Chapter 36

ASBESTOS HAZARDS AND CONTROLS

Contents

Approved by Rob Connelly
Revised 05/13

36.1 Policy
36.2 Scope
36.3 Applicability
36.4 Exceptions
36.5 Roles and Responsibilities
36.6 Definitions
36.7 Required Work Processes

Work Process A. General Requirements
Work Process B. Asbestos Identification Process
Work Process C. Training Requirements
Work Process D. Class I and II Asbestos Work Procedures
Work Process E. Class III Asbestos Work Procedures
Work Process F. Class IV Asbestos Maintenance and Custodial Work
Work Process G. Waste Disposal Requirements
Work Process H. Reports and Tests

36.8 Source Requirements
36.9 Reference Documents
36.10 Appendices

Appendix A. Asbestos Labels and Signs
Appendix B. Checklist for Auditing Asbestos Work Practices
Appendix C. ACM Damage Categories & Corrective Action

 

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36.1   Policy

Berkeley Lab’s Asbestos Program manages the presence of asbestos-containing material (ACM) at the Laboratory site by:

36.2   Scope

This plan was developed to ensure that exposure to asbestos by Lawrence Berkeley National Laboratory (Berkeley Lab) employees, visitors, and subcontractor employees’ is minimized.

Handling of asbestos or ACM must be in conformance with this plan. The Asbestos Program contains elements specifically required by laws and regulations, and additional requirements necessary to safely and effectively manage asbestos at Berkeley Lab.

36.3 Applicability           

This program applies to All Berkeley Lab employees, affiliates, visitors, and subcontractors.

36.4 Exceptions

None

36.5   Roles and Responsibilities

Roles

Responsibilities

Building Managers

Notify Environment, Health, Safety, and Security (EHSS) of suspected or known ACM that may pose a health hazard

Environmental Protection Group (EPG)

  • Submits written notification to the Bay Area Air Quality Management District (BAAQMD) at least 10 working days in advance of all demolitions (notification must be given at all times, even when ACM is not present) and renovations involving removal of regulated asbestos-containing material (RACM) greater than or equal to 100 linear feet, 100 ft2, or 35 ft3 unless the notification is completed by a subcontractor performing the work
  • Submits written notifications to BAAQMD of cumulative renovations (during a calendar year) that involve reportable amounts of RACM. (Note: This is a shared responsibility with Facilities, the Environmental Protection Group [EPG], and Industrial Hygiene.)
  • Prepares written requests to BAAQMD for approval of alternate removal methods, such as dry removals

Facilities Division

  • Maintains ACM to prevent employee exposures and releases to the environment

Responsibilities related to Asbestos Bulk Sampling:

  • Ensures that buildings and equipment are surveyed for ACM prior to demolitions and renovations. (Note: This is a dual responsibility shared with Industrial Hygiene.)
  • Ensures industrial hygiene services are budgeted for large-scale asbestos abatement projects. This is to provide day-to-day on-site industrial hygiene oversight for the project.
  • Includes site-specific contract specifications for large-scale asbestos abatement projects
  • Notifies the industrial hygienist and/or Environmental Protection of every demolition, whether or not it involves asbestos, and every removal of RACM prior to starting
  • Ensures that contract specifications are followed by abatement contractors. (Note: This is a shared responsibility with Industrial Hygiene.)
  • Submits copies of all contractor air-monitoring results to an EHSS Industrial Hygienist             
  • Notifies an EHSS industrial hygienist verbally of all asbestos abatement projects involving Class I, II and III work as far in advance as feasible
  • Performs asbestos abatement or encapsulating work in accordance with Work Processes D and E, as applicable, of this program
  • Ensures Facilities employees performing work with ACM or potentially exposed to asbestos at a concentration above the permissible exposure limit (PEL) or excursion limit have current training appropriate for the type of asbestos work they are performing
  • Obtains written approval from an EHSS industrial hygienist prior to purchasing new ACM

EHSS Industrial Hygienist

  • Reviews specifications for large-scale abatement projects and associated compliance plans involving the large-scale disturbance of ACM
  • Ensures buildings and equipment are surveyed for ACM by Facilities or contract consultants prior to demolitions and renovations. (Note: This is a dual responsibility shared with Facilities.)
  • Performs representative personal air monitoring and area air monitoring (e.g., clearance sampling) as appropriate for asbestos abatement work involving Berkeley Lab employees. Notifies the employee and the employee's supervisor of the results in writing within five working days of their receipt.
  • Performs quantitative respirator fit tests annually for employees routinely involved with asbestos abatement work. (Note: Given the limited amount of asbestos work performed by asbestos-trained employees in Facilities, employee fit tests may not be current. In these cases, asbestos work may not be performed until the fit test is made current again.)
  • Provides consultation and inspection for: Environmental Protection Agency (EPA)-approved Building Inspector / Management Planner, Contractor/Supervisor, Project Designer, with current certification.

    Note: Certified Industrial Hygienists do not have to attend the Building Inspector course (29 CFR 1926.1101 (k)(ii)(B).

Health Services Group

  • Provides, as necessary, complete asbestos physical examinations as described in 29 CFR 1926.1101 or 29 CFR 1910.1001 for Berkeley Lab employees who may be enrolled in the asbestos medical surveillance program

Supervisors of employees who routinely work with or may disturb ACM

  • Ensure employees are provided the appropriate protective clothing and respiratory protection
  • Ensure employees who conduct asbestos work comply with Berkeley Lab’s Asbestos Management Plan and 29 CFR 1926.1101. Ensure employees handling asbestos, or who may be exposed to asbestos at or above the PEL or excursion limit, have received required training.
  • Ensure appropriate employees receive medical surveillance if necessary

Waste Management Group

  • Provides assistance with labeling, storage, and disposal requirements for ACM. Selects a California Department of Toxic Substances Control (DTSC)-approved disposal site for all RACM and asbestos-contaminated waste material. (Note: DTSC approvals are not required for non-RACM materials, including undamaged floor tiles and Sheetrock containing less than 1% asbestos by point counting analysis.)
  • Ensures proper packing and loading of ACM onto transport vehicles
  • Ensures vehicles transporting RACM and asbestos-contaminated waste materials (e.g., clothing and equipment) are placarded in compliance with BAAQMD Rule 11-2-304.5, and that waste shipment records comply with BAAQMD Rule 11-2-502
  • Manifests RACM and asbestos-contaminated waste materials from Berkeley Lab to disposal site
  • Maintains disposal records
  • Ensures Hazardous Waste Handling Facility employees who handle asbestos-containing waste are adequately trained
  • Provides the Facilities Division with necessary waste-disposal information prior to abatement projects

 

36.6   Definitions

Term Definition

Abatement

Removal, encapsulation, enclosure, repair or demolition of ACM

Asbestos-containing material (ACM)

Building materials that contain asbestos in an amount greater than 1.0% by weight, area, or count

ACM waste

Asbestos-containing materials. Waste materials that contain friable asbestos in an amount of 1% or greater by weight, area, or count, and asbestos-contaminated materials (e.g., protective clothing and equipment)

Accredited

The analytical laboratory used for asbestos analysis must participate in a quality-assurance program administered by the American Industrial Hygiene Association (AIHA) or the National Institute of Occupational Safety and Health (NIOSH)

Asbestos

A generic term referring to naturally occurring fibrous mineral silicates. The three most common types are chrysotile (white) asbestos, amosite (brown) asbestos, and crocidolite (blue) asbestos.

Certified Industrial Hygienist (CIH)

Certified Industrial Hygienist; a person certified in the comprehensive practice of industrial hygiene by the American Board of Industrial Hygiene

Class I Asbestos Work

Activities involving the removal of thermal-system insulation (TSI) and surfacing ACM

Class II Asbestos Work

The removal of asbestos-containing wallboard, floor tile, roofing materials, transite, construction mastic, gaskets, etc. This does not involve the removal of TSI or surfacing materials.

Class III Asbestos Work (16-hour training)

Activities involving repair and maintenance operations where ACM (including TSI and surfacing materials) are likely to be disturbed. The amount removed must fit into one glove bag or waste bag less than 60 inches in width.

Class III Asbestos Work (four-hour training)

Exception to 1926.1101(k)(9)(v) for operations for which the competent person determines that the EPA curriculum does not adequately cover the training needed to perform an activity. In this case, Berkeley Lab craft workers receive this level of training to perform their trade work without requiring Class III 16 hours of training.

Class IV Asbestos Work

Maintenance or custodial activities during which employees contact ACM or PACM, and activities to clean up waste and debris containing ACM and PACM

Competent Person

One who meets the requirements in 29 CFR 1926.32(f), and can identify existing asbestos hazards in the workplace, select the appropriate control strategy, and has the authority to take prompt corrective measures to mitigate them

Composite

Several individual parts combining to form one integral system. For example, a composite asbestos sample of a Sheetrock wall system with asbestos-containing joint compound would be a sample of the entire wall material, (i.e., joint compound, tape, and wallboard combined).

Containment

The construction of an impermeable barrier around ACM to prevent the release of fibers into occupied areas during abatement. In addition, a containment controls the amount of incoming air so that a negative pressure in the work area can be maintained.

Contractor

An individual or business that Berkeley Lab hires to perform work involving ACM

Cumulative

A series of small renovations or removals of RACM performed during a calendar year

Demolition

The wrecking or taking out of any load-supporting structural member of a structure. (Note: This definition is for BAAQMD purposes.)

Encapsulant

A liquid material that can be applied to ACM that controls the possible release of asbestos fibers from the material. Bridging encapsulants do this by creating a membrane over the surface, while penetrating encapsulants penetrate into the material and bind the components together.

Encapsulation

Application of an encapsulant to ACM to control the release of asbestos fibers

Excursion limit

Exposure to asbestos in excess of 1.0 fiber per cubic centimeter of air (1.0 f/cc) as averaged over a sampling period of 30 minutes

Fiber

A particulate form of asbestos that is 5 micrometers or longer, with a length-to-diameter ratio of at least 3 to 1, as determined by phase contrast microscopy (PCM)

Friable

A material containing asbestos that can be crumbled, pulverized, or reduced to a powder under hand pressure when dry, or that has been crumbled, pulverized, or reduced to a powder

HEPA filter

A high-efficiency particulate air filter capable of filtering 0.3 micrometer particles with 99.97% efficiency. This is the only type of filter suitable for asbestos work, both in respirators and negative air machines.

Industrial Hygienist

Professional qualified by education, training, and experience to anticipate, recognize, evaluate, and develop controls for occupational health hazards

Negative exposure assessment

Demonstration by exposure monitoring that employee exposure during an operation is expected to be consistently below the PEL or excursion limit

Negative pressure ventilation system

A portable exhaust system equipped with HEPA filtration and capable of maintaining a negative pressure of 0.02 inches (or greater) of water in a contained area

Nonfriable ACM (Category I)

Intact asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing products

Nonfriable ACM (Category II)

Asbestos-containing material (excluding Category I) that, when dry and in its present form, cannot be crumbled, pulverized, or reduced to powder by hand pressure. This includes asbestos cement products, transite board, pipe, plaster, stucco, paint, and mastics.

Presumed asbestos-containing material (PACM)

Material that may contain asbestos and has not been sampled for asbestos content shall be assumed to contain asbestos and treated accordingly.

Phase contrast microscopy (PCM)

An analytical method used to count airborne fibers. Results are given as fibers per cubic centimeter of air (f/cc). Occupational Safety and Health Administration (OSHA) employee exposure standards are based on this method. This method counts all fibers greater than 5 microns in length, without specifically identifying the fiber type (cotton, fiberglass, nylon, etc., will also be counted).

Permissible exposure limit (PEL)

The eight hour, time-weighted average concentration of allowable airborne asbestos fibers to which an employee may be exposed. The limit for asbestos is 0.1 fibers per cubic centimeter (f/cc) of air.

Personal exposure monitoring

Determination of an employee’s exposure from breathing zone (i.e., 2-foot radius surrounding the head) air samples representative of the eight-hour time-weighted average (TWA) or 30-minute excursion limit

Planned renovation

Renovation, or number of renovations, that can be predicted to occur within one period of time, not to exceed one year

Polarized light microscopy (PLM)

Analytical method used to determine type and quantity (i.e., percent) of asbestos present in a bulk sample

Regulated asbestos-containing material (RACM)              

  • Friable ACM
  • Nonfriable Category I ACM that has or will become friable, or that has been subjected to sanding, drilling, grinding, cutting, or abrading
  • Nonfriable Category II ACM that may become crumbled, pulverized, or reduced to powder by the forces expected to act upon the material in the course of demolition or renovation.

Regulated asbestos work area

An area in which the exposure to asbestos fibers can reasonably be expected to exceed the PEL of 0.1 fibers per cubic centimeter of air. No one may enter the regulated area without training and proper protective equipment. Regulated areas are restricted by barriers, asbestos warning tape, signs, etc. (See Appendix A for proper signage.)

Renovation

The modifying of any existing structure or portion thereof

Reportable

Defined by the BAAQMD as every demolition, even if no RACM is involved, and renovations involving removal of RACM greater than or equal to 100 linear feet, 100 square feet (ft2), or 35 cubic feet (ft3)

Structure (in AHERA)

A microscopic bundle, cluster, fiber, or matrix that may contain asbestos

Structural member

Any load-supporting member of a facility, such as beams and load-supporting walls

Surfacing material

Material that is sprayed, trowelled, or otherwise applied to surfaces (e.g., fireproofing on structural steel, acoustical plaster on ceilings)

Surfactant

A chemical wetting agent added to water to improve penetration of the water into a solid material

Transmission electron microscopy (TEM)

A method that counts all fiber sizes (including those less than 5 microns in length) and positively identifies fiber type. The results are reported in structures/cc. This method is not recognized by the OSHA asbestos standard but is specified in the Asbestos Hazard Emergency Response Act (AHERA) standard.

Thermal system insulation (TSI)

Insulation applied to pipes, fittings, boilers, ducts, etc., to prevent heat loss or gain

Time weighted average (TWA)

Airborne exposure to a substance as averaged over an eight-hour workday

Visible emissions

Any release of ACM that is visually detectable without the aid of instruments

36.7   Required Work Processes

Work Process A. General Requirements

  1. Background
    1. Asbestos is a generic term referring to fibrous mineral silicates that were used extensively from about 1900 until very recently in the manufacture of construction and industrial products. Some products are still manufactured with a significant asbestos content. Work Process B lists various products that have been manufactured with asbestos. This list is not exhaustive, other products not listed may also contain asbestos.
    2. Asbestos-containing materials can be divided into two general categories: friable and nonfriable.
      1. Friable ACM products are those that can be readily crumbled or powdered by hand pressure, and are of more concern than nonfriable ACM because of the greater ease of fiber release. Examples of friable ACM include pipe insulation, sprayed-on acoustical insulation, and sprayed-on fireproofing. Intact and sealed friable asbestos materials are considered nonfriable and do not pose a health risk if they are undisturbed and undamaged.
      2. Non-friable ACM generally possesses a strong binder such as cement or vinyl, which stabilizes the asbestos, reducing the likelihood of generating airborne asbestos dust. However, specific actions such as sanding, grinding, cutting, or drilling of nonfriable asbestos can result in the release of asbestos fibers. Examples of nonfriable asbestos include intact vinyl asbestos floor tiles, roofing felts/shingles, and asbestos cement products such as transite panels and pipes.
  2. Management of the Asbestos Program. The EHSS Construction/Projects and Field Support Group manages the institutional Asbestos Program and its programmatic elements. Actual asbestos support functions, provided by the Facilities Division or its subcontractors, are managed directly by the Facilities Division. This will entail active involvement by EHSS and Facilities, with Berkeley Lab asbestos-control activities relating to demolition, renovation, maintenance activities, or other instances involving the possible disturbance of ACM.
  3. Asbestos as an Inhalation Hazard. Asbestos is primarily an inhalation hazard and a demonstrated human carcinogen. Employee exposure to airborne asbestos should be limited to levels that are “As Low As Reasonably Achievable” (ALARA) and must be limited to levels below applicable occupational exposure limits (see below).
  4. Asbestos-Related Diseases. Asbestos-related diseases caused by the inhalation of fibers typically occur 10 to 45 years after exposure. Asbestos does not cause any acute (immediate) effects, except skin warts that are mentioned below.
    1. Asbestosis — permanent fibrotic scarring of lung tissue, which results in a reduced ability to breathe, cardiovascular failure, and in severe cases, death.
    2. Lung Cancer — occurs more often in people exposed to asbestos than in non-exposed groups. This effect of asbestos exposure is greatly magnified by cigarette smoking.
    3. Mesothelioma — cancer of the lining of the chest and abdominal cavity. A rare disease that occurs almost exclusively in those exposed to asbestos.
    4. Skin warts — single asbestos fibers embedded in the skin may cause noncancerous warts. They heal when the fiber is removed.
  5. Hygiene Facilities
    1. For Class 1 asbestos jobs involving more than 25 linear or 10 square feet of TSI or surfacing material, there must be a decontamination area (29 CFR 1926.1101[j]) consisting of an equipment room, shower area, and clean room, in series and connected to the Regulated Area. Employees must enter and exit through the decontamination area.
    2. For Class 1 asbestos jobs involving less than 25 linear or 10 ft2, and Class 2 or 3 work that is above the PEL or where there is no negative exposure assessment, an equipment room adjacent to the Regulated Area must be constructed.
      1. The floor area and horizontal work surface must be constructed of 6-mil plastic (minimum), and be large enough to accommodate the cleaning of equipment and surfaces of waste containers.
      2. Work clothing must be HEPA vacuumed before it is removed and employees must enter or exit through the equipment room.
    3. Class IV work at Berkeley Lab does not require decontamination facilities. Employees trained at this level will not work in Regulated Areas or be involved in the cleanup of ACM or PACM.
  6. Labeling and Posting
    1. Identified (by laboratory analysis) friable ACM found to contain 1.0 % asbestos or greater should be labeled, when feasible, as shown in Appendix A, Figure A-1.
    2. Warning signs will be posted at the outside perimeter of each regulated area as shown in Appendix A, Figure A-2.
  7. Medical Surveillance. Any Berkeley Lab employee identified as being exposed to airborne asbestos for a combined total of 30 or more days per year engaged in Class I, II, and III work, or who is exposed at or above a permissible exposure limit, will be provided medical surveillance as described in 29 CFR 1926.1101 or 29 CFR 1910.1001 by the Health Services Group. All other employees who enroll in and complete predefined asbestos classes will be offered voluntary medical surveillance.
  8. New Products Containing Asbestos. No new asbestos-containing construction products will be procured or installed at Berkeley Lab without prior review by the Industrial Hygiene Group.
  9. Protective Clothing
    1. Employees who may be exposed to airborne asbestos levels exceeding the PEL or excursion limit will be provided protective clothing (e.g., disposable coveralls, gloves, shoe coverings, safety glasses, etc.) and work equipment at no cost.
    2. Contaminated clothing used in areas that may exceed the PEL or excursion limit will be transported in sealed poly bags and disposed of as asbestos-containing waste.
  10. Regulatory Agency Notification
    1. The BAAQMD requires a minimum of 10 working days’ notice prior to any building demolition.
      1. The same notification requirement applies to building renovations involving RACM removal over certain reportable quantities.
      2. An additional category of notification is for a series of small activities involving RACM that individually do not trigger notification, but collectively do. This is called a cumulative notification and it is submitted and paid for by the Facilities Division once per year.
    2. To ensure compliance with BAAQMD's notification requirements:
      1. The Environmental Services Group (ESG) will be informed of every demolition by Facilities, whether or not it involves asbestos.
      2. Outside contractors who perform work reportable to BAAQMD (i.e., greater than 100 linear, 100 square or 35 cubic feet) will send BAAQMD application forms to the Facilities Project Manager for EHSS ESG review prior to the subcontractor submitting the required notice to the BAAQMD.
  11. Respirators
    1. Air-purifying negative-pressure respirators used by Berkeley Lab personnel who may be exposed to asbestos above the PEL or excursion limit must be fit-tested prior to conducting asbestos work. This is in addition to the other aspects of the Respiratory Protection Program. Call extension 5918 for respirator fit testing and training.
    2. Powered air-purifying respirators shall be provided free of charge in lieu of a negative-pressure respirator if an employee requests one.
    3. Respirators shall be used in all of the following circumstances:
      1. Class I asbestos work
      2. Class II work where the ACM is not removed intact
      3. Class II & III work where wet methods are not used and there is not a negative exposure assessment
      4. Class III work where TSI or surfacing material that contains or may contain asbestos is removed
    4. Respirator Selection Table. The following table, which represents minimum requirements, should be used to select respiratory protection.

  12. Airborne Concentration of Asbestos

    Required Respirator

    Not in excess of 1 f/cc (10X PEL)

    Half-mask air-purifying (not disposable) with HEPA filters

    Not in excess of 5 f/cc (50X PEL)

    Full-face air-purifying respirator with HEPA filters

    Not in excess of 10 f/cc (100X PEL)

    Powered air-purifying with HEPA filters

    Not in excess of 100 f/cc (1000X PEL)

    Full facepiece supplied air respirator operated in pressure-demand mode

    Greater than 100 f/cc (1000X PEL)

    Full face piece supplied air respirator in pressure demand, equipped with 5-minute escape bottle


  13. Flooring Material Maintenance
    1. Rubber wheels (i.e., not plastic) should be used on chairs that are in contact with resilient flooring (e.g., linoleum, floor tiles, sheet flooring). The purpose of this requirement is to prevent floor abrasion and the subsequent potential creation of asbestos-containing dust. The Facilities Work Request Center at ext. 6274 is available for assistance in the replacement of wheels. The cost of the rubber wheels will be at the expense of the owner of the chair.
    2. Sanding of the flooring, its backing, or mastic, is prohibited.
    3. Stripping of floors must be conducted using low-abrasion pads at speeds lower than 300 rpm, and wet methods.
    4. Burnishing or dry buffing may be performed only on flooring that has sufficient finish so that the pad cannot contact the ACM.
    5. Dust and debris in an area containing visibly deteriorated ACM shall not be dusted, swept dry, or vacuumed without the use of a HEPA vacuum by AHERA asbestos trained Facilities workers.
  14. Roofing Products – Asphalt
    1. Asphalt roofing products containing asbestos are nonregulated (Category I, nonfriable) unless:
      1. They are or will become friable.
      2. They will be subjected to sanding, drilling, grinding, cutting, or abrading.
    2. Such nonregulated asphalt roofing products do not need to be reported prior to demolition or renovation activities unless they will become friable as part of the work or they are severely weathered and considered friable.
    3. Waste-disposal sites may have individual internal requirements that exceed legal disposal requirements; contact the Waste Management Group for guidance concerning bins, labeling and wrapping requirements, etc., before starting work.
  15. Asbestos Flooring Material                 
    1. Covering asbestos flooring material (e.g., VAT tiles, linoleum, etc.,) must be avoided, when feasible, to prevent potential inhalation exposure risks to employees and to prevent costly change orders due to materials being missed as part of future renovation projects. In cases where these materials are covered, Facilities will notify EHSS, which will enter this information into the Hazard Management System (HMS).
    2. As part of project planning and design, and when feasible, asbestos flooring material and mastic shall be removed prior to renovation projects to prevent abrading, scratching, wearing, breaking, or any other type of disturbance of the material.
    3. When carpet is glued to asbestos flooring materials, if more than a few tiles pop up, the carpet removal must stop and be removed inside a HEPA-filtered, negative-pressure containment. Contact an industrial hygienist for additional consultation.

Work Process B. Asbestos Identification Process

  1. For identification of asbestos content in materials, contact the Construction/Projects and Field Support Group (ext. 4028).
  2. For concerns regarding the safety of potential asbestos-containing materials, contact the EHSS Asbestos Program Coordinator, ext. 4028.
  3. Examples of Materials Manufactured with Asbestos    
    1. Cement/asbestos panels and pipes (transite)             
    2. High-temperature gaskets
    3. Pipe insulation (block, corrugated aircell, etc.)         
    4. Mastic for vinyl flooring
    5. Vinyl floor tiles and sheet vinyl flooring                   
    6. Wallboard (Sheetrock)
    7. Electric wiring insulation                                              
    8. Taping or joint compounds
    9. Spray-applied fireproofing and insulation                 
    10. Roofing felt/shingles/flashing
    11. Automotive brake linings and pads                                            
    12. Ceiling tiles
    13. Fire-resistant gloves, clothing                       
    14. HVAC duct insulation and tape
    15. Linoleum and other resilient flooring                                        
    16. Paint
    17. Fire doors                                                                                                       
    18. Window putty
    19. Plaster/stucco                                                                                 
    20. Elevator/crane brake shoes
  4. Building Surveys/Repairs  
    1. Buildings constructed after 1981 generally do not contain friable asbestos; however, an EHSS industrial hygienists must be consulted beforehand for all renovation and demolition projectssince there are no end dates for building survey purposes.
    2. The Facilities Division is responsible for the repair of damaged or deteriorated (unsealed ends, nicks, loose pieces of insulation, abraded floor tiles, etc.) friable and nonfriable ACM. The chart in Appendix C will be used to decide what type of repair is necessary and how soon it needs to be performed. An industrial hygienist will be available for consultation on these decisions.
    3. Pre-renovation / Demolition: Facilities is responsible for ensuring the affected structure or areas are surveyed for ACM prior to any demolition or renovation, per 40 CFR 61.145 and BAAQMD 11-2-303.8.
    4. If suspected ACM has not undergone laboratory analysis, it should be assumed to contain asbestos and treated accordingly.
  5. Bulk Sampling   
    1. The testing, evaluation, and sample collection of materials for asbestos analysis must be conducted by an accredited asbestos building inspector (40 CFR Part 763) or by a Certified Industrial Hygeinist.
    2. Analysis of these samples must be performed by persons or laboratories with proficiency demonstrated by participation in the National Voluntary Laboratory Accreditation Program (NVLAP).
  6. Employee Notification. Air-monitoring results from an industrial hygienist must be given in writing to the affected employee and his or her supervisor within five working days of their receipt.
  7. Exposure Monitoring and Job-site Clearance Levels
    1. The current OSHA PEL is 0.1 fibers per cubic centimeter (f/cc) of air averaged over an eight-hour day. The excursion limit for any 30-minute exposure is 1.0 f/cc of air.
    2. Initial monitoring of Berkeley Lab employees who are or who may be reasonably expected to be exposed to airborne asbestos concentrations exceeding the PEL or excursion limit will be performed by an industrial hygienist.
    3. Monitoring may be discontinued when results show that employee exposures are consistently below the PEL and excursion limit.
    4. Initial monitoring will be repeated whenever there has been a change in the control equipment, process, personnel, or work practices that may result in new or additional exposures.
    5. Acceptable job-site clearance levels are 70 structures per square millimeter (st/mm2) by TEM or 0.01 fibers per cubic centimeter (f/cc).
    6. Clearance sampling is not required for small-scale, short-duration projects.
  8. Identification of ACM in Buildings   
    1. Prior to remodeling, modifying, demolishing, or otherwise disturbing any facility component, the job site will be visually inspected by a qualified AHERA asbestos building inspector.
    2. If ACM is potentially present and an adequate prior survey of the area has not been conducted, a survey must be performed to identify any ACM that may be disturbed by the planned work.
      1. Any such materials identified as ACM will be removed or protected from disturbance before the work can proceed. (See 40 CFR 61.145[c] and BAAQMD 11-2-303.)
      2. Materials suspected of being ACM but not sampled will be assumed to contain asbestos and treated accordingly. This is most appropriate when the task is very limited in scope (e.g., a small spill <1 ft2, floor tiles <10 ft2) and the cost and time spent collecting and analyzing the samples is a significant part of, or exceeds, the cost of performing work.
  9. Sheetrock (drywall)   
    1. When a demolition or renovation impacts a wall system composed of Sheetrock, joint compound, and tape, a composite sample will be taken of the wall material.
    2. A wall system shown by composite sampling to contain less than 1% asbestos by point counting is not regulated by BAAQMD, EPA, or DTSC.
    3. If the composite sample result indicates a trace amount of asbestos, and/or the joint compound analysis indicates a 1% or greater asbestos content, an EH&S industrial hygienist must be contacted for further guidance before starting the work.

Work Process C. Training Requirements

Role

Required Training

Facilities employees routinely engaged in activities that may contact, but not disturb, asbestos containing building materials

Berkeley Lab annual asbestos awareness class. Although not classified as Class IV work, since dust, waste or debris from Class I-III work is not performed, the training will cover:

  • Examples of building materials that may contain asbestos
  • The health effects associated with asbestos exposure
  • The relationship between smoking and asbestos in causing cancer
  • The nature of the operations that could result in asbestos exposure, as well as how to minimize exposure through the use of engineering controls, work practices, personal protective equipment, and administrative controls
  • The relationship between friability and percent asbestos content and how it affects risk of exposure
  • Spill response

Employees identified as being potentially exposed to airborne asbestos levels above the PEL or excursion limit

OSHA-approved training per 29 CFR 1910.1001(j)(7) and 29 CFR 1926.1101(k)(iii))

Employees performing bulk sampling

EPA-approved building inspector course or be a Certified Industrial Hygienist (29 CFR 1926.1101[k][ii][B])

Asbestos Program Manager

  • EPA-approved Building Inspector/Management Planner and Contractor/Supervisor courses
  • Maintain current certification

Industrial Hygienist whose specialty area is asbestos

  • EPA-approved Building Inspector/Management Planner and Contractor/Supervisor courses
  • Maintain current certification

Class I Abatement Workers

Workers must have AHERA worker (32 hours) training.

Class II Abatement Workers

Workers must have AHERA worker (32 hours) training.
If the workers will remove/disturb only one type of building material (e.g., roofing, flooring, transite) they can be trained at a Class IV level, with additional training on specific work practices and engineering controls. This course will include hands-on training and be at least eight hours long.

Class III Workers (16 hr)

Supervisor and workers must be trained at the EPA 16-hour Operations & Maintenance level or higher.

Class III Workers (4 hr)

Berkeley Lab craft employees who may disturb small, incidental amounts of building materials that may contain asbestos as part of their trade

Class IV Workers

Trained to Berkeley Lab’s awareness level training for hazard communication purposes

Work Process D. Class I and II Asbestos Work Procedures

  1. Class 1 Asbestos Work   
    1. Definition: Removal of thermal system insulation (TSI) or surfacing material greater than one glove bag. Note: Any change or deviation from the below-specified control methods must be approved in writing by a CIH.
    2. Training: Abatement workers will supervised by a "competent" person who meets the requirements of 29 CFR 1926.32(f). Workers must have AHERA worker (32 hours) training.
    3. Air Sampling: Air monitoring required unless a negative exposure assessment has been performed for the entire operation. Clearance air sampling is required before negative-pressure enclosure is removed and the work area is re-occupied. The acceptance clearance level is <70 structures/mm2 by TEM. PCM clearance samples may be acceptable for small containments.
    4. Regulated Area: Required for all work
    5. PPE/Respirators: Disposable coveralls, shoe covers, and respirator. Respirators must always be worn. See Respirator Selection Table in Work Process A, Section 11, for guidance.
    6. Work Requirements   
      1. The work location will be identified as a "Regulated Area."
      2. An HVAC system inside the regulated area is isolated by sealing with a double layer of 6 mil plastic.
      3. Impermeable drop cloths will be placed on surface beneath all removal activity.
      4. Appendix B (Job Audit Checklist) will be completed by an EHSS industrial hygienist or a Facilities supervisor who is AHERA-trained as a “competent” person, before work starts.
    7. Negative-Pressure Enclosure    If the amount of ACM to be removed is more than 25 linear or 10 square feet, and exposure monitoring has shown that the PEL may be exceeded, a negative-pressure enclosure is required. Listed below are the requirements for the enclosure.
      1. A minimum of -0.02 inches of water differential and at least four air changes per hour must be maintained inside of the enclosure.
      2. Negative-pressure machines shall be exhausted to the outside of the building, if feasible.
      3. Full decontamination with an equipment room, shower area (with hot and cold water), and clean room in series is required at the work site (29 CFR 1926.1101[j]).
    8. Glove Bag Systems    
      1. Glove bags shall be used to remove ACM and PACM from straight runs of piping. Specifications for the glove bags and their use:
        1. Made of 6-mil-thick plastic and seamless at the bottom
        2. Installed so that it completely covers the circumference of the pipe
        3. Smoke-tested for leaks and any leaks sealed prior to use
        4. Used only once and not moved
        5. Not used on surface exceeding 150º F
        6. Collapsed by removing air with a HEPA vacuum prior to disposal
        7. Loose and friable material adjacent to the glove bag shall be wrapped and sealed in two layers of 6-mil plastic, or otherwise rendered intact.
        8. At least two persons shall perform Class 1 glove bag removals. Note: This is required in 29 CFR 1926.1101(g)(9).
        9. Glove bag removal operations shall be performed inside HEPA-filtered negative-pressure enclosures, when feasible, given the greater risk of asbestos fiber releases associated with glove bag work.
  2. Class II Asbestos Work   
    1. Definition: Removal of ACM other than TSI or surfacing materials. Examples of this type of work include the removal of roofing, flooring, mastics, gaskets, transite, wallboard, etc.
    2. Training: Abatement workers will be supervised by a "competent" person who meets the requirements of 29 CFR 1926.32(f). Workers must have AHERA worker training (32 hours). If the workers will remove/disturb only one type of building material (e.g., roofing, flooring, transite) they can be trained at a Class IV level, with additional training on specific work practices and engineering controls. This course will include hands-on training and be at least eight hours long.
    3. Air Sampling: Required unless there is a negative exposure assessment. Clearance air sampling may be required before the work area is occupied. The acceptance clearance level is <70 structures/mm2 by TEM. PCM clearance samples may be acceptable for small containments.
    4. PPE / Respirators: Same as for Class 1 work if the PEL is exceeded, wet methods are not used, or if the material is not removed substantially intact.
    5. Roofing: Shall be removed following the work practices listed below:
      1. Removed intact to the extent feasible
      2. Wet methods used when feasible
      3. Cutting machines misted continuously during use, unless a competent person determines misting decreases worker safety
      4. Loose dust left by sawing operations HEPA-vacuumed immediately
      5. Unwrapped or unbagged roofing material immediately lowered to the ground via covered, dust-tight chute, crane, or hoist. Wrapped or bagged material lowered to the ground at the end of the work shift.
      6. Roof-level heating and ventilating air-intake sources isolated by sealing and wrapping with two layers of 6-mil plastic or equivalent.
    6. Floor Tile Removal: Floor tiles must be removed following the work practices listed below:
      1. Removing floor tile <100 ft2  — contact the Asbestos Program Manager at ext. 4028
      2. Removing floor tile >100 ft2 — follow requirements for Class 1 work. However, Section 2.g.3 of this work process) (i.e., shower/equipment room) may be omitted if a negative exposure assessment has shown that the work is less than the PEL. In addition, the following list applies:
        1. Sanding of flooring, its backing, and the mastic is prohibited.
        2. Vacuums equipped with HEPA filter, disposable dust bag, and metal floor tool (no brush) must be used to clean floors.
        3. Resilient sheeting must be removed by cutting while wetting, and wetting during delamination.
        4. All scraping of residual adhesive or backings must be performed using wet methods.
        5. Dry sweeping and mechanical chipping are prohibited.
        6. When tiles are heated and removed intact, wetting may be omitted.
    7. Transite Panels, Siding, or Shingles (i.e., asbestos-cement products): The following work practice shall be followed:
      1. Cutting, abrading, or breaking is prohibited; if this is not possible, perform as Class 1 Asbestos Work. (Contact Asbestos Program Manager at ext. 4028 for drilling transite.)
      2. Each panel or shingle must be sprayed with amended water prior to removal.
      3. Unwrapped or unbagged panels must be lowered to the ground, or wrapped in plastic sheeting and lowered to the ground at the end of the project.

Work Process E. Class III Asbestos Work Procedures

Class III Asbestos Work 

  1.  Definition: Repair and maintenance activities that disturb ACM (or PACM), includes TSI and surfacing material and the cleanup of ACM dust or debris. The amount disturbed must fit in one glove bag or waste bag less than 60 inches in width. Examples include:
    1. Single glove bag removal of pipe insulation
    2. Patching of pipe insulation (<100 linear feet)
    3. Decontamination of surfaces (spills etc.) <25 square feet
    4. Removal of 1 square foot or less of RACM, using a local HEPA exhaust ventilation and collection system
  2. Training: Supervisor and workers trained at the EPA 16-hour Operations & Maintenance level or higher
  3. Air Sampling: Shall be performed as needed to document potential exposures.
  4. Regulated Areas: Not required, unless the PEL is exceeded or a negative exposure assessment has not been performed.
  5. PPE / Respirators: Required as for Class 1 work when TSI or surfacing material is disturbed, the PEL is exceeded, or when a negative exposure assessment has not been performed. See Respirators section in Work Process A for guidance in selecting a respirator.
  6. Work Requirements
    1. Post signs in such a manner that unauthorized persons will avoid entering the asbestos work area. (See Appendix A, Figures A-2 and A-3)
    2. Isolate the work area to the extent possible by closing doors, windows, or other openings.
    3. Wear disposable coveralls, shoe covers, and half-mask respirator with HEPA filters, as appropriate.
    4. Lightly mist any loose asbestos or asbestos debris with an appropriate wetting agent. Pick up or vacuum (HEPA) up loose material or dust. Wet-wipe hard surfaces after vacuuming. Note: The exposed hose end of the HEPA vacuum should be taped shut when the vacuum is not in use.
    5. Cover surfaces under the area to be abated with a sheet of 6-mil-thick plastic sheeting adequate to catch any debris.
    6. Wet the material thoroughly before handling. For pipe insulation removal,    use a glove bag.
    7. Local exhaust ventilation should be used when feasible.
    8. Whenever the work involves the disturbance of TSI or surfacing materials, impermeable plastic barriers, mini-enclosures or glove bags shall be used to isolate the work area.
    9. Use only hand tools to remove or repair material.
    10. Seal all exposed ACM surfaces with a coating of penetrating encapsulant and a layer of bridging encapsulant.
    11. Vacuum off protective clothing, and dispose of as asbestos-containing waste material. These materials should be double-bagged in 6-mil plastic bags and labeled as shown in Appendix A, Figure A-1. Rubber boots that are to be reused must be wet-wiped after use. Respirators should be removed last, wet-wiped, and placed in a storage bag. Filters should be removed from the respirator and disposed of, or the respirator filter’s air inlets should be sealed with tape, if left on the respirator, or stored in a separate storage bag. Dispose of the wet-wipe material and the respirator filters as asbestos-containing waste material.
    12. Clearance air-sampling is generally not required for work at this scale; however, this is left to the discretion of the industrial hygienist.Contractors performing this work will monitor their own workers. Removed ACM shall be disposed of in accordance with Work Process G.
    13. Removal of greater than 1 square foot of RACM triggers the requirement for a HEPA filtered, negative pressure mini-containment.

Work Process F. Class IV Asbestos Maintenance and Custodial Work

  1. Asbestos Removal and Repair Procedures
    1. The presence and location of ACM or PACM must be identified at the work site before work starts.
    2. In addition, before any demolition, the Environmental Protection Group will be informed. An outside contractor performing work that is reportable to the BAAQMD will submit the 10-day notification application to the Berkeley Lab Project Manager for review by the EHSS  Environmental Services Group prior to the subcontractor sending to the air district. Large-scale Class I and II work is rarely performed by Berkeley Lab employees. Occasional Class III work (and no Class IV work) is performed by Berkeley Lab Facilities AHERA/OSHA-trained asbestos workers. No Class IV work is conducted at the Laboratory, as Berkeley Lab employees trained at the awareness level don’t clean up dust, waste, and debris from Class I, II, or III jobs.
    3. All exposed RACM must be adequately wetted and kept wet during cutting, stripping, demolition, renovation, removal, handling, and disposal. Approval for dry removal of RACM must be received from the BAAQMD through the Environmental Services Group.
  2. Class IV Asbestos Work 
    1. Definition: Defined by OSHA as maintenance and custodial activities where employees contact ACM or PACM, but do not disturb the material and activities to clean up dust, waste, and debris resulting from Class I, II, and III activities.
    2. Training: Since Berkeley Lab employees trained at this level do not clean up dust, waste, or debris from Class I-III activities, training is limited to Berkeley Lab’s awareness-level training for hazard communication purposes.
    3. Air sampling: Not applicable because employees are not disturbing ACM related to cleanup of dust, waste, and debris resulting from Class I-III work.
    4. Regulated Areas: None. Employees who are trained at this level will not work in a regulated area.
    5. PPE / Respirators: Not required. Employees who are trained at the Berkeley Lab awareness level will not work in Regulated Areas or perform work that disturbs ACM dust, waste, or debris.
    6. Work requirements: Wet methods. Since this type of work only involves contact with ACM flooring, see Work Process A, Section 12, Flooring Material Maintenance.

Work Process G. Waste Disposal Requirements

  1. Friable ACM Containing 1% or Greater Asbestos (RACM)
    1. All RACM waste must be handled as hazardous waste. RACM will be thoroughly wetted before packaging, then packaged to prevent dispersion and to facilitate handling.
    2. The Waste Management Group at ext. 5867 or 5877 is responsible for determining the Hazardous Waste Handling Facility's storage and labeling requirements, selecting the disposal site, and manifesting and maintaining disposal records. It will also assist in determining how best to package the waste for disposal and arranging site pickup.
    3. Packaging       
      1. Labels: All containers of RACM must bear the asbestos warning label (Appendix A, Figure A-1) and the "Hazardous Waste" label.
      2. Bags: Asbestos waste must be sealed inside two layers of 6-mil-thick plastic bags after thorough wetting. The excess air in the bag must be removed by a HEPA vacuum. The outer bag must be labeled as shown in Appendix A, Figure A-1.
      3. Drums: Wetted asbestos waste can be contained in properly labeled Department of Transportation (DOT) spec. 17H 55-gallon steel drums equipped with polyethylene drum liner bags.
  2. Nonfriable ACM (transite, floor tile, etc.), Contact the Waste Management Group for assistance with labeling, storage, and disposal requirements. Labels may not be necessary if nonfriability can be demonstrated (29 CFR 1926.1101[k][7][A]).

Work Process H. Reports and Tests

  1. Bulk Sampling
    1. The testing, evaluation, and sample collection of materials for asbestos analysis must be conducted by an accredited asbestos building inspector (40 CFR Part 763) or by a CIH.
    2. Analysis of these samples must be performed by persons or laboratories with proficiency demonstrated by participation in the National Voluntary Laboratory Accreditation Program (NVLAP).
  2. Employee Notification. Air-monitoring results from the industrial hygienist must be given in writing to the affected employee and his or her supervisor within five working days of their receipt.
  3. Exposure Monitoring and Job-site Clearance Levels
    1. The current OSHA PEL is 0.1 fibers per cubic centimeter (f/cc) of air averaged over an eight-hour day. The excursion limit for any 30-minute exposure is 1.0 f/cc of air.
    2. Initial monitoring of Berkeley Lab employees who are or may be reasonably expected to be exposed to airborne asbestos concentrations exceeding the PEL or excursion limit will be performed by an industrial hygienist.
    3. Monitoring may be discontinued when results show that employee exposures are consistently below the PEL and excursion limit.
    4. Initial monitoring will be repeated whenever there has been a change in the control equipment, process, personnel, or work practices that may result in new or additional exposures.
    5. Acceptable job-site clearance levels are 70 structures per square millimeter (st/mm2) by TEM or 0.01 fibers per cubic centimeter (f/cc).
    6. Clearance sampling is not required for small-scale short duration projects.
  4. Air Sampling       
    1. Class I and II Work: Air monitoring is required unless a negative exposure assessment has been performed for the entire operation. Clearance air sampling is required before the negative-pressure enclosure is removed and the work area re-occupied. The acceptance clearance level is <70 structures/mm2 by TEM. PCM clearance samples may be acceptable for small containments.
    2. Class III Work: Must be performed as needed to document potential exposures.

36.8   Source Requirements

The interplay of EPA, OSHA, and BAAQMD regulations makes asbestos compliance somewhat complicated. Therefore, frequent consultation with an EHSS Industrial Hygienist, the Environmental Protection Group, Waste Management Group, and/or Berkeley Lab Environmental Counsel on asbestos-related issues is encouraged.

36.9   Reference Documents

Document number

Title

Type

07.07.002.010

Asbestos Management Plan

Plan


36.10 Appendices

Appendix A. Asbestos Labels and Signs


Danger

Contains Asbestos Fibers
Avoid Creating Dust
Cancer and Lung Disease Hazard

Figure A-1. Appropriate wording for labeling friable materials containing 1.0% asbestos by weight, or greater. This label is also appropriate for containers (including waste containers) that contain 1.0% or greater friable asbestos by weight. Waste containers holding RACM and asbestos-contaminated materials (such as protective equipment and clothing) must also include a label with the generator name and location, and a hazardous-waste label.

 

 

 


DANGER

ASBESTOS
Cancer and Lung Disease Hazard
Authorized Personnel Only
Respirators and Protective Clothing Are Required in This Area

Figure A-2. Appropriate wording for warning sign to demarcate areas where the PEL or excursion limit may be exceeded due to asbestos handling or the presence of damaged, friable ACM in need of repair.

 

 

 


CAUTION

ASBESTOS
Cancer and Lung Disease Hazard
Do Not Disturb Without Proper Training and Equipment

Figure A-3. Appropriate wording for warning sign where there is the potential for employees to come into contact with, release, or disturb asbestos or asbestos-containing construction materials.

 

 

Appendix B. Checklist for Auditing Asbestos Work Practices

Project Name:_____________________________________Date:_____________________
Asbestos Task(s):____________________________________________________________
Building:_____________Room:_____________Contractor:_________________________
LBNL Project Manager:______________________________________________________
LBNL Superintendent:________________________________________________________
LBNL IH:__________________________________________________________________
S = Satisfactory  US = Unsatisfactory  NI = Needs Improvement  NA = Not Applicable

WORK AREA

 

 

 

_________

Uncovered asbestos kept wet with water or with other encapsulating type spray while it is being worked on.

 

_________

Containment system suitable for the scope of work.

 

_________

Building HVAC system isolated form work area.

 

_________

All electrical equipment GFCI protected.

 

_________

Construction of containment substantial enough so that integrity is not likely to be  breached throughout the duration of the job.

 

_________

Negative pressure 0.02 inches of water or greater achieved. (i.e., static  pressure gauge reading and evidence of plastic sheeting pulled in).

 

_________

Perform smoke tube test of NPE and glove bag using non irritating tubes?

 

_________

Manometer used to measure negative pressure installed, properly zeroed, works, and will provide a useful printout. Keep copy of printout for our building file.

 

_________

Entrances posted with “Danger Asbestos” signs, access restricted by barricade tape and or other means.

 

_________

Coordinate with night shift PMTs to check integrity of containment throughout the night shift or weekend / holidays. Give them your pager, cell, home contact info in case of emergency.

 

_________

For RACM, BAAQMD notification in place and a copy obtained for our records?

 

_________

For small RACM jobs (<100 sq. or linear feet) remember to obtain copy of subcontractor’s cost proposal that describes the type and amount of RACM to be removed for our annual cumulative BAAQMD notification purposes and file with asbestos program manager separately and place in building file.

 

_________

Negative air machines and vacuums tested and copy of documentation obtained for our records.

 

_________

Building manager notified of the work and the building entrances and immediate work area posted with asbestos work notification? Keep copy of posting for our building file.

 

_________

Site specific work plan written, approved and a copy obtained for our building file?

 

_________

Glove bag jobs performed inside a NPE?

 AIR SAMPLING

 

 

_________

Representative personal exposure monitoring of employees performing abatement?

 

_________

Personal air sampling pumps on, calibrated before and after use, times recorded?

 

_________

Equipment removed from the containment before clearance samples collected?

 

_________

Remind subcontractor to turn in two blanks.

RESPIRATORY PROTECTION

 

 

_________

Respiratory protection adequate (half-mask respirators with HEPA  cartridges for most jobs except TSI and surfacing material or work performed by contractors we are not familiar with) for the type of work?

 

_________

Employees trained and fit tested to wear respiratory protective equipment?

 

_________

Documentation of fit-test and medical approval at the worksite and copies obtained for our records?

PROTECTIVE WORK CLOTHING AND EQUIPMENT

_________

Protective clothing, such as disposable head covering, foot covering, coveralls used in the regulated area?

_________

Contaminated clothing placed in labeled asbestos disposal bags?

 

_________

Decontamination facilities (e.g., hand washing, showers) adequate for the scope of work

TRAINING

 

 

 

_________

Are employees properly trained for the type of work they are performing, as specified by OSHA?

 

_________

Documentation of AHERA training at the worksite and copies obtained for our records?

 

_________

Is there an AHERA contractor/supervisor onsite (FULL TIME)?

 

_________

Employees all have GERT training? (Need to check training database or preferably they will provide a copy record w/ other submittals)

ASBESTOS WASTE

 

 

_________

Waste Management notified of the project?

 

_________

Loose asbestos kept wet and cleaned up as soon as possible? All material must be cleaned-up by the end of each work shift.

 

_________

Waste and asbestos contaminated materials collected, kept wet, and placed in properly labeled 6-mil plastic bags or hazardous waste containers?

 

_________

Waste bags and containers removed from containment before clearance sample collected?

COMMENTS        
__________________________________________________________________________
__________________________________________________________________________
__________________________________________________________________________
__________________________________________________________________________


 

_____________________

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