140P2022R0036-0002_Att03b-XRF_LBP_InspectionReport_200722_0002.pdf

XRF LEAD-BASED PAINT INSPECTION REPORT

Project Location:

Main Immigration Building Ellis Island

New York, NY 10004

Prepared for:

National Park Service, Statue of Liberty NM & Ellis Island

Ellis Receiving Office Jersey City, NJ 07305

Prepared by:

AIM Environmental LLC

725 River Road, Suite 32-81 Edgewater, NJ 07020

Report Date:

July, 22 2020

Main Immigration Building – Ellis Island, New York, NY 10004

AIM Project # 20-07-210

XRF Lead-Based Paint Inspection Page 1 of 2

SUMMARY OF WORK

AIM Environmental LLC (AIM) was retained by National Park Service to perform a limited inspection for Lead-Based Paint (LBP) at Main Immigration Building, Ellis Island, New York, NY 10004.

On July 14, 2020 AIM’s United States Environmental Protection Agency (USEPA) certified Lead-Based Paint Risk Assessor conducted a limited inspection for LBP throughout the exterior and interior spaces of the above-referenced facility.

The inspection was conducted to identify the presence of any LBP located on the painted/coated building components throughout 3rd floor areas that may be impacted by planned renovation activities. AIM’s certified Risk Assessor utilized a Thermo Scientific Niton XL2 GOLDD X-Ray Fluorescence Analyzer (XRF) to determine the presence or absence of lead in paint.

Any coated/painted components not addressed within Appendix A should be assumed to be coated with LBP.

XRF Spectrometry is used to identify elements within a substance and quantify the number of elements within the substance. The elements are identified by their unique X-ray emission wavelengths. The amount of the element is quantified by measuring the intensity of the emission characteristics. The X-ray occurs when photons are emitted from a source (XRF) and strike the substance/surface being tested. The photons emitted from the source then knock out the inner most electrons which emits an energy known as a secondary X-ray photon. The secondary X-ray is then analyzed within the XRF which calculates the element within the substance/surface and the amount of the element.

Following a standard operation procedure, the XRF was calibrated at the beginning of the inspection, every 4 hours from the start (not applicable), and at the end of the inspection utilizing the Standard Reference Material provided by the National Institute of Standards and Technology (NIST).

The following building components were observed to contain LBP:

Sample Location

Building Component

Substrate

Paint Color

Final Results

3rd Floor - Interior Window Metal Closer

Mechanism Metal Beige Lead-Based Paint

Please refer to Appendix A for a full listing of inspection results.

Lead-based paint is usually not considered a hazard if it is in good and intact condition. The LBP identified during the above-referenced inspection was observed in poor condition. Lead hazards arise from lead-based paint that is peeling, flaking, or in otherwise deteriorated condition.

Should the above-referenced LBP existing in conditions such as peeling, flaking, or otherwise deteriorating, be disturbed through renovation or repair, then the painted components should be abated by one of the following methods:

• Removal of paint

• Replacement of affected components

• Encapsulation of LBP surfaces

The abatement method selected will depend on the quantities and types of materials. The removal, replacement, or encapsulation of materials containing lead-based paint should be performed by a licensed contractor.

XRF Lead-Based Paint Inspection Page 2 of 2

Any construction activity that may disturb a surface where lead is present (at any concentration) must be completed in accordance with Occupational Safety and Health Administration’s (OSHA), Lead in Construction Standard (29 CFR 1926.62). All such activities will require respiratory protection for workers, exposure monitoring, employee training, and medical monitoring (including blood tests).

Air monitoring should be conducted to ensure that the lead-in-air level is below the Permissible Exposure Limit (PEL) of 50 micrograms per cubic meter (µg/m³).

LIMITATIONS AND CONDITIONS

The tasks detailed above were performed by AIM in a comprehensive and professional manner consistent with industry standards and practices. AIM cannot guarantee and does not warrant that this limited assessment has uncovered all adverse environmental conditions that may be present at the subject site. Nor can AIM warrant that the assessment requested will satisfy the dictates of, or provide a legal defense in connection with legal action brought forth. The observations and findings were representative of the conditions within the spaces inspected on July 14, 2020. AIM cannot guarantee that the conditions observed during our limited assessment will remain consistent.

The information contained in this report was prepared based upon specific parameters and regulations in force at the time of this report. The information herein is only for the specific use of the client and AIM. AIM accepts no responsibility for the use, interpretation, or reliance by other parties on the information contained herein, unless written authorization has been obtained from AIM.

Thank you for your attention and consideration in this matter. Please feel free to contact the undersigned should you have any questions or require any additional information.

Respectfully, 07/22/2020 Igor Martirosian Date EPA Inspector Certification #: LBP-R-I199128-1 Exp: 3/26/2022

Appendices:

Appendix A – XRF Results Table Appendix B – AIM Licenses and Certifications

XRF Lead-Based Paint Inspection

APPENDIX A

XRF Results Table

Main Immigration Building, Ellis Island, New York, NY 10004

XRF

Shot

Number Date Sample Location

Building

Component

Wall/ Elevation

Paint Condition

XRF

Reading

(Mg/Sq.Cm) Final Results

1 14-Jul-20 Standardization N/A N/A N/A N/A N/A N/A PASS

2 14-Jul-20 Standardization N/A N/A N/A N/A N/A N/A PASS

3 14-Jul-20 Calibration N/A N/A N/A N/A N/A 0 Non Lead-Based

Paint

4 14-Jul-20 Calibration N/A N/A N/A N/A N/A 0 Non Lead-Based

Paint

5 14-Jul-20 Calibration N/A N/A N/A N/A N/A 0 Non Lead-Based

Paint

6 14-Jul-20 Calibration N/A N/A N/A N/A N/A 1.17 Lead-Based Paint

7 14-Jul-20 Calibration N/A N/A N/A N/A N/A 1.17 Lead-Based Paint

8 14-Jul-20 Calibration N/A N/A N/A N/A N/A 1.15 Lead-Based Paint

9 14-Jul-20 3rd Floor – Interior Window Trim/Sill North Wood Beige Fair 0 Non Lead-Based

Paint

10 14-Jul-20 3rd Floor – Interior Window Trim/Sill North Wood Beige Fair 0 Non Lead-Based

Paint

11 14-Jul-20 3rd Floor – Interior Window Frame North Wood Beige Fair 0.02 Non Lead-Based

Paint

12 14-Jul-20 3rd Floor – Interior Window Sash North Wood Beige Peeling 0.01 Non Lead-Based

Paint

13 14-Jul-20 3rd Floor – Interior Window Sash North Wood Beige Peeling 0.02 Non Lead-Based

Paint

14 14-Jul-20 3rd Floor – Interior Window Metal

Closer Mechanism North Metal Beige Fair 6.72 Lead-Based Paint

15 14-Jul-20 3rd Floor – Interior Window Metal

Closer Mechanism North Metal Beige Fair 3.9 Lead-Based Paint

16 14-Jul-20 3rd Floor – Interior Window Metal

Closer Mechanism North Metal Beige Fair 7.16 Lead-Based Paint

Paint Condition

XRF

Reading

(Mg/Sq.Cm) Final Results

17 14-Jul-20 3rd Floor – Interior Window Sash North Wood Beige Peeling 0 Non Lead-Based

Paint

18 14-Jul-20 3rd Floor – Interior Window Frame North Wood Beige Fair 0 Non Lead-Based

Paint

19 14-Jul-20 3rd Floor – Interior Window Sash North Wood Beige Peeling 0 Non Lead-Based

Paint

20 14-Jul-20 3rd Floor – Interior Window Sash North Wood Beige Peeling 0 Non Lead-Based

Paint

21 14-Jul-20 3rd Floor – Interior Window Sash North Wood Beige Peeling 0 Non Lead-Based

Paint

22 14-Jul-20 3rd Floor – Interior Window Sash North Wood Beige Peeling 0 Non Lead-Based

Paint

23 14-Jul-20 3rd Floor – Interior Window Sash East Wood Beige Peeling 0 Non Lead-Based

Paint

24 14-Jul-20 3rd Floor – Interior Window Sash East Wood Beige Peeling 0 Non Lead-Based

Paint

25 14-Jul-20 3rd Floor – Interior Window Frame East Wood Beige Peeling 0 Non Lead-Based

Paint

26 14-Jul-20 3rd Floor – Interior Window Frame East Wood Beige Peeling 0 Non Lead-Based

Paint

27 14-Jul-20 3rd Floor – Interior Window Metal

Closer Mechanism East Metal Beige Fair 0.03

Non Lead-Based Paint

28 14-Jul-20 3rd Floor – Interior Window Metal

Closer Mechanism East Metal Beige Fair 0

Non Lead-Based Paint

29 14-Jul-20 3rd Floor – Interior Window Metal

Closer Mechanism East Metal Beige Fair 0.02

Non Lead-Based Paint

30 14-Jul-20 3rd Floor – Interior Window Metal

Closer Mechanism East Metal Beige Fair 0

Non Lead-Based Paint

31 14-Jul-20 3rd Floor – Interior Window Metal

Closer Mechanism East Metal Beige Fair 0.03

Non Lead-Based

Paint Condition

XRF

Reading

(Mg/Sq.Cm) Final Results

32 14-Jul-20 3rd Floor – Interior Window Frame East Wood Beige Fair 0 Non Lead-Based

Paint

33 14-Jul-20 3rd Floor – Interior Exterior Window

Frame South Wood Green Peeling 0

Non Lead-Based Paint

34 14-Jul-20 3rd Floor – Exterior Exterior Window

Frame South Wood Green Peeling 0

Non Lead-Based Paint

35 14-Jul-20 3rd Floor – Exterior Exterior Window

Frame South Wood Green Peeling 0.62

Non Lead-Based Paint

36 14-Jul-20 3rd Floor – Exterior Exterior Window

Frame South Wood Green Peeling 0.65

Non Lead-Based Paint

37 14-Jul-20 3rd Floor – Exterior Exterior Window

Frame South Wood Green Peeling 0.02

Non Lead-Based Paint

38 14-Jul-20 3rd Floor – Exterior Exterior Window

Sash South Wood Green Peeling 0.3

Non Lead-Based Paint

39 14-Jul-20 3rd Floor – Exterior Exterior Window

Sash South Wood Green Peeling 0

Non Lead-Based Paint

40 14-Jul-20 3rd Floor – Exterior Exterior Window

Sash West Wood Green Peeling 0

Non Lead-Based Paint

41 14-Jul-20 3rd Floor – Exterior Exterior Window

Sash West Wood Green Peeling 0

Non Lead-Based Paint

42 14-Jul-20 3rd Floor – Exterior Exterior Window

Sash West Wood Green Peeling 0

Non Lead-Based Paint

43 14-Jul-20 3rd Floor – Exterior Exterior Window

Frame West Wood Green Peeling 0

Non Lead-Based Paint

44 14-Jul-20 3rd Floor – Exterior Exterior Window

Frame West Wood Green Peeling 0

Non Lead-Based Paint

45 14-Jul-20 Calibration N/A N/A N/A N/A N/A 1.17 Lead-Based Paint

46 14-Jul-20 Calibration N/A N/A N/A N/A N/A 1.13 Lead-Based Paint

Paint Condition

XRF

Reading

(Mg/Sq.Cm) Final Results

47 14-Jul-20 Calibration N/A N/A N/A N/A N/A 1.17 Lead-Based Paint

48 14-Jul-20 Calibration N/A N/A N/A N/A N/A 0 Non Lead-Based

Paint

49 14-Jul-20 Calibration N/A N/A N/A N/A N/A 0 Non Lead-Based

Paint

50 14-Jul-20 Calibration N/A N/A N/A N/A N/A 0 Non Lead-Based

Notes:

Non Lead Based Paint – denotes paint with lead concentration below 1.0 mg/cm2 by XRF.

Bold Type – denotes paint at or above the action level of 1.0 mg/cm2 by XRF.

All untested/inaccessible painted surfaces should be assumed to contain Lead-Based Paint.

APPENDIX B

AIM Licenses and Certifications

AIM Environmental LLC has fulfilled the requirements of the Toxic Substances Control Act (TSCA) Section 402, and has received certification to conduct lead-based paint activities pursuant to 40 CFR Part 745.226

All EPA Administered Lead-based Paint Activities Program States, Tribes and Territories

This certification is valid from the date of issuance and expires January 04, 2022

Certification #

LBP-F159896-1

Issued On

June 13, 2018

Michelle Price, Chief

Lead, Heavy Metals, and Inorganics Branch