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Environmental Management (S-7)

 

Environmental Management (S-7)

"MORE THAN OUR CODE . . . IT'S OUR CORPS"

The Environmental Management System of MCAS Miramar
Asbestos Abatement/Management
Program Manager

858-577-6053

The Asbestos Management and Abatement applies to the demolition, removal, and disposal of regulated asbestos containing material (RACM) and protecting the public by minimizing the release of asbestos fibers during activities involving the processing, handling, and disposal of sbestos-containing material. There are specific work practices to be followed during demolitions and renovations of all structures, installations, and buildings. In addition, the regulations require the owner of the building and/or the contractor to notify applicable state and local agencies and/or EPA Regional Offices before all demolitions, or before renovations of buildings that contain a certain threshold amount of asbestos.
Before undertaking demolition or renovations, Marine Corps installations and activities must follow all applicable Federal, state, or local requirements. Note that some state requirements are more stringent than the Federal regulations (e.g., Asbestos is a HW in California and certain other states, but only a solid  waste under Federal regulations).
PROGRAMS, PLANS, RESOURCES AND RESPONSIBILITES

NAVMC OSH Directive 5100.8 and MCAS Miramar Station Orders 5100.8 & 5100.3A identify the necessity for a qualified and certified individual (Asbestos Program Manager) to perform duties on the station related to activities that may disturb asbestos containing materials and the necessary actions required to safely address these materials. The person selected to perform this duty is required to have extensive experience in asbestos related issues and hold specific certifications recognized by the U.S. DOD and the U.S. EPA (i.e. Supervisor to enter containment areas to inspect the correctness of abatement activities, Inspector to take samples of suspect asbestos-containing materials, Management Planner to prepare and maintain the MCAS Miramar Asbestos Management plan, Project Designer to design appropriate response actions regarding asbestos disturbance and review of contractor asbestos work plans). As per NAVMC Directive 5100.8, the responsibilities of the Asbestos Program Manager are as follows:

  • Have cognizance for all asbestos related activities of installation or unit asbestos control program.
  • Provide coordination in development of installation or unit asbestos control program.
  • Provide asbestos awareness training for personnel who do not ordinarily work with asbestos in the performance of their duties.
  • Coordinate AHERA training for personnel directly involved with asbestos removal or containment projects.
  • Verify and annotate MARCOR (NAVMC) 11406, Checklist for Asbestos Removal Operations, for all asbestos related activities on the installation or unit.
  • Review MARCOR (NAVMC) 11406 to ensure the form is appropriately completed and reflects the Supervisor signature certifying project is ready to start, then certifying Part 3, Step 1 with APM signature.
  • Maintain records of all required training as per 40 CFR 763 (AHERA - Asbestos Hazard Emergency Response Act).
  • Coordinate laboratory analysis of asbestos samples.
  • Record the results of asbestos surveys for all facilities in the installation or unit and hold these records indefinitely.
  • Require environmental monitoring and verify compliance with the requirements for asbestos operations.
  • Notify individuals of asbestos exposure.
  • Coordinate an asbestos medical surveillance program in accordance with Chapter 11.
  • Provide technical support and guidance for asbestos hazard operations.
  • Ensure all required equipment and tools are provided for asbestos operations.
  • Ensure proper containment is used to protect workers and the general public from asbestos hazards that may be generated.
  • Ensure abatement containment areas are visually free of any debris or residual insulations and other types of non-fibrous insulation (e.g., cork, rubber, fiberglass, etc.) after abatement operations are completed. Review MARCOR (NAVMC) 11406 to ensure the form is appropriately completed and reflects the Supervisor signature certifying asbestos abatement has successfully been completed and the containment area has passed visual inspection, then certifying Part 3, Step 2 with APM signature.
  • Ensure that a qualified Industrial Hygienist or authorized workplace air monitor determines the asbestos abatement containment area is free of asbestos fibers prior to removal of containment. Review MARCOR (NAVMC) 11406 to ensure the form is appropriately completed and reflects the Industrial Hygienist/Air Monitor signature certifying project has successfully passed the federal air clearance standard of 0.01 f/cc, then certifying Part 3, Step 3 with APM signature.
  • Notify shop upon receipt of completed MARCOR (NAVMC) 11406 that the area is *asbestos free and the containment has been disestablished. APM to ensure MARCOR (NAVMC) 11406 has been completed and date and sign when shop was notified. The MARCOR (NAVMC) 11406 checklists are to be permanently filed with the APM.
  • Asbestos Free statement is in regards to actual abated asbestos-containing material. Area where subject material was abated may still contain asbestos-containing materials and should be identified and addressed prior to any future disturbance.
  • Require contracting officials to receive health and safety plans from contractors before any work operations begin to ensure Marine Corp personnel and property will not be endangered by contractor operations.
  • Review all proposed facility sustainment, restoration, and modernization plans for potential asbestos disturbance activities.
TRAINING AND COMMUNICATION
The APM (Asbestos Program Manager) must be knowledgeable and experienced in all asbestos disciplines, and current in all AHERA asbestos certifications (i.e. Contractor/Supervisor, Inspector, Management Planner, and Project Designer). Also the APM should be experienced in air monitoring and analysis protocols (i.e. NIOSH 582 and 7400/7402 Methods) set forth by NIOSH (National Institute of Occupational Safety and Health). Additionally, it is recommended that the APM be experienced in instructional training and other environmental compliance issues to provide installation or unit personnel with the appropriate required regulatory training, oversee facility maintenance personnel, and ensure facility contractors maintain federal regulatory compliance.
PRACTICE-ASPECT-IMPACT-RISK

PRACTICES

  1. Facility Demolition
    1. An activity is defined as a facility demolition whenever there is removal of any load-bearing structure during the wrecking, removal or tearing down of a facility. Additionally, burning a facility is considered a demolition
  2. Facility Renovation
    1. Renovation is any activity that does not meet the definition of demolition that involves the stripping or removal of asbestos from a facility.
ASPECTS
  1. Air Quality - To prevent exposure to humans, any demolition or renovation must be performed by C-22 Asbestos Abatement licensed contractors. During asbestos removal, techniques are enacted to ensure that asbestos does not become airborne outside of the construction area.
  2. Waste - Local landfills are able to accept non-friable wastes (waste that cannot be crumbled, pulverized, or reduced to powder by hand pressure). 
  3. Hazardous Waste - Friable asbestos wastes are considered to be hazardous waste. Local landfills such as Miramar Landfill are unable to accept any friable asbestos waste that contains greater than 1% asbestos. 

IMPACTS & RISKS

  1. If asbestos is not properly handled while removed, it can become airborne and create a safety and environmental hazard for those people working in the vicinity.
  2. Not meeting asbestos disposal requirements could potentially put the Station at risk for receiving a notice of violation and/or a monetary fine.
OBJECTIVES-TARGETS-ACTIONS TO IMPROVE PERFORMANCE
AUDIT AND EVALUATION OF COMPLIANCE