94197779 - Proposed VA Hospital Garland - LBP Inspection Report - DRAFT.pdf

Lead-Based Paint Survey Report

Proposed VA Hospital Garland – Three Buildings

2300 Marie Curie Boulevard

Garland, Texas

June 21, 2019

Terracon Project No. 94197779

Prepared for:

Enapay, LLC

Mesquite, Texas

Prepared by:

Terracon Consultants, Inc.

Dallas, Texas DRAFT

Terracon Consultants, Inc. 8901 Carpenter Freeway, Suite 100 Dallas, Texas 75247

P [214] 630 1010 F [214] 630 7070 terracon.com/dallas

June 21, 2019

Mr. Marshall Hamilton

Enapay, LLC

207 West Main Street

Mesquite, Texas 75149

Telephone: 214-607-0247

E-mail: mjh@enapayllc.com

Re: Lead-Based Pant Survey

Proposed VA Hospital Garland – Three (3) Buildings

2300 Marie Curie Boulevard

Mr. Hamilton:

The purpose of this report is to present the results of the lead-containing paint survey performed

June 10-17, 2019 at the site of the proposed Veterans Administration (VA) Hospital Garland located at 2300 Marie Curie Boulevard, 700 Walter Reed Boulevard, and 900 North Shiloh Road in Garland, Texas. This survey was conducted in general accordance with Terracon Proposal No. P94197779 dated June 6, 2019. We understand this survey was requested due to the VA’s planned acquisition of the property.

Terracon appreciates the opportunity to provide this service to Enapay, LLC. If you have any questions regarding this report, or if you need assistance with project oversight and sampling during renovation or demolition of the on-site structures, please contact the undersigned at (214) 630-

1010.

Sincerely, Terracon Consultants, Inc.

Chad Champagne

Assistant Project Manager - Environmental

TDSHS Lead Risk Assessor License No. 2071012

Greg Calhoun

Senior Associate

Department Manager - Asbestos, Lead & IH Services

DRAFT

mailto:mjh@enapayllc.com

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TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Project Objective

2.0 BUILDING DESCRIPTION

3.0 FIELD ACTIVITIES

3.1 Methodology

3.2 XRF Instrumentation

3.3 XRF Results

4.0 REGULATORY OVERVIEW

5.0 FINDINGS AND CONCLUSIONS

6.0 GENERAL COMMENTS

APPENDIX A: LEAD-BASED PAINT INSPECTION RESULTS

APPENDIX B: XRF PERFORMANCE CHARACTERISTIC SHEET

APPENDIX C: PHOTOGRAPHS

APPENDIX D: DIAGRAMS

APPENDIX E: LICENSES

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LEAD-BASED PAINT INSPECTION REPORT

Proposed VA Hospital Garland – Three Buildings

2300 Marie Curie Boulevard

1.0 INTRODUCTION

Terracon Consultants, Inc. (Terracon) conducted a limited lead-containing paint inspection of-three (3) buildings on the proposed site of the Veterans Administration (VA) Hospital Garland located at 2300 Marie Curie Boulevard in Garland Texas. Our report presents project information, procedures, visual observations, inspection results, conclusions and recommendations. The purpose of this inspection was to provide information as to whether this building contains lead-based paint (LBP) that may be impacted by upcoming renovations.

1.1 Project Objective

The objective of the LBP inspection was to identify the presence, location and condition of accessible LBP surfaces present on the interior and exterior surfaces of the five-story main hospital structure (2300 Marie Curie Boulevard), a four-story medical plaza (700 Walter Reed

Boulevard), and a single-story storage building (900 North Shiloh Road) located in Garland, Texas.

The LBP sampling was conducted in general accordance with the 1997 revision of HUD Guidelines, Chapter 7.

U. S. Department of Housing and Urban Development (HUD) and U. S. Environmental Protection

Agency (EPA) guidelines establish an action level for lead-containing painted surfaces of 1.0 milligram per square centimeter (1.0 mg/cm2) as determined using an X-ray fluorescence (XRF) analyzer. The U.S. Occupational Safety and Health Administration (OSHA), however, considers paint containing any level of lead above the analytical method detection limit a potential hazard which should be communicated to any employees or contractors who may disturb the materials in the course of their assigned work.

OSHA recognizes that HUD and the EPA find XRF analyzers acceptable for analyzing lead in paint at their clearance level of 1.0 mg/cm2. They also recognize that some instruments can measure accurately at substantially lower levels. However, please be aware that while XRF analyzers may be an acceptable method of analysis for meeting HUD/EPA requirements, OSHA's concerns are different from those of HUD and EPA.

OSHA does not consider any method that relies solely on the analysis of bulk materials or surface content of lead (or other toxic material) to be acceptable for safely predicting employee exposure to airborne contaminants. Without air monitoring results or without the benefit of historical or objective data (including air sampling which clearly demonstrates that the employee cannot be exposed above the action level during any process, operation, or activity) the analysis of bulk or surface samples cannot be used to determine employee airborne exposure.

Lead-Based Paint Inspection

2300 Marie Curie Boulevard ■ Garland, Texas

June 21, 2019 ■ Terracon Project No. 94197779

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2.0 BUILDING DESCRIPTIONS

Main Hospital – 2300 Marie Curie Boulevard

Building

Five-story hospital building with a basement constructed circa 1970 with additions, including the plaza building, constructed circa 1975, 1999, and 2003

Total Area 167,236 square feet (sq. ft.)

Roof Multi-level roofing system finished with tar and gravel and rolled-on asphalt roofing

Exterior Walls Brick, painted concrete masonry unit (CMU), and painted wood siding

Interior Description

Occupied inpatient mental health clinic, offices, exam rooms, x-ray rooms, procedure rooms, operating rooms, pharmaceutical rooms, break rooms, conference rooms, corridors, restrooms, electrical rooms, mechanical rooms, elevator lobbies, and stairwells

Interior Walls

Textured drywall, textured concrete, textured concrete masonry unit

(CMU) blocks, wainscoting on drywall, wall covering on drywall, and ceramic tile on drywall

Interior Ceilings

Textured drywall and 2’x4’ and 2’x2’ lay-in ceiling tile suspended from a concrete deck; spray-on fireproofing was observed in various areas throughout the main hospital on the concrete deck and on the metal decks of the stairwells

Interior Floors Unfinished concrete, terrazzo, floor coating, resilient floor covering, vinyl floor tile, carpet, and ceramic tile on a concrete substrate

Survey Limitations/

Inaccessible Areas

The fourth and fifth floors were occupied by an inpatient mental health clinic; although the remaining areas of the building were largely vacant, a significant number of the rooms were locked or used as storage space. Various areas of the vacant spaces had limited lighting or no lighting. Debris and remnant furnishings were observed in various vacant areas throughout the interior of the building. Hard ceilings were installed in various areas throughout the interior of the building.

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Plaza Building – 700 Walter Reed Boulevard

Building Four-story, multi-tenant medical building attached to the main hospital building

Total Area (Included with the main building)

Roof Rubber membrane, rolled-on composition roofing material

Exterior Walls Texture on concrete and texture on plaster

Interior Description

Offices, exam rooms, x-ray rooms, procedure rooms, operating rooms, break rooms, conference rooms, corridors, restrooms, electrical rooms, mechanical rooms, elevator lobbies, and stairwells

Interior Walls

Textured drywall, textured concrete, textured CMU blocks, textured plaster, unfinished drywall, fiberglass reinforced panel on drywall, wall covering on drywall, and ceramic tile on drywall

Interior Ceilings

Textured drywall and 2’x4’ and 2’x2’ lay-in ceiling tile suspended from a concrete deck; spray-on fireproofing was observed on the concrete deck

Interior Floors Unfinished concrete, floor coating, resilient floor covering, vinyl floor tile, raised flooring, carpet, and ceramic tile on a concrete substrate

Survey Limitations/

Inaccessible Areas

Multiple medical suites located in various area of the building were occupied and operational at the time of the survey. The tenants of the occupied suites did not allow unlimited access and access was not granted to the final suite until June 14, 2019. Although the remaining areas of the building were largely vacant, a significant number of the rooms were locked or used as storage space.

Various areas of the vacant spaces had limited lighting or no lighting. Debris and remnant furnishings were observed in various vacant areas throughout the interior of the building. Hard ceilings were installed in various areas throughout the interior of the building.

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Storage Building – 900 North Shiloh Road

Building Single-story medical building constructed circa 1968

Total Area 19,881 sq. ft.

Roof Tar and gravel roofing system

Exterior Walls Texture on concrete and CMU blocks

Interior Description

Reception, exam rooms, offices, meeting rooms, conference rooms, corridors, restrooms, boiler room, electrical room, warehouse, and shipping/receiving

Interior Walls Textured concrete, textured drywall, wall covering on drywall, ceramic tile on drywall, and fiberglass reinforced panel on drywall

Interior Ceilings 2’ x 4’ lay-in ceiling tile system suspended from a concrete deck

Interior Floors Epoxy floor coating, vinyl floor tile, carpet, and ceramic tile on a concrete substrate and unfinished concrete

Survey Limitations/

Inaccessible Areas

The vacant building is currently being used for storage; debris and remnant furnishings were observed throughout the interior of the building.

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3.0 FIELD ACTIVITIES

The survey was conducted by the following Texas Department of State Health Services (TDSHS) certified lead risk assessors:

◼ Mr. Chad Champagne, TDSHS Lead Risk Assessor Certificate No. 2071012

◼ Mr. Andrew Cassidy, TDSHS Lead Risk Assessor Certificate No. 2071119

Copies of the licenses are attached in Appendix E. The LBP sampling was conducted in general accordance with the 1997 revision of HUD Guidelines, Chapter 7. A summary of survey activities is provided in the following sections.

3.1 Methodology

A Niton XLp XRF Analyzer and a Heuresis Pb200i XRF Paint Analyzer were used to determine whether a surface coating was LBP.

Each building was evaluated to identify different testing combinations present. Per HUD Guidelines for testing, individual tests are to be classified as part of a group based on the testing combination

(room equivalent, component, and substrate). Substrates are classified as brick, masonry, concrete, drywall, metal, plaster, or wood. A component is defined as an item, such as doors, windows, walls, etc. When using testing combinations, lead-containing paint results are classified by summing the individual component test results of positive, negative, or inconclusive.

For more detailed information, including testing location, component, color, and substrate, refer to the

XRF testing results contained in Appendix A.

Visual Assessment

Terracon conducted a visual assessment of accessible areas on the interior and exterior of each building. The visual assessment included evaluating the condition of the building area and the condition of painted surfaces. The information gathered in the visual assessment was utilized in determining the testing combinations for the LBP inspection.

Wall and Component Identification System

Perimeter Walls: Perimeter wall sides are identified with letters A, B, C, and D. Side A in a building is the entry door side. Sides B, C, and D are identified clockwise, starting from the “9 o’clock" position from Side A; thus, Side B is to the left, Side C is across from Side A, and Side D is to the right of Side

A.

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Interior Walls: Interior wall sides are identified with letters. Side A is the wall from which you enter from in each Room Equivalent. The remaining walls are identified clockwise from Side A; thus, Side A is the wall from which you entered, Side B is to the left, Side C is directly in front, and Side D is to the right.

Component: The component field is a representation of the specific testing building component sampled within the room. Each component is given a numerical value to differentiate it from other components. For example, if there are two windows on wall A, and you are testing the right window, start from left to right and mentally number the windows (i.e., 1 and 2). Thus, the window being tested within the room equivalent is window 2.

3.2 XRF Instrumentation

Terracon utilized a Niton XLp XRF (Serial Number 25496) Analyzer and a Heuresis Pb200i XRF Paint

Analyzer (Serial Number 2029) to conduct the lead-containing paint inspection. Both XRF analyzers were operated in the “Standard Mode” for this project. No substrate correction is recommended for brick, concrete, drywall, metal, plaster, or wood when these instruments are operated in Standard

Mode.

Each instrument was used in general accordance with HUD inspection guidelines and the procedures detailed in the manufacturers’ XRF Performance Characteristics Sheet (PCS) contained in Appendix

B. Under HUD guidelines, a lead measurement requires that a reading be taken with a 95% confidence level. This means that the actual measured lead value must exceed the regulatory action level by at least twice the uncertainty value to be considered valid. Uncertainty is not a constant value; it depends on time, measurement, substrate, and the actual lead concentration. In Standard Mode, the Niton XLP

XRF and the Heuresis Pb200i XRF automatically incorporate these factors to yield 95% confidence readings. XRF analytical results are expressed as a weight per area. LBP is defined by XRF readings

>1.0 mg/cm2.

Calibration of the Niton XLp and the Heuresis Pb200i XRF Paint Analyzer is performed by the manufacturer. This calibration involves measurement of known lead films (NIST reference standards) placed on different building material substrates. The data from the resultant spectra are incorporated into a mathematical function. This function, a component of proprietary software, is used to calculate concentrations of lead.

The accuracy of the field measurement depends on three factors. The first is the quality of the reference standard lead film prepared by NIST. The second factor is accuracy of the mathematical function (i.e., the difference between the calculated concentrations and actual concentrations). Third, the similarity between the building material samples used during calibration and the building materials encountered in the field can impact the accuracy of the measurement.

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Calibration checks are performed at least twice daily: once prior to the inspection and once immediately after the inspection, with additional checks performed after each 4 hours of continuous use (see

Appendix A for calibration results), using protocols provided by HUD and the instrument manufacturer according to the NIST reference standard.

3.3 XRF Results

3,356 XRF readings were taken from testing combinations observed on the interior and exterior of the five-story main hospital building located at 2300 Marie Curie Boulevard. One hundred twenty-five

(125) XRF readings were above the HUD and EPA action level for LBP of 1.0 mg/cm2.

836 XRF readings were taken from testing combinations observed on the interior and exterior of the four-story medical plaza building located at 700 Walter Reed Boulevard. Six (6) XRF readings were above the HUD and EPA action level for LBP of 1.0 mg/cm2.

334 XRF readings were taken from testing combinations observed on the interior and exterior of the single-story storage building located at 900 North Shiloh Road. Three (3) XRF readings were above the HUD and EPA action level for LBP of 1.0 mg/cm2.

No readings measured as inconclusive. For further information regarding the components tested see

XRF testing results in Appendix A.

4.0 REGULATORY OVERVIEW

The Department of Housing and Urban Development (HUD) has issued guidelines titled Guidelines for the Evaluation and Control of Lead Based Paint Hazard in Housing pursuant to Title X of the

Housing and Community Development Act of 1992. The US Environmental Protection Agency (EPA) and HUD action level for lead-containing painted surfaces is 1.0 milligram per square centimeter (1.0 mg/cm2) using the X-ray fluorescence analyzer (XRF) method, or 0.5% dry weight using the atomic absorption analytical method.

The State of Texas has established the Texas Environmental Lead Reduction Rules (TELRR) to establish the means to control and minimize public exposure to lead by regulating lead-containing paint activities in target housing and child-occupied facilities. The TELRR contains procedures and requirements for the accreditation of lead training providers, procedures and requirements for the certification of individuals and firms engaged in lead-containing paint activities and standards for performing such activities in target housing and child-occupied facilities. The

TELRR also requires that all lead-containing paint activities in target housing and child-occupied facilities be performed by certified individuals. However, the subject buildings at the proposed site DRAFT

Responsive ■ Resourceful ■ Reliable 8 of VA Hospital Garland do not meet the definition of a child-occupied facility or target housing, and therefore is exempt from the TELRR.

The OSHA Lead Standard for Construction (29 CFR 1926.62) applies to construction work where an employee may be occupationally exposed to lead. All work related to construction, alteration, or repair (including painting and decorating) is included. The lead-in-construction standard applies to any detectable concentration of lead in paint. OSHA considers paint containing any level of lead above the analytical method detection limit a potential hazard which should be communicated to any employees or contractors who may disturb the materials in the course of their assigned work. Due to the nature of the site, the OSHA regulations will apply to the construction and/or demolition activities, since the site does not meet the definition of a child occupied facility or target housing.

OSHA does not consider any method that relies solely on the analysis of bulk materials or surface content of lead (or other toxic material) to be acceptable for safely predicting employee exposure to airborne contaminants. Without air monitoring results or without the benefit of historical or objective data (including air sampling which clearly demonstrates that the employee cannot be exposed above the action level during any process, operation, or activity) the analysis of bulk or

Compliance with applicable OSHA lead regulations is the responsibility of the contractor performing the work and it is recommended that they be required to communicate potential lead hazards to their workforce and utilize lead-safe work practices such as outlined in the EPA

Renovation, Repair, and Painting Final Rule (40 CFR 745) or applicable portions of the Structural

Steel Painting Council (SSPC) Guidelines. It is further recommended that activities such as flame/torch dismantling, dry sanding and/or dry grinding of any components with lead-containing materials applied should be prohibited as part of any repair, renovation or demolition activity.

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5.0 FINDINGS AND CONCLUSIONS

LBP was identified in the evaluation performed on the proposed site of the VA Hospital Garland.

The following LBP were observed “poor” condition and may present a potential hazard:

Main Hospital Building at 2300 Marie Curie Boulevard

◼ Beige paint on 3rd floor elevator equipment room metal door casing (XRF reading 1562) and beige paint on 3rd floor elevator equipment room metal door jamb (XRF reading 1523)

Storage Building at 900 North Shiloh Road

◼ Tan paint on metal exterior roof access ladder (XRF reading 39) and white paint on hallway

7M plaster wall (XRF reading 278)

The following table presents XRF readings identifying lead concentrations above the HUD and EPA action level for LBP of 1.0 mg/cm2:

Reading

Number

Reading

Location Component

Lead

Concentration

(mg/cm2)

Main Hospital Building - 2300 Marie Curie Boulevard

7 5th Floor – Medical Records Pink paint on side A drywall wall 5.4*

12 5th Floor – Dietary Room White paint on side A drywall wall 7.3*

1st Floor – Administrative Conference

Room Gray paint on side C drywall 7.8*

1540 3rd Floor C11 Elevator Lobby Beige paint on side A metal door casing 1.7

1541 3rd Floor C11 Elevator Lobby Beige paint on side A metal door jamb 1.3

1547 3rd Floor C11 Elevator Lobby Beige paint on side C metal door 3.3

1548 3rd Floor C11 Elevator Lobby Beige paint on side C metal door casing 2.6

1549 3rd Floor C11 Elevator Lobby Beige paint on side C metal door jamb 3.5

1550 3rd Floor C12 White paint on side A metal door casing 2.9

1554 3rd Floor Exit Stair 1 Beige paint on side A metal door casing 3.4

1555 3rd Floor Exit Stair 1 Beige paint on side A metal door jamb 3.8

1556 3rd Floor Exit Stair 1 Beige paint on side A metal door 2.8

1562 3rd Floor Elevator Equipment Room Beige paint on side A metal door casing 1.9

1563 3rd Floor Elevator Equipment Room Beige paint on side A metal door jamb 3.2

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Number

Reading

Location Component

Lead

Concentration

(mg/cm2)

1998 1st Floor X-Ray 2 Beige paint on side A drywall wall 7.4*

1999 1st Floor X-Ray 2 Beige paint on side B drywall wall 5.4*

2000 1st Floor X-Ray 2 Beige paint on side C drywall wall 5.0*

2001 1st Floor X-Ray 2 Beige paint on side D drywall wall 5.7*

2002 1st Floor X-Ray 2 Beige paint on side D window casing 13.3*

2003 1st Floor CT Room Beige paint on side A door casing 8.6*

2004 1st Floor CT Room Beige paint on side A door jamb 6.1*

2005 1st Floor CT Room Beige paint on side A drywall wall 6.4*

2006 1st Floor CT Room Beige paint on side B drywall wall 5.4*

2007 1st Floor CT Room Beige paint on side C drywall wall 4.7*

2009 1st Floor CT Room Beige paint on side B drywall wall 6.0*

2010 1st Floor CT Room Beige paint on side D window casing 13.5*

2069 1st Floor Room D14 Beige paint on side B drywall wall 1.3

2071 1st Floor Room D14 Beige paint on side B drywall wall 1.0

2191 1st Floor Room 155-3 White paint on side D window casing 4.0*

2342 1st Floor OR 12 White paint on side A plastic wall 5.1*

2343 1st Floor OR 12 White paint on side B plastic wall 4.9*

2344 1st Floor OR 12 White paint on side C plastic wall 5.1*

2346 1st Floor OR 12 White paint on side D plastic wall 5.2*

2369 1st Floor OR 11 White paint on side A plastic wall 4.9*

2370 1st Floor OR 11 White paint on side B plastic wall 5.2*

2371 1st Floor OR 11 White paint on side C plastic wall 5.0*

2372 1st Floor OR 11 White paint on side D plastic wall 5.3*

2377 1st Floor OR 10 White paint on side A plastic wall 7.1*

2378 1st Floor OR 10 White paint on side B plastic wall 5.2*

2379 1st Floor OR 10 White paint on side C plastic wall 6.8*

2380 1st Floor OR 10 White paint on side D plastic wall 5.3*

2392 1st Floor OR 9 White paint on side A plastic wall 4.7*

2393 1st Floor OR 9 White paint on side B plastic wall 5.0*

2394 1st Floor OR 9 White paint on side C plastic wall 4.6*

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Number

Reading

Location Component

Lead

Concentration

(mg/cm2)

2395 1st Floor OR 9 White paint on side D plastic wall 5.1*

2399 1st Floor OR 8 White paint on side A plastic wall 4.4*

2400 1st Floor OR 8 White paint on side B plastic wall 5.3*

2401 1st Floor OR 8 White paint on side C plastic wall 5.2*

2402 1st Floor OR 8 White paint on side D plastic wall 5.0*

2430 1st Floor X-Ray Room Beige paint on side A metal door casing 11.7*

2431 1st Floor X-Ray Room White paint on side A plastic wall 10.0*

2432 1st Floor X-Ray Room White paint on side B plastic wall 9.9*

2433 1st Floor X-Ray Room White paint on side C plastic wall 9.5*

2434 1st Floor X-Ray Room White paint on side D plastic wall 9.1*

2560 1st Floor Cath Lab 2 Beige paint on side B metal window casing 11.8*

2561 1st Floor Cath Lab 2 White paint on side A drywall wall 4.6*

2562 1st Floor Cath Lab 2 White paint on side B drywall wall 6.3*

2564 1st Floor Cath Lab 2 White paint on side D drywall wall 5.7*

2580 1st Floor Room D63 Beige paint on side A metal window casing 9.8*

2581 1st Floor Room D63 White paint on side A drywall wall 5.5*

2582 1st Floor Room D63 White paint on side B drywall wall 5.7*

2614 1st Floor Radiology Room 5 Beige paint on side A metal door casing 13.6*

2615 1st Floor Radiology Room 5 Beige paint on side A metal door jamb 13.9*

2616 1st Floor Radiology Room 5 Beige paint on side A drywall wall 5.6*

2617 1st Floor Radiology Room 5 Beige paint on side A metal window casing 13.4*

2627 1st Floor Radiology Room 4 Beige paint on side A metal door casing 13.8*

2628 1st Floor Radiology Room 4 Beige paint on side A metal door jamb 13.7*

2629 1st Floor Radiology Room 4 Beige paint on side A drywall wall 5.4*

2631 1st Floor Radiology Room 4 Blue paint on side C drywall wall 5.5*

2632 1st Floor Radiology Room 4 Beige paint on side C metal window casing 13.9*

2633 1st Floor Radiology Room 4 Beige paint on side D drywall wall 4.8*

2638 1st Floor Radiology Room 3 Beige paint on side A metal door casing 10.8*

2639 1st Floor Radiology Room 3 Beige paint on side A metal door jamb 14.1*

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Number

Reading

Location Component

Lead

Concentration

(mg/cm2)

2640 1st Floor Radiology Room 3 Beige paint on side A drywall wall 5.5*

2641 1st Floor Radiology Room 3 Beige paint on side B drywall wall 5.5*

2642 1st Floor Radiology Room 3 Blue paint on side C drywall wall 5.7*

2643 1st Floor Radiology Room 3 Beige paint on side C metal window casing 13.4*

2644 1st Floor Radiology Room 3 Beige paint on side D drywall wall 5.2*

2647 1st Floor Radiology Room 2 Beige paint on side A metal door casing 13.2*

2648 1st Floor Radiology Room 2 Beige paint on side A metal door jamb 13.4*

2649 1st Floor Radiology Room 2 Beige paint on side A drywall wall 5.2*

2650 1st Floor Radiology Room 2 Beige paint on side B drywall wall 5.6*

2651 1st Floor Radiology Room 2 Beige paint on side B metal window casing 14.1*

2652 1st Floor Radiology Room 2 Blue paint on side C drywall wall 5.6*

2653 1st Floor Radiology Room 2 Beige paint on side D drywall wall 5.7*

2681 1st Floor Hallway D69 Beige paint on side A metal door casing 5.8*

2682 1st Floor Hallway D69 Beige paint on side A metal door jamb 5.2*

2686 1st Floor Hallway D69 White paint on side B metal window casing 3.4

2688 1st Floor Room D70 White paint on side A metal door casing 1.8

2690 1st Floor Room D70 White paint on side A metal window casing 3.2

2731 1st Floor R & F Room Gray paint on side A door casing 12.7*

2732 1st Floor R & F Room Gray paint on side A door jamb 13.1*

2733 1st Floor R & F Room White paint on side A drywall wall 5.4*

2734 1st Floor R & F Room Blue paint on side B drywall wall 5.3*

2835 1st Floor R & F Room Blue paint on side C drywall wall 5.4*

2736 1st Floor R & F Room White paint on side D drywall wall 1.3

2737 1st Floor R & F Room Gray paint on side D window casing 12.6*

2738 1st Floor Radiology Gray paint on side A door jamb 11.5*

2739 1st Floor Radiology Gray paint on side A door jamb 12.5*

2741 1st Floor Radiology Gray paint on side B window casing 13.5*

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Number

Reading

Location Component

Lead

Concentration

(mg/cm2)

2743 1st Floor Radiology Blue paint on side C drywall wall 6.6*

2744 1st Floor Radiology Blue paint on side D drywall wall 5.6*

2781 1st Floor IM Room Beige paint on side D drywall wall 5.2*

2801 1st Floor Room D77 Beige paint on side A metal door casing 7.7*

2803 1st Floor Room D77 Beige paint on side B metal window casing 13.2*

2804 1st Floor Room D77 Beige paint on side A drywall wall 5.1*

2805 1st Floor Room D77 Beige paint on side B drywall wall 4.5*

2806 1st Floor Room D77 Beige paint on side C drywall wall 6.1*

2807 1st Floor Room D77 Beige paint on side D drywall wall 4.3*

2827 1st Floor Room NM2 Orange paint on side D drywall wall 5.6*

2862 1st Floor Room D90 White paint on side A metal door jamb 3.6*

2863 1st Floor Room D90 White paint on side A drywall wall 5.7*

2864 1st Floor Room D90 White paint on side B drywall wall 7.5*

2865 1st Floor Room D90 White paint on side B metal window casing 12.7*

2879 1st Floor Room D92 Beige paint on side D drywall wall 5.2*

2999 Basement Room D101 Blue paint on metal pump motor 4.7

3029 Basement D107 Stairwell Beige paint on side A metal door 3.2

3030 Basement D107 Stairwell Beige paint on side A metal door casing 2.0

3031 Basement D107 Stairwell Beige paint on side A metal door jamb 2.9

3074 Basement Mechanical Room Gray paint on side A metal door casing 2.4

3075 Basement Mechanical Room Gray paint on side A metal door jamb 2.9

3076 Basement Mechanical Room Gray paint on side A metal door 2.0

3094 Basement Room D111 Beige paint on side A metal door 2.6

3095 Basement Room D111 Beige paint on side A metal door casing 2.8

3096 Basement Room D111 Beige paint on side A metal door jamb 3.1

Medical Plaza Building - 700 Walter Reed Boulevard

314 Room MP 111 Beige paint on side B drywall wall 6.0*

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Number

Reading

Location Component

Lead

Concentration

(mg/cm2)

325 MP Classroom White paint on side A metal door jamb 8.3*

326 MP Classroom White paint on side A metal door casing 9.1*

414 Suite 205 Cardiology Lab Beige paint on side D drywall wall 8.8*

433 Suite 205 Prep Room Beige paint on side C drywall wall 8.9*

440 Suite 205 Stress Room Beige paint on side D drywall wall 8.2*

Storage Building - 900 North Shiloh Road

39 South Exterior Tan paint on metal roof access ladder 2.7

277 Hallway 7M White paint on side A metal door casing 2.1

278 Hallway 7M White paint on side A plaster wall 1.1

*Substantially elevated XRF readings may indicate the presence of protective lead-lining on the interior of walls and adjacent substrate

The OSHA Lead Standard for Construction (29 CFR 1926.62) applies to construction work where an employee may be occupationally exposed to lead. All work related to construction, alteration, or repair (including painting and decorating) is included. The lead-in-construction standard applies to any detectable concentration of lead in paint. OSHA considers paint containing any level of lead above the analytical method’s LOD a potential hazard which should be communicated to any employees or contractors who may disturb the materials in the course of their assigned work.

Renovation activities impacting materials with identified lead-containing paint will be subject to

OSHA regulations (29 CFR 1926.62 - Lead Exposure in Construction). The OSHA regulation defines specific training requirements, engineering controls and working practices for construction personnel subject to this standard. There are also federal and state regulations, which require characterization of demolition debris to determine proper disposal procedures.

OSHA does not consider any method that relies solely on the analysis of bulk materials or surface content of lead (or other toxic material) to be acceptable for safely predicting employee exposure to airborne contaminants. Without air monitoring results or without the benefit of historical or objective data (including air sampling which clearly demonstrates that the employee cannot be exposed above the action level during any process, operation, or activity) the analysis of bulk or

6.0 GENERAL COMMENTS

This lead containing paint survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions

Responsive ■ Resourceful ■ Reliable 15 in the same locale. The results, findings, conclusions, and recommendations expressed in this report are based on conditions observed during our inspection of the building. The information contained in this report is relevant to the dates on which this inspection was performed, and should not be relied upon to represent conditions at a later date.

This report has been prepared on behalf of and exclusively for use by Enapay, LLC for specific application to their project as discussed. Contractors, consultants or others reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary.

Terracon does not warrant the work of regulatory agencies, laboratories or other third parties supplying information which may have been used in the preparation of this report. No warranty, express or implied is made.

APPENDIX A

LEAD-BASED PAINT INSPECTION RESULTS

Reading No Floor Room/Area Side Component Feature Color Substrate Condition Results PbC

1 Calibration White Negative < LOD

2 Calibration Red Positive 1.2

3 Calibration Gold Negative 0.7

4 Calibration Yellow Positive < LOD

5 Calibration Orange Positive 1.5

6 Calibration Green Negative < LOD

7 5th Medical Records A Wall N/A Pink Drywall Intact Positive 5.4

8 5th Medical Records B Wall N/A Pink Drywall Intact Negative < LOD

9 5th Medical Records C Wall N/A Pink Drywall Intact Negative < LOD

10 5th Medical Records D Wall N/A Pink Drywall Intact Negative < LOD

11 5th Medical Records A Ceiling N/A Pink Drywall Intact Negative < LOD

12 5th Dietary A Wall N/A White Drywall Intact Positive 7.3

13 5th Dietary B Wall N/A White Drywall Intact Negative < LOD

14 5th Dietary C Wall N/A White Drywall Intact Negative < LOD

15 5th Dietary D Wall N/A White Drywall Intact Negative < LOD

16 5th Dietary C Window Frame Black Metal Intact Negative < LOD

17 5th E Staff RR Ceiling White Drywall Intact Negative < LOD

18 5th Stockroom A Wall N/A Pink Drywall Intact Negative < LOD

19 5th Stockroom B Wall N/A Pink Drywall Intact Negative < LOD

20 5th Stockroom C Wall N/A Pink Drywall Intact Negative < LOD

21 5th Stockroom D Wall N/A Pink Drywall Intact Negative < LOD

22 5th Stockroom A Door Casing Pink Metal Intact Negative < LOD

23 5th Stockroom A Door Jamb Pink Metal Intact Negative < LOD

24 5th Facility Shop A Wall N/A Pink Drywall Intact Negative < LOD

25 5th Facility Shop B Wall N/A Pink Drywall Intact Negative < LOD

26 5th Facility Shop C Wall N/A Pink Drywall Intact Negative < LOD

27 5th Facility Shop D Wall N/A Pink Drywall Intact Negative < LOD

28 5th Facility Shop A Door Casing Pink Metal Intact Negative < LOD

29 5th Facility Shop A Door Jamb White Metal Intact Negative < LOD

30 5th Facility Shop C Window Frame Black Metal Intact Negative < LOD

31 5th Emergency Supply A Wall N/A Grey Drywall Intact Negative < LOD

32 5th Emergency Supply B Wall N/A Grey Drywall Intact Negative < LOD

33 5th Emergency Supply C Wall N/A Grey Drywall Intact Negative < LOD

34 5th Emergency Supply D Wall N/A Purple Drywall Intact Negative < LOD

35 5th Engineering Supply A Door Casing White Metal Intact Negative < LOD

36 5th Engineering Supply A Door Jamb White Metal Intact Negative < LOD

37 5th Staff Lounge A Wall N/A White Drywall Intact Negative < LOD

38 5th Staff Lounge B Wall N/A White Drywall Intact Negative < LOD

39 5th Staff Lounge C Wall N/A White Drywall Intact Negative < LOD

40 5th Staff Lounge D Wall N/A White Drywall Intact Negative < LOD

41 5th Staff Lounge A Door Casing Pink Metal Intact Negative < LOD

42 5th Staff Lounge A Door Jamb Pink Metal Intact Negative < LOD

43 5th Staff Lounge C Window Frame Black Metal Intact Negative < LOD

44 5th Admin Corridor A Wall Upper White Drywall Intact Negative < LOD

45 5th Admin Corridor B Wall Upper White Drywall Intact Negative < LOD

46 5th Admin Corridor C Wall Lower Black Drywall Intact Negative < LOD

47 5th Admin Corridor C Wall Lower Black Drywall Intact Negative < LOD

48 Calibration White Negative < LOD

49 Calibration Red Positive 1.3

50 Calibration Gold Negative 0.6

51 Calibration Yellow Positive < LOD

52 Calibration Orange Positive 1.6

53 Calibration Green Negative < LOD

54 Calibration White Negative < LOD

55 Calibration Red Positive 1.1

56 Calibration Gold Negative 0.6

57 Calibration Yellow Positive < LOD

58 Calibration Orange Positive 1.9

59 Calibration Green Negative < LOD

60 4th Exam A Wall N/A White Drywall Intact Negative < LOD

61 4th Exam B Wall N/A White Drywall Intact Negative < LOD

62 4th Exam C Wall N/A White Drywall Intact Negative < LOD

63 4th Exam D Wall N/A White Drywall Intact Negative < LOD

64 4th Exam A Door Casing White Metal Intact Negative < LOD

65 4th Exam A Door Jamb White Metal Intact Negative < LOD

66 4th Staff Restroom A Wall N/A White Drywall Intact Negative < LOD

67 4th Staff Restroom B Wall N/A White Drywall Intact Negative < LOD

68 4th Staff Restroom C Wall N/A White Drywall Intact Negative < LOD

69 4th Staff Restroom D Wall N/A White Drywall Intact Negative < LOD

70 4th Staff Restroom A Door Casing White Metal Intact Negative < LOD

71 4th Staff Restroom A Door Jamb White Metal Intact Negative < LOD

72 4th Nurse's Station A Wall N/A White Drywall Intact Negative < LOD

73 4th Nurse's Station B Wall N/A White Drywall Intact Negative < LOD

74 4th Nurse's Station C Wall N/A White Drywall Intact Negative < LOD

75 4th Nurse's Station D Wall N/A White Drywall Intact Negative < LOD

76 4th Nurse's Station B Door Casing White Metal Intact Negative < LOD

Main Hospital Building - 2300 Marie Curie Boulevard

77 4th Nurse's Station B Door Jamb White Metal Intact Negative < LOD

78 4th Clean Linen A Wall N/A White Drywall Intact Negative < LOD

79 4th Clean Linen B Wall N/A White Drywall Intact Negative < LOD

80 4th Clean Linen C Wall N/A White Drywall Intact Negative < LOD

81 4th Clean Linen D Wall N/A White Drywall Intact Negative < LOD

82 4th Clean Linen A Door Casing White Metal Intact Negative < LOD

83 4th Clean Linen A Door Jamb White Metal Intact Negative < LOD

84 4th 4048 Office A Wall N/A White Drywall Intact Negative < LOD

85 4th 4048 Office B Wall N/A White Drywall Intact Negative < LOD

86 4th 4048 Office C Wall N/A White Drywall Intact Negative < LOD

87 4th 4048 Office D Wall N/A White Drywall Intact Negative < LOD

88 4th 4048 Office A Door Casing White Metal Intact Negative < LOD

89 4th 4048 Office A Door Jamb White Metal Intact Negative < LOD

90 4th Breakroom A Wall N/A White Drywall Intact Negative < LOD

91 4th Breakroom B Wall N/A White Drywall Intact Negative < LOD

92 4th Breakroom C Wall N/A White Drywall Intact Negative < LOD

93 4th Breakroom D Wall N/A White Drywall Intact Negative < LOD

94 4th Breakroom A Door Casing White Metal Intact Negative < LOD

95 4th Breakroom A Door Jamb White Metal Intact Negative < LOD

96 4th Emergency Storage A Wall N/A White Drywall Intact Negative < LOD

97 4th Emergency Storage B Wall N/A White Drywall Intact Negative < LOD

98 4th Emergency Storage C Wall N/A White Drywall Intact Negative < LOD

99 4th Emergency Storage D Wall N/A White Drywall Intact Negative < LOD

100 4th Emergency Storage A Door Casing White Metal Intact Negative < LOD

101 4th Emergency Storage A Door Jamb White Metal Intact Negative < LOD

102 4th Laundry A Wall N/A White Drywall Intact Negative < LOD

103 4th Laundry B Wall N/A White Drywall Intact Negative < LOD

104 4th Laundry C Wall N/A White Drywall Intact Negative < LOD

105 4th Laundry D Wall N/A White Drywall Intact Negative < LOD

106 4th Laundry A Door Casing White Metal Intact Negative < LOD

107 4th Laundry A Door Jamb White Metal Intact Negative < LOD

108 4th Storage A Wall N/A White Drywall Intact Negative < LOD

109 4th Storage B Wall N/A White Drywall Intact Negative < LOD

110 4th Storage C Wall N/A White Drywall Intact Negative < LOD

111 4th Storage D Wall N/A White Drywall Intact Negative < LOD

112 4th Storage A Door Casing White Metal Intact Negative < LOD

113 4th Storage A Door Jamb White Metal Intact Negative < LOD

114 4th Therapist Office A Wall N/A White Drywall Intact Negative < LOD

115 4th Therapist Office B Wall N/A White Drywall Intact Negative < LOD

116 4th Therapist Office C Wall N/A White Drywall Intact Negative < LOD

117 4th Therapist Office D Wall N/A White Drywall Intact Negative < LOD

118 4th Therapist Office A Door Casing White Metal Intact Negative < LOD

119 4th Therapist Office A Door Jamb White Metal Intact Negative < LOD

120 4th Soiled Laundry A Wall N/A White Drywall Intact Negative < LOD

121 4th Soiled Laundry B Wall N/A White Drywall Intact Negative < LOD

122 4th Soiled Laundry C Wall N/A White Drywall Intact Negative < LOD

123 4th Soiled Laundry D Wall N/A White Drywall Intact Negative < LOD

124 4th Soiled Laundry A Door Casing White Metal Intact Negative < LOD

125 4th Soiled Laundry A Door Jamb White Metal Intact Negative < LOD

126 4th Soiled Laundry A Ceiling N/A White Drywall Intact Negative < LOD

127 4th EVS A Wall N/A White Drywall Intact Negative < LOD

128 4th EVS B Wall N/A White Drywall Intact Negative < LOD

129 4th EVS C Wall N/A White Drywall Intact Negative < LOD

130 4th EVS D Wall N/A White Drywall Intact Negative < LOD

131 4th EVS A Door Casing White Metal Intact Negative < LOD

132 4th EVS A Door Jamb White Metal Intact Negative < LOD

133 4th Lab A Wall N/A White Drywall Intact Negative < LOD

134 4th Lab B Wall N/A White Drywall Intact Negative < LOD

135 4th Lab C Wall N/A White Drywall Intact Negative < LOD

136 4th Lab D Wall N/A White Drywall Intact Negative < LOD

137 4th Lab A Door Casing White Metal Intact Negative < LOD

138 4th Lab A Door Jamb White Metal Intact Negative < LOD

139 4th Nourishment A Wall N/A White Drywall Intact Negative < LOD

140 4th Nourishment B Wall N/A White Drywall Intact Negative < LOD

141 4th Nourishment C Wall N/A White Drywall Intact Negative < LOD

142 4th Nourishment D Wall N/A White Drywall Intact Negative < LOD

143 4th Nourishment A Door Casing White Metal Intact Negative < LOD

144 4th Nourishment A Door Jamb White Metal Intact Negative < LOD

145 4th Laundry A Door Casing White Metal Intact Negative < LOD

146 4th Laundry A Door Jamb White Metal Intact Negative < LOD

147 4th Laundry A Wall N/A White Drywall Intact Negative < LOD

148 4th Laundry B Wall N/A White Drywall Intact Negative < LOD

149 4th Laundry C Wall N/A White Drywall Intact Negative < LOD

150 4th Laundry D Wall N/A White Drywall Intact Negative < LOD

151 4th Nurse's Station A Wall N/A White Drywall Intact Negative < LOD

152 4th Nurse's Station B Wall N/A White Drywall Intact Negative < LOD

153 4th Nurse's Station C Wall N/A White Drywall Intact Negative < LOD

154 4th Nurse's Station D Wall N/A White Drywall Intact Negative < LOD

155 4th Consulting A Wall N/A White Drywall Intact Negative < LOD

156 4th Consulting B Wall N/A White Drywall Intact Negative < LOD

157 4th Consulting C Wall N/A White Drywall Intact Negative < LOD

158 4th Consulting D Wall N/A White Drywall Intact Negative < LOD

159 4th Consulting A Door Casing White Metal Intact Negative < LOD

160 4th Consulting A Door Jamb White Metal Intact Negative < LOD

161 4th Exam A Door Casing White Metal Intact Negative < LOD

162 4th Exam A Door Jamb White Metal Intact Negative < LOD

163 4th Exam A Wall N/A White Drywall Intact Negative < LOD

164 4th Exam B Wall N/A White Drywall Intact Negative < LOD

165 4th Exam C Wall N/A White Drywall Intact Negative < LOD

166 4th Exam D Wall N/A White Drywall Intact Negative < LOD

167 4th Storage Closet A Door Casing White Metal Intact Negative < LOD

168 4th Storage Closet A Door Jamb White Metal Intact Negative < LOD

169 4th Storage Closet A Wall N/A White Drywall Intact Negative < LOD

170 4th Storage Closet B Wall N/A White Drywall Intact Negative < LOD

171 4th Storage Closet C Wall N/A White Drywall Intact Negative < LOD

172 4th Storage Closet D Wall N/A White Drywall Intact Negative < LOD

173 4th Clean Utility A Door Jamb White Metal Intact Negative < LOD

174 4th Clean Utility B Cabinet Door Pink Wood Intact Negative < LOD

175 4th Clean Utility A Wall N/A White Drywall Intact Negative < LOD

176 4th Clean Utility B Wall N/A White Drywall Intact Negative < LOD

177 4th Clean Utility C Wall N/A White Drywall Intact Negative < LOD

178 4th Clean Utility D Wall N/A White Drywall Intact Negative < LOD

179 4th Clean Utility A Ceiling N/A White Drywall Intact Negative < LOD

180 4th Laundry A Wall N/A White Drywall Intact Negative < LOD

181 4th Laundry B Wall N/A White Drywall Intact Negative < LOD

182 4th Laundry C Wall N/A White Drywall Intact Negative < LOD

183 4th Laundry D Wall N/A White Drywall Intact Negative < LOD

184 4th Laundry A Door Casing White Metal Intact Negative < LOD

185 4th Laundry A Door Jamb White Metal Intact Negative < LOD

186 4th Staff Locker A Wall N/A White Drywall Intact Negative < LOD

187 4th Staff Locker B Wall N/A White Drywall Intact Negative < LOD

188 4th Staff Locker C Wall N/A White Drywall Intact Negative < LOD

189 4th Staff Locker D Wall N/A White Drywall Intact Negative < LOD

190 4th Staff Locker A Door Casing White Metal Intact Negative < LOD

191 4th Staff Locker A Door Jamb White Metal Intact Negative < LOD

192 4th Seclusion Room A Wall N/A White Drywall Intact Negative < LOD

193 4th Seclusion Room B Wall N/A White Drywall Intact Negative < LOD

194 4th Seclusion Room C Wall N/A White Drywall Intact Negative < LOD

195 4th Seclusion Room D Wall N/A White Drywall Intact Negative < LOD

196 4th Seclusion Room C Wall N/A White Drywall Intact Negative < LOD

197 4th Seclusion Room C Door Casing White Metal Intact Negative < LOD

198 4th Seclusion Room C Door Jamb White Metal Intact Negative < LOD

199 4th Seclusion Room A Door Casing White Metal Intact Negative < LOD

200 4th Seclusion Room A Door Jamb White Metal Intact Negative < LOD

201 4th Craft Room A Wall N/A White Drywall Intact Negative < LOD

202 4th Craft Room B Wall N/A White Drywall Intact Negative < LOD

203 4th Craft Room C Wall N/A White Drywall Intact Negative < LOD

204 4th Craft Room D Wall N/A White Drywall Intact Negative < LOD

205 4th Craft Room A Door Casing White Metal Intact Negative < LOD

206 4th Craft Room A Door Jamb White Metal Intact Negative < LOD

207 4th Visitation A Wall N/A White Drywall Intact Negative < LOD

208 4th Visitation B Wall N/A White Drywall Intact Negative < LOD

209 4th Visitation C Wall N/A White Drywall Intact Negative < LOD

210 4th Visitation D Wall N/A White Drywall Intact Negative < LOD

211 4th Visitation A Door Casing White Metal Intact Negative < LOD

212 4th Visitation A Door Jamb White Metal Intact Negative < LOD

213 4th Storage A Door Casing White Metal Intact Negative < LOD

214 4th Storage A Door Jamb White Metal Intact Negative < LOD

215 4th Storage A Wall N/A White Drywall Intact Negative < LOD

216 4th Storage B Wall N/A White Drywall Intact Negative < LOD

217 4th Storage C Wall N/A White Drywall Intact Negative < LOD

218 4th Storage D Wall N/A White Drywall Intact Negative < LOD

219 4th Hallway A Wall N/A Tan Drywall Intact Negative < LOD

220 4th Hallway B Wall N/A Tan Drywall Intact Negative < LOD

221 4th Hallway C Wall N/A Tan Drywall Intact Negative < LOD

222 4th Hallway D Wall N/A Tan Drywall Intact Negative < LOD

223 4th Nurse's Station A Wall N/A White Drywall Intact Negative < LOD

224 4th Nurse's Station B Wall N/A White Drywall Intact Negative < LOD

225 4th Nurse's Station C Wall N/A White Drywall Intact Negative < LOD

226 4th Quiet Room A Wall N/A White Drywall Intact Negative < LOD

227 4th Quiet Room B Wall N/A White Drywall Intact Negative < LOD

228 4th Quiet Room C Wall N/A White Drywall Intact Negative < LOD

229 4th Quiet Room D Wall N/A White Drywall Intact Negative < LOD

230 4th Quiet Room A Wall N/A White Drywall Intact Negative < LOD

231 4th Quiet Room A Wall N/A White Drywall Intact Negative < LOD

232 Calibration White Negative < LOD

233 Calibration Red Positive 1.3

234 Calibration Gold Negative 0.5

235 Calibration Yellow Positive 3.9

236 Calibration Orange Positive 1.6

237 Calibration Green Negative < LOD

238 Calibration White Negative < LOD

239 Calibration Red Positive 1.2

240 Calibration Gold Negative 0.8

241 Calibration Yellow Positive 3.2

242 Calibration Orange Positive 1.7

243 Calibration Green Negative < LOD

244 2nd East Corridor A Wall Upper White Drywall Intact Negative < LOD

245 2nd East Corridor B Wall Upper White Drywall Intact Negative < LOD

246 2nd East Corridor C Wall Upper White Drywall Intact Negative < LOD

247 2nd East Corridor D Wall Upper White Drywall Intact Negative < LOD

248 2nd East Corridor A Wall Lower Tan Drywall Intact Negative < LOD

249 2nd East Corridor B Wall Lower Tan Drywall Intact Negative < LOD

250 2nd East Corridor D Wall Lower Tan Drywall Intact Negative < LOD

251 2nd East Corridor B Wall Crown Molding Tan Wood Intact Negative < LOD

252 2nd 258 A Wall N/A White Drywall Intact Negative < LOD

253 2nd 258 B Wall N/A White Drywall Intact Negative < LOD

254 2nd 258 C Wall N/A White Drywall Intact Negative < LOD

255 2nd 258 D Wall N/A White Drywall Intact Negative < LOD

256 2nd 258 A Ceiling N/A White Drywall Intact Negative < LOD

257 2nd 258 C Cabinet Door White Wood Intact Negative < LOD

258 2nd 258 Restroom A Wall N/A White Drywall Intact Negative < LOD

259 2nd 258 Restroom B Wall N/A White Drywall Intact Negative < LOD

260 2nd 258 Restroom C Wall N/A White Drywall Intact Negative < LOD

261 2nd 258 Restroom D Wall N/A White Drywall Intact Negative < LOD

262 2nd 254 A Wall N/A White Drywall Intact Negative < LOD

263 2nd 254 B Wall N/A White Drywall Intact Negative < LOD

264 2nd 254 C Wall N/A White Drywall Intact Negative < LOD

265 2nd 254 D Wall N/A White Drywall Intact Negative < LOD

266 2nd 254 A Ceiling N/A White Drywall Intact Negative < LOD

267 2nd 254 A Door Casing White Metal Intact Negative < LOD

268 2nd 254 A Door Jamb White Metal Intact Negative < LOD

269 2nd 254 A Cabinet Door White Wood Intact Negative < LOD

270 2nd 254 C Window Frame Black Metal Intact Negative < LOD

271 2nd 254 C Window Sill White Wood Intact Negative < LOD

272 2nd 254 Restroom A Wall N/A White Drywall Intact Negative < LOD

273 2nd 254 Restroom B Wall N/A White Drywall Intact Negative < LOD

274 2nd 254 Restroom C Wall N/A White Drywall Intact Negative < LOD

275 2nd 254 Restroom D Wall N/A White Drywall Intact Negative < LOD

276 2nd Oxygen Storage A Wall N/A White Drywall Intact Negative < LOD

277 2nd Oxygen Storage B Wall N/A White Drywall Intact Negative < LOD

278 2nd Oxygen Storage C Wall N/A White Drywall Intact Negative < LOD

279 2nd Oxygen Storage D Wall N/A White Drywall Intact Negative < LOD

280 2nd Oxygen Storage A Ceiling N/A White Drywall Intact Negative < LOD

281 2nd Oxygen Storage A Door Casing White Metal Intact Negative < LOD

282 2nd Oxygen Storage A Door Jamb White Metal Intact Negative < LOD

283 2nd 251 A Wall N/A White Drywall Intact Negative < LOD

284 2nd…