Lead Based Paint Inspection Report Building 2 Final.pdf

November 3, 2016

Mr. Darron Moore Department of Veterans Affairs Contracts 00504 Engineering Services – Big Springs, Texas Location 7201 I-40 West Suite 100 Amarillo TX 79106 Darron.Moore@va.gov

RE: Lead-Based Paint Inspection Veterans Affairs (VA) Medical Center 300 West Veterans Boulevard, Big Spring, Texas 79720

Building 2

Dear Mr. Moore:

HGS Engineering Inc. (HGS) was retained by Department of Veterans Affairs Contracts 00504 Engineering Services – Big Springs, Texas Location to perform a lead-based paint (LBP) inspection at Building 2. This inspection included a visual observation of suspect coatings for LBP, and use of a handheld RMD LPA-1 X-ray Fluorescent (XRF) Spectrum Analyzer on each testing combination (component/substrate/color) within the accessible interior and exterior of Building 2 to confirm areas of LBP.

Executive Summary

The lead-based paint survey was conducted on September 14, 2016, by Ms. Trina Mullen (Lead Risk Assessor License Number 2070182) and Mr. Lonnie Lyro, both representing HGS Engineering Inc. (HGS). A portable XRF Analyzer was used to measure lead content in interior and exterior painted surfaces. The inspection was performed in general accordance with the Housing and Urban Development (HUD) and the Occupational Safety & Health Administration’s (OSHA’s) Lead in Construction. The XRF is a direct read instrument and does not require laboratory analysis. Lead-based paint as defined by HUD, EPA and the Texas Department of State Health Services (DSHS) are paints with a lead concentration of greater than 1.0 milligrams per square centimeter (mg/cm²), 5,000 parts per million (ppm) or 0.5% lead by weight. OSHA’s “Lead in Construction Standard” addresses any concentration of lead in paint as Lead Containing Paint (LCP). Results indicate that the following coatings are LBP:

Metal stair railing (orange and white) at Stair Tower 38 Metal handrail (red) within Water Treatment Plant 35 Metal exterior door frame (gray) at the front of the building Metal exterior door frames (tan) at the front of the building Metal garage door frames (tan) at the front of the building Metal brick protection bumpers (tan) at the front of the building Metal gutters (tan) at the back of the building

Sampling and Analytical Procedures

HGS’s lead-based paint survey included testing of painted, varnished, or stained surfaces. HGS utilized the PROTEC Instruments RMD LPA-1 XRF Spectrum Analyzer to confirm areas of lead-based paint in accordance with EPA and OSHA. EPA establishes that lead-based paint is paint that contains more than

1.0 mg/cm2, 5,000 ppm or 0.5% lead by weight. For OSHA compliance purposes, OSHA’s “Lead in Construction Standard” (29 CRF 1926.62) addresses any concentration of lead in paint.

HGS performed a total of eighty-four (84) readings utilizing the RMD LPA-1 XRF.

The RMD LPA-1 XRF paint analyzer automatically calibrates for different substrates. Therefore, this paint analyzer does not report “inconclusive” test results for some substrates, such as metal surfaces. Paint chip samples are not required. Test results from the XRF Analyzer are tracked in the field by the lead inspector and later tabulated in table format for inclusion in this report.

The RMD LPA-1 XRF Analyzer results are either positive or negative with a numerical value for the lead concentration. The results are in milligrams per square centimeter (mg/cm2).

Calibrations were performed prior to and after testing in accordance with Performance Characteristics Sheets (PCS)

FINDINGS

A total of eighty-four (84) measurements were taken utilizing the RMD LPA-1 XRF.

The Table below contains the components, which tested positive (greater than 1.0 mg/cm2) for lead-based paint, utilizing the XRF:

Table 1 Veterans Affairs (VA) Medical Center, Building 2 Summary of Lead-Based Paint

Sample Location Component Substrate Color Lead %

2-05 Stair Tower 38 Stair Rail Metal Orange 3.5

2-06 Stair Tower 38 Stair Rail Metal White 1.5

2-31 Water Treatment Plant 35 Hand Rail Metal Red 5.2

2-49 Exterior Front Door Frame Metal Gray 1.1

2-51 Exterior Front Door Frame Metal Tan 1.5

2-52 Exterior Front Bumpers Metal Tan >9.9

2-53 Exterior Front Garage Door

Frame Metal Tan >9.9

2-55 Exterior Front Door Frame Metal Tan 1.6

2-56 Exterior Front Bumpers Metal Tan >9.9

2-57 Exterior Front Garage Door

Frame Metal Tan >9.9

2-84 Exterior Back Gutters Metal Tan >9.9

CONCLUSIONS

Of the eighty-four (84) measurements taken utilizing the RMD LPA-1 XRF, eleven (11) LBPs or coatings were identified. Table 1 is a listing of the identified LBPs within Building 2. A complete listing of those paints and coatings tested within Building 2 is included as an attachment to this report. All paints with a lead content of greater than 0.0 mg/cm2 are considered lead-containing paints (LCP) by OSHA. Locations of LBP are depicted on the drawings included as an attachment to this report.

Lead is a hazardous substance. Its condition, handling and disposal are regulated by Federal, State, and local agencies. Lead-containing materials, LBP and LCP generally do not pose a health risk unless the material is disturbed or sufficiently deteriorated to produce dust, which may become airborne and inhaled or ingested.

The EPA, HUD, and Texas DSHS Regulations in regard to LBP apply directly to target housing and child occupied facilities. The definition of target housing is any housing constructed prior to 1978, except housing for the elderly or persons with disabilities (unless any child who is less than 6 years of age resides or is expected to reside in such housing) or any zero-bedroom dwelling. The definition of Child Occupied Facility is a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years of age, on at least two different days within any week, provided that each day's visit lasts at least 3 hours and the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours. Child-occupied facilities may include, but are not limited to, day care centers, preschools and kindergarten classrooms.

The VA Facility is not considered target housing or a child-occupied facility and is therefore not subject to the EPA, HUD, or Texas DSHS Regulations. OSHA considers any amount of lead within paint or coatings to be Lead-Containing Paint (LCP) and is subject to OSHA Lead Standard 1926.62 and state regulations for the disposal of the lead paint.

RECOMMENDATIONS

If the LCP is going to be affected by future renovations, then all activity associated with the disturbance, handling and disposal of any LCP must comply with the OSHA Lead Standard 1926.62 and state regulations for the disposal of the lead paint.

OSHA requires the contractor to inform its employees of potential lead hazards, based upon the work being performed. The purpose of OSHA’s lead construction standard is to reduce the exposure to lead for all construction workers. HGS recommends contractors be informed of the presence of LCP within the facility prior to disturbance. OSHA’s standard includes an 8-hour time weighted average (TWA) of 50 micrograms of lead per cubic meter of air (mg/m3) and an action level (regardless of respirator use) of 30 mg/m3.

Although the standard emphasizes exposure assessment for individual job tasks, varying levels of worker protection are required of the contractor for certain tasks, including, but not limited to the following activities involving lead-based and lead-containing paint.

Manual demolition of structures, manual scraping, manual sanding, and use of heat guns where lead-containing coatings or paints are present;

Abrasive blasting enclosure movement and removal;

Power tool cleaning;

Lead burning;

Using lead-containing mortar or spray painting with lead-containing paint;

Abrasive blasting, rivet busting, or welding, cutting, or burning on any structure where lead-containing coatings or paint are present;

Cleanup activities where dry expendable abrasives are used; and

Any other task the employer believes may cause exposures in excess of the permissible exposure limit (PEL).

The Owner should prohibit the use of torch cutting or heat processes to remove the paint from all surfaces that are within these limits. If abrasive blasting (i.e. sandblasting, etc.) is to be performed, HGS recommends that the appropriate methods of containing the work area and personal protective equipment be utilized (i.e. respirator protection, eye protection, coveralls, etc.).

LIMITATIONS

Our professional services have been performed, our findings obtained, and our recommendations prepared in accordance with principles and practices in the fields of environmental science and engineering. The results, findings, conclusions, and recommendations expressed in the report are based only on conditions that were noted during the noted dates of fieldwork. This warranty is in lieu of all other warranties either expressed or implied. This company is not responsible for the independent conclusions, opinions, or recommendations made by others based on the results and designs presented in this report.

The passage of time may result in a change in the environmental characteristics at this site and surrounding properties. This report does not warrant against future operations or conditions, nor does it warrant operations or conditions present of a type or at a location not investigated.

Reasonable effort is made by HGS personnel to locate and sample materials representative of the site structures. However, for any facility, the existence of unique or concealed materials or debris not observed by HGS is a possibility. HGS does not warrant, guarantee or profess to have the ability to locate or identify all concealed hazardous materials at the facility. This report is intended for the sole use of Veterans Affairs (VA). This report is not intended to be utilized as a construction and/or bidding document, nor is this document designed to be used as a remediation or abatement specification. The scope of services performed in execution of this evaluation may not be appropriate to satisfy the needs of other users, and use or re-use of this document or the findings, conclusions, or recommendations is at the risk of said user.

Any conditions or materials that could not be visually identified on the surface were not inspected and may differ from those conditions or materials noted.

CLOSING

HGS appreciates the opportunity to be of service to the Department of Veterans Affairs on this project and looks forward to working with you on future assignments. In the meantime, if you have questions or comments regarding the information in this report or if we can be of further assistance, please do not hesitate to contact the undersigned in the HGS Round Rock, Texas office at (512) 366-6806.

Respectfully submitted, HGS Engineering, Inc.

Trina Mullen Industrial Hygiene Department Manager Lead Risk Assessor License No. 2070622 Direct Line: +1 512 336 6806 Email: trina.mullen@atcassociates.com

Tim Thompson HGS Engineering Inc.

1121 Noble Street Anniston, AL 36201 Email: tim@hgsengineeringinc.com

Attachments: Lead-Based Paint XRF Readings, Big Spring VA, Building 2

Licenses/Certifications Drawings

LEAD BASED PAINT XRF READINGS, BIG SPRING VA, BUILDING 2

Lead‐Based Paint XRF Readings

Big Spring, VA, Building 2

Sample Location Component Substrate Color Lead %

2‐01 Stair Tower 38 Door ‐ Exterior Metal Tan 0.1

2‐02 Stair Tower 38 Door Frame ‐ Exterior Metal Tan 0.2

2‐03 Stair Tower 38 Wall D Brick White 0.3

2‐04 Stair Tower 38 Stairs Concrete Green 0.1

2‐05 Stair Tower 38 Stair Rail Metal Orange 3.5

2‐06 Stair Tower 38 Stair Rail Metal White 1.5

2‐07 Stair Tower 38 Wall A CMU Green 0.2

2‐08 Stair Tower 38 Wall B CMU Dark Green 0.0

2‐09 Water Test Room 37B Door Metal Tan 0.2

2‐10 Water Test Room 37B Door Frame Metal Tan 0.2

2‐11 Pump Room 37 Wall A CMU White 0.2

2‐12 Pump Room 37 Wall B CMU White 0.1

2‐13 Pump Room 37 Wall C CMU White 0.1

2‐14 Pump Room 37 Wall D CMU White 0.2

2‐15 Pump Room 37 Window Sill Metal Tan 0.1

2‐16 Pump Room 37 Window Sash Metal Tan 0.0

2‐17 Pump Room 37 Door Metal Tan 0.0

2‐18 Pump Room 37 Door Frame Metal Light Green 0.7

2‐19 Chiller Plant 36 Wall A CMU Tan 0.2

2‐20 Chiller Plant 36 Wall B CMU Tan 0.2

2‐21 Chiller Plant 36 Wall C CMU Tan 0.1

2‐22 Chiller Plant 36 Wall D CMU Tan 0.1

2‐23 Chiller Plant 36 Chiller Foam Green 0.1

2‐24 Chiller Plant 36 Floor Concrete Maroon 0.3

2‐25 Chiller Plant 36 Door ‐ Exterior Metal Tan 0.4

2‐26 Chiller Plant 36 Door Frame ‐ Exterior Metal Tan 0.1

2‐27 Water Treatment Plant 35 Wall A CMU Tan 0.2

2‐28 Water Treatment Plant 35 Wall C CMU Tan 0.3

2‐29 Water Treatment Plant 35 Window Sill Metal Tan 0.1

2‐30 Water Treatment Plant 35 Window Sash Metal Tan 0.1

2‐31 Water Treatment Plant 35 Hand Rail Metal Red 5.2

2‐32 Boiler Plant 33 Wall A CMU White 0.3

2‐33 Boiler Plant 33 Wall B CMU White 0.1

2‐34 Boiler Plant 33 Wall C CMU White 0.2

2‐35 Boiler Plant 33 Wall D CMU White 0.2

2‐36 Boiler Plant 33 Boiler Curb Concrete Red 0.2

2‐37 Boiler Plant 33 Boiler Curb Metal Green 0.2

2‐38 Boiler Plant 33 Rail Metal Red 0.2

2‐39 Boiler Plant 33 Door ‐ Exterior Metal Tan 0.1

2‐40 Boiler Plant 33 Door Frame ‐ Exterior Metal Tan 0.1

2‐41 Office 31 Wall A Drywall White 0.1

2‐42 Office 31 Wall B Drywall White 0.2

2‐43 Office 31 Wall C Drywall White 0.2

2‐44 Office 31 Wall D Drywall White 0.1

2‐45 Office 31 Door Metal Tan 0.1

Lead‐Based Paint XRF Readings

Big Spring, VA, Building 2

Sample Location Component Substrate Color Lead %

2‐46 Office 31 Door Frame Metal Tan 0.1

2‐47 Office 31 Window Metal Brown 0.2

2‐48 Exterior Front Door Metal Gray 0.2

2‐49 Exterior Front Door Frame Metal Gray 1.1

2‐50 Exterior Front Door Metal Tan 0.3

2‐51 Exterior Front Door Frame Metal Tan 1.5

2‐52 Exterior Front Bumpers Metal Tan >9.9

2‐53 Exterior Front Garage Door Frame Metal Tan >9.9

2‐54 Exterior Front Door Metal Tan 0.2

2‐55 Exterior Front Door Frame Metal Tan 1.6

2‐56 Exterior Front Bumpers Metal Tan >9.9

2‐57 Exterior Front Garage Door Frame Metal Tan >9.9

2‐58 Exterior Front Window Apron Concrete Tan 0.2

2‐59 Exterior Front Curb Concrete Yellow 0.0

2‐60 Exterior Front Curb Concrete Red 0.3

2‐61 Exterior Front Window Apron Concrete Tan 0.2

2‐62 Warehouse Wall A CMU White 0.1

2‐63 Warehouse Wall B CMU White 0.0

2‐64 Warehouse Wall C CMU White 0.1

2‐65 Warehouse Wall D CMU White 0.2

2‐66 Warehouse Restroom Wall Ceramic Tile Light Blue 0.1

2‐67 Warehouse Restroom Floor Ceramic Tile Light Blue 0.1

2‐68 Warehouse Restroom Door Metal Black 0.1

2‐69 Warehouse Restroom Door Frame Metal Black 0.1

2‐70 Warehouse Ladder Metal Black 0.1

2‐71 Warehouse Ramp Metal Yellow 0.2

2‐72 Warehouse Wall CMU White 0.1

2‐73 Warehouse Floor Concrete Black 0.3

2‐74 Warehouse Floor Metal Gray 0.5

2‐75 Warehouse Office Wall A Drywall White 0.1

2‐76 Warehouse Office Wall B Drywall White 0.1

2‐77 Warehouse Office Wall C Drywall White 0.2

2‐78 Warehouse Office Wall D Drywall White 0.2

2‐79 Exterior Back Double Door Metal Pink 0.0

2‐80 Exterior Back Door Frame Metal Pink 0.0

2‐81 Exterior Back Door Jamb Metal Pink 0.0

2‐82 Exterior Back Equipment Metal Tan 0.0

2‐83 Exterior Back Pipes Metal Green 0.2

2‐84 Exterior Back Gutter Metal Tan >9.9

LICENSES/CERTIFICATIONS

DRAWINGS