Boiler Plant Lead Screening 2.11.2019.pdf

ENVIRONMENTAL CONSULTANTS

1331 Ashton Road P.O. Box 646 Hanover, MD 21076 410-684-3327 FAX: 410-684-3384 www.amaconsulting.com

February 11, 2019

Mr. Matt Hargrove, P.E.

General Engineer – Perry Point VA Maryland Health Care System Boiler Plant Road, Bldg 101, Room 6 Perry Point, MD 21902

RE: Lead-based paint (LBP) screening performed within Building 315 Boiler Plant of the

Perry Point VA located at the in Perry Point, Maryland; AMA Job #:19174

Dear Mr. Hargrove, This letter and accompanying field forms are to serve as the final report regarding a LBP screening performed within Building 315 Boiler Plant located in Perry Point, Maryland. Ms.

Jessica Woltemate, who is Environmental Protection Agency (EPA) trained LBP inspector and is accredited in the State of Maryland, represented Aerosol Monitoring and Analysis, Inc. (AMA) by performing the screening on February 9, 2018 at the above referenced location.

The inspection was performed with a Niton XLp 300A X-Ray Fluorescence (XRF) lead-based paint analyzer, Serial #99428. This XRF contains a small Cadmium 109 radioactive source that releases radiation when the instrument is pressed flatly against a surface and the operator engages the trigger. If the paint contains lead, the radiation will stimulate the lead atoms to re-emit x-rays that are sensed by a detector in the unit. The XRF then converts these signals to a final reading in milligrams of lead per square centimeter of surface area (mg/cm2). The Niton XRF is capable of achieving a ninety-five percent (95%) confidence level in the readings.

Calibration of the Niton XLp was conducted in accordance with the manufacturer’s instructions.

Prior to obtaining readings from suspect surfaces, twelve (12) calibration readings taken in K+ L Mode were performed on a calibration sheet and recorded. The calibration films used contains approximately 1.0 mg/cm2 and 0.0 mg/cm2 respectively. Calibration checks were performed prior to and at the end of the inspection.

The XLp features two modes of operation when in use: K+L Mode and Standard Mode. K+L Mode is a quantitative analysis which allows you to determine the statistical confidence of the reading to a 95% confidence level while allowing you to test longer. As stated in the XRF Performance Characteristics Sheet (PCS), Edition No. 1, developed under a contract with the U.S. Department of Housing and Urban Development (HUD), no substrate correction is needed when the XRF is in the K+L Mode. The K+L Mode was used during the course of the inspection.

A total of seventy-nine (79) XRF readings, including calibrations, were collected from suspect LBP finished components located throughout the building. Twelve (12) of the surfaces tested were found to contain greater than (>) 0.7 mg/cm2 of surface area tested, which is the amount defined as a lead-containing substance according to the COMAR, Title 26, Department of the Environment, Subtitle 16, Lead, Chapter 01. See Table I at the end of the report for a list of all samples that were found to have lead concentrations of >0.7 mg/cm2. At the time of the screening, AMA identified the following LBP components:

Component Yellow Metal Pipe Gray Metal Siding Orange Metal Hand Wheel Valve Blue Metal Hand Wheel Valve Silver Metal Hand Wheel Valve Gray Metal Structural Steel Orange Metal Ladder Orange Metal Door Gray Metal Heat Exchange Support White Metal Fuel Tank

There is no requirement to remove LBP prior to demolition activities for this type of building in the State of Maryland, only that components finished with LBP be tested, to determine the disposal requirements, following the requirements of the Resource Conservation and Recovery Act (RCRA) and any other applicable federal, state and local laws and regulations. In addition, contractors need to be made aware of the existence of LBP so their workers and the environment can be adequately protected. Prohibited methods of lead paint removal include: sanding (except with equipment fitted with HEPA filters), burning with an open flame torch, or any methods, which produce uncontrolled dust or fumes. All lead-containing waste is to be handled and disposed of as hazardous waste unless toxic characteristic leaching procedure (TCLP) testing is performed and indicates otherwise. The waste shall be considered as hazardous when the concentration of lead exceeds 5 parts per million (ppm) by the TCLP. Metal components should be recycled, and glazed finishes are to be disposed of as general construction debris.

The Occupational Safety and Health Administration (OSHA) Lead in Construction Standard (29 CFR 1926.62, with Maryland Amendments) must be adhered to during demolition to the LBP finished surfaces. This standard established the permissible exposure level (PEL) for lead at 50 micrograms per cubic meter (ug/m3) as an eight-hour time weighted average (TWA); the action level has been established at 30 ug/m3 as an eight hour TWA. This regulation also requires employers to use engineering controls and special work practices to reduce worker lead exposure to, at, or below the PEL. It also triggers several requirements regarding exposure monitoring, biological monitoring, and employee training when a worker is exposed to airborne lead levels at or above the action level.

Some painted surfaces may contain levels of lead at or below 0.7 mg/cm2, which are able to create lead dust or lead-contaminated soil hazards if the paint is turned into dust by abrasion, scraping, or sanding. Whenever renovation or demolition is performed on any painted components, an attempt should be made to control dust. If any surfaces with measurable amounts of lead are to be disturbed, it must be done so in accordance with the OSHA, and by trained personnel using appropriate techniques and respiratory protection. The OSHA does not honor threshold levels of lead in paint.

Enclosed, please find a copy of the XRF readings for your use. Please feel free to contact us at 410-684-3327 with any questions.

Respectfully submitted, Andrew Washington, CIH Project Manager

Enclosures

TABLE I POSITIVE XRF TABLE

TABLE I

POSITIVE XRF READING TABLE

BUILDING 315 BOILER PLANT

PERRY POINT VA

FEBRUARY 09, 2019

Sample # Location Color Component Substrate Condition Result

Boiler Plant Main Floor, North Wall Yellow Pipe Metal Intact 2.9

Boiler Plant Main Floor, North Wall Gray Siding Metal Intact 1.0

Boiler Plant Main Floor, West Side Yellow Pipe Metal Intact 2.4

Boiler Plant Main Floor, North Wall Orange

Hand Wheel Valve

Metal Intact 1.9

Boiler Plant Main Floor, North Wall Blue

Hand Wheel Valve

Metal Intact 1.4

Boiler Plant Main Floor, North Wall Silver

Hand Wheel Valve

Metal Intact 2.5

Boiler Plant Main Floor, East of Boiler #4 Gray Structural Steel Metal Intact 2.9

Boiler Plant Main Floor, North Wall Orange

Hand Wheel Valve

Metal Intact 1.3

Upper Level (2nd Floor), North of Boiler Orange Ladder Metal Intact 3.9

Boiler Plant Main Floor, South Wall Orange Door Metal Intact 2.2

Boiler Plant Main Floor, Northwest Room Gray

Heat Exchange Support

Metal Intact 2.4

086 West Exterior White Fuel Tank Metal Intact 2.4

XRF FIELD DATA SHEETS