Attachment_4.pdf

Lead Containing Paint Project Requirements for

Contractors and Consultants

Prepared By

Corpus Christi Army Depot

Department of Engineering Services

Facilities Engineering Management Division

May 2004

Revised May 2012

Memorandum for Lead Project Requirements

INTRODUCTION:

The work covered by this memorandum includes Corpus Christi Army Depot’s (CCAD) minimum requirements for Lead Containing Paint Surveys, Lead Air and Wipe

Sampling, and Lead Containing Paint Removal or Construction Projects. In addition to the Contracting Officer Representative (COR) and or Project Officer, the CCAD’s

Facilities Engineering Management Division and Safety and Environmental Division shall be copied on all lead-related documentation including but not limited to survey reports, air monitoring reports, project designs, in-progress daily lead reports and pre and post project submittals.

LEAD BUILDING MATERIAL SURVEYS:

1. Sampling activities undertaken to determine the presence of lead shall be conducted by personnel who have successfully completed the EPA/AHERA Lead Based Paint

Inspector/Risk Assessor course. A Lead Competent Person shall review and sign the final report.

2. The Lead Survey Report shall include:

a. Scope of Work detailing specific survey location and type of survey requested.

Include agency/person who requested the survey, purpose of the survey (planned renovation/demolition, etc.) and other hazardous materials included in the survey.

Include limitations of the survey (roofing excluded, inaccessible areas, etc.) and statement on previous lead survey data utilized.

b. Executive Summary detailing lead containing materials identified, quantity, location and condition of material. Include date when fieldwork was conducted, personnel who conducted the survey including training and/or license numbers, total number of samples collected and laboratory utilized for analysis.

c. Include section on survey methodology utilized and sampled material locations.

d. Observations/Recommendations for handling and/or removal and specific notes for damaged lead or conditions that could potentially affect the lead surface.

e. Appendices shall include laboratory sample analysis sheets (including QC samples), chain of custody, photographs of lead containing materials (if applicable), drawings depicting extent of lead containing materials and sample locations, inspectors license or training documentation, Lead Competent Person/CIH license and laboratory license/certifications (NLLAP,etc.).

LEAD SAMPLING (AIR &WIPE)

1. Sampling data reports shall include specific work area location, date collected, sample number, sample type (work area, clean room, etc.), specific sample description/location and drawing as necessary to accurately locate sample, sampling pump number, pre and post calibration flow rates, rotometer number, filter lot number, cassette sizes, type of wipes used, on/off times, total minutes of sample time, wipe area, concentration, printed name and signature of person collecting sample, printed name and signature of person performing sample analysis, Competent Person or CIH review signature, and date analyzed.

2. Personal air samples shall include employees name, last four digits of the social security number or employee I.D. number, and task being performed.

3. Personal breathing zone samples shall be collected within a one foot radius of the head (i.e., attached to or near the collar or lapel near the workers face). Area air samples shall be collected from the breathing zone typically 5-6 feet in height.

4. Pre-removal/background air/wipe sampling shall be conducted one day prior to removal activities to determine background concentrations before removal work begins.

Locations to include outside the building or outside the regulated area perimeter, inside the building or inside each regulated work area. A minimum of three pre-removal air/wipe samples shall be collected under normal building conditions.

5. Area air monitoring shall be conducted during the entire shift at locations including;

but not limited to; close to the work inside a regulated area; outside entrances to a regulated area; representative locations outside of the perimeter of a regulated area; inside clean room.

6. If sampling outside the regulated area shows elevated air lead levels, work shall be stopped immediately, and the COR, Project Officer and APM notified. The condition causing the increase shall be corrected. Work shall not restart until authorized by the

COR.

7. All sample collection and analysis shall be performed in accordance with an approved NIOSH method for lead. Results of all air/wipe sampling shall be made available to the COR, Project Officer and APM as soon a possible and results posted within the same time frame at the entrance to the regulated area and/or an adjacent location designated by the COR or Project Officer.

8. The contractor is responsible for performing exposure assessment and personal air monitoring of contractor’s workers.

9. The final air/wipe sampling report shall include a narrative on the scope of work including specific location of the project, materials and quantities removed, project duration, dates of removal, dates of clearance visual inspections/air clearance and approved changes to the scope of work. Project documentation shall include daily construction observation reports, air monitoring logs, certification of final visual inspection, analyst/laboratory certifications.

LEAD REMOVAL

Lead removal includes work that is specifically targeted at removing lead containing paint from building components. This includes mechanical, chemical, or blasting removal techniques. Throughout the duration of the contract work the safety of the

Contractor’s employees, Government employees, Government contract employees, subcontractors, and the public is the sole responsibility of the Contractor. On-site quality control is the responsibility of the Contractor. Quality control for lead removal operations includes, but is not limited to, observation regarding: integrity of the lead control barrier; decontamination facilities and protective coverings; worker protection programs; the air monitoring program; performance of removal measures including work area preparation and isolation; removal; encapsulation; patching; disposal; and conformance with Federal, State and local regulations.

Disposal of all lead containing paint and contaminated debris including PPE will be handled by the government. The government will provide the appropriate disposal containers and the contractor is responsible for placing the waste in the designated containers and ensuring containers are properly sealed when not in use. All disposal issues shall be coordinated with the COR or designated government representative.

If the Contractor’s Quality Control Program becomes ineffective and the COR, Project

Manager or COR’s designated representative determines that practices are in violation of the applicable regulations, or endangering workers or facility occupants, work shall be stopped immediately until corrective action is taken. Work shall not restart until authorized by the COR. Any costs resulting from such a stop work order issued by the

COR will be borne by the Contractor and will not be a basis for an increase in the contract amount.

LEAD PRE-JOB SUBMITTAL REQUIREMENTS

A detailed project specific pre-job submittal must be presented to the Contracting

Officer’s Representative (COR) and Project Manager for approval by CCAD’s Facilities

Engineering Management Division and Safety and Environmental Division ten (10) days before any onsite activity begins. At a minimum it must contain the following general requirements:

a) Lead Removal Plan – Submit a detailed plan of the work procedures to be used for lead removal. Such plan shall include; description and location of lead regulated areas including clean and dirty areas, decontamination unit and local exhaust equipment, sequencing of lead related work and schedule, removal method to include containment and control procedures, personal protective equipment to be used, initial exposure assessment in accordance with 29 CFR 1926.62, level of supervision, method of notification of other employers or subcontractors at the work site, interface of trades involved in the construction, fire and medical response procedures, security procedures to be used for all regulated areas, plan for storage and disposal procedures, and detailed description of the method to be employed in order to control the spread of lead wastes and airborne lead concentrations. Provide drawings as necessary to depict locations of items above.

b) Manufacturers catalog data and manufactures certification for all materials and equipment to be used in the work.

c) A Respiratory Protection Program which conforms to the requirements of 29

CFR 1910.134(b) and 29 CFR 1926.62.

d) Copy of EPA licenses, registrations and accreditation certificates, for the contractor(s) and personnel as applicable. Certifications shall include at least one Lead Competent Person and other personnel shall be trained lead workers either through an EPA accreditation program or OSHA training course.

e) Medical surveillance records, current respirator fit tests and certification of

Workers Acknowledgement for proposed project personnel.

f) Safety and Health Program

g) MSDS for all chemicals to be used onsite.

h) Information on all building materials to be installed and/or replacement parts to be used.

i) Certifications of the testing laboratory selected for the analysis of lead air, lead surface, lead bulk waste samples shall participate in the National Lead

Laboratory Accreditation Program (NLLAP) and be American Industrial

Hygiene Association (AIHA) accredited.

REQUIRED DAILY REPORTS

Daily reports shall be provided to the Project Manager and COR of all activities including, but not limited to, contractor and consultants daily field reports, containment log and visitor log, consultant reports including sampling activities, man hour utilization reports, and copies of applicable training certificates and licenses of new employees before they commence working with lead.

LEAD POST-JOB SUBMITTAL REQUIREMENTS

A detailed post-job submittal must be presented to the COR for approval by CCAD’s

Facilities Engineering Management Division and Safety and Environmental Division. At a minimum it must contain the following:

a) A narrative on the scope of work including specific location of the project, materials and quantities removed, project duration, dates of removal, dates of visual clearance, wipe or air clearance (if applicable) and approved changes to the scope of work.

b) MSDS sheets for building materials and/or replacement parts utilized on the project.

c) Training, respiratory and medical documentation for all personnel on the project.

d) Contractor and Consultants daily reports, visitor log, containment sign-in sheet.

e) Record of daily tailgate safety meetings.

f) Lead air, lead wipe, and lead bulk waste sampling log with results, laboratory sheets, and lab certifications (if applicable).

LEAD RELATED CONSTRUCTION WORK

Lead related construction work includes repair and maintenance operations that will involve some level of lead containing paint disturbance or encapsulation. This work will typically include only manual scraping for removal of lead containing paint. This type of work may also include component removal of items with lead containing paint.

Throughout the duration of the contract work the safety of the Contractor’s employees, Government employees, Government contract employees, subcontractors, and the public is the sole responsibility of the Contractor. On-site quality control is the responsibility of the Contractor. Quality control for lead containing paint operations includes, but is not limited to, observation regarding: integrity of the lead control barrier; decontamination facilities and protective coverings; worker protection programs; the air monitoring program; performance of removal measures including work area preparation and isolation; removal; encapsulation; patching; disposal; and conformance with Federal, State and local regulations.

Disposal of all lead containing paint and contaminated debris including PPE will be handled by the government. The government will provide the appropriate disposal containers and the contractor is responsible for placing the waste in the designated containers and ensuring containers are properly sealed when not in use. All disposal issues shall be coordinated with the COR or designated government representative.

If the Contractor’s Quality Control Program becomes ineffective and the COR, Project

Manager or COR’s designated representative determines that practices are in violation of the applicable regulations, or endangering workers or facility occupants, work shall be stopped immediately until corrective action is taken. Work shall not restart until authorized by the COR. Any costs resulting from such a stop work order issued by the

COR will be borne by the Contractor and will not be a basis for an increase in the contract amount.

LEAD PRE-JOB SUBMITTAL REQUIREMENTS

A detailed project specific pre-job submittal must be presented to the Contracting

Officer’s Representative (COR) and Project Manager for approval by CCAD’s Facilities

Engineering Management Division and Safety and Environmental Division ten (10) days before any onsite activity begins. At a minimum it must contain the following general requirements:

a) Lead Work Plan – Submit a detailed plan of the work procedures to be used for lead related work. Such plan shall include; description and location of components with lead containing paint, sequencing of lead related work and schedule, removal method to include containment (if applicable) and control procedures, personal protective equipment to be used, initial exposure assessment in accordance with 29 CFR 1926.62, level of supervision, method of notification of other employers or subcontractors at the work site, interface of trades involved in the construction, fire and medical response procedures, security procedures to be used for all regulated areas, plan for storage and disposal procedures, and detailed description of the method to be employed in order to control the spread of lead wastes and airborne lead concentrations.

Provide drawings as necessary to depict locations of items above.

b) Manufacturers catalog data and manufactures certification for all materials and equipment to be used in the work.

c) Encapsulation of lead containing paint shall be performed with Fiberlock Lead

Barrier Compound or equivalent material with COR or designated government representative approval.

d) A Respiratory Protection Program which conforms to the requirements of 29

CFR 1910.134(b) and 29 CFR 1926.62.

e) Copy of EPA licenses, registrations and accreditation certificates, for the contractor(s) and personnel as applicable. Certifications shall include at least one Lead Competent Person and other personnel shall have a lead awareness training course at a minimum.

f) Medical surveillance records, current respirator fit tests and certification of

Workers Acknowledgement for proposed project personnel.

g) Safety and Health Program

h) MSDS for all chemicals to be used onsite.

i) Information on all building materials to be installed and/or replacement parts to be used.

j) Certifications of the testing laboratory selected for the analysis of lead air, lead surface, lead bulk waste samples shall participate in the National Lead

Laboratory Accreditation Program (NLLAP) and be American Industrial

Hygiene Association (AIHA) accredited.

REQUIRED DAILY REPORTS

Daily reports shall be provided to the Project Manager and COR of all activities including, but not limited to, contractor and consultants daily field reports, containment log and visitor log (if applicable), consultant reports including sampling activities, man hour utilization reports, and copies of applicable training certificates and licenses of new employees before they commence working with lead.

LEAD POST-JOB SUBMITTAL REQUIREMENTS

A detailed post-job submittal must be presented to the COR for approval by CCAD’s

Facilities Engineering Management Division and Safety and Environmental Division. At a minimum it must contain the following:

g) A narrative on the scope of work including specific location of the project, materials and quantities removed, project duration, dates of removal, dates of visual clearance, wipe or air clearance (if applicable) and approved changes to the scope of work.

h) MSDS sheets for building materials and/or replacement parts utilized on the project.

i) Training, respiratory and medical documentation for all personnel on the project.

j) Contractor and Consultants daily reports, visitor log, containment sign-in sheet (if applicable).

k) Record of daily tailgate safety meetings.

l) Lead air, lead wipe, and lead bulk waste sampling log with results, laboratory sheets, and lab certifications (if applicable).

OTHER REQUIREMENTS

1. For any previously untested building components suspected to contain lead and located in areas impacted by the work, the Contractor shall notify the

COR and Project Manager. The COR will direct sampling as required to determine lead content. Any additional components identified as lead that have been approved by the COR for removal shall be removed by the

Contractor and will be paid for by an equitable adjustment to the contract.

2. Lead removal projects and other lead related work performed (i.e. surveys) considered “complete and approved for payment” when closeout report or survey report has been reviewed and approved by the COR or designated government representative.