Lead-Based Paint Survey.pdf

Lead-Based Paint Survey Report

Proposed VA Hospital Garland – Three Buildings 2300 Marie Curie Boulevard

Garland, Texas

June 21, 2019 Terracon Project No. 94197779

Prepared for:

Enapay, LLC

Mesquite, Texas

Prepared by:

Terracon Consultants, Inc.

Dallas, TexasDRAFT e Buie Bu urie Boulevurie Bo Garland, TexasGarla

June 21, 2019June 21 Terracon Project No. 94197779Terracon Project No. 941977

Terracon Consultants, Inc. 8901 Carpenter Freeway, Suite 100 Dallas, Texas 75247 P [214] 630 1010 F [214] 630 7070 terracon.com/dallas

June 21, 2019

Mr. Marshall Hamilton Enapay, LLC 207 West Main Street Mesquite, Texas 75149

Telephone: 214-607-0247 E-mail: mjh@enapayllc.com

Re: Lead-Based Pant Survey Proposed VA Hospital Garland – Three (3) Buildings 2300 Marie Curie Boulevard Garland, Texas Terracon Project No. 94197779

Mr. Hamilton:

The purpose of this report is to present the results of the lead-containing paint survey performed June 10-17, 2019 at the site of the proposed Veterans Administration (VA) Hospital Garland located at 2300 Marie Curie Boulevard, 700 Walter Reed Boulevard, and 900 North Shiloh Road in Garland, Texas. This survey was conducted in general accordance with Terracon Proposal No. P94197779 dated June 6, 2019. We understand this survey was requested due to the VA’s planned acquisition of the property.

Terracon appreciates the opportunity to provide this service to Enapay, LLC. If you have any questions regarding this report, or if you need assistance with project oversight and sampling during renovation or demolition of the on-site structures, please contact the undersigned at (214) 630- 1010.

Sincerely, Terracon Consultants, Inc.

Chad Champagne Assistant Project Manager - Environmental TDSHS Lead Risk Assessor License No. 2071012

Greg Calhoun Senior Associate Department Manager - Asbestos, Lead & IH ServicesDRAFTgsgs t the results of the leadt the results -containing paint surontaining oposed sed Veterans Administration (Veterans Administration (VAVA)) HospitaHo

0 Walter Reed Boulevard, and 900 North Shr Reed Boulevard, and 900 North Sh cted in general accordance ral accordance with Terracon Pwith Terracon derstand this survey was requested due to thvey was requested due to th tes the opportunitytes the opportunity to provide this service e this ding this report, or if you need assistance withding this report, or if you need assistanc r demolition r demo of the one on--site structures, pleassite structures, plea cerely,erely, Terracon Consultants, Inc.Terracon Consultants, Inc.

Chad Champagne Assistant Project Manager Assistant Project Manage - Env TDSHS Lead Risk Assessor TDSHS Lead Risk Asses

CalhounCalhoun ssociatessociate

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TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Project Objective

2.0 BUILDING DESCRIPTION

3.0 FIELD ACTIVITIES

3.1 Methodology

3.2 XRF Instrumentation

3.3 XRF Results

4.0 REGULATORY OVERVIEW

5.0 FINDINGS AND CONCLUSIONS

6.0 GENERAL COMMENTS

APPENDIX A: LEAD-BASED PAINT INSPECTION RESULTS

APPENDIX B: XRF PERFORMANCE CHARACTERISTIC SHEET

APPENDIX C: PHOTOGRAPHS

APPENDIX D: DIAGRAMS

APPENDIX E: LICENSES

DRAFT

AINT T INSPECTION RESULTSINSPECTION R

ORMANCE CHARACTERISTIC SHEETCHARACTERISTIC SHEET

OGRAPHSOGRAP

IAGRAMSIAGRA

LICENSESLIC

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LEAD-BASED PAINT INSPECTION REPORT

Proposed VA Hospital Garland – Three Buildings

2300 Marie Curie Boulevard Garland, Texas

Terracon Project No. 94197779

1.0 INTRODUCTION

Terracon Consultants, Inc. (Terracon) conducted a limited lead-containing paint inspection of-three (3) buildings on the proposed site of the Veterans Administration (VA) Hospital Garland located at 2300 Marie Curie Boulevard in Garland Texas. Our report presents project information, procedures, visual observations, inspection results, conclusions and recommendations. The purpose of this inspection was to provide information as to whether this building contains lead-based paint (LBP) that may be impacted by upcoming renovations.

1.1 Project Objective

The objective of the LBP inspection was to identify the presence, location and condition of accessible LBP surfaces present on the interior and exterior surfaces of the five-story main hospital structure (2300 Marie Curie Boulevard), a four-story medical plaza (700 Walter Reed Boulevard), and a single-story storage building (900 North Shiloh Road) located in Garland, Texas.

The LBP sampling was conducted in general accordance with the 1997 revision of HUD Guidelines, Chapter 7.

U. S. Department of Housing and Urban Development (HUD) and U. S. Environmental Protection Agency (EPA) guidelines establish an action level for lead-containing painted surfaces of 1.0 milligram per square centimeter (1.0 mg/cm2) as determined using an X-ray fluorescence (XRF) analyzer. The U.S. Occupational Safety and Health Administration (OSHA), however, considers paint containing any level of lead above the analytical method detection limit a potential hazard which should be communicated to any employees or contractors who may disturb the materials in the course of their assigned work.

OSHA recognizes that HUD and the EPA find XRF analyzers acceptable for analyzing lead in paint at their clearance level of 1.0 mg/cm2. They also recognize that some instruments can measure accurately at substantially lower levels. However, please be aware that while XRF analyzers may be an acceptable method of analysis for meeting HUD/EPA requirements, OSHA's concerns are different from those of HUD and EPA.

OSHA does not consider any method that relies solely on the analysis of bulk materials or surface content of lead (or other toxic material) to be acceptable for safely predicting employee exposure to airborne contaminants. Without air monitoring results or without the benefit of historical or objective data (including air sampling which clearly demonstrates that the employee cannot be exposed above the action level during any process, operation, or activity) the analysis of bulk or surface samples cannot be used to determine employee airborne exposure.

DRAFTcontainingcontain paint inspectinspection of-ministration (ministra VA) Hospitaltal GarlandGarl ur reportur repo presents project information, rmation, onclusions and recommendations. The onclusions and recommendations. The n as to whether this n as to whether this buildingbu contains leadd ming renovations. g renova was to identify the presencewas to identify the presence, location an, lo on the interior and exterior he interior and ex surfaces rfaces of to

Curie Boulevard), a fourulevard), a four--story medical plazstory medical plaz y storage building (900 North Shiloh Road) loing (900 North Shiloh Road) nducted in general accordance with ucted in general accordance w the 1997 997 t of Housing and Urban Development (HUDt of Housing and Urban Developmen A) A) guidelines guide establish an blish action level for vel fo per square centimeter (1.0 mg/cmsquare centimeter (1.0 mg/cm22)) as deteas dete

r. The U.S. Occupational Safety and Healt.S. Occupational Safety and Healt t containing any level of lead above the any level of l hich should be chich should be ommunicated to any emplmunicate in the course of their assigned work. in the course of their assigned wo

OSHA recognizes that HUD and theOSHA recognizes that HUD and the paint at their clearance level of paint at their clearance measure accurately at substameasure accurately at s analyzers may be an accepanalyzers may be an acc oncerns are different frooncerns are different f does not condoes not con lead (lead (

Lead-Based Paint Inspection

2300 Marie Curie Boulevard ■ Garland, Texas June 21, 2019 ■ Terracon Project No. 94197779

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Plaza Building – 700 Walter Reed Boulevard

Building Four-story, multi-tenant medical building attached to the main hospital building

Total Area (Included with the main building)

Roof Rubber membrane, rolled-on composition roofing material

Exterior Walls Texture on concrete and texture on plaster

Interior Description Offices, exam rooms, x-ray rooms, procedure rooms, operating rooms, break rooms, conference rooms, corridors, restrooms, electrical rooms, mechanical rooms, elevator lobbies, and stairwells

Interior Walls Textured drywall, textured concrete, textured CMU blocks, textured plaster, unfinished drywall, fiberglass reinforced panel on drywall, wall covering on drywall, and ceramic tile on drywall

Interior Ceilings Textured drywall and 2’x4’ and 2’x2’ lay-in ceiling tile suspended from a concrete deck; spray-on fireproofing was observed on the concrete deck

Interior Floors Unfinished concrete, floor coating, resilient floor covering, vinyl floor tile, raised flooring, carpet, and ceramic tile on a concrete substrate

Survey Limitations/ Inaccessible Areas

Multiple medical suites located in various area of the building were occupied and operational at the time of the survey. The tenants of the occupied suites did not allow unlimited access and access was not granted to the final suite until June 14, 2019. Although the remaining areas of the building were largely vacant, a significant number of the rooms were locked or used as storage space.

Various areas of the vacant spaces had limited lighting or no lighting. Debris and remnant furnishings were observed in various vacant areas throughout the interior of the building. Hard ceilings were installed in various areas throughout the interior of the building. DDDRAFtextured concrete, textured CMU blocks, tecrete, textur hed drywall, fiberglass reinforced panel on ass reinf g on drywall, and ceramic tile on drywallg on drywall, and ceramic tile on

AFTT

he mainhe ma

TTTTon roofing materialn roofing material TTTTTn plastern plaste

FTTTTTooms, procedure rooms, operating ooms, p erence rooms, corridors, restrooms, erence rooms, corridors anical rooms, elevator lobbies, and stairwelcal rooms, elevator lobFTTTTT AFed drywall and 2’x4’ and 2’x2’ laywall and 2’x4’ and 2’x2 -in ceiling ceiling m a concrete deck; spraye deck; spray-on fireproofing waon fireproofing wa oncrete deck AF R

Unfinished concrete, floor coating, resiUnfinished concrete, floor tile, raised flooring, carpet, and ceraraised flooring, carpe

RRRARSurvey Limitations/ Survey Limitation Inaccessible AreasInaccessible Areas

Multiple medical suites locatedple medical suites loca occupied and operational accupied and operational a the occupied suites did nthe occupied suites did n not granted to the finanot granted to the fina remaining areas orem numbernumb of the r Various areaVarious lighting. ting.

vacant werDRRRA

DDDDR

2300 Marie Curie Boulevard ■ Garland, Texas June 21, 2019 ■ Terracon Project No. 94197779

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3.0 FIELD ACTIVITIES

The survey was conducted by the following Texas Department of State Health Services (TDSHS) certified lead risk assessors:

Mr. Chad Champagne, TDSHS Lead Risk Assessor Certificate No. 2071012 Mr. Andrew Cassidy, TDSHS Lead Risk Assessor Certificate No. 2071119

Copies of the licenses are attached in Appendix E. The LBP sampling was conducted in general accordance with the 1997 revision of HUD Guidelines, Chapter 7. A summary of survey activities is provided in the following sections.

3.1 Methodology

A Niton XLp XRF Analyzer and a Heuresis Pb200i XRF Paint Analyzer were used to determine whether a surface coating was LBP.

Each building was evaluated to identify different testing combinations present. Per HUD Guidelines for testing, individual tests are to be classified as part of a group based on the testing combination (room equivalent, component, and substrate). Substrates are classified as brick, masonry, concrete, drywall, metal, plaster, or wood. A component is defined as an item, such as doors, windows, walls, etc. When using testing combinations, lead-containing paint results are classified by summing the individual component test results of positive, negative, or inconclusive.

For more detailed information, including testing location, component, color, and substrate, refer to the XRF testing results contained in Appendix A.

Visual Assessment

Terracon conducted a visual assessment of accessible areas on the interior and exterior of each building. The visual assessment included evaluating the condition of the building area and the condition of painted surfaces. The information gathered in the visual assessment was utilized in determining the testing combinations for the LBP inspection.

Wall and Component Identification System

Perimeter Walls: Perimeter wall sides are identified with letters A, B, C, and D. Side A in a building is the entry door side. Sides B, C, and D are identified clockwise, starting from the “9 o’clock" position from Side A; thus, Side B is to the left, Side C is across from Side A, and Side D is to the right of Side A.

DRAFT

Services (Service tificate tificate No. No. 2071012207 ertificate rtificate No. 20711192071119 sampling was conducted in general sampling was conducted in gener apter 7apter 7. A summary of survey activities ctivities is Pb200i XRF Paint Analyzer aint Ana were used entify different testing combinations presentifferent testing combinations present to be classified as part of a group based ofied as part of a group based o nt, and substrate). Substrates are classified). Substrates are classified r wood. A component is defined as r wood. A component is defined an item ting combinations, ting combination lead-containingontain paint res ent test ent test results of positive, negative, or inconof positive, negative, tailed information, including testing location, ailed information, including testing location, ng results contained in ults contained in Appendix A.Appendix A.

ual Assessmentual Assess

Terracon conducted a visual assessmeTerracon conducted a visual asses buildingb . The visual assessment insual assessment in condition of painted surfacescondition of painted surfa . Th determining the testing combinadetermining the testing co

Wall and Component IdWall and Component Id er Walls:er Walls: PPDoor soor s

2300 Marie Curie Boulevard ■ Garland, Texas June 21, 2019 ■ Terracon Project No. 94197779

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Interior Walls: Interior wall sides are identified with letters. Side A is the wall from which you enter from in each Room Equivalent. The remaining walls are identified clockwise from Side A; thus, Side A is the wall from which you entered, Side B is to the left, Side C is directly in front, and Side D is to the right.

Component: The component field is a representation of the specific testing building component sampled within the room. Each component is given a numerical value to differentiate it from other components. For example, if there are two windows on wall A, and you are testing the right window, start from left to right and mentally number the windows (i.e., 1 and 2). Thus, the window being tested within the room equivalent is window 2.

3.2 XRF Instrumentation

Terracon utilized a Niton XLp XRF (Serial Number 25496) Analyzer and a Heuresis Pb200i XRF Paint Analyzer (Serial Number 2029) to conduct the lead-containing paint inspection. Both XRF analyzers were operated in the “Standard Mode” for this project. No substrate correction is recommended for brick, concrete, drywall, metal, plaster, or wood when these instruments are operated in Standard Mode.

Each instrument was used in general accordance with HUD inspection guidelines and the procedures detailed in the manufacturers’ XRF Performance Characteristics Sheet (PCS) contained in Appendix B. Under HUD guidelines, a lead measurement requires that a reading be taken with a 95% confidence level. This means that the actual measured lead value must exceed the regulatory action level by at least twice the uncertainty value to be considered valid. Uncertainty is not a constant value; it depends on time, measurement, substrate, and the actual lead concentration. In Standard Mode, the Niton XLP XRF and the Heuresis Pb200i XRF automatically incorporate these factors to yield 95% confidence readings. XRF analytical results are expressed as a weight per area. LBP is defined by XRF readings >1.0 mg/cm2.

Calibration of the Niton XLp and the Heuresis Pb200i XRF Paint Analyzer is performed by the manufacturer. This calibration involves measurement of known lead films (NIST reference standards) placed on different building material substrates. The data from the resultant spectra are incorporated into a mathematical function. This function, a component of proprietary software, is used to calculate concentrations of lead.

The accuracy of the field measurement depends on three factors. The first is the quality of the reference standard lead film prepared by NIST. The second factor is accuracy of the mathematical function (i.e., the difference between the calculated concentrations and actual concentrations). Third, the similarity between the building material samples used during calibration and the building materials encountered in the field can impact the accuracy of the measurement.

DRAFT

; th; th nd Side Dnd Side testing building componenttesting buildin ue to differentiate it from other ue to differentiate it d you are testing the right window, d you are testing the right w and 2). Thus, the window being tested and 2). Thus, the window being te ber 25496) AAnalyzer and a nalyzer and a Heuresis Pb200i X the lead-containing paint inspection. g paint i Both X or this project. or this pr No substrate correction is retrate co er, or wood when theor wood when t se instruments ments are opa n general accordance with HUD inspection gance with HUD inspection g rersrers’’ XRF Performance Characteristics SheXRF Performance Charac nes, a lead measurement requires that a readnes, a lead measurement require that the actual measured lead value must ethat the actual measured lead valu uncertainty value to be considered valid. Unceuncertainty value to be considered valid.

asurement, substrate, and the actual lead consurement, substrate, and the actual lead con the Heuresis Pbeuresis 200i XRF00i XRF automatically incautomatically inc

gs. XRF analytical alytical results are expressed as results are expressed as

0 mg/cm0 mg/cm2..

Calibration of the Niton XLpCalibration of the Niton XLp and the and t H manufacturer. This calibration involvemanufacturer. This calibration involve placed on different building materiabuilding materia into a mathematical funinto a mathematical function. Tcti concentrations of lead.concentrations of lead.

accuracy of the accuracy of the ce standardce standard e.,e., thethe

2300 Marie Curie Boulevard ■ Garland, Texas June 21, 2019 ■ Terracon Project No. 94197779

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Calibration checks are performed at least twice daily: once prior to the inspection and once immediately after the inspection, with additional checks performed after each 4 hours of continuous use (see Appendix A for calibration results), using protocols provided by HUD and the instrument manufacturer according to the NIST reference standard.

3.3 XRF Results

3,356 XRF readings were taken from testing combinations observed on the interior and exterior of the five-story main hospital building located at 2300 Marie Curie Boulevard. One hundred twenty-five

(125) XRF readings were above the HUD and EPA action level for LBP of 1.0 mg/cm2.

836 XRF readings were taken from testing combinations observed on the interior and exterior of the four-story medical plaza building located at 700 Walter Reed Boulevard. Six (6) XRF readings were above the HUD and EPA action level for LBP of 1.0 mg/cm2.

334 XRF readings were taken from testing combinations observed on the interior and exterior of the single-story storage building located at 900 North Shiloh Road. Three (3) XRF readings were above the HUD and EPA action level for LBP of 1.0 mg/cm2.

No readings measured as inconclusive. For further information regarding the components tested see XRF testing results in Appendix A.

4.0 REGULATORY OVERVIEW

The Department of Housing and Urban Development (HUD) has issued guidelines titled Guidelines for the Evaluation and Control of Lead Based Paint Hazard in Housing pursuant to Title X of the Housing and Community Development Act of 1992. The US Environmental Protection Agency (EPA) and HUD action level for lead-containing painted surfaces is 1.0 milligram per square centimeter (1.0 mg/cm2) using the X-ray fluorescence analyzer (XRF) method, or 0.5% dry weight using the atomic absorption analytical method.

The State of Texas has established the Texas Environmental Lead Reduction Rules (TELRR) to establish the means to control and minimize public exposure to lead by regulating lead-containing paint activities in target housing and child-occupied facilities. The TELRR contains procedures and requirements for the accreditation of lead training providers, procedures and requirements for the certification of individuals and firms engaged in lead-containing paint activities and standards for performing such activities in target housing and child-occupied facilities. The TELRR also requires that all lead-containing paint activities in target housing and child-occupied facilities be performed by certified individuals. However, the subject buildings at the proposed site DRAFT nnuouo ment manment m ed ed on the interior and exterior of the on the interior and exterio BoulevardBouleva . One hundred twentytwenty-five vel for LBP ofvel for 1.0 mg/cm2.

onsons observed obs on the interior and exterior of he inte Walter Reed BoulevardReed Boulevard.. Six (6)S XRF reading f 1.0 mg/cm22.

ng combinationsng comb observeded on the interior anon th at 900 North Shiloh Road900 North Shiloh . Three (3)ee (3) XRF reX

LBP of 1.0 mg/cm1.0 mg/cm22..

conclusive. For further information regardingfurther information regarding pendix A.pendix A.

ATORY OVERVIEWATORY OVERV

ment of Housing and Urban Development (ent of Housing and Urban Development (HUH valuation and Control of Lead Based Paint on and Control of Lead Based Paint ng and Community Development Act of 1992munity Development Act of 1992 HUDHUD action level for action level for leleadad-containing painted mg/cmmg/cm22) using the X) using the X-ray fluorescence analyzfluoresc absorption analytical method.absorption analytical method.

The State of Texas has establishehas establishe establish the means to control aestablish the means to co paint activities in target houpaint activities in target h nd requirements for thend requirements for th the certification othe certification o rds for perfrds for perf so reqso req

2300 Marie Curie Boulevard ■ Garland, Texas June 21, 2019 ■ Terracon Project No. 94197779

Responsive ■ Resourceful ■ Reliable 8 of VA Hospital Garland do not meet the definition of a child-occupied facility or target housing, and therefore is exempt from the TELRR.

The OSHA Lead Standard for Construction (29 CFR 1926.62) applies to construction work where an employee may be occupationally exposed to lead. All work related to construction, alteration, or repair (including painting and decorating) is included. The lead-in-construction standard applies to any detectable concentration of lead in paint. OSHA considers paint containing any level of lead above the analytical method detection limit a potential hazard which should be communicated to any employees or contractors who may disturb the materials in the course of their assigned work. Due to the nature of the site, the OSHA regulations will apply to the construction and/or demolition activities, since the site does not meet the definition of a child occupied facility or target housing.

OSHA does not consider any method that relies solely on the analysis of bulk materials or surface content of lead (or other toxic material) to be acceptable for safely predicting employee exposure to airborne contaminants. Without air monitoring results or without the benefit of historical or objective data (including air sampling which clearly demonstrates that the employee cannot be exposed above the action level during any process, operation, or activity) the analysis of bulk or surface samples cannot be used to determine employee airborne exposure.

Compliance with applicable OSHA lead regulations is the responsibility of the contractor performing the work and it is recommended that they be required to communicate potential lead hazards to their workforce and utilize lead-safe work practices such as outlined in the EPA Renovation, Repair, and Painting Final Rule (40 CFR 745) or applicable portions of the Structural Steel Painting Council (SSPC) Guidelines. It is further recommended that activities such as flame/torch dismantling, dry sanding and/or dry grinding of any components with lead-containing materials applied should be prohibited as part of any repair, renovation or demolition activity.

DRAFT

struction work wstruction construction, alterationconstruct --inin--construction standard constructio nsiders paint containing any nsiders paint contai tential hazard which should be tential hazard which shou sturb the materials in the courssturb the materials in the course of e OSHA regulations will apply to the OSHA regulations will apply to the e does not meet the definition of a child e does not meet the definition of a child s solely on the analysis of bulk materials or the analysis o e acceptable for safely predicting employeesafely p monitoring results or without the benefit omonitoring results or without t g which clearly demonstrates that the empwhich clearly demonstrates that th uring any process, operation, or activity) theny process, operation, or activity) th ed to determine empmine e loyee airborne exposuree airborne exposur able OSHA lead regulations is the respable OSHA lead regulations and it is recommended that they be requiredand it is recommended that they orkforce and utilize leadorkforce and utiliz -safe work practafe w pair, and Painting Final Rule (40 CFR 745) pair, and Painting Final Rule (40 CFR 7 ng Council (SSPC) Guidelines. It is furthg Council (SSPC) Guidelines. It is furth h dismansmantling, dry sanding and/or dry grindtling, dry sanding and/or dry grind als applied should be prohibited as part of ashould be prohibited as part of a

2300 Marie Curie Boulevard ■ Garland, Texas June 21, 2019 ■ Terracon Project No. 94197779

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5.0 FINDINGS AND CONCLUSIONS

LBP was identified in the evaluation performed on the proposed site of the VA Hospital Garland.

The following LBP were observed “poor” condition and may present a potential hazard:

Main Hospital Building at 2300 Marie Curie Boulevard

Beige paint on 3rd floor elevator equipment room metal door casing (XRF reading 1562) and beige paint on 3rd floor elevator equipment room metal door jamb (XRF reading 1523)

Storage Building at 900 North Shiloh Road

Tan paint on metal exterior roof access ladder (XRF reading 39) and white paint on hallway 7M plaster wall (XRF reading 278)

The following table presents XRF readings identifying lead concentrations above the HUD and EPA action level for LBP of 1.0 mg/cm2:

Reading Number

Reading Location Component

Lead Concentration

(mg/cm2) Main Hospital Building - 2300 Marie Curie Boulevard

7 5th Floor – Medical Records Pink paint on side A drywall wall 5.4*

12 5th Floor – Dietary Room White paint on side A drywall wall 7.3*

858 1st Floor – Administrative Conference Room Gray paint on side C drywall 7.8*

1540 3rd Floor C11 Elevator Lobby Beige paint on side A metal door casing 1.7

1541 3rd Floor C11 Elevator Lobby Beige paint on side A metal door jamb 1.3

1547 3rd Floor C11 Elevator Lobby Beige paint on side C metal door 3.3

1548 3rd Floor C11 Elevator Lobby Beige paint on side C metal door casing 2.6

1549 3rd Floor C11 Elevator Lobby Beige paint on side C metal door jamb 3.5

1550 3rd Floor C12 White paint on side A metal door casing 2.9

1554 3rd Floor Exit Stair 1 Beige paint on side A metal door casing 3.4

1555 3rd Floor Exit Stair 1 Beige paint on side A metal door jamb 3.8

1556 3rd Floor Exit Stair 1 Beige paint on side A metal door 2.8

1562 3rd Floor Elevator Equipment Room Beige paint on side A metal door casing 1.9

1563 3rd Floor Elevator Equipment Room Beige paint on side A metal door jamb 3.2

Hospital Hospita Ga t t a potential hazard:a potent l l door casingdoor c (XRF reading 1562)g 1562) and metal door jambmetal do (XRF reading 1523)23) ss ladder (XRF reading 39) andF reading 39 white paint adings ngs identifying identifying lead concentrations abovlead concentrations a

RARAeading

RALocation

RARARARARARARARAMain Hospital 2300

RARARA55thth Floor Flo – Medical RecordsReco Pink paPink pRARARARA55thth Floor Flo – Dietary Roometary Room WhitWhitRARARA

DRA

1st Floor r –– Administrative Conference Administrative Conference

RoomRoo

DDDRRRDR15401540 33rdrd Floor C11 Elevator LobbyFloor C11 Eleva

DDDRD154115 33rdrd Floor C11 Elevator LobbFloor C11 Elevator LDDDRD1547 3rd Floor C11 Elevator Lloor C11 Elevator LDDDRD1548 3rd Floor C11 Elevaor C1DDDD1549154 3rd Floor C11 Eor C1DDDD15501550 33rdrdDDDD44 33rdrdDDDDDDDDD

2300 Marie Curie Boulevard ■ Garland, Texas June 21, 2019 ■ Terracon Project No. 94197779

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Reading Number

Reading Location Component

Lead Concentration

(mg/cm2) 2743 1st Floor Radiology Blue paint on side C drywall wall 6.6*

2744 1st Floor Radiology Blue paint on side D drywall wall 5.6*

2781 1st Floor IM Room Beige paint on side D drywall wall 5.2*

2801 1st Floor Room D77 Beige paint on side A metal door casing 7.7*

2803 1st Floor Room D77 Beige paint on side B metal window casing 13.2*

2804 1st Floor Room D77 Beige paint on side A drywall wall 5.1*

2805 1st Floor Room D77 Beige paint on side B drywall wall 4.5*

2806 1st Floor Room D77 Beige paint on side C drywall wall 6.1*

2807 1st Floor Room D77 Beige paint on side D drywall wall 4.3*

2827 1st Floor Room NM2 Orange paint on side D drywall wall 5.6*

2862 1st Floor Room D90 White paint on side A metal door jamb 3.6*

2863 1st Floor Room D90 White paint on side A drywall wall 5.7*

2864 1st Floor Room D90 White paint on side B drywall wall 7.5*

2865 1st Floor Room D90 White paint on side B metal window casing 12.7*

2879 1st Floor Room D92 Beige paint on side D drywall wall 5.2*

2999 Basement Room D101 Blue paint on metal pump motor 4.7

3029 Basement D107 Stairwell Beige paint on side A metal door 3.2

3030 Basement D107 Stairwell Beige paint on side A metal door casing 2.0

3031 Basement D107 Stairwell Beige paint on side A metal door jamb 2.9

3074 Basement Mechanical Room Gray paint on side A metal door casing 2.4

3075 Basement Mechanical Room Gray paint on side A metal door jamb 2.9

3076 Basement Mechanical Room Gray paint on side A metal door 2.0

3094 Basement Room D111 Beige paint on side A metal door 2.6

3095 Basement Room D111 Beige paint on side A metal door casing 2.8

3096 Basement Room D111 Beige paint on side A metal door jamb 3.1

Medical Plaza Building - 700 Walter Reed Boulevard

314 Room MP 111 Beige paint on side B drywall wall 6.0*

DRAFTTTT

C

TT

allall 6.

TTTTall wallall wall 5.6*TTTTdrywall walldrywall wall 5.2*TTTTmetal door casingmetal d 7.7*TTTFTside B metal window side B m casingcasing 13.2*13.2*

FTFTFTFTaint on side A drywall wallaint on s 5.1*1*FTFTFTFTge paint on side B drywall wallge paint on side B drywall 4.5*FTFTFTFTBeige paint on side C drywall wallpaint on side C dryw 6.FTFTFTFT Beige paint on side D drywall wallt on side D

AFFFAFOrange paint on side D drywall walln side D

AAAFFFAFWhite paint on side A metal door jamWhite paint on side A metal dAAAFAD90 White paint on side A drywall White paint on side A drywall AAAFAom D90 White paint on side B drywe paint on side B drAAAF RAor Room D90r Room D White paint on side B mWhite paint on side B m casin

RARARARAFloor Room D92Floor Room D92 Beige paint on Bei

RARARARABasement Room D101Basement Room D101 Blue paBRARARARABasement D107 StairwellBasement D107 Stairwell BeigBeigRARARARA

Basement D107 Stairwellasement D107 S BeigBeigRRRDR03131 Basement D107 Stairwellment D1

DDDRRRDR30743074 Basement Mechanical RoomBasement Mechanic

DDDRD3075 Basement Mechanical ement Mechanical DDDRD307630 Basement Mechaent MDDDD30943094 BasemeBasemDDDDBBDDDDD

2300 Marie Curie Boulevard ■ Garland, Texas June 21, 2019 ■ Terracon Project No. 94197779

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Reading Number

Reading Location Component

Lead Concentration

(mg/cm2) 325 MP Classroom White paint on side A metal door jamb 8.3*

326 MP Classroom White paint on side A metal door casing 9.1*

414 Suite 205 Cardiology Lab Beige paint on side D drywall wall 8.8*

433 Suite 205 Prep Room Beige paint on side C drywall wall 8.9*

440 Suite 205 Stress Room Beige paint on side D drywall wall 8.2*

Storage Building - 900 North Shiloh Road

39 South Exterior Tan paint on metal roof access ladder 2.7

277 Hallway 7M White paint on side A metal door casing 2.1

278 Hallway 7M White paint on side A plaster wall 1.1 *Substantially elevated XRF readings may indicate the presence of protective lead-lining on the interior of walls and adjacent substrate

The OSHA Lead Standard for Construction (29 CFR 1926.62) applies to construction work where an employee may be occupationally exposed to lead. All work related to construction, alteration, or repair (including painting and decorating) is included. The lead-in-construction standard applies to any detectable concentration of lead in paint. OSHA considers paint containing any level of lead above the analytical method’s LOD a potential hazard which should be communicated to any employees or contractors who may disturb the materials in the course of their assigned work.

Renovation activities impacting materials with identified lead-containing paint will be subject to OSHA regulations (29 CFR 1926.62 - Lead Exposure in Construction). The OSHA regulation defines specific training requirements, engineering controls and working practices for construction personnel subject to this standard. There are also federal and state regulations, which require characterization of demolition debris to determine proper disposal procedures.

OSHA does not consider any method that relies solely on the analysis of bulk materials or surface content of lead (or other toxic material) to be acceptable for safely predicting employee exposure to airborne contaminants. Without air monitoring results or without the benefit of historical or objective data (including air sampling which clearly demonstrates that the employee cannot be exposed above the action level during any process, operation, or activity) the analysis of bulk or surface samples cannot be used to determine employee airborne exposure.

6.0 GENERAL COMMENTS

This lead containing 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

DRAFTTTT

C

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jambjamb 8.

TTTToor casingoor casing 9.1*TTTTdrywall walldrywall wall 8.8*TTTTe C drywall walle C dryw 8.9*TTTFTn side D drywall walln side D 8.2*8.2*

FTFTFTFTFTFThiloh R

FTFTFTnt on metal roof access laddernt on metal roof access 2.7FTFTFTFTe paint on side A metal door casingpaint on side A metal doo 2.1FTFTFTFTWhite paint on side A plaster wallaint on side A pl

AFTFTFT

AFFTFFrotective lead-lining on the interior of walls and adjacent substratee interior of w uction (29 CFR 1926.62) applies to construction (29 CFR 1926.62) applies to co lly exposed to lead. All work osed to lead. All work related to cond to con and decorating) is included. The leadting) is included. The lea -inn oncentration of lead in paint. OSHA consilead in paint. OSHA consi he analytihe analyt cal method’s LOD a potentiaod’s LOD y employees or contractors who may distury employees or contractors who k.k.

activities impacting materials with identifiedactivities impacting materials with identifie gulations (29 CFR 1926.62 ons (29 CFR 1926.62 -- Lead ExposuLead Exposu s specific training requirements, engineeringaining requirements, engineering sonnel subject to this standard. There aresonnel subject to this sta characterization of demolition debris to detecharacterization of demolition d

OSHA does not consider any methodOSHA does not consider any method content of lead (or other toxic mateother toxic mate to airborne contaminants. Witto airborne contaminants objective data (including airobjective data (including xpoxposed above the actiosed above the actio ace samples cannace samples cann

ENEENE

2300 Marie Curie Boulevard ■ Garland, Texas June 21, 2019 ■ Terracon Project No. 94197779

Responsive ■ Resourceful ■ Reliable 15 in the same locale. The results, findings, conclusions, and recommendations expressed in this report are based on conditions observed during our inspection of the building. The information contained in this report is relevant to the dates on which this inspection was performed, and should not be relied upon to represent conditions at a later date.

This report has been prepared on behalf of and exclusively for use by Enapay, LLC for specific application to their project as discussed. Contractors, consultants or others 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, express or implied is made.

DRAFT

TheThe ormed, anormed, by by Enapay, LLC Enapay, LL for specific or others reviewing this report or others reviewing or remediation deemed necessary. or remediation deemed nec s, laboratories or other third parties s, laboratories or other third pa preparation of this report. No warranty, preparation of this report. No warranty

APPENDIX A

LEAD-BASED PAINT INSPECTION RESULTS

DRAFT

APPENDIX AAPPENDIX A

LEADLEAD--BASEDB PAINT INSPECTION RESNT INSPE

Reading No Floor Room Side Component Feature Color Substrate Condition Results PbC

1 Calibration White Negative 0 2 Calibration Red Positive 1.2 3 Calibration Gold Negative 0.7 4 Calibration Yellow Positive 4 5 Calibration Orange Positive 1.9 6 Calibration Green Negative 0.3 7 Basement Hallway 1 A Elevator Door 1 N/A Pink Metal Intact Negative 0.2 8 Basement Hallway 1 A Elevator Door 1 Casing Pink Metal Intact Negative 0.2 9 Basement Hallway 1 B Door Casing White Metal Intact Negative 0.3

10 Basement Hallway 1 A Wall N/A White Drywall Intact Negative 0.1 11 Basement Hallway 1 B Wall N/A White Drywall Intact Negative <LOD 12 Basement Hallway 1 C Wall N/A White Drywall Intact Negative 0.2 13 Basement Hallway 1 D Wall N/A White Drywall Intact Negative 0.2 14 Basement Hallway 2 C Door Casing White Metal Intact Negative 0.1 15 Basement Hallway 2 D Wall N/A White Drywall Intact Negative 0.2 16 Basement Hallway 2 B Wall N/A White Drywall Intact Negative 0.2 17 Basement Hallway 2 - Closet C Wall N/A White CM4 Intact Negative <LOD 18 Basement Women's RR A Door Casing White Metal Intact Negative 0.1 19 Basement Women's RR Middle Ceiling N/A White Drywall Fair Negative 0.1 20 Basement Men's RR A Door Casing White Metal Intact Negative 0.1 21 Basement Men's RR Middle Ceiling N/A White Drywall Intact Negative 0.1 22 Basement Stairwell A Door Casing White Metal Intact Negative 0.5 23 Basement Stairwell D Stringer N/A Beige Metal Intact Negative 0.1 24 Basement Stairwell D Pipe N/A Beige Metal Intact Negative 0.1 25 Basement Stairwell D Handrail N/A Beige Metal Intact Negative <LOD 26 Basement Stairwell A Wall N/A Beige Plaster Intact Negative <LOD 27 Basement Stairwell B Wall N/A Beige Plaster Intact Negative 0.1 28 Basement Stairwell C Wall N/A Beige Plaster Intact Negative <LOD 29 Basement Stairwell D Wall N/A Beige Plaster Intact Negative <LOD 30 Calibration 1.0 31 Calibration 0.9 32 Calibration 0.9 33 Calibration 0.9 34 Calibration 0.9 35 Calibration 0.9 36 1st M Hallway A Door Casing Gray Metal Intact Negative <LOD 37 1st M Hallway A Wall N/A White Drywall Intact Negative <LOD 38 1st M Hallway B Wall N/A White Drywall Intact Negative <LOD 39 1st M Hallway D Wall N/A White Drywall Intact Negative <LOD 40 1st M Hallway D Column 3 N/A White Concrete Intact Negative <LOD 41 1st M1 A Door Casing White Metal Intact Negative <LOD 42 1st M1 A Door Jamb White Metal Intact Negative <LOD 43 1st M1 B Window Casing Black Metal Intact Negative 0.2 44 1st M1 A Wall N/A White Drywall Intact Negative 0.1 45 1st M1 B Wall N/A White Drywall Intact Negative 0.1 46 1st M1 C Wall N/A White Drywall Intact Negative 0.2 47 1st M1 D Wall N/A White Drywall Intact Negative 0.1 48 1st M1 D Ceiling N/A White Drywall Intact Negative 0.1 49 1st M4 A Door Casing White Metal Intact Negative 0.1 50 1st M4 A Door Jamb White Metal Intact Negative <LOD 51 1st M4 C Window Casing Black Metal Intact Negative 0.3 52 1st M4 A Wall N/A White Drywall Intact Negative <LOD 53 1st M4 B Wall N/A White Drywall Intact Negative 0.1 54 1st M4 D Wall N/A White Drywall Intact Negative 0.1 55 1st M4 A Ceiling N/A White Drywall Intact Negative 0.2 56 1st M6 A Door Casing White Metal Intact Negative <LOD 57 1st M6 A Door Jamb White Metal Intact Negative 0.1 58 1st M6 C Window Casing Black Metal Intact Negative 0.1 59 1st M6 A Column N/A White Concrete Intact Negative <LOD 60 1st M6 A Wall N/A White Drywall Intact Negative 0.1 61 1st M6 B Wall N/A White Drywall Intact Negative 0.1 62 1st M6 C Wall N/A White Drywall Intact Negative 0.1 63 1st M6 D Wall N/A White Drywall Intact Negative <LOD 64 1st M6 A Ceiling N/A White Drywall Intact Negative 0.2 65 1st M8 A Column N/A White Concrete Fair Negative <LOD 66 1st M8 A Wall N/A White Drywall Intact Negative 0.2 67 1st M8 B Wall N/A White Drywall Intact Negative 0.1 68 1st M8 C Wall N/A White Drywall Intact Negative 0.1 69 1st M8 D Wall N/A White Drywall Intact Negative <LOD 70 1st M8 A Ceiling N/A White Plaster Intact Negative 0.1

Plaza Building - 700 Walter Reed Boulevard

DRAFT

IntactIntact IntactInt N etaletal Intact Nega DrywallDrywall Intact Negative DrywallDrywall Intact Negative ee DrywallDrywall IntactInta Negative 0 hitehite DrywallD IntactIntact Negative 0.2

Whitehite Metal IntactIntact Negative 0.1 WhiteWhite Drywall Intacttact NegativeNe 0.2 WhiteWh Drywall Intactt NegativeNegat 0.2 White CM4 Intact NegativeNegative <LOD ngng White Metal Intact NegativeNegative 0.1 N/AN/A White Drywall Fair Negativeative 0.10

CasingCasing White Metal Intact Negativeve N/AN/A Whitee DrywallDry Intact Negative

CasingCasing Whitehite Metal Intact Negat N/AN/A BeigeBeige Metal Intact Ne N/AN/A BeigeBeige Metal Intact ail N/AA BeigeBe Metal Intact Wall N/A Beige Plaster Inta WallW N/A BeigeBeig Plaster I WallWall N/A BeigeBeige Plaster WallWall N/A BeigeBeige Plaster ayy AA Door Casing lwaylway AA Wall N/A

HallwayHallway BB Wall N/A M HallwayM Hallwa DD Wall N/A M HallwayM Hal DD Column 3 N

M1 AA Door M1 AA DoorDoor M1M BB WindowWindow

1st M1M1 A WallWall 1st M1M1 B Wall 1st 1st M1M1 C Wall 1st 1st M1 D Wa

88 1st 1st M1 D C 4949 1st M4M AA 5050 1st M4M4 AA 5151 1st M4M4 CC 52 1st M4M4 AA 5353 1st M4M4 5454 1st M4M4 5555 1st M4M4 5656 1st M6M6

1st 1 M6M6 1st 1st M6M6 1st 1st MM 1st 1st

71 1st M10 A Door Casing White Metal Intact Negative 0.1 72 1st M10 A Door Jamb White Metal Intact Negative 0.1 73 1st M10 A Wall N/A White Drywall Intact Negative <LOD 74 1st M10 B Wall N/A White Drywall Intact Negative <LOD 75 1st M10 C Wall N/A White Drywall Intact Negative 0.1 76 1st M10 D Wall N/A White Drywall Fair Negative 0.1 77 1st M10 Middle Ceiling N/A White Drywall Intact Negative <LOD 78 1st M11 A Door Casing Beige Metal Intact Negative 0.1 79 1st M11 A Door Jamb Beige Metal Intact Negative <LOD 80 1st M11 A Wall N/A Beige Drywall Intact Negative 0.2 81 1st M11 B Wall N/A Beige Drywall Intact Negative 0.1 82 1st M11 C Wall N/A Beige Drywall Intact Negative 0.1 83 1st M11 D Wall 2 N/A Beige Drywall Intact Negative <LOD 84 1st M11 D Wall 2 N/A Beige Drywall Intact Negative 0.2 85 1st M13 A Door Casing Beige Metal Intact Negative 0.1 86 1st M13 A Door Jamb Beige Metal Intact Negative 0.1 87 1st M13 A Wall N/A Beige Drywall Intact Negative 0.1 88 1st M13 B Wall N/A Beige Drywall Intact Negative 0.1 89 1st M13 C Wall N/A Beige Drywall Intact Negative 0.1 90 1st M13 D Wall N/A Beige Drywall Intact Negative 0.1 91 1st M Hallway 1 A Door Casing White Metal Poor Negative 0.1 92 1st M Hallway 1 A Door Jamb White Metal Poor Negative 0.1 93 1st M Hallway 1 B Wall N/A White Drywall Fair Negative 0.1 94 1st M Hallway 2 B Door 1 Casing White Metal Poor Negative 0.2 95 1st M Hallway 2 B Door 1 Jamb White Metal Poor Negative <LOD 96 1st M17 A Door Casing Gray Metal Intact Negative 0.1 97 1st M17 A Door Jamb Gray Metal Intact Negative 0.1 98 1st M21 A Door Casing Beige Metal Fair Negative 0.1 99 1st M21 A Door Jamb Beige Metal Fair Negative 0.1

100 1st M21 C Wall N/A White Drywall Intact Negative <LOD 101 1st M21 D Wall N/A White Drywall Intact Negative <LOD 102 1st M21 D Ceiling N/A White Drywall Poor Negative <LOD 103 1st M21 D Cabinet Door White Metal Intact Negative <LOD 104 1st M Hallway 3 A Door Casing White Metal Poor Negative 0.2 105 1st M Hallway 3 A Door Jamb White Metal Poor Negative <LOD 106 1st M Hallway 3 A Ceiling N/A White Drywall Intact Negative <LOD 107 1st M24 A Door Casing White Metal Intact Negative 0.1 108 1st M24 A Door Jamb White Metal Intact Negative 0.1 109 1st M24 A Wall N/A Beige Drywall Intact Negative 0.1 110 1st M24 B Wall N/A Beige Drywall Intact Negative 0.1 111 1st M24 C Wall N/A Beige Drywall Intact Negative 0.2 112 1st M24 D Wall N/A Beige Drywall Intact Negative <LOD 113 1st M24 A Ceiling N/A Beige Drywall Intact Negative <LOD 114 1st OR4 A Door Jamb White Metal Fair Negative <LOD 115 1st OR4 A Ceiling N/A White Drywall Poor Negative <LOD 116 1st OR2 A Door Casing White Metal Intact Negative 0.1 117 1st OR2 A Door Window Casing Brown Metal Intact Negative 0.1 118 1st OR2 A Door Jamb White Metal Intact Negative 0.2 119 1st OR2 A Ceiling N/A White Drywall Fair Negative <LOD 120 1st OR1 A Door Casing White Metal Intact Negative <LOD 121 1st OR1 A Door Jamb White Metal Intact Negative 0.1 122 1st OR1 B Ceiling N/A White Drywall Fair Negative <LOD 123 1st OR3 A Door Casing White Metal Fair Negative 0.1 124 1st OR3 A Door Jamb White Metal Fair Negative 0.1 125 1st OR3 A Corner Board N/A White Metal Poor Negative 0.1 126 1st OR3 D Ceiling N/A White Drywall Fair Negative <LOD 127 1st M Hallway 5 A Door Casing White Metal Intact Negative 0.1 128 1st M Hallway 5 A Door Jamb White Metal Intact Negative 0.1 129 1st M Hallway 5 A Corner Board N/A White Metal Intact Negative <LOD 130 1st M Hallway 4 A Door Casing White Metal Intact Negative 0.1 131 1st M Hallway 4 A Door 1 Jamb White Metal Intact Negative <LOD 132 1st M Hallway 4 B Corner Board N/A White Metal Fair Negative 0.2 133 1st M27 A Door Casing White Metal Intact Negative 0.2 134 1st M27 A Door Jamb White Metal Intact Negative <LOD 135 1st M26 A Door Casing White Metal Poor Negative 0.1 136 1st M26 A Door Jamb White Metal Poor Negative 0.1 137 1st M26 A Ceiling N/A Beige Drywall Poor Negative 0.1 138 1st M23 A Door Casing White Metal Poor Negative 0.1 139 1st M23 A Door Jamb White Metal Poor Negative <LOD 140 1st M23 Middle Ceiling N/A Beige Drywall Fair Negative 0.1 141 1st M28 A Door Casing White Metal Fair Negative 0.1

DRAFT

IntactIntact IntactIntact IntactInt N wallwall Intact Nega DrywallDrywall Intact Negative DrywallDrywall Intact Negative DrywallDrywall IntactInta Negative <LO eigeeige DrywallD IntactIntact Negative 0.2 Beigeeige Metal IntactIntact Negative 0.1 BeigeB Metal Intacttact NegativeNe 0.1 BeigeBe Drywall Intactt NegativeNegat 0.1 Beige Drywall Intact NegativeNegative 0.1

AA Beige Drywall Intact NegativeNegative 0.1 N/AN/A Beige Drywall Intact Negativeative 0.10

CasingCasing White Metal Poor Negativeve JambJam Whitee MetalM Poor Negative N/AN/A Whitehite DrywallD Fair Negat

CasingCasing WhiteWhite Metal Poor Ne Jambamb WhiteWhite Metal Poor r Casingng GrayG Metal Intact oor Jamb Gray Metal Inta

DoorDo Casing BeigeBeig Metal DoorDoor Jamb BeigeBeige Metal WallWall N/A WhiteWhite Drywall WallWa N/AN/ Whitehite DrywDr

CeilingCeiling N/AN/A White DrDr D CabinetCabinet DoorDoor White A DoorDoor CasingCasing WhiteWhite A Dooroor JambJa WhiWhi A Ceilingng N/A W AA Door Casing

44 AA Door Jamb M24M24 AA Wall N/A M24M24 BB Wall N/A M24M2 CC Wall N M24 DD Wall M24 AA CeilingCeiling OR4OR AA DoorDoor

1st OR4OR4 A CeilingCeiling 1st OR2OR2 A Door 1st 1st OR2R2 A Door 1st 1st OR2 A Do

99 1st 1st OR2 A C 120120 1st OR1O AA 121121 1st OR1OR1 AA 12212 1st OR1OR1 BB 123 1st OR3OR3 AA 12412 1st OR3OR3 125125 1st OR3R3 126126 1st OR3R3

2727 1st M Hallway 5Hallway 5 1st 1 M Hallway 5M Hallway 1st 1st M HallwM Hallw 1st 1st M HaM Ha 1st 1st MM

142 1st M28 A Door Jamb White Metal Fair…