FA9301-15-R-0005 _Attachment_2 _Appendix_B_CA_Lead_in_Paint_Specifications.pdf

SECTION 02090

EDWARDS AIR FORCE BASE,

CALIFORNIA LEAD IN PAINT

SPECIFICATIONS (February 2015)

PART 1: GENERAL REQUIREMENTS

1.1 Summary

These specifications are designed to minimize and control potential lead hazards during surface preparation prior to painting, component removal, and demolition of construction materials that contain lead. The primary focus of these specifications is to address the work practices and procedures that the Contractor must follow when conducting activities that may disturb lead in coatings during construction related work. If work regarding elevated blood lead levels, lead abatement (as defined by HUD or Title 17) or Lead Hazard abatement related work is required; requirements or specifications not addressed herein may be required by Edwards AFB and applicable regulations.

No Contractor shall begin work that will disturb painted or lead containing surfaces in a manner that will either expose a worker to possible lead containing dust, create a lead hazard as defined in Title 17 or create possible lead containing waste, until all required pre-construction documentation has been reviewed and as applicable written approval from the Owner Project Manager, Contracting Officer and Owner Lead Representatives has been received. Any Contractor observed conducting such activities without having written approval from the Owner or its designate will be instructed to stop work. Work will not be allowed to resume until the aforementioned approval has been received by the Contractor. Owner shall be defined herein as Edwards Air Force Base designated personnel such as but not limited to Project Managers, Contracting Officers and/or their representatives; Owner may also include “Owner Lead Representatives” who are Bioenvironmental Engineering, Civil Engineering and Environmental Management lead responsible personnel who are properly trained and certified to perform lead related duties in the State of California.

These specifications shall apply to all work activities that are expected to disturb paint containing lead and other lead containing or coated materials. These activities include, but are not limited to, painting preparation work, penetration of painted/lead surfaces, demolition of painted/lead surfaces, hot work on lead, removal of painted/lead building components including the removal and replacement of painted components and other lead containing or coated components.

The Contractor shall utilize engineering controls to limit the release of lead dust or debris. These engineering controls may include, but are not limited to, “containment” as defined in Title 17, using wet methods, using tools with vacuum recovery systems with High Efficiency Air Particulate (HEPA) filtration, using vacuums with HEPA filtration, and the prompt cleanup of any debris produced. Dry scraping, sanding, grinding, or abrading lead-containing materials is not permitted.

1.2 Regulatory Compliance

There are various agencies that regulate activities involving lead-containing paints and coatings. The following definitions are discussed in order to assist in the interpretation of the requirements that follow. The following is a summary list of the most important agencies and regulations that apply to the disturbance of lead and/or lead in paint during construction work. This list is not to be considered comprehensive. The Contractor is responsible for complying with all applicable Federal, State, and Local regulations that may apply to the specific work being conducted by the Contractor.

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1.2.1 Environmental Protection Agency (EPA)

Lead: Identification of Dangerous Levels of Lead; Final Rule (40 CFR Part 745 Subpart D)

The EPA defines lead-based paint as paint and coatings that contain lead in concentrations equal to or more than one milligram per square centimeter (1 mg/cm2), 5000 parts per million (5000 ppm), or one half of one percent (0.5%) by weight. EPA regulations apply to all housing and child-occupied facilities built before 1978. When the term lead-based paint is used in the context of these specifications, the term is used only to refer to paint that contains lead in concentrations equal to or greater than that defined by the EPA as lead-based paint. (This is to differentiate lead- based paint from the term lead-containing paint as used for compliance with OSHA and Cal/OSHA.)

1.2.2 California Air Resources Board (CARB)

All paints/coatings volatile organic compound (VOC) shall comply with40 CFR Part 63 Subpart GG, or federally enforced State Implementation Plan (SIP) approved limits, whichever is more stringent..

For a list of definitions and the VOC requirements of specialty coatings, please contact Environmental Management (CEV). The use of lead-based and lead containing paint is prohibited.

1.2.3 Housing and Urban Development (HUD)

Requirements for Notification, Evaluation and Reduction of Lead-Based Paint Hazards in Federally Owned Residential Property and Housing Receiving Federal Assistance (24 CFR Part 35)

The HUD Rule for Federal Housing (shortened name) applies to all residential properties built before 1978 that receive Federal financial assistance. This regulation uses the same definition of lead-based paint as the EPA. The work practices and procedures described in these specifications are designed to comply with occupant and worker protection regulations as mandated by OSHA and Cal/OSHA regulations for work that disturbs lead paint. These specifications are not designed to comply with all the requirements of 24 CFR Part 35. EAFB may require additional practices and procedures in the scope of work for activities conducted in properties covered by the HUD Rule for Federal Housing.

1.2.4 California Department of Public Health (CDPH)

Accreditation, Certification, and Work Practices for Lead-Based Paint and Lead Hazards (Title 17, CCR, Division 1, Chapter 8, Sections 35000-361000)

This regulation primarily applies to residential and public buildings located in California. The definition of a public building is one that is generally accessible to the public. Some aspects of this regulation, particularly those that pertain to the definition of presumed lead-based paint and the containment requirements for disturbing lead-based paint and/or creating lead hazards apply to all structures in California.

This CDPH regulation definition of lead-based paint is identical to the EPA/HUD definition of 1 mg/cm2, 5000 ppm, 0.5% by weight. In addition, this regulation requires all paint on structures in California to be treated as presumed lead-based paint unless the paint is on a home built after 1978 or a school built after 1992. Contractors painting or disturbing paint on EAFB structures will treat all paint and coatings as presumed lead-based paint unless the paint has been tested by EAFB or its agents and is determined to not be lead-based paint.

The CDPH regulation differentiates between work that disturbs lead as part of renovation or maintenance work and work that disturbs lead as part of abatement work as defined in Title 17. The

FA9301-15-R-0005, Attachment 2, Appendix B CA Lead in Paint Specifications Page 2 of 24 work practices and procedures described in these specifications are designed to comply with occupant and worker protection regulations as mandated by OSHA and Cal/OSHA regulations for work that disturbs lead as part of renovation, demolition, and maintenance work. These specifications are not designed to comply with the requirements for abatement as defined in the CDPH Title 17 regulation.

EAFB may require additional practices and procedures in the scope of work for activities conducted as abatement as defined by Title 17.

1.2.5 Occupational Safety and Health Administration (OSHA) and California Occupational Safety and Health Administration (Cal/OSHA)

Lead Standard for the Construction Industry (CFR 1926.62)(8 CCR 1532.1)

This standard regulates work done by employees who may disturb lead as part of renovation or maintenance work. Painting activities that may disturb lead are covered by this standard. The OSHA and the Cal/OSHA standards are virtually identical though Cal/OSHA adds some requirements that are not in the OSHA standard. Since various facilities on EAFB are covered by Cal/OSHA, and since the requirements of the Cal/OSHA standard are somewhat more stringent, EAFB requires that all construction work that disturbs lead on EAFB facilities will be done in compliance with the Cal/OSHA Lead in Construction Standard found in Title 8: Construction Safety Orders, Chapter 4, Section 1532.1 (8 CCR 1532.1).

OSHA and Cal/OSHA regulate lead whenever lead is determined to exist in a material. When the term lead-containing paint is used in the context of these specifications, the term is used to refer to paint that contains lead in an amount equal to or above the reporting limit for the laboratory analysis or detected by an X-ray Fluorescent Analyzer (XRF); NOTE, OSHA does not use/accept XRF no lead detected results.

In addition, Cal/OSHA uses the EPA/HUD/CDPH definition of lead-based paint (1 mg/cm2, 5000 ppm, 0.5% by weight) for their pre-job notification requirements discussed in section 1.3.

The Cal/OSHA standard has additional requirements that are not in the Federal OSHA standard found in CFR 1926.62. Contractors not familiar with the California standard must familiarize themselves with the additional requirements. The following information summarizes the significant additional requirements in the Cal/OSHA standard. This summary is not meant to substitute for the Contractor reading and being familiar with the Cal/OSHA requirements.

a. The California standard requires employers to notify Cal/OSHA before employees conduct a trigger task that will disturb more than 100 square or linear feet of material that contains lead in concentrations equal to or above 1 mg/cm2, 5000 ppm, 0.5% by weight. The notification also applies to welding or torch cutting that takes more than one hour in a shift. Trigger tasks are described in 8 CCR 1532.1 (d)(2). In brief, they include manual demolition, scraping, sanding, using HEPA-attached equipment, using heat guns to remove lead paint, welding, torch cutting, and using other more aggressive techniques. (This is a summary list and does not list all tasks that are considered trigger tasks.)

b. The California standard defines lead-containing paint at the Consumer Product Safety Commission (CPSC) level of 0.06% by weight or 600 ppm for non-trigger tasks. However both the California and Federal OSHA standards require training, personal protective equipment, and specific work practice precautions whenever employees will disturb lead in any concentration (including less than 600 ppm). Thus Cal/OSHA (like OSHA) regulates paint when it contains lead above the reporting limit for laboratory analysis or detectable by an XRF.

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c. The California standard also requires CDPH lead training and certification for any supervisors or workers who are shown to be exposed to airborne lead levels above the PEL in residential or public buildings. (A public building is defined as being generally accessible to the public;

many buildings on EAFB are considered public buildings.)

d. The California standard uses the term regulated area. Cal/OSHA requires the supervisor to establish a regulated area whenever workers may be exposed to airborne lead over the PEL or if they will perform trigger tasks as defined in 8 CCR 1532.1 (d)(2).

1.2.6 Edwards Air Force Base Lead Management Plan

Edwards Air Force Base Guidance for lead in paint procedures; to be used in conjunction with the Lead Specifications and applicable federal, state and local rules and regulations.

1.2.7 412 Test Wing (Edwards Air Force Base) Hazardous Waste Management Plan

Edwards Air Force Base guidance and procedures for all aspects of hazardous waste management; if other rules and regulations are more stringent, they shall take precedence.

1.3 Lead-Work Pre-Job Notification Requirements

The Contractor is responsible for complying with the Lead-Work Pre-Job Notification as specified in

8 CCR 1532.1 (p). If notification is required for this project, the Contractor must provide the notification to Cal/OSHA and provide a copy of this notification to the Base Project Manager as part of the Contractor’s pre-work submittal package.

1.4 Documents Provided To the Base Project Manager by the Contractor

While additional documents may be required by the scope of work for this project, at a minimum the Contractor will be required to provide the EAFB Project Manager with the following documents regarding the Contractors ability to safely disturb paint and other materials that contain lead.

1.4.1 Documents Submitted Prior To the Start of Work

a. Prior to starting any work, a site specific work plan must be provided to the Base Owner Lead Representatives for review and approval. The Site Specific work plan shall be a separate document from other required submittals. The work plan shall include at least the following and any other Specification or regulatory required work procedures:

1. A description of equipment and materials, controls, crew size, job responsibilities, and operations and maintenance procedures for each activity in which lead is disturbed and potentially emitted;

2. A description of specific control methods (wet methods, engineering controls, containment, etc.);

3. Technology considered in meeting the Cal/OSHA permissible exposure level (PEL);

4. Air monitoring data documenting sources of lead emissions;

5. A detailed implementation schedule for the site specific work plan, including the schedule for inspections by a competent person;

6. A description of the lead work practice program which will be used to control worker exposures. This includes the use/type of personal protective equipment, work clothing, exposure and area air monitoring equipment, hygiene facilities and

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7. A description of the steps the Contractor will take to minimize the generation of hazardous waste produced on this project. This includes, but is not necessarily limited to how the contractor will separate waste streams. For example, how will the Contractor keep potentially hazardous waste such as paint chips and dust from being disposed of with other potentially non-hazardous construction materials and debris.

Note: If the Contractor is found conducting lead related work not specifically mentioned and described in the site specific work plan, the work will be stopped until a site specific work plan including that work is submitted, reviewed, and approved by the Base Owner Lead Representatives.

b. The Contractor shall submit to Base Owner Lead Representatives copies of recent (performed within the previous 12 months or less) blood sampling and analysis test results of lead (BLL) and zinc protoporphyrin (ZPP) levels for all workers who will be performing any Trigger Tasks with regards to lead-containing paints as defined in 8 CCR 1532.1 (d)(2).

c. The Contractor shall submit to Base Owner Lead Representatives copies of current medical evaluations and respiratory fit test records done in compliance with 8 CCR 1532.1 for all workers exposed to lead and/or who will wear respirators on this project. The Contractor is responsible for maintaining current documents and resubmitting copies to EAFB for any worker whose documents expire during the project. Any worker observed on a job site that either is not approved to conduct work by EAFB or has been approved but documentation pertaining to training, medical evaluation, or respiratory fit testing has expired, will be instructed to stop work until these documents are received by EAFB and the worker is approved to perform work that disturbs lead.

d. The Contractor shall submit to Base Owner Lead Representatives proof that the supervisor and workers meet the training requirements listed in 8 CCR 1532.1 (l)(2) for employees who may be exposed above the Action Level of 30 micrograms per cubic meter ug/m3) based on an eight hour time-weighted average.

e. The Contractor shall submit to Base Owner Lead Representatives proof of current CDPH certification as a lead supervisor for the onsite competent person for all projects that include trigger tasks (as defined in 8 CCR 1532.1 (d)(2). This requirement applies whether the activities disturb lead-based paint or lead-containing paint. (Summary: the supervisor must be a CDPH Certified Lead Supervisor if the crew will conduct trigger tasks on paint containing lead.)

f. The Contractor shall submit to Base Owner Lead Representatives proof of current CDPH certification as lead workers for all workers who will conduct trigger tasks (as defined in 8

CCR

1532.1 (d)(2)) whenever the tasks will disturb lead-based paint as defined by EPA/HUD/CDPH. (Summary, the crew will need CDPH Certification as Lead Workers if they perform trigger tasks on lead-based paint. They do not need CDPH certification if they perform trigger tasks on only lead-containing paint. However, paint is presumed to be lead-based paint until proven otherwise!)

g. Depending on the SOW and prior to bidding and awarding the official task order, CDPH certified workers may be waived by Owner Lead Representative on a case by case basis. This request may also be done as per requirements of section 3.2 “Alternative Work Plans” of this specification.

h. All work plans shall be prepared or reviewed by a certified CDPH Lead Supervisor, Project

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Designer, Inspector or Monitor. Work plans shall be signed by the qualified person and dated.

1.4.2 Documents That Must Be Provided to the Base Project Manager during the Work (Or Following Completion of the Work If Applicable)

The following documents must be provided the Base Project Manager following completion of the physical activities associated with the project. The following documents must be received and approved by the Base Project Manager or its designate before the work is considered completed and payment issued.

a. The Contractor must provide the results of all area air sampling and exposure sampling done to comply with the requirements of 8 CCR 1532.1 (d). Sample information must include (but is not restricted to) the name of the individuals wearing the samples, the individuals Social Security Number or Company ID number, the date the samples were collected, identification by unique method of the area where the work is being performed, and identification of the work being performed. EXAMPLE: James Black, 000-11-222, 06/25/03, Bill Jackson Elementary School, Building H, Classroom 5, East covered walkway, painted surface preparation work (wet manual scraping). Laboratory results shall be provided to EAFB within 48 hours of sample collection.

b. The Contractor must provide all waste disposal documentation.

c. Local sanitation district Wastewater Discharge Permit for Surface Washers (if required).

All project related close out submittals for each individual project are required to be submitted to the Project Manager from the Contractor as requested or required herein.

1.5 Third-party Oversight

The services of an independent third-party consultant to provide oversight of the project will be identified in statement of work for each project; the Prime Contractor is responsible for employing the third party consultant. The Contractor shall ensure this third-party consultant complies with and ensures Contractor compliance with this specification. The third-party consultant shall be appropriately licensed in the State of California as at least a CDPH certified Lead Project Monitor. To avoid a conflict of interest this individual shall not be affiliated in any way other than through this contract with the Contractor performing the lead related work.

Third party consultant duties include but are not limited to;

a. Visual inspections; during all work phases and clearance inspections.

b. Sampling (area, personal, air quality, clearance, wipe sampling, etc.) performed in accordance with accepted methods.

c. Inspection of Contractor’s, and contractor’s employees, work practices for compliance to the project specifications, site specific work plan and applicable regulations.

d. Thorough project documentation to include daily notes.

e. Reporting project discrepancies immediately to the Project Manager and Owner Lead

Representatives.

1.6 Sampling By EAFB

EAFB or its designate may determine it appropriate to collect air samples to evaluate the effectiveness of the Contractor’s engineering controls and work practices. Air sampling may also be used to verify the effectiveness of the Contractor’s containment system. Wipe sampling may also be utilized to perform these functions.

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1.7 Air Sampling By the Contractor

The Contractor is responsible for conducting exposure air sampling of the Contractor’s employees that complies with the requirements of 8 CCR 1532.1 (d). Should the Contractor wish to make use of the exceptions to air sampling stated in 8 CCR 1532.1 (d)(3)(C) & (D), the Contractor must submit the required information to EAFB and receive written approval from EAFB prior to the Contractor reducing the personal protection, containment, or engineering controls stated in this specification. The Contractor is responsible for area air sampling if no third party consultant is employed. In summary, prior to any actions being taken based on the results of previous sampling conducted at different job sites, EAFB must specifically approve the use of those results and the actions the Contractor wishes to take on the basis of the results of that sampling. Daily exposure/area air monitoring is required for all projects until written authorization from Owner Lead Representatives relaxes this requirement. EAFB Lead Representatives are the final authority on air sample result interpretation

1.8 Notification of Employers of Employees in Adjacent Areas

The Contractor is responsible for ensuring that employers of employees in areas adjacent to the work being conducted have been notified that work disturbing lead will take place. This notification is in addition to the posting of lead regulated area signs. This notification of adjacent employers is the ultimate responsibility of the Contractor but should be done in consultation with the Base Project Manager. In summary, this notice shall be provided to all other contractors and subcontractors in areas adjacent to the work. Those employers must be notified in advance of any upcoming work that will disturb or impact lead in a manner that may generate airborne levels of lead that could present a potential exposure to workers at or above the Permissible Exposure Limit (PEL) as defined in 8 CCR 1532.1(c). This notice shall also provide information on the control measures being implemented and a warning that the employer's employees are to remain outside of the posted regulated areas.

1.9 Protection of Adjacent Items

The Contractor shall remove or protect items (if any) located within 20 feet of all lead preparation areas in order to avoid contaminating those items with lead. Those items may have to be relocated or disposed of prior to the start of work. The Contractor must coordinate with the Base Project Manager the removal of items, the storage of those items, and the protection of items or materials left inside the work area.

1.10 Protection of Access/Egress of Building Occupants

The Contractor is responsible for ensuring that building occupants and those in adjacent areas are not exposed to lead dust or debris as they enter or exit buildings. The Contractor shall ensure that building occupants and others in the adjacent area do not enter the lead regulated area and have a safe means of access and egress to the building or adjacent area.

1.11 Training Requirements

For all work that will require performing trigger tasks (as defined in 8 CCR 1532.1 (d)(2) on lead-containing or lead-based paint, the Contractor shall provide a competent person who is currently certified as a lead supervisor by CDPH. The CDPH-certified supervisor must be on site whenever work disturbing lead is being conducted. Workers conducting trigger tasks on lead-based paint must also be CDPH certified. Those conducting trigger tasks or other activities disturbing lead on lead-containing paint (but not lead-based paint) must, at a minimum, meet the training requirements listed in 8 CCR 1532.1 for those workers who may be exposed above the Action Level. For more

FA9301-15-R-0005, Attachment 2, Appendix B CA Lead in Paint Specifications Page 7 of 24 information on CDPH training and certification see section 1.4.1 g. All applicable medical and current training qualification records will be available at each job site.

1.12 Suspension of Work

EAFB or its designate may suspend all work that disturbs lead if any controls (such as barriers) fail, if excessive amounts of debris known or suspected to contain lead are detected outside the containment, or if work is on the exterior of a structure and wind speeds are more than twenty miles per hour, or if in the judgment of EAFB or its designate, other factors exist that determine the work must be stopped because o f the potential of lead hazards being created. For example, the Base Environmental Office or Bio- Engineering may conduct perimeter monitoring and discover that lead is being released in concentrations above 1 ug/m3 above background levels or work area air monitoring that is above 15 ug/m3 calculated on an eight-hour time-weighted-average. In either case, EAFB or its designate may suspend work until more effective containment, work practices, and engineering controls are utilized.

2.0 MATERIALS AND EQUIPMENT

2.1 Fire Resistant Plastic Sheeting (Poly)

All plastic sheeting used on this project must be fire resistant.

2.2 Challenge Testing Of HEPA Filtration Systems

All HEPA equipped vacuums and pressure differential units to be used on this project during lead-containing paint operations shall be tested and meet ANSI requirements using DOP or an equivalent testing agent. This testing must take place semi-annually prior to their use and after replacement of any HEPA filter removed from previously tested equipment. Copies of all certifications must be provided to EAFB prior to use of the equipment. On-site testing may be required for certain projects.

2.3 Vacuum-Assisted Tools

When using power tools to disturb lead, the Contractor shall only use tools that have a vacuum assisted process equipped with HEPA filtration. The Contractor must receive written approval from EAFB for the use of all power tools for which the Contractor feels a HEPA-vacuum assisted process is not feasible.

2.4 Power Washing

No high pressure or uncontained and vacuum recovery water blasting tools may be used if the spray will contact lead-containing paint. For the purposes of this specification, power washing is defined as: The use of a low pressure power washer to rinse/wash stable painted or coated surfaces to remove dust, dirt, grime, and other foreign matter in preparation for re-painting. In no circumstance is this to be construed as water blasting, and is not intended nor shall be used to remove lead-containing paints or coatings from surfaces. Areas of loose, peeling, cracking, or unstable coatings shall be prepared for re-painting using the appropriate methods and personnel protective equipment as specified by Cal/OSHA and CDPH regulations, and these specifications.

2.4.1 Hydro Blasting

Hydro blasting of lead shall comply with this specification and any other applicable rules and regulations for hydro blasting. Detailed information on procedures, processes, materials, engineering

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Hydro blasting paint may also disturb asbestos or paint with other heavy metals, Cal/OSHA Lead in Construction Standards considers hydro blasting to be “abrasive blasting”; The Contractor is responsible for all applicable lead and/or heavy metals rules and regulations which may apply and shall be adhered to, when applicable, including mixed waste profiling, waste stream testing/analysis and disposal requirements. Address lead / heavy metals requirements in work plan when applicable.

Waste water from hydro blasting is considered a hazardous waste until appropriate waste testing proves otherwise. A waste water permit may be required to dispose of water; contact Edwards AFB Environmental Management for permit requirements before planning hydro blast projects. No water is allowed to be disposed of (sanitary sewer, dumping, draining onto land, landfill, etc.), without first profiling the waste stream and inquiring into permit or landfill disposal requirements.

2.5 Personal Protective Equipment

The Contractor shall use respirators and personal protective equipment as required by 8 CCR 1532.1 and as appropriate based on personal air monitoring results. All respirators must be NIOSH/MSHA approved. Respirator fit test records and the respiratory protection program shall be retained on site as part of the project documentation. Disposable dust/mist respirators shall not be used.

At a minimum, half-face respirators with P-100 cartridges will be required for all work that disturbs lead. If only water washing of the surfaces is performed, respiratory protection may not be required unless the Contractor’s air sampling results indicate that respirators are required, or any airborne lead is detected during initial exposure monitoring.

At a minimum, the Contractor must ensure that no lead dust or debris is tracked out of the contained, regulated area. The Contractor must ensure that all those allowed into the regulated area have adequate foot coverings and other appropriate PPE that ensure that they will not track contaminated material out of the area when the leave.

3.0 EXECUTION

3.0.1 Summary

Contractors conducting lead related construction work will be evaluated on a performance standard which includes, but is not limited to, cleanliness of work area, work practices as verified by exposure monitoring, containment set up, and ultimately, the clean-up of paint chips, dust, and debris.

Any work practice that creates lead chips, dust, or debris must be conducted within a regulated area as defined in 8 CCR 1532.1 and within containment at least as stringent as described in these specifications, or the applicable regulation. The containment system shall be designed and constructed to prevent visible dust or debris from escaping the work area. The regulated area shall be in compliance with the Cal/OSHA lead in construction standard found in 8 CCR 1532.1 (i)(6) and Title 17. In addition, the containment shall be designed to avoid generation of airborne lead in concentrations above 1 ug/m3 above background levels as measured downwind at the perimeter of the work area.

3.1 Compliance with Requirements for the Permissible Exposure Limit and Action Level and Air Sampling

Contractors strictly adhering to EAFB suggested work practices for paint preparation work and exterior wall penetration/removal may begin work assuming the OSHA Permissible Exposure Limit

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(PEL) will not be exceeded. Except when performing the Lead-Related Tasks (or Trigger Tasks), as described in OSHA and Cal/OSHA.

Contractors not strictly conforming to suggested work practices must start work assuming the PEL will be exceeded. This means the Contractor must comply with all OSHA requirements specified for work that results in exposures over the PEL. This will include, but is not limited to, complying with requirements for training, personal protection, regulated area development, blood testing, personal air monitoring, the development of a written site specific work plan, and the notification of employers in adjacent areas. Contractors must assume the Action Level of 30 micrograms per cubic meter (30 ug/m3) will be exceeded each time a new job task is conducted.

Contractors shall conduct personal air monitoring for each different work practice or activity that disturbs materials containing lead. Monitoring shall continue until all different job classifications have been shown not to expose workers to lead levels above the Action Level (30 ug/m3 ).

EAFB or its designate may choose to collect area air samples within the work area. The result of area samples in a lead work area should normally be far below what the workers are breathing. Therefore EAFB work area air samples that result in exposures above 15 ug/m3 will trigger a re-evaluation of the Contractor’s work practices, engineering controls, and containment system.

No Negative Expose Assessment (NEA) from outside Edwards Air Force Base will be accepted. All exposure assessments shall be developed on-base and in accordance with applicable rules and regulations and are subject to Owner Lead Representative review and acceptance.

All air sampling (personal and area) shall be calibrated with either a primary air flow calibrating device or a properly calibrated and documented secondary device and all air sampling should be performed in accordance with OSHA methods; OSHA methods are also applicable to area air sampling. No pump mounted rotometers are to be used for sample calibration. Include calibration device information on sample Chain of Custody.

3.1.1 Personal Air Sampling

The Contractor is responsible for conducting personal air monitoring during disturbance of lead-containing or lead-based paint to evaluate airborne exposures during performance of any work listed as a Trigger Task as discussed in 8 CCR 1532.1 (d) (2). This sampling shall be in accordance with Cal/OSHA regulations found in Title 8 Section 1532.1, in order to determine worker exposure to lead and evaluate the effectiveness of the Contractor’s written Site Specific Work Plan submitted to EAFB.

3.2 Alternative Work Plans

The Contractor may submit a written request for alternate work plans to the EAFB suggested work practices and these Specifications, as long as the request still complies with applicable rules and regulations. These alternate work plans must be approved in writing by Owner Lead Representatives prior to their implementation or use for a site specific work plan. Justification for changes to Specification requirements and work practices is required; cost alone is not justification.

3.3 Prohibited Work Practices

The following work activities are prohibited on the project:

a. Open-flame burning or torching.

b. Machine sanding or grinding without a tool equipped with a vacuum recovery system that includes High Efficiency Particulate Air (HEPA) filtration.

c. Un-contained hydro-blasting or high-pressure washing.

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d. Abrasive blasting or sandblasting without a tool equipped with a vacuum recovery system that includes HEPA filtration or done outside of a negative pressure enclosure.

e. Heat guns operating above 700 degrees Fahrenheit.

f. Dry scraping (except for limited areas where electrical hazards create a higher risk than lead.)

g. Use of methylene chloride based paint strippers.

h. All paints/coatings shall comply with East Kern Air Pollution Control District (EKAPCD), Antelope Valley Air Quality Management District (AVAQMD), Mojave Desert Air Quality Management District (MDAQMD) volatile organic compound (VOC) requirements of 100 grams/liter VOCs, unless the coating meets the definition of a specialty coating. For a list of definitions and the VOC requirements of specialty coatings, please contact Environmental Management (CEV). The use of lead-based and lead containing paint is prohibited.

3.4 Competent Person

The Contractor shall have a competent person (as defined by Cal/OSHA) onsite at all times to supervise and oversee all activities which may disturb materials containing lead. This person must be a CDPH Certified Lead Supervisor if trigger tasks will be performed as described in 8 CCR 1532.1 (d)(2). Trigger tasks include but are not limited to, manual demolition, scraping and sanding, using heat guns, power tool cleaning with or without dust collection systems, abrasive blasting, welding, cutting, torch burning, and debris clean-up.

3.5 Work Site Preparation

Preparation of the work area at the site must be completed using 6-mil polyethylene (poly) sheeting placed over floors, asphalt, concrete, soil, vegetation, and other surfaces in the immediate work area.

3.5.1 Exterior Work Site Preparation

a. For exterior work site preparation, one layer of 6-mil poly sheeting should be placed on the ground extending at least 10 feet beyond the perimeter of surfaces included in the work. This poly sheeting must be extended a minimum of twenty feet for a multistory building. Depending on wind conditions, the poly may need to be extended further than the ten and twenty foot minimums. The poly on the ground must be adequate to catch all paint chips, dust and debris that are released by the work.

b. Do not anchor ladder feet on top of plastic (puncture the plastic to anchor ladders securely to ground). For all other exterior painted surfaces, protect the poly sheeting with boards to prevent puncture from falling debris, nails, etc., if necessary. Secure the plastic to the side of the building with tape, or other anchoring system, so there is no gap between the plastic and the building. Weight all plastic sheets down using wooden two-by-fours or similar objects. If water blasting is to be performed raise edges of the plastic to create a catch basin to prevent runoff of contaminated water.

c. The exterior of all windows/openings located within ten feet of any disturbance of lead must be sealed by covering them with at least one layer of six mil thick poly sheeting. All ventilation machinery within 20 feet of the disturbance should be sealed by at least one layer of six mil thick poly sheeting. Keep all windows/openings within 20 feet of working surfaces closed, including openings of adjacent structures.

d. Should the disturbance of paint involve removing paint from the exterior of a window, then the Contractor must seal the inside of the window with two layers of 6 mil thick poly. There shall be no gaps between the interior wall and the material. EAFB may choose to waive the

FA9301-15-R-0005, Attachment 2, Appendix B CA Lead in Paint Specifications Page 11 of 24 requirement to seal the inside of the window with two layers of poly if the disturbance of lead involves less than 5% of the painted surface area of an exterior window.

e. Those in adjacent areas must be kept a sufficient distance from any chance of encountering lead dust and debris. Therefore the Contractor shall at least erect barrier tape at a 20-foot perimeter outside the edge of the containment area poly sheeting. This barrier tape shall comply with 8 CCR 1532.1(m) and read WARNING, LEAD WORK AREA, POISON, NO SMOKING OR

EATING.

f. The barrier tape must not be directly adjacent to poly sheeting used to contain dust and debris.

There must be a buffer zone between the poly sheeting and the barrier tape. In summary, if the poly sheeting extends ten feet out from the surface being disturbed, the barrier tape must be placed 30 feet away from the surface being disturbed. However, if the poly sheeting extends to 20 feet out, then the barrier tape must be at least 40 feet out from the surface being disturbed.

The area off the poly sheeting, but inside of the barrier tape, is still part of the regulated area but is not allowed to have any lead dust or debris present at any time.

g. EAFB recognizes that the distances described in developing the containment may not be feasible in certain situations. However, compromises in these requirements must be specifically approved by EAFB prior to their implementation.

h. The Contractor shall not conduct exterior work if wind speeds are greater than 20 miles per hour.

i. Work must stop and cleanup shall occur before rain begins.

j. The Contractor shall not leave debris or poly sheeting out overnight if work is not completed. The Contractor shall keep all debris in a secured area until final disposal.

3.5.2 Interior Site Preparation

a. For interior work site preparation, one layer of 6-mil poly sheeting must be placed on the entire floor. However, the entire floor area need not be covered by poly for large interior areas where the disturbance of lead is limited to the perimeter of the area. If the entire floor area is not covered with poly, the poly must extend out a minimum of ten feet from those areas where lead will be disturbed. The poly sheeting must be secured to the floor using tape so there is no gap between the floor and the wall.

b. If individual rooms are being worked in, seal all doorways with a primitive airlock flap to prevent contamination of other areas of the building. Post Lead Warning Signs at the building/area exterior near main and all secondary entryways. Establish a Cal/OSHA regulated Area when/where applicable. All ventilation systems must be turned off and sealed off in the room or interior space where lead will be disturbed. Any exceptions to this must be approved by EAFB. Ventilation system ducts and/or registers must be sealed with poly if they are within 20 feet of the disturbance of lead even if they are turned off. If furniture or other equipment is to remain in place, cover with a single layer of poly sheeting. All cleanup of the work area shall be performed using a HEPA vacuum, wet washing and HEPA vacuum techniques.

c. For lead remediation on floors 6-mil poly sheeting shall be used adjacent to removal areas as described here-in and poly shall be placed on floors not being remediated and used to transit between the work area and the outside/clean area.

d. If Title 17 containment requirements are more stringent, comply with Title 17 requirements.

FA9301-15-R-0005, Attachment 2, Appendix B CA Lead in Paint Specifications Page 12 of 24

3.5.3 Hot Work and Abrasive Blasting

a. Hot work (welding, torch cutting, etc.) and abrasive blasting, whether indoors or out, shall be done in a negative pressure containment until an NEA is established. Per OSHA, hot work on bare metal where lead coating(s) have been removed still requires an NEA to be established.

All applicable Cal/OSHA regulations shall be complied with.

b. Abrasive blasting will always be fully contained with at least two layers of 6-mil poly to contain all potential hazardous waste blast media.

c. All hot work shall require a HEPA filtered fume collector.

d. Final cleaning shall be Full HEPA vacuum, wet - wash, and HEPA vacuum cycle. Cycle may require repeating if visual inspection by Project Monitor or Owner Lead Representative find visual dust, dirt or debris; white-glove test.

e. Wipe clearance sampling may be required.

f. Regulated area and/or warning signs shall be established as required by regulation and/or as described here-in, whichever is more stringent.

g. For small amounts or outdoor hot work see section 3.2 Alternate Work Plans.

3.6 Wet Work Practices

If scraping or sanding is to be performed, this work must be done using wet methods unless a vacuum recovery system is used that includes HEPA filtration.

3.7 Abrasive Blasting

Cal/OSHA considers hydro blasting to be abrasive blasting; Cal/OSHA requirements for lead abrasive blasting shall be complied with. Where abrasive blasting is performed by the Contractor, a negative pressure enclosure must be constructed using at a minimum, six mil thick poly sheeting. The Contractor shall utilize air filtration units equipped with HEPA filtration to establish a negative pressure within the work area. Sufficient make-up air ports shall be installed with flapped openings and pre-filters to assist in providing outside air for dilution of airborne particulate. The integrity of the negative pressure enclosure shall be maintained at all times during the abrasive blasting work to prevent fugitive emissions.

A negative exposure assessment (NEA) for hydro blasting will be allowed, but the exposure assessment documentation must be developed on EAFB and in accordance with all Cal/OSHA requirements, Title 17 and these Specifications. NEA documentation is subject to Owner Lead Representatives review and approval.

For large hydro blast areas an initial smaller test containment is recommended to establish an exposure assessment. A Negative Exposure Assessment will only reduce the requirement for the negative pressure containment; all other Specification requirements still apply.

See section 3.5.3 for more requirements.

3.8 Power Washing of Exterior Building Surfaces

For the purposes of this procedure power washing is defined as: The use of a low pressure Power Washer to rinse/wash stable painted or coated surfaces to remove dust, dirt, grime, and other foreign matter in preparation for re-painting. In no circumstance is this to be construed as water blasting, and

FA9301-15-R-0005, Attachment 2, Appendix B CA Lead in Paint Specifications Page 13 of 24 is not intended nor shall be used to remove lead-containing paints or coatings from surfaces. Areas of loose, peeling, cracking, or unstable coatings shall be prepared for re-painting using the appropriate methods and personnel protective equipment as specified by Cal/OSHA regulations, and these specifications.

3.8.1 Waste Water Discharge Permits

Many local sanitation districts require the completion and submission of a waste discharge permit prior to allowing the use of power washers. Therefore, prior to performing power- wash operations on EAFB facilities or structures, the Contractor must obtain a Wastewater Discharge Permit for Surface Washers, if required, from EAFB Sanitation District, Water Quality Division; Industrial Waste Section, and adhere to the permit requirements. It is the Contractor's responsibility to obtain and properly fill out a current copy of this permit if it is required.

3.8.2 Required Work Practices For Power Washing

Where power washing of exterior surfaces of buildings coated with lead-containing paint(s) or coating(s) is specified, or in those areas where the Contractor opts to use power washing to prepare surfaces, all of the following conditions must be met prior to proceeding. Be advised that power washing is generally considered a source for industrial waste water which is regulated by the Clean Water Act, California and Edwards AFB.

a. The Contractor in conjuncture with EAFB shall select test areas typical of the surfaces to be power washed; these shall be approximately 100 square feet each. The Contractor shall construct containments for the test areas (all power wash areas) that are designed to capture and collect all wash water and any paint chips generated during the assessment. No waste water resulting from power washing operations may be allowed to drain into any storm drain as required by the State of California at any time. The Contractor must take appropriate measures to ensure all drains are either sealed or protected from accidental discharge. This is true for this test as well as for all power-washing operations regardless of the result of the waste water test.

b. The Contractor shall proceed with washing the test area surfaces utilizing the same methods, work practices, and procedures to be used in preparing the main body of the building. The Contractor shall follow the procedures recommended by the manufacturer of the power washing equipment and all requirements of the Cal/OSHA regulations. Work shall be halted if the washing process causes delamination of paint (if present) from the test area surfaces, or if water escapes the containment. Modifications to the methods and work practices shall be made prior to resumption of power washing. These modifications must be approved by EAFB prior to their implementation.

c. The Contractor shall perform employee exposure monitoring in accord with OSHA regulations during the entire washing procedure. In addition, air sampling data generated by the contractor must be provided to EAFB.

d. Based on the initial exposure monitoring results employee protective measures such as disposable clothing and respirators may not be required as power washing is not a listed lead related task by OSHA, and in all likelihood will not cause exposures to employees of airborne lead above the action level of 30 micrograms per cubic meter of air (30 ug/m3) calculated as an eight hour time weighted average (TWA). A written request to reduce PPE is required to be submitted to the Owner Lead Personnel for review and approval prior to any reductions.

e. At the completion of test area surface preparation, representative samples of the waste water

FA9301-15-R-0005, Attachment 2, Appendix B CA Lead in Paint Specifications Page 14 of 24 shall be properly collected / handled / shipped by contractor for analysis to determine the lead and/or hazardous content; sample results shall be submitted to Environmental Management for review and interpretation. Water from the water source (prior to being used for washing) as well as from the waste water should be collected and tested for lead/hazardous concentrations.

f. Prior to starting any power washing operation the Contractor shall first coordinate with Edwards Air Force Base water quality personnel in Environmental Management to ensure all applicable waste water regulations and permitting is properly addressed.

When test area waste water results show lead levels do not exceed allowable limits the Contractor will be given instructions to proceed…