Attach_J_-_SOW_Attachment_9.pdf

UNCLASSIFIED/FOR OFFICIAL USE ONLY

LEAD-BASED PAINT MANAGEMENT

PLAN

EAFB PLAN 32-4

September 2015

96TH TEST WING

EGLIN AIR FORCE BASE

THIS PAGE INTENTIONALLY LEFT BLANK

DEPARTMENT OF THE AIR FORCE

HEADQUARTERS 96TH TEST WING (AFMC)

EGLIN AIR FORCE BASE FLORIDA

M

8 September 2015

MEMORANDUM FOR INSTALLATION COMMANDER

FROM: 96 CEG/CC

SUBJECT: Eglin Air Force Base (EAFB) Plan 32-4, Lead Based Paint Management Plan

1. Subject plan has been reviewed and coordinated in accordance with Installation Plans review process. It is deemed accurate, complete, and necessary to the execution of unit mission.

2. This plan is effective upon receipt for planning purposes and for implementation as directed by the Installation Commander (96 TW/CC).

3. The office of primary responsibility (OPR) for this document is 96 CEG/CEIEC, Environmental Compliance Pollution Prevention office, 882-7665.

1st

Ind, INSTALLATION COMMANDER

MEMORANDUM FOR ALL EGLIN ORGANIZATIONS

Concur. Subject plan will be posted on the Installation Plans SharePoint site.

SECURITY INSTRUCTIONS/RECORD OF CHANGES

1. The long title of this document is Eglin Air Force Base Lead-Based Paint Management Plan.

The short title is EAFB Plan 32-4.

2. This plan is unclassified and may be reproduced in whole or in part without the permission of the OPR.

3. Operations Security (OPSEC) has been considered in the development of this plan. All organizations tasked by this plan will ensure necessary action is taken to safeguard any operational and communications information that might fall within the scope of the OPSEC program in accordance with AFI 10-701, Operations Security (OPSEC).

4. Distribution Policy Change. In following Air Force and Air Force Materiel Command’s

(AFMC) lead, hard copies will no longer be distributed. Plans will be located on the

Emergency Network (ENet) site at https://enet.eglin.af.mil/ . The plan OPR is responsible for providing copies of this plan to those customers with the need to know, but without access to these sites.

5. Plan Changes. If a change to the content of this plan is required, change requests will be submitted to the plan OPR.

RECORD OF CHANGES

CHANGE # DATED DATE POSTED POSTED BY

https://enet.eglin.af.mil/

PLAN SUMMARY

1. PURPOSE. This plan establishes policies and procedures for the management of lead-based paint at Eglin Air Force Base (AFB). It applies to all organizations, associates, contractors and individuals actively involved in management, renovation, abatement or disturbance of lead-based paint throughout the Eglin main base and surrounding reservation.

This includes renovation and demolition projects for facilities where lead-based paint has been applied in the past.

2. EXECUTION. Eglin AFB has many facilities that have been painted with materials containing lead. The Environmental Compliance Division of Environmental Management

(96 CEG/CEIEC) provides technical assistance to all base activities regarding the proper management and disposal of wastes generated during activities involving lead-based paints.

ACRONYMS

BE Bioenvironmental Engineering

CFR Code of Federal Regulations

EESOH-MIS Enterprise Environment, Safety, and Occupational Health

Management Information System

EBL Elevated Blood Lead

EPA Environmental Protection Agency

HAZMAT Hazardous Material

HUD Housing Urban Development

LBPPO Lead-Based Paint Program Officer

LBPPPA Lead-Based Paint Poisoning Prevention Act

LERA Lead Exposure Risk Assessment

LTI Lead Toxicity Investigation

MFH Military Family Housing

OSHA Occupational Safety and Health Administration

RCRA Resource Conservation and Recovery Act

TCLP Toxic Characteristic Leaching Procedure

TABLE OF CONTENTS

CONTENTS PAGE

Security Instructions and Record of Changes 4

Plan Summary 5

Acronyms 6

Table of Contents 7

Basic Plan 8

ANNEX A, TASKED ORGANIZATIONS 12

ANNEXES B – G Not Used

ANNEX H, ENVIRONMENTAL SERVICES 13

Appendix 1--Definitions 14

Appendix 2--Responsibilities 20

Appendix 3--Lead-based Paint Hazard Identification 28

Appendix 4--Hazard Management and Risk Reduction 31

Appendix 5--Record Keeping 37

Appendix 6--Protection of Facility Occupants 41

Appendix 7--Base Awareness and Education Plan 44

Appendix 8--Waste Disposal Requirements 49

Appendix 9--Public Health Questionnaire 50

ANNEXES I - Z Not Used

BASIC PLAN

REFERENCES:

Code of Federal Regulations:

24 CFR Part 35 Lead-Based Paint Poisoning Prevention in

Certain Residential Structures

29 CFR Part 1926.62 Lead

Part 1910.134 Respiratory Protection

Part 1910.1200 Hazard Communication

40 CFR Part 745 Lead-Based Paint Poisoning Prevention in

Certain Residential Structures

49 CFR

Part 171 General Information, Regulations, and

Definitions

Part 172

Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, Emergency Response Information, and Training

Requirements

Part 173 Shippers – General Regulations for Shipments &

Packaging

Part 177 Carriage by Public Highway

Air Force:

AFI 48-137 Respiratory Protection Program

AFI 90-821 Hazardous Communications

US Department of Housing and Urban Development (HUD) 1995 Guidelines for

Evaluation and Control of Lead-Based Paint Hazards in Housing

1. SITUATION: This plan provides an overview of potential hazards associated with lead exposures on Eglin Air Force Base.

1.1. The medical community has concluded that exposures to low levels of lead, once considered safe, can have an adverse effect on health. This seems to be particularly true for children who absorb about 40 percent more lead than an adult when an exposure occurs.

Exposure to lead may cause damage to the body's blood system and to the neural, urinary and reproductive systems. Research has documented a strong correlation between lead exposure and learning disabilities among children. Lead enters the bloodstream and may begin causing damage immediately. It does not pass through the body directly but is stored in bones and slowly released over time, resulting in a long-term impact to the body even after an individual has been removed from an affected area. Symptoms and elevated blood and urine lead levels occur rapidly after exposures.

1.2. The impetus for change in dealing with lead came in 1991, when the national Centers for

Disease Control lowered its threshold for concern from 25 micrograms of lead per deciliter of blood to 10 micrograms of lead per deciliter of blood. With the reduction, the US

Environmental Protection Agency (EPA) estimated that 10 to 15 percent of all preschoolers have lead levels high enough to impair their neurological development to a subtle but significant degree.

1.3. Sources of lead in our environment include lead-based paint (LBP), lead in water and lead-contaminated soil. Prior to 1990, leaded gasoline was considered by the EPA to be the most likely source of exposure to the general population and has been phased out.

1.4. Flaking and peeling paint represents an obvious exposure concern in homes, day care centers, schools and playgrounds. Less obvious but equally dangerous is lead-containing dust generated during renovation, demolition, sanding and stripping of painted surfaces. Lead-containing dust can also be generated when surface abrasion occurs during such routine activities as opening and shutting doors and windows. Toddlers and young children may chew on painted surfaces such as windowsills while teething.

1.5. Lead-containing pipes in many municipalities leak enough lead to be an exposure source.

Even new brass fixtures, which have been allowed to contain up to 8 percent lead, can leach enough lead to cause the water to exceed the EPA's drinking water standards. The EPA released its testing results for water authorities around the country.

1.6. Soil also represents a potential exposure concern, especially in urban areas where the levels of past auto and industrial emissions have left significant residues of lead. In more rural areas, where many military bases are located, lead-tainted soil is found near homes where deteriorated exterior paint has leached into the soil from rain. Very high levels of lead in soil have been found around steel structures such as bridges, water towers and shooting ranges.

2. MISSION: Provide the commander with a means to manage the abatement, renovation, demolition and subsequent disposal of LBP on base facilities.

3. EXECUTION:

3.1. The requirements addressed in this plan apply to all organizations located on Eglin AFB, including associates, units residing on Eglin AFB temporarily and contractors. Procedures related to the management, abatement, demolition and subsequent disposal of lead-containing paint on base facilities are outlined in this plan. New regulations governing testing, training, certification, abatement, disposal and worker protection are being developed by federal and state agencies to reduce exposures from all environmental sources.

3.2. This plan shall be an integral part of the Eglin AFB overall plan for inspecting, constructing, upgrading, repairing, maintaining and demolishing the facility inventory.

Prioritization shall be based on associated health and environmental risks as outlined in this instruction.

3.2.1. Priority 1 - Any facility frequented by children less than 7 years of age.

3.2.2. Priority 2 - Structures scheduled for demolition, repair or renovation.

3.2.3. Priority 3 - Facilities in a state of deterioration.

3.3. To further prioritize sampling requirements, with respect to customer needs, prioritization shall be classified as follows:

3.3.1. Class A - Emergency: Immediate health risks.

3.3.2. Class B - Urgent: Possible health risks.

3.3.3. Class C - Routine: No health risks or added government expense.

Note: The sampling responsibility is shared between 96 CEG/CEPTM (Mr. Dwight Berrong) and 96 AMDS/SGPB. Approximate turn-around times may vary, depending on the analytical support resources tasked.

3.4. The overall operation of the LBP program is a consolidated effort involving several base organizations:

3.4.1. The 96th Civil Engineer Group, Environmental Management (96 CEG/CEIE) provides overall regulatory oversight of the Eglin AFB LBP Management Program.

3.4.2. The 96th Civil Engineer Group Commander (96 CEG/CC) provides overall operation of the LBP program by providing a mechanism for the proper planning, design and abatement of existing LBP, associated hazards, and for sampling for lead prior to maintenance operations.

3.4.3. The 96th Medical Group Commander (96 MDG/CC) provides sampling, health hazard screening and blood lead level surveys for base personnel and their families, as required.

4. ADMINISTRATION AND LOGISTICS: Deficiencies or inaccuracies noted in this plan must be reported to the Environmental Compliance Branch of Environmental Management

(96 CEG/CEIEC) at 882-7665. At times, a problem may arise in complying with this plan or complying with LBP laws and control measures promulgated by EPA, Occupational Safety

Health Administration (OSHA), Florida Department of Environmental Protection or Air Force

Directives. Present the problem through your Unit Environmental Coordinator (UEC) to

96 CEG/CEIE. CEIEC will take action to resolve the problem or direct you to the appropriate office for action.

5. LIST OF CONTACTS:

96 CEG/CEIEC LBP Program Manager 882-7665

96 AMDS/SGPB Health Issues and Sampling 883-8453

96 AMDS/SGPM Medical Tests 883-8612

96 CEG/CEOOM Work Requests/Projects 882-6969

6. COMMAND AND SIGNAL: As host at Eglin AFB, the 96 TW/CC provides guidance and support to other USAF, Department of Defense, Federal Government agencies, contractors, etc., in lead-based paint management. See Tab A to Appendix 2 to Annex H for a chart of command relationships.

Annexes:

A--Tasked Organizations

H--Environmental Services

Z--Distribution

ANNEX A TO EAFB PLAN 32-4

TASKED ORGANIZATIONS

Eglin Air Force Base (EAFB) assigned and attached units, associate units, other federal agencies, and all on-base contractors as required by contract. All organizations on EAFB who have the potential to disturb, demolish, purchase, apply or dispose of lead-based paint.

ANNEX H TO EAFB PLAN 32-4

ENVIRONMENTAL SERVICES

1. GENERAL: The purpose of this annex is to assist all affected organizations in successfully abating, handling, managing, controlling and disposing lead-based paint. This annex establishes procedures and assigns specific responsibilities and procedures required to execute the handling, control and disposal requirements for all LBP on facilities or other items at Eglin

AFB.

2. SITUATION: All Eglin AFB assigned and associate units are required to manage LBP in accordance with federal, state and Air Force laws, regulations and instructions, and with the policies and procedures set forth in this management plan. LBP will be managed in the most cost-effective compliant manner and IAW Eglin AFB and Headquarters, Air Force Materiel

Command (HQ AFMC) established policies.

Appendices:

1--Definitions

2--Responsibilities

3--LBP Hazard Identification

4--Hazard Management and Risk Reduction

5--Record Keeping

6--Protection of Facility Occupants

7--Base Awareness and Education Plan

8--Waste Disposal Requirements

9--Public Health Questionnaire

APPENDIX 1 TO ANNEX H TO EAFB PLAN 32-4

DEFINITIONS

The following definitions were derived from the Housing and Urban Development lead-based paint guidelines and the draft Air Force Policy on LBP in Facilities.

1. Abatement: A comprehensive process of eliminating exposure or potential exposure to lead paint and lead dust through removal, enclosure or encapsulation. Abatement must include testing, measures for worker protection, containment of dust and debris, cleanup and disposal of waste and clearance testing.

2. Action Level: The point at which something needs to be done to correct or eliminate the presence of lead. Normally, this would be one-half the permissible exposure limit based/ quantified by reliable air or bulk sampling.

3. Biological Monitoring: The analysis of a person's blood to determine the level of lead contamination in the body.

4. Code of Federal Regulations (CFR): The basic component of the Federal Register publication system. The CFR is a codification of the regulations of the various federal agencies.

5. Characteristics: The Environmental Protection Agency has identified four characteristics of a hazardous waste: ignitability, corrosivity, reactivity and extraction procedure (EP) toxicity.

Any solid waste that exhibits one or more of these characteristics is classified as a hazardous waste under Resource Conservation and Recovery Act (RCRA).

6. Clearance Level: Defined by HUD as:

6.1. Floor: 100 micrograms per square foot.

6.2. Window Sills: 500 micrograms per square foot.

6.3. Window Wells: 800 micrograms per square foot.

7. Common Area: A room or area that is accessible to all tenants in a project (e.g., hallway and boiler room). Generally, any area that is not kept locked.

8. Comprehensive Survey: The testing of military family housing (MFH) and priority facilities for LBP in accordance with the HUD LBP guidelines. Such surveys are typically conducted after a Lead Exposure Risk Assessment (LERA).

9. Container: Any portable device, in which material is stored, transported, treated, disposed of or otherwise handled.

10. Containment: The process of enclosing or isolating a work area to protect both workers and the environment by controlling exposures to lead dust and debris created during abatement.

11. Contractor: Any business entity, public unit or person performing the actual abatement for a lead abatement project.

12. Disposal: The testing, containment, transporting and disposal of waste generated on an abatement project in accordance with federal, state and local regulations.

13. Disposal Facility: A facility or part of a facility at which solid and hazardous waste is intentionally placed into or on any land, and at which waste will remain after closure.

14. Elevated Blood Lead: When a child’s screening is greater than 9.0 micrograms of lead per deciliter of blood.

15. Environmental Management: The base organization that has the primary responsibility of overseeing and managing all base environmental programs.

16. Encapsulation: Refers to the resurfacing or covering surfaces, and sealing or caulking with durable materials so as to prevent or control chalking, flaking lead-containing substances from becoming part of house dust or accessible to children.

17. Enclosure: Involves covering painted surfaces with paneling, drywall or plaster to permanently seal the existing surface.

18. EPA Identification: The unique number assigned to EPA by each generator or transporter of hazardous waste and each treatment, storage or disposal facility.

19. EP Toxicity: A test called extraction procedure that is designed to identify wastes likely to leach hazardous concentrations of particular toxic constituents into the groundwater as a result of improper management. It is a characteristic of hazardous waste.

20. Exposure Monitoring: The personal air monitoring of an employee's breathing zone to determine the amount of contamination (e.g., lead) to which he/she is exposed.

21. Facility: Any type of building or housing structure on base.

22. Facilities Likely to Contain LBP: Certain types of paint applied before 1980 are more likely to contain lead. These are oil-based paints used in industrial facilities, on steel structures

(water towers, pipelines, etc.) and in yellow airfield and roadway pavement markings. They have excellent sealing (stain resistance) and anti-corrosion properties, and they are very durable and resistant to ultraviolet light in sunlight. They were also applied primarily to kitchens, bathrooms and interior and exterior wood trim in residences. Latex paint for architectural use, which normally does not contain lead, became popular after 1960 and nearly all paint applied after 1980 to interior and exterior houses and non-industrial buildings was latex paint. This was reinforced by the Consumer Product Safety Act. However, because of their desirable properties and lack of federal regulation, LBP continued to be used in industrial facilities, on steel structures and for pavement markings. Additionally, due to complex wording of the

Consumer Product Safety Act, LBP may also be found in non-industrial facilities, primarily in primers on ferrous metal surfaces.

23. Generator: Any person who first creates a hazardous waste or any person who first makes the waste subject to the Subtitle C regulation (e.g., imports a hazardous waste, initiates a shipment of a hazardous waste from a Treatment Storage Disposal Facility [TSDF], or mixes hazardous wastes of different Department of Transportation [DoT] shipping descriptions by placing them into a single container).

24. Groundwater: Refers to water below the land surface in a zone of saturation.

25. Hazardous Waste: NOTE: As defined in RCRA, a solid waste or combination of wastes which because of its quantity, concentration or physical, chemical or infectious characteristics may:

25.1. Cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or

25.2. Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed.

As defined in the regulations, a solid waste is hazardous if it meets one of four conditions:

25.3. Exhibits a characteristic of hazardous waste (40 CFR Sections 261.20 through 262.24).

25.4. Has been listed as hazardous (40 CFR Section 261.31 through 261.33).

25.5. Is a mixture containing a listed hazardous waste and a non-hazardous solid waste (unless the mixture is specifically excluded or no longer exhibits any of the characteristics of hazardous waste).

25.6. Is not excluded from regulation as a hazardous waste.

26. High Efficiency Particulate Air (HEPA): A filter capable of filtering out particles of 0.3 microns or greater from a body of air at 99.97 percent efficiency or greater.

27. High Phosphate Detergent: A detergent that contains at least 5 percent tri-sodium phosphate.

28. Industrial Hygienist: A person certified by the American Board of Hygiene or an industrial hygienist in training or an individual with equivalent education or experience.

29. Initial Survey: A cursory inspection of MFH units and priority facilities by a qualified individual, to determine any obvious and immediate hazards.

30. Lead-Based Paint: The paint or other surface coatings that contain lead in excess of 1.0 milligrams per centimeter squared or 0.5 percent by weight; or in the case of paint or other surface coatings on housing, such lower level as may be established by the Secretary of

Housing and Urban Development, as defined in Section 302(c) of the Lead-Based Paint

Poisoning Prevention Act (para 1b), or in the case of any other paint or surface coatings, such other lead content as may be established by the EPA.

31. Lead Exposure Risk Assessment: An assessment conducted by a qualified individual after an initial survey to further assess LBP hazards in MFH and priority facilities. Assessment includes a detailed review of building constructions, painting histories, and limited bulk and wipe sampling.

32. Manifest: The shipping document, EPA Form 8700-2, used for identifying the quantity, composition, origin, routing and destination of hazardous waste during its transportation from the point of generation to the point of treatment, storage, or disposal.

33. Mean: The arithmetic average of data values. The algebraic sum of the data values divided by the number of data values.

34. Medical Removal: The temporary removal of workers due to elevated blood lead levels as defined in these guidelines.

35. Micrograms: One millionth of a gram: 453 grams in a pound, 28,310,000 micrograms in one ounce.

36. Paint Removal: A strategy of abatement that entails stripping lead paint from surfaces of components.

37. Pattern: The process of identifying specific building components containing LBP at a hazardous level within a project or group of buildings.

38. Personal Samples (for sampling lead dust): Air samples collected from within the breathing zone of a worker, but outside the respirator. The samples are collected with a personal sampling pump, pulling 1 to 4 liters/minute of air.

39. Precision: The degree of repeatability of a series of successive measurements.

40. Priority Facility includes temporary living facilities, child care centers, registered day care homes, playgrounds, hospital pediatric areas, recreation or learning/teaching centers for children, gymnasiums and pools, and kindergarten and schools.

41. RCRA: The Resource Conservation and Recovery Act of 1976. Commonly referred to as

RCRA, this is an amendment to the Solid Waste Disposal Act of 1965. RCRA was amended in

1980 and most recently on November 8, 1984.

42. Regulation or Rule: All or part of any federal statement of general or particular applicability and future effect design to:

42.1. Implement, interpret, or prescribe law or policy.

42.2. Describe the federal department's organization or its procedure or practice requirements.

43. Removal and Replacement: A strategy of abatement which entails the removal of components such as windows, doors and trim that have lead painted surfaces and installing new components free of lead paint.

44. Representative Sample: A sample of a universe or whole (e.g., waste sample pile, ground water, or waste stream) which can be expected to exhibit the average properties of the universe or whole.

45. Site: The land where any facility or activity is physically located or conducted, including adjacent land used in connection with the facility or activity.

46. Sodium Sulfide: A chemical used to test a paint sample qualitatively for lead; typical concentrations are from 6 to 10 percent. A positive test is characterized by a gray, black or other dark discoloration of the paint film cross section.

47. Solid Waste: As defined in RCRA, means any non-hazardous garbage, refuse or sludge from a waste treatment plant, water supply treatment plant or air pollution control facility and other discarded material, including solid, liquid, semisolid or contained gaseous material resulting from industrial, commercial, mining and agricultural operations, and from community activities, but does not include solid or dissolved material in domestic sewage or solid or dissolved materials in irrigation return flows or industrial discharges which are point sources subject to permits under the Clean Water Act, or special nuclear or byproduct material as defined by the Atomic Energy Act of 1954.

48. Standard Deviation: A measure of the precision of the readings, the average deviation of the deviations from the mean. The smaller the standard deviation, the more precise the analysis, and the less variation there is when an analysis is repeated. The standard deviation is calculated by first obtaining the mean (arithmetic average) of all of the readings on a surface.

A formula is then used to calculate how much the values vary from the mean (standard deviation = the square root of the arithmetic average of the squares of the deviation from the mean). Many hand calculators have an automatic standard deviation function.

49. Storage: The holding of hazardous waste for a temporary period, at the end of which the hazardous waste is treated, disposed of, or stored elsewhere.

50. Stripping: The process of removing paint from surfaces using chemicals or heat guns.

51. Substrate: A surface upon which paint or varnish has been or may be applied. Examples of substrates include wood, plaster, metal and drywall.

52. Toxic Characteristic Leaching Procedure: See EP Toxicity Test.

53. Treatment Storage Disposal Facility: An EPA permitted facility for the storage, treatment and disposal of hazardous waste.

54. Transporter: Any person engaged in the off-site transportation of hazardous waste within the US, by air, rail, highway or water, if such transportation requires a manifest under 40 CFR

Part 262.

55. Tri-sodium Phosphate: A chemical compound used in Lead-Based Paint removal operations as a detergent.

56. Micrograms (μg): The prefix "micro" means "1/1,000,000 of" (one millionth of). A microgram is 1/1,000,000 of a gram and 1/1000 of a milligram. A microgram is equal to about

35/1,000,000,000 (thirty-five billionths) of an ounce. 28,400,000 μg is equal to 1 ounce.

57. Work Practice Control: A procedural control to limit the exposure to lead.

APPENDIX 2 TO ANNEX H TO EAFB PLAN 32-4

RESPONSIBILITIES

1. GENERAL: Assigns specific responsibilities within the Lead-Based Paint Management

Plan. The responsibilities of key individuals/groups are summarized below. An effective lead management program requires that these positions and organizations communicate with each other effectively and carry out the management activities.

1.1. Lead-Based Paint Program Officer: Oversees the day-to-day implementation and activities of the Plan. Ensures the LBP Management Plan is developed and remains current

(see para 2, Appendix 2 to Annex H).

1.2. Chief of Aerospace Medicine: Directs development of the base blood lead screening program. Directs lead toxicity investigations. Public Health will implement and maintain the blood lead screening program and notify the Chief of Aerospace Medicine when an elevated blood lead level is encountered (see para 3, Appendix 2 to Annex H).

1.3. Installation Commander (96 TW/CC):

1.3.1. Is the responsible official in overall compliance with Lead-Based Paint requirements.

Assigns responsibility for the management of Eglin’s LBP Program to the Chief of

Environmental Management.

1.3.2. Ensures development and publication of this instruction.

1.3.3. Oversees the implementation of this instruction.

1.4. 96 CEG/CC: Appoints a LBP Operations Officer to oversee abatement operations, e.g., efforts to modify design, renovation, construction and maintenance work practices to protect base personnel, employees and contractors from lead exposure as discussed in this plan (see para 8, Appendix 2 to Annex H).

1.5. 796 CES/CEOC, Engineering Flight: Determines if LBP will be disturbed during their projects. They will determine how the material should be handled and will clearly inform the contractors or base personnel performing the work of any potential hazard (see para 8, Appendix 2 to Annex H). Will ensure that planners and designers have identified potential lead hazards and have clearly identified them to contractors in the bid/proposal documents. Will work with vendors to identify lead-containing products being used at the base, and take steps to minimize their use and seek alternative products through contract wording and Hazardous

Material (HAZMAT) Cell review (see para 8, Appendix 2 to Annex H).

1.6. Supply Activities (HAZMAT Cell): Researches and provides commodity stock numbers to customers and also researches lead-free substitutes (see para 7, Appendix 2 to Annex H).

1.7. 96 CEG/CEIH, Military Family Housing Office: Ensures newcomers to base housing are informed of potential LBP hazards (see para 9, Appendix 2 to Annex H).

1.8. Facility Managers: Report signs of potential LBP hazard problems to the Lead-Based

Paint Program Officer and maintain results of all LBP surveillance and testing for their facilities (see para 10, Appendix 2 to Annex H).

1.9. 96 FSS/CC: Ensures that users of day care centers and child-oriented facilities are informed of actual or potential LBP hazards and reports any potential hazards to the Lead-

Based Paint Program Officer (see para 11, Appendix 2 to Annex H).

1.10. Environmental Management: Oversees the combined efforts of the LBP management program and provides regulatory leadership and coordination with state and federal regulatory agencies.

1.11. LBP Working Group (WG): Oversees the development of the LBP Management Plan, to include the coordination of responsibilities. This WG will be formed as an ad hoc type committee to develop the program and then be dissolved, to be reconfigured as the program warrants (see para 14, Appendix 2 to Annex H).

1.12. Bioenvironmental Engineering (BE): Conducts environmental and personal testing required by the LBP Management Plan and assists in hazard inspections and lead toxicity investigations (see para 4, Appendix 2 to Annex H).

2. LEAD-BASED PAINT PROGRAM OFFICER (LBPPO): Environmental Management is responsible for the management of all environmental compliance programs on Eglin Air

Force Base. 96 CEG/CEIE will appoint someone from that organization as the LBPPO. This individual will be responsible for publishing and overseeing the LBP Management Plan. The qualifications and duties of the LBPPO are described below.

2.1. Training: The individual shall attend and successfully complete a one-week lead hazard-training course approved by the EPA. This is not a mandatory course since it is an OSHA requirement and not an environmental requirement.

2.2. The LBPPO duties are as follows:

2.2.1. Coordinate completion of initial surveys of family housing and priority facilities to determine lead hazards.

2.2.2. Develop and implement a Management Plan for identifying, evaluating, prioritizing, managing and abating LBP.

2.2.3. Maintain an inventory of training resources and keep updated copies of applicable regulations on file.

2.2.4. Review and approve all training courses regarding the recognition and addressing of lead hazards that may be encountered on Eglin AFB.

3. CHIEF OF AEROSPACE MEDICINE (96 AMDS/SGP):

3.1. Initiates Lead Toxicity Investigations (LTI) and appoints appropriate individuals to conduct LTIs. Review and approve LTI reports.

3.2. Conducts or reviews follow-up treatment for children with elevated blood lead (EBL) levels.

3.3. Oversees the development of the base blood lead-screening program. The lead-screening program will include risk-based blood lead testing for children under the age of 7 to include the lead exposure questionnaire, and a database to track blood lead levels. When an elevated blood lead level is encountered, the SGP will initiate an LTI. Follow-up medical treatment for each child will be at the discretion of the SGP.

3.4. Consults with CEIH and public affairs (PA) and assists in the development of an informational package for base newcomers, addressing lead hazards.

4. BIOENVIRONMENTAL ENGINEERING (96 AMDS/SGPB):

4.1. Training: The Bioenvironmental Program Manager will complete the EPA Lead

Inspection/Risk Assessor Course (40 hours) and maintain certification.

4.2. Duties: The BE Program Manager will:

4.2.1. Assist 96 CEG/CEPTM in sampling and testing of paint to determine the lead content for the purpose of assessing the hazard potential in facilities, especially those determined to be a high priority and those scheduled for renovations, repairs and demolitions.

4.2.2. Determine if LBP in facility poses a hazard (hazard determination).

4.2.3. Consult with the Base Civil Engineer (BCE) and the Lead-Based Paint Program Officer

(LBPPO) and assist in determining the in-place management and/or abatement measures to be taken to reduce or eliminate the hazard.

4.2.4. Conduct air sampling and personnel monitoring, as necessary, to determine lead exposures in facilities during in-place management, abatement and other activities that disturb

LBP.

4.2.5. With the assistance of BCE, conduct walk-through inspections and evaluations of high-priority facilities to determine if there are existing hazards due to LBP.

4.2.6. Conduct or oversee the accomplishment and results of clearance sampling, which is performed after in-place management, abatement, maintenance, repair, modification and renovation activities disturbing LBP.

4.2.7. Assist in the Lead Toxicity Investigations and evaluate the data that is generated.

4.2.8. Develop a Respiratory Protection Program for the LBP Management Plan.

4.2.9. Assist project planners and designers in determining if their proposed projects will impact lead and how to deal with it. Review contract documents. This is other than what

CEIE does with reviewing drawings.

4.2.10. Consult with the Services Officer to develop/provide information on Day Care Centers.

4.2.11. Perform phase 2 and 3 evaluations as described in appendix 3, paragraph 3.

5. PUBLIC HEALTH (96 AMDS/SGPM):

5.1. Participates on the LBP Working Group, when convened.

5.2. Develops and implements the blood lead-screening program.

5.3. Maintains a database of lead exposure records.

5.4. Notifies 96 AMDS/SGP when an EBL is encountered and gives advice to 96 AMDS/SGP in the ensuing LTI.

5.5. Submits epidemiological reports on children with EBL to USAF School of Aerospace

Medicine Epidemiological Consult Service using the Air Force Disease Reporting System internet.

5.6. Reviews epidemiological data for adverse trends.

5.7. Participates in LTI and submits results to the Aerospace Medicine Council and MAJCOM

Public Health Officer as needed.

5.8. Educates parents of children with EBL levels on potential sources of lead in the environment and emphasizes preventive measures to decrease real and potential lead exposure.

As needed, provides base-wide education on lead exposure prevention.

5.9. Reports any abnormal blood lead values to 96 CEG/CEIEC.

6. CONTRACTING OFFICERS (CO) (AFTC/PZ): In conjunction with BCE, COs will play a key role in the LBP Management Plan. Because lead contamination is often not easy to spot, a child will often become very ill with high blood lead levels before the parent recognizes that a problem exists. This is why contracting activities, especially those performed within homes, should be closely monitored. COs will:

6.1. In conjunction with BCE, develop standard contract language to inform contractors of the potential to disturb LBP. It will be up to the project designers to determine where the hazards may exist and what steps the contractors must take to protect base personnel and families.

6.2. After BCE has identified potential hazards via specifications, drawings, etc., inform base contractors that they may encounter lead-based containing materials while conducting their work and that they must take precautions to protect their workers. When appropriate, incorporate this requirement into the contract with specific language included in the Statement of Work (SOW).

7. SUPPLY ACTIVITIES (96 CEG/CEIEC): The HAZMAT Cell will:

7.1. Establish a collaborative framework for collecting and maintaining HAZMAT data on the standardized Air Force HAZMAT tracking system. The Enterprise Environment, Safety, and

Occupational Health Management Information System (EESOH-MIS) is the standardized Air

Force HAZMAT and hazardous waste tracking system.

7.2. Request manufacturers/vendors provide information on lead-free substitutes for these materials. It may not be possible to eliminate all sources of lead in the supply line. Research and report on lead-free products when requested.

7.3. When materials are requested that are known to contain lead, inform the individual that he or she will be working with lead and must confer with the BE on safety precautions before using the material.

7.4. Do not release lead-containing materials for use in self-help activities except when specifically approved, on a case-by-case basis, through the established hazardous material licensing procedures.

7.5. Maintain copies of current Safety Data Sheets in the EESOH-MIS system on paint and plumbing suppliers.

8. 796TH CIVIL ENGINEER PLANNERS, DESIGNERS AND WORKERS

(796 CES/CEOC):

8.1. Planners, designers and workers must know where lead-containing materials may be encountered. Each responsible section of 96 CEG, in coordination with BE, shall research and advise regarding lead hazards, on any of the following situations:

8.1.1. Demolition of painted buildings or structures.

8.1.2. Renovation projects, including partial demolitions, installation of new windows or siding, and general remodeling.

8.1.3. Maintenance activities that involve any cutting, drilling, or sanding of painted surfaces.

Burning, welding, or cutting of any metal materials, whether painted, primed, or non-coated, can release very high levels of lead. Lead fumes will be generated when lead-containing materials are heated above 600 degrees Fahrenheit.

8.1.4. Plumbing work requiring welding, soldering, or replacement of metal fixtures or demolition of painted surfaces.

8.1.5. Use of any products that contain lead. The BE is responsible for providing information to individuals who will be using lead-containing materials.

8.2. 96th Civil Engineer Group (96 CEG/CEIEC and 96 CEG/CENPP) will:

8.2.1. Oversee the development and installation of a base-wide LBP Database which shall contain the results of all LBP testing.

8.2.2. Manage the LBP Database. Coordinate with BE and CEIE to ensure that the LBP

Database is current.

8.3. 796th Civil Engineer Squadron (796 CES/CEO) will:

8.3.1. Ensure any project, excluding Direct Scheduled Work performed by 796 CES, has a completed AF Form 813, Preliminary Environmental Impact Analysis, before beginning any work.

8.3.2. In the initial design phase of a project or work requirement development, include BE to determine potential areas of concern. If necessary, a predesign survey may need to be conducted. The survey may include a visual inspection and bulk sampling to assess lead hazards. If hazards are identified, the planners, designers and workers will need to incorporate necessary abatement procedures into their work plans or contract documents.

NOTE: BCE employees who conduct routine maintenance procedures should have awareness training for lead.

9. 96 CEG/CEIH: Children are affected most severely from lead exposure; therefore, the

MFH officer involvement in the LBP Management Plan will be very important. The MFH

Officer will:

9.1. Be familiar with and have easy access to all housing survey data involving LBP.

9.2. Develop and provide an informational package on LBP to families. These packages should include steps they can take to reduce exposure.

9.3. Screen requests for self-help activities that involve any disturbance of painted surfaces.

Do not approve until the lead content in painted surfaces is determined.

9.4. Lead Toxicity Investigations as defined in Appendix 3.

9.5. Contact BE concerning lead surveys of all MFH units.

9.6. Secure funding for the LBP survey from MAJCOM.

10. FACILITY MANAGERS (All units):

10.1. Take the Facility Managers training annually. This training is provided by the 796 CES

Customer Service, 796 CES/CEOER. Contact Customer Service at 882-8347 to get this training.

10.2. Be cognizant of how maintenance and renovation activities may affect LBP and the control methods that should be used. Most construction and maintenance activities that disturb

LBP will be planned and reviewed by the AF Form 813 Review Committee. During daily routines, the Facility Manager will have the opportunity to check on worker progress and determine if any suspected painted surfaces are disturbed.

10.3. Any activities that are not being performed using safe methods recognized by the LBP

Management Plan should be reported to the LBPPO immediately.

10.4. During routine inspections and operations of a particular building:

10.4.1. Inform the 96 CEG Zone Chief of water leaks or other damage that could cause paint to be disturbed.

10.4.2. Inform the 96 AMDS/SGPB of peeling or flaking paint.

11. 96 FSS/CC: It is important for the Force Support Officer to be aware of lead hazards, since day care centers and other child-oriented facilities are an abatement priority. Such areas should be properly surveyed for lead paint and lead-containing water. If lead is found, operators and workers of these facilities should:

11.1. Coordinate staff LBP training requirements and training with the Education and Training

Flight.

11.2. Assess paint conditions visually every week and never allow any activities that may disturb LBP to occur while children are in the building.

11.3. Watch for children chewing or resting their mouths on painted windowsills, playground equipment and other items.

11.4. Mop floors and wet wipe window sills and window wells, suspected or confirmed to contain LBP, frequently with a high phosphate detergent to minimize the potential for lead dust buildup.

11.5. Ensure no flaking or deteriorating lead-based paint is accessible to children.

12. 96 TW/PA: Public awareness and education on lead issues are important. All family members must understand the associated potential hazards and know the steps they can take to protect themselves and other family members. 96 TW/PA will:

12.1. Participate in the ESO Council which receives all important updates from the LBP

Working Group in order to help keep base personnel informed on lead issues and other environmental activities at the base.

12.2. Publish articles as needed in the base paper which deal with various aspects of lead as a risk in our working and domestic environment. All LBP awareness publications will be coordinated by 96 CEG/CEIEC, 96 TW/PA, 96 TW/JA, 96 AMDS/SGP/SGPB and

96 FSS/FSDE.

12.3. Publish announcements in the base paper about informal meetings, blood-lead screening programs and similar events.

13. 96 FSS/FSDE: Coordinate with 96 CEG/CEIEC and 96 AMDS/SGPB to schedule any

LBP awareness classes for personnel who, through their normal daily duties, have the potential to become exposed to airborne concentrations of lead above acceptable limits.

14. LBP WORKING GROUP:

14.1. Oversees the development of the EAFB 32-4 LBP Management Plan, to include the coordination of responsibilities.

14.2. Be formed as an ad hoc committee to develop the program and then be dissolved, to be reconfigured as the program warrants.

14.3. Be led by 96 CEG/CEIE. Membership will include at least the following organizations:

14.3.1. 96 CEG/CEIEC

14.3.2. 96 CEG/CEC, CEO, CEIH

14.3.3. 96 AMDS/SGPB and SGPM

15. 96 CEG/CEIE:

15.1. Manages all land areas (soil) of Eglin AFB that have been identified as having lead-based paint contamination.

15.2. Works with SGPB to have soils tested where lead-contaminated soils are suspected.

15.3. Pursues funding to remove all lead-contaminated soils.

15.4. Informs all regulatory agencies of sites with lead-contaminated soils.

15.5. Oversees the remediation of lead-contaminated soils.

15.6. Obtains regulatory concurrence with removing all land areas from the lead-contaminated list.

APPENDIX 3 TO ANNEX H TO EAFB PLAN 32-4

LEAD-BASED PAINT HAZARD IDENTIFICATION

1. GENERAL: This section describes LBP hazard identification approaches, methods, and procedures. Eglin AFB priority facilities are listed below:

1.1. Child Day Care Centers, annexes, playground equipment

1.2. AF-licensed family day care in military family housing

1.3. Pediatric wards/clinics and waiting areas

1.4. Temporary Lodging Facilities (TLF)

1.5. Youth centers and recreational facilities

1.6. MFH constructed before 1978

1.7. Chapel buildings

2. FACILITY LOCATIONS: Priority facilities at Eglin AFB are located as follows:

Facility Type Facility Number

Family Child Care Facilities (various) (AF Licensed) Base wide

Child Development Center Bldg 2781 and 2782

Youth Center Bldg 2582 and 2599

Chapel Bldg 605, 868, and 2574

**all playgrounds have been replaced with no painted surfaces

Note: These are areas where children frequent; therefore, they pose the greatest potential hazard on base. If LBP is found, these areas will be a priority for abatement. Risk assessments and comprehensive surveys as discussed later are only required for MFH and priority facilities.

3. STEPS FOR IMMEDIATE IDENTIFICATION OF HEALTH RISKS. The first step in implementing the program is to conduct building-by-building inspections to assess exposure concerns, starting with family housing and priority and high-priority facilities. In order to identify LBP hazards, it is necessary to understand testing procedures required in the LBP Plan.

The intent is to determine whether LBP hazards exist and, if so, to provide solutions on reducing and managing such hazards until complete abatement takes place. There are three phases of the hazard identification process:

3.1. Phase 1 - Initial Survey

3.2. Phase 2 - Performance of a Lead Exposure Risk Assessment for priority facilities

3.3. Phase 3 - Comprehensive LBP testing following the Housing and Urban Development or

Air Force equivalent guidelines.

4. INITIAL SURVEY - PHASE 1. The initial survey is a cursory examination of base housing and priority facilities for obvious signs of potential LBP hazards. The survey will be performed by the BE. The survey shall include a visual inspection of the following:

4.1. A representative number of units from each type of family housing.

4.2. All priority and high-priority facilities.

4.3. Each room of the selected units and facilities should be inspected for signs of deteriorating paint. All exterior and common areas should also be inspected. Appendix 4 should be followed when conducting the visual inspection.

4.4. Attempt to establish a pattern of where deteriorated paint exists in base housing. Additional inspections will likely be necessary. After identifying areas of loose and peeling lead-containing paint, the MFH Officer will make arrangements for such areas to be scraped and repainted as a temporary method of reducing the hazard.

5. COMPREHENSIVE LBP TESTING.

5.1. The purpose of conducting an LBP survey and testing project is to determine the location(s) of LBP-containing building components. Survey and testing is the next step after a

LERA has determined where the highest risks exist on an installation. Survey and testing should always be conducted in units where a child has an elevated blood lead level or in those units that will be renovated.

5.2. LBP survey and testing standard scope of work available in the Environmental

Management Office identifies and highlights key aspects of this type of work. Most of the material in this section comes from the highly useful Department of Housing and Urban

Development's Lead-Based Paint: Interim Guidelines for Hazard Identification in Public and

Indian Housing (Guidelines).

5.3. The scope of work assumes and it is recommended that the 1.0 mg/cm

(500 ppm) standard be used to determine abatement candidacy.

6. ROUTINE FACILITY INSPECTIONS. This applies only to priority facilities. Once the initial building evaluations are completed, annual re-inspections will be required. These inspections are important to monitor paint conditions and to correct hazards as they develop.

The inspections will be incorporated into routine facility inspections conducted by the facility manager responsible for each building.

7. LBP TESTING FOR NON-PRIORITY FACILITIES.

7.1. The comprehensive testing described for priority facilities is expensive and very time-consuming. While it is important to manage LBP in non-priority facilities, the risk to individuals in those buildings is relatively low. Testing for LBP in these buildings may occasionally be necessary when renovation, demolition or maintenance activities will disturb painted surfaces (if adequate records are not available).

7.2. Facility users/managers will initiate an AF Form 813, Request for Environmental

Assessment, prior to the initial meeting on upcoming projects. The BE will determine if the proposed scope of work will affect LBP. The BE will provide a written report to the planner/ designer listing impact areas that will need abatement actions. Such an inspection can take up to six weeks to complete. It is very important to initiate an AF Form 813 at the start of the project to prevent delays and wasting time developing a project that may not be economically feasible.

APPENDIX 4 TO ANNEX H TO EAFB PLAN 32-4

HAZARD MANAGEMENT AND RISK REDUCTION

1. GENERAL. This section presents various considerations and techniques for implementing a hazard management and risk reduction plan. The recommended philosophy of the plan should be to protect housing occupants (and workers) from situations and environments with a significant risk of exposure to sources of lead poisoning. This is markedly different from an approach that concentrates on eliminating lead-based paint just because it exists. Eliminating

LBP under most circumstances will be very expensive. Therefore, it is reasonable to manage

LBP in-place, as long as there is no significant risk of lead poisoning.

2. MISSION. The guidance that…