Attachment5_ LeadBasedPaintReport.pdf

Inspection Number IH 19-110 December 24, 2019

INSPECTION REPORT FOR

LEAD BASED PAINT (LBP)

USFS – KAMIAH SUPERVISORS OFFICE BUILDINGS

INSPECTION NUMBER IH 19-110

INSPECTION LOCATION:

USFS – Kamiah Supervisor’s Office Buildings Annex 1 - #1023 & Annex 2 - #1022

Kamiah, Idaho 83536

PREPARED FOR:

United States Forest Service 26 Fort Missoula Road

Missoula, Montana 59804

PREPARED BY:

Abatement Contractors of Montana, LLC 208 Commerce Street

Missoula, Montana 59807 406-549-8489 www.acm-contracting.com http://www.acm-contracting.com/

ABATEMENT CONTRACTORS OF MONTANA, LLC

PO Box 8747

Missoula, MT 59807 P 406-549-8489

F 406-728-9416

SPECIALTY CONSTRUCTION AND ENVIRONMENTAL REMEDIATION SERVICES www.acm-contracting.com

ACM Project Number: IH 19-110 December 23, 2019

LEAD-BASED PAINT INSPECTION

SUPERVISORS OFFICES

ANNEX 1, NUMBER 1023, AND ANNEX 2, NUMBER 1022

KAMIAH, IDAHO

Subject property:

Kamiah Supervisors Office Annex 1, Number 1023

Kamiah Supervisors Office

Annex 2, Number 1022

Prepared for:

26 Fort Missoula Road

Missoula, Montana 59804

Prepared by:

Abatement Contractors of Montana, LLC 208 Commerce Street

Missoula, Montana 59808

November 25, 2019 http://www.acm-contracting.com/

ACM Project Number: IH 19-110 Page 2 December 4, 2019

December 23, 2019

Corrie Kegel, PE

26 Fort Missoula Road Missoula, Montana 59804

Subject: Lead-Based Paint Inspection Report for Kamiah Supervisors Office: Annex 1, Number 1023, and Annex 2, Number 1022

Ms. Kegel, Abatement Contractors of Montana, LLC (ACM) is pleased to provide the findings of the limited lead-based paint (LBP) inspection completed at the Kamiah Supervisors Offices: Annex 1, Number 1023, and Annex 2, Number 1022, in Kamiah, Idaho 83563, hereafter referred to as the “site.” The inspection was performed November 25, 2019, by James Parker, United States (US) Environmental Protection Agency (EPA)-accredited LBP inspector.

INTRODUCTION

A LBP inspection was conducted at the Kamiah Supervisors Offices: Annex 1, Number 1023, and Annex 2, Number 1022, in Kamiah, Idaho 83563 for the United States Forest Service. The inspection was conducted by James Parker, US EPA-certified LBP inspector.

The purpose of the inspection was to confirm or deny the presence of LBP. As part of the inspection, a visual survey of the proposed work areas within the structure was conducted, and all painted surfaces were inventoried and tested.

The limited LBP inspection conformed to US Department of Housing and Urban Development (HUD) 24 CFR 35.930 (c) and (d). LBP is defined under Title X of the US EPA Residential LBP Hazard Reduction Act of 1992 as paint containing lead concentrations above 1.0 milligram per square centimeter (mg/cm

) when measured by a portable x-ray fluorescence (XRF) instrument, or 0.5% by weight

[5,000 parts per million (ppm)] when measured by a laboratory analysis.

These government offices are not considered to be a child-occupied target housing that receives federal assistance and/or is federally owned, so HUD regulations do apply.

The methods and findings for this inspection are presented in the following sections of this report.

Prior to renovation activities at the site, an abatement plan should be prepared for the containment, packaging, handling, transport and disposal of the regulated LBP identified at the site.

LEAD-BASED PAINT INSPECTION

The purpose of the LBP inspection is “to identify lead-containing surfaces”. Identification of lead-containing paint (LCP) and/or LBP is necessary to determine whether renovation/demolition workers may potentially be exposed to airborne lead concentrations exceeding permissible exposure limits (PEL) established by the Occupational Safety and Health Administration (OSHA).

HUD defines LBP as a surface coating containing lead in concentrations greater than 1.0 mg/cm

. The presence of LBP on surfaces scheduled to be impacted during the renovation activities increases the potential for workers to be exposed to airborne lead in concentrations greater than the OSHA PEL of 50 micrograms per cubic meter (µg/m

), which is established in 29 CFR 1926.62.

However, it is important to note that the presence of LCPs (i.e., coatings that contain lead at concentrations less than the HUD criterion of 1.0 mg/cm may also present a potential exposure hazard for renovation/demolition workers.

As a result of the LBP inspection conducted at the site, lead-based surface coatings (paints) were confirmed on the subject property as of the date of this inspection. The analytical results from this inspection effort identified the following LBP as defined by US EPA and/or HUD standards.

ACM Project Number: IH 19-110 Page 3 December 4, 2019

SCOPE OF WORK

The scope of work for this inspection included a LBP inspection of building components that will be impacted due to planned demolition activities. This work included a visual assessment, collecting chemical assay data via a portable x-ray fluorescence machine and documentation of suspect and confirmed/assumed LBP as defined by the US EPA and/or HUD. This inspection also included recording the locations of the materials, estimated quantities +/-10% of hazardous materials and recommendations for abatement of lead-containing surface coatings.

This limited LBP inspection was performed in anticipation of planned demolition and selective demolition activities that will disturb, impact, remove and/or demolish the building materials currently in place at the site.

The purpose for conducting the inspection was to ensure all local, state and federal regulations related to hazardous waste are complied with during the upcoming demolition of the site. Abatement Contractors of Montana, LLC’s scope of work for this inspection did not include preparation of abatement plans.

SITE DESCRIPTION

The Kamiah Supervisors Offices: Annex 1, Number 1023, and Annex 2, Number 1022, in Kamiah, Idaho have gone through some renovations. Although the exact history of the past construction history is unknown, the available data indicates that the original building was constructed in the 1960’s.

EXTERIOR OF BUILDING

The roofs of both buildings are framed with wood joists over pitched rafters. The rafters are supported on the north and south sides by wood framed walls which are covered with ply board siding. The east and west gables are wood framed and are covered with the same ply board siding.

The roofing materials were observed to be composite shingle.

The exterior wood sheathed walls transition to concrete basement walls to grade level, and the basement floor is concrete slab on grade. The upper ground level floor is supported by a center glue laminated beam that is supported by steel posts.

The exterior trim for the building includes gutters, downspouts, fascia and soffits. The windows include the following building components: aprons, casing and mullions. The exterior doors include the following building components: casing, jamb and apron.

INTERIOR OF BUILDING

The interior building components include window aprons, casings and mullions and door casings, jambs and aprons. The interior finish materials of the building vary depending on the portion of the building. Other portions of the building includes interior finish materials, such as vinyl floor tiles, vinyl sheet flooring, ceramic tile with grout, gypsum walls and ceilings, compressed wood fiberboard ceiling tiles resting on a suspended grid system and kitchen cabinetry.

EXPLANATION OF REGULATIONS

The OSHA 29 CFR 1926.62, Lead in Construction Standard, does not define lead-based coatings or materials, but does establish safe airborne exposure limits for employees working with lead-containing materials by PEL. In summary, if any material or coating contains lead above 100 ppm, then abatement, renovation and/or demolition contractors must demonstrate worker health and safety due diligence.

This includes lead awareness training for all affected employees, establishment of proper personal protective equipment (PPE), proper demarcation of affected work area(s) and performance of negative exposure assessment (NEA) lead air monitoring prior to downgrading any established PPE.

Relating to disposal of lead-containing waste, Resource and Recovery Act (RCRA) regulatory criteria for “total” lead in a waste stream is established in 40 CFR 261, Subpart C. The regulatory criteria are listed in milligrams per liter (mg/l) of dissolved lead in a solution (“wet basis”) as determined using the Toxicity Characteristic Leaching Procedure (TCLP) by US EPA Method 1311. Where the TCLP is

ACM Project Number: IH 19-110 Page 4 December 4, 2019 designed to simulate the leaching, the waste will undergo if disposed of in a sanitary landfill. The extraction fluid employed is a function of the alkalinity of the solid phase of the waste. Under the land disposal restriction regulations (40 CRF, Part 268), a restricted waste identified in 40 CFR 268.0 cannot be land disposed if a TCLP extract of the waste exceeds the values for any hazardous constituent listed in 40 CFR 268.40.

The TCLP regulatory criteria for leachable lead are 5.0 mg/l as established in 40 CFR 261.24. A waste stream with a leachable lead concentration determined to be greater than 5.0 mg/l using the TCLP analytical method is defined as a “hazardous waste” and must be transported by a hazardous waste transporter and disposed at a hazardous waste disposal facility.

For the purpose of a renovation or demolition project, a composite sample representative of the overall anticipated waste stream for the project may be collected and analyzed for leachable lead concentration. The RCRA solid waste regulations set forth in 40 CFR

260.10 define a representative sample as “a sample of a universe or whole (e.g., waste pile, lagoon, ground water) which can be expected to exhibit the average properties of the universe or whole.” If analytical data indicate the leachable lead concentration for the representative sample is less than the regulatory criteria of 5.0 mg/l, then the entire waste stream may be disposed as nonhazardous waste with regards to lead.

Materials containing 5.0 mg/l of lead, or more, as defined by a TCLP analysis are regulated by the RCRA as hazardous waste. Material determined to be hazardous waste must be transported in accordance with Department of Transportation (DOT) regulations as stipulated in 49 CFR 171.3. Hazardous waste must be handled and disposed in accordance with 40 CFR 260 through 265.

METHODS

ACM conducted the LBP survey using the current recognized protocol as presented in Guidelines for the Evaluation and Control of LBP Hazards. ACM identified HAs of suspect LBP on interior and exterior surfaces for the site building, as described above, in general accordance with American Standards for Testing and Materials (ASTM) Method E 1729-05 and/or Chapter 7 of the HUD Guidelines for the Evaluation and Control of LBP Hazards in Housing. ACM’s inspector distinguished HAs of suspect LBP visually and through field review of analytical data obtained using an Innov-X-Systems alpha-4000 XRF analyzer. If deemed appropriate by the inspector, multiple tests were taken within a given HA. In such instances, the highest observed concentration for tests representing a respective HA were reported.

The XRF uses an ionizing electrical source and internal calculations to provide direct-read lead data. Analytical data obtained from a field-calibrated XRF are accepted as accurate by the US EPA and HUD.

It should be noted that this instrument performs its own detector calibration upon startup, and its accuracy was checked against known standards set forth by the National Institute of Standards and Technology (NIST) prior to, during (at a 4-hour intervals) and following testing. The Performance Characteristic Sheet (PCS) is included in Appendix D.

FINDINGS

ACM collected a total of seventy two (72) XRF suspect lead coatings assays and calibration readings for this inspection. Any paint films with lead concentrations of 1.0 mg/cm

, or greater, were classified as regulated lead-containing materials. In addition, the substrate condition was visually assessed at each assay test site. Lead content in mg/cm is summarized in Table 1. Results from

ACM’s LBP assessment are summarized in the following sections for the site buildings.

ACM identified the following coated surfaces with a lead loading above the HUD criterion of 1.0 mg/cm

. These are highlighted in

BOLD RED and all other surfaces are summarized below.

ACM Project Number: IH 19-110 Page 5 December 4, 2019

Table 1. Summary of lead coatings by XRF at Kamiah Annex 2, Number 1022, and Annex 1, Number 1023, on November 25 or 26, 2019.

Sample Number

Substrate Component Color Location Condition Positive or Negative

XRF

Result

(mg/cm

Tolerance (mg/cm

Quantity

(SF, LF,

EA)

1 Standardization/calibration N/A 0.00 0.00

2 Calibration N/A 0.00 0.00

3 Calibration N/A 1.13 ±0.05

4 Wood Door Varnish 1008 interior main entry Good Negative 0.09 0.00

5 Wood Door Jamb Beige 1008 interior main entry Good Positive 1.12 0.00 ~10 EA

6 Wood Door Frame Light green

1008 interior main entry Good Positive 3.75 0.00 ~10 EA

7 Gypsum Wall Light green

1008 southwest office south side Good Negative 0.01 0.00

8 Wood Door Frame Light green

1008 northwest office closet Good Positive 2.11 0.00 ~10 EA

9 Wood Window Frame Light green

1008 Megan’s office Good Positive 1.44 0.00 ~18 EA

10 Wood Cove Base Off white 1008 living room office Good Negative 0.00 0.00

11 Wood Window Sill White 1008 northeast office/northeast window

Good Negative 0.00 0.00

12 Metal Door Light gray 1008 southeast exit door Good Negative 0.00 0.00

13 Plastic Door Frame White 1008 southeast exit door Good Negative 0.00 0.00

14 Wood Step Kick Beige 1008 southeast office step kickplate Good Negative 0.00 0.00

15 Wood Cabinet Varnish 1008 kitchen Good Negative 0.01 0.00

16 Ceramic tile Floor White 1008 kitchen Good Negative 0.49 ±0.04

17 Gypsum/wood Support Beam Light green

1008 center support beam Good Negative 0.14 ±0.03

18 Metal Pole Light green

1008 center support pole Good Negative 0.08 ±0.01

19 Wood Door Varnish 1008 basement office door southwest

Good Negative 0.01 0.00

20 Concrete Wall Beige 1008 basement west closet C/C Negative 0.07 ±0.01

21 Metal Beam Red 1008 basement west closet Good Negative 0.11 ±0.02

ACM Project Number: IH 19-110 Page 6 December 4, 2019

Sample Number

Substrate Component Color Location Condition Positive or Negative

XRF

Result

(mg/cm

Tolerance (mg/cm

Quantity

(SF, LF,

EA)

22 Gypsum Ceiling Light green

1008 basement northeast office Good Negative 0.00 0.00

23 Metal Pole Red 1008 mechanical closet beam spacer Good Negative 0.08 ±0.01

24 Gypsum Wall White 1008 basement bathroom Good Negative 0.00 0.00

25 Wood Door Blue 1008 exterior main entry Good Positive 5.00 0.00 1 EA

26 Metal Screen door White 1008 exterior main entry Good Negative 0.00 0.00

27 Metal Handrail Beige 1008 exterior main entry C/C/P Positive 5.00 0.00 ~20 LF

28 Wood Siding Blue 1008 exterior siding C/C Positive 1.61 0.00 ~1,200 SF

29 Wood Soffit Blue 1008 exterior Good Positive 5.00 0.00 ~528 SF

30 Wood Facia Off white 1008 exterior south side Good Positive 5.00 0.00 ~132 LF

31 Metal Gutter Off white 1008 exterior south side Good Negative 0.03 0.00

32 Wood Siding Beige 1008 exterior garage office Good Negative 0.00 0.00

33 Wood Door Varnish 1012 main entry Good Negative 0.16 0.00

34 Wood Door Frame White 1012 main entry Good Positive 2.03 0.00 1 EA

35 Wood Window Sill Varnish 1012 foyer Good Negative 0.01 0.00

36 Wood Window Pane White 1012 foyer Good Negative 0.97 ±0.07

37 Wood Window Frame White 1012 foyer Good Positive 1.89 0.00 ~20 EA

38 Wood Cabinet Varnish 1012 kitchen Good Negative 0.01 0.00

39 Gypsum Wall White Good Negative 0.10 0.00

40 Wood Door White 1012 west office entry Good Positive 5.00 0.00 ~16 EA

41 Wood Door Frame White 1012 west office entry Good Positive 5.00 0.00 ~16 EA

42 Gypsum Wall White 1012 west office north wall Good Negative 0.00 0.00

43 Wood Window Sill Beige 1012 west office west window Good Negative 0.00 0.00

ACM Project Number: IH 19-110 Page 7 December 4, 2019

Number

Substrate Component Color Location Condition Positive or Negative

XRF

Result

(mg/cm

Tolerance (mg/cm

Quantity

(SF, LF,

EA)

44 Metal Door White 1012 west office south exit Good Negative 0.00 0.00

45 Wood Door Frame White 1012 west office south exit Good Negative 0.00 0.00

46 Wood Threshold White 1012 west office entry kitchen Good Positive 5.00 0.00 ~4 SF

47 Gypsum Wall Clay 1012 north center office Good Negative 0.05 0.00

48 Wood Window Pane White 1012 north center office Good Negative 0.00 0.00

49 Wood Cove Base White 1012 north center office Good Negative 0.10 0.00

50 Wood Floor Varnish 1012 north center office Good Negative 0.06 0.00

51 Wood Door Frame White 1012 closet door east center office Good Positive 2.79 0.00 ~16 EA

52 Wood Window Frame White 1012 east center office window Good Positive 2.09 0.00 ~20 EA

53 Wood Window Pane White 1012 northeast office east window Good Positive 1.37 0.00 ~20 EA

54 Gypsum Wall Beige 1012 southeast office Good Negative 0.12 0.00

55 Wood Cabinet White 1012 center above stairs Good Negative 0.08 0.00

56 Gypsum/wood Support Beam White 1012 stairwell Good Negative 0.00 0.00

57 Wood Handrail White 1012 stairwell Good Negative 0.00 0.00

58 Re-standardization Good N/A 0.00

59 Metal Pole White 1012 basement support Good Negative 0.07 0.00

60 Wood Window Sill White 1012 basement northeast window Good Negative 0.00 0.00

61 Wood Window Pane Beige 1012 east basement window Good Positive 5.00 0.00 ~20 EA

62 Metal Beam Red 1012 basement mechanical room Good Negative 0.09 ±0.01

63 Wood Door Jamb White 1012 basement bathroom Good Negative 0.00 0.00

64 Gypsum Ceiling White 1012 basement bathroom Good Negative 0.00 0.00

65 Concrete Floor Gray 1012 basement bathroom Good Negative 0.00 0.00

ACM Project Number: IH 19-110 Page 8 December 4, 2019

Number

Substrate Component Color Location Condition Positive or Negative

XRF

Result

(mg/cm

Tolerance (mg/cm

Quantity

(SF, LF,

EA)

66 Concrete Wall Light green

1012 basement bathroom Good Negative 0.03 0.00

67 Metal Heating, Ventilation and Air Conditioning

White 1012 basement office Good Negative 0.10 0.00

68 Wood Door Blue gray 1012 exterior main entry Good Positive 5.00 0.00 1 EA

69 Wood Door Frame Blue gray 1012 exterior main entry Good Positive 5.00 0.00 1 EA

70 Metal Screen Door White 1012 exterior main entry Good Negative 0.00 0.00

71 Metal Handrail Gray 1012 exterior main entry Good Positive 5.00 0.00 ~10 LF

72 Wood Soffit Blue 1012 exterior main entry Good Positive 5.00 0.00 ~528 SF

Legend:

LK Loose and flakey CK Cracking CP Chipping

PL Peeling mg/cm

Micrograms per square centimeter

N/A Not applicable

SF Square feet LF Linear feet EA Each

ACM Project Number: IH 19-110 Page 9 December 4, 2019

DATA VALIDATION AND DATA QUALITY ASSESSMENT

The XRF instrument was calibrated to the manufacturer’s standards prior to collecting field measurements, and was checked periodically throughout the testing period against known NIST standards. All checks performed throughout the assessment were within 10% of one another. Overall, the precision, accuracy, method compliance and completeness of the data set were determined to be acceptable based on the data submitted and reported.

SUMMARY OF FINDINGS

LEAD-BASED PAINT

LBP was confirmed on representative painted surfaces tested at the referenced site. These painted surfaces should be treated as lead hazardous waste and abated prior to removal, renovation, demolition and/or salvage that may disturb the LBP.

The Federal Dangerous Waste Regulation (40 CFR Part 261) requires that lead-containing materials with a lead content above the 5,000-ppm threshold be treated as lead hazardous waste until TCLP bulk waste stream sampling proves otherwise. The TCLP lead characterization threshold is 5 ppm. TCLP lead waste stream bulk sampling and analysis was not conducted as part of this survey inspection.

The regulatory action level for lead, as defined under RCRA is 5 mg/L. Therefore, a result above 5 mg/L requires special consideration for pre-demolition lead abatement. Furthermore, transport and disposal of demolition waste from this inspection would be required to be contained (burrito wrapped in 6-mil plastic sheeting) for lead, and all waste is required to be disposed of as lead hazardous waste at a waste disposal facility that accepts lead hazardous waste.

Lead-Based Paint Recommendations

All coatings identified as containing greater than 100 ppm lead from bulk paint analysis, or by XRF assay testing, associated with this inspection are governed by Federal regulations.

The LBP coated surfaces require special abatement considerations prior to commencing renovation and demolition activities. Several options for abatement in conjunction with renovation/demolition operations may be considered for this project. The owner’s representative should work with the owner to develop a cost-effective abatement/demolition plan, with considerations for the health and safety of the abatement workers, the demolition personnel, volunteers and residents within the immediate vicinity of the renovation/demolition project.

If renovation of the property is completed in accordance with current US EPA guidelines, the services completed throughout the project would require lead-qualified contractors and consultants to complete the work. The removal and containerization of the lead contaminated material should be completed during the lead abatement portion of the project.

LIMITATIONS

This lead inspection summary was prepared based on information gathered during our site visits, phone conversations with the client and interpretations of chemical assays collected during the inspection. The inspection was comprehensive to the referenced buildings. Supplemental inspection and sampling may be required if additional lead HAs are exposed during excavation and/or demolition, or if the scope of work is expanded to include additional buildings or buried/underground piping that have not been inspected or analyzed for lead content.

If you have any questions regarding this report, please call me at (406) 549-8489. We look forward to working with you in the future.

Sincerely, James Parker Project Manager, QA/QC

Sincerely, Mike Foust Vice President/Lead Risk Assessor

LBP-R-28404-1

ACM Project Number: IH 19-110 Page 10 December 4, 2019

Supervisor’s Offices

Inspection Number: IH 19-110 December 24, 2019

Supervisor’s Office, Annex 2, 1008, Kamiah, Idaho

Door Jamb (Beige) – Positive for LBP

Door Frame (Light Green) – Positive for LBP

Door Frame (Light Green) – Positive for LBP

Window Frame (Light Green) – Positive for LBP

Exterior Door (Blue) – Positive for LBP

Handrail (Beige) – Positive for LBP

Exterior Siding (Blue), Soffit (Blue) & Fascia Board (Off-White) – Positive for LBP

Supervisor Office, Annex 1, 1012

Door Frame (White) – Positive for LBP

Window Frame (White) – Positive for LBP

Door (White) & Door Frame (White) – Positive for LBP

Wood Threshold (White) – Positive for LBP

Closet Door Frame (White) – Positive for LBP

Window Frame (White) & Window Pane (White) – Positive for LBP

Window Pane (Beige) – Positive for LBP

Exterior Door & Door Frame (Bluish-Gray) – Positive for LBP

Exterior Handrail (Gray) – Positive for LBP

Exterior Soffit & Fascia Board (Blue) – Positive for LBP

Door Frame (Bluish-Gray) – Positive for LBP