657-19-117JB - TES_Limited LBP XRF Survey Report.pdf

Limited Lead Based Paint (LBP) XRF Survey Report

2418 MERRIAM LANE

KANSAS CITY, KS 66106

Report Prepared For:

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

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

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

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 750 W. Hampden Ave., Suite 300 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 1 Jefferson Barracks Dr., St. Louis, MO 63125

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