657-19-117JB - Lead Safe Demo Plan.pdf

Project 657-19-117JB (VEG 19.23) February 7, 2020

Basement East Wing of Building 1 – St. Louis VAMC

1 Jefferson Barracks Dr., St. Louis, MO 63125

LEAD-BASED PAINT REMOVAL & DISPOSAL

SPECIFICATIONS

Prepared by:

2418 Merriam Lane Kansas City, Kansas 66106

For:

Valhalla Engineering Group 750 W. Hampden Ave., Suite 300

Englewood, CO 80110.

Project:

Implementation of Sterile Processing Ventilation Requirements Basement East Wing of Building 1 - St. Louis VAMC

1 Jefferson Barracks Dr., St. Louis, MO 63125

Project Number 657-19-117JB (VEG 19.23)

February 7, 2020

Project 657-19-117JB (VEG 19.23) February 7, 2020

Lead-Based Paint Removal and Disposal Specifications

Implementation of Sterile Processing Ventilation Requirements

Basement East Wing of Building 1 - St. Louis VAMC

1 Jefferson Barracks Dr., St. Louis, MO 63125

February 7, 2020

A copy of these specifications will remain at the site at all times. All personnel working or visiting the site will be briefed on this document prior to proceeding with any activities at the site.

The following project document has been reviewed and contractor agrees to abide by its guidance:

Abatement Contractor Project Manager Date

Project 657-19-117JB (VEG 19.23) February 7, 2020

Introduction

In accordance with OHSA Lead in Construction Standard 29 CFR 1926.62 and the Unified Facilities Guide Specifications (UFGS), Division 2 – Existing Conditions, Section 02 83 13.00 20 – Lead in Construction, the following lead safe work practices and engineering controls outlined in the specifications below are to be followed during Lead-Based Paint (LBP) demolition/removal activities undertaken for purposes of this project.

All workers performing the below referenced tasks, shall be certified EPA Lead- Safe Renovators and supervised by a licensed Missouri Department of Health and Senior Services (MDHSS) Lead Abatement Supervisor for the duration of the project. Although these activities (i.e., plaster ceiling and wall demo) may result in the permanent elimination of a lead based painted building components, the following specification has been written for Lead-Safe Demolition/Removal in accordance with EPAs Renovation, Repair and Painting (RRP) rule. This is not a “Lead Abatement” project as the intent is not to address the LBP, the purpose is to replace existing equipment and in turn safely demo under controlled conditions any LBP plaster walls/ceilings and lead-containing ceramic wall tile that are in the critical work path of this project.

The Lead Safe Contractor will comply with applicable safety requirements pertaining to VA Health and Safety specifications and ICRA. Infection Control is critical in all medical center facilities. Interior construction activities causing disturbance of existing dust, or creating new dust, must be conducted within ventilation-controlled areas that minimize the flow of airborne particles into patient areas.

An infection control risk assessment (ICRA) must be performed by VA personnel in accordance with Facility Guidelines Institute (FGI) Guidelines. The ICRA procedures found on the American Society for Healthcare Engineering (ASHE) website shall be utilized.

Scope of Work

The lead safe demolition/removal scope of work may consist, when applicable, of removing lead-based painted components under controlled isolated conditions in accordance with the specification below within the designated project work areas.

Please reference the attached LBP Inspection Report and LBP Location Drawings.

It is the contractor’s responsibility to verify quantities.

Appendices;

A. Material Location Drawings w/Lead-Based Paint Inspection Report

Project 657-19-117JB (VEG 19.23) 2/7/2020

Building 1 – St. Louis VAMC

SECTION 02 83 33.13

LEAD-BASED PAINT REMOVAL AND DISPOSAL

PART 1 - GENERAL

1.1 SUMMARY

A. Section Includes:

1. Removing and disposal of lead-based paint at interior locations

2. Assume all painted surfaces are lead-based paint. It is not anticipated that any painted surfaces should be disturbed by this project. However, should there be any need to remove any paint this specification will apply.

3. The following data is provided for reference along with drawings:

SAMP # BUILDING LOCATION COMPONENT SUBSTRATE COLOR COND.

XRF Reading

(mgcm2)

8 GE17 Wall Plaster White Intact 10.3

20 GE19 Wall Plaster White Intact 8.9

26 GE19 Wainscot Ceramic Gray Intact 20.7

74 GE32 Wainscot Ceramic Gray Intact 19.6

88 GE22 Wainscot Ceramic Off-White Intact 12.2

89 GE22 Sink Porcelain White Intact 3.8

98 GE23 Shower Wall Ceramic Off-White Intact 13.9

141 GE29 Wall Ceramic White Intact 18.9

02 83 33.13 - 2

1.2 RELATED REQUIREMENTS

A. Should any lead-based paint need to be disturbed coordinate with glove bag asbestos removal specification.

1.3 DEFINITIONS

A. Action Level: Employee exposure, without regard to use of respirator, to lead airborne concentration of 30 micrograms per cubic meter (0.03 parts per million) of air averaged over 8-hour period. As used in this section, ”30 micrograms per cubic meter of air (0.03 parts per million)" refers to action level.

B. Area Monitoring: Sampling of lead concentrations within lead control area and inside physical boundaries which are representative of airborne lead concentrations which may reach breathing zone of personnel potentially exposed to lead.

C. Breathing Zone: Area within hemisphere, forward of shoulders, with 150 mm to 225 mm (6 to 9 inches) radius and center at nose or mouth of employee.

D. Certified Industrial Hygienist (CIH): As used in this section, refers to an

Industrial Hygienist employed by Contractor.

E. Change Rooms and Shower Facilities: Rooms within designated physical boundary around lead control area equipped with separate storage facilities for clean protective work clothing and equipment and for street clothes which prevent cross- contamination.

F. Competent Person: Person capable of identifying lead hazards in work area and authorized by contractor to take corrective action.

G. Decontamination Room: Room for removal of contaminated personal protective equipment (PPE).

H. Eight-Hour Time Weighted Average (TWA): Airborne concentration of lead averaged over 8-hour workday to which an employee is exposed.

I. High Efficiency Particulate Air (HEPA) Filter Equipment:

HEPA filtered vacuuming equipment with UL 586 filter system capable of collecting and retaining lead-contaminated paint dust. HEPA filter means

99.97 percent efficient against 0.3 micron (0.012 mil) size particles.

J. Lead: Metallic lead, inorganic lead compounds, and organic lead soaps.

Excluded from this definition are other organic lead compounds.

K. Lead Control Area: Enclosed area or structure with full containment to prevent spreading lead dust, paint chips, and debris from lead-based paint removal operations. Lead control area is isolated by physical boundaries to prevent unauthorized entry of personnel.

02 83 33.13 - 3

L. Lead Permissible Exposure Limit (PEL): Fifty micrograms per cubic meter

(0.05 parts per million) of air as 8-hour time weighted average as determined by 29 CFR Part 1910.1025. When employee is exposed for more than

8 hours per work day, determine PEL by following formula. PEL micrograms/cubic meter (parts per million) of air = 400/No. of hrs. worked per day.

M. Personnel Monitoring: Sampling of lead concentrations within employee breathing zone to determine 8-hour time weighted average concentration according to 29 CFR Part 1910.1025. Take samples representative of employee's work tasks.

N. Physical Boundary: Area physically roped or partitioned off around enclosed lead control area to limit unauthorized entry of personnel. As used in this section, "inside boundary" shall mean same as "outside lead control area."

1.4 APPLICABLE PUBLICATIONS

A. Comply with references to extent specified in this section.

B. American National Standards Institute (ANSI):

1. Z9.2-12 - Fundamentals Governing the Design & Operation of Local

Exhaust Ventilation Systems.

C. Code of Federal Regulations (CFR):

1. 29 CFR Part 1910 - Occupational Safety and Health Standards.

2. 29 CFR Part 1926 - Safety and Health Regulations for Construction.

3. 40 CFR Part 260 - Hazardous Waste Management System: General.

4. 40 CFR Part 261 - Identification and Listing of Hazardous Waste.

5. 40 CFR Part 262 - Standards Applicable to Generators of Hazardous

Waste.

6. 40 CFR Part 263 - Standards Applicable to Transporters of Hazardous

Waste.

7. 40 CFR Part 264 - Standards for Owners and Operations of Hazardous

Waste Treatment, Storage, and Disposal Facilities.

8. 40 CFR Part 265 - Interim Status Standards for Owners and Operators of

Hazardous Waste Treatment, Storage, and Disposal Facilities.

9. 40 CFR Part 268 - Land Disposal Restrictions.

10. 49 CFR Part 172 - Hazardous Material Table, Special Provisions, Hazardous Material Communications, Emergency Response Information, and

Training Requirements, and Security Plans.

11. 49 CFR Part 178 - Specifications for Packaging’s.

D. Underwriters Laboratories (UL):

1. 586-09 - High-Efficiency, Particulate, Air Filter Units.

02 83 33.13 - 4

1.5 PRE-REMOVAL MEETINGS

A. Conduct pre-removal meeting at project site minimum 10 days before beginning Work of this section.

1. Required Participants:

a. Contracting Officer's Representative.

b. Certified Industrial Hygienist.

c. VPIH

d. Lead Safe Contractor

2. Meeting Agenda: Distribute agenda to participants minimum 3 days before meeting.

a. Respiratory protection program.

b. Hazard communication program.

c. Hazardous waste management plan.

d. Safety and health regulation compliance.

e. Employee training.

f. Removal schedule.

g. Removal sequence.

h. Preparatory work.

i. Protection before, during, and after removal.

j. Removal.

k. Inspecting and testing.

l. Other items affecting successful completion.

3. Document and distribute meeting minutes to participants to record decisions affecting installation.

1.6 SUBMITTALS

A. Submittal Procedures: Section 01 33 23, SHOP DRAWINGS, PRODUCT DATA, AND SAMPLES.

B. Manufacturer's Literature and Data:

1. Description of each product.

a. Paint removal products.

b. Vacuum filters.

c. Respirators.

2. Safety data sheet for each paint removal product.

3. Installation instructions.

a. Paint removal products.

02 83 33.13 - 5

C. Test Reports: Submit testing laboratory reports.

1. Submit air monitoring results within three working days, signed by testing laboratory employee performing air monitoring, employee analyzing sample, and CIH.

D. Certificates: Certify completed training.

1. Submit certificate for each employee signed and dated by CIH and employee stating employee was trained.

E. Qualifications: Substantiate qualifications comply with specifications.

1. Paint removal contractor.

2. Testing laboratory.

a. Name, address, and telephone number.

b. Current evidence of participation in NIOSH PAT Program.

c. Copy of current AIHA accreditation certificate.

3. Industrial hygienist.

a. Name, address, and telephone number.

b. Resume showing previous experience.

c. Copy of current ABIH CIH certification.

4. Paint disposal facility.

a. Name, address, and telephone number.

b. Current license or authorization to receive and dispose lead contaminated waste.

F. Record Documents:

1. Completed and signed hazardous waste manifest from waste transporter.

2. Paint disposal facility receipts and disposition reports.

3. Certification of medical examinations.

4. Employee training certification.

1.7 QUALITY ASSURANCE

A. Safety and Health Regulation Compliance:

1. Comply with laws, ordinances, rules, and regulations of federal, state, and local authorities having jurisdiction regarding removing, handling, storing, transporting, and disposing lead waste materials.

a. Comply with applicable requirements of 29 CFR Part 1910.1025.

b. Notify Contracting Officer's Representative and request resolution of conflicts between regulations and specified requirements before starting work.

02 83 33.13 - 6

B. Paint Removal Contractor: Experienced contractor, registered or licensed by applicable state agency regulating lead-based paint removal.

C. Testing Laboratory: State certified independent testing laboratory experienced in airborne lead monitoring, testing, and reporting.

1. Successful participant in NIOSH Proficiency Analytical Testing (PAT)

Program within prior 12 months.

2. Accredited by American Industrial Hygiene Association (AIHA).

D. Certified Industrial Hygienist: Certified as CIH by American Board of

Industrial Hygiene in comprehensive practice and responsible for:

1. Certify Training.

2. Review and approve lead-based paint removal plan for conformance to applicable referenced standards.

3. Inspect lead-based paint removal work for conformance with approved plan.

4. Direct monitoring.

5. Ensure work is performed according to specifications.

6. Ensure personnel and environment hazardous exposures are adequately controlled.

E. Paint Disposal Facility: State certified disposal facility qualified to receive and dispose lead-based paint.

F. Lead-based Paint Removal Plan:

1. Submit detailed, site-specific plan describing lead-based paint removal procedures.

2. Include sketch showing location, size, and details of lead control areas, decontamination rooms, change rooms, shower facilities, and mechanical ventilation system.

3. Include eating, drinking, and restroom procedures, interface of trades, work sequencing, collected wastewater and paint debris disposal plan, air sampling plan, respirators, protective equipment, and detailed description of containment methods ensuring airborne lead concentrations do not exceed action level outside lead control area.

a. Eating, drinking, and smoking are not acceptable within lead control area.

4. Include air sampling, training and strategy, sampling methodology, frequency, duration, and qualifications of air monitoring personnel.

02 83 33.13 - 7

G. Respiratory Protection Program: Establish and implement program required by 29 CFR Part 1910.134, 29 CFR Part 1910.1025, and

29 CFR Part 1926.62.

1. Provide each employee negative pressure or other appropriate respirator.

a. Test fit each employee's respirator at initial fitting and maximum 6-month intervals, as required by 29 CFR Part 1926.62.

H. Hazard Communication Program: Establish and implement program required by 29 CFR Part 1910.1200.

I. Hazardous Waste Management Plan: Establish and implement plan according to applicable requirements of Federal, State, and local hazardous waste regulations including the following:

1. Identification of hazardous wastes associated with work.

2. Estimated quantities of generated and disposed waste.

3. Names and qualifications of each contractor transporting, storing, treating, and disposing wastes. Include facility location and

24-hour point of contact. Provide two copies of EPA, state and/or local hazardous waste permits.

4. Names and qualifications (experience and training) of personnel working on-site with hazardous wastes.

5. List of required waste handling equipment including cleaning, volume reduction, and transport equipment.

6. Spill prevention, containment, and cleanup contingency implementation measures.

7. Work plan and schedule for waste containment, removal, and disposal with daily waste cleaned up and containerization.

8. Hazardous waste disposal cost.

1.8 WARRANTY

A. Construction Warranty: FAR clause 52.246-21, "Warranty of

Construction."

PART 2 - PRODUCTS

2.1 PAINT REMOVAL PRODUCTS

A. Chemical Stripper: Biodegradable, non-toxic, capable of removing existing paint layers in one application, and acceptable to CIH.

02 83 33.13 - 8

2.2 ACCESSORIES

A. Waste Collection Drums: 49 CFR Part 178; Type 1A2, steel, removable head, 200 L (55 gal.) capacity, capable of containing waste without loss.

B. Vacuum Cleaner: HEPA filtered type.

C. Scrapers:

1. Metal type for use on metal, concrete, and masonry surfaces.

2. Plastic type for use on wood, plaster, gypsum board, and other surfaces.

D. Rinse Water: Potable.

E. Cleaning Cloths: Cotton.

PART 3 - EXECUTION

3.1 EXAMINATION

A. Before exposure to lead-contaminated dust, provide workers with comprehensive medical examination required by 29 CFR Part 1926.62 (I)

(1) (i) and (ii).

1. Exemption: Examination is not required when employee medical records show last examination required by 29 CFR Part 1926.62(I) was completed within previous 12 months.

B. Maintain complete and accurate employee medical records according to

29 CFR Part 1910.20.

C. Train each employee performing paint removal, disposal, and air sampling operations according to 29 CFR Part 1926.62.

1. Certify training is completed before employee is permitted to work on project and enter lead control area.

3.2 PREPARATION

A. Protect existing work indicated to remain.

1. Perform paint removal work without damaging and contaminating adjacent work.

2. Restore damage and contamination to original condition.

B. Notify Contracting Officer 10 days before starting paint removal work.

C. Lead Control Area Requirements:

1. Establish lead control area by completely enclosing lead-based paint and lead-containing materials removal work area within negative pressure containments with HEPA filtered exhaust screens.

02 83 33.13 - 9

2. Contain removal operations using negative pressure full containment system with minimum one change room and HEPA filtered exhaust.

D. Boundary Requirements: Provide physical boundaries around lead control area by providing critical barrier containment or other enclosures to ensure that airborne lead concentrations do not meet or exceed action level outside of lead control area.

E. Heating, Ventilating and Air Conditioning (HVAC) Systems: Shut down, lock out, and isolate HVAC systems supplying exhausting, and passing through lead control areas. Seal HVAC inlets and outlet within lead control area with 6-mil plastic sheet and tape. Tape seal seams in HVAC components passing through lead control area.

F. Change Room and Shower Facilities: Provide clean change rooms and shower facilities within physical boundary around lead control area according to 29 CFR Part 1926.62.

G. Mechanical Ventilation System:

1. Provide ventilation system to control personnel exposure to lead according to 29 CFR Part 1926.57.

2. Design, construct, install, and maintain HEPA filtered fixed local exhaust ventilation system according to ANSI Z9.2 and approved by

CIH.

3. Exhaust ventilation air to exterior wherever possible.

4. When exhaust ventilation air must be recirculated into work area, provide HEPA filter with reliable back-up filter and controls to monitor lead concentration in return air and to bypass recirculation system automatically when system fails.

H. Personnel Protection: Provide and use required protective clothing and equipment within lead control area.

I. Warning Signs: Provide warning signs complying with 29 CFR Part 1926.62 at lead control area approaches. Locate signs so personnel read signs and take necessary precautions before entering lead control area.

3.3 WORK PROCEDURES

A. Remove lead-based paint according to approved lead-based paint removal plan.

1. Perform work only in presence of CIH or Industrial Hygienist (IH)

Technician under direction of CIH ensuring continuous inspection of work in progress and direction of air monitoring activities.

02 83 33.13 - 10

2. Handle, store, transport, and dispose lead or and lead contaminated waste according to 40 CFR Part 260, 40 CFR Part 261, 40 CFR Part 262, 40 CFR Part 263, 40 CFR Part 264, and

40 CFR Part 265. Comply with land disposal restriction notification requirements as required by 40 CFR Part 268.

B. Use procedures and equipment required to limit occupational and environmental lead exposure when lead-based paint is removed according to 29 CFR Part 1926.62.

C. Dispose removed paint and waste according to Environmental Protection

Agency (EPA), federal, state, and local requirements.

D. Personnel Exiting Procedures:

1. When personnel exit lead control area, comply with the following procedures:

a. Vacuum exposed clothing surfaces.

b. Remove protective clothing and equipment in decontamination room. Place clothing in approved impermeable disposal bag.

c. Shower.

d. Dress in clean clothes before leaving lead control area.

E. Monitoring - General:

1. Monitor airborne lead concentrations according to

29 CFR Part 1910.1025by testing laboratory as directed by CIH.

2. Take personal air monitoring samples on employees anticipated to have greatest exposure risk as determined by CIH. Additionally, take air monitoring samples on minimum 25 percent of work crew or minimum of two employees, whichever is greater, during each work shift.

3. Submit results of air monitoring samples, signed by CIH, within 24 hours after taking air samples. Notify Contracting Officer's

Representative immediately of lead exposure at or exceeding action level outside of lead control area.

F. Monitoring During Paint Removal:

1. Perform personal and area monitoring during entire paint removal operation.

2. Conduct area monitoring at physical boundary daily for each work shift to ensure unprotected personnel are not exposed above action level anytime.

3. For outdoor operations, take at least one sample on each shift leeward of lead control area. When adjacent areas are contaminated, 02 83 33.13 - 11 clean area of contamination and have CIH visually inspect and certify lead contamination is cleaned.

4. Stop work when outside boundary lead levels meet or exceed action level. Notify Contracting Officer's Representative, immediately.

5. Correct conditions causing increased lead concentration as directed by CIH.

6. Review sampling data collected during work stoppage to determine if conditions require additional work method modifications as determined by CIH.

7. Resume paint removal when approved by CIH.

3.4 LEAD-BASED PAINT REMOVAL

A. Remove paint within areas indicated on drawings completely exposing substrate. Minimize damage to substrate.

B. Comply with paint removal processes described lead paint removal plan.

C. Lead-Based Paint Removal: Select processes for each application to minimize work area lead contamination and waste.

3.5 SUBSTRATE SURFACE PREPARATION

A. Protect substrates from deterioration and contamination until refinished.

1. Protect metal substrates from flash rusting.

B. Prepare and paint substrates according to Section 09 91 00, PAINTING.

3.6 FIELD QUALITY CONTROL

A. Field Tests: Performed by testing laboratory specified in Section

01 45 29, TESTING LABORATORY SERVICES.

B. Perform sampling and testing for:

1. Air monitoring.

2. Lead based paint.

3.7 CLEANING AND DISPOSAL

A. Cleaning:

1. Maintain lead control area surfaces free of accumulating paint chips and dust. Confine dust, debris, and waste to work area.

2. Vacuum clean work area daily, at end of each shift, and when paint removal operation is complete.

B. CIH Certification: Certify in writing that inside and outside lead control area air monitoring samples are less than action level, employee respiratory protection was adequate, the work was performed

02 83 33.13 - 12 according to 29 CFR Part 1926.62, and no visible accumulations of lead-based paint and dust remain on worksite.

1. Do not remove lead control area or roped-off boundary and warning signs before Contracting Officer's Representative's receipt of CIH's certification.

2. Reclean areas showing dust or residual paint chips.

C. Testing: Where indicated and when directed by Contracting Officer's

Representative, test lead-based paint residue and used abrasive according to 40 CFR Part 261 for hazardous waste.

D. Waste Collection:

1. Collect lead-contaminated materials including waste, scrap, debris, bags, containers, equipment, and clothing, which may produce airborne lead contamination.

2. Place lead contaminated materials in waste disposal drums. Label each drum identifying waste type according to 49 CFR Part 172 and date waste materials were first put into drum. Obtain and complete the Uniform

Hazardous Waste Manifest forms. Comply with land disposal restriction notification requirements required by 40 CFR Part 268:

3. Coordinate temporary storage location on project site with Contracting

Officer's Representative.

E. Waste Disposal:

1. Minimum 14 days before delivery, notify Contracting Officer's

Representative who will arrange for job site inspection of drums and manifests by paint disposal facility personnel.

2. Contracting Officer's Representative will arrange hazardous wastes removal, transport and delivery to paint disposal facility to ensure drums do not remain on project site longer than 90 calendar days from drum label date.

F. Waste Disposal:

1. Do not store hazardous waste drums in temporary storage location longer than 90 calendar days from drum label date.

2. Remove, transport, and deliver drums to paint disposal facility.

a. Obtain signed receipt including date, time, quantity, and description of materials received according to 40 CFR Part 262.

b. Obtain final report of materials disposition after disposal completion.

- - - E N D - - -

Appendix A

Material Location Drawing &

Lead-Based Paint Re-Inspection Report

Limited Lead Based Paint (LBP) XRF Survey Report

2418 MERRIAM LANE

KANSAS CITY, KS 66106

Report Prepared For:

Valhalla Engineering Group

Englewood, CO 80110

Project:

Limited LBP XRF Survey Project Number 657-19-117JB (VEG 19.23)

Implement Sterile Processing Ventilation Requirements

Building 1 - St. Louis VAMC

TES Project #: 20047ALM.01

January 21, 2020

A Full Service Environmental Consulting and Testing Firm P.O. Box 410295, Kansas City, MO 64141 Phone: 913-432-5500 Fax: 913-432-0704

January 21, 2020 TES Project# 20047ALM.01

Valhalla Engineering Group, LLC

Englewood, CO 80110

RE: Limited LBP XRF Survey

Project Number 657-19-117JB (VEG 19.23) Implement Sterile Processing Ventilation Requirements Building 1 - St. Louis VAMC

Dear Client:

Please find enclosed the limited component-specific LBP XRF survey report for Building 1 at the V.A. Medical Center located at 1 Jefferson Barracks Dr., St. Louis, MO. The limited lead-based paint survey was performed by Titan Environmental Services, Inc. (MO License # 060130-004227, Expiration January 30, 2020), following the Housing and Urban Development (HUD) Guidelines Chapter 7 (revised 2012) and all applicable local and State regulations.

The purpose of the limited survey was to assess the presence of lead-based paint on building components associated with the Basement project work area that may be impacted during the Implementation of Sterile Processing Ventilation Requirements. The limited impact-specific LBP XRF survey was performed on January 10, 2020.

Travis Taylor, MO Certified Lead-based Paint Inspector/Risk Assessor (License # 170717- 300005280, Expiration date: July 17, 2021) conducted the limited survey. The limited LBP XRF survey was performed through the use of a Heuresis Pb200i Series X-Ray Fluorescence (XRF) testing instrument, serial # 1045.

XRF TESTING

Upon arriving on-site, the LBP inspector conducted the initial calibration procedures for the XRF instrument, using a National Institute of Standards and Technology (NIST) LBP calibration paint film, standardized to 1.02 mg/cm2. The results of the initial calibration indicated that the instrument was functioning within the 0.3 mg/cm2 calibration check variation tolerance limits.

Following completing the initial calibration, a total of one-hundred and forty-three (143) individual tests (assays) were performed on impact specific components within the areas of work that may be impacted through planned renovation and demolition activities. Results from the XRF testing indicated that eight (8) of the painted surfaces tested contain LBP at or above the existing action level of 1.0 mg/cm2, the level at which HUD and the EPA consider surface coatings to be lead-based. The testing locations, LBP components and positive readings are outlined in the table below.

SAMP

BUILDING LOCATION COMPONENT SUBSTRATE COLOR COND.

XRF Reading

(mgcm2)

8 GE17 Wall Plaster White Intact 10.3

20 GE19 Wall Plaster White Intact 8.9

26 GE19 Wainscot Ceramic Gray Intact 20.7

74 GE32 Wainscot Ceramic Gray Intact 19.6

88 GE22 Wainscot Ceramic Off-White Intact 12.2

89 GE22 Sink Porcelain White Intact 3.8

SAMP

BUILDING LOCATION COMPONENT SUBSTRATE COLOR COND.

XRF Reading

(mgcm2)

98 GE23 Shower Wall Ceramic Off-White Intact 13.9

141 GE29 Wall Ceramic White Intact 18.9

According to Chapter 7 HUD guidelines (Second Edition, 2012), if one testing combination (i.e. walls, or ceilings, etc.) is positive for lead in an interior or exterior room equivalent, then all other similar testing combinations in those areas are also assumed to be positive for lead.

Those components which were found to contain LBP and which were in intact condition should be monitored by the owner of the property; any further deterioration of components or components that are already in poor condition should undergo corrective action (i.e., scrapping, priming and painting) to maintain the LBP surface.

Please note that while the testing and reporting was performed in accordance with the HUD Guidelines Chapter 7 Regulations for lead-based paint inspections, the entire structure was not tested.

Some inspectors and risk assessors test non-paint surfaces such as unpainted ceramic tile and porcelain bathtubs for lead content because these items can be a source of high levels of lead dust causing cross contamination outside of work areas and potential airborne lead exposure for workers during demolition or renovation. For this reason, some inspectors and risk assessors include ceramic tile and bathtubs in pre-rehabilitation inspections/risk assessments and reference the OSHA lead in construction standard (29 CFR 1926.62) in their reports.

GENERAL REQUIREMENTS

XRF testing has indicated detectable concentrations of lead present in the existing coatings that may be impacted as a part of the planned Implementation of Sterile Processing Ventilation Requirements project. The OSHA Lead in Construction Standard (29 CFR 1926.62) requires that controls be implemented if any detectable concentrations of lead are present.

The OSHA Compliance Directive issued for the OSHA Lead in Construction Standard, Instruction CPL 2- 2.58, states that if an employer has appropriately tested for lead (e.g., tested all layers of paints or coatings that may be disturbed) utilizing a valid detection method, and found no detectable levels of lead, then the standard does not apply. However, in this case, paints with detectable concentrations of lead require the contractor performing the work to implement lead-safe work practices and assess actual employee exposures during the work in accordance 29 CFR 1926.62.

Based on the findings of our limited survey, 29 CFR 1926.62 must be invoked during the Implementation of Sterile Processing Ventilation Requirements project that will disturb the lead-based paint during renovation and demolition activities. It should be noted that other hazardous metals can also be present in coatings. Any disturbance of paint containing heavy metals in addition to lead must be performed in accordance with the requirements of the applicable OSHA standards.

In addition, containment will be required for the protection of the environment and the public, and any hazardous waste must be properly managed.

Any contracting firm tasked to impact (i.e., scrape, drill/core, demo, etc.) lead based surface coated components (i.e., plaster walls) associated with the above referenced project shall at least be a Certified EPA Lead Safe Renovation Firm and employ at least Certified EPA Lead Safe Renovators and shall implement all required lead safe work practices during the work in accordance with applicable EPA and OSHA Regulations.

CLOSING COMMENTS

TES has performed the tasks set forth above in a thorough and professional manner consistent with industry standards. The limited component-specific LBP XRF survey was performed by TES at the request of the client. Consequently, TES cannot guarantee and does not warrant that this limited assessment has revealed all lead-based surface coatings and other adverse environmental conditions affecting the site.

The results reported and any opinions reached by TES are for the benefit of the client. The results and opinions set forth by TES in its report will be valid as of the date of the report.

TES appreciates the opportunity to be of assistance to you and Valhalla Engineering. If you have any questions, please don’t hesitate to contact us.

Respectfully, Travis Taylor MO LBP Risk Assessor

Attachments –

1. Lead-Based Paint (LBP) Component Location Drawings

2. Representative LBP Component Photo Log

3. LBP XRF Survey Results Spreadsheet

4. Individual & Corporate Licenses

Attachment 1:

Lead-Based Paint (LBP)

Component Location Drawings

Attachment 2:

Representative LBP Component Photo Log

Attachment 3:

LBP XRF Survey Results Spreadsheet

Attachment 4:

Individual & Corporate Licenses