State University of New York at Geneseo

Asbestos Operations and Management Plan

This Operations and Maintenance Plan (O & M Plan) was developed to identify those procedures and protocols implemented in buildings of the State University of New York at Geneseo (SUNY Geneseo) to ensure airborne levels of asbestos fibers remain below regulatory thresholds. This goal is accomplished through the following:

1. Prohibition of disturbing suspect materials (EPA List of Suspect Materials is included in Appendix A)
2. Providing information to all members of the campus community on suspect materials
3. Sampling and analytical testing of building materials prior to any planned disturbances
4. Continual observation of existing asbestos containing materials (ACM) and presumed asbestos containing materials (PACM)
5. Maintaining a team of NYS Certified asbestos personnel on campus
6. Assuring all abatement activities are conducted in accordance with applicable codes and regulations.
7. Timely repair, abatement or/and or clean-up of any disturbed asbestos containing materials

In the 1994 amendments to its Asbestos Standard, the Occupational Safety and Health Administration (OSHA) determined that all suspect building materials in buildings constructed prior to 1980 are" presumed to contain asbestos" until analytical testing, following specified protocols, proves otherwise. For this reason, all suspect building materials (EPA List of Suspect Building Materials is included in Appendix A), in all campus buildings, except South Hall and Saratoga Terrace (both built after 1980), must be managed as through they contain asbestos. Management of these materials must be in accordance with this O & M Plan.

To "refute the presumption" that all pre-1980 building materials contain asbestos, samples must be collected and analyzed following specific protocols. EPA requires the following number of random samples of each homogeneous area be collected:

If all samples from a homogeneous area are "Non-Detect" for asbestos, the homogeneous area will be considered non-asbestos containing. If some number of the samples indicate the presence of asbestos, the Inspector may revisit the determination of homogeneous area, and additional samples may be collected, or the entire homogeneous area may be considered confirmed ACM.

Samples may only be collected by a NYS Certified Asbestos Inspector.

Care must be taken during sample collection to ensure sampling tools are cleaned between collection of each sample. Cross-contamination may result in false positive results. Upon collection samples must be placed in clean plastic bags or other containers and immediately sealed.

Labeled and sealed samples are to be delivered, with completed Asbestos Sample Collection Log and WO to the EHS Department for shipment to the contracted analytical lab.

Bulk samples of friable PACM are analyzed by Polarized Light Microscopy (PLM). Bulk samples of non-friable Organically Bound PACM (floor tile, base cover, mastics, roofing materials, patches, etc.) will be analyzed "to positive" following this protocol:

Refuting the presumption of asbestos in building materials for SUCF, OGS and DASNY projects will be the responsibility of the involved agency. SUNY Geneseo will collect samples of PACM for such projects only under very limited circumstances. However, no representations of homogeneous area will be provided by campus personnel to these agencies.

As asbestos fibers are invisible and have no odor, air sampling is the only objective method for determining the level of air borne asbestos fibers. Although required by Code Rule 56 for abatement activities, air monitoring is not recommended by EPA as a typical O&M activity.

Air monitoring is conducted by collecting a known volume of air through a filter, then subjecting that filter to a recognized analytical technique. Phase Contrast Microscopy (PCM) is the standard analytical procedure for air sample fiber level determinations. However, PCM measures all fibers, not just asbestos fibers, and can result in false high fiber levels. Should PCM air monitoring results be above the Code Rule 56 clearance level of 0.01 f/cc, Transmission Electron Microscopy (TEM) analysis can be conducted on the filter. TEM analysis will provide a true level of asbestos fibers present.

It is always preferred that the abatement activity occur in areas and at times when the building or immediate vicinity will not be occupied. However, in situations of accidental release occurrences and when contracted abatement must occur in occupied buildings, air monitoring can provide a level of comfort for those campus employees working in the areas. Air monitoring will be conducted, as required by Code Rule 56, under these circumstances. Results will be compared to the OSHA PEL for asbestos of 0.1 f/cc as an 8 hour TWA. Additional air samples may be collected as determined by the EHS Department.

An Asbestos Notification is posted in entrances to every SUNY Geneseo campus building. This notification includes an explanation of PACM and what building materials are assumed to contain asbestos. It also includes a specific prohibition on disturbing any PACM or ACM. These signs serve as notifications of locations of PACM to building occupants, the public and contractors. Other campus areas, such as mechanical rooms, may have additional notifications posted.

All campus employees are provided additional information on asbestos in building materials including potential health hazards during awareness training provided by the EHS Department.

The Facilities Planning Office (FPO) provides additional orientation to outside contractors. FPO will also coordinate the posting of building notifications for contracted SUCF, DASNY and campus managed projects involving abatement.

It is the responsibility of all campus personnel, including employees, students, and contractors to report any possible disturbances of PACM to the EHS Department.

Newly installed insulation and fire-proofing materials should be specifically labeled as "Non-Asbestos Containing". Materials that are confirmed to contain asbestos are typically removed shortly after analytical testing. However, if a material is confirmed to contain asbestos and is not scheduled for removal, it should be listed as such on the Asbestos Sample Results Spreadsheet (maintained electronically by EHS) and, if appropriate, specifically labeled as "ACM", "ACBM" or ‘Asbestos Containing". If a material is identified as non-asbestos containing through procedures required by regulation, the material is to be identified as "Non-Asbestos Containing" in the spreadsheet, and if appropriate, specifically labeled or noted on the building notification, as such.

Even with continual observation and maintenance of PACMs and ACMs, accidental releases of asbestos fibers will and do occur. Roof leaks, dropped tools, and other accidents can disturb these materials.

When an accident occurs that results in the disturbance of ACM or PACM, the immediate area is to be evacuated and locked or otherwise cordoned off to a distance of 25 feet from the disturbance and any building ventilation terminated. Additional response actions will depend on the amount of disturbed material and the area in which the incident occurred. Typically, these actions will not include full abatement, but will include air monitoring and follow appropriate Code Rule 56 requirements. As a general rule:

To facilitate building systems repair and maintenance in buildings with PACM and ACM, SUNY Geneseo maintains a team of NYS Certified Asbestos Supervisors, Workers and other certified positions as deemed necessary. Members of this team receive annual physicals and respirator training as required by Code Rule 56 and OSHA regulations. This team is restricted in its efforts to projects classified as "Minor" by Code Rule 56 and to release response actions.

Team members are responsible to ensure they follow all applicable Code Rule 56 requirements. Non-adherence with applicable requirement constituents reason for removal from the Response Team and possible DOL action.

These requirements include, but are not limited to:

• Glove bags and tents must be used for all pipe insulation removals.
• All disturbed PACM or ACM must be wetted.
• Personnel air monitoring must be conducted on every assignment.
• Disposal of abated asbestos waste must follow NYS DEC requirements.
• Semi-annual respirator fit-tests.

Questions on specific operational requirements of Code Rule 56 and other regulatory requirements are to be forwarded to the EHS Department or clarified during NYSDOH certified training.

When conditions of deteriorated ACM or PACM or materials with potential for damage are brought to the attention of the EHS Department, an assessment of the hazard posed to campus personnel will be made. This assessment may be conducted by EHS or contracted personnel.

The assessment may use the EPA AHERA Hazard Assessment Ranking or other recognized assessment method.

The results of the Hazard Ranking will be provided to the AVP for Facilities and Planning for further action.

The EPA NESHAP regulations require manifesting of all friable asbestos. To ensure compliance with this requirement, all shipments of friable asbestos waste require a manifest which must be signed by the EHS Department representative or a designee. Non-friable asbestos may be shipped on a bill-of-lading or other shipping document. After receipt by the landfill, a receipted copy of the shipping record or manifest must be returned to the EHS Department.

EPA Sample List of Suspect Asbestos-containing Materials

Cement Pipes

Cement Wallboard

Cement Siding

Asphalt Floor Tile

Vinyl Floor Tile

Flooring Backing

Construction Mastics (floor tile, carpet, ceiling tile, etc.)

Packing Materials (for wall/floor penetrations)

High Temperature Gaskets

Laboratory Hoods/Table Tops

Laboratory Gloves

Fire Blankets

Fire Curtains

Elevator Equipment Panels

Elevator Brake Shoes

HVAC Duct Insulation

Boiler Insulation

Breeching Insulation

Ductwork Flexible Fabric Connections

Cooling Towers

Pipe Insulation

Heating and Electrical Ducts

Electrical Panel Partitions

Electrical Cloth

Electrical Wiring Insulation

Chalkboards

Roofing Shingles

Roofing Felt

Base Flashing

Thermal Paper Products

Fire Doors

Caulking/Putties

Adhesives

Wallboard

Joint Compounds

Vinyl Wall Coverings

Spackling Compounds

Acoustical Plaster

Decorative Plaster

Textured Paints/Coatings

Ceiling Tiles and Lay-in Panels

Spray-Applied insulation

Blown-in Insulation

Fireproofing materials

Taping compounds (thermal)

EPA Notes that: "This list does not include every product/material that may contain asbestos. It is intended as a general guide to show which types of materials may contain asbestos.

Common Campus Activities with potential for disturbing ACM or PACM

Part of the planning process for installation of new carpeting is the determination if any asbestos is present in the existing flooring. Existing carpet may be glued to asbestos floor tile or if no carpet is currently in place, the floor tiles over which the new carpet is to be installed may contain asbestos (VAT). Even in situation where the tile may not be asbestos containing, the mastic used to glue the tiles to the floor or the base board to the wall may be asbestos containing. Three options exist for installing carpet over VAT or over carpet glued to VAT:

1. Remove the existing VAT and/or mastic
2. Use installation methods developed specifically for installing carpet in these situations
3. Leave existing carpet in place.

Campus departments or entities wanting to install new carpet must assess these options prior to purchase and installation.

When it is necessary to conduct work above a dropped ceiling (tile or plaster) over which ACM or PACM such as fire-proofing or pipe insulation is installed, the following procedure must be followed by the Campus Response Team:

1. Secure area
2. Place plastic drop cloth under area to be opened. Use ladder that can be easily cleaned by wiping down (fiberglass) or plastic covered scaffolding, as needed.
3. Remove a single tile or the smallest amount of plaster possible to gain head and arm access to area above ceiling.
4. Use HEPA vacuum to clean removed tile and place on plastic.
5. Use HEPA vacuum to clean next row of tiles or area of plaster to be removed.
6. Continue Step 5 until sufficient area is opened.
7. If work will cause vibration or other possible disturbance of ACM or PACM, install plastic sheeting under the material.

With few exceptions, all abatement activities on the SUNY Geneseo campus are to be conducted during non-working hours. Because of extended building use hours during regular semesters, non-working hours for other than residential buildings is typically Midnight through 7 AM. During summers, these hours are typically from 7 PM to 7 AM. Building specific exceptions to these guideline times may be granted. It is also noted that custodial and security personnel are in academic buildings during these hours and areas where abatement activities are being conducted must be secured to prevent inadvertent entrance by these and other campus personnel.

Abatement should be avoided whenever possible in occupied areas of residential buildings during academic semesters. Abatement activities to be conducted in mechanical rooms or other non-occupied areas of residential buildings may be scheduled during regular semesters, if absolutely necessary. However, semester breaks will always be the first option.

As automobile break linings are constructed of materials containing asbestos, work on such brakes creates the potential for airborne asbestos fibers. SUNY Geneseo employees working on brakes must attend asbestos awareness training provided by EHS. OSHA procedures for minimizing asbestos fiber releases while working on brakes must be adhered to. These procedures are specified in 29 CFR 1910.1001 Appendix F and are included as Appendix C to this document.

A Variance for management of loose, unadhered floor tile has been secured through the New York State Department of Labor. This variance allows members of the Campus Certified Asbestos Team to remove less than 160 square feet of loose, unadhered floor tile from campus buildings. The variance must be posted during floor tile removal activities.

This mandatory appendix specifies engineering controls and work practices that must be implemented by the employer during automotive brake and clutch inspection, disassembly, repair, and assembly operations.

Proper use of these engineering controls and work practices by trained employees will reduce employees' asbestos exposure below the permissible exposure level during clutch and brake inspection, disassembly, repair, and assembly operations.

The employer shall institute engineering controls and work practices using either the method set forth in paragraph [A] or paragraph [B] of this appendix, or any other method which the employer can demonstrate to be equivalent in terms of reducing employee exposure to asbestos as defined and which meets the requirements described in paragraph [C] of this appendix, for those facilities in which no more than 5 pairs of brakes or 5 clutches are inspected, disassembled, reassembled and/or repaired per week, the method set forth in paragraph [D] of this appendix may be used:

[A] Negative Pressure Enclosure/HEPA Vacuum System Method (for facilities where more than 5 pairs of brakes or 5 clutches are worked on per week)

[B] Low Pressure/Wet Cleaning Method (for facilities where more than 5 pairs of brakes or 5 clutches are worked on per week)

[C] Equivalent Methods (for facilities where more than 5 pairs of brakes or 5 clutches are worked on per week)

[D] Wet Method (for facilities where no more than 5 pairs of brakes or 5 clutches are worked on per week)

Sample identification:

Example:

40N - 419 - WLPL - East:

designates a wall plaster sample from the east wall of Room 412 in Onondaga North.

______________ - _____________ - __________________ - ________________

______________ - _____________ - __________________ - ________________

______________ - _____________ - __________________ - ________________

______________ - _____________ - __________________ - ________________

______________ - _____________ - __________________ - ________________

______________ - _____________ - __________________ - ________________

______________ - _____________ - __________________ - ________________

All samples represent a limited amount of PACM or ACM that must be identified by the sampler.

Examples:

The samples identified on this log represent the following (must include an estimated number of square or linear feet): _____________________________________________

________________________________________________________________________________________________________________________________________________________________________________________________________________________

Project Log:

1. Building _________________________ Area or Room #: _________________

4. Method and/or Variances Used (glove bag, tent, etc.): __________________________

________________________________________________________________________

5. Number of Waste Bags generated ________________and moved to locked storage.

6. Persons on Project

Name (Circle Supervisor) SS#

________________________________________ ________________________

________________________________________ ________________________

________________________________________ ________________________

________________________________________ ________________________

7. Tools and Equipment Used (specify quantity)

_____ HEPA Vacuum _____ Signs _____ Plastic Sheeting

_____ 6 ml Disposable Bags _____ Glove Bags _____ Duct Tape

_____ Spray Adhesive _____ Staple Gun _____ Scrapers

_____ Ladder/Scaffold _____ Rags/Wipes _____ Wire Brush

_____ Amended Water _____ Shovel _____ Squeegee

_____ Encapsulating Material Other ____________________________________

Notifications and Signage (how posted): _______________________________________

Personal Sampling (REQUIRED on ALL Activities, except sample collection)

Example:

Ron Morsch 7/2/02 90 minutes 2.2 L/min 2.1 L/min 193.5 Liters

Name/Date Run Time Flow Rate(start) Flow Rate (finish) Total Flow

_________________ _____ min. ______L/min _____ L/min ________Liters

_________________ _____ min. ______L/min _____ L/min ________Liters

Other project information: __________________________________________________

________________________________________________________________________