scale) fiber
        Routine maintenance where accidental disturbance         release episode.
        of ACBM is likely.                                           Recommended Respiratory Protection

        Maintenance or repair activities involving               No respiratory protection. Half-face HEPA-
        intentional small-scale disturbance of ACBM.             filtered air purifying respirators should be
                                                                 available if needed.
        Maintenance or repair activities involving
        intentional small-scale disturbance of ACBM              Half-faced HEPA-filtered air-purifying respirator.
        supplemented by the use of a glove-bag.

        Any activity involving large-scale disturbance of        Full-face PAPA with HEPA filters.
        ACBM (as in abatement).
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        Half-face HEPA-filtered air purifying respirator.       Half-face HEPA filtered air-purifying respirator.

        Supplied air respirator (Type C) or full-face PAPR      Type C respirator or full-face PAPR with HEPA
        with HEPA filters.                                      filters.



In conjunction with the selection of respirators for use, all employees required to use such respirators must be trained in
proper fit-testing procedures. Fit testing, especially when using one-half face HEPA filtered air purifying respirators, is
essential to ensure that maximum protection is provided to custodial and maintenance personnel. OSHA (29 CFR
1926.1101 and 29 CFR 1910.134, respectively) requires initial and biannual fit testing for employees required to use-


negative pressure respirators.

Medical Surveillance Program
The employer is required to institute a Medical Surveillance Program for all employees whom:

    Are engaged in Class I, II, and III asbestos work for a combined total of 30 or more days per year

   Are exposed at or above the PEL or Excursion Limit for 30 or more days

   Wear negative pressure respirators

The surveillance program consists of many steps. To maintain a good surveillance program, it is recommended that the
program consist of the following elements (minimum requirements):

   Initial examination

   Annual examination

   Termination examination

   Medical history provided to the physician

   Written opinion by the physician

   Employees medical records

OSHA requires that before the examination, the employer provide to the examining physician the following information:

    A copy of the OSHA Standard (29 CFR 1910.1001) which includes: the mandatory medical questionnaire, the
     mandatory interpretation and classification of chest roentgenograms, and the non-mandatory Medical Surveillance
     Guidelines

   A description of the affected employee's duties as they relate to the employee's exposure level

   The employee's representative exposure level or anticipated exposure level
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   A description of any personal protective and respiratory equipment used or to be used

   Information from previous medical examinations of the affected employee that is not otherwise available to the
    examining physician

The employee's medical records will be maintained and will contain at a minimum the following information:

   The name of the employee

   The social security number of the employee

   A copy of the employee's medical examination results

   A copy of the employee's medical history

   The medical questionnaire responses

   A copy of all medical test results

   The physicians' recommendations

   Any employee medical complaints related to asbestos exposure

   The physicians' written opinion

   A copy of the information provided to the physician by the employee

OSHA provides a broad spectrum of specific tests physicians must perform as part of the medical surveillance program.
Certain tests are required by OSHA as a minimum in order to be in compliance with regulations. These minimum
requirements for medical examination are as follows:

   A report of the employee's medical and work history

   A complete physical examination with emphasis on the respiratory and cardiovascular systems and digestive tract
    (to be performed at least annually)

   Completion of the medical questionnaire

   A pulmonary function test whose purpose is to assert not only the state of the employee's respiratory health, but also
    his/her ability to use a negative pressure respirator




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AP2-Notifications and Labeling

Warning Labels
29 CFR 1926.1101 and 1910.1001 require that labels be affixed to all products containing asbestos and to all containers
containing such products, including waste containers. Where feasible, all asbestos products shall contain a visible label.
Labels shall be printed in large bold letters on contrasting background in accordance with the requirements of 29 CFR
1910.1200(f) of OSHA's Hazard Communication Standard, and shall contain the following information:



                                                DANGER
                                        CONTAINS ASBESTOS FIBERS
                                          AVOID CREATING DUST
                                        CANCER AND LUNG DISEASE
                                                HAZARD



Warning Signs
The building owner shall post warning signs at the entrance to rooms or areas (which contain ACBM) into which
employees can reasonably be expected to enter. Warning signs are also required to indicate regulated work areas. The
warning sign shall identify the ACBM material which is present, its location, and appropriate work practices which, if
followed, will ensure that the ACBM or PACM will not be disturbed. The warning signs shall state the following
information:
                                                 DANGER

                                                ASBESTOS

                             CANCER AND LUNG DISEASE HAZARD

                                 AUTHORIZED PERSONNEL ONLY



In addition, where the use of respirators and protective clothing is required, the warning signs shall include the
following:

                          RESPIRATORS AND PROTECTIVE CLOTHING

                                    ARE REQUIRED IN THIS AREA



In addition, a more site-specific warning sign could be developed from the example provided
as Exhibit 3-1.


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EXHIBIT 3-1
Employee Notification Sign


THE FOLLOWING MATERIALS AT BUILDING___________________________________

FORT BUCHANAN HAVE BEEN IDENTIFIED AS ASBESTOS-CONTAINING OR ARE
PRESUMEDASBESTOS-CONTAINING:

   Flooring materials and adhesives located throughout the building

   Drywall, mud and tape located through out the building

   HVAC duct mastic materials

   Cove base and adhesives

   Transite panels on laboratory hoods

   Window caulking material on north-side aluminum windows

   insulating materials on boiler lines, domestic water lines, HVAC lines

   Cementitious Transite panels on the cooling towers

   Sink undercoating

   Roofing materials

Please review the Asbestos Operations and Maintenance Plan located in the Environmental
Office regarding the care of these materials.

NOTE:            MODIFY THIS SIGN AND POST NEAR ACBM IN BUILDINGS AS APPROPRIATE.

Notifications
The APM is responsible for informing building occupants and those who may come in contact with asbestos-containing
materials about its location in order to prevent inadvertent disturbances. This includes employees, facility maintenance
employees, tenants, and outside contractors. Section 4 of the "Green Book" includes information on occupant, tenant,
and worker notification of the presence of ACBM.

Employee Awareness Notification
Employees and tenants should be informed about the location of ACBM, instructed to avoid
disturbance of these materials, and told to report damage or suspected releases to the APM.
This notification can be written or communicated verbally.



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In addition, facility maintenance employees should be prohibited from conducting activities that would disturb ACBM
without prior authorization from the APM. Facility maintenance employees working in areas with ACBM are required to
complete the asbestos awareness training mentioned in AP1 and should be familiar with the general Work Practices
presented in Section 4 of this O&M Plan. Form 1 in AP5 should be completed as documentation of facility maintenance
awareness training session.

Outside Contractor Notification
Outside contractors need to be informed of the location of ACBM if present in the buildings they will be working in. The
Contractor Notification form (Form 2 in AP5) should be used to inform all contractors of potential asbestos hazards they
may encounter at Fort Buchanan.

Asbestos Abatement Contractor Notification
The asbestos abatement contractor retained to perform operation and maintenance activities will be notified in the
contract documents or separate letter about the location and content of ACBM. When asbestos abatement work is being
planned, the employees working in and near the area of the abatement should be provided information about:

   The specific work to be performed

   The abatement work schedule

   Precautions being taken

   What will be visible during the work

   That posted warning signs must be obeyed

Form 3 in AP5, titled Employee Notification of an Asbestos Abatement Project, can be used to document this
notification.

Agency Notifications
The APM, or his designee, should file all notices required by federal, state, and local regulations prior to the start of any
O&M activities that are governed by these regulations. Federal requirements for notification are established by the
NESHAP rules, EPA Worker Protection Rule, and OSHA regulations. Written notification to EPA is required for
demolition or renovation work involving asbestos above certain quantities per 40 CFR 61.145, (a) and (b). If the
combined amounts of regulated asbestos-containing material (RACM) to be stripped, removed, dislodged, cut, drilled or
similarly disturbed is over 260 linear feet (80 linear meters), 160 square feet (15 square meters), or 35 cubic feet (1 cubic
meter) for any single project, notice must be given at least 10 working days prior to beginning work. Also, if the
combined estimated quantities of RACM to be removed or stripped in individual non-scheduled operations during a
calendar year (January 1 through December 31) exceed the amounts listed above, a NESHAP notice must be submitted
at least 10 working days before the end of the calendar year (e.g., December 15), preceding the year for which notice is
being given. A new written notice must be filed with the EPA if the start date for a project is revised (earlier or later)
from the date filed in the original or a previous notice. A notice must be updated if the amount of asbestos affected
changes by 20 percent or more. Form 4 in AP5, entitled Notification of Demolition and Renovation, can be used for EPA
notification.


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If wetting of RACM during removal would unavoidably damage equipment or present a safety
hazard, written approval from the EPA is required for alternative emission control methods (dry removal).

The EPA notification requirements for emergency renovation work are established by 40 CFR 61.145 (a) and (b). More
information on emergency work is included in AP9.

PREQB Rule 422 for managing materials containing asbestos also requires agency notification. In accordance with this
rule, a work plan must be submitted to the PREQB 30 days prior to starting work on materials containing asbestos. In
addition, local Law Number 9, titled the Environmental Public Policy Act of June 18, 1970, requires the evaluation of
the project to determine the potential environmental impact. Once the project is evaluated and found not to adversely
affect the environment, the proper air emission and special waste disposal permits must be obtained prior to the start of
abatement activities.



AP3-Periodic Surveillance and Re-inspection
Visual monitoring of ACBM should be accomplished at set intervals. The purpose of this monitoring is to ensure that
personnel discover any damaged or deteriorated ACBM as soon as possible. This allows management to take the
appropriate corrective actions. Both the custodial and maintenance staff should monitor the condition of asbestos
in their work areas. In the event of a problem, such as the deterioration of insulation around a pipe, the staff should
contact their supervisor and the APM as soon as possible.

Periodic Surveillance
Periodic surveillance should be conducted at least every 6 months. The surveillance should include visual observations
recorded on a periodic surveillance form (refer to AP5, Form 5) that should be turned in to the APM.

No formal training requirements exist for conducting this surveillance program. It is recommended, however, that the
personnel who will conduct the periodic surveillance attend an EPA-accredited training class for an asbestos
Inspector/Management Planner. When conducting periodic surveillance, it is important to note key information such as:

   Building number

   Building name

   Location of the facility

   Location of the specific area

   Number of the area (if applicable)

   Any changes to the condition of the area, e.g., type of work that is being conducted in area

   Any changes in the condition of the ACBM

All of this information is important, but the most important information is the location of the ACBM and its condition.


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Re-inspection Program
A complete re-inspection of the facility should be conducted at least every 3 years and completed by a certified
asbestos Inspector/Management Planner. A re-inspection form is located in AP5 (Form 6). During a re-inspection, the
majority of the information is the same as in the periodic surveillance. The primary difference when conducting a
re-inspection is that in addition to noting the condition of the material and the friability, the inspector must also
note the potential for disturbance and give a response action to the material. At this time, The O&M Plan and
asbestos inventory should be updated to show the newest changes found during the re-inspection. These re-inspections
ensure that the O&M Plan can be kept current to show any changes in the response actions, condition of the
ACBM, and the use of the functional space in which the ACBM exists. Any of these areas can be used to
identify the possibility of a new hazard in the facility.



AP4-Work Permit Program
This procedure is used as the basis for determining the proper response by the APM to ensure that ACBM is handled in a
manner that minimizes the potential for exposure. A work permit program is implemented by the APM to control and
prevent disturbances of ACBM during maintenance, renovation, and remodeling work. The APM requires that a Job
Request Form for Maintenance Work (Form 7 in AP5) be submitted prior to any work occurring which may impact
building materials within the facility. The job request form should provide the APM with the name of the person or
persons who will be conducting the work, the time, location of, and type of job, as well as any information known about
the presence of ACBM. After the APM has received the job request form, the APM should:

   Review the asbestos inventory and relevant Asbestos Survey and Assessment Reports and any other pertinent
    records to determine if ACBM is located within the intended work site

   Request that the Inspection Branch visit the intended work site and determine whether asbestos that may be present
    is likely to be disturbed by the work.

If the APM determines that ACBM is not located within the work area, the APM should complete the Maintenance
Work Authorization Form (Form 8 in AP5) and submit it to the Chief of the O&M Division.

If asbestos is found within the intended work area, and the APM determines that the disturbance of the ACBM is
unlikely, the APM should:

   Complete the Maintenance Work Authorization Form and submit it to the Chief of the O&M Division. The
    Authorization Form should inform the workers of the location of the asbestos, provide the worker with Work
    Practices (see Section 4) which, if followed, will avoid or minimize the disturbance of the ACBM.

   Instruct the Inspection Branch to conduct periodic visits to the work site to determine if the condition of the material
    or work practices have changed. The Work Evaluation Form (Form 9 in AP5) should be used to record this data.

If asbestos is found within the intended work area, and the APM determines that the work may impact the ACBM, the
APM should complete the Maintenance Work Authorization Form and submit it to the Chief of the O&M Division. The
Authorization Form should:


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   Recommend that the ACBM be removed prior to the proposed work by an Asbestos Contractor or

   Recommend that work practices found within this Plan be used to minimize the disturbance.

Exhibit 3-2, the Work Permit Program checklist, may assist the APM with following this procedure.

Whenever possible, all work disturbing ACBM should be scheduled for a time when the work area will not be in use and
can be closed off to anyone other than trained workers or other authorized personnel. If an area is always occupied, plans
should be made to isolate the work area from building occupants using visual and/or physical barriers. If a special work
area arrangement is required, it may be beneficial to provide a sketch to the workers showing how the area is to be set
up. If respirators are to be used, it may be desirable to vacate the area to avoid concerns that a worker using a respirator
may prompt from unprotected workers/occupants.

Scheduling of work might be affected by notification requirements. All notification requirements should be met before
work is scheduled (refer to AP2). Under certain circumstances, some emergency work can be performed prior to the
filing of a notification and permits from PREQB. For notification requirements regarding emergency work, contact the
PREQB, as discussed in AP9.


EXHIBIT 3-2
Work Permit Program Checklist



        ‫ڤ‬        Receive and review Form 7- Job Request Form for Maintenance Work
        ‫ڤ‬        Work to be performed: (FILL OUT AS REQUIRED)

        ‫ڤ‬        Review or request survey data to determine whether ACBM is affected

        ‫ڤ‬        Complete Form 8- Maintenance Work Authorization Form

        ‫ڤ‬        Review historical air monitoring data for work practices to be used

        ‫ڤ‬        Select Work Practice(s) for all ACBM to be encountered

        ‫ڤ‬        Select personnel protective equipment and decontamination requirements to be used, if needed

        ‫ڤ‬        Select appropriate materials and review potential hazards (confined spaces, scaffold use, etc.)

        ‫ڤ‬        Schedule work when area is not in use or develop a plan to isolate area (if necessary)

        ‫ڤ‬        Federal, state, and local notifications filed (if applicable)

        ‫ڤ‬        Notify personnel affected by work

        ‫ڤ‬        Assign workers (or contractor) with appropriate level of training and verify currency of training, fit tests,
                 and medical surveillance


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        ‫ڤ‬        Assign trained air monitoring person and determine air monitoring to be performed, if needed. Record
                 air monitoring requirements on Maintenance Work Authorization Form


        ‫ڤ‬        Provide copies to workers / contractor of:

                Maintenance Work Authorization Form
                Work Practice checklist for proper work level
                Work Practice(s):
                Administrative Procedure(s)
                Notifications
                Schedule of work


        ‫ڤ‬        As practical, review work practices during work for compliance with requirements


        ‫ڤ‬        Complete Form 9— Work Evaluation Form


        ‫ڤ‬        File all required records in proper files


         Signed: _________________________________                 Date: ____________________




AP5-Recordkeeping and Forms
The APM is responsible for maintaining documentation related to all facets of the Asbestos O&M Plan. A well-maintained and
comprehensive record keeping program is a necessity for protecting residents and workers from exposure and
demonstrating compliance with the regulations. This documentation will also be used to evaluate and modify the
asbestos management program and work practices.

The EPA's "Green Book" recommends retention of the following records of O&M work in permanent files:

   Inspection and Assessment Reports

   A copy of the O&M Program (initial program and all updated versions)

   The Work Practices Used

   Respiratory Protection Program

   Fiber Release Reports

   Job Request Forms for Maintenance work


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   Maintenance Work Authorization Forms

   Evaluation Forms

   Periodic Surveillance and Re-inspection Reports

For employers with employees engaged in asbestos-related work, federal regulations require that the employer retain:

   Personal Air Sampling and Exposure Monitoring Records

   Historical Data (used to qualify for exemptions from 051-IA's initial monitoring requirements)

   Medical Records (for employees subject to a medical surveillance program)

   Employee Training Records

   Fit Test Records (for employees who use respirators)

OSHA requires that employers provide to each employee their record of exposure and medical surveillance under the
Records Access Standard (29 CFR 1910.20) and the Hazard Communication Standard (29 CFR 1910.1200 & 1926.59). -

The asbestos inventory in Appendix A and the corresponding drawings in Appendix B should also be updated after each
abatement project. In addition, the following records must also be retained:

   Waste Tracking and Disposal
   Air Monitoring Data
   Qualifications, Training and Fit Test records for outside contractors Copies of Agency Notification Letters and
    PREQB Permits
   Analytical data collected within the facility (such as settled dust sampling)

EPA recommends that building owners make available all written elements of the Asbestos
Management Program to the building's staff, as well as to tenants and building occupants.
Building owners are also encouraged to consult with their legal counsel concerning appropriate
record keeping strategies as a standard part of their asbestos management programs.

The following example forms are provided in this procedure to assist the APM with activity documentation:




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Form 1--Record of Two Hour Asbestos Awareness Training

Form 2--Contractor Notification Form

Form 3--Employee Notification of an Asbestos Abatement Project

Form 4--Periodic Surveillance Log

Form 5--ACBM Re-inspection Form

Form 6--Job Request Form for Maintenance Work

Form 7--Maintenance Work Authorization Form

Form 8--Work Evaluation Form

Form 9--Fiber Release Episode Report



                                          FORMS




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FORM 1
RECORD OF 2-HOUR ASBESTOS AWARENESS TRAINING
Fort Buchanan has implemented a program to help minimize exposure to asbestos-containing materials. Part of this
program includes providing an asbestos awareness training session. This training session will be approximately two
hours and will cover the following topics:

    Information regarding asbestos and its various uses and forms
    Location of ACBM in the facility
    Health effects associated with asbestos exposure
    Recognition of damage, deterioration, and delamination of ACBM
    Proper response to fiber release episodes
    Housekeeping requirements relative to the General Industry Standard
    Name and phone number for the Asbestos Program Manager
    Question and answer-period to discuss asbestos in the building
    Location of the Asbestos Survey Reports and O&M Plan


This is to verify the employees named below attended the Asbestos Awareness Training.



Employee Name/Title                                     Social Security Number             Date

Employee Name/Title                                     Social Security Number             Date

Employee Name/Title                                     Social Security Number             Date

Employee Name/Title                                     Social Security Number             Date

Employee Name/Title                                     Social Security Number             Date




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Employee Name/Title                        Social Security Number                            Date



Name of Asbestos Awareness Trainer _________________________________

FORM 2
CONTRACTOR NOTIFICATION FORM
To comply with relevant federal and state laws and the Fort Buchanan Operations and Maintenance Plan, the
Environmental Office will provide the Contractor with the data regarding the locations of asbestos-containing building
materials (ACBM). This will be done prior to the Contractor entering any building at Fort Buchanan.


Please complete this form and return to:
Mr. Anibal Negron, Building 556, DPW Environmental Office


I,                      representing and haying the authority for ________________________ (company), hereby
indicate and agree that a representative of Ft. Buchanan, Mr. Anibal Negron. Asbestos Program Manager. has provided
me information regarding the specific locations and materials that are asbestos-containing and that may be encountered
or have the potential of being encountered during the course of activities on project ____________________
(name or number) in _______________________________________________________________ (building).


I agree that neither I, nor any of my employees, agents, subcontractors, or other individuals or entities over whom I have
any responsibility or control, will disturb ACBM as found in the asbestos inspection for the above-mentioned building.


I further understand and agree that should I, my employees, agents, subcontractors, or other individuals or entities over
whom I have control, encounter any material(s) suspected of containing asbestos, said material(s) shall not be disturbed
without first notifying the facility's Asbestos Program Manager, or appointed designee, and receiving approval that such
material may be disturbed.
_______________________________________________________________________________________
Print Name                            Signature                                 Date

________________________________________________________________________________________
Company                                                                      Position

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FORM 3
EMPLOYEE NOTIFICATION OF AN ASBESTOS ABATEMENT PROJECT
Date of Notification: _____________

On the above date, facility employees, and maintenance contractors were provided with the following information
concerning a scheduled asbestos abatement project.

    Location of asbestos abatement project

    Size of project

   Start date of project

   Projected completion date

   Name of asbestos abatement contractor

   Name of Outside Asbestos Management Consultant

   Name, address, and phone number of Asbestos Coordinator and Corporate Asbestos Coordinator

The notification was made by the following method:

__________________________________________________________________________________
(Letter to employees, mailings, posted notices, etc.)



________________ Notification attached.




_________________________________________
Asbestos Program Manager

_______________________
Date




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FORM 4
PERIODIC SURVEILLANCE LOG
Please complete the last column with your initials and the date when the six-month surveillance is performed.

Personnel Performing           Observations                   Date                  Initials (when
    Surveillance                                                                     completed)




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Form 5
ACBM RE-INSPECTION FORM
(To be completed by an AHERA-accredited inspector every 3 years)
Location of asbestos-containing building material(s) and general description:


Type of ACBM(s):

    1. Friable Surfacing Material ACBM.

    2. Thermal System Insulation.

    3. Non-friable ACBM.

    4. Other (describe):

Assessment:

1. Evidence of physical damage:


2. Evidence of water damage:


3. Evidence of delamination or other:


4. Degree of accessibility of the material:


5. Degree of activity near the material:


6. Location in an air plenum, air shaft, or air stream:


7. Other observations (including the condition of the encapsulant or enclosure, if any):

Printed Name: _________________________________


Signed: _______________________________________

Date:_________________________


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Note: Review Appendix A of the O&M Plan for a description and location of ACBM within the facility. Attach
current inspector accreditation certificate.



FORM 6
JOB REQUEST FORM FOR MAINTENANCE WORK
Name:

Date:

Telephone No.

Job Request No

Requested starting date:                            Anticipated finish date:

Address, building, and room number(s) (or description of area) where work is to be performed:

Description of work:

Description of any asbestos-containing material that might be affected, if known (include location and type):

Name and telephone number of requestor:

Name and telephone number of supervisor:

Submit this application to:

(The Asbestos Program Manager)

NOTE: An application must be submitted for all maintenance work whether or not asbestos-containing
material might be affected. An authorization form must then be received before any work can proceed

______ Granted (Job Request No. __________________)
______ With conditions*
______ Denied

*Conditions:




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FORM 7
MAINTENANCE WORK AUTHORIZATION FORM
                                                                      No. __________________

Authorization is given to proceed with the following maintenance work:


Presence of Asbestos-Containing Building Material (ACBM)

______ ACBM is not present in the vicinity of the maintenance work.

______ ACBM is present, but its disturbance is not anticipated; however, if conditions change, the Asbestos
       Program Manager will re-evaluate the work request prior to proceeding.

_____ ACBM is present and may be disturbed.

Work Practice if ACBM is Present

The following work practices shall be employed to avoid or minimize disturbing asbestos (See Section 4):

Personal Protection if ACBM is Present

The following clothes shall be worn and equipment used during the work to protect workers (manuals on
personal protection can be referenced): _________________________________________




Special Practices and/or Equipment Required




Signed ___________________________________________________________ Date: _____________




                 Asbestos Program Manager (or appointed designee)

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FORM 8
WORK EVALUATION FORM
This evaluation covers the following maintenance work:

Location of work (address, building, room number(s), or general description):

Date(s) of work:

Description of work:

Work approval form number:

Evaluation of work practices employed to minimize disturbance of asbestos

Evaluation of work practices employed to contain released fibers and to clean up the work area:

Evaluation of equipment and procedures used to protect workers:


Personal air monitoring results: (in-house worker or contract?'


Worker name                                                              Results

Worker name                                                              Results

Handling or storage of ACBM waste:


Signed _________________________________________                            Date __________




         Asbestos Program Manager (or appointed designee)




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FORM 9
FIBER RELEASE EPISODE REPORT
Facility:


Building and room number(s) (or description of area) where episode occurred:




            Name of person reporting the release:


            Date of release:


            Describe the episode:




            Describe the cleanup procedures:




            Name(s) of person(s) cleaning up the release:

        Are they certified asbestos workers?                                   ____Yes ____No
            If YES, what are the certification number(s).



Signed_____________________________________________ Date _____________




            Asbestos Program Manager (or appointed designee)


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AP6-Selection of Personal Protective Equipment and
Decontamination Procedures
Personnel potentially exposed to asbestos must be provided with clean protective work clothing and equipment, and
appropriate decontamination facilities.

Protective Clothing and Equipment
Appropriate protective work clothing and equipment shall include coveralls or similar full-body work clothing, gloves,
hard hats, safety shoes, or disposable shoe covers, and eye protection. Protective clothing for O&M work will be selected
by the APM with confirmation by the Fort Buchanan Health Clinic Industrial Hygiene and Preventative Medicine
Branch. An industrial hygienist performs worker assessments and ensures that personnel needing PPE such as respiratory
protection are cleared medically and fit tested. This Branch also maintains the records of personnel who have been
issued PPE. Protective clothing selections should be recorded on the Maintenance Work Authorization Form (Form 8 in
AP5). The supply of PPE is maintained by each individual division at Fort Buchanan.

Each HEPA vacuum manufacturer requires slightly different maintenance procedures for disposing of dust and debris
from the tank and for replacing filters. Instructions from each manufacturer must be followed for any particular type of
HEPA vacuum. The following will apply to all HEPA vacuum maintenance regardless of manufacturer:

   A properly fitted respirator and   PPE including gloves will be worn

    A location will be selected that is not subject to cross drafts or wind

Decontamination
At no time shall workers be allowed to leave the work site wearing asbestos-contaminated clothing or equipment. All
contaminated clothing or equipment shall remain in the equipment room or work area. This is a significant step in
preventing the movement of asbestos contamination from the regulated area to an uncontaminated area.

Contaminated clothing that is to be cleaned, laundered, or disposed of should be placed in closed containers. The use of
disposable whole-body coverall is recommended. Persons responsible for handling contaminated clothing must be
informed of the potential hazards. Warning labels must be placed on the containers. At no time shall asbestos be
removed from protective cloths or equipment by any means that entrains asbestos into air, such as brushing, shaking,
blowing, or using a non-HEPA vacuum cleaner.

To decontaminate a HEPA vacuum, a wipe down will be performed with damp cloths, sponges, or towels that will be
discarded with asbestos waste. All bags and filters will be misted with amended water before handling and removal, if
practical. HEPA vacuum bags and filters will be double bagged in labeled asbestos waste disposal bags and discarded in
accordance with asbestos waste disposal practices including notification of regulatory agencies and approved landfills.




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AP7-Developing the Air Monitoring Program
The Air Monitoring Program developed for a specific facility must address how exposure monitoring will be conducted
to provide data for use in the design and validation of work practices. The program should define exposure limits for
both workers and the building environment.

The Air Monitoring Program should also specify when air monitoring will be performed, the types of monitoring
(personnel, background, area, clearance, periodic and/or initial), analysis methods, training requirements for monitoring
personnel, and procedures for maintaining data from O&M activities, including any data required for OSHA historical
data monitoring exemptions. Air monitoring data should be considered when selecting the type of respirators for
activities that require respiratory protection.

Design and Validation of an O&M Program
The APM using the O&M Plan should determine the exposure objectives for the facility. Establishment of limits on
airborne asbestos for each work practice level determines the exposures to which maintenance workers and building
occupants will be subjected. As a minimum, the requirements of the OSHA regulation must be met. These air monitoring
requirements provide building owners and managers with the information necessary to determine what level of
protection is required by the federal government. Exposure monitoring will be needed to validate that each work practice
level meets the intended exposure goals. To fit within the level definitions, the following must hold true:

   Level 1 (No Worker or Area Protection). Work practices should not result in elevated
    airborne asbestos levels. Disturbance of ACBM will not occur.

    Level 2 (Worker Protection, with Minimal Area Protection). Work practices may result in localized elevations of
     airborne asbestos levels that may only affect the worker, but not the building environment.

   Level 3 (Worker and Area Protection). Work practices may, if uncontrolled, result in elevations of airborne asbestos
    levels that are sufficient to require worker protection and isolation of the work area from the rest of the facility.

O&M programs should always emphasize the use of exposure reduction methods (such as wetting or local exhaust
ventilation, etc.) to avoid unnecessary disturbance of asbestos and the need for work area isolation. Work procedures, or
modifications to them, should be designed to fit the exposure goals of the owner and/or employer, the circumstances of
the particular building, and the skill and training of the APM and workers. The only way that a work practice can be
validated is to perform the procedure and monitor airborne levels during and after the work. Personal monitoring is
required to determine whether work area isolation is needed. If no disturbance of ACBM will occur (such as with many
Level 1 work practices), monitoring may not be required. Meaningful exposure monitoring requires sufficiently long
sample durations (readings are not instantaneous). O&M procedures are small in scale and short in duration, requiring
that many procedures be repeated a number of times to enable the collection of a sample with sufficient accuracy. Note:
This section is not intended as a substitute for a complete Air Monitoring Program needed for O&M work. This section
note
air/monitoring issues that the APM needs to address at Fort Buchanan. The abatement activities and air monitoring at
Fort Buchanan will be performed by outside contractors. In certain cases where frequent O&M activities are performed,
the O&M program may include having one or more designated, trained workers perform air monitoring during O&M
activities. The workers performing the air monitoring should be certified by PREQB as air monitors.



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Training required for the Air Monitoring Program includes NIOSH air monitoring course (H582), industrial hygiene
training, or other requirements. Training for persons performing air-monitoring work should include hands-on training
with the equipment to be used. Personnel performing air monitoring should also be PREQB-certified.

Air monitoring requirements for a given work practice should be based on the Air Monitoring Program and
stated on the Maintenance Work Authorization Form. Exposure monitoring should be addressed in the Air Monitoring
Program and is required for operations covered by OSHA regulations. Review applicable OSHA and PREQB regulations
in detail when developing air monitoring procedures for O&M work. OSHA regulations (29 CFR 1926.1101 and
1910.1001) require an initial exposure assessment or a negative exposure assessment.

Initial Exposure Assessment
Each employer who has a work place or work operation covered by this standard shall ensure that a competent person
conducts an exposure assessment immediately before or at the initiation of the operation to assess expected exposures
during that operation or work place. The assessment must be completed in time to comply with requirements that are
triggered by exposure data or the lack of a negative exposure assessment, and to provide information necessary to assure
that all control systems planned are appropriate for that operation and will work properly. The initial exposure
assessment shall be based on data derived from the following sources:

   If feasible, the employer shall monitor employees and base the exposure assessment on the results of exposure
    monitoring which is conducted pursuant to the criteria in 29 CFR


   In addition, the assessment shall include consideration of all observations, information or calculations which
    indicate employee exposure to asbestos (including any previous monitoring conducted in the work place), or

   The operations of the employer which indicate the levels of airborne asbestos likely to be encountered on the job.
    However, the assessment may conclude that exposures are likely to be consistently below PELs only as a
    conclusion of a negative exposure assessment conducted pursuant to paragraph 29 CFR 1926.1101(f)(2)(iii) of the
    OSHA standard.

Negative Exposure Assessment
A negative exposure assessment means a demonstration by the employer that employee exposure during an operation is
expected to be consistently below the PELs. This demonstration must comply with the following criteria in 29 CFR
1926.1101(f)(2)(iii):

   Objective data demonstrating that the product or material containing asbestos minerals or the activity involving such
    product or material cannot release airborne fibers in concentrations exceeding the time-weighted average (TWA)
    and excursion limit r those work conditions having the greatest potential for releasing asbestos; or

   Where the employer has monitored prior asbestos jobs for the PEL and the excursion limit within 12 months of the
    current or projected job. The monitoring and analysis were performed in compliance with the asbestos standard in
    effect; and the data were obtained during work operations conducted under work place conditions "closely
    resembling" the processes, type of material, control methods, work practices, and environmental condition used and
    prevailing in the employer's current operations, the operations were conducted employees whose training and


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    experience are no more extensive than that of employees performing the current job, and these data show that under
    the conditions prevailing and which will prevail in the current work place there is a high degree of certainty that
    employee exposures will not exceed the TWA and excursion limit; or

   The results of initial exposure monitoring made from breathing zone air samples (representative of the 8-hour
    TWA and/or 30-minute short-term exposures of each employee covering operations) which are most likely during
    the performance of the entire asbestos job to result in exposures over the PELs.

"Closely Resemble" as used in 29 CFR 1926.1101(f)(2)(iii), means that the major work place conditions which have
contributed to the levels of historic asbestos exposure, are no more protective than conditions of the current work place.
In other words, conditions of the current work place are no worse than the conditions present in the work place where the
historical air monitoring data were collected).

Periodic Monitoring and Observation of Monitoring
The OSHA standard also has a requirement for periodic monitoring and for observation of monitoring. These
requirements are summarized as follows:

   Daily monitoring must be conducted for all Class I and Class II operations, unless a negative exposure assessment
    has been made for the entire operation. Please note that Fort Buchanan personnel shall not conduct Class I and
    II operations.

   Periodic monitoring must be conducted for all operations under the OSHA standard (other than Class I and II
    operations) at intervals to verify that the PEL is not being exceeded.

   When all employees are equipped with supplied-air respirators operated in positive pressure mode, the employer
    may dispense with the daily monitoring unless the operation is a Class I operation and alternative control methods
    not listed in the standard are being used. In this case, periodic monitoring must continue regardless of the respiratory
    protection.

Termination of Monitoring
If the periodic monitoring required by 29 CER 1926.1101 (f)(3) reveals that employee exposures, as indicated by
statistically reliable measurements, are below the action level, the employer may discontinue monitoring "for those
employees whose exposures are represented by such monitoring."

Once data are generated for a certain work practice in a given facility, the APM should be able to judge whether that
level of work practice is appropriate for O&M work in that facility and whether more air monitoring is necessary. In
certain situations (i.e., removals of resilient floor coverings using manufacturer's recommended practices), OSHA has
allowed the use of data generated by third party manufacturers to support a claim for an exemption from initial air
monitoring. Personal air monitoring is required following changes in work practices, employees, employee skill levels,
or other pertinent factors which could lead to the OSHA PEL being exceeded. Validation of the work practices using air
monitoring data applies only when the OSHA monitoring requirements listed above are met.

Personal monitoring (8-hour TWA) shall consist of one or more samples representing full shift exposure for employees
in each work area. If possible, samples should be based on an 8-hour TWA. If this is not possible, an excursion limit
sample could be run for at least 36 minutes. All analysis for OSHA compliance should be by Phase Contrast Microscopy

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(PCM). Transmission Electron Microscopy (TEM) analysis will distinguish asbestos fibers from other fibers and might
also be used if desired, although PCM data is required by OSHA. TEM data cannot be substituted for OSHA-required
PCM data, unless approved by the local OSHA office. The use of TEM analysis or settled dust sampling to evaluate the
need for pre-cleaning prior to an O&M activity might be considered. Neither method is required by current regulations.

Settled Dust Sampling
There is currently no agreement on the efficacy of settled dust sampling, nor is there a tendency to advocate its use. It is
presented here as an available analytical tool that might be used, since
it can be related to estimated air concentrations if the area was to be aggressively sampled. Settled dust sampling can
also be used during O&M activities to document disturbances during the activity. Settled dust sampling might be used as
part of a clearance protocol for O&M work, but no regulatory standards for dust sampling exist at this time. The APM
may wish to consult with an experienced laboratory or consultant(s) regarding the latest settled dust sampling
procedures and protocols. Procedures commonly in use include micro vacuuming, surface wipe samples, and tape
lift methods.

Clearance Testing Following O&M Activities
After work is completed, a thorough cleaning will be necessary. No visible dust or debris should be left in the work area.
Clearance testing refers to air monitoring in the work area after abatement and cleaning or O&M activities to verify that
the building or work area is ready to be re-occupied. Clearance testing involves measuring airborne fiber concentrations
and is usually performed by certified inspectors. OSHA currently requires clearance monitoring in accordance with the
NIOSH Method 7400, Phase Contrast Microscopy Analysis. This method entails drawing air samples into 25-mm
cassettes with 0.8 micrometer mixed cellulose ester backing filters~ The sample is then prepared for PCM and the total
number of fibers present are counted. Below are the recommended guidelines for clearance sampling and analysis:


                                                           Sampling
                                                          Sensitivity
                                                          (fibers/cm)
                                                        Desired Volume
                                                             (Liters)
  Location Sampled No. of Samples                                                               Rate (LPM)
Each Work Area              1-5                        0.01         1200 to 1800                   1-10
 Work Area (Blank)           1                         0.01                  0              Open for 30
                                                                                            seconds
Laboratory (Blank)                 1                   0.01                   0             Do Not Open


The work area blank sample is analyzed for quality control purposes along with the laboratory blank which is sent to
an independent laboratory to verify the equipment is free from cross-contamination.

Decontamination of the work site is deemed complete if the air samples analyzed using PCM result in less than
0.01 fibers/cm3 as outline in NIOSH Method 7400. If the fiber concentration is not below this threshold, then additional cleaning
and sampling should occur. In addition, air samples may be taken and analyzed using TEM, a more sensitive method to
distinguish between asbestos and non-asbestos containing fibers.




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AP8-Selection of Materials
The APM should be responsible for the selection of certain materials used for O&M activities.
This manual will not attempt to provide guidance on the selection of all materials needed for
O&M work. Information on selection of the following materials is provided:

   Polyethylene

   Lockdown encapsulants

Guidance on the selection of other materials should be obtained in training courses, or from reference materials, such as
the NIBS Guide Specifications for Asbestos Abatement.

Polyethylene
Polyethylene is commonly hung as curtains or tents to contain asbestos fibers preventing them from releasing outside of
the work area. Various thickness, colors, and types of polyethylene are available. The most common thicknesses used for
asbestos-related work are 4 mil and 6 mil (0.10 mm and 0.15 mm). Two mil (0.05 mm) polyethylene is also available,
but is not recommended because it tears easily and provides a false sense of security. Polyethylene is also available in
fire retardant and anti-static types. Fire retardant polyethylene does not support flame as readily as standard
polyethylene. However, some tests have shown only minimal differences in flame spread time between standard and fire
retardant polyethylene. Anti-static polyethylene should be used around equipment sensitive to static electricity.

Lockdown Encapsulants
Once final cleaning of an asbestos material is complete, a coating or lockdown encapsulant can be applied to immobilize
remaining invisible asbestos fibers. Lockdown encapsulants selected should be appropriate for the intended use. Never
use an encapsulant with a flash-point of less than 1400F. Use high temperature-rated encapsulants for heating system
components, such as piping, boilers, and flues. Lockdowns should also be compatible with any replacement materials,
such as new flooring adhesive. Compatibility should be verified before the start of work.

Lockdowns are available in clear or colored mixtures. Clear mixture should be used where a colored encapsulant would
be objectionable for appearance reasons. Colored encapsulants should be used (where possible) with a color chosen to
indicate that an area has been locked down. The color also allows a worker to see where encapsulant has been applied
during the application.



AP9-Emergency Responses
The asbestos management program at Fort Buchanan is designed to reduce disruption of ACBM. However, the presence
of ACBM, coupled with facility operations may present a situation where an accidental disturbance of ACBM is
possible. Emergency response is necessary when this occurs. The level of response depends on the extent of the
disruption, where it occurred, when it occurred, and family and employee occupancy patterns relative to the occurrence.
Once these factors are assessed, the APM will direct the specific actions needed to respond to the incident.




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General Response to a Fiber Release
In case of an accidental disturbance of ACBM, the APM shall insure that the following steps are taken:

1.   Turn off the HVAC system in the area of the disturbance.

2.   Restrict access to the area of disturbance.

3.   Determine level of fiber release.

4.   Mist the disturbed area with water.

5.   Contact trained and certified personnel or an asbestos abatement contractor to clean up the disturbance.

6.   Notify the PREQB

7.   Complete the Fiber Release Episode Report

Emergency work is acknowledged in regulations and is permitted under certain conditions. The NESHAP and PREQB
regulations specify that a notification for emergency renovation operations must be postmarked or delivered by the
following working day.

Emergency work may involve activities (such as work around activated electrical equipment) where the use of wetting
would result in equipment damage or a safety hazard. The regulations allow work without wetting regulated ACBM
under specific situations. For facilities where dry removal work might be required, the APM should review regulatory
requirements in 40 CFR 61, Subpart M, in advance and with the authorities who have jurisdiction over the facility.

A fiber release episode is considered an accidental or purposeful event that causes ACBM to fail or become dislodged.
These episodes are categorized into "minor" and "major" episodes depending on the amount of ACBM involved. The
type of episode influences the response action and the type of personnel conducting the response action. In either case,
the APM shall be notified immediately, and a Fiber Release Episode Report (Form 10 in AP5) shall be filled out.

Minor Fiber Release Episode
A minor fiber release episode at Fort Buchanan is defined as a situation when 2 square or linear feet or less of friable
ACBM becomes dislodged or fails. In addition, the release must have occurred in a relatively remote area of the facility.
Maintenance and custodial personnel with 16 hours of EPA accredited training can respond to these episodes. The
procedures that must be followed to respond to a minor fiber release episode include:

               Thoroughly saturate the debris using wet methods

               Clean and wet wipe the area

               Place all asbestos debris in a sealed, labeled, leak-tight container




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Major Fiber Release Episode
A major fiber release episode at Fort Buchanan is defined as a situation when more than 2 square or linear feet of ACBM
fails or becomes dislodged. Only those individuals who have received the 32-hour training course can conduct the
response actions for these episodes. However, until the response action is under way, the APM must:

              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
               of the building

              Contact an asbestos abatement contractor to clean up the release

           The asbestos abatement contractor shall be responsible for isolating the area from the rest of the
           facility, as necessary. For instance, polyethylene sheeting with an applicable support structure
           could be used to isolate the contaminated area. If the space is small or the contamination is
           widespread, pre-cleaning of the wall surfaces may be required. Typically, a change room
           facility would be attached to the isolated area utilizing two-curtain, overlapping flab doorways. The space
           may also be placed under HEPA filtered negative pressure. HEPA-filtered exhaust units are exhausted out of
           the space whenever possible and operated for the duration of the cleanup process. All waste from the cleaning
           shall be disposed of an ACBM. Other surfaces within the isolated area shall be wet wiped and/or HEPA
           vacuumed. After all areas and items have dried (or a minimum of 12 hours), air samples shall be collected
           within the isolated area for analysis by PCM. Remediation will be considered complete when all "inside" air
           samples demonstrate a concentration of 0.01 fibers/cm3, or are statistically below background levels.


SECTION 4


Work Practices
This section describes various specialized work practices that may be performed by Fort Buchanan personnel once they
have completed the asbestos awareness training. The Fort Buchanan APM has decided that all work that may impact
ACBM in excess of 2 square feet or 2 linear feet shall be completed by a contractor with experienced and PREQB-
certified personnel. The only exception is the routine maintenance of asbestos-containing flooring products. The specific
work practices employed on a given occasion will be determined on a case-by-case basis. Each activity will need to be
evaluated by the APM. These Work Practices may also be used as guidelines to define the scope of work when hiring
contractors for maintenance or removal of
ACBM.

   WP1 Wet Strip Floor Wax from Resilient Asbestos Flooring
   WP2 Dry or Spray buffing Resilient Asbestos Flooring
   WP3 Cleaning Resilient Asbestos Flooring

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       WP4 Cut or Drill Asbestos Cement Panels
       WP5 Remove Asbestos Cement Panels
       WP6 Remove Asbestos-containing Built-up Roofing
       WP7 Clean Up Debris
       WPS Replace Asbestos-containing Gaskets and Packing
       WP9 Remove Asbestos-containing Caulking and Glazing Compound
       WP1O Clean Room that has Asbestos-containing Dust
       WPI1 Attach Item to Ceiling Finished with ACBM
       WP12 Repair or Replace Item in Surface Finished with ACBM
       WP13 Replace Bulbs in Light Fixture Attached to or in Surface Finished with ACBM
       WP14 Clean Room with Exposed Surfaces Finished with ACBM
       WP15 Repair Damaged Surfacing ACBM
       WP16 Accessing through an ACBM Finished Surface
       WP17 Painting Surfacing ACBM
       WPI8 Remove Asbestos Containing Insulation Inside HVAC Unit for Maintenance Work
       WP19 Replacement of Resilient Asbestos Floor Tiles
       WP2O Install New Resilient Flooring or Carpeting Over Resilient Asbestos Flooring
      WP2l Install Partition Over Resilient Asbestos Flooring
       WP22 Remove Carpet Over Resilient Asbestos Flooring
Under no circumstances are Fort Buchanan personnel to attempt to remove, disturb, or clean up asbestos-
containing debris. Only an approved asbestos abatement contractor can engage in tasks that disturb or require
removal of ACBM. Asbestos abatement activities conducted at Fort Buchanan shall be completed according to all EPA,
OSHA and PREQB regulations and only after prior written approval from the APM. Prior to any removal work, a set of
asbestos abatement specifications shall be prepared by a PREQB Licensed Project Designer. The specifications shall
identify the abatement scope of work, location of decontamination and waste load-out units, points of access to water
and electricity within the facility, work schedule, insurance requirements, and many other project-specific aspects of the
abatement work. Furthermore, no renovation, demolition, or remodeling is to take place without prior written approval
from the APM.


General Custodial Practice
Areas that contain asbestos need to be cleaned following special procedures to reduce the risk of exposure to airborne
asbestos. All custodial and maintenance personnel should be instructed not to disturb ACBM and to use the
following "do's and don'ts" of cleaning in areas of ACBM.
Do Not:                                                          Do:
-   Dust with a brush                                 -Dust with a damp cloth
-   Dry sweep floors                                  - Wet mop floors
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—   Use an ordinary vacuum to clean up Use only a special HEPA vacuum to
                                           —


    asbestos debris clean up asbestos debris

—   Brush or sweep ceilings and walls Avoid touching or disturbing ceilings
                                       —


     covered with ACBM and walls covered with ACBM


The custodial staff should always use HEPA vacuums to clean carpets, furniture, and drapes in rooms with ACBM.
Bare floors should always be wet-mopped, while dusting should be performed with wet cloths. Any debris that is
found near ACBM, or damaged ACBM, should immediately be reported to a supervisor and removed by properly trained
personnel. All debris, vacuum filters, vacuum bags, cloths, and mop-heads should be misted and disposed of wet m
sealed plastic bags according to EPA and PREQB regulations for asbestos waste.


Worker Checklists
OSHA has defined three levels of work practices involving asbestos. They are:

Level A--work that may contact ACBM but not disturb it. If damaged ACBM is encountered or work could damage
ACBM, a worker must notify their supervisor or the APM.

Level B--Work may disturb ACBM, but the OSHA PEL will not be exceeded and the release of ACBM, dust
and debris is confined to the immediate location of the disturbance.

Level C--Work may disturb ACBM and the OSHA PEL may be exceeded or ACBM, dust or debris may be scattered
beyond the immediate location of the disturbance. Level C work must take place in an enclosure (e.g., glove-bag or
mini-enclosure).

The various work practices in this section may reference these levels of work as appropriate. When referenced, the
following checklists for Level A, B, or C work may be useful to review prior to proceeding with the specified
activity. Fort Buchanan personnel shall not conduct Level B or C asbestos work practices. These levels must
be conducted by an asbestos contractor utilizing personnel certified by the PREQB.


Level A Worker Checklist
Level A work may contact ACBM but not disturb it. If you encounter damaged ACBM, or ~f the work
could damage the ACBM, stop work and not ~fy your supervisor.

Pre-Work Activities

            Obtain and review copies from Supervisor or Asbestos Program Manager (APM) of:

            Completed Maintenance Work Authorization Form,

            Work practice(s) to be used including personal protective equipment options,

            Work Notification(s) (as applicable), and


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           Schedule for work.

           Review work practices and any other administrative procedures used in work practice.

           Inspect work area for visible dust or debris. If present, stop work and notify APM.~

           Obtain recommended tools, equipment and materials as applicable and Maintenance Work Authorization
            Form.

           Move tools, equipment and materials to work area.

           Shut off and lock out any HVAC or electrical systems to be worked on.

           If required on Maintenance Work Authorization Form, put on respirators and perform fit checks.

Work Practices

           Always use wet methods, HEPA vacuums, prompt clean-up and disposal of waste.

           Prohibited practices: Do not dry clean-up dust and debris, or use compressed air or high-speed abrasive
            saws.

           Perform work per steps in work practice(s).

Clean-Up and Tear-Down

           Remove lockout tags (if used) & restart any HVAC or electrical system(s) that were shut off.

           Return tools, equipment and remaining materials to storage area.

           Notify APM or supervisor that work is completed and return documents to APM or site contract.


Level B Worker checklist
Level B work may disturb ACBM, but the OSHA PEL will not be exceeded and the release of ACBM, dust and
debris is confined to the immediate location of the disturbance.

Pre-Work Activities

           Obtain and review copies from Supervisor or Asbestos Program Manager (APM) of:

           Completed Maintenance Work Authorization Form

           Work practice(s) to be used including personal protective equipment options

           Work Notification(s) (as applicable)

           Schedule for work
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           Review work practices and referenced general procedures used in work practice(s).

           Obtain recommended tools, equipment and materials.

           Obtain required respirators as listed on Maintenance Work Authorization Form.

           Move tools, equipment and materials to work area.

           Shut off and lock out 1-IVAC and electrical systems serving work area.

           Vacate and secure work area, such as by locking doors and/or setting up temporary barriers.

           Put on respirators and perform fit checks.

           Put on protective clothing.

           Air monitoring personnel begins air monitoring work (if required).

           Pre-clean work area if visible dust or debris is present.

Work Area

           Set up work area as required by work practice.

Work Practices

           Always use wet methods, HEPA vacuums, prompt clean-up and disposal of waste.

           Prohibited practices: Do not dry clean-up dust and debris, or use compressed air or high-speed abrasive
            saws.

           Perform work per steps in work practice(s).

Clean-Up and Tear-Down

           Package and label asbestos waste for disposal.

           Apply lockdown encapsulant, where required, using garden sprayer, to surfaces where ACBM was
            removed or disturbed.

           Perform ceiling panel replacement work or ceiling repair work if needed.

           Clean tools, equipment and work area using wet wiping and HEPA vacuuming as appropriate and return
            tools and equipment to outside work area.

           Decontaminate packaged waste & move waste to outside work area.

           Workers decontaminate and remove protective clothing and respirators. If contaminated, dispose of
            protective clothing as ACBM.


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           Complete visual inspection. Complete air monitoring work.

           If feasible, get APM or designee to complete Work Evaluation Form.

           Transport waste to designated asbestos waste storage area.

           Remove drop cloth, clean with HEPA/wet methods or properly dispose of as contaminated.

           Return decontaminated tools, equipment and remaining materials to storage area.

           Remove lockout tags and restart HVAC and electrical system(s).

           Restore normal accessibility to work area.

           Notify APM or Supervisor that work is completed and return documents to APM or site contract.


Level C Worker checklist

Level C work may disturb ACBM and the PEL may be exceeded or ACBM, dust, and/or debris may be
scattered beyond the immediate location of the disturbance. Level C work must take place in an enclosure
(glove-bag or mini-enclosure).

Pre-Work Activities

           Obtain and review copies from Supervisor or Asbestos Program Manager (APM) of:

           Completed Maintenance Work Authorization Form,

           Work practice(s) to be used including personal protective equipment options,

           Work Notification(s) (as applicable), and

           Schedule for work.

           Review work practices and referenced general procedures used in work practice(s).

           Obtain recommended tools, equipment and materials.

           Obtain required respirators as listed on Maintenance Work Authorization Form.

           Move tools, equipment and materials to work area.

           Shut off and lock out HVAC and electrical systems serving work area.

           Vacate and secure work area, such as by locking doors and/or setting up temporary barriers.

           Put on respirators and perform fit checks.

           Put on protective clothing.
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           Air monitoring personnel begins air monitoring work (if required).

           Pre-clean work area if visible dust or debris is present.

Work Area

           Perform all Level C work inside an enclosure (glove-bag or mini-enclosure). Set up work area and
            decontamination facilities as required by work practices.

Work Practices

           Always use wet methods, HEPA vacuums, prompt clean-up and disposal of waste.

           Prohibited practices: Do not dry clean-up dust and debris, or use compressed air or high-speed abrasive
            saws.

           Perform work per steps in work practice(s).

Clean-Up and Tear-Down

           Package and label asbestos waste for disposal.

           Apply lockdown encapsulant, where required, using garden sprayer, to surfaces
            where ACBM was removed or disturbed.

           Perform ceiling panel replacement work or ceiling repair work if needed.

           Clean tools, equipment and work area using wet wiping and HEPA vacuuming as appropriate and return
            tools and equipment to outside work area.

           Decontaminate packaged waste & move waste to outside work area.

           Workers decontaminate and remove protective clothing and respirators. If contaminated, dispose of
            protective clothing as ACBM.

           Complete visual inspection. Complete air monitoring work.

           If feasible, get APM or designee to complete Work Evaluation Form.

           Transport waste to designated asbestos waste storage area.

           Remove drop cloth, clean with HEPA and wet methods or properly dispose of as contaminated.

           Return decontaminated tools, equipment and remaining materials to storage area.

           Remove lockout tags and restart HVAC and electrical system(s).

           Restore normal accessibility to work area.


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               Notify APM or Supervisor that work is completed and return documents to APM or site contract.



WP1-Wet Strip Floor Wax from Resilient Asbestos Flooring

Summary
This work practice describes the procedures for stripping floor wax or finish from resilient asbestos flooring.

Note: Do not strip damaged flooring. Any loose or damaged flooring should be repaired or replaced before
stripping is started. Do not dry strip, scrape, sand, or &rind resilient asbestos flooring to remove any
blemishes or imperfections. Stripping pads should be kept wet during use and rinsed thoroughly immediately
after use and prior to storage.

Work Practice
    Place tools, equipment, and materials needed in the work area.


   Adequately wet floor by mop, applying liberal amounts of the stripping chemical. Allow
    chemical to soak for amount of time recommended by manufacturer. Reapply as necessary to keep the floor
    adequately wet.

   After the wax or finish has softened, strip flooring using the least abrasive pad and low speed setting (300 rpm
    maximum). Keep floor adequately wet during machine operation. Do not over-strip. Stop stripping when the old
    wax or finish is removed. Work small areas at a time.

    Remove dirty stripping solution with wet vacuum or "strip" mop.

   With "rinse" mop, apply liberal amount of clean water to area stripped, and remove water with wet vacuum or mop.
    Repeat rinse procedures.
   If some spots of wax or finish remain, re-strip those areas.

   If new flooring will be installed over the stripped floor, do not apply wax or finish. When applying new wax or
    finish, do so according to manufacturer's recommendations.



WP2-Dry or Spray Buffing Resilient Asbestos Flooring

Summary
This work practice describes the procedures for spray buffing the polish to restore gloss on resilient asbestos
flooring.



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Note: Do not buff damaged flooring. Any loose or damaged flooring should be repaired or replaced before
buffing is started. This practice assumes that the floor has adequate coats of polish and the flooring itself will
not be damaged or contacted by the buffing equipment.

Work Practice
   Place tools, equipment, and materials needed in the work area.

   Pick up any loose debris and place into disposal bag. Using scraper and water, remove all foreign matter from the
    finished surface (e.g., gum, tar, stickers).

   Spot or damp mop to remove stains and spills. Mix chemical cleaner or restorer with water, and apply it according
    to manufacturer's recommendations. If dry buffing will be performed, apply restorer chemical as required.

   Allow floor to dry thoroughly.

   To spray-buff, spray small area with spray-buff solution, and buff using manufacturer's recommended pad or brush
    at recommended rpm. Repeat procedure until entire area is spray-buffed.

    To dry buff, buff or dry buffing with manufacturer's recommended pad or brush at recommended rpm.



WP3-Cleaning Resilient Asbestos Flooring

Summary
This work practice describes the procedures for cleaning the polish on resilient asbestos flooring prior to buffing or
application of additional polish.

Note: Do not polish loose or damaged flooring. Any damaged flooring should be repaired or replaced before
cleaning is started.

Work Practice
   Place tools, equipment, and materials needed in the work area.

   Install polyethylene sheeting on adjoining floors for protection from any spilled cleaning solution.

   Mix scrubbing chemical with water as recommended by manufacturer, and apply liberal amount (do not flood)
    using mop. Allow to soak for amount of time recommended by manufacturer. Keep floor adequately wet by
    reapplying cleaning solution. Work small areas at a time.

   Using scrubbing machine, manufacturer's recommended pads and operating speed, clean floor to remove embedded
    dirt and surface marks.


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   Remove spent scrubbing solution with wet vacuum or mop.

   Rinse area using clean mop and clean rinse water. Remove water with wet vacuum or mop. Damp mop area to clean
    up any remaining water or streaks.



WP4-Cut or Drill Asbestos Cement Panels

Summary
This work practice covers the procedures for cutting or drilling asbestos cement panels.

Examples of Level B
An example of Level B work involves drilling a few holes in an asbestos cement board to install a new electrical panel.
OSHA requires that during Class III (O&M) operations that involve drilling, cutting, abrading, sanding, chipping,
breaking, or sawing of thermal system insulation or surfacing materials, the employer shall use impermeable drop-cloths,
and shall isolate the operation using mini-enclosures or glove bag systems, or another isolation method. This work
practice relies on the HEPA exhausted collar on the drill as another isolation method. During design of the
O&M program the designer must be a competent person and must determine that the use of the HEPA exhaust
collar as described in the work practice effectively isolates the drilling work. This evaluation should be based on an
initial exposure assessment, leading to a Negative Exposure Assessment (NEA), as described in the OSHA construction
standard 29 CFR 1926.1101(f)(2). During implementation of the program, the APM must also be a competent
person, and must make a determination that conditions at a specific job site are equivalent to those that existed
during development of the work practice, so that the work practice is applicable. The work order issued to the person
performing the work should inform them of the NEA and any conditions that are attached to the NEA. It is possible
that after there has been some experience with the OSHA regulation the manufacturers of the type of equipment used in
this work practice will make the proper evaluations and submissions to OSHA and provide a copy of this to the O&M
program designer. In any case, as a minimum requirement, the supervisor that assigns work to maintenance staff should
be a competent person able to evaluate the applicability of a dust collection collar with HEPA vacuum to a particular
situation.

Note: An NEA must have been made by a competent person before this work practice is used. Verifii that an
NEA has been made. If an NEA cannot be verified, stop work and not ify your supervisor.

Level B Work Practice
       Perform Pre-work activities on Level B checklist.

       Tools, equipment and materials:

        A. Tools as needed, and

        B. Hand or power drill equipped with a HEPA vacuum dust collection attachment.



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       Secure work area.

       Put down drop cloth.

       If accessible, install a drop cloth on the back side of the panel below where hole will penetrate through panel.

        Place tools, equipment and materials needed onto drop cloth. Adequately wet both sides of area to be drilled
         using garden sprayer with amended water. Keep water away from any electrical cords or equipment.

         A. Drill hole using hand drill or power drill with operating HEPA vacuum attached. Wet drilling area using
            amended water.

        B. As options, the following wetting methods/controls may be used:

         C. For small holes, a wet sponge can be placed on both sides of the surface and the hole drilled through the
            sponges.

         D. A HEPA vacuum hose may be used near the bit of a non-HEPA equipped drill, and on the back side if
            accessible.

         E. Shaving cream can be sprayed on both sides of the drilling area to control dust and debris. Shaving cream
            must be wiped up and disposed of as ACBM.

         F. Wipe debris off drill using wet disposable towels and place towels into disposal bag.

         G. If back side was enclosed, insert wand of garden sprayer with amended water into backside enclosure and
            wet dust or debris. Remove back side enclosure and place into disposal bag. Wet wipe surfaces that were
            exposed inside back side enclosure.

        Perform maintenance work and clean-up and tear-down steps on Level B checklist to complete work.



WP5-Remove Asbestos Cement Panels

Summary
This work practice covers the procedures for removing a small number of asbestos cement panels to support
O&M work.

Note: An NEA must have been made by a Competent Person before this work practice is used. Verify that a
NEA has been made. If an NEA cannot be verified, stop work and notify your supervisor.

Example of Level A
An example of Level A work involves removal of several corrugated or flat asbestos cement panels that are painted or in
good condition, and have fasteners that can be easily removed.

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Level A Work Practice

       Perform Pre-work activities on Level A checklist.

       Tools, equipment and materials:

        A. Tools as needed, and

        B. Tools as needed to remove panel fasteners (slatter's ripper, nail clipper, screwdriver).

       Secure work area.

       Place tools, equipment and materials needed in work area.
       Adequately wet panels to be removed with amended water. Remove fasteners holding panel in place. Clean
       fasteners if they are to be reused. Dispose of fasteners as ACBM if not being reused.

       Remove panel and wrap in two (2) layers of polyethylene sheet for disposal as ACBM.

        A. Perform maintenance work and clean-up and tear-down steps on Level A checklist to complete work.

Example of Level B

       An example of Level B work involves removal of several corrugated or flat asbestos cement panels in fair
        condition.

Level B Work Practice

        Perform Pre-work activities on Level B checklist.

       Tools, equipment and materials:

       A. Tools as needed, and

       B. Tools as needed to remove panel fasteners (slatter's ripper, nail clipper, screwdriver).

       Secure work area.

      Put down drop cloth.

      Place tools, equipment and materials needed onto drop cloth.

      Adequately wet panel(s) to be removed using garden sprayer with amended water.

      Remove fasteners holding panel in place. HEPA vacuum and wet fasteners as they are removed.

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      Clean fasteners using water if they are to be reused. Dispose of fasteners as ACBM if not being reused.

      Remove panel and wrap in two (2) layers of polyethylene sheet for disposal as ACBM.

      HEPA vacuum and wet wipe surfaces to which panel was attached.

      HEPA vacuum and wet wipe up any dust or debris from panel removal.

      Perform work and clean-up and tear-down steps on Level B checklist to complete work.



WP6-Remove Asbestos-Containing Built-Up Roofing

Summary
This work practice describes the work required to remove a small amount of asbestos-containing built-up
roofing or flashing for maintenance or repair work.

Note: An NEA must have been made by a Competent Person before this work practice is used. Verify that an
NEA has been made. If an NEA cannot be verified, stop work and notify your supervisor. Use fall prevention
measures (including safety harnesses, a warning line system with safety monitor, and/or a motion stopping
system) as required by OSHA for roofing work. Roofing removal work shall be completed before any
penetrations through the roof deck are made.

Example of Level A

   An example of Level A work involves the replacement or removal intact of less than 25 square feet of asbestos-
    containing built-up roofing without creating visible dust, to perform patching, repair work, or install new vent or
    stack.

Level A Work Practice
      Perform Pre-work activities on Level A checklist.

      Tools, equipment and materials:
       A. Tools as needed,

       B. Safety harness/warning line system and/or motion stopping system,

       C. Hook knife,

       D. Scraper 2 to 3" (50-75 mm) wide stiff blade,

       E.   Replacement roofing materials and tools, and

       F.   Rope for lowering bags.

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       Secure work area.

       Place tools, equipment and materials needed in work area.

       Cut around area to be removed using hand tools. Note that several layers may be present.

       Scrape up roofing and place into disposal bags. Remove any remaining roofing debris in removal area using
        scraper and place into disposed bags. Lower bags to ground.

       Perform maintenance/repair work and clean-up and tear-down steps on Level A checklist to complete work.

Example of Level B
    An example of Level B work is replacement or removal of a small area of asbestoscontaining built-up roofing that is
    damaged, may become non-intact or create visible dust during removal, or where more than 25 square feet is
    removed.

Level B Work Practice
        Perform Pre-work activities on Level B checklist.

       Tools, equipment and materials:

        A. Tools as needed,

         B. Safety harness/warning line system and/or motion stopping system,

         C. Hook knife,

         D. Scraper 2 to 3" (50-75 mm) wide stiff blade,

         E. Replacement roofing materials and tools, and

         F. Rope for lowering bags.

       Secure work area.

        Put down drop cloth. Seal any windows, HVAC units, air intakes, or other openings that could allow fibers
         from work area into building. Do not seal any plumbing vents in work area.

        Place tools, equipment and materials needed in work area.

        If feasible and safe, adequately wet roofing to be removed using garden sprayer with amended water. The use
         of wetting and amended water for roofing work should be limited for the following reasons:

         A. Wet roofing can create slip hazards,

        B. Roofing mastic/coal tar/bitumen will not adhere to wet surfaces, and

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         C. Water can damage materials below the roof membrane.

        Cut around area to be removed using hand tools. Wet cutting area using amended water. Note that several
         layers may be present.
        Scrape up roofing and place into disposal bags. Wet and remove any roofing debris in removal area using
         scraper and place into disposed bags. Lower bags to ground.

        HEPA vacuum or wet wipe removal area. Use HEPA vacuum where needed to clean up ACBM. It may not be
         appropriate or necessary to use HEPA vacuum on non-ACBM.

       Perform maintenance/repair work and clean-up and tear-down steps on Level B checklist to complete work.



WP 7-Clean Up Debris
Summary
This work practice describes the procedures to be used to clean debris and dust that has resulted from disturbance of
ACBM.

Examples of Level B
Level B procedures are appropriate where a small quantity of debris needs to be picked up, but dust in the space also
needs to be removed as a potentially asbestos contaminated material. This could be required after the fallout of a small
amount of material from a ceiling, pipe insulation or other source. If a large quantity of material is involved, then this
section should be combined with cleaning of all surfaces in the room. It is usually easier and less expensive to simply
remove the dust using asbestos control procedures, than it is to attempt to find out if it contains asbestos.

For instance, an example of Level B could consist of clean-up of debris and dust on surfaces after a small area of
surfacing ACBM has fallen from a ceiling, pipe insulation or other source.

Note: An NEA must have been made by a Competent Person before this work practice is used. If an NEA has
not been made, stop work and notify your supervisor. This work practice is limited to the cleanup of a small
quantity of relatively intact debris which has fallen from an architectural finish, fire-proofing, or thermal
insulation on pipes, boilers or other equipment. Coordinate work with proper O&M work practice to repair
cause of fiber release.

Work Practice
Perform Pre-work activities on Level B checklist.

       Tools, equipment and materials:

         A. Tools as needed.

       Secure work area.

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       Remove asbestos-containing debris using the following sequence:

       A. Shut down all ventilation into room.


        B. Start HEPA vacuum before entering the area.

       C. Use the HEPA vacuum to clean a path at least 6 feet (1.83 m) wide from the entry point of the work area to
          the site of the fallen material.

        D. Remove all small debris with the HEPA vacuum.

        E. Remove any dust or loose debris from the surface of larger pieces of ACBM with a HEPA vacuum. Mist
           surface of pieces with amended water.

        F. Pick up such pieces and place in the bottom of a 6 mil polyethylene disposal bag. Place pieces in the bag
           without dropping and avoiding unnecessary disturbance and release of material. Thoroughly wet debris in
           bag with amended water as it is collected.

        G. Remove all remaining visible debris with HEPA vacuum.

        H. HEPA vacuum an area 3 feet beyond the location in which any visible debris was found. HEPA vacuum in
           two directions.

        I. Wet wipe any hard surfaces or objects in the area.

        J.   Place a 6 mil polyethylene drop cloth immediately on top of the HEPA vacuumed area before performing
             any repair work on site from which fall-out occurred.

        K. HEPA vacuum the site from which material fell removing all loose material which can be removed by the
           vacuums suction.

        L. Repair or remove remaining material using the appropriate O&M work practice.

        M. HEPA vacuum ladder and/or any tools used and pass out of the work area.

       Clean and decontaminate objects in the vicinity of debris using the following procedure:

        A. Perform all work of decontaminating objects wherever possible on a plastic drop sheet.

        B. HEPA vacuum all surfaces of object and immediate area before moving the object.

        C. Pick-up object, if possible, and HEPA vacuum all surfaces.

        D. Hand to off-sheet worker who will wet-clean object, if possible, and place in storage location.


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         E. Decontaminate area where object was located by HEPA vacuuming twice, in two perpendicular
            directions. Wet clean if necessary to remove any debris.

         F. Return object to its original location.

       Perform clean up and teardown steps on Level B checklist to complete work.



WP8-Replace Asbestos-Containing Gaskets/Packing

Summary
This work practice describes the work required to replace ACBM gaskets or ACBM valve packing for O&M work.
Work practices for the following situations are provided as examples. They should be edited as required for the
particular conditions in a facility.

Example of Level A
The example work practice is for a situation where the gasket/packing comes out in one piece, and no residue needs to be
removed. This could cover a great portion of non-industrial cases. The O&M designer will need to determine if this work
practice applied to a packing which unwinds from around a valve stem, but comes out in one piece. The example of
Level A work would involve removal and replacement of non-adhered gasket/packing that can be removed intact.

Level A Work Practice
        Perform Pre-work activities on Level A checklist.

       Tools, equipment and materials:

         A. Tools as needed,

         B. Tools required to access gasket, and

         C. Replacement materials.

       Secure work area.

       Place tools, equipment and materials needed in work area.

        Disassemble equipment as needed to expose entire gasket.


       Remove gasket and place into disposal bag. Wet-wipe flange where gasket was installed.

        Install new gasket and reassemble equipment.

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        Perform applicable steps on Level A checklist to complete work.

Example of Level B
An example of Level B work could consist of removal and replacement of gaskets/packing that is damaged or adhered to
its seat. During design of the work practice the O&M designer (who must be a competent person) needs to either make
the determination that airborne fiber levels during the use of the work practice will not exceed the OSHA PELs required
for an alternative Class II work practice, or needs to make an NEA. To meet Class II requirements the designer must
certify in writing that use of the work practice will reduce direct and indirect employee exposure to below the PELS
under all expected conditions of use, and that the work practice meets the requirements of the OSHA standard. Each time
that work is assigned the asbestos program manager (APM) must evaluate the work area and make a determination that
conditions at the specific job site are equivalent to those that exist during development of the work practice, so that the
work practice is applicable. The need for Level B work practices that are site specific will usually be greater on
industrial sites, locations where workers will frequently be working on gaskets, and where pipes are hot, cold or filled
with a material incompatible with water. The example work procedure is based on wet methods. If water cannot be used,
then the work practice will rely more on careful work practices, and local exhaust ventilation. If work on gaskets/packing
is an infrequent event, it may be simpler to follow the OSHA glove-bag procedure than to develop a site-specific
procedure.

   Remove and replace gasket/packing that is damaged or adhered to the gasket seat.

Level B Work Practice
        Perform Pre-work activities on Level B checklist.

       Tools, equipment and materials:

         A. Tools as needed,

         B. Tools required to access and work remove gasket or packing, and

         C. Replacement materials.

        Secure work area.

       Prepare work area with drop cloth.

       Place tools, equipment and materials needed into work area.

       If pipe is hot or cold put on protective equipment as required.

       Remove TSI as necessary using appropriate procedures.

       Disassemble equipment as needed to expose entire gasket/packing.

        Remove gasket/packing using the following procedures:

        A. Use this procedure only if an NEA has been made. If you do not know if an N7EA has been made, stop
           work, and notify your supervisor.


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       B. Wet gasket with amended water. If wetting is not practical due to temperature of pipe or nature of pipe fill,
          stop work, and notify your supervisor.

       C. Use careful handling and local exhaust ventilation with a HEPA vacuum to remove the gasket/packing.

       D. Carefully scrape gasket from seat while holding nozzle of HEPA vacuum m proxunity to the flange or
          packing box. Immediately place pieces of gasket in disposal bag. Try to remove gasket in as few pieces as
          possible.

       E. Promptly pick up any debris with a HEPA vacuum.

       F. Clean residue from surface of seat using wet methods. Keep work site continuously wet.
       G. Tools as needed,

            Scraper 2 to 3" (50-75 mm) wide stiff blade, and

            Stiff nylon bristle brushes.

       Secure work area.

       Put down drop cloth.

       Place tools, equipment and materials needed onto drop cloth.

       Enter work area and adequately wet caulking to be removed using garden sprayer with amended water.

       Using utility knife or edge of scraper, cut away caulking and place into disposal bags.

       Remove any residual caulking using scraper, knife and nylon brushes and place caulking into disposal bags.

       HEPA vacuum and wet wipe areas where caulking was removed.

      Perform maintenance work and clean-up and tear-down steps on Level B checklist to complete work.



WP9-Remove Asbestos-Containing Caulking and
Glazing Compound
Summary
This work practice describes the procedures for removing small amounts of asbestos-containing caulking compound as
required for maintenance or repair work.

Note: An NEA must have been made by a Competent Person before this work practice is used. Verify that an
NEA has been made. If an NEA cannot be verified, stop work and notify your supervisor.


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Example of Level A
One example of Level A work could be removal of a small amount of pliable caulking compound. No sanding would be
performed.

Level A Work Practice

       Perform Pre-work activities on Level A checklist.

       Tools, equipment and materials:
                 A. Tools as needed,
                 B. Scraper 2 to 3" (50-75 mm) wide stiff blade.
        Secure work area.
        Place tools, equipment and materials needed in work area.
        Using utility knife or edge of scraper, cut away caulking and place into disposal bags.

       Remove any residual caulking using scraper and knife and place caulldng into disposal bags.

       HEPA vacuum and/or wet wipe areas where caulking was removed.

       Perform maintenance work and

       Perform clean-up and tear-down steps on Level A checklist to complete work.


Examples of Level B
Examples of Level B would be to:

       Re-glaze several small window panes. No sanding will be performed.

       Remove small amount of dry caulking compound.

Level B Work Practice
        Perform Pre-work activities on Level B checklist.

       Tools, equipment and materials:

        A. Tools as needed,

        B. Scraper 2 to 3" (50-75 mm) wide stiff blade, and


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        C. Stiff nylon bristle brushes.

       Secure work area.

        Put down drop cloth.

        Place tools, equipment and materials needed onto drop cloth.

        Enter work area and adequately wet caulking to be removed using garden sprayer with amended water.

        Using utility knife or edge of scraper, cut away caulking and place into disposal bags.

        Remove any residual caulking using scraper, knife and nylon brushes and place caulking into disposal bags.

       HEPA vacuum and wet wipe areas where caulking was removed.

       Perform maintenance work and clean-up and tear-down steps on Level B checklist to complete work.




WP10-Clean Room that has Asbestos-Containing Dust
Summary
This work practice should be used for routine or special cleaning in rooms where asbestos-containing dust is present, or
is assumed to be present. This is useful in situations where an ACBM may be periodically disturbed (e.g., a soft
acoustical finish in reach of occupants). This work practice augments normal cleaning practice by adding HEPA
vacuums and wet methods. It is intended to substitute for normal cleaning practices in locations where there could be a
periodic minor disturbance of an ACBM. Cleaning with HEPA vacuums, wet methods and dust removal methods
prevents the accumulation of asbestos in the dust. The practices include the cleaning of furniture, fixtures, and other
surfaces.

Examples of Level A
Examples of Level A work would be to:

   Clean an office area where asbestos-containing dust may settle on furniture due to periodic disturbance of an
    exposed ACBM.
   Clean a mechanical room where dust is assumed to contain ACBM from thermal systems insulation present in
    room.

Note: An NEA must have been made by a Competent Person before this work practice is used. Verify that an NEA has
been made. If an NEA cannot be verified, stop work and notify your supervisor. This work procedure is intended for
routine or periodic cleaning of a space. If you discover visible dust or debris, or a fallout of ACBM, stop work, and
notify your supervisor.



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Level A Work Practice

   Perform Pre-work activities on Level A checklist.

   Tools, equipment and materials:

         A. Tools as needed,
         B. Dusting materials (cloths, dusters, mops) that are damp or are treated with anti-static dust attractant
            preparations, and
         C. Furniture polish.

       Routine dusting: Using damp or treated dusting materials, clean surfaces beginning from the top of the room and
        working towards the floor. Do not dry dust. HEPA vacuum surfaces that are not easily cleaned with dusting
        materials.

       Routine vacuuming: Perform routine vacuuming with HEPA vacuums. HEPA vacuum surfaces such as drapes
        and fabric covered surfaces by starting at the top and working towards floor. HEPA vacuum carpet as last step
        after all dusting.

       Routine floor cleaning: Dust mop using damp mops or treated dusting mops. Wash floors using normal mopping
         procedures. HEPA vacuum carpeting. Maintain resilient flooring using work practices in this plan. Do not dry
        dust. Do not use a vacuum cleaner without a HEPA filter.

    
         Periodic cleaning: Surfaces that are not routinely cleaned are to be cleaned during periodic cleaning using wet
         methods or HEPA vacuums. Wet wipe smooth hard surfaces (such as blinds) or wash with paper towels or
        disposable cloths. HEPA vacuum cloth or textured surfaces. Dispose of all dirty cloths and soiled dusting
        materials while still damp in ACBM disposal bags.

       Apply new polish where needed using standard procedures.

       Perform clean-up and tear-down steps on Level A checklist to complete work.



WP11-Attach Item to Ceiling Finished with ACBM

Summary
This work practice describes the work required to attach an item to a ceiling finished with surfacing ACBM, such as
acoustical plaster or a decorative sprayed-on surface texture material.

Example of Level A
An example of Level A would be to mount a "rosette "with bedding adhesive to the surface of a suspended acoustical
plaster ceiling. Attach device to rosette.

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Level A Work Practice

       Perform Pre-work activities on Level A checklist.
       Tools, equipment and materials:
        A. Tools as needed.

       Secure Work Area.

       Place tools, equipment and materials needed in work area.

       Put bedding adhesive on bottom of rosette and press against ceiling.

       Perform clean-up and tear-down steps on Level A checklist to complete work.

Note: An NEA must have been made by a Competent Person before the Level B work practice is used. If an
NEA has not been made, stop work and notify your supervisor.

Examples of Level B
Examples of Level B work would be to:                -



   Attach a battery-powered smoke detector to a suspended acoustical plaster ceiling with two toggle bolts.

   Attach track lighting to an ACBM finished ceiling where experience has proven that a minimal disturbance will
    occur.

Note: The ceiling is a "controlled system." Do not contact or work on ceiling unless authorized by APM.

Level B Work Practice

       Perform Pre-work activities on Level B checklist.

       Tools, equipment and materials:

        A. Tools as needed, and

        B. Item to be attached to ceiling and related tools.

      Secure Work Area.

       Put down drop sheet.

       Place tools, equipment and materials needed onto drop cloth.

       Wet area on ceiling where item will be attached using garden sprayer with amended water.

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       Drill holes through ceiling with one of the following procedures:

         A. Drill hole with drill equipped with dust collection collar attached to a HEPA vacuum. Maintain HEPA
            vacuum in operation during entire process of drilling holes.

         B. Using hand tools and 1-JEPA vacuum near attachment location, or power tools with attached HEPA
            vacuum, attach item to ceiling. If small holes are being drilled, drill through a wet sponge or shaving cream
            to control fiber release.

         C. Scrape away surfacing to at least ½" beyond where hole is needed. Keep the hose of an operating HEPA
            vacuum within 6" and below area where scraping is occurring. Adequately wet scraping area and any dust
            or debris generated. Drill hole through substrate after ACBM is removed.

       Immediately place all debris into ACBM disposal bags.

       Spray holes with a clear penetrating encapsulant to stabilize disturbed edges.

       Perform clean-up and tear-down steps on Level B checklist to complete work.




WP1 2-Repair or Replace Item in Surface Finished with
ACBM

Summary
This work practice covers the procedures for repairing or replacing an item that is installed in or attached to a
surface finished with ACBM, such as an acoustical plaster ceiling or fireproofed deck or beam.

Example of Level A
This example pre-supposes that the construction of the light fixture permits the diffuser to be removed without touching
or disturbing the ceiling. Workers performing this task should at a minimum have awareness training so that they are
informed of the asbestos-containing ceiling, and know to avoid disturbing it. During design of the O&M procedure, the
designer (who must be a Competent Person as defined by OSHA) must make a determination that the surfacing ACBM
is in good condition and that it will not be disturbed by the work.

An example of Level A work is to replace diffuser that is completely surrounded by the metal frame of a light fixture
recessed in a ceiling finished with ACBM acoustical plaster, where the diffuser can be removed without any disturbance
of ACBM.

Notes: The ceiling is a "controlled system." Do not contact or work on ceiling unless authorized by facility
management.



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Level A Work Practice

        Perform Pre-work activities on Level A checklist.

        Tools, equipment and materials:

         A.   Tools as needed, and

         B. Repair and/or replacement parts and tools as needed.

        Secure Work Area.

        Place tools, equipment and materials needed in work area.

        Carefully open diffuser without touchmg the ACBM acoustical plaster ceiling.

        Perform clean-up and tear-down steps on Level A checklist to complete work.

Example of Level B
An example of Level B work is the removal of a light fixture that is recessed in a ceiling finished with ACBM acoustical
plaster, where the light fixture has an escutcheon so that it can be unfastened and dropped out. This example pre-
supposes that the light fixture is constructed so that it is clamped in a hole in the ceiling and can be removed by

taking out a few screws and sliding the entire unit out. Workers performing this task should at a minimum have O&M
training and sufficient electrical knowledge to be able to disconnect the light fixture.

Note: An NEA must have been made by a Competent Person before the Level B work practice is used. If an
NEA has not been made, stop work and notify your supervisor.

Level B Work Practice

        Perform Pre-work activities on Level B checklist.

       Tools, equipment and materials:

         A. Tools as needed, and

        B. Repair and or replacement parts and tools as needed.

        Secure Work Area.

        Put down drop sheet.

        Place tools, equipment and materials needed onto drop cloth.

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       Lightly mist area of ACBM acoustical plaster around frame of light fixture using garden sprayer containing
        amended distilled water and allow water to soak in for several minutes.

       Completely remove screws holding light fixture in place, while holding fixture so that it does not move.

       Gradually lower one side of fixture while removing any loose ceiling material with HEPA vacuum. Lower other
        side while continuing with HEPA vacuum. Use HEPA vacuum to remove any ceiling material as fixture is
        lowered from the ceiling. Disconnect wire from fixture and coil above ceiling so that it does not contact the
        acoustical plaster.

       HEPA vacuum and then wet wipe all surfaces of light fixture.

       Collect any surfacing debris from repair/replacement work using HEPA vacuum.

       Perform clean-up and tear-down steps on Level B checklist to complete work.




WP1 3-Replace Bulbs in Light Fixture Attached to or in
Surface Finished with ACBM

Summary
This work practice covers procedures for replacing light bulbs in a fixture attached to a surface finished with
ACBM.

Examples of Level A
Examples of Level A work could be to:

   Replace bulbs in recessed or pendant mount light fixtures attached to an asbestos-containing decorative texture
    finish or acoustical plaster ceiling where the material may be contacted, but it is unlikely that any debris will be
    released.

   Replace bulbs in fixtures mounted on fireproofed surface where the material may be contacted, but it is unlikely
    that any material will be released.

Note: An NEA must have been made by a Competent Person before this work practice is used. If an NEA has
not been made, stop work and notify your supervisor.

Level A Work Practice

   Perform Pre-work activities on Level A checklist.

   Tools, equipment and materials:

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        A. Tools as needed, and

         B. Replacement bulbs.

   Secure Work Area.

   Place tools, equipment and materials needed in work area.

   Carefully replace light bulbs without jarring fixture or releasing debris. Clean-up any dust
     or debris generated using HEPA vacuum.

     Perform clean-up and tear-down steps on Level A checklist to complete work.

Examples of Level B
This work practice is appropriate for situations where the surfacing treatments may be disturbed during re-lamping by
knocking off a small amount of debris, or will be contacted and is so fragile that the contact may knock off a small

amount of debris. If the release of debris is unlikely, then Level A procedure could be used. The ceiling should be
designated as a "controlled system" that is to be contacted only by those with awareness training, at a minimum.

Examples of Level B work would be to:

   Replace bulbs in light fixtures recessed in an asbestos-containing decorative texture finish or acoustical plaster
    ceiling where the material is likely to be contacted and release of a small amount of debris is likely.

    Replace bulbs in recessed fixtures where ACBM surfacing material debris is visible inside fixture.

   Replace bulbs in pendant mount fixture where ACBM debris is present inside or on top of fixture.

Note: The ceiling is a "controlled system." Do not contact or disturb ceiling unless you have been authorized
by the APM.

Level B Work Practice

    Perform Pre-work activities on Level B checklist.

    Tools, equipment and materials:

     A. Tools as needed, and

     B. Replacement bulbs.

    Secure Work Area.

    Put down drop sheet.

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   Place tools, equipment and materials needed onto drop cloth.

   Put on respirator and perform fit check.

   Carefully replace light bulbs without jarring fixture. Clean-up any dust or debris generated using HEPA vacuum.

   Perform clean-up and tear-down steps on Level B checklist to complete work.



WP14- Clean Room with Exposed Surfaces Finished
with ACBM
Summary
This work practice covers the procedures for cleaning a room with exposed surfaces finished with ACBM.
This room has been predetermined to not be contaminated or has previously been cleaned. However, debris
could be released from the material by contact with occupants during normal occupation of the space. This
work practice is intended to collect any debris that may have been released before it can accumulate. This is
not the procedure to use if a fiber release has occurred (see related work practice for a minor fiber release
episode).

Examples of Level A
Examples of Level A would be:

   Routine cleaning in room with spray-applied acoustical plaster on walls or ceilings where there is no visible dusf or
    debris.

   Routine cleaning in mechanical room with exposed fireproofing in good condition where there is no visible dust or
    debris.

Note: If any debris from ACBM is found in an area to be cleaned, notify the APM or your supervisor. The
APM will need to determine whether this work practice is appropriate or if more stringent practices are needed.

Level A Work Practice

       Tools, equipment and materials:

        A. Standard cleaning equipment and materials.

       Clean area using standard cleaning methods. Avoid contact with any ACBM materials that could be damaged
        during cleaning.

       Do not clean up asbestos debris. If asbestos debris is found in a space, stop cleaning work in that space and
        notify your supervisor.
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       The following precautions should be observed when working around the ACBM:

        A. Do not bump ACBM with vacuum cleaners, broom handles, mop handles or similar objects. Do not exhaust
           vacuum cleaners toward ACBM.

        B. Do not brush ACBM surfaces with a broom or similar objects to remove cobwebs or other items attached to
           ACBM.




WP15-Repair Damaged Surfacing ACBM

Summary
This work practice covers the procedures for repairing small amounts of damaged surfacing ACBM, such as
acoustical plaster or fireproofing. The procedure assumes that the damage is in isolated areas not greater in
size than the OSHA limit on Class III work (operation will generate no more waste than can be contained in
one 60" by 60" glove-bag or disposal bag). It is standard industry practice not to fill these bags more than one-
third full, to allow for proper sealing and to guard against breakage.

Examples of Level A
Examples of Level A would be to:

   Repair small hole in acoustical plaster ceiling or wall without disturbing surrounding plaster.

   Repair small gouged area in asbestos-containing decorative texture finish without disturbing surrounding finish.

Note: An NEA must have been made by a Competent Person before this work practice is used. If an NEA has
not been made, stop work and notify your supervisor. The ceiling is a "controlled system." Do not contact or
disturb ceiling unless you have been authorized by the APM.

Level A Work Practice

      Perform Pre-work activities on Level A checklist.

      Tools, equipment and materials:

        A. Tools as needed, and

        B. Non-ACBM caulking materials & tools.

       Secure Work Area.

      Place tools, equipment and materials needed in work area.

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       Repair damaged area using non-ACBM caulking without disturbing ACBM. Do not scrape or sand existing
        ceiling.

      Perform clean-up and tear-down steps on Level A checklist to complete work.

Examples of Level B
Examples of Level B work could include:

   Repair of gouge marks in acoustical plaster ceiling where a small amount of damaged ACBM is present.

   Repair of small area of delaminated acoustical plaster in good condition.

Level B Work Practice

       Perform Pre-work activities on Level B checklist.

        Tools, equipment and materials:

        A. Tools as needed,

        B. Small stiff-bladed scraper, and

        C. Non-ACBM repair materials & tools.

       Secure Work Area.

       Put down drop sheet.

       Place tools, equipment and materials needed onto drop cloth.

       Mist any damaged surfacing material using garden sprayer containing amended water arid allow water to soak
        in for several minutes.

       HEPA vacuum within several inches of damaged area, remove any loose material by hand or with scraper.
        Collect material in disposal bags as it is removed. Remove material around edges of damaged area until well-
        adhered material is found, but do not remove beyond area protected by drop cloth. Mist removal area during
        removal of damaged material.

      Repair damaged area using non-ACBM and perform clean-up and tear-down steps on Level B checklist to
       complete work.




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WP16-Accessing through an ACBM Finished Surface

Summary
This work practice covers the procedures for opening access doors (such as those used in a wall or ceiling to
access valves or dampers) in ACBM finished surfaces such as acoustical plaster or fireproofing.

Level A work practices should only be used in situations where the ACBM surface material is in good condition
and will be contacted but not disturbed by the work. During design of the O&M procedure, a Competent Person (as
defined by OSHA) must make a determination that the exposed surfacing ACBM is in good condition and that
contact with the material without disturbance will not cause an exposure to a worker that is above the PEL.

Level B should be used for work that can be accomplished without generating airborne fiber levels in the breathing
zone of workers that are above the PEL, and without spreading visible dust and debris from the ACBM.

Example of Level A
Level A work practice should be used only in situations where the access door can be opened without disturbing the
ACBM. During design of the O&M procedure, a Competent Person (as defined by OSHA) must make a determination
that the ACBM will not be disturbed and that there will be no exposure above the PEL to a worker.

An example of Level A would be to:

   Open access door in acoustical plaster ceiling that has been opened before. Ceiling or wall is in good condition and
    debris is not likely on door.

Level A Work Practice

       Perform Pre-work activities on Level A checklist.

       Tools, equipment and materials:

        A. Tools as needed.
       Secure Work Area.

       Put down drop sheet.

       Place tools, equipment and materials needed in work area.

       Unlatch door and open carefully. Avoid contact with ACBM, be careful not to disturb ACBM during process of
        opening access door.

       Perform maintenance work required above or behind access door and slowly close door until it is secured in
        place.

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       Complete applicable steps on Level A checklist to complete work.

Examples of Level B
These procedures use amended water to wet the surface. Some surfaces can be stained by even a small amount of water.
An inconspicuous part of the surfacing material should be tested for staining and the work practice adjusted as required
to avoid defacing architectural finishes.

Examples of Level B would be to:

    Open access door in acoustical plaster ceiling where ACBM is in fair condition and may be disturbed.

    Open access door that has surfacing material on flanges that will be disturbed when door is opened.

Note: An NEA must have been made by a Competent Person before this work practice is used. If an NEA has
not been made, stop work and notify your supervisor. The ceiling is a "controlled system." Do not contact or
disturb ceiling unless you have been authorized by the APM.

Level B Work Practice

       Perform Pre-work activities on Level B checklist.

       Tools, equipment and materials:

        A. Tools as needed, and
        B. Sponge

       Secure Work Area.

       Prepare work area with drop cloth.

       Place tools, equipment and materials needed onto drop cloth.

       Unlatch door and open door 0.25 to 0.5 inches. HEPA vacuum around edges of door. Slowly open door and
        HEPA vacuum any debris on door or any ACBM disturbed while opening door.

       Perform maintenance work required above or behind access door and then slowly close door until it is secured
        in place.

        Perform clean-up and tear-down steps on Level B checklist to complete work.




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WP17-Painting Surfacing ACBM
Summary
This work practice describes the work required to paint small amounts of surfacing ACBM, such as acoustical
plaster or a decorative texture finish. Paint coats should be as thin as possible to prevent delamination of
surfacing that may be caused by painting. This work may need to be treated as abatement work depending
upon the type and condition of the surfacing.

Painting a previously painted surface is Level A work because the surfacing material is contacted but not
disturbed. The individuals performing this work should at a minimum have O&M training. Painting an unpainted
surface where the OSHA PEL will not be exceeded or where the surface is strong enough that dust or debris
will not be released is Level B work.

Depending upon the type, condition and friability of the ACBM, this work may need to be treated as an
abatement activity instead of O&M work.

Example of Level A
An example of Level A would be to repaint previously painted asbestos-containing acoustical plaster in good condition.
No preparation of the surface is required.

Level A Work Practice

       Perform Pre-work activities on Level A checklist.

       Tools, equipment and materials:

        A. Tools as needed, and
        B. Paint, rollers or low pressure airless sprayer, and other painting equipment.

       Secure Work Area.

       Prepare work area with drop cloth.

       Place tools, equipment and materials needed on drop cloth.

       Paint ceiling using sprayer or rollers. If rollers are used, try to contact each area of the ceiling only once to
        avoid damage to ACBM.

       When painting is completed, clean up any loose debris using wet wiping and/or HEPA vacuuming, and roll up
        drop cloth. Dispose of paint rollers as ACBM.

       Perform clean-up and tear-down steps on Level A checklist to complete work.

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Example of Level B

An example of Level B work would be to paint asbestos-containing decorative texture finish that has not been previously
painted.

Note: An NEA must have been made by a Competent Person before this work practice is used. If an NEA has
not been made, stop work and notify your supervisor. The ceiling is a "controlled system." Do not contact or
disturb ceiling unless authorized by the APM.

Level B Work Practice

       Perform Pre-work activities on Level B checklist.

       Tools, equipment and materials:

        A. Tools as needed, and

        B. Paint, rollers or low pressure airless sprayer, and other painting equipment.

       Secure Work Area.

       Put down drop sheet.

        Place tools, equipment and materials needed onto drop cloth.

       Paint ceiling using sprayer or rollers. If rollers are used, try to contact each area of the ceiling only once to avoid
        damage to ACBM.

       When painting is completed, clean up any loose debris using wet-wiping and/or HEPA vacuuming and roll up
        drop cloth. Dispose of paint rollers as ACBM.

       Perform clean-up and tear-down steps on Level B checklist to complete work.




    WP1 8-Remove Asbestos-Containing Insulation Inside HVAC
                  Unit for Maintenance Work
Summary
This work practice describes the procedures for removing small amounts of asbestos-containing duct of pipe
insulation inside an HVAC unit.

Example of Level B
An example of Level B would be to remove no more than one 4-foot length of laminated corrugated paper pipe
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insulation in good condition, where the insulation can be removed intact.

Note: An NEA must have been made by a Competent Person before this work practice is used. If an NEA has
not been made, stop work and notify your supervisor. Asbestos-containing pipe insulation is a "Controlled
System." Do not contact or disturb pipe insulation unless you have been authorized by the
APM.

Level B Work Practice

       Perform Pre-work activities on Level B checklist.

       Tools, equipment and materials:

        A. Tools as needed,

        B. Scraper (2-3" [50-75 mm] wide stiff blade),

        C. Stiff nylon bristle brushes, and

        D. Non-ACBM replacement insulation.

       Secure work area.

       Put down drop cloth.

       Place tools, equipment and materials needed onto drop cloth.

       Adequately wet insulation to be removed.

       Wait until water has soaked into insulation. Add water until insulation is completely saturated.

       Cut bands holding insulation in place.

       Slice lagging with a razor knife at joints between sections of insulation and length wise at joints between
        clamshell halves.

       Open insulation clamshell and place intact into an asbestos disposal bag. Do not drop.

       Keep hose of an operating HEPA vacuum adjacent to the removal area during entire removal operations to
        capture any debris or fibers generated.

       Wet wipe surface of pipe to remove any ACBM residue.

       HEPA vacuum and then wet wipe surface of HVAC unit and floor in vicinity of the work.


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       Perform maintenance work and replace/restore insulation. Restore vapor barrier on cold insulation and seal off
        to adjacent vapor barrier surfaces.

       Perform clean-up and tear-down steps on Level B checklist to complete work.

        Examples of Level C

       Remove a small amount of ACBM pipe insulation in poor condition inside HVAC unit.

       Remove a small amount of duct insulation as required to replace flexible connector.

        Note: An NEA must have been made by a Competent Person before this work practice is used. If an
        NEA has not been made, stop work and notify your supervisor. Asbestos-containing pipe insulation is
        a "Controlled System." Do not contact or disturb pipe insulation unless you have been authorized by
        the APM. Do not use power tools inside glove-bags. Do not use this procedure if more debris will be
        disturbed than will fit comfortably into one 60-inch by 60-inch disposal bag. If more than this amount
        of debris is found, stop work, close ceiling, and notify your supervisor.

       Level C Work Practice

      Perform Pre-work activities on Level C checklist.

      Tools, equipment and materials:
                 A. Tools as needed,

                 B. Scraper (2 to 3" [50-75 mm] wide stiff blade),

                 C. Stiff nylon bristle brushes,

                 D. Glove-bags, and

                 E. Non-ACBM replacement insulation.

      Secure work area.

      Put down drop cloth.

      Place tools, equipment and materials needed onto drop cloth.

      Install duct tape around area to be removed.

      Place tools, equipment, and other materials into glove-bag. Attach glove-bag to duct tape using more duct tape.

      Remove all loose or damaged insulation using glove-bag procedures.

      Remove glove-bag leaving duct tape from step above.


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      Perform maintenance work and replace/restore insulation. Restore vapor barrier on cold insulation and seal off to
       adjacent vapor barrier surfaces.

      Perform clean-up and tear-down steps on Level C checklist to complete work. Leave duct tape installed above in
       place.



WP1 9—Replacement of Resilient Asbestos Floor Tiles

Summary
This work practice covers the O&M Procedures for removing small amounts of asbestos-containing floor tile
and mastic. The work practices are based on the Resilient Floor Covering Manufactures (RFCM) procedure.

Examples of Level A
Examples of Level A work include:

   Replacement of several floor tiles that are loose or can be removed with minimal or no breakage, and tile and/or
    mastic does not become friable.
   Remove a small area of well-adhered tile and/or mastic that is not likely to become friable.

   Remove several floor tiles and mastic to drill hole(s) in subfloor to attach object to floor or install a pipe or conduit.

Note: RFCM Procedure. This work practice is based on the resilient floor covering manufacturers
recommended work practice. You must have had a minimum of 8 hours of training in the use of the
recommended work practices including hands on training to do the work of this procedure. An NEA must have
been made by a Competent Person before this work practice is used.

Do not sand resilient flooring. Do not use this procedure for activities that crumble, pulverize, or otherwise
deteriorate resilient flooring to the extent that it is no longer bound with its matrix. If job conditions change,
stop work and notify your supervisor.

Level A Work Practice

     Perform Pre-work activities on Level A checklist (included at the end of this section).

    Verify that an NEA has been made. If an NEA cannot be verified, stop work and notify your supervisor.

    Tools, equipment, and materials:


       A. Tools as needed,


        B. Weighted scraper with long handle,


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       C. Wall scraper 2 to 3" (50-75 mm) wide stiff blade with short handle,

       D. Commercial-type hand-held hot air blower or radiant heat source,

        E. Safety glasses,

        F. Wet/dry type HEPA vacuum with hose and attachments with metal floor tool,

        G. Garden sprayer with amended water, and Hammer.

     Place tools, equipment and materials needed in work area.

     Secure work area.

     Use the following procedure to remove resilient tile floor covering:

        A. Floor tiles must be wetted (misted with a garden sprayer) before actual removal begins, unless heat will be
           used to remove tiles.

        B. Start removal by carefully wedging a wall scraper in the seam of two adjoining tiles and gradually forcing
           the edge of one of the tiles up and away from the floor. Continue to force the balance of the tile up by
           working the scraper beneath the tile. Exert both a forward pressure and a twisting action on the blade to
           promote release of the tile from the adhesive and the floor.

        C. When the tile is removed, place it (without breaking it further into smaller pieces) in a waste bag or waste
           container.

        D. If it is necessary to remove more tiles to accomplish the work, after the first tile is removed and
           accessibility to other tiles is improved, force the wall scraper under the exposed edge of another tile.
           Continue to exert a prying twisting force to the scraper as it is moved under the tile until the tile releases
           from the floor. Again, dispose of the tile by placing it in a waste bag or waste container without additional
           breaking. Continue in this manner until enough tiles are removed to accomplish the work.

        E. Force the scraper through tightly-adhered areas by striking the scraper handle with a hammer using blows
           of moderate force while maintaining the scraper at a 25 to 30 degree angle to the floor. The resilient floor
           covering manufacturers' work practices recommend the use of safety goggles during this work.

        F. Continue to wet (mist) the tiles throughout the procedure.

        G. It should be the goal to remove individual tiles as a complete unit, although breakage of tiles is unavoidable.

        H. If the procedure above is inadequate to loosen tiles use heat to soften adhesive, or alternatively, without first
           prying up floor tiles using a scraper, thoroughly heat the tile(s) with a hot air gun or radiant heat source
           until the heat penetrates through the tile and softens the adhesive, and remove tiles by hand or by using a
           scraper. The resilient floor covering manufacturers work practices recommend that the hot air gun or radiant
           heat source, tiles and adhesive be carefully handled to avoid bums, and that heated tiles and adhesive be

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             handled only with suitable glove protection for hands. Caution: Over-heating resilient tile might produce
             harmful vapors, and a respirator with organic vapor carti-idges might be needed.

        I.   Deposit tiles in a waste bag or leak-tight container. Do not attempt to break tiles after they are in bag.

        J.   Wet scrape residual adhesive.

      Wet Scrape Residual Adhesive: After removing tile always wet scrape the residual adhesive to remove any loose
       material using the following procedure so that no ridges or puddles are evident and what remains is a thin,
       smooth film.

        A. Moisten the adhesive with water mixed with liquid dish-washing detergent (to aid in wetting the adhesive).
           Wet scrape with a stiff-bladed wall or floor scraper removing ridges and any loose adhesives.

        B. Place loosened adhesive residues into a waste bag or waste container.

        C. Wet vacuum standing water with HEPA wet/dry vacuum.

        D. Continue the above steps until what remains of the residual asphaltic "cut-back" adhesive is a thin, smooth
           film.

      Wet Remove residue of adhesive from Concrete with Wet Sand and Rubbing Stones:
       If work that could disturb the adhesive residue, such as drilling through the floor, is going to occur, completely
       remove residue of adhesive left after removal of resilient floor tile using either this procedure or the removal
       solution procedure that follows:

        A. Place a small amount of cutting sand (enough to cover area of removed tile) into a container, add water
           mixed with liquid detergent (1 ounce [30 ml] of liquid dish-washing detergent to 1 gallon [3.79 liters] of
           water) to dampen the sand (20 pounds [9.07 kg] of sand to one-half gallon [1.89 litersl of solution).

        B. Place sand over area of removed tile and wet remove the existing adhesive residue with a hand held rubbing
           stone. The sand and sub-floor must be continuously kept wet.

        C. Occasionally push away cutting sand from the sub-floor with a wall or floor scraper to check for complete
           removal.

        D. Wet-scrape sand into a pile using a stiff-bladed floor or wall scraper and place sand and adhesive residue in
           a waste bag or waste container.

        E. Rinse area with clear clean water using a hand sprayer. Avoid getting sand on boots. Worker's boots should
           also be rinsed and cleaned if necessary.

        F. Wet-vacuum standing water with HEPA wet/dry vacuum with a metal floor attachment (no brush).

        G. Continue with the above steps until adhesive is completely removed in the required area.


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        H. Allow sub-floor to dry and vacuum up any remaining dirt or sand using a vacuum equipped with a HEPA
           filter and metal floor attachment (no brush).

       I.   Wet-wipe and/or wash down all equipment used during the work.

      Wet Remove residue of adhesive from Concrete with Removal Solution: If work that could disturb the adhesive
       residue (such as drilling through the floor) is going to occur, completely remove residue of adhesive left after
       removal of resilient floor tile using either the following procedure or the previous wet sand and rubbing stone
       procedure:

       A. Put the removal solution onto the residual adhesive with a hand sprayer or rag over the area of removed tile.
          Put enough removal solution (e.g., "mop on, mop off, no machine scrub" stripping solution) to ensure that
          the area is thoroughly wet. Allow the area to soak for 5-10 minutes. Remove the adhesive by hand scrubbing
          with a piece of a black floor pad (or equivalent). The sub-floor must be kept continuously wet.

        B. Occasionally push away the adhesive slurry from the sub-floor with a wall or floor scraper to check for
           complete removal. Continue to scrub the floor with the black pad, in the same area until the concrete sub-
           floor is cleaned to the desired degree.

        C. Wet HEPA vacuum the adhesive slurry. When the HEPA vacuum is full, place a commercially suitable
           water absorbent into the HEPA container until the adhesive slurry is absorbed.

        D. Rinse area with clear clean water using a hand sprayer or mop. Avoid getting remover on boots. Worker's
           boots should also be rinsed and cleaned if necessary.

        E. Wet-vacuum standing water with HEPA wet/dry vacuum with a metal floor attachment (no brush).

        F. Continue with the above steps until adhesive is completely removed in required area.

        G. Allow sub-floor to dry and vacuum using a vacuum equipped with a HEPA filter and metal floor
           attachment (no brush).

       H. Wet-wipe and/or wash down all equipment used during the work.

       Perform required clean-up and tear-down steps on Level A checklist to complete work.




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WP-20 Install New Resilient Flooring or Carpet Over
Resilient Asbestos Flooring
Summary
This procedure covers the work required to prepare resilient flooring for the installation of new flooring or
carpet.

Example of Level A
An example of Level A includes new carpet being installed over well-adhered resilient asbestos tile or vinyl sheet
flooring with ACBM backing in good condition.

Note: This work practice must be used in conjunction with a Level A Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are begun. Review manufacturer's
recommendations concerning installation of new flooring over existing before proceeding with this work.

Level A Work Practice
       Perform Pre-work activities on Level A checklist.

       Tools, equipment, and materials:

        A. Tools as needed, and

        B. Wall scraper 2 to 3" (50-75 mm) wide stiff blade with short handle.

       Place tools, equipment and materials needed in work area.

       Secure work area.

       HEPA vacuum.

       Strip wax/finish from existing floor using O&M work practice "Wet Strip Wax from Resilient Asbestos
        Flooring."

.      Level off any minor high spots on floor using scraper. Promptly remove any scrapings with a HEPA vacuum.
        Do not sand or grind flooring.

      Fill any low areas using manufacturers recommended underlayment or Leveling compound

       Vacuum floor using a vacuum equipped with a HEPA filter and metal floor attachment (no brush).

       Wet-wipe and/or wash down all equipment used scrape floor during the work.

      Install new flooring or carpet as recommended by manufacturer.

      Perform clean-up and tear-down on Level A checklist to complete work.


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WP21-lnstall Partition Over Resilient Asbestos Flooring
Summary
This work procedure describes the procedures for installing a wall over asbestos flooring that will remain in place.

Example of Level A
An example of Level A would be to install partition over resilient asbestos flooring that is well adhered and in good
condition.

Level A Work Practice
        Perform pre-work activities on Level A checklist.

        Tools, equipment, and materials:

         A.   Tools as needed,


         B. Anchoring devices and equipment, and

         C. Non-asbestos adhesive.

       Place tools, equipment and materials needed in work area.

        Install base plate of wall on full bed of adhesive and attach to floor using appropriate anchoring devices.

        HEPA vacuum any chips or dust generated during fastening operation.

        Complete installation of wall.

        Perform cleanup and tear down steps on Level A checklist to complete work.




WP22—Remove Carpet Over Resilient Asbestos
Flooring

Summary
This work practice describes the procedures to be used for removing a small area of carpet installed over
resilient asbestos flooring for O&M work. These procedures assume that the carpet adhesive or mastic does not
contain asbestos, and that contamination is not present on the top side of the carpet. If a large area is involved, the
work might require that abatement procedures be used. Removal of well-adhered carpet can pull up resilient
asbestos flooring beneath the carpet.
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Example of Level A
An example of Level A would be to remove carpet that is non-adhered or weakly adhered to resilient asbestos flooring.

Level A Work Practice

       Perform pre-work activities on Level A checklist.

       Tools, equipment, and materials:

        A. Tools as needed,

        B. Metal straightedge for use when cutting carpet, and

        C. Scraper (2 to 3" [50-70 mm] wide stiff blade).

       Place tools, equipment and materials needed in work area.

       Find a seam or corner where carpet removal can begin. If no seams or corners exist, make a cut around the piece
        to be removed. Cut carpet using utility knife with a new blade.

       Pry up corner or seam of carpet using scraper. Pull back a section large enough [approximately one square
        foot (0.1 in2)] to hang onto while removing carpet. HEPA vacuum exposed flooring and back of carpet.

       Pull carpeting back slowly and HEPA vacuum exposed flooring & back of carpet. Remove carpet in pieces
        no larger than 200 square feet.

       If carpet and adhesive are non-ACBM, roll up carpet and dispose of as non-ACBM waste. If portions of
        asbestos-containing flooring remain attached to carpet backing, dispose of carpet as ACBM or in accordance
        with applicable regulations.

       HEPA vacuum surface of flooring after carpet is removed. If residual asbestos containing adhesive or residual
        felt backing needs to be removed, follow wet-scraping procedures. Allow substrate to dry before installing new
        flooring.

       Perform clean-up and tear down steps on Level A checklist to complete work.




Example of Level B
An example of Level B would be to remove carpet adhered to good condition resilient asbestos flooring where mastic
and/or a small number of tiles may be pulled up, or flooring may be pulled up without separation of backing and wear
layer. Resilient flooring mastic may or may not contain asbestos.




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Level B Work Practice

       Perform pre-work activities on Level B checklist.

       Tools, equipment, and materials:

        A. Tools as needed,

        B. Metal straightedge for use when cutting carpet, and

        C. Scraper (2 to 3" [50-70 mm] wide stiff blade).

       Secure work area.

       Place tools, equipment and materials needed in work area.

       Find a seam or corner where carpet removal can begin. If no seams or corners exist, make a cut around the piece
        to be removed. Wet the areas that need to be cut using amended water. Cut carpet using utility knife with a new
        blade.

       Pry up corner or seam of carpet using scraper. Pull back a section large enough (approximately one square foot)
        to hang onto while removing carpet. Adequately wet flooring and adhesive exposed.

       Pull carpeting back slowly and spray amended water on flooring and adhesive as they are exposed. Remove
        carpet in pieces no larger than 200 square feet.

       If carpet and adhesive are non-ACBM, roll up carpet and dispose of as non-ACBM waste. If portions of
        asbestos-containing flooring remain attached to carpet backing, dispose of carpet as ACBM. Loose vinyl
        asbestos flooring shall be disposed of in disposal bags or containers.

       HEPA vacuum surface of flooring after carpet is removed. If residual asbestos containing adhesive or residual
        felt backing needs to be removed, follow wet-scraping procedures. Allow substrate to dry before installing new
        flooring.

       Perform clean-up and tear down steps on Level B checklist to complete work.




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SECTION 5


References
EPA Publications

U.S. EPA guidance documents can be ordered by calling the TSCA Hotline at 202-554-1404 or through EPA's website
at http: //www.epa.gov

    U.S. Environmental Protection Agency. Asbestos Abatement Projects; Worker Protection; Final Rule ("Worker
     Protection Rule"). 40 CFR 763.120-126. Washington D.C. 1987.

    U.S. Environmental Protection Agency. National Emission Standards for Hazardous Air Pollutants (NESHAP). 40
     CFR 61.140-157. Washington D.C. 1984, revised 1990.

    U.S. Environmental Protection Agency. Asbestos-Containing Materials in Schools; Final Rule and Notice
     (Asbestos Hazard Emergency Response Act - AHERA). 40 CFR 763.80-99. Washington D.C. 1987.

    U.S. Environmental Protection Agency. Managing Asbestos in Place ("Green Book"). EPA Publication #20T-
     2003. Washington D.C. 1990.

    U.S. Environmental Protection Agency, Guidance for Controlling Asbestos-Containing Materials in Buildings
     ("Purple Book"). EPA publication #560/5-85-024. Washmgton D.C. 1985.

    U.S. Environmental Protection Agency. A Guide to Respiratory Protection for the Asbestos Abatement Industry
     ("White Book"). EPA publication #560-OPTS-86-001. Washington D.C. 1986.

    U.S. Environmental Protection Agency. Simplified Sampling scheme for Surfacing Materials ("Pink Book"). EPA
     publication #560/5-85-030a. Washington D.C. 1985.

    U.S. Environmental Protection Agency, EPA Guidance for Service and Maintenance Personnel, EPA publication
     #560/5-85-018, Washington D.C. 1985.

    U.S. Environmental Protection Agency. Model training course materials for accrediting Asbestos Building
     Inspectors and Management Planners in accordance with AHERA. Washington D.C. 1987.

    U.S. Environmental Protection Agency. Abatement of Asbestos-Containing Pipe Insulation, Asbestos-in-
     Buildings. Technical Bulletin 1986-2. Washington D.C. 1986.

    U.S. Environmental Protection Agency. Advisory Regarding Availability of an Improved Asbestos Bulk Sample
     Analysis Test Method; Supplementary Information Bulk Sample Collection and Analysis. Washington D.C. 1994.


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OSHA Regulations
Guidance documents by the Occupational Safety and Health Administration (OSHA) can be
ordered by calling OSHA at 202-693-1999 or through OSHA's website at http://www.osha.gov

   Occupational Safety and Health Administration. Asbestos Regulations for the Construction Industry. 29 CFR
    1926.1101. Washington D.C. 1994.

   Occupational Safety and Health Administration. Respiratory Protection. 29 CFR 1910.134. Washington, D.C. 1978.

   Occupational Safety and Health Administration. Hazard Communication Standard for the Construction Industry. 29
    CFR 1926.59. Washington D.C. 1987.



Commonwealth of Puerto Rico Publications
   Laws, regulations, and guidance documents established by the Puerto Rico Environmental

   Quality Board (PREQB) are available on their website at http://www.jca-pr.org.

   Puerto Rico Legislature. Environmental Public Policy Act (Law Number 9) of June 18, 1970.

   PREQB. Management of Materials Containing Asbestos. Rule 422 in the Regulations for the Control of
    Atmospheric Contamination.

   PREQB. Guidance for the Management of Asbestos. Appendix G in the Regulations for the Control of Atmospheric
    Contamination.

   PREQB. Regulations for the Management of Non-Hazardous Solid Waste. Rules 500 through 610. October 1993.



U.S. General Services Administration (PMSE)
   U.S. General Services Administration. Documentation Package for Asbestos Operations & Maintenance Programs.
    Washington D.C. 1990.



Military Policy, Directives and Guidance
The following military documents can be obtained from the Defense Environmental Network and Information Exchange
(DEMX) at website: http://www.denix.osd.mil.

   Army Regulation (AR) 200-1. Environmental Protection and Enhancement. June 19, 1997.

   U.S.Army Corps of Engineers. Guide Specifications for Construction. Section 13280; Asbestos Abatement.
    October 1999.

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Miscellaneous References
Institute for Environmental Assessment, 433 Jackson Street, Anoka, MN 55303:

   Suggested Operations and Maintenance Procedures

   Guide to Asbestos Personal Monitoring

   Recognition of Damage, Deterioration and Delamination

   Aerodynamic Characteristics of Asbestos

   Keyes, D. L. and J. Chesson. Guide to Monitoring Airborne Asbestos in Buildings. Tucson, AZ. 1989.

   Health Effects Institute. Asbestos Research, Asbestos in Public and Commercial Buildings; A Literature Review
    and Synthesis of Current Knowledge. Cambridge, MA. 1991.

   National Institute of Building Sciences. Asbestos Abatement and Management in Buildings; Model Guide
    Specifications. 1987.


O&M Program Elements References
   APM Appointment & Training
     — Purple Book, AHERA, White Book

   Worker Training
    — Purple Book, AHERA, White Book, OSHA 29 CFR 1926.1101

   Work Practices

   AHERA, OSHA 29 CFR 1910.1001, 29 CFR 1926.1101

   Building Inspection & Assessment
    — Purple Book, AHERA, Pink Book, OSHA 29 CFR 1910.1001,29 CFR 1926.1101

   Occupant Notification & Communication
    — AHERA, OSHA 29 CFR 1910.1001, 29 CFR 1926.1101

   Hazard Communication Program
    — OSHA 29 CFR 1910.1200, OSHA 29 CFR 1926.59.

   Worker Exposure Monitoring
    — OSHA 29 CFR 1910.1001, 29 CFR 1926.1101

   Respiratory Protection Program
    — White Book, OSHA 29 CFR 1910.1001, 29 CFR 1910.134, 29 CFR 1926.1101
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   Work Permit System

   Waste Disposal
    — EPA NESHAP, 40 CFR 61.145,40 CFR 61.150, OSHA 29 CFR 1910.1200, DOT 49 CFR Parts 171 & 180

    Recordkeeping

    AHERA, OSHA 29 CFR 1910.1001, 29 CFR 1926.1101

    Fiber Releases
     — Purple Book, AHERA

   Periodic Surveillance & Re-inspections
     — Purple Book, AHERA

   Air Monitoring
     — Purple Book, AHERA, OSHA 29 CFR 1910.1001, 29 CFR 1926.1101

    Confined Spaces
     — OSHA 29 CFR 1910.1001, 29 CFR 1915.1001, 29 CFR 1926.1101

    General Safety Hazards
    — White Book, Appendix D; OSHA 29 CFR 1926.



SECTION 6


Life-Cycle Cost Analysis
Exhibit 6-1 is a template that can be used to summarize life cycle costs.

                                                       EXHIBIT 6-1
Life Cycle Cost Analysis
                            Yearly O&M Refresher
                                                            Three Year Re-inspection       One Time Asbestos
Initial O&M Setup Cost'     Training & Six-Month
                                             2                                  3                              4
                               Reassessment                     by Consultant              Abatement Cost
$                           $                          $                               $


Notes:
1. Initial O&M setup cost includes the cost of developing an O&M Plan, conducting the initial onsite personnel
    training, placing notification signs on the employee bulletin boards, and labeling asbestos-containing materials
    where required.
2. The yearly O&M refresher training and six-month reassessment cost assumes in-house refresher training and in-
    house reassessments. The six-month reassessment will typically be conducted by the APM according to the
    procedures outlined in Section 3.
3. The three-year re-inspection cost consists of a independent environmental consultant visiting the facility and
    physically
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     touching and reassessing each homogeneous area of asbestos-containing material.

4.   The one-time asbestos abatement cost does not include assumed asbestos-containing materials (e.g., fire doors,
       roofing materials, etc.) and assumes that all identified materials will be abated at the same time.



APPENDIX A




                                                     Glossary

Acoustical Insulation: The general application or use of asbestos for the control of sound due to its lack of reverberant
surfaces.

Acoustical Tile: A finishing material in a building usually found in the ceiling or walls for the purpose of noise control.

Actinolite: One of six naturally occurring asbestos minerals. It is not normally used commercially.

Action Level (AL): A level of airborne fibers specified by OSHA as a warning or alert level. it is currently 0.1 fibers per
cubic centimeter (fibers/cm3) of air, 8-hour time-weighted average, as measured by phase contrast microscopy.
Addenda: Changes made to working drawings and specifications for a building before the

work is bid.

AlA:     American Institute of Architects

Algorithm: A formal numerical procedure for assessing suspect material; results are given a numerical score.

Amosite: An asbestiform mineral of the amphibole group containing approximately 50 percent silicon and 40 percent
iron oxide, and is made up of straight, brittle fibers, light gray to pale brown in color.

Amphibole: One of the two major groups of minerals from which the asbestiform minerals are derived — distinguished
by their chain-like crystal structure and chemical composition. Amosite and crocidolite are examples of amphibole
minerals.

Anthophyllite: One of six naturally occurring asbestos minerals. It is of limited commercial value.

As-built Drawings: Drawings and specifications which should reflect the way a building was actually constructed (also
known as record documents).

Asbestiform Minerals: Minerals which, due to their crystal structures and chemical composition, tend to be separated
into fibers and can be classified as a form of asbestos.
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Asbestos: A generic name given to a number of naturally occurring hydrated mineral silicates that possess a unique
crystalline structure, are incombustible in air, and are separable into fibers. Asbestos includes the asbestiform varieties of
chrysotile (serpentine); crocidolite (riebeckite); amosite (cummingtonite-grunerite); anthophyllite; and tremolite-
actmolite.

Asbestos Bodies: Coated asbestos fibers often seen in the lungs of asbestos-exposure victims.

Asbestos-containing Building Material (ACBM): Surfacing ACBM, thermal system insulation ACBM, or
miscellaneous ACBM that is found in or on interior structural members or other parts of a school building (AHERA
definition).

Asbestos-containing Material (ACBM): Any material or product which contains more than 1 percent asbestos (AI-
IERA definition).

Asbestosis: A non-malignant, progressive lung disease caused by the inhalation of asbestos dust and characterized by
diffuse fibrosis.

Breaching: A duct which transports combustion gases from a boiler or heater to a chimney or stack. Also called a flue.

Bulk Sample: A sample of bulk material; in the case of asbestos, suspect material.

Category I Non-friable ACM: Asbestos-containing packing, gaskets, resilient floor covering and asphalt roofing
products containing more than 1 percent asbestos.

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

Cementitious ACM: Asbestos-containing materials that are densely packed, granular and are generally non-friable.

Chain-of-custody: Formal procedures for tracking samples and ensuring their integrity.

Change order: A change to construction documents after a contract for construction has been signed.

Claims-made Insurance: A form of insurance in which a claim is allowed only if the insurance is in effect when the
claim is made; that is, when the injury or effect is observed.

Class I Asbestos Work: Activities defined by OSHA involving the removal of thermal system insulation (ThI) and
surfacing ACBM and PACM.

Class II Asbestos Work: Activities defined by OSHA involving the removal of ACBM which is not thermal system
insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor
tile and sheeting, roofing and siding shingles, and construction mastic. Certain "incidental" roofing materials such as
mastic, flashing and cements when they are still intact are excluded from Class II asbestos work. Removal of small
amounts of these materials which would fit into a glove-bag may be classified as a Class III job.
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Class III Asbestos Work: Activities defined by OSHA that involve repair and maintenance operations, where ACM,
including TSI and surfacing ACBM, is likely to be disturbed. Operations may include drilling, abrading, cutting a hole,
cable pulling, crawling through tunnels or attics and spaces above the ceiling, where asbestos is actively disturbed or
asbestos-containing debris is actively disturbed.

Class IV Asbestos Work: Maintenance and custodial construction activities during which employees contact but do not
disturb ACBM and activities to clean-up dust, waste and debris resulting from Class I, II, and III activities. This may
include dusting surfaces where ACBM waste and debris and accompanying dust exists and cleaning up loose ACBM
debris from TSI or surfacing ACBM following construction.

Clean Room: An uncontaminated room having facilities for the storage of employees' street clothing and
uncontaminated materials and equipment.

Competent Person: In addition to the definition in 29 CFR 1926.32(f), a person who is capable of identifying existing
asbestos hazards as defined in 29 CFR 1926, Section 1101, selecting the appropriate control strategy, has the authority to
take prompt corrective measures to eliminate them, and has EPA Model Accreditation Plan (MAP)
"Contractor/Supervisor" training; accreditation required by 40 OFR 763, Subpart E, Appendix C.

Contractor/Supervisor: Individual who supervises asbestos abatement work and has EPA
Model Accreditation Plan "Contractor/Supervisor" training; accreditation required by
40 CFR 763, Subpart E, Appendix C.

Contract Documents: Legally binding building drawings and specifications. Also called construction documents.

Chrysotile: The only asbestiform mineral of the serpentine group which contains approximately 40 percent each of
silica and magnesium oxide. It is the most common form of asbestos used in buildings.

CIH: An industrial hygienist who has been granted certification by the American Board of Industrial Hygiene.

Cilia: Tiny hair-like structures in the windpipe and bronchi of the lung passages that help force undesirable particles and
liquids up and out of the lungs.

Crocidolite: The strongest of asbestos minerals. An asbestiform mineral of the amphibole group. It is of minor
commercial value in the U.S.

Damaged Friable Surfacing (miscellaneous) Material: Friable surfacing (miscellaneous) ACBM which has
deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or, if
applicable, which has delaminated such that the bond to the substrate (adhesion) is inadequate or which for any other
reason lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of
AP into layers; separation of ACBM from the substrate; flaking, blistering, or crumbling of ACBM surface; water
damage; significant or repeated water stains; scrapes~ gouges; mars or other signs of physical injury on the ACBM.
Asbestos debris originating from the ACBM in question may also indicate damage (AHERA definition).


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Damaged or Significantly Damaged Thermal System Insulation: Thermal system insulation on pipes, boilers, tanks,
ducts, and other thermal system insulation equipment for which the insulation has lost its structural integrity, or its
covering, in whole or in part, is crushed, water-stained, gouged, punctured, missing, or not intact such that it is not able
to contain fibers. Damage may be further illustrated by occasional punctures, gouges, or other signs of physical injury to
ACBM; occasional water damage on the protective coverings/ jackets: or exposed ACBM ends or joints. Asbestos debris
originating from the ACBM in question may also indicate damage (AHERA definition)Dose-response Effect: The
relationship between the amount of pollutant a person is exposed to (dose) and the increase risk of disease (effect).
Usually the greater the dose, the greater the effect.

Electrical Systems: The system of wires, lights, power generation equipment and related facilities to produce, convey,
and utilize electrical power in a building.

Encapsulation: The use of an agent to seal the surface (bridging encapsulant) or penetrate the bulk (penetrating
encapsulant) of ACBM.

Epidemilogy: The study of causes, occurrence and distribution of disease throughout a population.

Errors and Omissions Insurance: A type of insurance which protects professionals for mistakes they may make in
contracted plans and recommendations.

Escutcheon: A protective cover plate surrounding a light switch, light fixture mount, or other similar item.

Excursion Limit (EL): A level of airborne fibers specified by OSHA as a short term excursion level. it is currently 1.0
fibers per cubic centimeter (fibers/cm3) of air, 30-minute time-weighted average, as measured by phase contrast
microscopy.

Fibers/cm3: Fibers per cubic centimeter of air.

Fireproofing: Spray or trowel applied fire-resistant materials.

Friable: Any material that can be crumbled, pulverized, or reduced to powder by hand pressure.

Functional Spaces: Spatially distinct units within a building which contain identifiable populations of building
occupants.

General Liability Insurance: A type of insurance which covers the insured for damage to property and person caused
by his or her own negligence.

Heating, Ventilating, and Air Conditioning (HVAC) system: The system of pipes, ducts, and equipment (air
conditioners, chillers, heaters, boilers, pumps, fans) used to heat, cool, move, and filter air in a building. HVAC systems
are also known as mechanical systems.

High Efficiency Particulate Air (HEPA) Filter: A type of filter which is 99.97 percent efficient at trapping and
retaining particles of 0.3 micrometers in diameter.
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Homogeneous: An area which appears similar throughout in terms of color, texture, and date of material application.

Industrial Hygienist: A professional qualified by education, training, and experience to recognize, evaluate, and
develop controls for occupational health hazards.

Indemnify: To pay for or pay back; Indemnification clauses in contracts are intended to cover the cost of judgements
and/or legal defenses in the event of litigation.

Latency Period: The time between first exposure to a disease-causing agent and the appearance of the disease.

Liability: Being subject to legal action for one's behavior.

Lung Cancer: A malignant growth of abnormal cells in the lungs, specifically of the bronchi covering.

Mechanical Systems: see HVAC systems

Mesothelioma: A relatively rare form of cancer which develops in the lining of the pleura or peritoneum with no known
cure. It is almost always caused by exposure to asbestos.

Miscellaneous Material: Interior building material on structural components, structural members or fixtures, such as
floor and ceiling tiles, and does not include surfacing material or thermal system insulation (AHERA definition)

Model Accreditation Plan (MAP): USEPA training accreditation requirements for persons who work with asbestos as
specified in 40 CFR 763, Subpart E, Appendix C.

Modification: A changed or altered procedure, material or component of a control system, which replaces a procedure,
material or component of a required system.

MSHA: Mine Safety and Health Administration.

Negative Pressure Respirators: Respirators which function by the wearer breathing in air through a filter.

Negative Pressure Respirator Check: A form of qualitative fit testing in which the wearer covers the filters of a
negative pressure, air-purifying respirator to check for leaks around the face seal.

NIOSH: National Institute for Occupational Safety and Health, which was established by the Occupational Safety and
Health Act of 1970.

NIOSH/MSHA: The official approving agencies for respiratory protective equipment who test and certify respirators.

Negative Exposure Assessment: A demonstration by the Contractor to show that employee exposure during an
operation is expected to be consistently below the OSHA Permissible Exposure Limits (PELs).

NESHAP: National Emission Standards for Hazardous Air Pollutants. The USEPA NESHAP regulation for asbestos is
at 40 CFR 61, Subpart M.


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Non-friable ACBM: A NESHAP term defined in 40 CFR 61, Subpart M and EPA 340/1-90-018, meaning any material
containing more than 1 percent asbestos, as determined using the method specified in 40 CFR 763, Subpart E, Appendix
A, Section 1, Polarized Light Microscopy, that, when dry, cannot be crumbled, pulverized or reduced to powder by hand
pressure.

Non-friable ACBM (Category I): A NESHAP term defined in 40 CFR 61, Subpart E and EPA 340/1-90-018, meaning
asbestos-containing packing, gaskets, resilient floor covering, and asphalt roofing products containing more than 1
percent asbestos as determined using the method specified in 40 CFR 763, Subpart F, Appendix A, Section 1, Polarized
Light Microscopy, that, when dry, cannot be crumbled; pulverized or reduced to powder by hand pressure.

Specifications: A written set of standards, procedures, and materials for the construction of a building.

Structural Member: Any load-supporting member, such as beams and load supporting walls of a facility.

Submittals: Drawings or descriptive literature such as operating manuals transmitted to the building owner upon
construction completion.

Substrate: The material or existing surface located under or behind the asbestos-containing material.

Surfacing Material: Material in a school building that is sprayed-on, troweled-on or otherwise applied 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 (AHERA definition).

Synergistic: The combination of two effects which. is greater than the sum of the two independent effects.

Thermal System Insulation: Material applied to pipes, fittings, boilers, breaching, tanks, ducts, or other interior
structural components to prevent heat loss or gain, or water condensation, or for other purposes.

Tort: A legal wrong, sometimes referred to as negligence.

Transite®: A trade name for asbestos cement wallboard and pipe.

Transmission Electron Microscopy (TEM): A method of microscopic analysis which utilizes an electron beam that is
focused onto a thin sample. As the beam penetrates (transmits) through the sample, the difference, in densities produces
an image on a fluorescent screen from which samples can be identified and counted. Used for analyzing air samples for
asbestos.

Tremolite: One of six naturally occurring asbestos minerals. Tremolite has few commercial uses.

TWA: Time Weighted Average, as in air sampling.

Working Drawings: A set of drawings which reflect the intended construction and appearance of the building. Also
known as building plans.

Competent Person: In addition to the definition in 29 CFR 1926.32(f), a person who is capable of identifying existing
asbestos hazards as defined in 29 CFR 1926, Section 1101, selecting the appropriate control strategy, has the authority to
take prompt corrective measures to eliminate them, and has EPA Model Accreditation Plan (MAP)

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"Contractor/Supervisor" training; accreditation required by 40 OFR 763, Subpart E, Appendix C.

Contractor/Supervisor: Individual who supervises asbestos abatement work and has EPA
Model Accreditation Plan "Contractor/Supervisor" training; accreditation required by
40 CFR 763, Subpart E, Appendix C.

Contract Documents: Legally binding building drawings and specifications. Also called construction documents.

Chrysotile: The only asbestiform mineral of the serpentine group which contains approximately 40 percent each of
silica and magnesium oxide. It is the most common form of asbestos used in buildings.

CIH: An industrial hygienist who has been granted certification by the American Board of Industrial Hygiene.

Cilia: Tiny hair-like structures in the windpipe and bronchi of the lung passages that help force undesirable particles and
liquids up and out of the lungs.

Crocidolite: The strongest of asbestos minerals. An asbestiform mineral of the amphibole group. It is of minor
commercial value in the U.S.

Damaged Friable Surfacing (miscellaneous) Material: Friable surfacing (miscellaneous) ACBM which has
deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or, if
applicable, which has delaminated such that the bond to the substrate (adhesion) is inadequate or which for any other
reason lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of
AP into layers; separation of ACBM from the substrate; flaking, blistering, or crumbling of ACBM surface; water
damage; significant or repeated water stains; scrapes~ gouges; mars or other signs of physical injury on the ACBM.
Asbestos debris originating from the ACBM in question may also indicate damage (AHERA definition).

Competent Person: In addition to the definition in 29 CFR 1926.32(f), a person who is capable of identifying existing
asbestos hazards as defined in 29 CFR 1926, Section 1101, selecting the appropriate control strategy, has the authority to
take prompt corrective measures to eliminate them, and has EPA Model Accreditation Plan (MAP)
"Contractor/Supervisor" training; accreditation required by 40 OFR 763, Subpart E, Appendix C.

Contractor/Supervisor: Individual who supervises asbestos abatement work and has EPA
Model Accreditation Plan "Contractor/Supervisor" training; accreditation required by
40 CFR 763, Subpart E, Appendix C.

Contract Documents: Legally binding building drawings and specifications. Also called construction documents.

Chrysotile: The only asbestiform mineral of the serpentine group which contains approximately 40 percent each of
silica and magnesium oxide. It is the most common form of asbestos used in buildings.

CIH: An industrial hygienist who has been granted certification by the American Board of Industrial Hygiene.

Cilia: Tiny hair-like structures in the windpipe and bronchi of the lung passages that help force undesirable particles and
liquids up and out of the lungs.

Crocidolite: The strongest of asbestos minerals. An asbestiform mineral of the amphibole group. It is of minor
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commercial value in the U.S.

Damaged Friable Surfacing (miscellaneous) Material: Friable surfacing (miscellaneous) ACBM which has
deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or, if
applicable, which has delaminated such that the bond to the substrate (adhesion) is inadequate or which for any other
reason lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of
AP into layers; separation of ACBM from the substrate; flaking, blistering, or crumbling of ACBM surface; water
damage; significant or repeated water stains; scrapes~ gouges; mars or other signs of physical injury on the ACBM.
Asbestos debris originating from the ACBM in question may also indicate damage (AHERA definition).

Damaged or Significantly Damaged Thermal System Insulation: Thermal system insulation on pipes, boilers, tanks,
ducts, and other thermal system insulation equipment for which the insulation has lost its structural integrity, or its
covering, in whole or in part, is crushed, water-stained, gouged, punctured, missing, or not intact such that it is not able
to contain fibers. Damage may be further illustrated by occasional punctures, gouges, or other signs of physical injury to
ACBM; occasional water damage on the protective coverings/ jackets: or exposed ACBM ends or joints. Asbestos debris
originating from the ACBM in question may also indicate damage (AHERA definition)Dose-response Effect: The
relationship between the amount of pollutant a person is exposed to (dose) and the increase risk of disease (effect).
Usually the greater the dose, the greater the effect.

Electrical Systems: The system of wires, lights, power generation equipment and related facilities to produce, convey,
and utilize electrical power in a building.

Encapsulation: The use of an agent to seal the surface (bridging encapsulant) or penetrate the bulk (penetrating
encapsulant) of ACBM.

Epidemilogy: The study of causes, occurrence and distribution of disease throughout a population.

Errors and Omissions Insurance: A type of insurance which protects professionals for mistakes they may make in
contracted plans and recommendations.

Escutcheon: A protective cover plate surrounding a light switch, light fixture mount, or other similar item.

Excursion Limit (EL): A level of airborne fibers specified by OSHA as a short term excursion level. it is currently 1.0
fibers per cubic centimeter (fibers/cm3) of air, 30-minute time-weighted average, as measured by phase contrast
microscopy.

Fibers/cm3: Fibers per cubic centimeter of air.

Fireproofing: Spray or trowel applied fire-resistant materials.

Friable: Any material that can be crumbled, pulverized, or reduced to powder by hand pressure.

Functional Spaces: Spatially distinct units within a building which contain identifiable populations of building
occupants.

General Liability Insurance: A type of insurance which covers the insured for damage to property and person caused
by his or her own negligence.
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Heating, Ventilating, and Air Conditioning (HVAC) system: The system of pipes, ducts, and equipment (air
conditioners, chillers, heaters, boilers, pumps, fans) used to heat, cool, move, and filter air in a building. HVAC systems
are also known as mechanical systems.

High Efficiency Particulate Air (HEPA) Filter: A type of filter which is 99.97 percent efficient at trapping and
retaining particles of 0.3 micrometers in diameter.

Homogeneous: An area which appears similar throughout in terms of color, texture, and date of material application.

Industrial Hygienist: A professional qualified by education, training, and experience to recognize, evaluate, and
develop controls for occupational health hazards.

Indemnify: To pay for or pay back; Indemnification clauses in contracts are intended to cover the cost of judgements
and/or legal defenses in the event of litigation.

Latency Period: The time between first exposure to a disease-causing agent and the appearance of the disease.

Liability: Being subject to legal action for one's behavior.

Lung Cancer: A malignant growth of abnormal cells in the lungs, specifically of the bronchi covering.

Mechanical Systems: see HVAC systems

Mesothelioma: A relatively rare form of cancer which develops in the lining of the pleura or peritoneum with no known
cure. It is almost always caused by exposure to asbestos.

Miscellaneous Material: Interior building material on structural components, structural members or fixtures, such as
floor and ceiling tiles, and does not include surfacing material or thermal system insulation (AHERA definition)

Model Accreditation Plan (MAP): USEPA training accreditation requirements for persons who work with asbestos as
specified in 40 CFR 763, Subpart E, Appendix C.

Modification: A changed or altered procedure, material or component of a control system, which replaces a procedure,
material or component of a required system.

MSHA: Mine Safety and Health Administration.

Negative Pressure Respirators: Respirators which function by the wearer breathing in air through a filter.

Negative Pressure Respirator Check: A form of qualitative fit testing in which the wearer covers the filters of a
negative pressure, air-purifying respirator to check for leaks around the face seal.

NIOSH: National Institute for Occupational Safety and Health, which was established by the Occupational Safety and
Health Act of 1970.

NIOSH/MSHA: The official approving agencies for respiratory protective equipment who test and certify respirators.
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Negative Exposure Assessment: A demonstration by the Contractor to show that employee exposure during an
operation is expected to be consistently below the OSHA Permissible Exposure Limits (PELs).

NESHAP: National Emission Standards for Hazardous Air Pollutants. The USEPA NESHAP regulation for asbestos is
at 40 CFR 61, Subpart M.

Non-friable ACBM: A NESHAP term defined in 40 CFR 61, Subpart M and EPA 340/1-90-018, meaning any material
containing more than 1 percent asbestos, as determined using the method specified in 40 CFR 763, Subpart E, Appendix
A, Section 1, Polarized Light Microscopy, that, when dry, cannot be crumbled, pulverized or reduced to powder by hand
pressure.

Non-friable ACBM (Category I): A NESHAP term defined in 40 CFR 61, Subpart E and EPA 340/1-90-018, meaning
asbestos-containing packing, gaskets, resilient floor covering, and asphalt roofing products containing more than 1
percent asbestos as determined using the method specified in 40 CFR 763, Subpart F, Appendix A, Section 1, Polarized
Light Microscopy, that, when dry, cannot be crumbled; pulverized or reduced to powder by hand pressure.

Specifications: A written set of standards, procedures, and materials for the construction of a building.

Structural Member: Any load-supporting member, such as beams and load supporting walls of a facility.

Submittals: Drawings or descriptive literature such as operating manuals transmitted to the building owner upon
construction completion.

Substrate: The material or existing surface located under or behind the asbestos-containing material.

Surfacing Material: Material in a school building that is sprayed-on, troweled-on or otherwise applied 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 (AHERA definition).

Synergistic: The combination of two effects which. is greater than the sum of the two independent effects.

Thermal System Insulation: Material applied to pipes, fittings, boilers, breaching, tanks, ducts, or other interior
structural components to prevent heat loss or gain, or water condensation, or for other purposes.

Tort: A legal wrong, sometimes referred to as negligence.

Transite®: A trade name for asbestos cement wallboard and pipe.

Transmission Electron Microscopy (TEM): A method of microscopic analysis which utilizes an electron beam that is
focused onto a thin sample. As the beam penetrates (transmits) through the sample, the difference, in densities produces
an image on a fluorescent screen from which samples can be identified and counted. Used for analyzing air samples for
asbestos.

Tremolite: One of six naturally occurring asbestos minerals. Tremolite has few commercial uses.

TWA: Time Weighted Average, as in air sampling.

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