Taos Lead Inspection Report.pdf

LEAD-BASED PAINT INSPECTION

At

TAOS SERVICE UNIT

Taos Hospital Building 2000 for

Albuquerque Area Indian Health Service Division of Health Facilities 5300 Homestead Road, NE

Albuquerque, New Mexico 87110

By

U.S. Public Health Service Federal Occupational Health

2201 Sixth Avenue, M/S Rx-21 Seattle, Washington 98121-2500

September 2007

FOR INFORMATIONAL PURPOSES ONLY

TABLE OF CONTENTS

Section Title Page No.

1.0 INTRODUCTION 1

2.0 SURVEY METHODOLOGIES 1

2.1 XRF INSTRUMENTATION 1

2.2 XRF CALIBRATION CHECK 2

2.3 SUBSTRATE CORRECTION 2

2.4 FIELD DOCUMENTATION 2

3.0 LEAD-BASED PAINT DEFINITIONS 2

4.0 RESULTS SUMMARY 3

5.0 PROJECT LIMITATIONS 3

Appendices

A TABLES OF XRF FIELD DATA AND CALIBRATIONS

B SITE MAP

C CERTIFICATIONS

1.0 INTRODUCTION

A Lead-Based Paint (LBP) Inspection was conducted at Building 2000 at the Indian Health Service (IHS), Taos Service Unit, in Taos, New Mexico on December 21, 2006. The purpose of the inspection was to identify lead in paint on interior and exterior painted surfaces. Measurements were made using a Niton X-ray Fluorescence (XRF) Spectrum Analyzer. Confirmatory chip sampling for laboratory analysis proved to be unnecessary. Mrs. Suzette Numkena, Lead Inspector/Risk Assessor, representing Federal Occupational Health (FOH), conducted the survey.

Sampling procedures similar to the U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, dated June 1995, and revised in 1997, were followed for the Taos Hospital. Within each area sampled, procedures similar to the HUD multifamily housing inspection, as outlined in Chapter 7 of the HUD Guidelines, were employed.

Building 2000 is a single-story building, medical building. The building appeared to be constructed in a single phase. The interior is approximately 19,982 square feet.

2.0 SURVEY METHODS

2.1 XRF Instrumentation

Measurements of lead in paint were made using a Niton XRF Spectrum Analyzer (serial number XL309- U3978NR6814). The XRF Lead Paint Analyzer non-destructively measures lead concentrations of painted surfaces. The XRF system includes three main components: (1) the XRF analyzer, which is a portable analytical instrument operating on the principles of X-ray fluorescence; (2) forms for recording of field data; and (3) report generation software, which allows for generation of data tables.

The criteria for classifying results obtained using the XRF are as shown in Table 1 below. These results are taken from the HUD/EPA Performance Characteristics Sheet, specific for the XRF system used in this survey.

Table 1: LBP Classification Criteria, K-Shell Value

Substrate Negative Inconclusive Positive

Brick < 0.9 None > 1.0 Concrete < 0.9 None > 1.0 Drywall < 0.9 None > 1.0 Metal < 0.9 None > 1.0 Plaster < 0.9 None > 1.0 Wood < 0.9 None > 1.0

*Values Reported as Milligrams per Square Centimeter (mg/cm2)

FOH Lead Inspectors are licensed by the State of Utah Department of Environmental Quality, Division of Radiation Control, to own and operate x-ray fluorescence analyzers in Utah. FOH representatives obtained a Reciprocity Agreement with the State of Arizona Radiation Regulatory Agency, which allows operation of XRF instruments in New Mexico under the Utah license. Mr. Denny, Mr. Johnson, Ms.

Jury, Mr. Marshall, and Mrs. Numkena, are certified by the United States Environmental Protection Agency (EPA) to perform LBP inspections. Copies of certifications for the Lead Inspectors and/or Risk Assessors can be found in Appendix D.

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2.2 XRF Calibration Check

Standard quality control procedures with respect to the XRF were performed during the survey. The internal calibration of the XRF was checked by taking a minimum of three consecutive measurements on a National Institute for Standards and Technology (NIST) standard with a known concentration of lead.

The results of the calibration checks were then used to verify that the instrument was operating within acceptable limits. These calibration checks are reported within the XRF data tables found in Appendix A of this report and are maintained in a file to detect changes in instrument performance over time.

2.3 Substrate Correction

For some XRF instruments it is necessary to make corrections for bias in XRF readings made on some painted surfaces or "substrates". In accordance with the HUD/EPA Performance Characteristics Sheet for the XRF analyzer used, it is not necessary to correct for substrate bias.

2.4 Field Documentation

Field data forms were used to manually record information about individual XRF measurements. This information included the room number, the building component (such as wall, ceiling, door, baseboard, cabinet, etc.), component substrate (for example drywall, wood, metal, concrete), and paint condition.

The field data forms were then used by the inspector to couple measurement-specific descriptive information to the sequential data once the instrument’s electronic memory was downloaded to a personal computer. This information was then manipulated by the instrument’s software to generate data tables for the written report.

According to the HUD Guidelines, each enclosed space in a structure (e.g., room, stairway, hallway, etc.)

is considered a separate "room equivalent" and must be tested separately. To keep track of where individual measurement locations were made, interior and exterior walls of a structure were designated as A, B, C, and D, as shown in the attached drawings. The A wall was designated as the North wall in this inspection, and the B, C, and D walls are in clockwise order from the A wall. The wall and position on the wall (i.e., left, right, or center) was also recorded when readings were taken on components such as windows or doors. Any comments regarding a particular room were also recorded and may be found in the data tables located in Appendix A.

Paint color and condition are noted and included in the data tables. Under Paint Condition an "I" indicates intact or sound paint; an "F" indicates fair condition (paint surfaces show minor damage); a "P" indicates poor condition (paint is peeling, cracking, or blistering or shows other significant damage).

The report generation software combined the lead readings stored in the XRF analyzer with the test sample location information recorded in the field to produce data tables. The transfer of data from the analyzer to the computer was made through an interface cable supplied as part of the XRF system.

3.0 LEAD-BASED PAINT DEFINITIONS

The U.S. Department of Housing and Urban Development (HUD) considers paint to be lead-based paint (LBP) if the concentration is 1.0 milligram of lead per square centimeter (1.0 mg/cm

) or greater, or if the lead concentration is greater than 5000 parts per million (ppm) or 0.5% by weight. The Consumer Product Safety Commission (CPSC) currently considers paint to be lead-containing if the concentration of lead exceeds 600 ppm (0.06% by weight). In 1978, the CPSC banned the sale of lead-based paint to consumers and its application to areas where consumers have direct access to painted surfaces. This survey classified LBP on the basis of the HUD 1.0 mg/cm criteria and 0.5% by weight (5000 ppm).

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By contrast, the mission of the Occupational Safety and Health Administration (OSHA), with respect to lead in paint, is to protect workers during construction activities that may generate elevated airborne lead concentrations. OSHA states that construction work (including renovation, maintenance, and demolition) carried-out on structures coated with paints that have lead concentrations lower than the HUD or CPSC limits can still result in airborne lead concentrations in excess of regulatory limits. For this reason, OSHA has not defined lead-containing paint, but states that paint having any measurable level of lead may pose a substantial exposure hazard during construction work, depending upon the work performed. The owner or employers must be aware of the OSHA Lead in Construction Standard (29 CFR 1926.62) and the Respiratory Protection Standard (29 CFR 1910.134).

4.0 RESULTS SUMMARY

Lead paint inspection data tables are located in Appendix A of this report. The tables show all lead measurements in the order taken for each of the structures and sampling areas tested. Descriptions of the columns found in the data tables are described in Appendix A.

According to HUD Guidelines, NO lead-based paint was identified at or above 1.0 mg/cm2 on interior building or exterior components sampled during the survey.

5.0 PROJECT LIMITATIONS

This Project was performed using, as a minimum, practices consistent with standards acceptable within the industry at this time, and a level of diligence typically exercised by industrial hygiene and environmental consultants performing similar services.

The procedures used in this investigation attempt to establish a balance between the competing goals of limiting investigative and reporting costs and time, and reducing the uncertainty about unknown conditions. Therefore, because the findings of this report were derived from the scope, costs, time, and other limitations, the conclusions should not be construed as a guarantee that all environmental or occupational hazards have been identified and fully evaluated. Where sample collection and testing have been performed, FOH's professional opinions are based in part on the interpretation of data from discrete sampling locations that may not represent conditions at non-sampled locations. FOH assumes no responsibility for omissions or errors resulting from inaccurate information, or data, provided by sources outside of FOH or from omissions or errors in public records.

Furthermore, it is emphasized that the final decision on how much risk to accept always remains with the client since FOH is not in a position to fully understand all of the client's needs. Clients with a greater aversion to risk may want to take additional actions while others, with less aversion to risk, may want to take no further action.

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APPENDIX A

Tables of XRF Field Data & Calibrations

Data Table Heading Descriptions

Column Heading Description

XL No. Sequential number of each lead measurement

Site Building number or name

Insp Inspector initials

Side Wall (A, B, C, or D) the measurement was taken on

Room Room number shot was taken in

Sub Substrate of tested material (wood, concrete, etc.)

Feat The actual component tested (door, window, etc.)

Cnd Condition of paint (Intact, Fair, Poor)

Clr Color of Paint

Result Negative or Positive for lead content over 1.0mg/cm2

Pbc±Prec Result reported in milligrams per centimeter squared

(mg/cm2).

APPENDIX B

Site Map

U.S. Public Health Service Federal Occupational Heal 2201 Sixth Avenue, M/S R Seattle, Washington 98121

600 601

302 303 304 305 306 307301300

317 308

322 323 324

331 330 329 328

314 313 312

104 604

603 602

701 702

FOR INFORMATIONAL PURPOSES ONLY

th x21 -2500

1410 1

304 1305 Proj ect:

ALBU

1402 1100

NORTH

Functional Space Map

Taos Hospital Building 2000

QUERQUE AREA INDIAN HEALTH SE

TAOS SERVICE UNIT

Taos, New Mexico

0021003

802 04 1201 1202 1203 1204

1 1 9 1208 210 120

3 11 401 402

RVICE

APPENDIX C

Certifications