Appendix_O_-_Lead_Paint_Mgmt_Plan.pdf

Contract No. FA2523-05-C-9001 FY-15

CDRL CEV-15F

LEAD PAINT MANAGEMENT PLAN

Thule Air Base

FINAL, FY-15

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629-3840 ext. 2698 Supersedes CDRL CEV-15F, FY-14

CDRL CEV-15F Lead Paint Management Plan

Thule Air Base 3 FY-15

TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2 REGULATORY BACKGROUND

2.1 Purpose

2.2 Scope

2.3 Regulatory Overview

3 REQUIREMENTS

3.1 Lead Based Paint Hazard Abatement

3.2 Lead Based Paint Removal

4 ORGANIZATIONS AND RESPONSIBILITIES

4.1 General

4.2 Base Commander, 821 ABG/CC

4.3 Greenland Contractors, GC

4.3.1 Base Civil Engineer, GC/CE

4.3.1.1 Project Management, GC/CESE

4.3.1.2 Engineers and Planners, GC/CEME

4.3.1.3 LBP Operating Officer, GC/OMEP

4.3.1.4 Facility Inspector, GC/CEME

4.3.2 Chief of CE Operations & Maintenance, GC/CEOM

4.3.2.1 Lead Abatement Team Leader, GC/CEOM

4.3.2.1.1 Lead Abatement Team, GC/CEOM

4.3.3 Lead Based Paint Program Officer, GC/EE

4.3.3.1 Environmental Engineering, GC/EE

4.3.3.1.1 Occupational Safety and Health, GC/OHS

4.3.4 Base Hospital, GC/SG

4.3.5 Lead Management Team, LMT

4.3.6 Seasonal Contractors

5 LEAD BASED PAINT HAZARD IDENTIFICATION

6 HAZARD MANAGEMENT AND RISK REDUCTION

6.1 In-Place Management

6.2 Facility Maintenance

6.3 Lead Based Paint Abatement in Renovation, Construction, and Demolitions

Projects

6.4 Engineering and Work Practice Controls

6.5 Housekeeping

6.6 Hygiene Facilities and Practices

6.7 Signs

6.8 Lead Containing Product Control

7 WORKER PROTECTION

7.1 Exposure assessment

7.1.1 Initial Exposure Assessments

7.1.2 Positive Initial Determination

Thule Air Base 4 FY-15

7.1.3 Negative Initial Determination

7.2 Exposure Monitoring

7.2.1 Personal Monitoring

7.2.2 Task Related Triggers

7.3 Medical Surveillance

7.3.1 Initial Surveillance

7.3.2 Routine Surveillance

7.3.3 Medical Examinations

7.4 Medical Removal Protection

7.5 Other Requirements and Guidance

8 RECORD KEEPING

8.1 Training

8.2 Personnel Exposure Monitoring – Medical Surveillance

8.3 Work Records

8.4 Waste Testing and Disposal Records

8.5 Facility Inspection

8.6 Inventory

9 PROTECTION OF FACILITY OCCUPANTS

10 TRAINING

10.1 Summary of Training

10.1.1 Employees Assigned Lead Work, LAT

10.1.2 LBPOO, Planners and Designers, CM and LATLs

10.1.3 LBPPO, GC/OHS and GC/CEOM

10.1.4 Base Personnel

11 WASTE HANDLING AND DISPOSAL

11.1 Regulatory Requirements

11.2 Lead Waste Handling

11.3 Lead Waste Disposal

12 CONTRACTING PROCEDURES

12.1 Contracting Procedures and Provisions

12.2 Regulatory Compliance

12.3 Monitoring During Contract Performance

12.4 Post Project Inspection

APPENDICES

APPENDIX 1: ABBREVIATIONS AND ACRONYMS

APPENDIX 2: DEFINITION OF TERMS

APPENDIX 3: STANDARD CONTRACT LANGUAGE

APPENDIX 4: CHECKLIST FOR ABATEMENT PLANNING

APPENDIX 5: LEAD EXPOSURE LIMITS

APPENDIX 6: REFERENCES

APPENDIX 7: DISTRIBUTION LIST

APPENDIX 8: 2014 REVIEW COMMENTS

Thule Air Base 5 FY-15

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title: The long title of this document is the “Lead Paint Management Plan”. The short title is LPMP, and this title will be used as reference throughout the entire document.

Classification: The document is unclassified.

Responsibilities: Greenland Contractors, Environmental Engineering (GC/EE) is the office of primary responsibility for establishing and maintaining the plan. The instructions given in this plan are applicable to all organizations and tenant units on Thule AB. Organizations are authorized to extract and reproduce those portions of the plan that are essential in the accomplishment of necessary planning and in the preparation of supporting documents and reports.

Reviews/changes: The plan will be reviewed and updated annually IAW the CDRL and distributed accordingly. A draft is submitted to the requiring office, 21 CES/CEIE, by 1 Nov for review. Review comments, if any, will be provided by 21 CES/CEIE within 60 days. Review comments received will be incorporated in the final version of the plan within 30 days; thereafter the document will be submitted to 821ABG/CC for signature. The signed plan will then be submitted as the Final edition.

Further, the plan is subject to change if any of the applicable laws, regulations, or requirements is altered.

Distribution: The plan will be distributed to the organizations according to the distribution list in

APPENDIX 7.

Thule Air Base 6 FY-15

2 REGULATORY BACKGROUND

2.1 Purpose

The purpose of the plan is to ensure that Lead Based Paint (LBP) and Lead Containing Materials (LCM) are managed in a safe manner that complies with applicable environmental and safety regulations.

This will include:

- Identification of actual and potential lead exposure at TAB.

- Identification of employees actually or potentially exposed to lead either through their work or dwelling.

- Identification of training requirements and through public awareness to diminish the risk of lead poisoning to human health and lead contamination of the environment.

- Testing all suspected surfaces and materials for lead concentration so that construction, demolition and maintenance activities are performed using appropriate personnel protection and waste management procedures.

- Monitoring issues of hazardous materials to prevent lead containing materials, which can be substituted with non-lead containing materials, being brought to Thule AB.

- Ensuring waste will be handled in compliance with the Hazardous Waste Management Plan, CDRL CEV-15B (HWMP) or Solid Waste Management Plan, CDRL CEV-15E (SWMP), as appropriate.

- Implementing monitoring for workers prior to, during, and after working at jobs that may result in lead exposure.

- DoD employees need to be aware of hazards at Thule Air Base, but not enrolled in an industrial hygiene surveillance program without 21 AMDS/SGGB consent.

- Ensuring personnel with elevated blood lead levels are removed from lead exposure.

The goal is to achieve a full state of awareness of the requirements for managing LBP and LCM to protect employees’ health, provide safe working conditions, and minimize the use and impacts of LBP and LCM on public health and the environment.

2.2 Scope

The provisions of the LPMP apply to all personnel, installation-wide. Certain responsibilities are assigned to specific individuals identified in the plan. Although the LPMP addresses management of LBP and LCM, waste management requirements for these materials can be found in the HWMP and SWMP.

Thule Air Base 7 FY-15

2.3 Regulatory Overview

The following legislation regulates handling of lead and lead-related work at Thule Air Base.

US Federal Laws: None, however 29 CFR, part 1926.62, Lead (Used as Guidance only)

DoD: None

USAF: Air Force Policy & Guidance on Lead Based Paint in Facilities, 24 May

Thule AB: Final Governing Standards for US Installations in Greenland (FGS)

ESOH Council Decisions

Host Country: Not applicable

Thule Air Base 8 FY-15

3 REQUIREMENTS

3.1 Lead Based Paint Hazard Abatement

In accordance with the Air Force Policy and Guidance on Lead Based Paint in Facilities, Air Force installations must identify, evaluate, control, and eliminate existing LBP hazards, giving priority to facilities frequented by children under age 7. There are no priority facilities at Thule AB, because there are no children living on base. The only time children are present at the installation is when they are at Thule in transit, before they move on to Qaanaaq or the surrounding villages.

At Thule AB the primary method for LBP hazard abatement is in-place management. Existing structures are maintained to reduce the risk of lead exposure to acceptable levels for workers and building occupants. LBP and LCM will be managed to prevent unacceptable exposures to lead during construction, renovation, and demolition activities.

Building occupants will be protected by implementation of access and administrative controls to prevent exposures to lead in active work areas. Workers will be protected from lead exposure by implementation of training, supervision in proper work procedures, use of personal protective equipment, and management requirements for LCM and LBP.

Use of LBP and LCM will be restricted to applications where there is no substitute material with adequate performance characteristics or when required by Technical Order (TO).

Generated waste containing lead or LBP will be managed in compliance with the HWMP and SWMP for Thule AB.

3.2 Lead Based Paint Removal

Removal of LBP will not be the primary method for lead abatement at Thule AB. Where LBP must be disturbed and/or removed during repair, renovation or demolition work, these activities will be conducted in a manner to minimize exposures to workers and building occupants, and to ensure waste is properly managed.

If used, specific measures, protective equipment, and clean-up procedures must be implemented in conjunction with a biological monitoring program for LBP workers to monitor potential lead poisoning through blood lead and zinc protoporphyrin (ZPP).

Thule Air Base 9 FY-15

4 ORGANIZATIONS AND RESPONSIBILITIES

4.1 General

An effective Lead Management Program at Thule Air Base (TAB) requires the participation of several organizations.

At base level the Base Civil Engineer (BCE) and Environmental Engineering (GC/EE) have the primary responsibility for developing and implementing the lead management at TAB. Other base organizations, both seasonal and permanent, must assist the BCE and EE in identification of LBP/LCM, sampling programs, quality control, legal implications and interpretations, and conservation of health and well being of all base personnel.

4.2 Base Commander, 821 ABG/CC

The Base Commander has the overall responsibility for revision and coordination of lead management at Thule AB. This responsibility is implemented through the base Environmental Protection Committee (EPC), of which the Base Commander is chairman.

4.3 Greenland Contractors, GC

Greenland Contractors has the responsibility for development and execution of an LBP Management Program. This program includes the development of a Lead Paint Management Plan (LPMP).

4.3.1 Base Civil Engineer, GC/CE

The responsibilities of the Base Civil Engineer (BCE) are:

- Ensuring projects that have the potential of exposing employees to lead dust or other lead hazards are coordinated with the Lead Based Paint Program Officer (LBPPO) in order to decide whether removal of personnel from the area, temporary controls, or other protective measures are necessary to protect personnel until recommended actions are completed.

- Development of procedures to ensure all projects developed by Thule AB Civil Engineering and seasonal contractors, which involve disturbance of LBP/LCM, is reviewed by the Lead Based Paint Operating Officer (LBPOO) for compliance with the LMP.

- Ensuring that a sufficient number of in-house technicians are trained according to section 10.

- Coordinating the schedule for lead training courses.

- Making 821 SPTS/CE aware of the training requirement to obtain funding for training of in-house resources.

- Deciding whether lead-related work will be done with Thule BMC resources or by contract.

- Maintaining the day-to-day contact with the Lead Management Team (LMT).

4.3.1.1 Project Management, GC/CESE

The responsibilities of the Project Coordinator include:

- Acting as focal point for all seasonal contractors performing projects involving disturbance of LBP/LCM.

Thule Air Base 10 FY-15

- Review contractor submittals, including documentation of sufficient training and safe work practices.

- Ensuring seasonal contractors observe the contract specifications to avoid noncompliance with lead policies and procedures for work performance, use of protective equipment, worker and supervisor training demands, work place surveillance, and clearance sampling after conclusion of the work-involving disturbance of LBP/LCM.

- Provide updated information to the LBPOO when changes in the LBP/LCM status occur.

4.3.1.2 Engineers and Planners, GC/CEME

The responsibilities of the Engineers and Planners include:

- Identifying activities that may disturb LBP in the initial design phase of a project or any work request development in cooperation with the LBPOO.

- Incorporate working procedures in projects and work requests according to directions from

LBPOO.

4.3.1.3 LBP Operating Officer, GC/OMEP

The responsibility of the LBP Operating Officer (LBPOO) includes:

- Acting as a member of the LMT.

- Successfully completing required supervisor training as required according to section 10.1.2.

- Identify and develop working procedures in connection to:

Demolition of painted buildings or structures.

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

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

Plumbing work that requires welding, soldering, or replacing metal fixtures or demolition of painted surfaces.

Soil excavation, especially in areas adjacent to buildings with LBP.

Use of any new products that contain lead.

- Obtain the necessary lead information through a LBP database in the initial design phase of a project or any work request development. If information cannot be found in the LBP database, contact the contact the 21 CES/CEPD, 21 CES/CEO and/or 21 CES/CEIEI for execution of an X-ray fluorescence test (XRF) preformed by USAF or Non-DoD personnel (Contractor) trained in the XRF Method using USAF XRF instrument.

- Assist the LBPPO during inspections of damaged LBP/LCM to decide whether repair, maintenance, or removal of the material is necessary.

- Provide updated information to the LBPPO when changes of LBP/LCM status occur.

Thule Air Base 11 FY-15

4.3.1.4 Facility Inspector, GC/CEME

The responsibilities of the Facility Inspector include:

- Acting as a member of the LMT.

- Obtaining information through the LBP database for survey preparation purposes.

- Promptly address any visibly damaged LBP/LCM in facilities to the LBPPO.

- Preparing approval-requesting documents (AF Form 332 and DD Form 1391) to initiate corrective actions for facilities where potential LBP is disturbed.

- Identify all areas of disturbed LBP found during the survey on the Facility Inspection Record Form.

4.3.2 Chief of CE Operations & Maintenance, GC/CEOM

The responsibilities of the Chief of CE O&M include:

- For in-house capacity lead abatement work, to appoint a supervisor as Lead Abatement Team Leader (LATL) for each shop within GC Operations & Maintenance, that is responsible for performance of lead-related work tasks.

- Appoint a competent person having the qualifications and authorities for ensuring worker safety and health required by this LPMP.

4.3.2.1 Lead Abatement Team Leader, GC/CEOM

It is the responsibility of the GC LATL to:

- Establish the Lead Abatement Team (LAT).

- Manage the LAT.

- Successfully completing supervisor training as required according to section 10.1.2.

- Prepare and carry out training of the LAT according to section 10.1.1.

- Keep training records of LAT members using AF Form 55 for one year beyond the last date of employment of each member.

- Insure the LAT members are scheduled for the required medical surveillance identified by the Health Services Director on AF Form 2766, Clinical Occupational Health Examination Requirements.

- Manage the lead equipment bench stock in cooperation with the other GC Operations & Maintenance shop LATLs.

- Ensure all LBP/LCM removed from a facility is properly containerized, stored in a secured area, and disposed of in accordance with the LPMP.

- The LATL establishes regulated access to work areas where it has been determined by the LBPPO that employees may have been exposed to lead dust in excess of permissible exposure levels.

Thule Air Base 12 FY-15

4.3.2.1.1 Lead Abatement Team, GC/CEOM

The LAT will perform all types of in-house lead-related work, including maintenance, renovation and abatement work etc.

4.3.3 Lead Based Paint Program Officer, GC/EE

The LBP Program Officer is responsible for:

- Acting as chairman of the LMT.

- Successfully having completed a one week training class approved by the USEPA called “Lead Based Paint Inspectors and Risk Assessors” according to Section 10.1.3.

- Acting as the focal point for all LBP issues at Thule Air Base.

- Being aware of coordination requirements for various LBP-related projects.

- Identify the location of all records for the program, including lead surveys, lab results, inspections, abatement actions, and other information (identified in section 6 of this document). Ensure records are maintained for use when needed.

- Periodic direct visual inspections to assess conditions of painted surfaces and other lead hazards.

- Assist the project planners and designers in determining if a proposed project will affect lead and how to deal with it.

- Review of all project-material technical specifications to ensure compliance with the LPMP.

- Coordinate completion of surveys of facilities prior to renovation, demolition, maintenance, and other Civil Engineering activities that may disturb lead-containing materials.

- Maintain an inventory of trained personnel and updated copies of applicable regulations on file.

- Ensuring Base Awareness Training according to section 10.1.4.

4.3.3.1 Environmental Engineering, GC/EE

The responsibility of Environmental Engineering includes:

- Swab testing of painted surfaces and paint dust.

- Soil and water sampling for testing in accordance with FGS requirements.

- Updating and maintaining a LBP testing database for TAB.

- Reviewing all purchases of hazardous materials for lead-containing materials.

4.3.3.1.1 Occupational Safety and Health, GC/OHS

For in-house resources the OSH Coordinator is responsible for:

- Acting as a member of the LMT.

- Wiping sampling for lead hazard assessment before abatement and for clearance testing after abatement.

- Air sampling to assess worker exposure and efficiency of work methods aimed at reducing lead dust generation.

- Providing fit testing of respiratory protective equipment.

Thule Air Base 13 FY-15

- Identifying required medical surveillance requirements for incorporation into the Respiratory Protection Program and in relation to lead-related work in cooperation with

GC/SG.

- Identifying required personal protective equipment (PPE) in cooperation with the GC Safety Engineer.

- Assuring that air sampling performs personal monitoring in order to determine employees’ exposure to lead dust.

- Keeping on file all work involving disturbance of LBP/LCM performed by Danish or Greenlandic employees for review by the Greenlandic Labor Inspection.

- Identifying the required PPE for employees who are involved in lead-related work.

- Being responsible for ensuring current regulations for Lead Abatement are complied with in the following areas:

Safety precautions

Applicable procedures

Work procedures

Reporting of any known or suspected lead-related problems disclosed during safety inspections.

Furthermore, successful completion of a one week training class approved by the USEPA called “Lead Based Paint Inspectors and Risk Assessors” according to section 10.1.3 is also required.

- Schedule and perform frequent and regular inspections of the job sites involving “task-related triggers” (see section 7.2.2) to determine appropriate controls and work practices, materials, and equipment to meet the requirements of this LPMP.

Identifying existing lead hazards in the workplace, being capable of selecting the appropriate control strategy, and having the authority to take prompt corrective measures.

4.3.4 Base Hospital, GC/SG

The responsibilities related to GC/SG include:

- The Base Health Services Director and the Head Nurse will act as members of the LMT.

- Assess the requirement for occupational exams for employees actually or potentially exposed to lead.

- At a minimum, GC/SG will test workers who have been exposed to lead.

- It is further the responsibility of GC/SG to perform any medical exams judged necessary for evaluation of negative impact from lead exposure for any TAB inhabitants in general, and lead exposed employees in specific.

4.3.5 Lead Management Team, LMT

A Lead Management Team (LMT) is set up to ensure effective lead management at Thule Air Base. The team consists of the LBP Program Officer (LBPPO), the LBP Operating Officer (LBPOO), the Facility Inspector, the GC/OHS, the Base Health Services Director (BHSD) and the Head Nurse (HN). The management team is responsible for ensuring that the Thule Lead Paint Management Program is implemented and properly managed.

Thule Air Base 14 FY-15

The LMT will meet quarterly to discuss medical findings and poisoning preventive measures related to LBP and LCM. All medical information will be given in a form protecting the anonymity of personnel tested and minutes from meetings will be filed with the Environmental office.

The LMT has the responsibility to:

- Ensure the Thule Air Base Lead Paint Management Program is implemented and properly managed.

- Address updates to the LMP and the lead inventory.

- Support all organizations involved in lead abatement.

- Resolve any potential conflicts.

4.3.6 Seasonal Contractors

Seasonal contractors performing work disturbing LBP/LCM will comply with the directions in the LPMP under the supervision of the Project Coordinator, Project Management – see 6.3.

Thule Air Base 15 FY-15

5 LEAD BASED PAINT HAZARD IDENTIFICATION

This section describes Lead Based Paint (LBP) hazard identification approaches, methods, and procedures to be applied at Thule AB. Thule AB does not have any priority facilities, which are frequented by children, and this document does not address priority facilities.

In order to protect personnel and workers from lead hazards and ensure safe working procedures without unnecessary delaying the performance of the daily operation in relation to e.g.: Maintenance and renovation work.

The assessment of environmental lead hazards will include any or all of the following: Evaluation of existing information in the LBP database, visual inspections and sampling for lead in paint, dust, soil, water, and air depending on the information needed, the purpose of the assessment and the nature of the environment.

Testing for LBP in non-priority buildings, which includes all facilities at TAB, becomes necessary when renovation, demolition, or maintenance activities will disturb painted surfaces and the necessary lead information cannot be found in the LBP database.

Identifying and addressing lead based paint hazard will be performed by persons and organizations involved in lead-related work, according to their responsibilities outlined in section 4.

A standard checklist is included in APPENDIX 4 to help with the process of planning LBP abatement.

Thule Air Base 16 FY-15

6 HAZARD MANAGEMENT AND RISK REDUCTION

This section presents various considerations and techniques for hazard management and risk reduction. Hazard management and risk reduction is markedly different from an approach that concentrates on eliminating LBP just because it exists. Systematic elimination of LBP at TAB will not be performed.

6.1 In-Place Management

In place management involves measures, which will reduce the LBP hazard to an acceptable level.

In-place management will include the following:

- Inspections to assess surface conditions.

- Facility maintenance.

- Incorporation of LBP abatement in renovation, construction, and demolition projects at the base.

6.2 Facility Maintenance

The following procedures must be followed for work which disturbs a surface coated with LBP which involves heating, sanding, cutting or any of the tasks stated under “Task Related Triggers”, section 7.2.2:

- If lead content information is not available, a Swab test (surface wipe test) will need to be conducted during work where lead based paint dust can occur. The LBPOO will contact the LBPPO.

- The execution of the work must be in agreement with written work procedures developed by the LBPOO and coordinated with the LBPPO. Depending on the work, the procedures must include engineering and work controls, housekeeping and hygiene facilities and practices.

- Before the work is initiated, GC/EE must be notified in order to ensure proper PPE and personnel monitoring according to section 7 of this plan.

The following work procedures will apply as a minimum:

- First, the worker shall move objects away from the work area vicinity and cover flooring and fixed objects with a layer of minimum 4-mil plastic sheeting. Lightly wetting (with water) of the area to be affected will help reduce dust levels.

- Once prep work is complete, the worker using proper personal protective equipment (PPE) may proceed to disturb the painted surface, taking care to minimize generating dust.

- After disturbance is complete, the area shall be patched and repainted as usual. Plastic sheeting should be carefully picked up and containerized. Visible paint chips should also be picked up. Collection of paint chips, dust and debris may be accomplished by using High Efficiency Particulate Air (HEPA) filtered vacuums. Collected waste must be disposed of according to the HWMP. Then wet-wipe walls and mops the floor with 5%-tri sodium phosphate (TSP) detergent.

- While conducting such activities, the workers must wear coveralls to prevent contamination of personal clothing. Coveralls must be removed on leaving the work area and disposed of as lead contaminated waste. Under no circumstances will workers wear coveralls in vehicles or at home. Reusable PPE will be wet cleaned and dried before reuse. Filters

Thule Air Base 17 FY-15 from respirators are not reusable. If overhead work is needed, it will require workers to use coveralls with a hood to prevent hair contamination. Instruct workers not to smoke, drink, or eat until the work is complete and they have thoroughly washed their hands and face.

- A competent person must schedule and perform frequent and regular inspections of the job sites in order to ensure compliance with the LPMP.

- The worker will isolate the work area from other employees.

6.3 Lead Based Paint Abatement in Renovation, Construction, and Demolitions Projects

During the initial project-planning phase of projects mentioned in the section title, the LBPOO must be informed of the intended scope of work.

The LBPOO will consult the LBP database for the necessary lead information. If information is not available, then a Swab test will need to be planned and conducted prior to the start of work.

The LBPOO will contact the LBPPO.

Based on the scope of work and the disturbance of LBP/LCM, work procedures including engineering and work controls, housekeeping and hygiene facilities and practices must be incorporated in the project by the design engineers and planners according to directions from the LBPOO.

The projects must be prepared by design engineers and planners in order to comply with the

LPMP.

The LBPPO will conduct a review of the project in order to ensure compliance with the LPMP.

GC/CE will determine if the project is feasible and cost-effective, or whether it must be reconsidered.

If work is to be performed by seasonal contractors, the Project Coordinator (GC/CESE) will ensure lead policies and procedures according to this plan are written into the contract, including “Standard Contract Language” (see APPENDIX 3).

6.4 Engineering and Work Practice Controls

The following engineering controls will be used for working in lead contaminated areas:

- HEPA filtered local exhaust ventilation for power tools used on LBP or LCM.

- HEPA vacuums for cleanup instead of dry sweeping or compressed air.

- Adequate ventilation during indoor heat gun usage to prevent buildup of lead and volatile organic compounds (VOCs).

- Use of wet methods to reduce airborne dust generation; for example, a water sprayer to hold down settled lead dust on the plastic sheeting covering the floor or ground.

Some examples of good work practices are:

- Wetting of surfaces with water mist prior to scraping, sweeping, or sawing.

- Providing onsite washing facilities, and following good hygiene practices.

Thule Air Base 18 FY-15

- Use of exclusion zones and decontamination procedures for both personnel and equipment to prevent spreading of contamination outside the work zone.

- Isolation of building ventilation systems from lead contaminated work areas (e.g., covering vents to prevent entry of lead contaminated dust and debris).

- Daily clean up of working area and equipment to prevent leaded dust accumulations.

- Whenever feasible, avoiding methods with known high exposure potential, such as machine sanding without local exhaust ventilation.

6.5 Housekeeping

All surfaces at the workplace must be kept clean and free from lead accumulations.

Cleanup of all surfaces must be completed by HEPA vacuuming.

Shoveling, wet sweeping, and brushing must only be used where vacuuming has been tried and proven ineffective.

6.6 Hygiene Facilities and Practices

Good hygiene practices must be ensured for all employees performing work that is covered by the task-related triggers or for workers who are exposed to airborne lead above the PEL.

- No food, beverage, or tobacco product may be present or consumed, no cosmetic products may be applied and neither must any wristwatches or jewelry be worn in work areas.

- Decontamination and change areas, showers (where feasible), eating, and hand washing areas must be present to prevent spread of lead contamination.

- Decontamination will be set up with a tools section (dirty), shower room and clean room.

There will be airlocks between the different sections, and contaminated working clothes must not be brought from the dirty section to the clean.

- The procedure for entering the work area will be through the clean section where protective clothing and respirators are put on, walking through the shower section and picking up tools in the dirty section to the work area.

- Leaving the work area, tools and protective clothing will be left in the dirty area; the employee will then shower and put on his daily clothes in the clean area.

- An entry/leave log will be placed at the entrance to the clean room and it must be filled in by anyone entering or leaving the work area.

- The entry/leave log will be filed in the supervisor office and kept available for the employee, former employees, and their representatives for 30 years.

- Wipe sampling of designated “clean” areas during abatement jobs lasting more than two weeks must be conducted.

Thule Air Base 19 FY-15

6.7 Signs

Warning signs with the wording shown below must be posted at every entry point to a lead contaminated working area:

Warning Lead Work Area

Poison No Smoking or Eating

This requirement does not preclude posting of other appropriate hazard warnings such as “Respirators Required in this Area.” The signs must be illuminated and cleaned as necessary so that the legend is readily visible.

6.8 Lead Containing Product Control

The HAZMART will assure requests for hazardous materials are presented to GC/EE for review.

When approved and authorized by GC/EE, the hazardous materials will be tracked through the base EMIS system.

The LBPOO will identify the facility location for lead-containing products to the LBPPO for update of the LBP Data Base.

Thule Air Base 20 FY-15

7 WORKER PROTECTION

7.1 Exposure assessment

Before workers begin any jobs involving the disturbance of lead-based paint, an exposure assessment must be accomplished to determine the actual levels of lead that are to be expected during the course of work. For lead exposure limits refer to APPENDIX 5.

7.1.1 Initial Exposure Assessments

If any employee potentially is or might be exposed to airborne concentrations of lead, initial monitoring of the work place should be conducted. The purpose of this initial assessment is to determine if workers are being exposed to lead concentrations equal to or greater than the action level (AL) of 30 g/m3. The exposure assessment can include current results from exposure monitoring of employees, previous monitoring results, or other objective data. The data must demonstrate the specific process, operation, or activity involving lead must not result in exposures above the AL under any circumstances.

7.1.2 Positive Initial Determination

When the initial assessment shows the potential for any employee to be exposed to lead concentrations at or above the AL (for one day or more), the determination is positive and exposure monitoring (or assessment with existing data) for each individual on the job must be conducted during representative work shifts.

7.1.3 Negative Initial Determination

When the determination shows that no employee is potentially exposed to lead at or above the AL (for one day or more), the determination is negative and further exposure assessment is not necessary until there is a change in the workplace.

7.2 Exposure Monitoring

Exposures must be analyzed and documented to ensure worker protection and regulatory compliance.

7.2.1 Personal Monitoring

Personal monitoring must be performed for all lead related work whenever a positive initial determination is made (see section 7.1.2.):

“Exposure Monitoring” refers to the measurement of a worker’s exposure to an airborne contaminant, regardless of any respiratory protection worn. An air sample is collected outside of any respirator worn as close to the worker’s mouth and nose as is practical and under no circumstances more than 30 cm (12 inches) away.

It is required that exposure monitoring consists of full-shift samples. In the case of multiple shifts, each shift, or the shift with the highest expected exposure level, should be monitored. Since the degree of worker protection provided may depend upon the results of exposure monitoring, it is critical that the sampling be representative of the employee’s regular, daily, and highest exposure to lead.

Until exposure assessments have been completed, appropriate controls and work practices must be developed relying on task-related triggers.

Thule Air Base 21 FY-15

7.2.2 Task Related Triggers

Table 1: Task-Related Triggers for the use of personal protective equipment (adapted from 29 CFR 1926.62:f.2.iii: Table 1)

Typical tasks: Typical concentration range Required PPE:

Manual Demolition Manual Scraping Manual Sanding Heat Gun Use Power tool paint removal in the HEPA vacuum-assist dust collection system.

50 g/m3 to 500 g/m3. Respiratory protection:

Half mask with air/purifying respirator with HEPA filter.

Protective clothing:

Disposable chemically resistant coveralls, gloves, safety shoes, shoe covers, safety goggles or shields, hardhats as required.

If work is performed under-up the coverall must be fitted with a hood.

Cleaning on dry, abrasive blasting jobs Abrasive blasting enclosure movement/removal.

500 g/m3 to 2,500 g/m3 Respiratory protection:

Full-face piece air purifying respirator with HEPA filters or better.

Protective clothing:

Disposable chemically resistant coveralls, gloves, safety shoes, shoe covers, safety goggles or shields, hardhats as required.

If work is performed under-up the coverall must be fitted with a hood.

Abrasive blasting Greater than 2,500 g/m3 Half mask supplied air respirator in pressure demand mode, other positive pressure mode or better.

Protective clothing:

Disposable chemically resistant coveralls, gloves, safety shoes, shoe covers, safety goggles or shields, hardhats as required.

If work is performed under-up the coverall must be fitted with a hood.

Cleaning PPE:

Protective clothing:

Protective clothing shall be disposed of in closed bags or containers as lead contaminated hazardous waste.

Respirators:

Respirators must be wet-cleaned after use and left to dry.

Filters must be disposed of in closed bag or contained as hazardous waste.

Thule Air Base 22 FY-15

Respiratory protection will be selected in compliance with Table 2 below:

Table 2 Respiratory Protection for Lead Exposures (adapted from 29 CFR 1926.62 (f) Table 1)

Airborne Concentration of Lead or Condition of Use

Required Respirator

Not in excess of 0.5 mg/m3 (10 X PEL) Any air purifying respirator equipped with HEPA filtersa,c.

Not in excess of 1.25 mg/m3 (25 X PEL) Any powered, air purifying respirator equipped with HEPA filtersb,c.

Not in excess of 2.5 mg/m3 (50 X PEL) Any air purifying full face piece respirator equipped with HEPA filtersb,c.

Any powered, air purifying respirator with a tight-fitting face piece and HEPA filtersb,c.

Not in excess of 50 mg/m3 (1000 X PEL) Any supplied-air respirator operated in a pressure-demand or other positive-pressure modec.

Not in excess of 100 mg/m3 (2000 X PEL) Any supplied-air respirator that has a full-face piece and is operated in a pressure-demand or other positive-pressure modec.

Greater than 100 mg/m3, unknown concentration, or fire fighting (2000 X PEL)

Any self-contained breathing apparatus that has a full-face piece and is operated in a pressure-demand or other positive-pressure modec.

Notes:

a Respirators specified for high concentrations can be used at lower concentrations of lead.

b Full face piece is required if lead aerosols cause eye or skin irritation at the use concentrations.

c A high efficiency particulate filter (HEPA) means a filter that is a 99.97% efficient against particles of 0,3 micron size or larger.

7.3 Medical Surveillance

Workers must undergo both initial and routine medical surveillance, depending upon the level and duration of their airborne exposures to lead. The LMT will discuss lead exposure and monitoring as required at their monthly meetings. The BHSD will make the determination about medical sampling requirements for employees.

All seasonal contractors are responsible for their own medical monitoring programs.

All medical examination procedures must be under the supervision of a licensed physician.

7.3.1 Initial Surveillance

Initial medical monitoring is to establish baseline Blood Lead Levels (BLL) and to detect workers who have already been overexposed to lead.

It is required to:

- Monitor individuals exposed to lead equal to or greater than 30 g/m3.

- Provide initial medical monitoring to all employees who will be performing task-related trigger activities (see Table 1 section 7.2.2).

- Conduct monitoring of worker’s BLLs and zinc protoporphyrin levels (ZPPL). ZPPL are a way of measuring long-term lead exposures.

- Provide continued medical monitoring at least every two months, until two consecutive BLLs are less than 40 g/dl when an employee’s initial BLL is equal to or greater than 40 g/dl.

Thule Air Base 23 FY-15

7.3.2 Routine Surveillance

All employees exposed to lead will have their BLL and ZPPL checked every two months.

Employees exposed to more than 30 µg/m3 lead for more than 30 days within 12 consecutive months will be given a medical examination in addition to the required BLL and ZPPL tests.

All employees must be notified of their individual BLL in writing within five working days after the receipt of the results.

All employees with a BLL greater than 40 g/dl must be informed that temporary medical removal from the worksite with lead exposure is required, when periodic and follow-up blood testing indicates a BLL equal to or greater than 50 g/dl.

Medical removal means an employee is not permitted to continue to work in a leaded environment.

7.3.3 Medical Examinations

Medical examinations must be provided prior to assignment to work in lead contaminated areas for workers whose exposures will be equal to or greater than 30 g/m3 for more than 30 days per year.

Medical examinations must be made available at least annually for any employee who has a BLL equal to or greater than 40 g/dl any time during the past 12 months.

Medical examination must be provided as soon as possible for any employee who either had reported symptoms consistent with lead intoxication or upon employee request. Reasons that an employee may request a medical examination include medical advice related to conceiving a healthy baby, pregnancy, and difficulty in breathing during respirator fit testing or use.

Written medical opinions must be handed over to employees.

Medical examinations for employees medically removed from the job due to exposures to lead must be made available to the person in question

At termination of employment, an exit medical examination will be performed for each employee.

Medical examinations provided to employees must include:

- Detailed work history

- Medical history

- Physical examination

- Pulmonary status to determine if respirator can be worn

- Blood pressure check

- Blood sampling and analysis for BLLs; and ZPPLs

- Routine urine analysis with microscopic examination

- Pregnancy testing or laboratory evaluation of male fertility, if requested by the employee

- Any other test relevant to lead exposure recommended by the examining physician

Thule Air Base 24 FY-15

7.4 Medical Removal Protection

Occupationally lead exposed employees with a BLL 50 µg/dl or more are to be medically removed from lead exposure.

Employees can be reassigned to areas where there are not occasional exposures to lead and the employee can resume performing lead work when BLLs decrease below 40 µg/dl whole blood.

Medical removal protection benefits may be enjoyed for 18 months or as long as the actual job continues, including the right to return to the former job.

7.5 Other Requirements and Guidance

In addition to this plan and the OSHA Construction Lead Standard Procedures and Testing, there are other applicable construction standards that may be used for guidance during lead hazard control projects. OSHA standards for construction are found in 29 CFR, Part 1926, Safety & Health Regulations for Construction (Used as Guidance only). Some of the other standards are:

- 29 CFR, Part 1926.20, General Safety & Health Provisions (Used as Guidance only),

- 29 CFR, Part 1926.50, Medical Services and First Aid (Used as Guidance only),

- 29 CFR, Part 1926.51, Sanitation (Used as Guidance only),

- 29 CFR, Part 1926.52, Occupational Noise Exposure (Used as Guidance only),

- 29 CFR, Part 1926.55, Gases, Vapors, Fumes, Dusts, and Mists (Used as Guidance only),

- 29 CFR, Part 1926.59, Hazard Communication (Used as Guidance only), and

- 29 CFR, Part 1926.353 (c), Ventilation: Welding, Cutting, or Heating of Toxic Metals (Used as Guidance only).

Thule Air Base 25 FY-15

8 RECORD KEEPING

Accurate records are required for all aspects of this plan, including training, worker protection, personnel exposure monitoring, educational seminars, LBP test results in non-priority facilities, maintenance records, abatement records, waste testing, waste disposal, and facility inspections.

Records of exposure assessment, medical surveillance, medical removals, and, if applicable, objective data used for exemption from the requirement for initial monitoring must be made available upon request to affected employees, former employees, and designated employee representatives. These records must be kept for 30 years (29 CFR, Part 1910.1020, Access to Employment Exposure and Medical Records (Used as Guidance only)). Reference should be made to 29 CFR, Part 1926.62, Paragraph N, Record keeping (Used as Guidance only) for additional requirements for transfer and disposal of records.

8.1 Training

Copies of all training certificates for the LBPPO, the LBPOO, and other trained base personnel must be registered in the employees’ AF Form 55: Employee Safety and Health Record and kept on file in the office/shop where the person in question is employed.

Seasonal contractors shall provide the Project Management/Project Coordinator the following for their workers:

- Written lead compliance program for the contract

And upon request from the Project Coordinator, provide documentation for the following:

- Documentation of sufficient training

- Records that medical exams, including baseline BL test and post-abatement medical exams, have been performed

The Project Coordinator will keep these documents on record.

All training records must be kept on file for the duration of employment plus one year.

8.2 Personnel Exposure Monitoring – Medical Surveillance

Personnel exposure monitoring results will be kept on file in GC/EE.

Records of all medical test results and exams will be kept on file at the Base Hospital.

These records must include:

- Employee name

- Social security number or equivalent

- Physicians written opinion

- Exposure data provided

- Employee’s medical complaints associated with lead exposure

Thule Air Base 26 FY-15

GC/SE will establish and maintain an accurate record of each employee removed from current exposure to lead. These records must have the following information:

- Employee name

- Social Security Number or equivalent

- Date of removal and return to the job with an explanation of how each removal and return was accomplished.

- Whether the removal was due to an elevated BLL. If the removal was for a different reason, the exact reason should not be stated to prevent disclosure of confidential medical information.

8.3 Work Records

Activities that disturb LBP must be provided with at least the following information:

- Activity performed

- Area of LBP disturbed

- Wipe testing results for verification of final inspection

The records will be filed in full by GC/CEOM, and the wipe testing results will be filed in GC/EE as well.

8.4 Waste Testing and Disposal Records

Waste testing and disposal records will be filed according to the TAB HWMP.

8.5 Facility Inspection

Facility inspection records will be kept on file in GC/CEOM.

8.6 Inventory

There is not any complete inventory of lead-based paint for Thule Air Base. It is recommended to perform a complete survey of lead-based paint by the XRF method for all buildings at Thule Air Base.

Thule Air Base 27 FY-15

9 PROTECTION OF FACILITY OCCUPANTS

During lead contaminated work activities, all occupants in impaired facilities are removed from areas that may expose them to lead dust and debris. Facility occupants have the right to know where the lead is located in their facility and how to protect themselves when lead-related work is being performed.

As long as precautions for abatement and maintenance work are taken as described in this plan and according to the LBPPOs recommendations, exposure in these facilities from LBP is not expected to be a significant problem.

Note:

DoD employees should not occupy or re-occupy abated area until clearance levels are acceptable IAW this plan. GC will provide a copy of clearance results to 21 CES/CEIE and 21

AMDS/SGPB.

Thule Air Base 28 FY-15

10 TRAINING

This section describes the required training for the persons involved in lead-related activities according to this plan.

10.1 Summary of Training

The following individuals must attend the listed EPA-certified and awareness courses and keep the training current through annual refresher training:

Table 3: Training Requirements for Lead Issues

Department/Individuals Course Recommended

LBPPO Lead Based Paint Inspectors and Risk Assessors to include 29 CFR 1926.62

GC/OHS Lead Based Paint Inspectors and Risk Assessors to include 29 CFR 1926.62

LBPOO, CE Planners and Designers, Construction Manager and Lead Abatement Team Leaders (LATL)

Lead Abatement for Supervisors/Contractors to include 29 CFR 1926.62

Lead Abatement Team (LAT) Trained on the contents of 29 CFR 1926.62

Base Personnel Base Awareness Training

Note:

Contractors not covered by the Occupational Safety and Health Administration (OSHA) 29 CFR 1926.62 and not appointed special tasks in this plan, will themselves be responsible for their workforce being adequately trained.

10.1.1 Employees Assigned Lead Work, LAT

Lead Worker Training will deal with the following issues:

- Hazard Communication. Hazard communication on lead hazards per 29 CFR, Part 1926.59, Hazard Communication (Used as Guidance only) for the Construction Industry.

- Safe Work Practices. Including work site preparation, permissible and prohibited practices, and cleanup.

- Engineering Controls. Including work practices associated with the employee’s job assignment, and following relevant good work practices.

- Health Risks. The nature of lead-related diseases including, but not limited to:

o Effects on the nervous system o Effects reproductive system o Effects muscular-skeletal systems and kidneys o Routes of exposure o Dose-response relationships

Precautionary Measures:

- Entry and exit procedures for the working area

- Prohibition of eating, drinking, smoking, chewing (gum or tobacco), and applying cosmetics in the work or changing area

- Potential exposure of base personnel

Thule Air Base 29 FY-15

Personal Protective Devices:

- Respirator fit-testing demonstration and hands-on training in the use of proper clothing, as well as familiarization with the requirements of 29 CFR, Part 1910.1025, Lead and 29 CFR, part 1926.62, Lead (Used as Guidance only)

Prevention of Contamination:

- Prevention of contamination of residential premises, including, but not limited to, procedures to avoid ambient discharges and ground contamination.

Medical Monitoring:

- Requirements for medical monitoring for lead toxicity, medical history for Lead abatement workers, and medical removal protection.

The LATL that have passed the “Lead abatement for Supervisors/Contractors” course will give the training. The training must be refreshed annually.

10.1.2 LBPOO, Planners and Designers, CM and LATLs

The LBPOO, Planners and Designers, Construction Manager and Lead Abatement Team Leaders (LATL) must receive and pass the “Lead abatement for Supervisors/Contractors” course. The course must consist of the following elements:

- Instruction in 29 CFR, part 1926.62, Lead (Used as Guidance only).

- Regulatory Requirements. Relevant federal and local regulatory requirements, procedures, and standards.

- Supervisory Techniques. Supervisory techniques to enforce required work practices and to discourage unsafe work practices.

- Lead Inspection Reports. Reading and interpreting lead inspections.

- Lead Disposal Requirements. Proper disposal procedures for lead-contaminated debris and soil according to the TAB HWMP.

The training must be given by an EPA-approved instructor and must be refreshed annually.

10.1.3 LBPPO, GC/OHS and GC/CEOM

The LBPPO, GC/CE and the GC/CEOM, must be trained as inspector and risk assessor. The training must cover the following areas:

- 29 CFR, part 1926.62, Lead (Used as…