Augusta_Savage_Arts_&_Community_Center_Lead_Plan.pdf

Lead Control Plan for Lead-Based Paint Stabilization within the Cafeteria Main Room of the Augusta Savage Arts and Community Center in Green Cove Springs, Florida

Cross Environmental Services, Inc. (CES) 39646 Fig Street Crystal Springs, Florida 33524 813-783-1688

July 18, 2025 http://crossenv.com/ http://crossenv.com/�

Background and Overview

Lead-based paints, coatings and films have been used to protect steel and steel products for many years. These same paints and products have been used as well to coat other building components such as concrete and CMUs.

In the case of paint film stabilization certain coatings have evolved that permit the application of a coating or coating over lead-based films or paints. These special encapsulation coatings will serve to help control exposures to the lead films or coatings beneath.

Plan Goals and Objectives

Protect site workers from lead abatement hazards as per this project Protect the nearby public from lead abatement hazards as per this project Protect the environment from lead abatement hazards and wastes as per this project

Both the Federal Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) have numerous rules, regulations, and standards regarding the handling and abatement of lead containing films and coatings on structural steel as well as other materials.

OSHA in particular has detailed some practices that are forbidden as to the removal of lead films and coatings, such as direct burning on lead by open flame torch or by uncontrolled abrasive blasting. These methods are known to produce high airborne lead exposures to project employees and in certain cases even the general public.

These methods and processes are not part of this plan.

Like OSHA EPA wants control of airborne lead particulates as well as project wastes and waste materials contaminated by lead and lead residues.

Certain lead-based paints and coatings can be protected and stabilized depending on condition at time of protective coating application and product limits

Engineering, Administrative, Personal Protective Equipment

In the interest of both occupational and environmental safety and health we will use all three controls to effect site lead control and keep lead exposures in control to site abatement workers. The CES Respiratory Protection Plan and the CES Medical Monitoring Plan are incorporated here-in by reference. Medical monitoring is conducted annually by CES as per OSHA for respirator use and as needed for lead screening and evaluation. Respirator fit tests are documented.

Basic Baseline Medical Monitoring for Lead follows as per NIOSH. This notes the basic parameters for lead biological monitoring. The construction industry standard is more stringent than the OSHA General Industry Lead Standard.

SPECIFIC MEDICAL TESTS PUBLISHED IN THE LITERATURE

FOR OSHA REGULATED SUBSTANCES

Lead, inorganic CAS No: 7439-92-1

EDITOR(S) / AUTHOR(S) SPECIFIC MEDICAL TEST(S) REFERENCE(S)

US DOL OSHA

Blood Sampling and Analysis Determination:

• Blood Lead level At least every 2 months for each employee whose last blood sampling and analysis indicated a blood lead level at or above 40ug/100g of whole blood

• Hemoglobin

• Zinc Protoporphyrin

• Blood Urea Nitrogen

• Serum Creatinine

Pages 110-111

Code of Federal Regulations. 29 CFR Part 1910 -- Occupational Safety and Health Standards. Part 1910.1025. US GPO. July 1, 2000. Pages 104-135.

Lead-Based Paint and or Coatings Controls-

In this case, Fiberlock LBC or Lead Binding Compound will be applied over lead-based paint substrates in NAS Jacksonville Hanger #124 to affect the reduction of lead exposure potential at the site and work as an agent to lessen future lead exposures within the product and substrate combination limits.

The work plan and outline goal are to control lead exposures during process setups, such as site mobilization, pre-work set up and then lead abatement (coating) and final cleanup, equipment and protective systems enclosures removal or removals.

A Fiberlock LBC Product Data Sheet follows, and the steps therein will be the application process for this work and is incorporated by reference.

As said earlier, using the Fiberlock LBC product bulletin as a guide the LBC will be applied to the lead-based paint or coatings on concrete, CMUs and other materials as per the statement of work. PPE will be used as per the bulletin and described below in this document.

The use of the Fiberlock LBC process fits the intent of OSHA 29 CFR 1926.62 Lead in Construction and other protective means and methods for lead control and protection. The crux of this rule and other strategies are to keep airborne lead dusts as low as possible during operations such as in industrial lead film and paint removal or coatings abatement from structural steel for commercial and residential sites. Abatement does not always mean removal of lead-based paints or coatings; it can mean enclosure or encapsulation as well, Coating and Abatement Process- Steps

A. Site Inspection by CES Site Supervisor

1. Initial Site Safety Meeting and

2. Site Worker Briefing and Hazards and Controls Review

A. Fiberlock ABC application means and methods as per Fiberlock Technical Bulletin as inserted in this document and PPE use respiratory protection, disposable suits, gloves and decon procedures.

B. Site Lead Hazards and Control Methods

1. Personal Air Sampling for Airborne Lead dusts as per NIOSH 7105 as seen below next page. This NIOSH and OSHA 29 CFR 1926.62 accepted method uses 37 mm cellouse ester air sample cassette filter media and a personal sample pump at the worker's breathing zone to help determine lead exposure, this sample method will be used during initial work shifts as a negative exposure assessment to determine airborne lead levels if any. The usual procedure is to collect two full-shift air samples on the workers applying the chemicals to the paint and removing the wax paper like covering.

2. Use of CES employee PPE, for this project.

3. Use of lead warning signs to control access to immediate lead activity areas at the site as seen below:

4. Use of waste containers, drums to contain lead bearing wastes at the site marked with the following labels, if any wastes are generated as per RCRA if any are generated at this site and by the work at hand.

http://www.accuform.com/safety-sign/danger-danger-lead-work-area-may-damage-fertility-or-the-unborn-child-causes-damage-to-the-central-nervous-system-do-not-eat-drink-or-smoke-in-this-area-bilingual-SBMCAW188 http://www.accuform.com/safety-sign/danger-danger-lead-work-area-may-damage-fertility-or-the-unborn-child-causes-damage-to-the-central-nervous-system-do-not-eat-drink-or-smoke-in-this-area-bilingual-SBMCAW188�

Caution Sign for Drums Awaiting Environmental Assessment- Lead TCLP

Label for Drum Contents Identified as a Lead-Containing Hazardous Waste- by TCLP

Hazardous Waste Drum or Pail Label

NO DRUM CUTTING OR BURNING NEAR

OR ON THIS DRUM. THESE DRUMS ARE

AWAITING ENVIRONMENTAL

ASSESSMENT PRIOR TO DISPOSAL DO

NOT MOVE- NO SMOKING IN THIS AREA

http://www.adepgroup.com/services.html https://www.amazon.com/NMC-HW1-Hazardous-Container-HAZARDOUS/dp/B009RVF3U0

NIOSH and OSHA Lead in Construction 29 CFR 1926.62 accepted analytical method for airborne lead dust sampling at work sites.

NIOSH Employee Lead Hazard Information and Protective Means and Methods:

Lead CAS 7439-92-1

Pb RTECS OF7525000 Synonyms & Trade Names Lead metal, Plumbum

DOT ID & Guide

Exposure Limits

NIOSH REL*: TWA 0.050 mg/m3 See Appendix C [*Note: The REL also applies to other lead compounds (as Pb) -- see Appendix C.] OSHA PEL*: [1910.1025] TWA 0.050 mg/m3 See Appendix C [*Note: The PEL also applies to other lead compounds (as Pb) --see Appendix C.]

IDLH 100 mg/m3 (as Pb) See: 7439921 Conversion

Physical Description A heavy, ductile, soft, gray solid.

MW: 207.2 BP: 3164°F MLT: 621°F Sol: Insoluble VP: 0 mmHg (approx)

IP: NA Sp.Gr: 11.34

Fl.P: NA UEL: NA LEL: NA Noncombustible Solid in bulk form.

Incompatibilities & Reactivities Strong oxidizers, hydrogen peroxide, acids

Measurement Methods

NIOSH 7082, 7105, 7300, 7700, 7701, 7702; OSHA ID121, ID125G, ID206

See: NMAM or OSHA Methods

Personal Protection & Sanitation Skin: Prevent skin contact Eyes: Prevent eye contact Wash skin: Daily Remove: When wet or contaminated Change: Daily

First Aid (See procedures) Eye: Irrigate immediately Skin: Soap flush promptly Breathing: Respiratory support Swallow: Medical attention immediately

Respirator Recommendations NIOSH/OSHA Up to 0.5 mg/m3: (APF = 10) Any air-purifying respirator with a high-efficiency particulate filter/(APF = 10) Any supplied-air respirator Up to 1.25 mg/m3: (APF = 25) Any supplied-air respirator operated in a continuous-flow mode/(APF = 25) Any powered, air-purifying respirator with a high-efficiency particulate filter Up to 2.5 mg/m3: (APF = 50) Any air-purifying, full-facepiece respirator with a high-efficiency particulate filter/(APF = 50) Any supplied-air respirator that has a tight-fitting facepiece and is operated in a continuous-flow mode/(APF = 50) Any powered, air-purifying respirator with a tight-fitting facepiece and a high-efficiency particulate filter/(APF = 50) Any self-contained breathing apparatus with a full facepiece/(APF =

50) Any supplied-air respirator with a full facepiece

Up to 50 mg/m3: (APF = 1000) Any supplied-air respirator operated in a pressure-demand or other positive-pressure mode Up to 100 mg/m3: (APF = 2000) Any supplied-air respirator that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode Emergency or planned entry into unknown concentrations or IDLH conditions: (APF = 10,000) Any self-contained breathing apparatus that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode/(APF = 10,000) Any supplied-air respirator that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode in combination with an auxiliary self-contained positive-pressure breathing apparatus Escape: (APF = 50) Any air-purifying, full-facepiece respirator with a high-efficiency particulate filter/Any appropriate escape-type, self-contained breathing apparatus Exposure Routes inhalation, ingestion, skin and/or eye contact Symptoms Lassitude (weakness, exhaustion), insomnia; facial pallor; anorexia, weight loss, malnutrition; constipation, abdominal pain, colic; anemia; gingival lead line; tremor;

paralysis wrist, ankles; encephalopathy; kidney disease; irritation eyes; hypotension Target Organs Eyes, gastrointestinal tract, central nervous system, kidneys, blood, gingival tissue

C. Fall Protection Means and Methods D. Emergency Procedures and Contacts

3. Site Mobilization and Equipment Staging Areas Review

4. Control of Work Area and Demarcation

B. Set Up of Site Safety Equipment

1. Portable Eye Wash, First Aid Kits, Fire Extinguishers and Sanitary Facilities, Posting of Emergency Contact Numbers

2. Staging of Chemical Spill Control Equipment/Materials, if required

3. Rigging and Attachment of Fall Protection Harnesses, if required

C. Set Up of Aerial Lifts, if required, Set up of Ladders, if required

1. Inspection and Check and Placement, Critical

D. Personal Protective Equipment (PPE)

1. Worker PPE Review and Requirements

A. ½ Face APR HEPA Filtered Respirator or Full-Face Powered APR Respirator w/ HEPA Filter.

B. Full Body Suits- Disposable Type C. Rubber Boots, Safety Toe Type, if needed D. Chemical Resistant Gloves, Nitrile, Neoprene (8 Hr.)

E. Fall Protection Harness and Restraint for Aerial Lift, if needed F. Hard Hat G. Compliant Ladders

This is an example of a NIOSH approved respirator similar to the respiratory protection to be used at for lead abatement, The NIOSH-approved respirator uses HEPA or P-100 filter cartridges that are accepted by both NIOSH and OSHA for Lead in Construction work and lead abatement of the type detailed in this work plan.

E. Portable Eye Wash- Field Type

1. Eye Wash, Water Based Gravity Feed 0.4 gal per minute 15 minute duration as per SDS located at site for quick access

2. Portable eye wash bottles may be used but are not a substitute for #1 in this subsection

F. Review of Fiberlock LBC Coating Process

Put down drop cloths and use barricade tape and Lead Danger Signs as seen above to isolate the work area.

HEPA vacuum loose paint and wet scrape with water as the wetting agent. Do not flood only mist the loose and flaking paint.

Clean drop cloths and work area with careful and complete wet wiping and HEPA vacuuming so no visible debris is seen.

When the paint surfaces are ready to be coated as per the Fiberlock LBC Product Data Sheet as seen above use the means and methods in this publication to coat and seal the surface or surfaces in question.

After any phase of the lead stabilization work is completed make certain each in the lead work area disposes of their protective coveralls in a lead waste drum and cleans their respirator and washes hands and face and arms.

We do not expect the OSHA PEL or Action Limit for Lead at this site to be exceeded during the preparation and the application of Fiberlock LBC on these painted or coated surfaces.

G. Workers PPE Disposal

Worker protective suits, gloves, and other equipment that cannot be cleaned and neutralized will be disposed of and tested as per RCRA

40 CFR 240-261

H. Worker's Decontamination and Prevention

Site workers will decon by washing with soap and water at the site and especially before eating drinking or smoking. Smoking drinking and eating will not be permitted in the lead work area. All food and drink will be kept out of and away from the lead work area and abatement operations. Hand and face washing will be especially encouraged.

I. Summary

Based on the job and tasks for this work we do not expect that CES employees will be exposed at or above the 50 ug/m3 airborne lead levels as per OSHA 29 CFR 1926.62.

This is a coating and application process and not removal of the lead-based paint or coating substrate.

Even though we expect levels to be below the threshold, CES holds the standard to still ensure the protocol is in place for waste management. Prior to the removal of any waste, representative samples of each waste stream generated by the work will be collected and analyzed as per RCRA 40 CFE 240-280, and the Toxicity Characteristic Leaching Procedure (TCLP) as per 40 CFR 261.

Samples will be collected and sent to the following laboratory:

EMSL Analytical 200 Route 130 North Cinnaminson, New Jersey 08077 Phone: 1-800-220-3675, Fax: 856-786-5974

When laboratory analysis results indicate lead or other toxic metal concentrations higher than the regulatory EPA limits of 5 micrograms (μg), waste will be transported by the following company:

Greer Enterprises, LLC 1909 Brookdale Drive Mobile, Alabama 36618 Phone – (251)679-1967

USDOT #: 1693843

EPA ID: ALR000046581

Approved Landfill:

Glencoe 402 Webster Chapel Road Glencoe, Alabama 35905 Phone – (800)739-9156

EPA RCRA ID: ALD981020894

Submitted by:

Elijah Brown Director, Safety and Health Cross Environmental Services, Inc. (CES) 39646 Fig Avenue Post Office Box 1299 Crystal Springs, FL 33524 Home Office 813-783-1688 Cell Phone 813-422-4342

Other certifications and licenses from states and the federal government are available upon request

SPECIFIC MEDICAL TESTS PUBLISHED IN THE LITERATUREFOR OSHA REGULATED SUBSTANCES