Bldg 60 LBP Survey Report FINAL.pdf

LEAD-BASED PAINT SURVEY

VA NORTH TEXAS HEALTH CARE SYSTEM

4500 SOUTH LANCASTER ROAD

DALLAS, TX 75216

BUILDING 60 - COMMUNITY LIVING CENTER

PREPARED FOR:

VA MEDICAL CENTER

ENGINEERING SERVICES

4500 SOUTH LANCASTER ROAD

DALLAS, TX 75216

JANUARY 7, 2015

PREPARED BY:

MICRO AIR OF TEXAS, INC.

P. O. Box 1225 Dickinson, TX 77539

(281) 280-9965

Melissa Kiser, I.H.

EPA Certified and DSHS Certified

Lead Risk Assessor (DSHS Certification #2070957)

TABLE OF CONTENTS

Page #

Section A General Information

Introduction 1 - 2 Facility Description Sampling Methodology Limitations

Section B - Executive Summary

Information 2 XRF Lead-based Paint Sampling Summary Table 3 - 8

Section C - Conclusions and Recommendations 9

Appendix I - XRF Sample Location Drawings

M ICRO AIR OF TEXAS, INC. VA North Texas Health Care System - Lead-based Paint Survey Building 60 - Dallas, Texas 1

A. GENERAL SURVEY INFORMATION

Micro Air of Texas, Inc. was contracted by the VA North Texas Health Care System (VANTHCS) to conduct a lead-based paint inspection on all buildings located on the Dallas, Texas VAMC campus, as well as all buildings located at the VAMC in Bonham, Texas and others owned by the VANTHCS system. Under this contract, Micro Air conducted a lead-based paint inspection in the Dallas VAMC Building 60, which currently is known as the Community Living Center. This survey was conducted using a portable X-ray Fluorescence Analyzer (XRF) to determine the levels of lead present in painted surfaces. This survey was performed on January 7, 2015.

Facility Description

The scope of work for this survey included the exterior doors, hand rails, interior walls, window frames, doors, I-beams, and miscellaneous other interior building components of this one-story building, which was constructed in 1984, according to information provided by VAMC Engineering Services. This building is constructed with brick exterior walls, a wooden frame, and it has a concrete floor. The building interior has sheetrock, various floor coverings, and drop ceilings. The facility houses nursing home patients.

Sampling Methodology

The objective of this lead survey was to determine, as accurately as possible, the nature and extent of all paint which may be lead-containing. Paints were grouped by the “Room Equivalent” (room number / function, etc.), “Building Component” (wall, door, window frame, etc.), “Substrate” (plaster, metal, wood, brick, etc.), and “Paint Color”. Paint chip samples were collected for confirmation purposes, as necessary, for any XRF sample result that was “inconclusive”. This survey was directed by Melissa Kiser, an EPA Certified Lead Risk Assessor and a Department of State Health Services (DSHS) Certified Lead Risk Assessor (Certification # 2070957), and performed by Jennifer McMillin and James Cyran, both are considered an Industrial Hygiene Technician. Micro Air of Texas, Inc. is licensed by the DSHS as a Lead Firm in the state of Texas (TDSHS license #2110550).

The Department of Housing and Urban Development (HUD) testing protocol was not used for this inspection, as this building is not considered to be included in the definition of “Target Housing” or “Child-Occupied Facility”; therefore, not every painted surface of every Room Equivalent was tested.

If paint chip samples were collected, all material samples were sealed in airtight containers and documented on field data forms. Strict chain of custody procedures were adhered to between the sample site and the laboratory. The samples were analyzed by J Resources, Inc., an AIHA ELPAT accredited laboratory (AIHA3 laboratory ID #157714.). All samples were analyzed utilizing Atomic Absorption Spectro-photometry, in accordance with ASTM Method D3335-85A and EPA Method SW846-(7420/3050B). Standard quality control procedures were adhered to during the analyses. The laboratory analytical report can be located in Appendix II of this report. No paint chip samples were collected during this inspection. All XRF results were conclusive.

M ICRO AIR OF TEXAS, INC. VA North Texas Health Care System - Lead-based Paint Survey Building 60 - Dallas, Texas 2

Limitations

Micro Air’s scope of services was limited primarily to accessible interior and exterior building components.

While Micro Air made every effort to perform a thorough survey, the possibility exists that paint containing lead were not identified, inaccessible, or different from those identified at other locations. The findings and opinions presented are indicative of conditions on the date of our site inspection and should not be relied upon to represent conditions at substantially later dates, due to possible changes in the condition of building materials, renovations, and repairs.

This report is for the exclusive use of the client and its agents; any use by unauthorized parties in whole or in part, except as directed by legal jurisdiction, is at the sole risk of the user.

B. EXECUTIVE SUMMARY OF FINDINGS

According to the HUD Lead-based Paint Interim Guidelines for Hazard Identification and 40 CFR Part 745, Environmental Protection Agency Lead-based Paint in Target Housing and Child-Occupied Facilities, the definition of lead-based paint is paint which has a lead content of 5000 mg/kg (0.5% by weight) or greater, or 1.0 milligrams per square centimeter (mg/cm ) of painted surface area. All XRF results have been reported2 in mg/cm (weight of lead per surface area). There were a total of 5 XRF readings on various building2 components with results greater than 1.0 mg/cm . All other collected samples had a lead content less than2

1.0 mg/cm . A total of 84 XRF readings were collected during this lead-based paint inspection.2

M ICRO AIR OF TEXAS, INC. VA North Texas Health Care System - Lead-based Paint Survey Building 60 - Dallas, Texas 3

XRF LEAD-BASED PAINT SAMPLING

SUMMARY TABLE

BUILDING 60

Sample ID# Room Equivalent

Component Substrate Color XRF Result (mg/cm )2

60-01 Hallway at Room 140

Wall Sheetrock Cream 0.00

60-02 Hallway at Room 140

Door Wood Cream 0.00

60-03 Hallway at Room 140

Door Frame Metal Cream 0.00

60-04 Hallway at Room 140

Wall Around Water

Fountain

Ceramic Tile on Sheetrock

Tan 0.00

60-05 Room 102 Mens Restroom

Wall Concrete CMU Block

Tan 0.00

60-06 Room 110 Wall Vinyl on Sheetrock

Brown 0.00

60-07 Room 110 Wall Vinyl on Sheetrock

Yellow 0.00

60-08 Room 107 Wall Sheetrock Blue 0.00

60-09 Hallway at Room A103

Wall Sheetrock Light Blue 0.00

60-10 Hallway at Room A103

Door Frame Metal Tan 0.00

60-11 Room A103 Wall Sheetrock Light Blue 0.00

60-12 Room A103 Wall Ceramic Tile on Sheetrock

Brown >1.00

60-13 Room A103 Wall Sheetrock Blue & Green

0.00

60-14 Room A103 Locker Metal Tan 0.00

60-15 Room A103A Restroom

Wall Ceramic Tile on Sheetrock

Cream >5.00

M ICRO AIR OF TEXAS, INC. VA North Texas Health Care System - Lead-based Paint Survey Building 60 - Dallas, Texas 4

SUMMARY TABLE

BUILDING 60

Sample ID# Room Equivalent

Component Substrate Color XRF Result (mg/cm )2

60-16 Room A103A Restroom

Wall Ceramic Tile on Sheetrock

Tan >5.00

60-17 Hallway at Room A106

Door Frame Metal Tan 0.00

60-18 Room A141 Wall Sheetrock Tan 0.00

60-19 Room A141 Wall Vinyl on Sheetrock

Tan 0.00

60-20 Hallway at Room A112

Wall Sheetrock Light Blue 0.00

60-21 Hallway at Room A156

Wall Ceramic Tile on Sheetrock

Cream >1.00

60-22 Room A156 Wall Ceramic Tile on Sheetrock

Tan 0.00

60-23 Room A156 Door Frame Metal Tan 0.00

60-24 Room A120 Wall Sheetrock Light Green 0.00

60-25 Room A120 Locker Metal Cream 0.00

60-26 Room A122 Door Frame Metal Cream 0.00

60-27 Hallway at Room A126

Wall Sheetrock Blue 0.00

60-28 Exterior Walkway

Support Beam Metal Dark Brown 0.00

60-29 Smoking Shelter Wall Wood Dark Brown 0.00

60-30 Smoking Shelter Wall Wood White 0.00

M ICRO AIR OF TEXAS, INC. VA North Texas Health Care System - Lead-based Paint Survey Building 60 - Dallas, Texas 5

SUMMARY TABLE

BUILDING 60

Sample ID# Room Equivalent

Component Substrate Color XRF Result (mg/cm )2

60-31 Exterior Railing Metal Dark Brown 0.00

60-32 Exterior Fence Metal Black 0.13

60-33 Room A174 Wall Sheetrock Tan 0.00

60-34 Room A164 Wall Sheetrock White 0.00

60-35 Room A164 Door Frame Metal Tan 0.00

60-36 Room A166 Hand Rail Metal Orange 0.04

60-37 A-Wing Mechanical

Room

Pipe Metal Red 0.73

60-38 A-Wing Mechanical

Room

Pipe Metal Blue 0.00

60-39 Hallway at Room A152

Wall Sheetrock Gray 0.00

60-40 Hallway at Room A152

Wall Sheetrock White 0.00

60-41 Mechanical Room 114

Wall Sheetrock White 0.00

60-42 Mechanical Room 114

Sprinkler Pipe Metal Blue 0.00

60-43 Mechanical Room 114

Sprinkler Pipe Metal Red 0.00

60-44 Room 115 Wall Wood Gray 0.00

60-45 Room 115 Door Frame Metal Tan 0.00

M ICRO AIR OF TEXAS, INC. VA North Texas Health Care System - Lead-based Paint Survey Building 60 - Dallas, Texas 6

SUMMARY TABLE

BUILDING 60

Sample ID# Room Equivalent

Component Substrate Color XRF Result (mg/cm )2

60-46 Hallway at Room 118

Fire Extinguisher

Cabinet

Metal Cream 0.00

60-47 Room 120 Wall Sheetrock Brown 0.00

60-48 Hallway at Room B109

Wall Sheetrock Light Blue 0.00

60-49 Room B109 Door Frame Metal Tan 0.00

60-50 Room B142 Wall Sheetrock Cream 0.00

60-51 Hallway at Room B155

Wall Sheetrock Light Blue 0.00

60-52 Room B155 Door Frame Metal Tan 0.00

60-53 Room B119 Wall Sheetrock Green 0.00

60-54 Room B119 Wall Sheetrock Light Green 0.00

60-55 Room B119 Locker Metal Cream 0.00

60-56 Room B119 Wall Ceramic Tile on Sheetrock

Orange 0.00

60-57 Hallway at Room B131

Door Frame Metal Tan 0.00

60-58 Room B150 Wall Sheetrock Light Blue 0.00

60-59 Room B164 Wall Sheetrock Cream 0.00

60-60 Room B166 Wall Sheetrock Cream 0.00

M ICRO AIR OF TEXAS, INC. VA North Texas Health Care System - Lead-based Paint Survey Building 60 - Dallas, Texas 7

SUMMARY TABLE

BUILDING 60

Sample ID# Room Equivalent

Component Substrate Color XRF Result (mg/cm )2

60-61 Room B166 Wall Sheetrock Cream 0.00

60-62 Room 124 Wall Sheetrock Cream 0.00

60-63 Room 124 Wall Ceramic Tile on Sheetrock

Tan >1.00

60-64 Room 124 Wall Sheetrock Blue 0.00

60-65 Hallway at Room 138

Wall Sheetrock Cream 0.00

60-66 Room 138 Door Frame Metal Cream 0.00

60-67 Mechanical Room 133

Wall Sheetrock Cream 0.00

60-68 Mechanical Room 133

HVAC Duct Metal Cream 0.00

60-69 Room 121 Wall Sheetrock Cream 0.00

60-70 Room 121 Door Metal Cream 0.00

60-71 Room 121 Door Frame Metal Cream 0.00

60-72 Room 121 Wall Vinyl on Sheetrock

Blue 0.00

60-73 Entrance to C-Wing

Door Frame Metal Black 0.00

60-74 Room C101 Wall Sheetrock Tan 0.00

60-75 Room C102 Door Wood Cream 0.00

M ICRO AIR OF TEXAS, INC. VA North Texas Health Care System - Lead-based Paint Survey Building 60 - Dallas, Texas 8

SUMMARY TABLE

BUILDING 60

Sample ID# Room Equivalent

Component Substrate Color XRF Result (mg/cm )2

60-76 Room C102 Door Frame Metal Cream 0.00

60-77 Room C136 Door Frame Wood Tan 0.00

60-78 Room C136 Wall Sheetrock Cream 0.00

60-79 Room C160 Wall Sheetrock Cream 0.00

60-80 Hallway at Room C120

Fire Extinguisher

Box

Metal Cream 0.00

60-81 Room C120 Wall Sheetrock Cream 0.00

60-82 Room C120A Wall Sheetrock Cream 0.00

60-83 Room C165 Wall Sheetrock Cream 0.00

60-84 Room C105 Wall Sheetrock Cream 0.00

M ICRO AIR OF TEXAS, INC. VA North Texas Health Care System - Lead-based Paint Survey Building 60 - Dallas, Texas 9

C. CONCLUSIONS AND RECOMMENDATIONS

According to the HUD Lead-Based Paint Interim Guidelines for Hazard Identification and 40 CFR Part 744, Environmental Protection Agency Lead-based Paint in Target Housing and Child-Occupied Facilities, the definition of lead-based paint is paint which has a lead content of 5000 mg/kg (0.5% by weight) or greater, or 1.0 milligrams per square centimeter (mg/cm ) surface area. The Texas Environmental Lead Reduction2

Rules (TELRR) define lead-based paint as “paint or surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter or more than 0.5% by weight”, and this applies to Target Housing and Child-Occupied Facilities. Both the HUD Guidelines and the TELRR define “Target Housing” as “any housing constructed prior to 1978, except housing for the elderly or persons with disabilities (unless any child who is six years of age or younger resides or is expected to reside in such housing) or any zero-bedroom dwelling”. Both regulations define a “Child-Occupied Facility” as “a building or part of a building constructed before 1978, including but not limited to, a day-care center, preschool, or kindergarten classroom, that is visited regularly by the same child, six years of age or younger, at least two days in any calendar week if the visits are for at least three hours each day and 60 hours each year”.

At this time, the above referenced HUD and TELRR regulations do not apply to the building inspected in this survey because it does not meet either definition of “Target Housing” or “Child-Occupied Facility”.

There are currently no federal or state regulations requiring abatement of lead-based paint in buildings which are not considered to be Target Housing or Child-Occupied Facilities; however, state and federal disposal requirements apply to all demolished structures that include lead-based paint components. If any structural components of the building that have lead-based paint are going to be demolished and disposed of, it is recommended that the paint from these substrates be further tested prior to demolition and disposal for leachable lead (Toxicity Characteristic Leaching Procedure (TCLP) analysis), which will determine whether any hazardous waste disposal requirements apply. This should be performed by the contractor that is responsible for demolition and disposal of demolished building materials.

It should be noted that the OSHA Construction Industry Standard, 29 CFR, 1926.62 does apply to any employee involved with demolition / renovation work that might occur in the above building. The Construction Industry Standard regulates occupational exposures to airborne lead, which includes demolition or salvage of structures where lead or materials containing lead are present, and any amount of lead present in painted surfaces, including those which fall below the above definition of lead-based paint, could result in regulated occupational exposures and should therefore be monitored according to OSHA 1926.62 whenever they are disturbed in a manner that could result in exposure to airborne lead particulates. It is the responsibility of the employer to comply with 29 CFR, 1926.62 to protect the safety and health of his / her employees involved in the demolition or renovation of the above structure. According to OSHA, the Permissible Exposure Limit (PEL) for lead is 50 micrograms per cubic meter (µg/m ) (8 hour Time Weighted3

Average (TWA)) with an action limit of 30 µg/m 8 hour TWA.3

VAMC employees who are not subject to 29 CFR, 1926.62 (non-construction / demolition related work) are subject to the OSHA General Industry Standard, 29 CFR, 1910.1025. This standard was promulgated by OSHA to protect workers who could potentially be exposed to inorganic lead, including metallic lead, all inorganic compounds, and organic lead soaps. Again, the occupational exposure to inorganic lead is to be limited to 50 micrograms per cubic meter (µg/m ) (8 hour Time Weighted Average).3

Appendix I XRF Sample Location Drawings