University of Nevada, Reno

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1 University of Nevada, Reno ASBESTOS PROGRAM Program Contact: John A. Braun, CSP Environmental Health and Safety University of Nevada, Reno Phone:

2 ASBESTOS PROGRAM UNIVERSITY OF NEVADA, RENO TABLE OF CONTENTS 1.0 INTRODUCTION Policy Purpose Scope RESPONSIBILITY Department Director Supervisors, Project Leaders, Project Coordinators Craft Supervisors Employees Department of Environmental Health and Safety (EH&S) SPECIFIC PROCEDURES Inspections/Surveys Inspectors Bulk Material Sample Numbers Bulk Material Sample Collection Procedures Sample Analysis Interpretation of Sample Results Written Survey reports Consultant Surveys AIR MONITORING Negative Exposure Assessments (NEAs) Final Clearance Air Sample Minor Wall Penetrations ASBESTOS WALL DISPOSAL NOTIFICATIONS Regulatory & EHS Regulatory Notification EHS Notification ACCIDENTIAL/UNPLANNED ASBESTOS RELEASE EMPLOYEE TRAINING RECORDKEEPING LABELING WARNING SIGNS GLOSSARY 16 Appendix A CRAFT ASBESTOS SURVEY FLOW CHART 18 Appendix B CONSTRUCTION PROJECT FLOW CHART 19 Appendix C WET METHOD WALL PENETRATIONS 20 Appendix D NEA ACOUSTIC CEILING 21 Appendix E SUMMARY RESPONSIBILITIES 23 Appendix F REFERENCE CHECKLIST 25 Appendix G QUICK REFERENCE FOR CLASS OF WORK 26 2 University of Nevada Reno

3 1.0 INTRODUCTION 1.1 Safety Policy It is the policy of the University of Nevada, Reno (UNR) to ensure safe and healthy learning, research, work, entertainment and student living environments for faculty, staff, students and visitors. Implicit in this policy is a requirement to provide individuals with pertinent information regarding asbestos safety. All persons MUST review the Asbestos Program prior to performing any maintenance services work, such as penetrating walls, removing ceiling or floor tiles, or otherwise disturbing construction materials, within University of Nevada, Reno buildings. Unless shown to be otherwise, one must presume asbestos containing materials (PACM). This University of Nevada, Reno program requires that all employees and contractors be made aware of asbestos containing materials in their work area. Every effort shall be made to minimize the unintentional disturbance of asbestos containing material on the University of Nevada, Reno campus by following the procedures outlined in this document. This program requires that all Class I, Class II and/or Class III (see Glossary for definitions) asbestos abatement work performed by University of Nevada, Reno employees or contractors will be performed only by Nevada Asbestos Licensed employees and under Asbestos Licensed supervision. All asbestos management practices used on campus will meet or exceed all applicable pertinent federal, state and local regulations. 1.2 Purpose The purpose of this program is to minimize and control potential exposures to asbestos fibers liberated from building materials for all employees, students and members of the public on campus and to assure compliance with all applicable asbestos control regulations. 1.3 Scope This program applies to all personnel on campus who are involved in construction and maintenance craft trades and those who may perform repairs, remodels or renovations to any existing building. 3 University of Nevada Reno

4 2.0 RESPONSIBILITIES 2.1 Facilities Services Department (FSD) and Facilities Maintenance Services Directors Facilities Services and Facilities Maintenance Asbestos Services have the responsibility to: a. Provide administrative and financial support for this program within individual departments. b. Ensure the Asbestos Program is implemented and maintained within the department. c. Ensure that only personnel who possess current certifications/licenses perform any and all asbestos related work activities. d. Notify, when required, appropriate regulatory agencies (State of Nevada's Department of Business and Industry Industrial Relations Division of Occupational Safety and Health Enforcement Section and Washoe County Air Quality of planned abatement activities when required and prior to commencing work on a given asbestos project. e. Require employees that work in, on or around asbestos containing material and their supervisors to be asbestos trained. f. Advise all contractors about all known asbestos containing materials in areas where they will be working prior to start of work. g. Ensure that asbestos related contract specifications include stipulations for the provision of necessary copies of written safety plans, personnel certification and licensing documentation. h. Ensure that third party contract specifications include stipulations for the documented use of asbestos-free materials. i. Ensure that all third party contracted repair, maintenance, or renovation work have an asbestos survey completed by Facilities Maintenance Asbestos Services or a properly licensed asbestos consultant prior to the commencement of any work. j. Ensure that all third party contracts contain specifications stipulating the requirements for notification of state and local authorities as per Section 5.2 b of this plan at least ten days prior to commencing any work on the project, and for the payment of necessary filing/application fees if applicable. k. Ensure that craft groups contact EH&S or Facilities Maintenance Asbestos Services to obtain an asbestos survey or survey results prior to commencing repair, remodeling, or construction activities in accordance with the decision making flow chart contained in Appendix A l. Ensure that all asbestos related work performed by University of Nevada, Reno staff and third party contractors is conducted in a manner that conforms to procedures outlined in this document. m. Ensure that the EH&S Department receives notification of project completion and copies of all asbestos abatement final reports. 2.2 Supervisors, Project Leaders, and Project Coordinators Individuals who have a supervisory responsibility play a key role in the Asbestos Program. They have responsibility for: a. Ensuring their subordinates are trained and understand the applicable provisions of the program. b. Ensuring their subordinates fulfill all requirements before any asbestos work is performed. c. Ensuring asbestos removal equipment is maintained in safe operating condition. d. Ensuring the precautions listed in the Asbestos Program are understood and followed by all employees and contractors. 4 University of Nevada Reno

5 e. Informing contractors and service personnel regarding the expectations of this program. 2.3 Craft Supervisors Supervisors have the responsibility to: a. Ensure all employees that work in, on or around asbestos containing material to be asbestos trained. b. Contact Facilities Maintenance Asbestos Services or EH&S Department unless the material is PACM for an asbestos survey/report prior to disturbing any asbestos containing material (ACM) or Presumed Asbestos Containing Material PACM or before the execution of any renovation project or permitting any employee to disturb any potentially asbestos containing materials in accordance with the decision making flow chart in Appendix A. NOTE: Job walks are often necessary to permit proper planning and scheduling of surveys and the standard turnaround time for laboratory analysis of bulk material samples is approximately 24 hours. 2.4 Facilities Maintenance Services (CLASS III & IV ASBESTOS) Workers Facilities Maintenance Services workers have the responsibility to: a. Read and comply with procedures and guidelines provided by their supervisors and the EH&S Department. b. Perform job duties in a manner that conforms to procedures outlined in this document. Follow all OSHA /EPE guidelines and follow proper work practices. c. Ensure their asbestos worker (Class III & IV) training is up to date prior to undertaking any duties related to that training. d. Ensure that any Negative Exposure Assessments NEAs to be used are current. 2.5 Environmental Health and Safety (EH&S) Department a. Provide technical information and assist Asbestos Crew in the development, and implementation of the Asbestos Program. b. Review and revise the Asbestos Program, as needed, for compliance with applicable regulations and process updates. c. Assist in providing Asbestos Program instruction, as needed. d. Conduct Asbestos Program safety assessments to determine if any engineering and/or other controls are needed, and how they should be implemented. e. Recommend appropriate engineering controls, administrative controls and personal protective equipment. f. Provide or make arrangements for annual Respiratory Protection fit-testing and training. g. Maintain database for all asbestos projects. Database will include all records as stated in section 8.0 of this program. h. Identify and label those areas that require asbestos warning signage. i. Conduct the original NEA air sampling and annual verification sampling and maintain all air sampling records. j. Conduct clearance sampling. k. Arrange for disposal of asbestos containing materials generated on the University of Nevada, Reno campus, with the exception of contracted asbestos abatement projects, unless determined by a Project coordinator. 5 University of Nevada Reno

6 3.0 SPECIFIC PROCEDURES 3.1 Inspections/Surveys a. Inspections will be conducted by Asbestos Hazard Emergency Response Act AHERA certified asbestos inspector only. b. Existing sampling records and reports will be consulted prior to performing an inspection or survey, to avoid unnecessary duplication and expense. 3.2 Inspectors shall ensure the following objectives are met: a. The location of all ACM and PACM not previously sampled through a visual inspection of the area will be determined. b. A determination of the friability status of all ACM or PACM in the area will be performed. c. The appropriate number of bulk material samples of all ACM or PACM in the area not previously sampled will be secured for analysis. 3.3 Bulk Material Sample Numbers are to be determined in accordance with 29 CFR (j)(8)(ii)(B), or 29 CFR (k)(5)(ii)(B) and 40 CFR Part as follows: a. TSI & Surfacing materials bulk samples shall be collected in a random manner based upon the following surface areas: linear or ft 2 or less; 3 samples 2. >1000 linear or ft 2 to 5000 linear or ft 2 5 samples 3. >5000 linear or ft 2 to 9000 linear or ft 2 7 samples 4. >9000 linear or ft 2 9 samples; in accordance with accepted standards of prudent professional practice. b. Thermal System Insulation (TSI) materials require that a minimum of three bulk samples be collected from each homogeneous area and one bulk material sample from each homogeneous area of patched TSI material. 3.4 Bulk Material Sample Collection Procedures a. University of Nevada, Reno personnel collecting bulk samples shall wear personal protective equipment (PPE) appropriate to the hazard. The following minimal equipment use guidelines shall be followed: 1. Friable material sampling requires the use of a half-mask air purifying respirator, equipped with either a HEPA, N100, R100 or P100 filter cartridge, and gloves by those personnel collecting the samples. 2. Non-friable material sampling does not require the use of PPE, provided that visible dust is not generated during sample collection. Clearance sampling is not required and will not be completed on all non-friable jobs. b. Samples will be collected in a random pattern within the area of potential disturbance. c. Core samples will be collected whenever feasible. All bulk samples shall be to the full depth of the ACM or PACM. d. Wet methods shall be used when sampling those materials reasonably expected to become friable as a result of the sampling techniques used. Such methods include, but are not limited 6 University of Nevada Reno

7 to, the application of a fine water mist to surface of the materials as the sample is being collected. e. All samples will be immediately placed into a leak proof container and sealed. f. All sample containers will be labeled with an appropriate sample number. g. The sample number and location will be identified on a drawing of the survey area. Copies of all such drawings shall be maintained at the EH&S Department. h. Sample data (date, location, material description, etc.) will be recorded on a field sample data sheet. i. Sample data will be recorded on a laboratory service request, or chain-of-custody, document and records of such documents shall be maintained at the EH&S office and in the project file kept at FSD. j. The original service request or chain-of-custody document shall be delivered to the analytical laboratory along with the samples. k. The signature of the laboratory representative who receives the samples shall be obtained on the original chain-of-custody document copy. 3.5 Sample Analysis will meet the following criteria: a. An EPA accredited laboratory must analyze samples. b. Sample analysis will meet standard EPA polarized light method (PLM) criteria. c. Should additional confirmation of the reported findings for a specific sample be in question, an additional point counting analytical method will be requested of the laboratory by the EH&S Department or Facilities Maintenance Department. 3.6 Interpretation of Sample Results shall be based upon the following criteria: a. For a given homogeneous material to be classified as asbestos free, all of the required material samples must be reported as either containing no asbestos, or <1% asbestos by weight. b. If all of the required samples for a given homogeneous material are reported as containing <1% asbestos by weight, additional analysis of at least one sample, by the point counting method, shall be requested of the analytical laboratory by the EH&S Department. c. Should one (1) sample of a given homogeneous material be reported as containing greater than 1% asbestos by weight, the entire material shall be considered as asbestos containing. No amount of additional material sampling and reporting can over-ride the finding of a material as being asbestos containing. d. Until sampling and analysis establishes that a PACM material contains no asbestos, or contains <1% asbestos by weight, all such materials shall be presumed to contain asbestos (thus the designation PACM). e. Only an AHERA certified building inspector has the legal authority to make a determination that a given material, such as fiberglass insulation, is asbestos free based upon a visual inspection. 3.7 Written Survey Reports shall include the following: a. A summary page(s), identifying those structural materials or surfaces which were sampled, the date sampled and the results of the sample analysis. This page(s) shall also contain 7 University of Nevada Reno

8 recommendations for abatement; including employee/contractor training requirements or work methods to be used in order to control asbestos fiber releases. b. Copies of the laboratory analysis reports. c. Copies of the laboratory service request/chain-of-custody documents. d. Copies of building drawings that identify sample locations by individual sample number. e. If appropriate, copies of the craft work order that generated the original survey request. 3.8 Consultant Surveys shall comply with the University of Nevada, Reno Asbestos Management Plan standards as defined in this document. a. The minimum number of samples shall be in accordance with the criteria established in section 3.3 of this Section. b. Consultant reports shall include building drawings identifying sample numbers and locations. c. A copy of the consultant s report and survey findings shall be provided to the EH&S Department. d. Consultant survey data that meets University Plan standards for acceptability will be entered into the EH&S database and will become part of the University overall asbestos regulatory compliance record (See Paragraph 8.2). 8 University of Nevada Reno

9 4.0 AIR MONITORING 4.1 NEGATIVE EXPOSURE ASSESSMENTS (NEA) are required for all Facilities Maintenance Services (FMS) procedures. NEAs normally consist of a series of air samples collected during the performance of a specific FMS task, the results of which are used to statistically establish that occupational exposures will consistently remain below the PEL (0.1 f/cc) for the O&M process/procedure monitored. An NEA must be established for each asbestos job. For example: (carpet removal, tile removal, mastic removal) would require three NEAs. Once a NEA has been established, air sampling must be conducted on at least an annual basis to confirm that the O&M procedure is maintaining an acceptable air concentration. Properly trained and qualified personnel (industrial hygienists, licensed monitors or specially trained personnel) must conduct NEAs. 4.2 FINAL CLEARANCE AIR SAMPLES are required for all asbestos abatement Class 1 and Class 2 Friable (not for Class 2 Non-Friable) projects prior to dismantling area containment. A properly licensed independent third-party consultant and EHS are required for all clearance air sampling. Acceptable clearance samples must establish a final airborne concentration of less than 0.01 f/cc inside the containment. 4.3 MINOR WALL PENETRATIONS Wall penetrations to hang pictures, blackboards, planters, etc. will be made in accordance with the Wet Method procedure contained in Appendix C. 9 University of Nevada Reno

10 5.0 ASBESTOS WASTE DISPOSAL Disposal of asbestos waste resulting from in-house asbestos work activities shall be arranged for by the Facilities Maintenance Department according to the following criteria: a. Friable asbestos waste shall follow all federal EPA and OSHA guidelines to include wet asbestos waste and double bag in six millimeter (6 mil) polyethylene disposal bags. Bagged asbestos waste materials must be labeled with proper EPA and OSHA warning labels. b. Non-friable asbestos waste must be maintained in a manner that will minimize damage. c. All asbestos waste materials will be placed in storage at FMS facilities designated for such storage purposes. d. All asbestos waste must be taken to disposal facilities permitted to handle such materials. e. Disposal records will be maintained by EH&S. NOTE: The General Contractor (GC) is responsible for the disposal of any, and all, contractor generated asbestos waste materials. 10 University of Nevada Reno

11 6.0 Regulatory - EHS 6.1 Notification of regulatory agencies shall be accomplished in accordance with written OSHA and Washoe County Regulatory requirements. a. Third party contractors are required to file the appropriate notifications and documents with the State of Nevada Washoe County Air Quality and Nevada State OSHA Department authorities ten days prior to commencing any asbestos work on the project if applicable. b. Facilities Planning & Construction (FPC) or FMS staff shall file the appropriate notifications and reporting documents with State of Nevada Washoe County Air Quality and Nevada State OSHA for in-house construction/remodeling projects ten days prior to commencing any work on the project if applicable. Note: Effective immediately, there will be no courtesy notifications to OSHA or Washoe County. 6.2 EHS EHS (Occupational Safety Officer) will receive all Asbestos job notifications that are sent to OSHA, Washoe County and any other regulatory agency. 11 University of Nevada Reno

12 7.0 ACCIDENTAL/UNPLANNED ASBESTOS RELEASE 7.1 PERSON CREATING OR DISCOVERING THE ACCIDENTAL RELEASE In the event of accidental damage to asbestos containing building materials (ACM pipe insulation, ACM ceiling acoustical materials, etc.) which results in the liberation of the asbestos, the person or persons either responsible for or who discover the damage shall initiate the following actions: 7.2 ISOLATE THE AREA OF DAMAGE through the use of barricades in order to contain the release and to prevent ACM materials from being spread to a larger area. Avoid all contact with the ACM debris. 7.3 NOTIFY AREA PERSONNEL of the release. All personnel should leave the area in question until full containment or clean-up is completed. 7.4 NOTIFY THEIR SUPERVISOR of the release. 7.5 SUPERVISOR OF THE PERSON REPORTING THE RELEASE The supervisor who receives notification of an accidental asbestos release will: 7.6 CONTACT the appropriate FSD personnel to make arrangements for clean-up of the debris by properly qualified personnel. 7.7 NOTIFY EH&S Department of the spill and request air monitoring of the site. 12 University of Nevada Reno

13 8.0 EMPLOYEE TRAINING All University of Nevada, Reno employee Asbestos Training must meet or exceed the OSHA requirements set forth in 29 CFR (k)(9) 8.1 Training for employees who perform Class I (removal of surfacing/tsi/acm or PACM). Supervisor EPA accredited Contractor/Supervisor (5 day course with annual 1 day refresher) or equivalent. Worker EPA accredited Worker (4day course with annual 1 day refresher) or equivalent. 8.2 Training for employees who perform Class II (removal of other ACM) Supervisor EPA accredited Contractor/Supervisor (5 day course with annual 1 day refresher) or equivalent. Worker One day (8 Hour) course covering topics outlined in the standard and shall include handson training. Annual refresher course is required but no specific requirements on duration. 8.3 Training for employees who perform Class III (maintenance or repair) Supervisor AHERA Operations or Maintenance 2 day course or equivalent. Worker AHERA Operations or Maintenance 2 day course or equivalent or if the person determines that the AHERA course does not adequately cover the training. Annual refresher training would require a minimum of 2 hours and include a hands-on component. One day (8 Hour) course covering topics outlined in the standard and shall include hands-on training Annual refresher course is required but no specific requirements on duration. 8.4 Training for employees who perform Class IV Supervisor AHREA Operations or Maintenance 2 day course or equivalent. Worker AHERA Operations or Maintenance 2 day course or equivalent or if the person determines that the AHERA course does not adequately cover the training. Annual refresher training would require a minimum of 2 hours and include a hands-on component. 13 University of Nevada Reno

14 8.5 All AHERA trained and/or certified employees will also be required to attend the appropriate AHERA annual refresher courses prior to the expiration date of their current training credentials. 8.6 All University of Nevada, Reno employees who perform Class I & II work are also required to receive the following training and/or certification(s): a. Annual asbestos and respirator medical examinations b. Respiratory Protection Training c. Annual respirator fit testing d. Asbestos management plan review 14 University of Nevada Reno

15 9.0 RECORDKEEPING - LABELING - WARNING SIGNS 9.1 All employee asbestos related training records will be maintained by FMS with a copy provided to the employee. 9.2 All building survey and asbestos abatement documents, drawings, records and reports will be maintained at the EH&S Department. All documents including the following will be maintained electronically: a. Asbestos Survey Request Project Coordinator and trade Shop b. Building drawings- identifies were samples were taken Asbestos Services c. Survey Data Form Asbestos Services d. Analysis Report - Third Party e. Asbestos Survey Report - Asbestos Services f. Clearance Report - Third Party and EHS (This needs to include the description of the scope of work completed) 9.3 EH&S Department personnel will identify those campus locations which require warning signs as per OSHA 29 CFR (j)(4)(i) a. All Boiler rooms will have Asbestos signs posted. 15 University of Nevada Reno

16 10.0 GLOSSARY ASBESTOS: includes chrysotile, amosite, crocidolite and tremolite asbestos, anthophyllite asbestos, actinolite asbestos and any of these materials that have been chemically treated and/or altered. ASBESTOS CONTAINING MATERIALS (ACM): all materials containing greater than 1% asbestos by weight. PRESUMED ASBESTOS CONTAINING MATERIAL (PACM): any material that is likely to contain asbestos which has not been positively identified through analysis by a National Institute for Standards and Technology (NIST) or EPA accredited laboratory. REGULATED ASBESTOS CONTAINING MATERIAL (RACM): those friable materials containing greater than 1% asbestos by weight; Category 1 non-friable material that has become friable; Category 1 non-friable material that will be subject to grinding, cutting, sanding or abrading; and Category 2 non-friable material that will have a high probability of being crumbled, pulverized or reduced to a powder by the demolition/renovation activity. ASBESTOS HAZARD EMERGENCY RESPONSE ACT (AHERA): a set of regulations governing all activities involved in the identification and abatement of asbestos containing materials. The regulations establish minimum personnel training requirements and accepted procedures to be used to control asbestos hazards. BULK MATERIAL SAMPLES: samples of ACM or PACM construction materials collected from areas of proposed construction or remodeling related activities. Normal sample process involves the extraction of a core sample of the material in question. CORE SAMPLES: a bulk material sample that penetrates to the full depth of the construction material being sampled. CATEGORY 1 NON-FRIABLE MATERIALS: asbestos containing packing, gaskets, resilient floor coverings and asphalt roofing products. CATEGORY 2 NON-FRIABLE MATERIALS: non-friable asbestos containing products that are not Category 1 materials, such as various transite cement products. CLASS I asbestos work: the removal of thermal system insulation (TSI) and sprayed-on or troweledon (surfacing) ACM or PACM. CLASS II asbestos work: the removal of ACM or PACM that is not TSI or surfacing ACM or PACM, including, but not limited to, floor tiles, ceiling tiles, exterior siding, ACM cement pipe, etc. CLASS III asbestos work: repair and maintenance operations that are likely to disturb ACM or PACM which removes less than 1 glove bag of material (measuring 60 by 60 inches or less). CLASS IV operations: custodial and housekeeping operations where minimal contact with ACM or PACM may occur. 16 University of Nevada Reno

17 Facilities Services Department (FSD) is the overarching name of the department includes everyone. Facilities Planning & Construction (FPC) (not sure if an acronym has been established) often referred to Facilities Services (reason for the confusion and inconsistency) includes the planning and construction, project management arm of the department. Facilities Maintenance Services (FMS) previously known as Operations & Maintenance includes the craft service, utility services, grounds and custodial services. FIBER: a structure that is at least 5 microns in length, with a length to width aspect ratio of 3:1. FRIABLE: those asbestos containing materials that will crumble, flake or otherwise release asbestos dust under hand pressure or which can release fibers when disturbed by mechanical means (drilling, sawing, sanding, etc.). Often these materials have degraded since their original installation, thus evolving from being non-friable to being friable. They can include spray-on acoustic materials, flaking plaster and damaged pipe insulation materials. NON-FRIABLE: solid asbestos containing construction materials that are in good condition and will not release asbestos fibers, including intact floor tiles, laboratory bench counter tops, transite panels, cement products, and encased pipe insulation. When undertaken and performed by properly qualified personnel, friable ACM can be rendered non-friable by appropriate encapsulation and enclosure methods. Non-friable materials can be made friable by mechanical means. Examples include: asphalt/cement roofing products, base flashing, asbestos cement, siding, vinyl asbestos floor tile, packing material, gaskets HOMOGENEOUS MATERIALS: Materials that are evenly mixed and similar in appearance and texture throughout and which is further supported by laboratory analytical documentation that establishes a markedly similar and consistent composition. NATIONAL EMISSION STANDARD for HAZARDOUS AIR POLLUTANTS (NESHAP): a set of regulations set forth by the federal Environmental Protection Agency (EPA) to control asbestos emissions from renovation and demolition activities in all commercial buildings. PERMISSIBLE EXPOSURE LIMIT (PEL): defined as 0.1 fibers/cubic centimeter (f/cc) of air. This translates into the permissible inhalation of a total of 1,000,000 fibers/day (100,000 f/m 3 x 10 M 3 of air inhaled/day). SURVEY: a written determination of construction material composition by a properly licensed inspector. A survey may include either the collection of an appropriate number of bulk samples or a review of existing building survey records and/or a physical inspection of the proposed work site. THERMAL SYSTEM INSULATION (TSI): any pipe or boiler insulation system, which may or may not contain ACM or PACM. 17 University of Nevada Reno

18 Craft - Asbestos Survey/ Asbestos Removal Decision Making Process Flow Chart Appendix A Wall Is the area to be worked a wall, ceiling or floor? (all pipe covering is suspect) Floor Is the wall, plaster or sheet rock going to be disturbed? Yes Are small number of holes going to be drilled? (anchors, nails, etc.) No Is the wall going to be cut or sanded? Yes Contact Asbestos Services No Yes No Not a known asbestos job Proceed with work Acoustic Tile Yes Ceiling Is the ceiling Acoustic tile, sprayed-on acoustic or other? Sprayed-on Acoustic No Is the acoustic going to be disturbed? No Has the surface been sealed in the past? (sealed by HazMat or previously painted) Other Is the ceiling Plaster or Sheet Rock going to be disturbed? Yes No Yes Contact Asbestos Services Yes Is the flooring Tile or carpet? Tile Yes Will the tile be broken up or made friable? Yes Is there tile under the carpet? No No Is there mastic under the carpet or tile? No Not a known asbestos job Proceed with work

19 Asbestos Survey Process Flow Chart for Work Order or Construction Project Work order generated from UNR employee Construction project req. generated from project coordinator Appendix B Work order sent to appropriate craft supervisor Plans and blueprints developed No Project folder on hold work order closed Is this project going to be completed? Yes Asbestos job completed by contractor or Asbestos Svs Complete asbestos survey request form with scope of work Asbestos Svs. review asbestos database No Asbestos Svs. Generate work order for asbestos Asbestos Svs. Sample for asbestos Is there asbestos data in the database? database? All documents are sent to EHS Yes Is there Asbestos? No No Sends samples to 3 rd party laboratory for analysis 19 University of Nevada Reno EHS updates & uploads documents into the database Yes Provide (old) copies to CRAFTS or project coordinator Not a known asbestos job Receive results within 24 hours

20 STANDARD WET METHOD FOR WALL PENETRATIONS APPENDIX C As a result of construction material asbestos surveys indicating that some buildings on campus have asbestos containing sheetrock joint compound and skim coats, a standardized wet method to control potential occupational asbestos exposures which may result from maintenance activities involving minor penetrations of walls is required. Possible exposures may result from employees making penetrations through asbestos contaminated wall surfaces for the purposes of installing screws and/or wall anchors. Construction material sampling of all wall surfaces prior to release of work is ill advised due to the nature and extent of damage to wall surfaces due to the sampling protocol. Damage due to sampling will exceed the potential damage of the screw and/or anchor installation itself. Therefore, a safe method of achieving necessary wall penetrations without causing unwanted employee exposures is required. The method should incorporate work procedures that control fiber releases. One example would be to use a damp sponge or wet paper towel when making the wall penetration. The damp sponge or wet paper towel should be placed directly on the wall surface at the point of penetration, and the penetration made through both the sponge or paper towel and the wall. The penetration tool (drill bit, screw driver, knife, etc.) should then be withdrawn through the sponge or paper towel while hand pressure is applied to the tool through the sponge or paper towel, thus wiping off possible asbestos contamination following the penetration. Following extraction of the penetration tool the sponge or paper towel should be used to wipe the wall surface of any remaining debris. The sponge or paper towel should then be placed into a small plastic bag and sealed. Of the two methods, damp sponge or wet paper towel, the wet paper towel is the preferred method. It eliminates the need to place the contaminated sponge into the water container and thus contaminating the water with asbestos fibers. The sealed bag and its contents should be delivered to Asbestos Services at the earliest convenient occasion for disposal. In the event the above procedure cannot be accomplished, or there are any questions regarding this procedure, please contact the Asbestos Services. 20 University of Nevada Reno

21 21 University of Nevada Reno APPENDIX D NEA FOR A STANDARD METHOD FOR SPRAYED ACOUSTIC CEILING ANCHOR SCREW INSTALLATION A negative exposure assessment (NEA) has been completed for the identified procedure. In order for the NEA to apply, the approved procedure must be precisely followed. This approved method was established and tested on asbestos containing spayed acoustic ceiling. The procedure involved the installation of ceiling mounted smoke alarms. A total of three air samples were collected; one during the installation of each of three smoke alarms. Each alarm installation involved drilling holes for and installing three anchor screws to mount the smoke alarm base plate. Equipment used: Platform mounted portable containment structure with adjustable height feature HEPA vacuum Personal Protective Equipment (PPE) Respirator Tyvek suit Wet paper toweling Step ladder Powered and hand tools Drill & bit Screw driver Hammer Electrical extension cord(s) Selection of anchor screws with plastic sleeves Plastic trash bags Procedure: 1. Set up portable containment structure tight to the work surface and centered on the area to be drilled. Shims may be needed under the wheels to seal the structure to the ceiling surface. Lock wheels in place to avoid any movement of the structure while work is in progress. 2. Place the step ladder, tools and wet paper towels inside the containment structure 3. Attach the HEPA vacuum to the provided opening in the containment structure. Turn on the HEPA vacuum and leave it running for the duration of the work. 4. Don PPE 5. Enter containment structure and seal the zippered opening. 6. Using the palm and fingers of one hand, puncture a sheet of wet paper toweling with a drill bit that is properly sized for the anchor screw plastic sleeve. 7. Place the tip of the exposed drill bit against the point to be drilled. 8. Using one hand, push the wet paper towel against the ceiling material and form a seal around the drill bit. 9. Drill a hole through the ceiling surface while continuing to hold the wet paper towel against the ceiling surface. 10. When the hole is completely drilled, carefully lower the drill and paper toweling and fold towel into itself, sealing the acoustic debris into the towel.

22 11. Place the used paper towel into a plastic trash bag and close the bag. 12. Repeat the process until the desired number of holes is drilled at this location. 13. Use a hammer to tap the anchor screw plastic sleeves into position in the drilled holes. 14. Mount object by screwing anchor screws into the installed plastic sleeves. 15. When complete, use additional wet paper towels to wipe all interior surfaces clean of loose ceiling debris. Place used towels into the trash bag and close it. 16. Open containment access and exit containment. 17. If necessary, relocate containment structure to the next location and repeat the procedure for all remaining anchor screw installation locations. 18. When complete, properly seal and tie plastic bag containing the debris and used towels. 19. Place sealed bag into second plastic bag, seal, tie and properly label the bag as asbestos containing debris for disposal. 20. Contact EH&S to dispose of the ACM debris. Results: A total of three samples were collected, one each at three different locations in the same hallway area. The resulting airborne concentrations are listed below: Sample # Location Fiber Concentration NEA-1 SFB SE Hall f/cc NEA-3 SFB E Exit f/cc NEA-4 SFB NE Hall f/cc Average Concentration = f/cc Standard Deviation = f/cc 99% Confidence Interval = f/cc Discussion: The NEA results indicate that installing anchor screws in sprayed acoustic ACM ceilings can be done safely when using proper techniques. Occupational exposure to asbestos was well within permissible exposure limits for this procedure. It is advised that personnel installing anchor screws using this procedure continue to wear all PPE listed in the procedure. This practice will serve to maintain any resulting asbestos exposures at the lowest possible level. 22 University of Nevada Reno

23 APPENDIX E SUMMARY OF INSTITUTIONAL/AGENCY RESPONSIBILITIES I. UNIVERSITY OF NEVADA, RENO The University will maintain and update as necessary an Asbestos Management Plan that will serve as the official policy regarding asbestos issues. The Plan will meet regulatory requirements and serve as guidance to University of Nevada, Reno employees. University responsibilities will be generally divided between two departments: A. Facilities Services Department/Facilities Maintenance Services Will notify Asbestos Services of planned work potentially involving asbestos, initiate work orders, arrange and manage asbestos abatement contracts and manage Facilities Services workers who perform minor operations and maintenance (O&M) tasks. B. Environmental Health and Safety (EH&S) Will attend construction meetings prior to remodeling or construction work commencement, perform requested air monitoring, interpret and communicate analytical data, interpret regulatory standards, provide technical support to Facilities Services Department crews, and maintain asbestos related training and sampling records. II. CONSTRUCTION/REMODELING CONTRACTORS Contractors will obtain all necessary bulk material surveys prior to commencement of contract work activities. Required bulk construction material asbestos surveys may either be performed by Facilities Maintenance Asbestos Services, EH&S Department personnel, or contracted out to properly licensed consulting organizations. In the event that asbestos material surveys are contacted out, copies of final survey analytical reports should also be filed with the EH&S Department. III. ASBESTOS ABATEMENT CONTRACTORS Only current Nevada Asbestos licensed and qualified personnel will be permitted to perform abatement-related work. Abatement contractors will perform all abatement-related activities in compliance with federal state and local regulations. Copies of air sampling records required by federal, state or local regulations, and the analytical results, will be submitted to the EH&S Department and Project Coordinator at the completion of any abatement project. IV. STATE PUBLIC WORKS BOARD (BOARD) N/A The role of the Board in University asbestos related issues is limited to only those construction/remodeling contracts over which the Board maintains jurisdiction. The Board shall be responsible for assuring contractor compliance with all pertinent asbestos- related regulatory 23 University of Nevada Reno

24 requirements and for obtaining all required asbestos bulk material surveys. The Board should provide copies of all final asbestos bulk material survey analytical reports to the EH&S Department. V. WASHOE COUNTY DISTRICT HEALTH DEPARTMENT AIR QUALITY MANAGEMENT DIVISION (DIVISION) The Division has been delegated the authority for the enforcement of the Asbestos National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations (40 CFR 61, Subpart M). The Division has the authority to collect all duly established filing fees related to required asbestos survey report filings for regulated construction/remodeling projects. VI. NEVADA INDUSTRIAL RELATIONS DIVISION OCCUPATIONAL SAFETY AND HEALTH ENFORCEMENT SECTION OSHA has the responsibility for the enforcement of all Federal Occupational Health and Safety standards regarding employee occupational work activities, as they pertain to work with asbestos containing materials (29 CFR and 29 CFR ). 24 University of Nevada Reno

25 APPENDIX F 1. Asbestos Survey Request Completed by Project Coordinator or Trade Shop i. Building Name and Number ii. Proper floor iii. Room number 2. Building drawings- identifies were samples were taken Completed by Asbestos Services i. Use the most current/up-to-date floor plan ii. Building Name and Number iii. Proper floor iv. Room number v. Hallway numbered vi. All Sample locations vii. Labeled clearly viii. Accurately 3. Survey Data Form Completed by Asbestos Services i. Locations sampled matches the floor plan sampling location ii. Sampling nomenclature the same as the floor plan sampling nomenclature 4. Analysis Report - Completed by Third Party i. Results of the sampling 4. Asbestos Survey Report - Completed by Asbestos Services 5. Clearance Report - Completed by Third Party and EHS i. Description of Asbestos Services completed ii. What portion of the wall/ceiling/flooring/etc. was cleared of asbestos? 25 University of Nevada Reno

26 APPENDIX G For a quick reference to the OSHA standard's provisions by work class, please see the following table. Quick Reference of Provisions by Work Class* Class I Class II Class III Class IV Definition Removal of thermal system insulation (TSI) and surfacing material (SM) containing > 1% asbestos Removal of material other than TSI or SM containing > 1% asbestos Maintenance and repair operations disturbing material containing > 1% asbestos Housekeeping and custodial cleanup of dust, waste, and debris from Class I, II, or III activities Regulated Areas Required (warning signs mandatory) Required (warning signs mandatory) Required (warning signs mandatory) Required (warning signs mandatory) competent person Must be onsite Must inspect each work shift Must attend supervisory training Must be onsite Must inspect often Must attend supervisory training Must be onsite Must inspect often Must attend operational and maintenance training Must be onsite Must inspect often Must attend operational and maintenance training Air Monitoring Initial if no negative exposure assessment (NEA) Daily unless positive pressure mode respirator is used Additional if conditions change Note: Terminate if < permissible exposure limits (PELs) Initial if no NEA Daily unless positive pressure mode respirator is used Additional if conditions change Note: Terminate if < PELs Initial if no NEA Periodic to accurately predict if > PELs Additional if conditions change Note: Terminate if < PELs Initial if no NEA Periodic to accurately predict if > PELs Additional if conditions change Note: Terminate if < PELs Medical > Surveillance Required if Wearing negative- pressure respirator, or > 30 days of work/year Required if Wearing negative-pressure respirator, or > 30 days of work/year Required if Wearing negative-pressure respirator, or > 30 days of work/year Required if Wearing negative-pressure respirator, or > PEL for more than 30 days/year Respirators Mandatory for all Class I jobs Mandatory if Non-intact removal, or No NEA, or > PEL, or Dry removal (except for roofing), or In emergencies Mandatory if No NEA, or TSI or SM disturbed, or > PEL, or Dry removal (except for roofing), or In emergencies Mandatory In regulated area where required, or If > PEL, or In emergencies Protective Clothing and Equipment Required for all jobs if > 25 linear or 10 square feet of TSI or SM removal, or No NEA, or > PEL Required for all jobs if No NEA, or > PEL Required for all jobs if No NEA, or > PEL Required for all jobs if No NEA, or > PEL Training Equivalent to EPA Model Accreditation Plan (MAP) asbestos abatement workers course Equivalent to MAP course if critical barriers required; otherwise, train on specific work practices and engineering controls that must be used Equivalent to AHERA course for maintenance and custodial staff Equivalent to AHERA course for maintenance and custodial staff Employee and Equipment Decontamination Required if > 25 linear or 10 square feet TSI or SM removal Full decon unit Equipment room, shower, and clean room in series connected to the regulated area; other decon facility arrangements are acceptable if the specified series arrangement is not feasible (see 29 CFR Part , Subpart Z) Lunch areas Note: Must follow detailed decontamination procedures (see 29 CFR Part (j)(1)(iii) If < 25 linear or 10 square feet TSI or SM removal Equipment room/area required Impermeable drop cloths required Area must accommodate cleanup Must decontaminate all personal protective equipment (PPE) Must enter regulated area through equipment room/decon area No smoking in work area If > PEL or no NEA Equipment room/area required Impermeable drop cloths required Area must accommodate cleanup Must clean work clothes with HEPA vacuum before removal Must Decontaminate all PPE Must enter regulated area through equipment room/decon area Must enter regulated area through equipment room/decon area No smoking in work area > PEL or no NEA Equipment room/area required Impermeable drop cloths required Area must accommodate cleanup Must clean work clothes with HEPA vacuum before removal Must Decontaminate all PPE Must enter regulated area through equipment room/decon area Must enter regulated area through equipment room/decon area NEA must vacuum No smoking in work area If cleaning up asbestos containing surfacing material or thermal system insulation debris from a Class I or III activity after the activity is finished Equipment room/area required Drop cloths required Area must accommodate cleanup Must clean work clothes with HEPA vacuum before removal Must decontaminate all PPE Must enter regulated area through equipment room/decon area No smoking in work area Note: If cleaning up dust, waste, and debris while a Class I, II, or III activity is still in progress, the requirements of that activity apply. Generally Required Work Practices and Wet methods HEPA vacuum Wet methods HEPA vacuum Wet methods HEPA vacuum Wet methods HEPA vacuum 26 University of Nevada Reno

27 Engineering Controls Prompt cleanup/disposal Prompt cleanup/disposal Prompt cleanup/disposal Prompt cleanup/disposal Required Work Practices and Engineering Controls to Comply with PELs HEPA local exhaust Enclosure or isolation Directed ventilation Other work practices Respirators HEPA local exhaust Enclosure Directed ventilation Other work practices Respirators HEPA local exhaust Enclosure Directed ventilation Other work practices Respirators HEPA local exhaust Enclosure Directed ventilation Other work practices Respirators Prohibited Work Practices and Administrative Controls High-speed abrasive disc saws without HEPA Compressed air without capture device Dry sweeping/shoveling High-speed abrasive disc saws without HEPA Compressed air without capture device Dry sweeping/shoveling High-speed abrasive disc saws without HEPA Compressed air without capture device Dry sweeping/shoveling High-speed abrasive disc saws without HEPA Compressed air without capture device Employee rotation Controls and Work Practices Critical barriers/isolation methods required if > 25 linear or 10 square feet of TSI or SM removal < 25 linear or 10 square feet of TSI or SM removal only if no NEA or there are adjacent workers HVAC isolation required Impermeable dropcloths required Directed ventilation required if no NEA or > a PEL Objects must be covered One or more of the following controls must be used: Negative-pressure enclosure Glove bag Negative-pressure glove bag Negative pressure glove box Water spray process Mini enclosure For indoor work only Critical barriers/isolation methods required if no NEA likely > a PEL non-intact removal Impermeable dropcloths required For removal of vinyl and asphalt flooring materials No sanding HEPA vacuum Wet methods No dry sweeping Any mechanical chipping must be done in negative-pressure enclosure Intact removal if possible Dry heat removal allowed Assume contains asbestos without an analysis For removal of roofing materials Intact removal if possible Wet methods if feasible Cutting machine misting HEPA-vacuum debris Lower to ground as soon as possible but no later than day's end Control dust of un-bagged material Prevent intake of airborne asbestos< through roof vent system Class II For removal of cement-like siding, shingles, or transite panels Intact removal if possible Wet Methods Lower to ground via dust-tight chute, crane, or hoist immediately or place in an impervious waste bag or wrap in plastic sheeting and lower to ground by day's end Cut nail heads For removal of gaskets Use glove bags if not intact Wet removal Prompt disposal Wet scraping Additional requirements Wet methods Intact removal if possible Cutting, abrading, or breaking prohibited Critical barriers required If no NEA > Pel via monitoring Impermeable dropcloths required Local HEPA exhaust required Note: Enclosure or isolation of operation required if TSI or SM is drilled, cut, abraded, sanded, sawed, or chipped See Generally Required Work Practices and Engineering Controls in this table *This is an overview of the standards' requirements. You must consult the standard for the specifics of the requirements for each class. 27 University of Nevada Reno

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