Buxton_DKQ_Lead_Paint_Report_0002.pdf

Terracon Consultants, Inc. 2401 Brentwood Road Suite 107 Rale igh, Nor th Carol ina 27604

P (919) 873-2211 F (919) 873-9555 terracon.com

September 9, 2021

U.S. National Park Service

1401 National Park Drive

Manteo, NC 27954

Attn: Mr. Tim Akers – Safety Manager

M: (252) 475-8327

E: timothy.akers@nps.gov

Re: Limited Lead Paint Sampling Report

Buxton Double Keepers Quarters

Lighthouse Road

Buxton, North Carolina 27920

Terracon Project No. 70217524

Dear Mr. Akers:

The purpose of this report is to present the limited lead paint survey performed on August 12, 2021, at the Double Keepers Quarters (DKQ) located on Lighthouse Road in Buxton, North Carolina.

This survey was conducted in general accordance with Terracon Proposal No. P70217524, dated

August 5, 2021. We understand that these services were requested due to the planned repair and repainting of the exterior of the structure.

Lead was detected above laboratory reporting limits in samples collected. Please refer to the attached report for details.

Terracon appreciates the opportunity to provide these services to U.S. National Park Service. If you have any questions regarding this report, please contact the undersigned at (919) 873-2211.

Sincerely, Terracon Consultants Inc.

Alicia Coley, CIH For: Jeffrey Gurrie, CIH

Project Industrial Hygienist Authorized Project Reviewer mailto:timothy.akers@nps.gov

LIMITED LEAD PAINT SURVEY REPORT

Buxton Double Keepers Quarters

Lighthouse Road

Buxton, North Carolina 27920

September 9, 2021

Prepared For:

U.S. National Park Service

Manteo, North Carolina

Prepared By:

Terracon Consultants, Inc.

Raleigh, North Carolina

TABLE OF CONTENTS

Page No.

1.0 INTRODUCTION

2.0 BUILDING DESCRIPTION

3.0 FIELD ACTIVITIES

4.0 REGULATORY OVERVIEW

5.0 FINDINGS AND RECOMMENDATIONS

6.0 GENERAL COMMENTS

Appendix A Lead Paint Survey Sample Summary

Appendix B Lead Paint Laboratory Analytical Report

Appendix C Photolog

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LIMITED LEAD PAINT SURVEY REPORT

BUXTON DOUBLE KEEPERS QUARTERS

LIGHTHOUSE ROAD

BUXTON, NORTH CAROLINA 27920

August 31, 2021

1.0 INTRODUCTION

Terracon Consultants, Inc. (Terracon) conducted a limited lead paint sampling survey of the Double

Keepers Quarters (DKQ) located on Lighthouse Road in Buxton, North Carolina. The survey was performed on August 12, 2021, and in general accordance with Terracon Proposal No. P70217524, dated August 5, 2021. We understand that the limited lead paint survey was requested due to the planned repair and repainting of the exterior of the structure.

Building components at the exterior of the building were visually assessed and suspect lead paint coatings were identified and documented. The survey was limited to safely accessible areas of the exterior of the building that are included in the proposed renovation scope. Paint chip samples were collected and delivered to an accredited laboratory to perform Flame Atomic Absorption

Spectrophotometry (Flame AAS) analysis.

The Occupational Health and Safety Administration (OSHA) has promulgated a worker protection standard for the disturbance of lead-containing paints during demolition projects. The limited lead paint sampling was performed to meet informational needs to comply with the OSHA Lead in

Construction Standard (29 CRF 1926.62). Currently, proposed renovation or demolition activities which may impact lead paint is subject to OSHA regulation 29 CFR 1926.62 – Lead Exposure in

Construction for worker protection. If paint is removed from the substrate, it may be subject to disposal requirements.

2.0 BUILDING DESCRIPTION

Based on information provided by the Client, the DKQ building is a 5,350 square foot two-story building atop a crawlspace. The building houses a museum for the Cape Hatteras Lighthouse complex and primarily contains display space, restrooms, and several storage areas. The building has a wood siding façade and a pitched shingled roof. The scope of services was limited to sampling white exterior painted surfaces scheduled for repainting.

3.0 FIELD ACTIVITIES

The lead paint sampling was conducted by Alicia Coley of Terracon. A paint chip sample was collected from homogenous painted surfaces identified to determine its lead content, measured by percent by weight. The paint samples were collected down to the surface substrate so as to include any underlying paint systems in the analysis. The random paint chip samples were

Limited Lead Paint Survey Report

DKQ Building ■ Buxton, North Carolina

September 9, 2021 ■ Terracon Project No. 70217524

Responsive ■ Resourceful ■ Reliable 2 selected based on current paint schemes and may not be inclusive of old paint systems covered with paneling or existing painted systems. Currently, proposed renovation and demolition activities that could potentially disturb lead paint are subject to the OSHA regulations (29 CFR 1926.62 –

Lead).

The lead paint sampling began with the Terracon representative walking the exterior of the structure, observing painted surfaces, and selecting sample locations. After the sampling strategy was determined, Terracon collected 15 paint chip samples from homogeneous surfaces.

Paint chip samples were submitted under a chain of custody to EMSL Analytical, Inc. (EMSL) of

Kernersville, North Carolina. Paint chip samples were analyzed by Flame Atomic Absorption

Spectrophotometry method SW846-3050B/7000B. EMSL is an American Industrial Hygiene

Association (AIHA) Environmental Lead Laboratory Accreditation (ELLAP) accredited laboratory

(ELLAP, Lab Code 102564), to perform Flame Atomic Absorption Spectrophotometry analysis. A summary of the paint chip samples collected during the survey is presented in Appendix A. The lead paint laboratory analytical report is provided in Appendix B.

4.0 REGULATORY OVERVIEW

The lead paint sampling activities were conducted to meet informational needs to comply with the

OSHA Lead in Construction Standard. Lead is also regulated by the Environmental Protection

Agency (EPA) for disposal.

The Resource Conservation and Recovery Act (RCRA) gave the USEPA authority to regulate the waste status of demolition or renovation debris, including lead-containing materials. Specific notification and testing requirements must be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead containing wastes are considered hazardous waste under

RCRA if Toxicity Characteristic Leaching Procedure (TCLP) results exceed 5 milligrams per liter

(mg/L). EPA exempts from most RCRA requirements those generators whose combined hazardous waste generation is less than 100 kilograms (kg) per month.

Detectable lead quantities may constitute a lead dust hazard during renovation/demolition activities.

Personnel performing renovation/demolition activities that may disturb painted components with concentrations of lead above the designated analytical detection limit should comply with all current

OSHA regulations in order to minimize employee exposure. OSHA defines lead-based paint as a paint, which contains lead, regardless of the concentration. Currently, any proposed renovation/demolition is subject to the OSHA regulations (29 CFR 1926.62 – Lead). The OSHA regulation defines specific training requirements, engineering controls and working practices for construction personnel subject to this standard. Occupational exposure to lead occurring in the course of construction work, including maintenance activities, painting, alteration and repairs is subject to the OSHA Lead Exposure in Construction standard.

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Construction work covered by 29 CFR 1926.62 includes any repair or renovation activities or other activities that disturb in-place lead-containing materials, but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than 50 micrograms per cubic meter (g/m3) averaged over an eight-hour period without adequate protection. The OSHA Standard also establishes an action level of 30 g/m3 which if exceeded triggers the requirement for medical monitoring.

The above overview is not intended to be inclusive of all potentially pertinent regulatory information.

The relevant EPA and OSHA standards should be consulted prior to undertaking activities involving the demolition, renovation, or maintenance of surfaces coated with lead-based paints.

5.0 FINDINGS AND RECOMMENDATIONS

Lead was detected above laboratory reporting limits in 13 of the 15 paints sampled. The following painted surfaces contained lead:

▪ White on Wood Railing

▪ White on Metal Downspout

▪ White on Wood Column

▪ White on Wood Siding

▪ White on Brick Cistern

▪ White on Exterior Wood Window Frame

▪ White on Wood Porch Sill Plate

▪ White on Exterior Wood Window Trim

▪ White on Wood Ceiling

▪ White on Wood Beadboard Ceiling

▪ White on Wood Porch Beam

A summary of the paint chip samples collected during the survey is presented in Appendix A. The lead paint laboratory analytical report is provided in Appendix B. Photographs of typical painted surfaces sampled are provided in Appendix C. Please note that paints not sampled should be considered lead-containing.

Contractors should be made aware of the presence of the identified lead coatings, so that they may maintain compliance with worker protection regulations, employ lead-safe work practices, and/or conduct a negative exposure assessment per OSHA (29 CFR 1926.62 – Lead Exposure in

Construction). Removed paint waste may be subject to additional regulations and TCLP testing for disposal.

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6.0 GENERAL COMMENTS

This limited lead paint survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our survey of the building.

This report has been prepared on behalf of and exclusively for use by U.S. National Park Service for specific application to their project as discussed. This report is not a bidding document.

Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories or other third parties supplying information, which may have been used in the preparation of this report. No warranty, expressed or implied is made.

APPENDIX A

LEAD PAINT SURVEY SAMPLE SUMMARY

Sample # Description Sample Location

Lead

Concentration (%

Weight)

DKQ-1 White on Wood Railing Northeast 0.089%

DKQ-2 White on Metal Downspout Northeast 0.17%

DKQ-3 White on Wood Column Front/North 1.4%

DKQ-4 White on Wood Siding East 0.014%

DKQ-5 White on Brick Cistern East 15%

DKQ-6 White on Exterior Wood Window Frame East/Southeast (Addition) 0.052%

DKQ-7 White on Wood Siding West Side of East Addition 0.0082%

DKQ-8 White on Wood Porch Sill Plate Back Porch 0.027%

DKQ-9 White on Exterior Wood Window Trim South 0.0084%

DKQ-10 White on Wood Siding North/Northwest 0.0098%

DKQ-11 White on Exterior Wood Window North/Northeast <0.026%

DKQ-12 White on Wood Ceiling Front Porch 0.48%

DKQ-13 White on Wood Siding South at Addition Roof Line <0.023%

DKQ-14 White on Wood Beadboard Ceiling Back Room by Restrooms 1.1%

DKQ-15 White on Wood Porch Beam Back Roof Beam 0.015%

Appendix A

LEAD PAINT SURVEY SAMPLE SUMMARY

Buxton Double Keepers Quarters

Buxton, North Carolina 27920

Lighthouse Road

*Bolded samples indicate samples with OSHA-regulated paints with lead concentrations above the laboratory detection limit.

A-1

APPENDIX B

LEAD PAINT LABORATORY ANALYICAL REPORT

Client Sample Description ConcentrationLab ID Analyzed Weight Lead

Collected

EMSL Analytical, Inc.

706 Gralin Street, Kernersville, NC 27284 Phone/Fax: (336) 992-1025 / (336) 992-4175 http://www.EMSL.com greensborolab@emsl.com

Attn: Alicia Coley Terracon Consultants, Inc.

2401 Brentwood Road Suite 107 Raleigh, NC 27604

Received: 8/16/2021 09:00 AM

70217524 Buxton DKQ

Fax: (919) 873-9555 Phone: (919) 873-2211

Project:

Collected:

Test Report: Lead in Paint Chips by Flame AAS (SW 846 3050B/7000B)*

022106061 CustomerID: TITA51 CustomerPO: 70217524 ProjectID:

EMSL Order:

.2623022106061-0001DKQ-1 0.089 % wt8/17/2021 g

.0559022106061-0002DKQ-2 0.17 % wt8/17/2021 g

.2699022106061-0003DKQ-3 1.4 % wt8/17/2021 g

.2732022106061-0004DKQ-4 0.014 % wt8/17/2021 g

.2963022106061-0005DKQ-5 15 % wt8/17/2021 g

.2595022106061-0006DKQ-6 0.052 % wt8/17/2021 g

.2629022106061-0007DKQ-7 0.0082 % wt8/17/2021 g

.2376022106061-0008DKQ-8 0.027 % wt8/17/2021 g

.2917022106061-0009DKQ-9 0.0084 % wt8/17/2021 g

.2726022106061-0010DKQ-10 0.0098 % wt8/17/2021 g

.0771022106061-0011DKQ-11 <0.026 % wt8/17/2021 g

.1416022106061-0012DKQ-12 0.48 % wt8/17/2021 g

.0864022106061-0013DKQ-13 <0.023 % wt8/17/2021 g

.2669022106061-0014DKQ-14 1.1 % wt8/17/2021 g

.1488022106061-0015DKQ-15 0.015 % wt8/17/2021 g

James Cole, Laboratory Manager or other approved signatory

Test Report ChmSnglePrm/nQC-7.32.3 Printed: 8/18/2021 8:06:55 AM

EMSL maintains liability limited to cost of analysis. Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. The report reflects the samples as received.

Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted.

Analysis following Lead in Paint by EMSL SOP/Determination of Environmental Lead by FLAA. Reporting limit is 0.008% wt based on the minimum sample weight per our SOP. "<" (less than) result signifies the analyte was not detected at or above the reporting limit. Measurement of uncertainty is available upon request. Definitions of modifications are available upon request.

Samples analyzed by EMSL Analytical, Inc. Kernersville, NC EMSL Lab ID 102564 is accredited by the AIHA Laboratory Accreditation Program (AIHA-LAP), LLC in the Environmental Lead accreditation program for Lead in Paint Chips.

Initial report from 08/18/2021 08:06:55 http://www.EMSL.com mailto:greensborolab@emsl.com

OrderID: 022106061

OrderID: 022106061

APPENDIX C

PHOTOGRAPHS

Photos Taken August 12, 2021 ■ Terracon Project No. 70217524

Photo #1 View of building exterior. Photo #2 View of wood railing.

Photo #3 View of metal downspout. Photo #4 View of wood column.

Photo #5 View of wood siding. Photo #6 View of brick cistern.

Photos Taken August 12, 2021 ■ Terracon Project No. 70217524

Photo #7 View of exterior wood window frame.

Photo #8 View of wood porch sill plate.

Photo #9 View of wood ceiling. Photo #10 View of wood porch beam.