Attachment 19 - Lead Based Paint Report.pdf

LEAD-BASED PAINT

INSPECTION AND ASSESSMENT REPORT

BUILDINGS 1, 2, 3, 4, 5, 6, 8, 12, 13, 14, 17, 18, 25, 27, 28, 39, 40, 41, 46

VA MEDICAL CENTER

3701 PELHAM LOOP ROAD EAST

TUSCALOOSA, AL 35404

Prepared For:

DEPARTMENT OF VETERAN AFFAIRS

VAMC

3701 PELHAM LOOP ROAD EAST

TUSCALOOSA, AL 35404

ATTN: MARK VERSACE

Conducted and Prepared by:

Safety Environmental Laboratories and Consulting, Inc.

989 Yeager Parkway Pelham, AL 35124

SELC Project # 2014-1107

Report Issued: August 29, 2014

Inspected By: Reported By: Reviewed By:

Nathan Pee Elizabeth Hyde N. Glenn Ray, REM, Environmental Technician/ Project Manager/ REPA Lead Inspector Environmental Specialist Technical Director AL Safe State LBP Inspector/ AL Safe State LBP Inspector/ AL Safe State LBP Assessor # LRP0712528583 Assessor # LRA0612542250 Inspector/ Assessor

#LRA0712203952

TABLE OF CONTENTS:

1.0 PURPOSE AND SCOPE OF SERVICES 1

2.0 REGULATIONS, STANDARDS & GUIDELINES 1

3.0 PREVOUS INSPECTION REPORTS 3

4.0 PROJECT DESCRIPTION 3

5.0 INSPECTION METHODOLOGY 3

6.0 LEAD BASED PAINT TESTING AND RESULTS 4

6.1 Paints Containing >1.0 mg/cm² Lead 5

6.2 Paints Containing <1.0 mg/cm² Lead 15

7.0 CONCLUSIONS AND RECOMMENDATIONS 18

8.0 ASSUMPTIONS AND LIMITATIONS 19

APPENDICES:

Appendix A Building 1 Inspection Documentation A-1 – XRF Testing Data Sheets A-2 – XRF Testing Location Plans A-3 – Photographic Documentation

Please note that format “X”-1 through “X”-3 will be continued for each building in the appendices below, with the exception of Appendix T and Appendix U.

Appendix B Building 2 Inspection Documentation Appendix C Building 3 Inspection Documentation Appendix D Building 4 Inspection Documentation Appendix E Building 5 Inspection Documentation Appendix F Building 6 Inspection Documentation Appendix G Building 8 Inspection Documentation Appendix H Building 12 Inspection Documentation Appendix I Building 13 Inspection Documentation Appendix J Building 14 Inspection Documentation Appendix K Building 17 Inspection Documentation Appendix L Building 18 Inspection Documentation Appendix M Building 25 Inspection Documentation Appendix N Building 27 Inspection Documentation Appendix O Building 28 Inspection Documentation Appendix P Building 39 Inspection Documentation Appendix Q Building 40 Inspection Documentation Appendix R Building 41 Inspection Documentation Appendix S Building 46 Inspection Documentation Appendix T 2009/2010 SELC Lead Based Paint Inspection Report (partial copy) Appendix U Inspector and Laboratory Certifications

Lead Based Paint Inspection and Assessment Report August 29, 2014 Buildings 1, 2, 3, 4, 5, 6, 8, 12, 13, 14, 17, 18, 25, 27, 28, 39, 40, 41, 46 VAMC Tuscaloosa – Tuscaloosa, Alabama

SELC Project No.: 2014-1107 Page 1

1.0 PURPOSE AND SCOPE OF SERVICES

The purpose of this “Lead Based Paint Inspection and Assessment" was to determine the potential lead content in paints/coatings applied to primary building components of 19 buildings (Buildings 1, 2, 3, 4, 5, 6, 8, 12, 13, 14, 17, 18, 25, 27, 28, 38, 40, 41, 46) at the VAMC Tuscaloosa campus located at 3701 Pelham Loop Road East in Tuscaloosa, Alabama. These buildings do not meet the United States Environmental Protection Agency (USEPA) definition of “Target Housing” or “Child Occupied Facility”. LBP inspection data for the buildings, or portions of buildings, that do meet that EPA housing criteria are reported separately. Generally, SELC’s goal was to provide information at a level of detail sufficient for basic hazard communication and initial project planning purposes and to provide information for prospective remediation contractors (i.e. bidders) to determine the appropriate level of worker protection that will be needed for compliance with the OSHA Lead in Construction Standard 29 CFR Part 1926.62. A summary of the scope of services provided by Safety Environmental Laboratories and Consulting, Inc. (SELC) is presented below:

A. Conduct a review of historical lead-based paint (LBP) reports, specifically the 2009/2010

LBP Inspection conducted by SELC at the above referenced, subject structures.

B. Conduct a visual inspection of the selected interior surfaces for the presence of potential lead based paints (LBP) (primer, paint, varnish, stain).

C. Collect and record data about the location and condition of each homogeneous coating.

Inspect for damage or deteriorated paint.

D. The paint inspection and testing procedures utilized will generally follow guidance outlined in the HUD “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing”, July 2012 version of Chapter 7, except that the testing locations and frequency for testing will be adjusted to meet the needs of facilities that are not considered to be “Target Housing” or “Child Occupied” facilities, as defined by USEPA and HUD.

E. Conduct representative testing of each homogeneous coating on-site by a portable X-ray Fluorescence (XRF) analyzer, in accordance with manufacturer's recommendations.

F. Identify management and/or mitigation options for areas of damaged or deteriorated LBP. Management and/or mitigation options are generally discussed in the text of this report. For these areas, propose associated abatement costs.

G. Prepare a report (contained herein) which: describes the inspection process, presents all testing results, presents lead-based paint (LBP) descriptions, and generally identifies LBP locations in accordance with OSHA "Communication of Hazards" requirements.

Please note that this report excludes the daycare portion of Building 40. A LBP Inspection of the daycare portion of Building 40 has been submitted under separate cover.

2.0 REGULATIONS, STANDARDS & GUIDELINES

This section of the report outlines basic provisions of various regulations, standards and guidelines related to LBP, as well as lead-containing paints (LCP), associated with construction and demolition operations.

The United States Occupational Safety & Health Administration (OSHA) regulates occupational exposure to lead, in the construction industry through the Lead Exposure in Construction Standard 29 CFR 1926.62. This standard applies to employers of persons potentially exposed to lead from building/structure renovation, repair, construction, and demolition operations.

Employers shall assure that no employee is exposed to lead concentrations at or above the permissible exposure limit (PEL). Where the lead exposure resultant from a given work activity

SELC Project No.: 2014-1107 Page 2 is not known the use of personnel protective equipment and engineered controls coupled with exposure monitoring are generally required at least until the exposure level is established.

However, the OSHA Standard does not indicate what minimum concentration of lead in paint or material will likely constitute potential exposures in excess of the PEL. In response to questions concerning this issue OSHA has stated that any detectable concentration of lead may trigger certain provisions of 29 CFR 1926.62, depending upon factors such as the paint condition and the nature of the work impacting the paint. In consideration of the OSHA Standard this inspection addressed lead content in paints down to 0.01 milligrams per square centimeter (mg/cm²) as well as paints with lead concentrations at or greater than 1.0 mg/cm², which is the threshold for coatings commonly referred to as lead-based paint (LBP) that is regulated by the EPA and HUD for certain activities in Target Housing and Child Occupied Facilities.

The federal standards specifically applicable to generators and transporters of hazardous waste are contained in 40 CFR Parts 262 and 263 respectively. Part 40 CFR 262.11 states that the person who generates a solid waste must determine if that waste is a hazardous waste. The definition of hazardous waste and the requirements for hazardous waste determination are contained in 40 CFR 261. The generator of waste on a construction / demolition project may be listed as either, the owner/operator or the contractor; however, both parties share responsibility for regulatory compliance. The waste stream for a renovation or demolition project would presumably consist of a mixture of painted and unpainted building material debris, as is typically generated by renovation or demolition operations. It is common for composite building renovation or demolition waste streams to pass the TCLP test for lead even though various building components are coated with LBP or LCP, in part due to the large volume of non-lead containing materials that comprise buildings. In order to obtain that result, generally the TCLP test method would be conducted on samples derived from painted building components and non-painted components that have been mixed/composited proportional to the actual composition of the structure to be demolished/renovated; rather than a TCLP test of the paints only. However, knowledge of the potential non-hazardous outcome of that type of testing process, in no way relieves the responsible parties of their obligations to actually conduct the necessary waste characterization processes to ensure regulatory compliance.

The only hazardous waste test method allowed by the EPA is the TCLP Method; however, in some cases the EPA will allow other information, in lieu of TCLP analysis, to document non-hazardous status. For example, information derived from “knowledge of process” may be acceptable for certain types of waste streams. If that approach was applied to renovation or demolition debris, one would likely have to know the concentration (in parts per million - ppm) of lead in the paints, and would need to provide valid calculations demonstrating how the relatively small amount of lead in the paints versus the large volume of non-lead containing waste materials could not statistically produce a failing TCLP test. One factor of importance to understand about this process is that the TCLP method involves a 20:1 dilution, such that if the total lead content in the waste stream is originally less than 100 ppm, then the final TCLP leachable lead content cannot be more than the lead hazardous waste threshold of 5 ppm.

Disposal of “architectural” components from housing structures has recently been exempted, by the USEPA, from hazardous material testing, with respect to lead. However, that exemption was basically written to reduce the burden on homeowners performing renovation and LBP abatement work, and as such does not apply to government facilities.

Another potentially important factor, relevant to waste characterization and management, is that metal components coated with LBP/LCP can be relinquished to a properly licensed facility as scrap metal which may not be subject to hazardous waste regulation depending upon the nature of that facility’s operations.

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3.0 PREVIOUS INSPECTION REPORT

In 2009/2010, SELC performed a LBP Inspection at 22 buildings located on the VAMC Tuscaloosa campus. These 22 buildings included the subject structures that were inspected during this 2014 inspection, as well as Buildings 33, 61, and 63, which were not included in the scope of work of this 2014 inspection.

LBP was identified on multiple building components in the 19 subject structures that were inspected by SELC in 2014. Generally, the LBP identified in 2014 is consistent with that identified in 2009/2010. A listing of LBP identified by SELC during the 2014 inspection in each subject structure is provided in Section 6.0. Please note that 2009/2010 LBP testing data was also incorporated into the data presented in Section 6.0. A copy of the 2009/2010 SELC report, excluding drawings/site plans and certificates, is included in this report as Appendix T.

4.0 PROJECT DESCRIPTION

This section of the report contains a basic description of the 19 subject structures on the VAMC Tuscaloosa, AL campus, and is presented in part, to demonstrate that SELC has a good understanding about the construction history of the subject facility. The information provided in this section also generally references any known, large-scale improvement and/or renovation or LBP abatement projects that have reportedly occurred at the 19 subject structures.

SELC understands the VAMC Tuscaloosa campus was initially constructed in the early 1930s.

Buildings 1, 2, 3, 4, 5, 6, 8, 12, 13, 14, 17, 18, 25, 27, and 28 were reportedly constructed between 1931 and 1936. Buildings 39, 40, and 41 were reportedly constructed in 1944.

Building 46 was reportedly constructed in 1963.

Please note that most of the subject structures are unpainted, brick-faced buildings that are supported by wood, concrete, and metal structural supports. Most buildings have pitched, slate roofs on the original structure, with flat roofs on additions. Buildings 1, 2, 3, 4, 5, 39, 40, and 46 reportedly have new slate roofs that have been replaced within the last several years.

Generally, interior wall finishes in the 19 subject structures include, but are not limited to, painted plaster, gypsum board, concrete masonry units, and concrete. Original ceilings are painted plaster; however most plaster ceilings are covered by lay-in ceiling tile systems.

Generally, flooring is finished with carpet, tiles, laminate products, or hardwood.

Windows throughout the buildings were originally painted wood or metal. SELC has previously identified these as being coated with LBP. However, according to information provided by the VAMC, windows in Buildings 1, 2, and 3 have been replace, although original framing remains in place. The exterior of original window frames were reportedly coated with an encapsulant product and covered with factory coated aluminum. Other buildings at which original window sashes have been replaced and/or exterior window framing has been covered with aluminum include Buildings 5, 8 (except for attic windows), 39, and 40.

5.0 INSPECTION METHODOLOGY

The paint inspections were performed at the 19 buildings between July 2, 2014 and August 5, 2014 by Nathan Pee, a University of Alabama Safe State Environmental Program accredited lead inspector. Mr. Pee is an employee of SELC, an Alabama Department of Public Health

SELC Project No.: 2014-1107 Page 4 accredited lead firm. All work was performed in accordance with all applicable EPA, HUD, and Alabama regulations. The inspection procedures generally conformed to EPA Regulation 40 CFR 745 utilizing the methodology referenced in July 2012 HUD Guidelines Chapter 7.

However, specific testing locations and frequencies were adjusted to meet the needs of facilities that do not meet the USEPA definition of “Target Housing” or “Child Occupied Facility”. Mr. Pee conducted paint testing using a Niton XRF portable paint analyzer in accordance with the manufacturer’s recommended procedures. SELC is licensed by the Alabama Department of Public Health (ADPH) to own and operate a XRF which contains a radioactive material. See Appendix U for inspector and firm certifications.

As previously referenced, the LBP inspection was generally conducted following guidelines published by the EPA and HUD for “Target Housing” and other facilities, constructed prior to 1978, that are occupied by children, age six and under, for a certain amount of time as defined for “Child Occupied Facilities.” However, given that the buildings are not and will not be occupied by children there is not a need to specifically identify lead levels on each and every wall in each and every room. Rather the goal is to identify the lead ranges and paint conditions.

SELC’s primary deviation from the protocols of the HUD Guidelines was a reduction in the quantity of tests per each type of component at each building. However, this inspection addressed all readily accessible interior and exterior painted building materials associated with the 19 subject structures.

HUD and the US EPA guidelines specify a positive determination for LBP when the lead content in a coating is equal to or greater than 1.0 milligrams of lead per square centimeter of painted surface (mg/cm2) when measured by X-Ray Fluorescence (XRF).

A properly trained lead paint XRF technician employed by SELC used a Niton XLp-700-303, Serial # 21385, to measure the lead content of surface coatings on representative homogenous building components. A homogeneous component is a building material that is uniform in function, composition, texture, age, and generally appears consistent at various locations in/on the building. It should be noted that surface color is not a good indicator of paint homogeneity, because underlying coatings may vary from area to area, even when the surface color is the same. Although surface paint color is recorded it should not be used as the sole source of tracking LBP locations because future painting can change the surface color. The type of component (e.g. door frame) and the substrate material (e.g. metal) coupled with the general area and construction/renovation dates are more important factors for identifying and tracking homogeneous LBP.

6.0 LEAD BASED PAINT TESTING AND RESULTS

Generally, when conducting LBP inspections, SELC assumes that all coatings (primers, paints, stains, varnishes) that were applied / installed prior to 1978 may potentially contain detectable concentrations of lead. The significance of the 1978 date is discussed below. However, installation / application dates were not utilized to exclude paints from testing during this project.

In the early 1970s, common household/commercial paints contained a maximum lead content of 0.5% by weight. The Consumer Product Safety Commission (CPSC), in 1978, established a maximum lead content of 0.06% by weight in dry film of newly applied paint. Again in 2011, the CPSC lowered the allowable lead level in paints, manufactured for normal consumer usage, to 0.009%. To date the USEPA and HUD have developed the most comprehensive lead hazard identification and elimination programs which set the threshold lead level in paints at 0.5% by weight or 1.0 mg/cm² by XRF. However, the EPA and HUD standards apply only to housing and

SELC Project No.: 2014-1107 Page 5 other child (age six and under) occupied facilities that were constructed prior to 1978.

OSHA regulates occupational exposure to lead, but the allowable lead content in materials is not specified by that agency. Directives from OSHA indicate that any detectable concentration of lead may trigger certain provisions of 29 CFR 1926.62 depending upon the nature of the construction activities. Employers are required by 29 CFR 1926.62 to assume that where lead (any detectable concentration) is involved in workplace activities, the employees exposure will be above the action level, and shall protect them until an exposure assessment proves otherwise, unless they have recent (within 12 months) data proving otherwise, for the same work under the same conditions involving the same type of LBP/LCP and similar lead concentration.

SELC conducted on-site XRF testing between July 2, 2014 and August 5, 2014 using a portable XRF paint analyzer. A total of 1,632 instrument readings were recorded. Eighty-five (85) of those readings were related to instrument calibration or internal diagnostics. There were also 112 “Null” readings. This “null”/incomplete status should not be confused with “inconclusive”, which is a condition that older model XRF devices produced when the XRF was unable to reconcile between Positive and Negative. The “null’ results recorded by SELC’s modern Niton instrument are simply incomplete tests normally caused by the inspectors finger not maintaining constant pressure on the XRF trigger, or the instrument sliding along the testing surface thereby forcing the inspector to terminate the test.

During the 2014 LBP inspection, XRF data from SELC’s 2009/2010 inspection was taken into consideration during the compilation of the data present in Section 6.0. A copy of the 2009/2010 SELC report, excluding drawings/site plans and certificates, is included in this report as Appendix T.

SELC has created a comprehensive appendix for each building that presents the findings of this inspection. Each Appendix includes; the XRF testing data sheets (included in Appendix “X”-1) XRF testing location plans (Appendix “X”-2); and photographic documentation of damaged or deteriorated LBP (Appendix “X”-3). The XRF testing data sheets provide a complete listing of the paint tests and building components on which paint testing was performed.

6.1 Paints Containing >1.0 mg/cm² Lead

Building components that were found to have LBP, coatings with lead concentrations equal to or greater than the 1.0 mg/cm² threshold for lead based paint as established by HUD and the EPA for “Target Housing and Child Occupied Facilities”, are listed below. Lead content for each type of component (per building) is listed as the range from lowest to highest.

Please note that LBP and the respective building components that are represented below (in Section 6.1) in italicized, bold lettering (bold) represent LBP observed to be damaged or deteriorated. Please refer to Appendix “X”-3 for photographic documentation of areas typical of damaged/deteriorated LBP observed during the 2014 inspection. Other LPBs listed below in Section 6.1 were generally observed to be intact to fair condition.

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Building 1 – Main Office Building and Medical Clinics Paint on exterior wood balusters on mech. penthouse roof = 2.70 to 5.20 mg/cm2 Paint on plaster ceilings (damaged observed generally in = 0.04 to 7.00 mg/cm2 staircases or above ceiling tiles) Paint on wood dormers = 0.24 to 1.90 mg/cm2 Paint on interior metal ductwork in attic mechanical area = 32.4 to 35.9 mg/cm2 Paint on concrete equipment stands in mechanical areas = 0.80 to 2.30 mg/cm2 Paint on interior metal hatch door and door frame in = 6.70 to 8.40 mg/cm2 mechanical penthouse Paint on plaster walls (damaged in localized areas only) = 0.00 to 1.70 mg/cm2 Paint on exterior metal window lintels = 0.01 to 32.7 mg/cm2 Paint on metal exterior handrails See Note Below Paint on interior plaster baseboards in main entrance/lobby = 4.80 mg/cm2 Paint on interior plaster columns in main entrance/lobby = 3.80 mg/cm2 Paint on plaster crown moldings in main entrance/lobby = 4.50 mg/cm2 Paint on interior metal doors and door frames = 0.00 to 4.10 mg/cm2 Paint on interior metal electrical panel (elevator mechanical room) = 5.60 mg/cm2 Paint on metal motors in elevator mechanical room = 0.60 to 1.80 mg/cm2 Paint on metal motor stands in elevator mechanical room = 0.60 to 1.00 mg/cm2 Paint on interior metal stairs (mechanical areas) = 0.36 to 3.80 mg/cm2 Paint on interior metal stringers (mechanical areas) = 0.01 to 4.70mg/cm2 Paint on interior plaster trim in main entrance/lobby = 6.30 mg/cm2 Paint on metal handrails and posts in staircases See Note Below Paint on wood wall in attic See Note Below

Building 1 Note: LBP was identified on these components during the 2009/2010 inspection; however, either these components were not identified as having LBP during this 2014 inspection, or a re-test was not performed. Unless LBP on these components has been abated, or these components have been removed and recently replaced, they should still be considered to be coated with LBP.

Building 2 – Office Building and Mental Health Clinics

Paint on exterior metal crawlspace vent = 20.7 mg/cm2 Paint on interior metal piping (attic) = 10.10 mg/cm2 Paint on interior metal door and door frame (attic elevator room) = 0.00 to 2.10 mg/cm2 Paint on interior metal ductwork in attic = 8.90 to 10.1 mg/cm2 Paint on interior metal handrail (mechanical 8A) = 1.60 mg/cm2 Paint on interior metal ladder (attic) = 7.70 mg/cm2 Paint on interior metal radiators = 1.80 mg/cm2 Paint on interior metal stairs = 8.40 mg/cm2 Paint on interior metal stringers in staircases = 2.90 to 4.60 mg/cm2 Paint on plaster walls = 0.07 to 1.70 mg/cm2 Paint on exterior metal window lintels = 0.70 to 1.20 mg/cm2 Paint on interior wood window sills (attic) = 14.7 mg/cm2

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Building 3 – Office Building and Boiler Plant Paint on interior metal doors (sub-basement) = 0.00 to 4.00 mg/cm2 Paint on interior metal door frames = 0.00 to 3.80 mg/cm2

(damaged in sub-basement) Paint on structural steel = 3.40 to 13.3 mg/cm2 Paint on plaster walls (damage in localized areas only) = 0.00 to 1.30 mg/cm2 Paint on exterior brick chimney/stack = 1.30 mg/cm2 Paint on wood access door to attic = 6.20 mg/cm2 Paint on interior metal balusters = 2.60 mg/cm2 Paint on interior metal cage (attic elevator room) = 5.30 mg/cm2 Paint on interior metal closet door frames = 3.30 to 5.80 mg/cm2 Paint on wood closet rods = 2.40 mg/cm2 Paint on wood closet shelves and shelf supports = 3.40 to 4.50 mg/cm2 Paint on interior wood doors (sub-basement) = 0.00 to 3.80 mg/cm2 Paint on exterior metal door frames = 0.00 to 2.00 mg/cm2 Paint on exterior metal door lintels = 2.60 mg/cm2 Paint on interior metal hand rail (attic elevator room) = 0.00 to 8.20 mg/cm2 Paint on interior metal ladders = 0.00 to 9.00 mg/cm2 Paint on interior metal large door in sub-basement = 8.90 mg/cm2 Paint on interior metal stair components (tread and riser) = 0.00 to 6.30 mg/cm2 Paint on interior brick walls = 0.00 to 3.90 mg/cm2 Paint on exterior wood window = 29.8 mg/cm2 Paint on metal boiler in sub-basement See Note Below Paint on concrete ceiling and ceiling beam in sub-basement See Note Below Paint on concrete curb in sub-basement See Note Below Paint on metal fire boxes in hallways See Note Below Paint on metal handrails throughout building See Note Below Paint on wooden mirror frame and shelf in bathroom See Note Below Paint on wooden newel post in stairwell See Note Below Paint on metal sliding door in sub-basement See Note Below Paint on stringers in stairwells See Note Below Paint on wooden transom in hallway and office See Note Below Paint on concrete wall in storage room See Note Below Paint on wooden walls in storage room and hallway See Note Below Paint on metal windows and frames in sub-basement See Note Below Paint on concrete bay door header on exterior See Note Below

Building 3 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

Building 4 - Auditorium Paint on interior metal window = 4.80 mg/cm2 Paint on interior wood window components = 1.30 to 18.4 mg/cm2 Paint on exterior wood window components = 2.10 to 32.4 mg/cm2 Paint on exterior wood ceilings = 38.9 mg/cm2 Paint on exterior wood door frame = 6.20 to 29.6 mg/cm2

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Paint on exterior handrails, balusters, newel posts = 0.04 to 10.1 mg/cm2 Paint on interior metal spiral stair components = 3.50 to 9.50 mg/cm2 Paint on wood transom (interior and exterior faces) = 4.40 to 41.4 mg/cm2 Paint on brick walls = 0.11 to 10.8 mg/cm2 Paint on interior metal balusters = 0.00 to 3.70 mg/cm2 Paint on interior wood baseboards = 4.10 to 6.90 mg/cm2 Paint on interior metal attic/ceiling access panel = 8.00 mg/cm2 Paint on interior wood chair rail = 19.3 mg/cm2 Paint on wood crown molding = 19.40 mg/cm2 Paint on interior wood doors = 0.00 to 2.40 mg/cm2 Paint on interior metal door frames = 0.00 to 2.50 mg/cm2 Paint on interior wood door frames = 0.40 to 13.7 mg/cm2 Paint on interior wood door molding = 12.30 mg/cm2 Paint on interior metal ladder (mezzanine) = 0.00 to 7.50 mg/cm2 Paint on interior metal newel posts in stairwells = 0.00 to 5.40 mg/cm2 Paint on metal radiator covers = 9.20 mg/cm2 Paint on interior wood stage, stage molding, and columns = 8.50 to 12.6 mg/cm2 Paint on interior metal staircase stringer = 0.00 to 5.20 mg/cm2 Paint on structural steel = 3.10 to 10.1 mg/cm2 Paint on interior plaster walls and ceilings = 0.01 to 10.3 mg/cm2 Paint on interior wood walls = 0.00 to 12.4 mg/cm2 Paint on interior wood wall trim = 12.80 mg/cm2 Paint on wood cabinetry in auditorium See Note Below Paint on metal cage in foyer See Note Below Paint on interior metal handrails See Note Below Paint on wood exterior columns See Note Below Paint on metal fire hydrant See Note Below Paint on exterior concrete threshold See Note Below

Building 4 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

Building 5 – Office Building (Safety/Engineering)

Paint on exterior wood door molding = 26.50 mg/cm2 Paint on exterior wood columns and pilasters = 0.00 to 17.9 mg/cm2 Paint on wood exterior wood ceiling and trim See Note Below Paint on exterior wood soffit See Note Below Paint on interior metal balusters = 0.00 to 3.60 mg/cm2 Paint on plaster ceilings = 0.16 to 3.70 mg/cm2 Paint on plaster cove base / baseboards = 0.00 to 2.10 mg/cm2 Paint on interior metal door (mechanical areas) = 0.00 to 2.90 mg/cm2 Paint on interior metal door frames = 0.00 to 9.40 mg/cm2 Paint on exterior wood door frames = 0.00 to 1.70 mg/cm2 Paint on metal fire ext. cab door frames = 0.01 to 2.80 mg/cm2 Paint on interior wood newel posts = 3.10 mg/cm2 Paint on interior metal risers and stringers in stairwells = 0.01 to 5.60 mg/cm2

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Paint on wood and metal stall divider = 2.00 to 2.10 mg/cm2 Paint on wood and metal stall door = 1.60 mg/cm2 Paint on wood and metal transoms = 1.50 to 12.5 mg/cm2 Paint on interior wood window components (excluding sashes) = 0.00 to 10.5 mg/cm2 Paint on block walls in stairwells and Mechanical Room See Note Below Paint on exterior metal newel posts See Note Below Paint on exterior concrete thresholds See Note Below

Building 5 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

Building 6 – Former VISN Office Building / Quarters Building

Paint on exterior wood porch ceilings = 21.8 mg/cm2 Paint on exterior wood columns = 0.06 to 36.5 mg/cm2 Paint on exterior metal doors = 28.20 mg/cm2 Paint on exterior wood doors = 0.50 to 28.8 mg/cm2 Paint on exterior wood door frames = 15.3 to 38.2 mg/cm2 Paint on exterior metal handrails = 0.50 to 1.80 mg/cm2 Paint on exterior wood handrails = 2.50 mg/cm2 Paint on wood louver and louver screens = 4.00 to 4.20 mg/cm2 Paint on exterior wood newel posts = 1.00 mg/cm2 Paint on wood stair risers and stringers = 4.20 to 8.60 mg/cm2 Paint on exterior wood window components and transoms = 2.10 to 10.1 mg/cm2

(Note: original sashes remain in attic / are coated with LBP) Paint on exterior metal window lintels = 4.90 to 24.5 mg/cm2 Paint on structural steel = 8.40 to 10.1mg/cm2 Paint on exterior brick walls = 25.9 mg/cm2 Paint on interior plaster ceilings **textured ceiling material = 0.00 to 3.10 mg/cm2 on plaster ceilings is significantly damaged/delaminating Paint on wood balusters in stair wells = 2.30 to 5.90 mg/cm2 Paint on wood baseboards = 0.00 to 9.10 mg/cm2 Paint on wood closet doors = 0.01 to 4.60 mg/cm2 Paint on wood closet door frames = 5.30 mg/cm2 Paint on wood closet rods = 2.30 mg/cm2 Paint on wood closet shelves = 3.30 to 4.10 mg/cm2 Paint on wood closet shelf supports = 2.30 to 4.20 mg/cm2 Paint on interior wood doors = 0.00 to 9.50 mg/cm2 Paint on interior wood door frames = 0.00 to 7.40 mg/cm2 Paint on interior door frame (rear) = 3.40 mg/cm2 Paint on interior door (rear) = 7.70 mg/cm2 Paint on wood fascia = 35.10 mg/cm2 Paint on interior wood handrails = 0.03 to 6.20 mg/cm2 Paint on wood stair landing in attics = 5.90 mg/cm2 Paint on wood mantle = 5.50 to 6.10 mg/cm2 Paint on interior wood newel posts = 0.11 to 3.90 mg/cm2 Paint on exterior wood soffit = 40.3 mg/cm2

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Paint on wood stair tread = 5.90 to 6.90 mg/cm2 Paint on interior face of wood window components and transom = 0.10 to 10.7 mg/cm2

(excludes sashes, except in attic) Paint on plaster wall in bathroom See Note Below

Building 6 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

Building 8 – Hospice Sunrise Center

Paint on wood crawlspace door and door frame = 3.10 to 6.00 mg/cm2 Paint on exterior wood doors = 30.3 mg/cm2 Paint on exterior wood door frames = 33.0 to 45.8 mg/cm2 Paint on wood fascia and soffit = 34.8 to 36.5 mg/cm2 Paint on exterior metal handrail = 0.80 to 7.60 mg/cm2 Paint on exterior wood handrails = 1.30 to 1.90 mg/cm2 Paint on interior wood window components (all) = 0.01 to 8.70 mg/cm2 Paint on exterior metal window lintels = 3.90 to 11.2 mg/cm2 Paint on exterior wood window components (all) = 0.06 to 40.7 mg/cm2 Paint on interior wood stair risers and stringers = 4.50 to 7.70 mg/cm2 Paint on concrete walls in basement See Note Below Paint on interior wood door frames = 0.01 to 9.10 mg/cm2 Paint on interior wood balusters in stairwells = 0.02 to 9.30 mg/cm2 Paint on interior wood baseboards = 0.00 to 12.6 mg/cm2 Paint on wood closet door frames = 5.70 to 5.90 mg/cm2 Paint on wood closet shelves and shelf supports = 2.90 mg/cm2 Paint on interior wood doors = 0.00 to 6.70 mg/cm2 Paint on interior wood handrails = 12.80 mg/cm2 Paint on wood mantle = 8.30 mg/cm2 Paint on structural steel = 11.5 to 12.9 mg/cm2 Paint on exterior and interior wood transom = 3.50 to 10.8 mg/cm2 Paint on wood stair treads = 2.90 to 3.60 mg/cm2 Paint on exterior wood trim = 40.0 mg/cm2 Paint on interior wood wall (porch) = 1.40 mg/cm2 Paint on interior plaster ceilings See Note Below Paint on wood closet coat rack hangers See Note Below Paint on interior newel posts in stairwells See Note Below Paint on wood bathroom stall See Note Below Paint on plaster walls in foyer and hallway See Note Below

Building 8 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

SELC Project No.: 2014-1107 Page 11

Building 12 - Warehouse Paint on wood door frames (interior and exterior) = 7.30 to 39.2 mg/cm2 Paint on wood eaves, fascia, soffit = 2.50 to 36.9 mg/cm2 Paint on exterior metal handrails = 0.05 to 3.40 mg/cm2 Paint on exterior wood components (see note below) = 2.20 mg/cm2 Paint on metal windows (interior and exterior) = 0.13 to 8.30 mg/cm2 Paint on interior metal window cages = 8.40 to 12.3 mg/cm2 Paint on interior metal doors = 1.40 mg/cm2 Paint on interior metal door frames = 0.00 to 2.50 mg/cm2 Paint on concrete floor and ground markings = 3.40 to 3.90 mg/cm2 Paint on structural steel = 0.00 to 16.9 mg/cm2 Paint on metal safe = 1.40 mg/cm2 Paint on interior plaster walls = 5.40 mg/cm2 Paint on interior concrete window sills = 0.13 to 2.80 mg/cm2 Paint on concrete floor in bathroom See Note Below Paint on metal stall in bathroom See Note Below Paint on gypsum board walls in offices See Note Below

Building 12 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

Building 13 – Small Building Paint on metal window components = 6.20 to 28.7 mg/cm2 Paint on metal piping = 1.20 mg/cm2 Paint on exterior wood door frame See Note Below

Building 13 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

Building 14 – Small Building Paint on wood doors = 34.6 mg/cm² Paint on wood door frames = 8.40 mg/cm² Paint on wood fascia = 22.3 mg/cm² Paint on metal windows = 1.90 mg/cm²

Building 17 - Shops

Paint on exterior wood doors = 32.9 mg/cm2 Paint on exterior wood door frames = 31.7 mg/cm2 Paint on exterior metal door lintels = 45.4 mg/cm2 Paint on exterior metal windows = 0.30 to 25.0 mg/cm2 Paint on exterior metal window lintels = 20.0 to 24.7 mg/cm2 Paint on interior plaster ceilings and walls = 1.60 to 1.70 mg/cm2 Paint on interior wood doors = 0.00 to 7.30 mg/cm2 Paint on interior wood door frames = 0.00 to 8.30 mg/cm2

SELC Project No.: 2014-1107 Page 12

Paint on interior metal door frames = 0.00 to 2.70 mg/cm2 Paint on exterior wood rafters, eaves, fascia = 27.5 to 34.2 mg/cm2 Paint on structural steel = 0.00 to 9.70 mg/cm2 Paint on interior metal windows = 0.30 to 4.20 mg/cm2 Paint on interior metal window frames = 0.30 to 4.40 mg/cm2 Metal marking paint See Note Below

Building 17 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

Building 18 - Laundry

Paint on interior concrete floor (basement) = 0.03 to 1.40 mg/cm2 Paint on exterior metal handrails = 0.00 to 19.3 mg/cm2 Paint on exterior metal windows = 0.06 to 10.0 mg/cm2 Paint on interior metal window cages = 8.80 mg/cm2 Paint on exterior metal window lintels = 11.3 mg/cm2 Paint on interior wood door (one office) = 0.00 to 1.30 mg/cm2 Paint on interior metal pipes (basement) = 10.10 mg/cm2 Paint on interior wood roof deck = 9.10 mg/cm2 Paint on structural steel (including roof deck) = 0.00 to 25.9 mg/cm2 Paint on interior concrete walls = 0.00 to 1.40 mg/cm2 Paint on wood door and door frame (exterior) See Note Below Paint on wood eaves, fascia, soffit See Note Below

Building 18 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

Building 25 – Garage Building

Paint on metal corner protectors = 8.80 to 10.1 mg/cm² Paint on wood fascia and soffit = 0.00 to 21.3 mg/cm² Paint on wood roll up door frames = 22.1 to 24.0 mg/cm2 Paint on wood louver = 2.50 to 20.9 mg/cm2 Paint on metal roll up doors = 16.3 to 17.6 mg/cm2 Paint on wood door frames = 8.30 mg/cm² Paint on concrete walls See Note Below

Building 25 Note: LBP was identified on these components during the 2009/2010 inspection; however, either these components were not re-tested, or were not identified as having LBP during this inspection. Unless LBP on these components has been abated, or these components have been removed and recently replaced, they should still be considered to be coated with LBP.

SELC Project No.: 2014-1107 Page 13

Building 27 – Garage Building Paint on metal corner protectors = 0.19 to 10.1 mg/cm² Paint on wood louver doors = 5.20 to 9.30 mg/cm2 Paint on wood louver = 8.40 to 22.3 mg/cm2 Paint on wood roll up door frames = 16.1 to 20.6 mg/cm2 Paint on wood fascia and soffit = 10.1 to 19.6 mg/cm2

Building 28 – Garage Building

Paint on metal corner protectors = 8.50 mg/cm² Paint on wood fascia and soffit = 31.6 to 33.6 mg/cm² Paint on wood louver = 23.10 mg/cm² Paint on wood roll up door frames = 8.30 to 43.3 mg/cm²

Building 39 – Office Building / Tuscaloosa OIT Offices

Paint on interior metal cages = 1.20 to 14.3 mg/cm2 Paint on exterior metal window lintels = 35.7 to 35.8 mg/cm2 Paint on exterior metal downspout bases = 2.00 mg/cm2 Paint on interior metal handrails = 1.50 to 2.60 mg/cm2 Paint on structural steel = 9.00 to 11.6 mg/cm2 Paint on wood windows in attic = 13.9 to 17.6 mg/cm2 Paint on interior plaster / concrete ceilings (areas of = 0.17 to 1.10 mg/cm2 significant delamination in first and second floor offices off central hallway)

Paint on interior plaster walls (areas of significant = 0.00 to 1.30 mg/cm2 delamination in first and second floor offices off central hallway)

Paint on interior plaster columns = 0.50 to 1.20 mg/cm2 Paint on interior metal doors = 0.15 to 1.40 mg/cm2 Paint on interior metal door frames = 0.00 to 2.30 mg/cm2 Paint on interior wood door frames = 23.20 mg/cm2 Paint on interior fire ext. cab door frames = 1.60 to 8.40 mg/cm2 Paint on interior metal window frames = 0.00 to 9.70 mg/cm2 Paint on concrete baseboard in storage room See Note Below Paint on wood window sills and sashes throughout building See Note Below

Building 39 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

Building 40 – Office Building / Daycare*

*Please note that this report excludes the daycare portion of Building 40. A LBP Inspection of the daycare portion of Building 40 has been submitted under separate cover.

Paint on interior metal cages = 1.70 mg/cm2 Paint on structural steel = 8.40 to 21.9 mg/cm2 Paint on interior wood windows = 9.70 to 19.0 mg/cm2 Paint on exterior metal downspout bases = 2.40 mg/cm2

SELC Project No.: 2014-1107 Page 14

Paint on exterior metal window lintels = 25.80 mg/cm2 Paint on interior metal handrails = 0.00 to 3.00 mg/cm2 Paint on interior plaster ceilings (localized areas) = 1.70 mg/cm2 Paint on interior plaster walls (localized areas) = 1.20 to 1.30 mg/cm2 Paint on interior metal door frames = 1.90 to 3.60 mg/cm2 Paint on interior wood door frames = 0.50 to 17.3 mg/cm2 Paint on interior wood doors = 21.30 mg/cm2 Paint on interior metal window frames = 9.00 mg/cm2 Paint on interior wood window sills = 0.14 to 11.8 mg/cm2

Building 41 – Grounds Building

Paint on wood rafter, fascia, eave, soffit = 13.9 to 19.3 mg/cm2 Paint on metal windows (interior & exterior) = 0.30 to 19.2 mg/cm2 Paint on metal window lintels (interior & exterior) = 0.70 to 16.5 mg/cm2 Paint on interior concrete window sills = 0.50 to 1.60 mg/cm2 Paint on concrete ceilings and columns on ground floor See Note Below Paint on interior metal door frames = 0.00 to 1.60 mg/cm2 Paint on interior metal cage = 2.00 mg/cm2 Paint on interior metal corner protectors = 1.50 to 3.90 mg/cm2 Paint on wood crawlspace access door = 9.70 mg/cm2 Paint on interior metal door = 0.21 to 2.40 mg/cm2 Paint on interior wood doors = 0.17 to 7.80 mg/cm2 Paint on interior wood shelving = 3.00 mg/cm2 Paint on plaster wall in bathroom See Note Below

Building 41 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

Building 46 - Chapel

Paint on wood decorative grill = 6.60 mg/cm² Paint on exterior metal door = 7.40 mg/cm² Paint on exterior metal door frames = 5.40 to 12.0 mg/cm2 Paint on metal down spout bases = 1.10 mg/cm2 Paint on wood soffit and fascia = 16.6 mg/cm2 Paint on metal window lintel = 0.00 to 2.40 mg/cm2 Paint on interior metal handrails = 2.40 to 7.30 mg/cm2 Paint on exterior metal sign = 1.40 mg/cm2 Paint on metal storage box See Note Below

Building 46 Note: LBP was identified on these components during the 2009/2010 this 2014 inspection, or a re-test was not performed. Unless LBP on these components

SELC Project No.: 2014-1107 Page 15

6.2 Paints Containing <1.0 mg/cm² Lead

XRF testing detected only low concentrations of lead (i.e. ≥0.01 mg/cm² to 0.99 mg/cm²), referred to as lead containing paints (LCP), as potentially regulated by OSHA in the coatings applied to the following components:

Building 1 – Main Office Building and Medical Clinics Paint on exterior metal awning Paint on interior metal baluster Paint on interior concrete ceilings / columns / floors Paint on interior wood doors Paint on interior metal fire ext. cabinets Paint on interior wood hand rails Paint on exterior metal lamps Paint on interior metal sprinkler piping Paint on interior wood stairs Paint on interior brick walls Paint on interior concrete window sills

Building 2 – Office Building and Mental Health Clinic

Paint on interior metal cages Paint on plaster ceilings Paint on interior plaster columns Paint on metal fire ext. cab. doors Paint on concrete floors Paint on metal motors Paint on interior metal doors (excluding attic)

Building 3 – Office Building and Boiler Plant

Paint on concrete baseboards Paint on wood cabinets Paint on interior wood door frames Paint on interior concrete floors Paint on exterior metal handrails Paint on interior metal newel posts Paint on interior metal stringers Paint on interior gypsum board walls Paint on interior plaster window sills

Building 4 - Auditorium

Paint on exterior metal archway Paint on exterior wood walls Paint on interior concrete floors Paint on exterior metal pipe Paint on metal radiators

Building 5 – Office Building (Safety/Engineering)

Paint on concrete ceiling Paint on interior wood door Paint on metal downspout base

SELC Project No.: 2014-1107 Page 16

Paint on fire ext. cab door Paint on exterior concrete floor Paint on exterior metal handrail Paint on metal radiators Paint on interior and exterior concrete steps Paint on interior plaster and brick walls Paint on exterior metal window lintel Paint on wood window screen frame

Building 6 – Former VISN Office Building / Quarters Building

Paint on crawlspace door and door frame Paint on metal downspout base Paint on exterior concrete floor Paint on metal light fixtures Paint on interior concrete and plaster walls

Building 8 – Hospice Sunrise Center

Paint on wood closet doors and rods Paint on wood crown molding Paint on metal downspout base Paint on brick fireplace Paint on concrete floor Paint on exterior metal ladder Paint on metal light fixture Painted wood louvered door frame Paint on interior concrete and plaster walls

Building 12 - Warehouse

Paint on metal awning pole Paint on exterior wood crawlspace door Paint on exterior metal dock Paint on interior wood door Paint on exterior metal door frame Paint on metal downspout base Paint on metal radiator Paint on metal sprinkler pipe Paint on metal interior walls Paint on exterior factory coated metal

Building 13 – Small Building

Paint on exterior wood door Paint on exterior metal door and door frame Paint on wood fascia Paint on metal louver Paint on interior concrete masonry unit walls

Building 14 – Small Building

Paint on exterior wood screen widow frame

SELC Project No.: 2014-1107 Page 17

Building 17 - Shops Paint on gypsum board ceiling Paint on interior concrete ceiling Paint on interior metal doors Paint on interior concrete floor Paint on interior metal ladder Paint on metal radiator Paint on interior wood shelving Paint on interior metal sprinkler pipe Paint on interior metal stall door and wall Paint on interior brick wall Paint on interior concrete masonry block Interior factory coated metal walls Paint on concrete window sills

Building 18 - Laundry

Paint on interior metal doors and door frames Paint on interior brick, plaster, and metal walls Paint on interior metal windows and window frames Paint on interior concrete window sills

Building 25 – Garage Building

Paint on exterior concrete walls

Building 27 – Garage Building

Paint on exterior metal handrail

Building 28 – Garage Building

NONE

Building 39 – Office Building / Tuscaloosa OIT Offices

Paint on interior concrete ceilings Paint on interior concrete cove base Paint on wood fire ext. cab doors Paint on metal radiator covers Paint on metal sprinkler piping Paint on interior wood window sills

Building 40 – Office Building / Daycare (excludes daycare)

Paint on interior plaster columns Paint on interior metal doors Paint on metal radiator cover Paint on exterior metal handrails

Building 41 – Grounds Building

Paint on plaster ceilings and walls Paint on interior brick door surrounding Paint on exterior metal downspout base Paint on wood fire ext. cab door Paint on metal fire ext. cab door frames

SELC Project No.: 2014-1107 Page 18

Paint on concrete floor Paint on interior metal handrails Paint on interior metal piping Paint on metal radiators Paint on interior metal roll up door frame Paint on interior brick walls

Building 46 - Chapel

Paint on plaster arches Paint on exterior concrete ceilings Paint on wood closet doors Paint on metal closet doors and door frames Paint on interior wood door Paint on interior metal doors and door frames Paint on interior concrete equipment stands Paint on concrete floor Paint on concrete masonry unit walls Paint on interior wooden window sills

7.0 CONCLUSIONS AND RECOMMENDATIONS

With regard to damaged or deteriorated LBP, lead hazard control measures, either interim controls or abatement, should be implemented to remove potential LBP hazards, which are created by the presence of and exposure to lead paint chips and/or lead-containing dust or soil.

Lead hazard control measures should be performed by an Alabama Department of Public Health accredited lead abatement company.

Interim hazard control measures include dust removal, paint film stabilization, control of friction/abrasion points, and/or moisture control. Refer to Chapter 11 of the Guidelines for the Identification and Control of Lead-Based Paint Hazards in Housing for information on interim control methods of addressing LPB hazards. Permanent hazard control measures (abatement) would include encapsulation, LBP removal, or building component replacement. Refer to Chapter 12 of the Guidelines for the Identification and Control of Lead-Based Paint Hazards in Housing for information on abatement methods. Subsequent to completion of the chosen hazard control option, a thorough cleaning of all surfaces in the affected areas should be conducted, and followed by a Clearance Examination (visual inspection & dust wipe sampling) performed by a certified LBP Inspector/Risk Assessor.

Costs of LBP abatement vary greatly depending on the type of work planned (encapsulation, enclosure, LBP removal, or building component removal). However, according to the EPA, professional LBP abatement costs average $8.00 to $15.00 per square foot for a typical residential structure. Please note that estimates for LBP can/should be obtained by a licensed LBP abatement contractor for each planned renovation or demolition project.

The VAMC can address lead exposure issues associated with renovation and demolition projects through identification of the LBP descriptions and appropriate delineation of the contractor’s obligations for OSHA compliance. Preparation of lead handling specifications and related notes on project drawings are the best way to identify these criteria. Lead exposure reduction issues for the maintenance staff could be addressed through safe working practices that are generally defined in various EPA documents, special training classes, and/or a facility

SELC Project No.: 2014-1107 Page 19 specific LBP Operations & Maintenance program.

8.0 ASSUMPTIONS AND LIMITATIONS

The results,…