SOW RC Lead Sampling and Analysis 2020_.pdf

STATEMENT OF WORK

Industrial Hygiene Services for

North Dakota Army National Guard Industrial Hygiene Program Army National Guard Facilities

June 2020

1. General.

1.1 Objective.

1.1.1 The purpose of this contract is to provide qualified personnel to complete lead dust wipe sample collection in North Dakota Army National Guard (ND ARNG) Readiness Centers, analysis of the dust wipes through an accredited laboratory, interpretation of the laboratory results, and publication of a report for each facility listed in this contract.

1.1.2 The Contractor shall provide the necessary personnel and materials required to collect lead dust wipe samples and prepare a comprehensive report for the specified facilities.

1.1.3 Accredited laboratory will analyze and report results for collected lead dust wipe samples and blanks.

1.2 Description of Readiness Centers (RCs) or Armories. RCs and Armories provide space for units to support and train soldiers. They generally contain offices, classrooms, an assembly hall, and a kitchen. Some may contain an active, inactive (not converted), or converted indoor firing range and/or maintenance bay that are used during drill weekends. Include the presence of indoor firing ranges and their status as well as maintenance bays in the description of processes. Some states have a reproduction room and/or photo developing room in a RC or Armory which must also be listed and assessed.

1.3 Sampling Supplies and Equipment. All sampling supplies and equipment will be provided by the contractor. This can be through direct purchase of supplies or through coordination with the accredited laboratory.

1.4 Scheduling and Coordination. The contractor shall contact the ND ARNG State Surgeons Office to verify facility point of contact (POC) information for the facilities provided in attachment 2 and coordinate the facility visit schedule.

1.5 Laboratory Accreditation and Analyses.

1.5.1 Laboratory Accreditation. Laboratory must be accredited through the American Industrial Hygiene Association (AIHA) Environmental Lead Laboratory Accreditation Program (ELLAP) and/or the Environmental Protection Agency

ARNG-CSG-P

Statement of Work, All Facilities

(EPA) National Lead Laboratory Accreditation Program (NLLAP) for analysis of lead in dust wipes.

1.5.2 Lead Analysis. The laboratory uses Environmental Protection Agency (EPA) Method 600/r-93/200 (modified), EPA SW-846 7000B, or other recognized regulatory method for the analysis capability of lead in paint, soil, surface dust (collected by wipe), and airborne dust. The laboratory minimum detection limit must be capable of achieving less than 10 micrograms per square foot (10 µg/ft2) for surface dust samples from samples collected from a 12 inch by 12 inch square area.

1.5.3 Reporting Requirements. The laboratory provides analysis results to the contractor and the ND ARNG State Surgeons Office by e-mail in electronic pdf format within 15 business days of sample receipt. Results are reported in micrograms per square foot and document includes client sample identification numbering and scanned field data sheets.

1.6 Personnel Qualifications.

1.6.1 Field work must be performed by an individual with a minimum of 2 years experience as an industrial hygienist/industrial hygiene technician or by a currently certified EPA Lead Assessor.

1.6.2 Acceptable supporting documentation for the industrial hygienist / industrial hygiene technician would be a resume with applicable job experience/projects listed.

1.6.3 Acceptable supporting documentation for the EPA certified Lead Assessor would be a training certificate or identification card which shows Lead Assessor training occurred within the last three years.

2 Descriptions of Tasks and Specifications

2.1 Indoor Firing Range (IFR) Identification. Identify if the Readiness Center contained an indoor firing range and what status that range is now (i.e.

nonfunctional, closed, etc.) This information will be provided by the ND ARNG State Surgeons Office and verified on-site.

2.2 Sampling. Collect surface wipe samples throughout the facility following the ARNG Lead Sampling Guide (attachment 3).

2.3 Sample Analysis. Send the collected samples and blanks to an accredited laboratory.

2.4 Housekeeping. Verify the facility has a housekeeping plan that addresses lead dust. Evaluate housekeeping and hygiene practices pertaining dust throughout the facility. Verify housekeeping SOP is being followed by viewing record of cleaning at facility (if it exists).

3 Reporting Requirements. The following should be included for the final report:

3.1 Administrative Information.

3.1.1 The date of the survey, address, and the POC of the facility.

3.1.2 An executive summary of the entire survey. Maximum of 1-2 pages.

3.1.3 A table of contents for the report.

3.1.4 Personnel information about who conducted the survey (i.e. company and personnel involved).

3.1.5 A conclusion. Maximum of 1-2 paragraphs.

3.1.6 A signature (digital is allowed).

3.1.7 The entire report / supporting documents in electronic format as PDF files.

3.2 Sample Information.

3.2.1 Any findings and discussion about the sampling, housekeeping or anything else observed during the survey.

3.2.2 A table with the sampling locations and results. Note if any result exceeded 40 micrograms per square foot.

3.2.3 Photographs. Include photographs of sample locations and surrounding area (in order to identify samples location for clean-up or follow-up sampling).

3.2.4 Sampling sheets and laboratory analyses should be included in an appendix.

3.3 Other Information.

3.3.1 References. See attachment 1 for recommended references.

3.3.2 Copies of field notes.

3.3.3 Any recommendations.

4 Points of contact. Contact the ND ARNG State Surgeons Office for further information. Technical POC is Mr. Kevin Buck, 701-333-3118, kevin.k.buck.civ@mail.mil

Attachments

1. Regulations and Standards 2 List of Facilities

3. ARNG Lead Sampling Guide mailto:kevin.k.buck.civ@mail.mil

Attachment 1

Regulations and Standards

1. Memorandum for the Chiefs of Staff of all States, Puerto Rico, the US Virgin Islands, Guam, and the District of Columbia. SUBJECT: Possible Lead Dust Hazard in Army National Guard (ARNG) Readiness Centers, 23 September 2015.

2. Army National Guard (ARNG) Industrial Hygiene Program, Industrial Hygiene Sampling Guide for Surface Lead in Readiness Centers, 26 October 2015.

3. DA PAM 40-503, Medical Services, The Army Industrial Hygiene Program, 2 April 2013. http://armypubs.army.mil/epubs/pdf/P40_503.PDF

4. American Society for Testing and Materials (ASTM) Standard E1728, 2010, "Standard Practice for Collection of Settled Dust Samples Using Wipe Sampling Methods for Subsequent Lead Determination," ASTM International, West Conshohocken, PA, www.astm.org.

5. Army National Guard Pamphlet (NG Pam) 420-15, Guidelines and Procedures for Rehabilitation and Conversion of Indoor Firing Ranges, 3 November 2006.

6. OSHA Instruction Letter 02-02-058, Lead Exposure in Construction, Office of Health Compliance Assistance, 13 December 1993.

7. OSHA Standard Interpretation, Clarification of “as free as practicable” and lead contamination under 29 CFR 1926.62, dated January 13, 2003.

Notes:

1. Corps of Engineer standards should not be used.

2. Contact the Regional Industrial Hygiene Office for a copy of references if none is available.

http://armypubs.army.mil/epubs/pdf/P40_503.PDF

Attachment 2 Facility List

North Dakota Army National Guard

Facility Type

Year Built Address City, State, Zip

Armory 1989 3920 31st St. NW, Fargo AFRC 3920 Fargo, ND 58102-6206

Armory 2003 2003 N 4th St, Wahpeton AFRC 0100 Wahpeton, ND 58075-3424

Armory 1996 1501 48th St S, Grand Forks RC Grand Forks, ND 58201-

Armory 1983 4417 Highway 20, Bldg 6400 Devils Lake, ND 58301-9000

Armory 1958 504 Prospect St Lisbon, ND 58054

Armory 1971 747 7th St SE Valley City, ND 58072

Armory 1974 212 3rd St NE Jamestown, ND 58402

Armory 1991 3420 2nd St NE, Minot AFRC 0200 Minot, ND 58702-0297

Armory 1958 2 Main St. Williston, ND 58802

Armory 1973 46 Museum Drive Dickinson, ND 58601

Armory 1963 508 1st Ave Edgeley, ND 58433

Armory 1965 1208 1st Ave South Wishek, ND 58495

Armory 1988 4200 Miriam Ave, Bismarck RJB Bismarck, ND 58506

Armory 2005 4150 Miriam Ave, R&R Building Bismarck, ND 58506

Armory 2001 3406 Yegen Road, Bismarck Aviation Armory Bismarck, ND 58501

SUBJECT: ARNG Industrial Hygiene Sampling Guide for Surface Lead in Readiness Centers, 28 October 2015

Attachment 3 ARNG Lead Sampling Guide

ARMY NATIONAL GUARD

INDUSTRIAL HYGIENE SAMPLING GUIDE FOR

SURFACE LEAD IN READINESS CENTERS

28 OCTOBER 2015

1. REFERENCES. See Appendix A.

2. PURPOSE. The purpose of this guide is to provide clear instruction for conducting annual lead surface wipe sampling at Army National Guard (ARNG) Readiness Centers (RCs) that contain active, nonfunctional, closed, or disposed indoor firing ranges (IFRs).

The annual surface sampling to assess possible lead surface levels in the RC does not take the place of the mandated comprehensive industrial hygiene survey; active IFR industrial hygiene evaluation; or assessment of inactive IFRs identified for rehabilitation and conversion.

3. AUTHORITY.

a. Workplace Hazard Assessment. The Department of the Army Pamphlet (DA- PAM) 40-503, paragraph 1-8b(3), mandates that facilities provide healthful work environments in accordance with the most stringent assessment standards (reference 1). The Occupational Health and Safety Administration (OSHA) through the Code of Federal Regulations (29 CFR 1910), have enforceable regulatory standards for workplace safety (reference 2).

b. Sampling Methodology. The American Society for Testing and Materials (ASTM) International is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials, products (such as lead wipes), systems, and services, including surface wipe testing for lead (reference 3).

c. Evaluation Criteria. The recently signed Memorandum for the Chiefs of Staff (COS) regarding possible lead in RCs (reference 4) sets forth the requirement to conduct surface wipe sampling annually and to set limitations on public and family member access to the RCs based on unacceptable sampling results. The memorandum requires surface levels less than forty micrograms per square foot (<40 µg/ft2) in areas that will accessed by the public or family members. Army National Guard Regulation (NGR) 385-15 paragraph 5-4 requires a housekeeping program sufficient to maintain all active IFR surfaces as free as practicable of accumulations of lead dust (reference 5). The Army National Guard Pamphlet (NG Pam) 420-15 paragraph 3-6(o) states that the lead surface goal in rehabilitated IFRs is <200 µg/ft2 prior to encapsulation (reference 6). The NG Pam 420-15 paragraph 3- 6(p) also requires that annual testing continue after successful IFR surface cleaning, encapsulation, and enclosure (tile or linoleum) to verify that no lead migration from the substrate is occurring (reference 6).

4. SAMPLING PLANNING AND INSTRUCTIONS.

a. Sampling Plan.

1) Identification of Personnel Qualified to Conduct Sampling. As responsible office for the execution of the surface wipe sampling program (reference 4), each ARNG Regional IH Office will make the final determination as to the qualification of personnel to conduct lead surface wipe sampling. All personnel performing the wipe sampling surveys must read this guidance and either demonstrate the skills necessary to perform the work or provide proof of certification in lead sampling prior to conducting the surveys.

2) Site Identification. Complete the Facility Information Spreadsheet provided with this document, ensuring the list of all RCs containing IFRs (regardless of status) in the state, district, or territory is complete. Identify the status of IFRs (active, nonfunctional, closed, or disposed) using the criteria outlined in the ARNG COS Memorandum (reference 4) in advance if possible.

3) Coordination and Travel Planning. Coordinate with the state, district, or territory representative in the Safety and/or Occupational Health Office to arrange dates and times to conduct sampling. Plan travel routes that allow multiple facilities to be visited in a day when feasible.

4) Team Member Designation. For quality control purposes and ease of performance, it is recommended that all sampling surveys be conducted by teams of at least two personnel. Because there is variability between each person’s technique and wiping pressure during sampling, a ‘sampler’ and ‘assistant’ should be designated in each team (reference 3). The ‘sampler’ will conduct all wiping within a state, district, or territory to maintain consistency in sampling results.

5) Sample Collection Plan. Thirty five (35) samples and three blanks will be collected from each RC with an active or nonfunctional (closed but not cleaned and converted) IFR. Twenty three (23) samples and two blanks will be collected from each RC with a closed (cleaned) or disposed IFR. Sampling will be conducted using the method outlined in the ASTM E 1728 (reference 3). Sample location and methods are discussed in paragraph 4c. Actual sample locations will be recorded on a floor plan of each facility.

b. Sampling Supplies. The ARNG Regional IH Offices will provide all sampling supplies to their designated sampling teams in the region and any deviation from the following listed materials must be approved.

1) Wipes. Use Environmental Express® Ghost Wipes™ with a valid expiration date or wipes meeting the criteria outlined in ASTM E1792 (reference 7).

2) Containers. Collected wipe samples will be stored and transported in individual plastic containers with secure, screw on lids. Wipes will not be placed directly into small re-sealable plastic bags because as the ASTM E1728 relates, laboratory recoverability is improved when using straight sided plastic containers (reference 3).

3) Bags. Plastic storage bags for collected wipe samples/plastic containers will be used to further protect samples.

4) Gloves. Disposable, one time use, powder free gloves are required for each sample (reference 3).

5) Templates. To achieve the desired laboratory detection limit of 40 µg/ft2, 30 centimeter (cm) by 30 cm pre-cut cardboard one time use templates must be used.

c. Surface Wipe Sampling Procedures.

1) Supply Request. Request supplies by e-mail no less than two weeks prior to the start of the surveys using the form in Appendix B. The provided supply packs will include administrative support items such as field data sheets, laboratory chain of custody and analysis request forms, pre-labeled shipping boxes, permanent markers, duct tape, gloves, and re-sealable bags.

2) Control, Storage, and Transportation of Sampling Supplies. Maintain wipes, templates, plastic tubes, and lids in closed, re-sealable bags until ready for use and keep clean and away from contamination. Maintain visual control of supplies at all times at facilities. Do not leave collected samples and supplies in vehicles overnight and avoid temperature extremes of heat or cold.

3) Damaged Supplies. Use only supplied wipes in undamaged packaging. If a wipe is found to be dried out or damaged, it must be discarded. If other supplies are found damaged or contaminated, do not use.

4) Surface Selection. Select floor surfaces that are “solid, hard, and non-porous” as much as possible. Choose locations near the edges of rooms where dust is most likely settled. Seek out locations under desks or cabinets where cleaning occurs less frequently. Table 1 (for RCs with active or nonfunctional IFRs) and Table 2 (for RCs with closed or disposed IFRs) list surface location, type, and collection quantity. If the locations listed in the table are not present at the RC, move on to the next location designation.

Table 1. Sample Collection for RCs with Active or Nonfunctional IFRs.

Sample Collection Location Surface Type Quantity Samples

IFR1 Floor 3 IFR1 Wall 3 per wall IFR1 Ceiling/Elevated Location 3 Floor Area Outside of IFR Floor 1 Drill Hall Floor 2 Rooms specifically occupied/rented by the public (Boy/Girl Scouts etc.)

Floor 1 per room Table / Desk 1 per room

Family Readiness Office Floor 1 per office Table / Desk 1 per office

Break Room Floor 1 Table 1

Kitchen Floor 1 Counter / Prep Area 1

Other Occupied Offices or Rooms (to reach a total of 35 samples) Floor To be determined Blanks N/A 3

TOTAL 38

1 Samples Determined by NGR 385-15 and NG Pam 420-15 (references 5 and 6).

Table 2. Sample Collection for RCs with Closed or Disposed IFRs.

Sample Collection Location Surface Type Quantity Samples

Former IFR Floor 2 Former IFR Wall 1 per wall Floor Area Outside of former IFR Floor 1 Drill Hall Floor 2 Rooms specifically occupied/rented by the public (Boy/Girl Scouts etc.)

Floor 1 per room Table / Desk 1 per room

Family Readiness Office Floor 1 per office Table / Desk 1 per office

Break Room Floor 1 Table 1

Kitchen Floor 1 Counter / Prep Area 1

Other Occupied Offices or Rooms (to reach a total of 23 samples) Floor To be determined Blanks N/A 2

TOTAL 25

5) Sampling Supplies. Use a new pair of gloves and a new, clean template for the collection of each sample (reference 3). No sampling supplies will be reused.

6) Template Placement. With clean hands and only touching the outer edges, the ‘assistant’ will place a clean template on the floor surface without disturbing existing dust. They will ensure the template has the ability to lay flat and secure the template to the floor surface by its outer edges with tape. Template location will be recorded on the facility floor plan. Without touching the wipe, the ‘assistant’ will tear open the top edge of the wipe packet and hold it ready for the ‘sampler’.

7) Sample Collection. The ‘sampler’ will don a pair of clean, powder free gloves;

remove the wipe from the open package, unfold it, and begin wiping in accordance with the method outlined in ASTM E 1728 and depicted in the following (reference 3).

a) “Using an open flat hand with the fingertips together, place the wipe on the surface to be sampled. Wipe the selected surface area, side to side, in an overlapping “S” pattern while applying moderate pressure to the fingertips. Wipe the surface so that the entire selected surface area is covered. Perform the wiping process using the fingers not the entire hand” (reference 3).

b) “Fold the wipe in half with the collected dust side folded inward, and repeat the preceding wiping procedure within the selected sampling area using an overlapping up and down “S” pattern” (reference 3).

c) “Fold the wipe in half again with the collected dust side folded inward, and repeat the wiping procedure one more time, around the perimeter, concentrating on collecting settled dust from all corners and edges within the selected surface area” (reference 3).

d) While the ‘sampler’ is collecting the wipe sample, the ‘assistant’ will ready the collection tube and cap.

8) Documentation and Labeling. Use a permanent marker to mark the side of the collection tube with the sampling identification (ID). The following sampling ID naming convention will be followed:

State two letter abbreviation (space) First Four Letters of Town/City of Readiness Center

Location (space) Sample Number (space)

Example: PA HARR 1, PA HARR 2, PA HARR 3, and so on.

9) Blanks. Prepare the number of blanks described in tables 1 and 2. While wearing a pair of clean gloves open a packet, remove the wipe, expose briefly to air and place into a plastic tube and label with sample ID criteria listed above.

10) Field Data Sheets. Fill out the provided field data sheets completely including signature and date. Use the example provided in Appendix C.

11) Sample Shipping. Fill out laboratory request for analysis of the selected laboratory and include a copy of the field data sheet with the analysis request and samples. Appendix D lists important details to include on the laboratory chain of custody. Keep a copy of the lab request and field data sheet. E-mail a copy of the lab request and field data sheet to the Regional ARNG IH Office.

d. Results Discussion. The Regional IH Office will receive sample results and will provide data in a ‘preliminary findings’ e-mail that will be followed by a formal published report summarizing results for the state, district, or territory.

APPENDIX A

REFERENCES

1. Department of the Army Pamphlet (DA-PAM) 40-503, The Army Industrial Hygiene Program, 2 April 2013.

2. Title 29 Code of Federal Regulations (CFR), Part 1910, 2015 Edition, Occupational Safety and Health Administration (OSHA).

3. American Society for Testing and Materials (ASTM) Standard E1728, 2010, "Standard Practice for Collection of Settled Dust Samples Using Wipe Sampling Methods for Subsequent Lead Determination," ASTM International, West Conshohocken, PA, www.astm.org.

4. Memorandum for the Chiefs of Staff of all States, Puerto Rico, the US Virgin Islands, Guam, and the District of Columbia. SUBJECT: Possible Lead Dust Hazard in Army National Guard (ARNG) Readiness Centers, 23 September 2015.

5. Army National Guard Regulation (NGR) 385-15, Policy and Responsibility for Inspection, Evaluation, and Operation of Army National Guard Indoor Firing Ranges, 3 November 2006.

6. Army National Guard Pamphlet (NG Pam) 420-15, Guidelines and Procedures for Rehabilitation and Conversion of Indoor Firing Ranges, 3 November 2006.

7. ASTM Standard E1792, 2011, “Standard Specification for Wipe Sampling Materials for Lead in Surface Dust,” ASTM International, West Conshohocken, PA, www.astm.org.

http://www.astm.org/ http://www.astm.org/ http://www.astm.org/

APPENDIX B

EQUIPMENT AND SUPPLY REQUEST FORM (PAGE 1)

Requester Name: State/District to be sampled:

Survey Dates: Date Supplies Needed By:

Ship to Address:

Pick up at Havre de Grace, MD Office Date/Time:

List RCs

Ghost Wipes (38 or 25 per RC)

Collection Tubes + Lids

(38 or 25 per RC)

Templates (38 or 25 per RC)

Gloves (38 or 25 pairs per RC)

Large Zip Lock Bags (1 per RC)

Totals from Page 2 Additional Supplies for

Margin of Error.

+50

Additional +50 Additional +50 Additional

+50 Pairs Additional

+10 Additional

Grand Total

Additional Provided: 2 Permanent markers, 2 rolls duct tape, 1 per facility + 10 extra field data sheets, 2 per facility + 10 extra laboratory analysis requests, FedEx pre- labeled Shipping Boxes

E-mail supply requests to regional IH e-mail address

APPENDIX B

EQUIPMENT AND SUPPLY REQUEST FORM (PAGE 2)

List RCs Ghost Wipes

(38 or 25 per RC)

Collection Tubes + Lids

(38 or 25 per RC)

Templates (38 or 25 per RC)

Gloves (38 or 25 pairs per RC)

Large Zip Lock Bags (1 per RC)

Page 2 Totals

APPENDIX C

SAMPLE FIELD DATA SHEET

Wipe Sampling Project – Field Data Sheet

State/District: RC Location: Sampling Date:

UIC:

Unit POC:

Email:

Sampling Performed By: Team members:

Status of IFR at this RC: Active Inactive (closed/not cleaned) Closed (cleaned)

Disposed Unknown

Sample ID (XX XXXX #) Room/Area Surface

(Wall, Floor, etc)

Ship Samples in provided pre-labeled boxes. Include the Laboratory Chain of Custody and copy of the field data sheet(s).

Samples Shipped by:

Signature:

Date Shipped:

APPENDIX D

CHAIN OF CUSTODY/LABORATORY ANALYSIS REQUEST

Include:

The Regional IH Name and Contact Information

The State/District, Location, and Date of the Sampling

Select ‘Normal Business Hours’ and ‘Standard Turn Around Time’.

Check ‘Include COC/Field Data Sheets with Report’

Check ‘Lead (Pb) Analysis’ for ‘Dust in Wipes’

List Sample IDs and Wipe Area (30cm X 30cm = 900 cm2)

Include ‘Submitted By’ and ‘Signature’