Asbestos Management Plan Attachment A

Asbestos Management Plan Attachment A

Asbestos Management Plan



Asbestos Containing Materials (ACM) are prevalent in buildings throughout the San Diego State University Campus. Typically, ACM is found in fireproofing, acoustical and decorative ceiling and wall plasters, and thermal pipe and tank insulation. ACM may also be found in such materials as plaster walls, ceiling and floor tiles, roof felts, chemical hoods, oven gaskets, automobile brakes and clutches, and many other items. Because of the significant amount of asbestos (both friable and non-friable) within SDSU buildings, it is imperative that a coordinated program be in place for identifying ACM, notifying building occupants of its presence and location, and developing procedures to minimize disturbance of asbestos and possible exposure. This section describes the San Diego State University program for identifying and characterizing the condition of asbestos in buildings.


Two systemwide asbestos surveys were performed for the CSU System. Baker Consultants performed the initial survey in 1985, and a follow-up survey was performed in 1987-88 by the Dynamac Corporation. The scope of each survey was as follows:

  1. Locate all suspected friable asbestos containing building materials (ACBM).
  • Sample all suspected materials and analyze them using Polarized Light Microscopy (PLM).
  • Characterize the condition of the asbestos based upon a modified EPA algorithm developed by the consultants.
  • Assign a hazard ranking category and number to each sample location that tested positive for asbestos.
  • Develop abatement cost estimates for all asbestos locations that were categorized as C, D, and F by Dynamac or 4, 5, 6, and 7 by Baker Consultants.
  • Cost estimates included asbestos abatement, development of abatement specifications, project monitoring, and, in the Dynamac report, restoration. However, restoration costs were not included for all locations that were needed, and Baker consultants did not include any restoration costs in their reports.
  • Develop guidelines for an asbestos operation and maintenance program.

    A. Periodic Surveillance of Known Locations of ACM

    In order to prevent exposure of building occupants to asbestos fibers, periodic surveillance of known locations of friable and non-friable ACM will be performed to determine if damage or deterioration has occurred. Facilities Services personnel will conduct the annual surveillance and maintain the associated records. If there is a need to perform additional sampling and analysis of suspect building materials, the Asbestos Coordinator in EH&S should be contacted (extension 46778).

    B. Inspection of Previously Unidentified ACM

    Neither one of the system-wide asbestos surveys sampled for and confirmed the presence of non-friable ACM such as plaster walls, vinyl asbestos floor tiles, ceiling tiles, and roofing felts. Because of the potential for employee exposure to asbestos fibers when these materials are disturbed (e.g. penetrating walls, removing floor & ceiling tiles), a procedure shall be used to ensure that building materials are sampled and analyzed prior to the start of construction or maintenance activities. Cal/ OSHA requires that certain building materials be sampled for the presence of asbestos, or assumed to be ACM. Additionally, the NESHAP requires that RACM (regulated asbestos containing material) must be removed prior to demolition or renovation.

    1. Work Order Review

    Facilities Services must route work orders through EH&S. EH&S will assess the potential for asbestos hazards. This may involve the sampling and analysis of suspected asbestos containing building materials. The proposed work shall not commence until EH&S has completed the assessment and approved the work order. The work order is then sent forward with comments relating to asbestos control.

    2. Bulk Materials Sampling & Analysis

    AHERA sampling techniques shall be utilized throughout the sampling survey (reference EPA Pink Book). Asbestos sampling shall be performed only by EH&S or Facilities Services staff who are trained in this process. The samples are analyzed by an EPA accredited laboratory. A copy of the laboratory sample results shall be sent by EH&S to the Project Manager. The results are also entered into the Campus Asbestos Material Location File.

    (a) Asbestos bulk samples shall be collected by, or under the direction of, a person who has completed an asbestos building inspector course and who is currently certified.

    Asbestos Management Plan Attachment A

    (b) The immediate area shall be secured so that building occupants are not present. Preferably, sampling should be performed outside of normal business hours.

    (c) An appropriate respirator equipped with HEPA filters shall be donned prior to collecting samples.

    (d) Asbestos containing material should not be sampled dry. Wet the surface of the sample area with a surfactant (typically 50% polyethylene-glycol) or water. For core sampling, a wet sponge can be placed over the sampled area and the core will be run through the sponge into the suspected ACM. Penetrate the suspected material completely with a sharp object such as a coring tool, blade or knife and remove a small section of the suspect material. Minimum sampling numbers:

    • Area of the homogenous suspect ACM 1000 linear or square feet (3) three bulk samples shall be collected.
    • Area of homogenous suspect ACM is at least 1000 linear or square feet, but 5000 linear or square feet, at least (5) bulk samples shall be collected.
    • Area of homogenous suspect ACM is 5000 linear or square feet (7) seven bulk samples shall be collected from each area.

    (e) Place the sample in a sealed container.

    (f) Patch or repair the material where the sample was removed.

    (g) Label the sealed container and record the following information:

    • Date
    • Location of sample (a graphic depiction of sample location should be included for demolition records)
    • Type of material (e.g. plaster wall, thermal system insulation)
    • Name or initials of individual taking sample
    • Laboratory that will be analyzing sample and phone number
    • Sample result (to be filled in after analysis)
    • Sample number — unique to the location and/or sample

    (h) Submit the sample to an EPA approved laboratory for analysis.

    (i) Depending upon the quantifying limit needed, the sample should be analyzed by either of two methods:

    • Polarized Light Microscopy (PLM) for quantifying limits equal to or exceeding 0.1% asbestos by weight.
    • Transmission Election Microscopy (TEM) if a detection limit below 0.1% asbestos by weight is needed.

    Note: Fine dust samples from operations like brake rebuilding should be analyzed using TEM.

    3. Quality Assurance (QA)

    Appropriate analytical Quality Assurance (QA) procedures must be established and followed by the analytical laboratory. It is the responsibility of EH&S to ensure that appropriate QA requirements are provided to Purchasing and Contracts for inclusion in bid specifications.

    4. Documentation

    All sample results are incorporated into the Master Data Base Asbestos Locations Within SDSU Buildings. This list is communicated to building occupants in accordance with the notification requirements of Section IV.B of the Asbestos Management Plan .

    The master ACM Sample list is maintained by the Asbestos Coordinator, and is available in the EH&S Office, Chemical Sciences Laboratory 106. during normal work hours (8 a.m. to 4:30 p.m.).

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