2016-04-25_Proj_002-490L_Bridge_Lead_Paint_Testing_Report_w_Attachments.pdf

Mold Indoor Air Quality Asbestos Environmental Consulting

INDOOR/OUTDOOR

ENVIRONMENTAL, LLC

1632 Colorado Gulch Helena, Montana 59601

Phone: 406/439-1247 Fax: 406/442-6335

Email: frantz.rp@gmail.com April 25, 2016

Seth English-Young Environmental Specialist Federal Highway Administration Western Federal Lands 610 East Fifth Street Vancouver, WA 98661 Tel: 360-619-7803

RE: Lead-Based Paint Testing Report

FHWA-WFLHD Projects: MT SWEETGRASS 210(1) Two Mile Creek Bridge, MT DOT 569(3) California Creek Bridge Indoor/Outdoor Environmental Project No. 002-490

Dear Mr. English-Young:

This report transmits the findings from a limited Lead-Based Paint (LBP) testing performed by Indoor/Outdoor Environmental’s (henceforth, “I/O’s”) Environmental Scientist and Accredited Asbestos Inspector Robert Frantz for the above-referenced sites on April 14 and 15, 2016. The testing was limited to the two above referenced bridges. The testing was requested by Mr.

English-Young, with the Federal Highway Administration, Western Federal Lands based in Vancouver, WA.

Testing was conducted using 3M LeadCheck Swabs, off the shelf products that are advertised to be EPA recognized lead indicator tests. The LeadCheck swabs produce a red or pinkish color when activated and put into contact with paint containing “hazardous levels of lead.”

In addition, two paint chip samples of a black coating were shipped to a laboratory and analyzed for the presence of lead, and were found to exceed the EPA Lead-Based Paint threshold of 0.5%.

The tested painted surface descriptions, locations and indicator or laboratory analytical results are summarized in Tables 1 and 2, photographs of the indicator tests are in Attachment 1, and the laboratory report (for 2 paint chip samples) and sample chain of custody are in Attachment 2.

FINDINGS AND CONCLUSIONS

I/O concludes that Lead was detected in tests of painted surfaces on the subject structures, and Lead Abatement or appropriate precautions are warranted when demolishing and disposing of these structures, which include:

o MT Sweetgrass 910(1) Two Mile Creek Bridge; and o MT DOT 569(3) California Creek Bridge.

Lead-Based Paint Testing Report FHWA-WFLHD Projects: MT SWEETGRASS 210(1) Two Mile Creek Bridge, MT DOT 569(3) California Creek Bridge

Indoor/Outdoor Environmental, LLC

FHWA-WFLHD Project No: MT Sweetgrass 910(1) Two Mile Creek Bridge Indoor/Outdoor Environmental Project No. 002-490.3L

TEST FINDINGS

The subject structure is a steel truss bridge for the main truss span supported by 2 concrete pedestal abutments at each end, with two wood timber framed ramps at each end, abutments under the ramps consisting of concrete piers (6) against wood timbers, with exposed wood under intermittent steel plates, wooded rails and posts (Photographs 1 through 18).

Lead tests were positive for nearly type of every painted surface tested on the subject bridge

(see summary Table 1):

o LBP1.A and B: Silver Paint over Orange Primer on Steel Bridge Original Components:

Test Locations: Ends of Truss Top Chords.

Surfaces include: Steel Beams, Channel, Bars, etc., Rivets, Bolts, Nuts; Silver Paint over Orange Primer appears to be the original paint on original components.

Tested Positive for Lead.

Photographs 2 and 3.

o LBP2.A and B: Dull Grey Paint on Steel Bridge Replacement Components:

Test Locations: Diagonals on North and South Trusses.

Surfaces include: Replacement parts bolted in place, Diagonals and Plates, etc., Bolts, Nuts; Apparently Replacement Components.

Photographs 4, 5, 6 and 7.

o LBP3.A and B: White Paint on Wood Rail Posts

Test Locations: Ends of Trusses.

Surfaces include: White Paint on Wood Posts;

Photographs 8, 9 and 10.

o LBP4.A and B: Silver Paint over Orange Primer on Steel Beams:

Test Location: East and West end Beams.

Photographs 11 and 12.

o LBP5.A and B: Grey Paint on Steel Channels attached to Beams:

Test Locations: Steel Channel Bolted to Original East and West Beams.

Weak Reaction, Indeterminate to Likely Lead Present.

Photographs 13, 14, 15, and 16.

o LBP6.A and B: Black Coating on Wooden Rail Posts:

Sample Locations: Near West Ends of North and South Trusses.

MT DOT 569(3) California Creek Bridge

Black Coating on the Lower 30-inches of Original or Older Rail Posts (Replacements are Pressure-treated).

Two samples indicated the coating is Positive for Lead (Pb), 8.9% and 1.3% Pb by Weight.

Photographs 17 and 18.

TEST CONCLUSIONS

I/O concludes that potentially hazardous concentrations of lead are present in nearly all painted surfaces in the bridge.

o Lead tests were positive for nearly type of every painted surface tested on the subject bridge.

o Some degree of lead abatement will be necessary to remove the bridge, primarily on steel components, even if the steel is recycled.

o Samples of painted wood and other wood demolition waste components should be collected and analyzed using the Toxicity Characteristic Leaching Procedure (TCLP) to determine whether the material could leach high concentrations of hazardous chemicals. If leachable lead is present above the TCLP threshold of 5.0 milligrams per liter (mg/L), the material must be managed as a hazardous waste.

I/O suspects the TCLP would not exceed the 5 mg/L threshold, so painted wood components could be disposed of along with other non-painted wood components as non-hazardous waste.

ABATEMENT RECOMMENDATIONS

I/O recommends removing the bridge from the site and conducting minimal lead abatement activities necessary to break down the bridge to pieces small enough to be transported to a recycler.

o If feasible, the bridge could be lifted by a crane and moved to a work area away from the river.

o The bridge could be dismantled by cutting structural components such as truss chords and beams with shears, saws or cutting torches, or by dismantling into smaller pieces by rivet busting or removal of nuts and bolts.

Minimal lead abatement would be necessary to remove swathes of paint from cut locations, or to remove paint from over and around rivets and bolts.

Prior to transport, workers should remove all loose and flakey paint from the entire structure.

o Recycling is recommended because the cost of complete abatement of steel components would very likely exceed the benefit of salvaging the steel for use as structural components.

MT DOT 569(3) California Creek Bridge

Given the current condition of the bridge, with numerous replaced parts and steel channel bolted to the beams, the steel components are likely not useful as replacement structural parts for other structures.

o A TCLP sample of painted wood and other wood demolition waste components should be collected. If leachable lead is below the TCLP threshold of 5.0 mg/L, the material can be disposed of as non-hazardous waste.

o A generic Lead Abatement Spec sheet is attached (Attachment 3).

ABATEMENT COST ESTIMATE

Mr. Frantz discussed lead abatement costs for the subject bridge with three lead abatement contractors, and learned it is very difficult to develop a cost estimate because so many factors that drive costs are not specified.

o The bridge removal plan or approach is not known, nor is the location of any associated abatement work.

If the bridge is moved to a convenient location close to workers, abatement unit costs could range from $4 to $6 per square foot for wood components, while costs for lead paint abatement on steel at a remote site could be in the $100 to $250 per square foot range.

Set-up costs (containment, deployment, etc.) could be very high if the abatement is conducted in place or at a remote location.

If the bridge will be recycled, only a small amount of abatement would be necessary to cut the bridge into small enough pieces to haul over the road.

o Mr. Frantz spoke with a lead abatement contractor who happens to be very familiar with the bridge (he keeps a cabin located immediately adjacent to the bridge).

He estimated the cost would not exceed $30,000 if the bridge could be lifted by a crane and moved to a secure location nearby, where it could be contained and worked on for what he estimated would be a 4-week period.

He estimated the cost would be significantly greater if the bridge was abated in place.

He estimated the cost would be significantly lower if the bridge was only abated enough to cut into sections that could be trailered to a recycler.

He stated he was confident the wood components would pass the TCLP criteria and could be land filled as non-hazardous waste.

o Mr. Frantz spoke with a lead abatement contractor who has recently conducted bridge abatement projects.

He estimated the cost with travel, lodging, lifts, trucking, hauling of metal to a recycler in Billings, Montana, blood lead level testing, etc., would be around $23,780.00.

MT DOT 569(3) California Creek Bridge

I/O recommends developing a request for proposals for complete bridge removal, to include all necessary components including removal of the bridge, lead abatement dismantling and transportation to a recycler, or any other options.

o A generic Lead Abatement Spec sheet is attached (Attachment 3).

FHWA-WFLHD Project No: MT DOT 569(3) California Creek Bridge Indoor/Outdoor Environmental Project No. 002-490.5

TEST FINDINGS

The subject structure is a wood timber framed bridge with wood piers and abutments, with an asphalt road surface over a wooden deck, wood rails and posts (Photographs 19 through 24).

The only painted surfaces were the Rails: Lead tests were positive for some Rail components, the posts, and were negative for others, the horizontal Rails (see summary Table 2):

o LBP1.A: White Paint on Wood Rail Post:

Test Location: North side of the Post at the north end of the East Rail.

Photograph 20.

o LBP1.B and C: White Paint on Wood Rails (horizontals):

Test Locations: West sides of the East and West Rails.

Tested Negative for Lead.

Photographs 21, 22, and 23.

TEST CONCLUSIONS

I/O concludes that potentially hazardous concentrations of lead are present in paint on rail posts, while the horizontal rails appear to be painted with non-lead-based paint.

o A lead test conducted on a rail post painted white was positive for lead, while 2 negative tests for lead at locations on painted horizontal rails.

o Samples of painted wood and other wood demolition waste components should be collected and analyzed using the Toxicity Characteristic Leaching Procedure (TCLP) to determine whether the material could leach high concentrations of hazardous chemicals. If leachable lead is present above the TCLP threshold of 5.0 milligrams per liter (mg/L), the material must be managed as a hazardous waste.

I/O suspects the TCLP would not exceed the 5 mg/L threshold, so painted wood components could be disposed of along with other non-painted wood components as non-hazardous waste.

ABATEMENT RECOMMENDATIONS AND COST ESTIMATE

In the unlikely event the TCLP threshold is exceeded, the rail posts could be unbolted, removed and delivered to an abatement contractor’s who could remove the paint for roughly $4 per square foot, according to one local contact.

MT DOT 569(3) California Creek Bridge o The cost of abating the 16 - 5.5-foot-long, 8x8 inch posts the 4 - 5.5 and at $4 per square feet would be approximately $1800, plus any additional labor and transportation costs to remove and transport the materials.

METHODS AND MATERIALS

LEAD-BASED PAINT TESTING AND SAMPLING METHODS

Testing was conducted using 3M LeadCheck Swabs, off the shelf products that are advertised to be EPA recognized lead indicator tests, which swabs produce a red or pinkish color when activated and put into contact with paint containing “hazardous levels of lead.”

o First, the subject painted area is cleaned, dried and then scraped to expose any buried layers of paint.

o The LeadCheck Swabs are activated by crushing two ampules of reagents inside the swabs, then shaking to mix the reagent.

o The reagent is then squeezed through the porous tip at the end of the swab.

o The swab is then rubbed on the prepared painted area for 30 seconds. Alternatively, the swab can be placed in a plastic bag and squeezed onto paint chips collected from the subject surface.

o If the swab tip and/or test surface turns pink or red, the test is “positive,” indicating “A

HAZARDOUS LEVEL OF LEAD IS PRESENT.”

o If the swab or test area does not show a pink or red color, the test is “negative.” At that time, the swab should be tested to assure the reagent is active by squeezing reagent onto a spot on a confirmation card provided in the kit, which consists of paper containing a small amount of lead that should produce a red or pink color if the swab is active and functioning properly. If card turns red, the swab was indeed active and the negative test result is reliable. If the card does not turn red or pink, replace the swab with a new on and retest the painted surface.

o If Lead Chromate paint is a possibility, a Lead Chromate test may be conducted by placing a swab and paint chips or shavings in a plastic bag and seal, then squeeze reagent on the paint and let sit for 18 hours. If a pink reaction occurs, Lead is present.

I/O collected from two locations bulk samples of paint (“paint chips”) from a black, glossy coating to establish the concentrations of lead in the materials. The paint chip samples were removed from the material, placed in zip-lock bags and shipped to a qualified laboratory for Lead analysis.

o The laboratory report is in Attachment 2, and the locations and Lead concentrations of paints/coatings impacted by the subject project are summarized in Table 1.

MT DOT 569(3) California Creek Bridge o The samples were delivered by air courier for analysis to SanAir Technologies Laboratory, Inc., of Powhatan, VA, an independent American Industrial Hygiene Association (AIHA) accredited laboratory (the laboratory report is in Attachment 1).

The samples were analyzed for Lead content using U.S. EPA Method 7420.

The U.S. Department of Housing and Urban Development (HUD) and the U.S.

Environmental Protection Agency (EPA) define lead-based paint as paint containing greater than 0.5% lead (Pb) by weight.

LEAD-BASED PAINT REGULATION OVERVIEW

Activities related to Lead-Based Paint are regulated by at least two jurisdictions, and the Lead content of paint sold to consumers is regulated by a third jurisdiction:

o EPA and HUD: The U.S. Environmental Protection Agency (EPA) and the U.S.

Department of Housing and Urban Development (HUD) define Lead-Based Paint as paint containing greater than 0.5% lead by weight.

When workers impact lead-based paint, EPA requires the use of Lead-safe practices and other actions to prevent exposures that can cause Lead poisoning.

EPA regulates disposal of lead-containing wastes, such as surfaces with Lead-

Based Paint, under the Resource Conservation and Recovery Act (RCRA). RCRA requires demolition debris to be tested using the Toxicity Characteristic Leaching Procedure (TCLP) to determine whether the material could leach high concentrations of hazardous chemicals. If leachable lead is present above the TCLP threshold of 5.0 milligrams per liter (mg/L), the material must be managed (disposed

of) as a hazardous waste.

HUD requires inspections and certain corrective actions under certain conditions for structures with Lead-Based Paint that are occupied by children.

o OSHA: Any construction-type activity that may disturb a surface with detectable lead (at any concentration) must be performed in accordance with the (U.S. Department of Labor) Occupational Safety and Health Administration (OSHA) Lead Standard (29 CFR 1926.62).

The OSHA Lead Standard covers activities including renovation, maintenance, repair work, and repainting (other than routine, minor surface prep and repainting where no deteriorated paint is present).

OSHA considers certain tasks to be higher-risk for exposure to Lead, such as demolition, dry manual scraping or sanding, heat gun applications, and abrasive blasting, and requires respiratory protection for workers until air monitoring proves exposures are below the Permissible Exposure Limit (PEL).

OSHA does not define lead paint based on content. Any detectable lead in a paint makes it lead paint for purposes of complying with OSHA regulations to determine worker exposure.

o CPSC: The Consumer Product Safety Commission (CPSC) regulates the concentration of Lead permitted in surface coatings such as paint.

MT DOT 569(3) California Creek Bridge

Under the Consumer Product Safety Improvement Act of 2008, beginning in August 2009, the concentration of detectable Lead permitted in paint and similar surface-coating materials for consumer use was reduced from 600 ppm (0.06%) to 90 ppm (0.009%). Note that a coating can contain up to this amount of Lead and still not be considered a paint that contains Lead.

In addition, materials with detectable amounts of lead must be properly removed and disposed of according to local, state and federal regulations.

LIMITATIONS

This report was prepared at the request of the client, and is based on site observations, interviews, reports, laboratory results of samples collected during this survey, and professional experience. The conclusions and recommendations in this report are professional opinions based solely upon said observations, gathered historical information, experience, and interpretations of laboratory analyses as described in this report.

This report has been prepared to provide information concerning the potential for exposures to the specific materials, or information about site environmental parameters described in this report, and includes observations of activities or processes that were observed during site visits, or gathered from other sources. As such, it is not possible to identify or quantify exposures or environmental parameters other than those specifically addressed during the assessment.

The opinions and recommendations I/O has presented herein are for the exclusive use of the client. The scope of services performed by Indoor/Outdoor Environmental, LLC may not be appropriate to satisfy the needs of other users, and any use or re-use of this document, or the findings presented herein, is at the sole risk of the user.

The opinions presented herein apply to the site conditions existing at the time of the investigation.

Therefore, opinions and recommendations may not apply to future conditions that may exist at the site, which we have not had the opportunity to evaluate. New information, including new information about past conditions, could change the interpretations, conclusions and recommendations presented herein.

The conclusions and recommendations in this report do not carry the weight of law, and are freely offered to the client as professional advice. The client may choose to form other conclusions, or follow courses of action other than those recommended in this report. I/O is not responsible for actions or inactions that result from clients either following or not following recommendations in this report.

I/O did not conduct intrusive or destructive inspecting or sampling at the site, and therefore, I/O cannot draw any firm conclusions regarding the presence, absence, or magnitude of hazardous materials, mold growth, or other risk factors in areas that could not be observed. I/O has made every effort to communicate with clients during the investigation, discuss investigative options, and explain limitations in data or observations in the report. I/O invites clients to provide any

MT DOT 569(3) California Creek Bridge information that might assist in better understanding conditions at the site.

UNCONDITIONAL RELEASE AND LIMITATION OF LIABILITY

The client understands that I/O and the laboratory that analyzed samples are not insurers, and that the inspection and this report shall not be construed as a guarantee or warranty of the adequacy, performance, or condition of any structure, item, or system at the subject property.

The client thereby releases and exempts I/O, the laboratory, and our respective agents and employees of and from all liability and responsibility for the cost of repairing or replacing any unreported defect or deficiency, and for any consequential damage, property damage or personal injury of any nature. In the event that I/O, the laboratory, or our respective agents or employees are found liable due to breach of contract, breach of warranty, negligent misrepresentation, negligent hiring or any other theory of liability, then the cumulative aggregate total liability of us, the laboratory, and our respective agents and employees shall be limited to a sum equal to the amount of the fee paid by you for the inspection and report.

We trust this report meets your requirements at this time. Please feel free to contact us to discuss this report, or if we can be of further assistance. We would be happy to assist you further on this project, at your request.

Respectfully Submitted, Robert P. Frantz Certified Lead Inspector: Certificate #: RGA CLI-10-0003

Tables 1 & 2: Summaries of Lead Test Results

Attachment 1: Site Photographs

Attachment 2: Lead-Based Paint Sample Laboratory Report

Attachment 3: Generic Lead Abatement Project Specification

Indoor/Outdoor Environmental, LLC Page

ATTACHMENT 1: SITE PHOTOGRAPHS

Photograph 1: View of the east end of the south truss on the Two Mile Creek Bridge, showing the location of test LBP1.A.

Photograph 2: Close up view of test LBP1.A, which indicates the paint is Positive for Lead.

Photograph 3: Close up view of test LBP1.B, which indicates the paint is Positive

Photograph 4: View near the west-center of the north truss on the Two Mile Creek Bridge, showing the location of test LBP2.A.

Photograph 5: Two Mile Creek Bridge: Close up view of test LBP2.A; The pink color indicates the paint is Positive for Lead.

Photograph 6: Two Mile Creek Bridge: Test location LBP2.A on a replacement diagonal (left), next to an original diagonal with silver paint (right).

Photograph 7: Two Mile Creek Bridge: Close up view of test location LBP2.B, from a diagonal near the east end of the south truss; The pink indicates Positive

Photograph 8: Two Mile Creek Bridge: Close up view of test location LBP3.A, where paint chips were removed from white paint on a wood rail post near the east end on the north-facing side of the south truss.

Photograph 9: Two Mile Creek Bridge: Close up view of test location LBP3.A, where paint chips were removed from white paint on a wood rail post near the west end on the south-facing side of the north truss.

Photograph 10: Two Mile Creek Bridge: Test for chips from locations LBP3.A and LBP3.B showing pink reactions with the white paint chips indicating Positive for Lead.

Photograph 11: Two Mile Creek Bridge: Test for location LBP4.A on the north end of the east beam over the east abutment, showing pink reaction with the paint indicating Positive for Lead.

Photograph 12: Two Mile Creek Bridge: Test for location LBP4.B on the south end of the west beam over the west abutment, showing pink reaction with the paint indicating Positive for Lead.

Photograph 13: Two Mile Creek Bridge: Test for location LBP5.A in the center of a beam sistered to the east beam over the east abutment, showing little to no reaction with the paint suggesting Negative for Lead. Lead Chromate Test Conducted.

Photograph 14: Two Mile Creek Bridge: Test for location LBP5.B on the south end of the west beam over the west abutment, showing little reaction with the paint suggesting possibly positive for Lead. Lead Chromate Test Conducted.

Photograph 15: Two Mile Creek Bridge: Confirmation tests for locations LBP5.A and LBP5.A confirming that the reagents had properly activated for both swabs.

Photograph 16: Two Mile Creek Bridge: Lead Chromate Test results for LBP5.A and LBP5.B. The test for location LBP5.B had a slightly pinkish color, suggesting a reaction indicating the presence of Lead.

Photograph 17: Two Mile Creek Bridge: Sample LBP6.A, Black coating, was removed from this damaged post near the west end of the north truss. The lab detected a Lead concentration of 8.9% Lead by weight in the material.

Photograph 18: Two Mile Creek Bridge: Location for sample LBP6.B, at the west end of the south truss. The lab detected a Lead concentration of 1.3% Lead by weight in the material.

Photograph 19: View of the California Creek Bridge looking north, showing the white rails and posts on the east side of the bridge.

Photograph 20: California Creek Bridge: Location of test LBP1.A on the north side of the northeast end Rail Post (photo is rotated 90% to the right), showing a pink reaction with the paint indicating Positive for Lead.

Photograph 21: California Creek Bridge: Test location LBP1.B on the west side of the upper west rail, showing no reaction after being swabbed, suggesting the paint is Negative for Lead.

Photograph 22: California Creek Bridge: The strong pink reaction to the confirmation sheet (bright pink circle) confirms the swab was active, suggesting the paint is Negative for Lead.

Photograph 23: California Creek Bridge: Test location LBP1.C, near the center of the west side of the east rail, showing not reaction, suggesting the paint is Negative for Lead.

Photograph 24: California Creek Bridge: Test location LBP1.C, center of the west side of the east rail. The strong pink reaction to the confirmation sheet (bright pink circle), confirms the swab is active suggesting the paint is Negative for Lead.

ATTACHMENT 2: LEAD-BASED PAINT SAMPLE LABORATORY REPORTS

SanAir Technologies LaboratorySanAir Technologies Laboratory

Analysis Report prepared for

Indoor Outdoor Environmental, LLC

Report Date: 4/19/2016 Project Name: Two Mile Bridge Project #: 002-490.3 SanAir ID#: 16012787

804.897.1177 www.sanair.com804.897.1177 www.sanair.com

SanAir Technologies Laboratory, Inc.

1551 Oakbridge Drive, Suite B, Powhatan, VA 23139

804.897.1177 Toll Free: 888.895.1177 Fax: 804.897.0070

Web: http://www.sanair.com E-mail: iaq@sanair.com

Indoor Outdoor Environmental, LLC 1632 Colorado Gulch Drive Helena, MT 59601

April 19, 2016

SanAir ID # 16012787 Project Name: Two Mile Bridge Project Number: 002-490.3

Dear Robert Frantz, We at SanAir would like to thank you for the work you recently submitted. The 2 sample(s) were received on Monday, April 18, 2016 via FedEx. The final report(s) is enclosed for the following sample(s): LBP6.A, LBP6.B.

These results only pertain to this job and should not be used in the interpretation of any other job.

This report is only complete in its entirety. Refer to the listing below of the pages included in a complete final report.

Sincerely, SanAir Technologies Laboratory

Final Report Includes:

- Cover Letter

- Analysis Pages

- Disclaimers and Additional Information sample conditions:

2 sample(s) in Good condition

SanAir Technologies Laboratory, Inc.

1551 Oakbridge Drive, Suite B, Powhatan, VA 23139

804.897.1177 Toll Free: 888.895.1177 Fax: 804.897.0070

Web: http://www.sanair.com E-mail: iaq@sanair.com

Name:

Address:

Indoor Outdoor Environmental, LLC 1632 Colorado Gulch Drive Helena, MT 59601

Project Number:

P.O. Number:

Project Name:

002-490.3

Two Mile Bridge

Collected Date:

Received Date:

Report Date:

Analyst:

4/14/2016

4/18/2016 8:50:00 AM

4/19/2016 8:37:02 AM

Peterson, Chelsea

Lead Paint Analysis Test Method: SW846/3050B/7000B NOTE: µg/g=ppm Sample Description µg Pb Sample Calculated Sample Sample in Sample Size (grams) RL Result Result

16012787-001 LBP6.A / Coating On 9689 0.1091 91.7 88807.9 8.8808 % By Weightµg/g (ppm)

Corner 30 Inches Of Rail Posts

Test Method: SW846/3050B/7000B NOTE: µg/g=ppm Sample Description µg Pb Sample Calculated Sample Sample in Sample Size (grams) RL Result Result

16012787-002 LBP6.B / Coating On 1380 0.1041 96.1 13256.4 1.3256 % By Weightµg/g (ppm)

Corner 30 Inches Of Rail Posts

Method Reporting Limit <10 µg/0.1 g paint SanAir Technologies Laboratory, Inc participates in the AIHA ELPAT for environmental Lead.

AIHA Lab Id: 162952

16012787 SanAir ID Number

FINAL REPORT

Certification

Signature: Reviewed:

Date: 4/18/2016 Date: 4/18/2016 Page 1 of 1

Revision Date 10/25/2012 Page 1 of 1

Disclaimer

Results relate only to the items tested

Results are not corrected for blanks

All quality control results are acceptable unless otherwise noted

SanAir Technologies Laboratory, Inc is not responsible for sample collection or interpretation made by others

This report does not constitute endorsement by AIHA/NVLAP and/or any other U.S. governmental Agencies; and may not be certified by every local, state or federal regulatory agencies

Lead Exposure Limits

Air

1.5 µg/m3 EPA National Ambient Air Quality Standard (Quality Time – Weight Average) 30 µg/m3 OSHA Action Level (8-hour time weighted average) 50 µg/m3 OSHA Permissible Exposure Limit (General Industry) 50 µg/m3 OSHA Permissible Exposure Limit (Construction)

Dust

40 µg/ft2 HUD Clearance Level for Floors 250 µg/ft2 HUD Clearance Level for Interior Window Sills 400 µg/ft2 HUD Clearance Level for Window Troughs

Water 15 ppb (µg/liter) EPA Maximum Containment Level

Paint 0.5% by weight HUD definition of lead based paint

1.0 mg/cm2 5000 ppm

Soil 400 ppm HUD-Play areas and high-contact areas for children

Hazardous Waste 5 ppm Analyzed as “leachable” using Toxicity Characteristic Leachate Procedure (TCLP)

ATTACHMENT 3: GENERIC LEAD ABATEMENT PROJECT SPECIFICATION

SECTION 00

LEAD-PAINT REMOVAL

PART 1 - GENERAL

1.1 DESCRIPTION

This section specifies abatement and disposal of lead-based paint

(LBP) and controls needed to limit occupational and environmental exposure to lead hazards.

1.2 RELATED WORK

A. Section 01569, TRADITIONAL ASBESTOS ABATEMENT.

B. Section 02050, DEMOLITION.

C. Section 09900, PAINTING.

1.3 APPLICABLE PUBLICATIONS

A. The publications listed below form a part of this specification to the extent referenced. The publications are referred to in the text by basic designation only.

B. CODE OF FEDERAL REGULATIONS (CFR)

CFR 29 Part 1910........Occupational Safety and Health Standards

CFR 29 Part 1926........Safety and Health Regulations for

Construction

CFR 40 Part 148.........Hazardous Waste Injection Restrictions

CFR 40 Part 260.........Hazardous Waste Management System:

General

CFR 40 Part 261.........Identification and Listing of Hazardous

Waste

CFR 40 Part 262.........Standards Applicable to Generators of

Hazardous Waste

CRF 40 Part 263.........Standards Applicable to Transporters of

Hazardous Waste

CFR 40 Part 264.........Standards for Owners and Operations of

Hazardous Waste Treatment, Storage, and

Disposal Facilities

CFR 40 Part 265.........Interim Status Standards for Owners and

Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities

CFR 40 Part 268.........Land Disposal Restrictions

CFR 49 Part 172.........Hazardous Material Table, Special

Provisions, Hazardous Material

Communications, Emergency Response

Information, and Training Requirements

CFR 49 Part 178.........Specifications for Packaging

C. National Fire Protection Association (NFPA):

NFPA 701-1999...........Methods of Fire Test for Flame-Resistant

Textiles and Films

D. National Institute For Occupational Safety And Health (NIOSH)

NIOSH OSHA Booklet 3142.Lead in Construction

E. Underwriters Laboratories (UL)

UL 586-1996.............High-Efficiency, Particulate, Air Filter

Units

F. American National Standards Institute

Z9.2-1979 (R1991).......Fundamentals Governing the Design and

Operation of Local Exhaust Systems

Z88.2-1992..............Respiratory Protection

1.4 DEFINITIONS

A. Action Level:

Employee exposure, without regard to use of respirations, to an airborne concentration of lead of 30 micrograms per cubic meter of air averaged over an 8-hour period. As used in this section,”30 micrograms per cubic meter of air" refers to the action level.

B. Area Monitoring:

Sampling of lead concentrations within the lead control area and inside the physical boundaries which is representative of the airborne lead concentrations which may reach the breathing zone of personnel potentially exposed to lead.

C. Physical Boundary:

Area physically roped or partitioned off around an enclosed lead control area to limit unauthorized entry of personnel. As used in this section, "inside boundary" shall mean the same as "outside lead control area."

D. Certified Industrial Hygienist (CIH):

As used in this section, refers to an Industrial Hygienist employed by the Contractor and is certified by the American Board of Industrial Hygiene in comprehensive practice.

E. Change Rooms and Shower Facilities:

Rooms within the designated physical boundary around the lead control area equipped with separate storage facilities for clean protective work clothing and equipment and for street clothes which prevent cross- contamination.

F. Competent Person:

A person capable of identifying lead hazards in the work area and is authorized by the contractor to take corrective action.

G. Decontamination Room:

Room for removal of contaminated personal protective equipment

(PPE).

H. Eight-Hour Time Weighted Average (TWA):

Airborne concentration of lead averaged over an 8-hour workday to which an employee is exposed.

I. High Efficiency Particulate Air (HEPA) Filter Equipment:

HEPA filtered vacuuming equipment with a UL 586 filter system capable of collecting and retaining lead-contaminated paint dust.

A high efficiency particulate filter means 99.97 percent efficient against 0.3 micron size particles.

J. Lead:

Metallic lead, inorganic lead compounds, and organic lead soaps.

Excluded from this definition are other organic lead compounds.

K. Lead Control Area:

An enclosed area or structure with full containment to prevent the spread of lead dust, paint chips, or debris of lead-containing paint removal operations. The lead control area is isolated by physical boundaries to prevent unauthorized entry of personnel.

L. Lead Permissible Exposure Limit (PEL):

Fifty micrograms per cubic meter of air as an 8-hour time weighted average as determined by 29 CFR 1910.1025. If an employee is exposed for more than 8 hours in a work day, the PEL shall be determined by the following formula. PEL

(micrograms/cubic meter of air) = 400/No. of hrs worked per day

M. Personnel Monitoring:

Sampling of lead concentrations within the breathing zone of an employee to determine the 8-hour time weighted average concentration in accordance with 29 CFR 1910.1025. Samples shall be representative of the employee's work tasks. Breathing zone shall be considered an area within a hemisphere, forward of the shoulders, with a radius of 150 mm to 225 mm (6 to 9 inches) and the center at the nose or mouth of an employee.

1.5 QUALITY ASSURANCE

A. Before exposure to lead-contaminated dust, provide workers with a comprehensive medical examination as required by 29 CFR 1926.62

(I) (1) (i) & (ii). The examination shall not be required if adequate records show that employees have been examined as required by 29 CFR 1926.62(I) without the last year.

B. Medical Records:

Maintain complete and accurate medical records of employees in accordance with 29 CFR 1910.20.

C. CIH Responsibilities:

The Contractor shall employ a certified Industrial Hygienist who will be responsible for the following:

1. Certify Training.

2. Review and approve lead-containing paint removal plan for conformance to the applicable referenced standards.

3. Inspect lead-containing paint removal work for conformance with the approved plan.

4. Direct monitoring.

5. Ensure work is performed in strict accordance with specifications at all times.

6. Ensure hazardous exposure to personnel and to the environment are adequately controlled at all times.

D. Training:

Train each employee performing paint removal, disposal, and air sampling operations prior to the time of initial job assignment, in accordance with 29 CFR 1926.62.

E. Training Certification:

Submit certificates signed and dated by the CIH and by each employee stating that the employee has received training.

F. Respiratory Protection Program:

1. Furnish each employee required to wear a negative pressure respirator or other appropriate type with a respirator fit test at the time of initial fitting and at least every 6 months thereafter as required by 29 CFR 1926.62.

2. Establish and implement a respiratory protection program as required by 29 CFR 1910.134, 29 CFR 1910.1025, and 29 CFR

1926.62.

G. Hazard Communication Program:

Establish and implement a Hazard Communication Program as required by 29 CFR 1910.1200.

H. Hazardous Waste Management:

The Hazardous Waste Management plan shall comply with applicable requirements of Federal, State, and local hazardous waste regulations and address.

1. Identification of hazardous wastes associated with the work.

2. Estimated quantities of wastes to be generated and disposed of.

3. Names and qualifications of each contractor that will be transporting, storing, treating, and disposing of the wastes.

Include the facility location and a 24-hour point of contact.

Furnish two copies of EPA hazardous waste permits and EPA

Identification numbers.

4. Names and qualifications (experience and training) of personnel who will be working on-site with hazardous wastes.

5. List of waste handling equipment to be used in performing the work, to include cleaning, volume reduction, and transport equipment.

6. Spill prevention, containment, and cleanup contingency measures to be implemented.

7. Work plan and schedule for waste containment, removal and disposal. Wastes shall be cleaned up and containerized daily.

8. Cost for hazardous waste disposal according to this plan.

I. Safety and Health Compliance

1. In addition to the detailed requirements of this specification, comply with laws, ordinances, rules, and regulations of federal, state, and local authorities regarding removing, handling, storing, transporting, and disposing of lead waste materials. Comply with the applicable requirements of the current issue of 29 CFR 1910.1025. Submit matters regarding interpretation of standards to the Contracting

Officer for resolution before starting work.

2. Where specification requirements and the referenced documents vary, the most stringent requirements shall apply.

3. Follow local laws, ordinances, criteria, rules and regulations regarding removing, handling, storing, transporting, and disposing of lead-contaminated materials.

J. Pre-Construction Conference:

Along with the CIH, meet with the Contracting Officer to discuss in detail the lead-containing paint removal work plan, including work procedures and precautions for the work plan.

1.6 SUBMITTALS

A. Submit the following in accordance with Section 01340, SAMPLES

AND SHOP DRAWINGS.

B. Manufacturer's Catalog Data:

Vacuum filters

Respirators

C. Instructions:

Paint removal materials. Include applicable material safety data sheets.

D. Statements Certifications and Statements:

1. Qualifications of CIH

Submit name, address, and telephone number of the CIH selected to perform responsibilities in paragraph entitled "CIH

Responsibilities." Provide previous experience of the CIH.

Submit proper documentation that the Industrial Hygienist is certified by the American Board of Industrial Hygiene in comprehensive practice, including certification number and date of certification/recertification.

2. Testing Laboratory

Submit the name, address, and telephone number of the testing laboratory selected to perform the monitoring, testing, and reporting of airborne concentrations of lead. Provide proper documentation that persons performing the analysis have been judged proficient by successful participation within the last year in the National Institute for Occupational Safety and

Health (NIOSH) Proficiency Analytical Testing (PAT) Program.

The laboratory shall be accredited by the American Industrial

Hygiene Association (AIHA). Provide AIHA documentation along with date of accreditation/reaccreditation.

3. Lead-Containing Paint Removal Plan

a. Submit a detailed job-specific plan of the work procedures to be used in the removal of lead-containing paint. The plan shall include a sketch showing the location, size, and details of lead control areas, location and details of decontamination rooms, change rooms, shower facilities, and mechanical ventilation system.

b. Include in the plan, eating, drinking, smoking and restroom procedures, interface of trades, sequencing of lead related work, collected wastewater and paint debris disposal plan, air sampling plan, respirators, protective equipment, and a detailed description of the method of containment of the operation to ensure that airborne lead concentrations of 30 micrograms per cubic meter of air are not exceeded outside of the lead control area.

c. Include air sampling, training and strategy, sampling methodology, frequency, duration of sampling, and qualifications of air monitoring personnel in the air sampling portion on the plan.

4. Field Test Reports

Monitoring Results: Submit monitoring results to the

Contracting Officer within 3 working days, signed by the testing laboratory employee performing the air monitoring, the employee that analyzed the sample, and the CIH.

5. Records:

a. Completed and signed hazardous waste manifest from treatment or disposal facility

b. Certification of Medical Examinations

c. Employee training certification

PART 2 PRODUCTS

PAINT REMOVAL PRODUCTS: Submit applicable Material Safety Data

Sheets for paint removal products used in paint removal work. Use the least toxic product, suitable for the job and acceptable to the Industrial Hygienist.

PART 3 EXECUTION

3.1 PROTECTION

A. Notification

Notify the Contracting Officer 10 days prior to the start of any paint removal work.

B. Lead Control Area Requirements

1. Establish a lead control area by completely enclosing with containment screens the area or structure where lead-containing paint removal operations will be performed.

2. Contain removal operations by the use of a negative pressure full containment system with at least one change room and with

HEPA filtered exhaust.

C. Protection of Existing Work to Remain

Perform paint removal work without damage or contamination of adjacent areas. Where existing work is damaged or contaminated, restore work to its original condition.

D. Boundary Requirements

Provide physical boundaries around the lead control area by roping off the area [designated on the drawings] or providing curtains, portable partitions or other enclosures to ensure that airborne concentrations of lead will not reach 30 micrograms per cubic meter of air outside of the lead control area.

E. Heating, Ventilating and Air Conditioning (HVAC) Systems

Shut down, lock out, and isolate HVAC systems that supply, exhaust, or pass through the lead control areas. Seal intake and exhaust vents in the lead control area with 6-mil plastic sheet and tape. Seal seams in HVAC components that pass through the lead control area. Coordinate with Federal Highway

Administration and mechanical contractor to ensure the HVAC system is not affected in occupied areas. (The removal of lead containing window components is to be accomplished from the outside of the buildings. Critical barriers will be installed at the window openings so the HVAC will not be affected. If due to accessibility issues removal is conducted from the inside, then the HVAC will need to be addressed and arrangements made to ensure HVAC service is not disrupted in occupied areas).

F. Change Room and Shower Facilities:

Provide clean change rooms and shower facilities within the physical boundary around the designated lead control area in accordance with requirements of 29 CFR 1926.62.

G. Mechanical Ventilation System:

1. Use adequate ventilation to control personnel exposure to lead in accordance with 29 CFR 1926.57.

2. To the extent feasible, use fixed local exhaust ventilation connected to HEPA filters or other collection systems, approved by the industrial hygienist. Local exhaust ventilation systems shall be designed, constructed, installed, and maintained in accordance with ANSI Z9.2.

3. If air from exhaust ventilation is recirculated into the work place, the system shall have a high efficiency filter with reliable back-up filter and controls to monitor the concentration of lead in the return air and to bypass the recirculation system automatically if it fails. Air may be recirculated only where exhaust to the outside is not feasible.

H. Personnel Protection:

Personnel shall wear and use protective clothing and equipment as specified herein. Eating, smoking, or drinking is not permitted in the lead control area. No one will be permitted in the lead control area unless they have been given appropriate training and protective equipment.

I. Warning Signs:

Provide warning signs at approaches to lead control areas. Locate signs at such a distance that personnel may read the sign and take the necessary precautions before entering the area. Signs shall comply with the requirements of 29 CFR 1926.62.

3.2 WORK PROCEDURES

A. Perform removal of lead-containing paint in accordance with approved lead-containing paint removal plan. Use procedures and equipment required to imit occupational and environmental exposure to lead when lead- containing paint is removed in accordance with 29 CFR 1926.62, except as specified herein.

Dispose of removed paint chips and associated waste in compliance with Environmental Protection Agency (EPA), federal, state, and local requirements.

B. Personnel Exiting Procedures:

1. Whenever personnel exist the lead-controlled area, they shall perform the following procedures and shall not leave the work place wearing any clothing or equipment worn during the work day:

a. Vacuum themselves off.

b. Remove protective clothing in the decontamination room, and place them in an approved impermeable disposal bag.

c. Shower.

d. Change to clean clothes prior to leaving the physical boundary designated around the lead-contaminated job site.

C. Monitoring: Monitoring of airborne concentrations of lead shall be in accordance with 29 CFR 1910.1025 and as specified herein.

Air monitoring, testing, and reporting shall be performed by a

CIH or an Industrial Hygiene (IH) Technician who is under the direction of the CIH:

1. The CIH or the IH Technician under the direction of the CIH shall be on the job site directing the monitoring, and inspecting the lead-containing paint removal work to ensure that the requirements of the Contract have been satisfied during the entire lead-containing paint removal operation.

2. Take personal air monitoring samples on employees who are anticipated to have the greatest risk of exposure as determined by the CIH. In addition, take air monitoring samples on at least 25 percent of the work crew or a minimum of two employees, whichever is greater, during each work shift.

3. Submit results of air monitoring samples, signed by the CIH, within 36 hours after the air samples are taken. Notify the

Contracting Officer immediately of exposure to lead at or in excess of the action level of 30 micrograms per cubic meter of air outside of the lead control area.

D. Monitoring During Paint Removal Work:

1. Perform personal and area monitoring during the entire paint removal operation. Sufficient area monitoring shall be conducted at the physical boundary to ensure unprotected personnel are not exposed above 30 micrograms per cubic meter of air at all times. If the outside boundary lead levels are at or exceed 30 micrograms per cubic meter of air, work shall be stopped and the CIH shall immediately correct the condition(s) causing the increased levels and notify the

Contracting Officer immediately.

2. The CIH shall review the sampling data collected on that day to determine if condition(s) requires any further change in work methods. Removal work shall resume when approval is given by the CIH. The Contractor shall control the lead level outside of the work boundary to less than 30 micrograms per cubic meter of air at all times. As a minimum, conduct area monitoring daily on each shift in which lead paint removal operations are performed in areas immediately adjacent to the lead control area.

3.3 LEAD-CONTAINING PAINT REMOVAL

A. Remove paint within the areas designated on the drawings in order to completely expose the substrate. Take whatever precautions are necessary to minimize damage to the underlying substrate.

B. Indoor Lead Paint Removal:

Select paint removal processes to minimize contamination of work areas with lead-contaminated dust or other lead-contaminated debris/waste. This paint removal process should be described in the lead-containing paint removal plan. Perform manual sanding and scraping to the maximum extent feasible.

C. Mechanical Paint Removal and Blast Cleaning:

Perform mechanical paint removal and blast cleaning in lead control areas using negative pressure full containments with HEPA filtered exhaust. Collect paint residue and spent grit (used abrasive) from blasting operations for disposal in accordance with EPA, state and local requirements.

3.4 SURFACE PREPARATIONS

Avoid flash rusting or other deterioration of the substrate.

Provide surface preparations for painting in accordance with

Section 09900, "Painting."

3.5 CLEANUP AND DISPOSAL

A. Cleanup: Maintain surfaces of the lead control area free of accumulations of paint chips and dust. Restrict the spread of dust and debris; keep waste from being distributed over the work area. Do not dry sweep or use compressed air to clean up the area. At the end of each shift and when the paint removal operation has been completed, clean the area of visible lead paint contamination by vacuuming with a HEPA filtered vacuum cleaner and wet mopping the area.

B. Certification: The CIH shall certify in writing that the inside and outside lead control area air monitoring samples are less than 30 micrograms per cubic meter of air, the respiratory protection for the employees was adequate, the work procedures were performed in accordance with 29 CFR 1926.62, and that there were no visible accumulations of lead-contaminated paint and dust on the worksite. Do not remove the lead control area or roped-off boundary and warning signs prior to the Contracting Officer's receipt of the CIH's certification. Reclean areas showing dust or residual paint chips.

C. Testing of Lead-Containing Paint Residue and Used Abrasive Where indicated or when directed by the Contracting Officer, test lead containing paint residue and used abrasive in accordance with 40

CFR 261 for hazardous waste.

D.