RFP_Atch_3e_-_Bldg_2167_Work_and_Safety_Plan.docx

Wicke Umwelttechnik GmbH

Work and Safety Plan IAW BGR 128 No.: 2167 RAB / IGR / 2016 / 12 / 02

By order of:

IGR AG

Luitpoldstraße 60a

67806 Rockenhausen

Convert Bldg. 2167

Ramstein Air Base

Table of Contents

1. Preface:

Wicke Umwelttechnik GmbH received an order from IGR AG Rockenhausen for a contaminant investigation in the context of the conversion of building 2167 on Ramstein Air Base during which several contaminants were detected. According to BGR128, it is necessary to prepare a work and safety plan for which the signatory was commissioned, and which is the subject of this report.

2. Documents used:

The report on hand is based on the Contaminant Investigation Report of the Wicke Umwelttechnik GmbH No.: 2167 RAB / IGR / 2016 / 12 / 02. All categories of contaminants as well as the sampling locations and descriptions of the building parts and components can be found there.

Moreover, reference is made to various German technical regulations, in particular the following:

National Law:

Ordiance on Preventive Occupational Health Examinations (ArbMed.VV)

BG-regulations (BGV) = Regulations of the Trade Associations, like e.g: BGR 128, BGR 128 = BG-Rules for work in contaminated areas Other regulations = PCB-regulations

3. Determination of hazards:

Contaminants or substances with potentially hazardous properties were found in the course of the contaminant investigation of the building in question. The hazard potential of these substances will be discussed below.

3.1 Asbestos:

Firmly bound asbestos containing materials were found in bldg. 2167 RAB in vinyl asbestos floorings („Floor-Flex-tiles“), asbestos cement window sills and as asbestos cement roof coverings .

The old disc seals in the flange connections of the mechanical systems were visually assessed as containing asbestos (weakly bound).

Although the powder fill of a fire rated door analyzed did not reveal any asbestos, these doors may still have asbestos-containing seals or sealing ropes (weakly bound asbestos) if their year of construction was before 1995.

The asbestos types crocidolite asbestos and chrysotile asbestos are inorganic, naturally occurring crystalline silicates which occur in the form of fibers and/or fiber bundles. Under mechanical stress, the fibers can splice longitudinally into fibers becoming increasingly thinner, which occur in the dusts resulting from handling asbestos or asbestos containing materials. Asbestos fibrers are respirable and have been proven to cause cancer.

3.2 Respirable Artificial Mineral Fibers (AMF):

Respirable artificial mineral fibers were found as mineral fiber insulation of the mechanical systems (on pipes or receptacles for ventilation, heating, water supply system) and as insulating fill of stud walls, as well as mineral fiber board inserts of various suspended ceiling structures.

The fiber geometry met the WHO criteria for critical respirable fibers (D<3µm; L>5µm; L:D>3) for most fibers. Therefore, the materials shall be classified in category 2 "potentially carcinogenic" in accordance with the GefstoffV. As far as the classification of mineral fibers and their handling is concerned, reference is made to the applicable regulations (e.g. TRGS 905, TRGS 521).

Moreover, AMF products may cause skin irritation in case of contact.

3.3 PCB (polychlorinated biphenyls):

PCB is a mixture of a multitude of isomers with different chlorine contents.

The capacitors of the old lighting system found in the building as well as any possibly existing transformers shall be classified as containing PCBs based on the current state of knowledge.

In the course of the investigation for the paints and coatings found in the building, no suspicious substances were discovered during the laboratory analyses with regard to a possible PAH contamination.

Because of the toxicity of PCBs, there is a general ban on their use. Inhalation, ingestion or absorption of PCB through the skin can cause a variety of health problems. PCB can irritate the respiratory tract, digestive tract, eyes and skin. Sometimes temporary symptoms such as dizziness, fatigue, nausea or loss of appetite occur. PCB can cause health problems, such as

· Acne,

· Digestive disorders,

· Liver damage,

· Blood count changes,

· Mood disorder.

Moreover, PCB is suspected of having carcinogenic effects. PCB can impair fertility and damage the fetus in the womb. PCB is particularly worrying because it is not or only slightly degraded in the body, but accumulates in the body.

3.4 Heavy Metals like lead, chromium, copper, nickel, cadmium, zinc.

The above mentioned heavy metals can often be found in paints and coatings.

No particularly striking heavy metal contents were found in any of the material samples analyzed.

The exposure to these dusts containing heavy metals shall be classified as hazardous to health.

Impact of substances containing lead, chromium, mercury or cadmium (among other heavy metals) on mankind and nature:

Inhalation or ingestion of substances containing lead, chromium, mercury or cadmium (eating, drinking or smoking with dirty hands) can cause various health problems. These range from temporary discomfort such as headaches, loss of appetite, fatigue, irritability or skin discolouration to more serious ones such as blood diseases, intestinal colics or seizures. Permanent damage to health is also possible (irreversible nerve damage). Lead and cadmium are potentially teratogenic and can affect fertility.

Moreover, lead, cadmium, chromium, mercury as well as zinc are ecotoxic; therefore, penetration into soil, water and sewer systems shall be avoided.

3.5 Mercury:

Mercury is an activator in elementary form in old fluorescent tubes. The release by intentional or unintentional destruction of such lamps shall therefore be avoided as a matter of urgency.

Mercury is toxic when being inhaled or swallowed. These kinds of exposure to merdury can cause irritation to the respiratory tract, digestive tract, eyes and skin (e.g. burning, tears, itching). Other symptoms range from temporary discomfort such as nausea, loss of appetite, fatigue, metal taste, diarrhoea, mood changes to more serious health problems such as lung damage, kidney damage, nerve damage, mood disorders. Mercury accumulates in the body.

The fluorescent tubes of old light-fixtures that were found inside the building can be assumed to contain mercury based on the current state of knowledge. The fluorescent tubes should be dismantled and separated without being destroyed and should be disposed of by a specialist company.

3.6 Polyaromatic hydrocarbons (PAH)

In the past, wood parquetry and wood paving blocks were usually glued with hard coal tar pitch dissolved with organic solvents. The advantage of these adhesives as compared with hot asphalt was that their preparation and handling was easier. In addition, the adhesive could be applied in thinner layers. However, hard coal tar and hard coal tar pitch contain polycyclic aromatic hydrocarbons (PAHs) which are released when dismounting these adhesive-contaminated construction materials.

Hazards for mankind and environment:

Inhalation or skin contact may cause damage to health and may cause irritation to the respiratory tract, eyes and skin as well as liver damage, kidney damage and blood count changes. Benzo(a)pyrene can harm the unborn child in the womb. Benzo(a)pyrene can affect fertility, lead to hereditary damage and cause cancer.

No PAH-contaminated substances were found in the building under investigation. However, PAH-contaminated "tar surfaces" might be present in the outdoor area. However, these were not the subject of our investigation.

For contamination loads below the limit of 50mg/kg benzo(a)pyrene (=key parameter), no contaminant-specific protective measures need to be observed when dismantling PAH-contaminated components.

3.7 Heavy metals-containing batteries of the emergency lighting system

The toxicity of compounds containing heavy metals has already been discussed mainly for lead, cadmium and mercury. They are particularly hazardous in case of uncontrolled intake, e.g. by eating or smoking with dirty fingers during or after execution of work.

3.8 Treated wood („A4-wood“)

Construction timbers, varnished wooden doors and furniture can be contaminated with toxic paints, wood preservatives or other contaminants. Therefore, their dusts are hazardous to health and have a carcinogenic potential. Absorption through the skin or by inhalation and ingestion shall be avoided. Therefore, people should not smoke when working and should absolutely wash their hands before eating or drinking.

3.9. Mineral oil hydrocarbons (MOSH)

Mineral oils of various kinds were often used in mechanical workshops. Therefore, concrete and soil in the area of these workshops may contain mineral oil hydrocarbons (MOSH).

However, detection of MOSH was not the subject of this investigation.

4. Occupational safety and health protection (safety plan):

4.1 Asbestos

All materials containing asbestos (vinyl asbestos floorings, asbestos cement roof coverings, asbestos cement window sills, disc seals containing asbestos, old fire rated doors, etc.) should be dismantled and/or milled off, should be consolidated and disposed of as asbestos-containing waste in accordance with the applicable regulations.

The technical, personal and organizational protective measures that should be taken within the scope of the remediation measures are described in detail in TRGS 519. Therefore, these measures are only listed briefly below.

Organizational measures:

· The work shall be announced to the responsible German authority „Struktur- und Genehmigungsdirektion Süd, Referat Gewerbeaufsicht, Neustadt, Mr. Zimmermann, Tel: 06321-991-144 and to the responsible trade association at least 7 days before starting execution of work.

· Preventive occupational health examinations G26.2 (respiratory protective equipment) are compulsory for working persons.

· Before starting work, all persons working shall be instructed accordingly. The instruction shall be documented in writing.

· An operating and work instruction as well as a risk assessment shall be prepared and presented on the construction site.

· The executing company shall have a supervisor with proof of expertise in compliance with TRGS 519 who will be permanently present on the construction site.

· The executing company shall have the permit according to Annex III No. 2.4.2 Para. 4 Hazardous Substances Ordinance (GefStoffV) for handling weakly bound asbestos.

Technical protective measures for dismantling „weakly bound“ asbestos products

· The working area shall be marked and signs with the necessary warnings shall be provided.

· Work shall be accomplished in enclosed areas (“containment areas”) while maintaining a vacuum.

The filtered exhaust air shall be discharged to the exterior.

· Access through a four-chamber personnel lock with shower.

· The consolidated and packed material shall be transported outside through a 2-chamber material lock.

· Afterwards, the containment area shall be cleaned with an industrial vacuum cleaner of dust filtering class H (former class “K1”). Smooth surfaces shall additionally be subject to moist cleaning (wiping).

· Before repealing the protective measures, a release measurement shall be accomplished IAW VDI 3492.

· The roof covering of corrugated asbestos cement boards shall be dismounted by unscrewing the connections from the underground. The boards shall not be damaged during this process and shall directly be packed in big bags. The working area shall be cleaned with vacuum cleaner class H.

Personal protective equipment:

· Breathing masks with particle filter P3 for weakly bound asbestos products and particle filter P2 for firmly bound asbestos-containing construction materials. The time limits for wearing respiratory protective equipment as per BGR 190 shall be complied with. (A break of minimum 30 minutes without mask after every 2 hours while wearing a mask).

· Personal protective clothing of category III, type 5/6

· Eye protection, gloves, safety shoes or boots, overshoes, as necessary.

Disposal:

· The consolidated materials can be disposed of on a SAM-certified dump under the waste code as per AVV 170605 „asbestos-containing construction materials”. (SAM = Sonderabfall-Management-Gesellschaft Rheinland Pfalz mbH, Hazardous Waste Management Society).

4.2 AMF

The technical, personal and organizational protective measures within the scope of the remediation measures are specified in TRGS 521 and vary depending on the exposure category.

In the case of large-scale dismantling of fiber-releasing AMF materials, measures in accordance with exposure category 3 are required:

Organizational Measures:

· Preventive occupational health examinations G26.2 (respiratory protective equipment) are compulsory for working persons.

· Before starting work, all persons working shall be instructed accordingly. The instruction shall be documented in writing.

· An operating and work instruction as well as a risk assessment shall be prepared and presented on the construction site.

Technical protective measures for large-scale dismantling of fiber-releasing AMF materials of exposure category 3

· The working area shall be marked and warning signs shall be provided.

· Work shall be accomplished in enclosed areas with mechanical ventilation via a suction filter system.

· Afterwards, the enclosed area shall be cleaned with an industrial vacuum cleaner of dust filtering class M as a minimzm, optionally with vaccum cleaner of the higher filter class H (K1). Smooth surfaces shall additionally be subject to moist cleaning (wiping).

· Access through a single-chamber personnel lock.

· Before repealing the protective measures, the cleaned working area shall be subject to a visual inspection by an expert. An additional measurement of the room air for efficiency control may be accomplished as per VDI 3492, however it is not mandatory.

Personal protective equipment:

· Breathing masks with particle filter P2. The time limits for wearing respiratory protective equipment as per BGR 190 shall be complied with. (A break of minimum 30 minutes without mask after every 2 hours while wearing a mask).

· Personal protective clothing of category III, type 5/6

· Eye protection, gloves, safety shoes or boots, overshoes, as necessary.

· The properly packed materials can be disposed of under the waste code as per AVV 170603 „other insulation materials consisting of hazardous materials or containing such materials”.

4.3 PCB:

The capacitors in old fluorescent lamps and transformers contain PCB.

To avoid PCB contamination of the building and of the waste to be hauled-off and to exclude a risk for the personnel, the fluorescent lamps with their integral capacitors shall be dismounted and separated undamaged and shall be disposed of by a specialist company.

Disposal of contaminated capacitors and transformers:

· Disposal shall be accomplished under the Waste Code as per AVV 160209 "Transformers and capacitors containing PCB or PCT" on a SAM-certified dump. (SAM = Sonderabfall-Management-Gesellschaft Rheinland Pfalz mbH, Hazardous Waste Management Society).

4.4 Heavy metals like lead, cadmium, zinc, chromimum, arsenic, nickel and copper No particularly striking heavy metal contents were found in any of the material samples analyzed for building 2167 RAB.

The technical, personal and organizational protective measures for removing old paint coats and coatings containing heavy metals shall be deteremined in accordance with TRGS 505, 905 and BGR 128.

Organizational measures:

· Preventive occupational health examinations G26.2 (respiratory protective equipment group II), G.40 (carcinogenic materials) and G.2 (lead and its compounds) are compulsory for working persons.

· Before starting work, all persons working shall be instructed accordingly. The instruction shall be documented in writing.

· An operating and work instruction as well as a risk assessment shall be prepared and presented on the construction site.

· The executing company shall have a supervisor with proof of expertise in compliance with BGR 128 (for remediation measures involving hazardous construction materials) who will be permanently present on the construction site.

· Before repealing the protective measures, the cleaned working area shall be subject to a visual inspection by an expert. Measurements of the room air may be accomplished as per VDI 4300 sheet 2.

Technical protective measures

· The working area shall be marked and warning signs shall be provided.

· Work shall be accomplished in enclosed areas with mechanical ventilation via a suction filter system.

· Afterwards, the enclosed area shall be cleaned with an industrial vacuum cleaner of dust filtering class M as a minim, optionally with vaccum cleaner of the higher filter class H (K1). Smooth surfaces shall additionally be subject to moist cleaning (wiping).

· Access through single-chamber lock.

· Breathing masks with particle filter P2. The time limits for wearing respiratory protective equipment as per BGR 190 shall be complied with. (A break of minimum 30 minutes without mask after every 2 hours while wearing a mask).

· The metal waste can be disposed of / recycled as coordinated with the scrap processing company (blast-furnace melting). When disposing of lead paint, e.g. in combination with wall plaster or blasting cleaning media, it depends on the “total amount of construction debris", whether only the paint is removed or whether adhering construction debris shall also be disposed of. In any case, mineral waste containing heavy metals shall be analyzed in accordance with the LAGA* requirements. If the contamination of the construction debris exceeds the LAGA-Z2 classification, this waste shall be collected in closed containers and shall be disposed of on a SAM-certified dump (SAM = Sonderabfall-Management-Gesellschaft Rheinland Pfalz mbH). The LAGA-classification values for recycling materials and non-treated construction debris are applicable: e.g. for lead: Z O (<100 mg/kg TM), Z 1.1. (<200 mg kg/TM), Z 1.2. (<300mg/kg TM), Z 2 (<1000 mg/kg TM). The Waste Disposal Ordinance (DepV) is applicable for values higher than Z2.

* LAGA = Länder Arbeitsgemeinschaft Abfall (German Federal Waste Authority)

4.5 Mercury-containing fluorescent tubes:

The fluorescent tubes of old fluorescent light-fixtures that were found inside the building can be considered as containing mercury based on the present state of knowledge.

The light-fixtures with their fluorescent tubes must not be broken during dismantling, shall be separated and disposed of properly.

Disposal of contaminated fluorescent tubes:

· The material can be disposed of under the Waste Code as per AVV: 200121 "Fluorescent tubes and other mercury containing waste” on a SAM-certified dump. (SAM = Sonderabfall-Management-Gesellschaft Rheinland Pfalz mbH).

4.6. Polyaromatic hydrocarbons (PAH)

The technical, personal and organizational protective measures within the scope of remediation measures are described in TRGS 524, 905 and BGR 128.

In the course of the investigation, no suspicious substances with regard to a possible PAH contamination were found inside the building.

For contamination loads below 50mg/kg benzo(a)pyrene, no contaminant-specific protective measures need to be observed when dismantling weakly contaminated construction materials.

If the above mentioned limit is exceeded, PAH contaminated construction materials shall be dismantled compliant with all applicable requirements and regulations.

As far as disposal is concerned, the limit value for differentiating between hazardous and non-hazardous waste is 30 mg PAH /kg dry matter IAW EPA.

PAH-contaminated roof sealing sheets and roof insulation materials shall be dismantled while observing all applicable regulations and shall be disposed of as coal tar-containing bitument mixtures (170301) or coal tar- and tar-containing products (170303).

PAH-containing adhesives or adhesive residues on concrete surfaces (floor slabs, concrete pavements or concrete roof surfaces (the latter after removal of the roof sealing layer) can be milled-off afterwards.

Organizational measures (only if the limit value for benzo(a)pyrene (50mg) is not exceeded):

· Preventive occupational health examinations G26.2 (respiratory protective equipment group II) and G.40 (carcinogenic materials) are compulsory for working persons.

· Before starting work, all persons working shall be instructed accordingly. The instruction shall be documented in writing.

· An operating and work instruction as well as a risk assessment shall be prepared and presented on the construction site.

· The executing company shall have a supervisor with proof of expertise in compliance with BGR 128 who will be permanently present on the construction site.

Organizational measures (only if the limit value for benzo(a)pyrene (50mg) is exceeded):

· The working area shall be marked and warning signs shall be provided.

· Work shall be accomplished in enclosed areas with mechanical ventilation via a suction filter system.

· Afterwards, the enclosed area shall be cleaned with an industrial vacuum cleaner of dust filtering class M as a minim, optionally with vaccum cleaner of the higher filter class H (former “K1”). Smooth surfaces shall additionally be subject to moist cleaning (wiping).

· Access through single-chamber lock.

· Before repealing the protective measures, the cleaned working area shall be subject to a visual inspection by an expert. An additional measurement of the room air for efficiency control may be accomplished as per VDI 4300, however it is not mandatory.

Personal protective equipment: (if the limit value for benzo(a)pyrene (50mg) is exceeded):

· Breathing masks with particle filter ABP2/P3. The time limits for wearing respiratory protective equipment as per BGR 190 shall be complied with. (A break of minimum 30 minutes without mask after every 2 hours while wearing a mask).

4.7 Heavy-metal containing batteries of the emergency lighting system:

The batteries shall be disposed of by a specialized disposal company. The components shall be dismantled unopened and without releasing any contaminants. They shall be loaded into appropriate containers complying with the conditions for acceptance by the disposal company and shall be hauled-off.

4.8 Treated wood („A4-wood“)

Construction timbers and their dusts can be contaminated with toxic paints, wood preservatives or other contaminants. Therefore, they may be hazardous to health and have a carcinogenic potential. Absorption through the skin or by inhalation and ingestion shall be avoided. Therefore, people should not smoke when working and should absolutely wash their hands before eating or drinking.

This wood should be dismantled with low-dust procedures, e.g. sawing with dust extraction / saber saw, so that contamination of the ambient air will be avoided as far as possible.

· Eye protection, gloves, safety shoes or boots.

· The material shall be disposed of under the waste code as per AVV 170204 „wood containing hazardous substances” (Cat. A IV), except for wood with a total PCB-content higher than 50mg/kg dry matter that shall be disposed of as “PCB-containing waste wood”.

4.9. Mineral oil hydrocarbons (MOSH)

If construction debris or soil that are contaminated with mineral oil have to be handled during excavation work, the protective measures required for handling PAH-containing materials should be complied with. Moreover, the LAGA requirements are also applicable for disposal of mineral waste.

5. Disposal scheme

All types of contaminants that have been found in the building shall be disposed of as required by the applicable legal regulations.

See table: „Disposal concept“.

6. Documentation:

Dismantling and disposal of the contaminated materials shall be documented by the responsile specialist company and shall be supervised by an expert on site if necessary.

Weilerbach, Dec. 24, 2016

F. Wicke

(Freddy Wicke, Dipl. Chem. / GF)

Geschäftsführer: Dipl. Chem. Freddy Wicke www.wicke-umwelttechnik.de image2.jpeg image1.jpeg