Attach 2 Lead Report 03152023.pdf

March 15, 2023

Jonathan Moore Project Management Specialist AJW-L532 NAS Program Support Subteam S&K Engineering & Research jonathan.ctr.moore@faa.gov

RE: Lead Results

Tower/ASDE Houston, Texas 18212 Aldine Westfield Road, Houston, Texas Project Number 109631-LS

Dear Jonathan Moore, Titan Environmental Solutions, Inc. (TES) was provided three (3) paint chip samples from homogenous areas of suspect lead-based paints and/or lead-containing materials (LBPs/LCMs) collected by the Client from the above referenced property (Subject Property).

TES submits lead samples to an American Industrial Hygiene Association (AIHA) accredited laboratory under the Environmental Lead Laboratory Accreditation Program (ELLAP) and a participant in the AIHA Environmental Lead Proficiency Analytical Testing (ELPAT) Program and/or California Water Resources Board (CWRB) accredited under the Environmental Laboratory Accreditation Program (ELAP), under proper Chain-of-Custody (COC) documentation.

The lead samples were submitted to SGS Forensic Laboratories located in Carson, California.

SGS Forensic Laboratories is accredited by AIHA under ELLAP (AIHA-LAP #101629). Paint chip sample extraction and analysis were conducted in accordance with EPA Methods 3050B and 7000B, respectively, and samples analyzed for total lead content by flame atomic absorption spectrophotometry (FAAS).

The following Table 1-1 provides a summary of suspect LCM/LBP paint chip sampling analytical results.

Lead Results

18212 Aldine Westfield Road, Houston, Texas Project Number 109631-LS

March 15, 2023

Table 1-1: Lead Paint Chip Sampling FAAS Analytical Results

Sample No.

Sample Locations Component / Substrate Color Lead

Concentration

(PPM)

Category

01 Louver E Center Brace Brace / Galvanized Steel Orange 910 LCM

02 Second Level Building E Side Wall Side Wall / Galvanized Steel White <60 BRL

03 Third Level Ladder Brace E Brace / Galvanized Steel Orange 43,000 LBP

Legend:

N = North, E = East, W = West, S = South Classification:

- BRL = Below Reporting Limit (RL) of 60 and 6,000 ppm total lead

- LCP = Lead Containing Materials with lead concentrations ≥ RL and ≥ 90 ppm

- LCM = Lead Containing Materials with lead concentrations ≥ RL – <5,000 ppm

- LBP = Lead-Based Paints with lead concentration ≥5,000 ppm *Locations are estimates based on accessible materials located in the survey area only. Additional locations may be present at the Subject Property.

TES has the following recommendations based on the findings of this sampling:

For the purpose of this lead survey, any material containing any detectable level of lead is subject to OSHA’s Lead in Construction Standard codified in Title 29, Code of Federal Regulations, Section 1926.62 (29 CFR Part 1926.62).

In accordance with 29 CFR 1926.62, any disturbance of LCM and/or LBP should be performed by lead hazard communication trained workers using lead safe work practices that do not result in exposures above the Action Level (AL) of 30 micrograms per cubic meter of air (µg/m3) and/or Permissible Exposure Limit

(PEL) of 50 µg/m3.

In accordance with Resource Conservation and Recovery Act (RCRA) Title 40, Code of Federal Regulations, Section 261 (40 CFR 261) and California

Department of Toxic Substance Control (DTSC) requirements, all lead containing wastes should be sampled and analyzed for total and leachable lead concentrations and disposed of accordingly based on the waste characterization analytical results.

Any paints/coatings that have not been identified in this report should be considered presumed LBP and handled as LBP unless sampled and proven to be non-LBP by a CDPH Lead-Related Construction Inspector/Assessor (LRCIA).

Any LCMs/LBPs to remain at the Subject Property should be properly managed in-place in accordance with applicable regulations via a Lead Paint Management

Plan designed by a CDPH Certified Professional.

Lead Results

18212 Aldine Westfield Road, Houston, Texas Project Number 109631-LS

March 15, 2023

All lead activities must be performed in accordance with all applicable federal, state and local regulations, including but not limited to those summarized in this report.

TES appreciates the opportunity to be of service to you on this project. If there are any questions concerning the report, or if we may be of further assistance, please contact us at (888) 948-4826.

Sincerely, Titan Environmental Solutions, Inc.

Robert Menald, CIEC, CAC, LRCIA Ibrahim M. Sobeih, MS, MSPH, CIH, CAC, FAIHA Project Manager Director of Industrial Hygiene and Safety

Attachments:

1. Laboratory Analytical Report and COC

Metals Analysis of Paints Client ID:

Report Number:

Date Received:

M249103

Job ID / Site: 109631-LS ; IAH (Houston, TX) ASDE Tower ; 18212 Aldine Westfield Road, Houston, TX

TITAN Environmental Solutions, Inc.

Suite B

L1630

SGSFL Job ID:

Date Analyzed:

L1630

Tony Lam

Fullerton, CA 92831

1521 E. Orangethorpe Ave.

Date Printed: 03/14/23

03/14/23

First Reported: 03/14/23

03/09/23

Final Report

(AIHA-LAP, LLC Accreditation, Lab ID #101629)

Date(s) Collected: 02/23/2023 Total Samples Submitted:

Total Samples Analyzed:

Sample Number Lab Number Result Result Reporting Method

Analyte Units Limit* Reference

EPA 3050B/7000B910Pb01 LM245802 ppm 60

EPA 3050B/7000B< 60Pb02 LM245803 ppm 60

EPA 3050B/7000B43000Pb03 LM245804 ppm 6000

Analytical results and reports are generated by SGS Forensic Laboratories at the request of and for the exclusive use of the person or entity (client) named on such report.

Results, reports or copies of same will not be released by SGS Forensic Laboratories to any third party without prior written request from client. This report applies only to the sample(s) tested. Supporting laboratory documentation is available upon request. This report must not be reproduced except in full, unless approved by SGS Forensic

Laboratories. The client is solely responsible for the use and interpretation of test results and reports requested from SGS Forensic Laboratories. SGS Forensic Laboratories is not able to assess the degree of hazard resulting from materials analyzed. SGS Forensic Laboratories reserves the right to dispose of all samples after a period of thirty

(30) days, according to all state and federal guidelines, unless otherwise specified. Any modifications that have been made to referenced test methods are documented in

SGS Forensic Laboratories' Standard Operating Procedures Manual. Sample results have not been blank corrected. Quality control and sample receipt condition were acceptable unless otherwise noted.

Note* Sampling data used in this report was provided by the client as noted on the associated chain of custody form.

* The Reporting Limit represents the lowest amount of analyte that the laboratory can confidently detect in the sample, and is not a regulatory level. The Units for the Reporting Limit are the same as the Units for the Final Results.

Beatriz Hinojosa, Laboratory Supervisor, Carson Laboratory