Attachment_C-_Lead_Based_and_Risk_Assessment_Report_for_519_East_State_Street_Murfreesboro_TN_37129.pdf

Lead Hazard Risk Assessment & Lead-Based Paint Testing Report

PERFORMED AT: PREPARED BY:

The Residence Located at AAT Environmental Incorporated 519 East State Street Certifications- Risk-LBP-RA-46457-164949 Murfreesboro, Tennessee 37129 Firm-LBP-F-132-163356

2515 Burgess Street Murfreesboro, Tennessee 37128

TEL: 615-907-5850

Project # 20251115.01L

PREPARED FOR:

Mr. Robert N. Holtz, Director Community Development City of Murfreesboro 211 Bridge Avenue Murfreesboro, Tennessee 37129

November 17, 2025

Table of Contents

Executive Summary Identifying Information and Purpose of Risk Assessment Identifying Lead Hazards Ongoing Monitoring Disclosure Information Future Remodeling Precautions Conditions and Limitations Site Information and Field Testing Residential Questionnaire Building Conditions Survey Interior Dust Sampling Soil Sampling and Laboratory Information Lead Hazard Control Options and Cost Estimates Appendix A: XRF Lead-based Paint Testing Results Appendix B: Dust Sample Analytical Data Appendix C: Soil Sample Analytical Data Appendix D: Site and Floor Plan Appendix E: Scope of Renovation Work, as Provided to Assessor Appendix F: Copy of Risk Assessor’s License/Certification Appendix G: Copy of Firm’s Activity License/Certification Appendix H: Copy of Performance Characteristic Sheet Appendix I: Copy of “LEAD Speak” – A Brief Summary Appendix J: Additional Lead and Lead Safety Resource Data Appendix K: Photographs of Paint Films and Condition

Executive Summary

The Lead Hazard Risk Assessment and Lead-Based Paint Testing conducted on November 17, 2025, at 3:00 PM found twelve (1) substrate containing lead-based surface coatings (paint). None of these were a lead paint hazard at the subject property at the assessment time and date. The analytical results from this assessment identified the following lead-based paint (LBP) hazards and any potential lead hazards as defined by the EPA and HUD standards.

Exterior Lead-Based (Paint) Hazards

Lead-based paint (paint in film layers). Hazards were not identified during the exterior inspection of the home. At the time and date of inspection.

⮚ Lead Paint was Identified on the front columns (not a hazard).

Exterior Lead-based Paint (Dust) Hazards

At the time of the Inspection, Lead in dust was not found on the hard surfaces on the exterior of the Home.

⮚No Lead Paint Dust was Identified.

Exterior Lead-based Paint (Soil) Hazards

At the time of Inspection, Lead in soil was not found on the home exterior.

⮚No Lead Paint Soil was Identified.

Interior Lead-Based (Paint) At the time of inspection, lead-based paint (paint in film layers) was Not found on the following Interior components of this home.

⮚ Lead Paint was Identified on the interior.

Interior Lead-Based (Dust) Hazards At the time of inspection, no lead-based dust was found on the interior surfaces of this home.

⮚No Lead Paint Dust was Identified.

Please remember that professionally trained, experienced, and licensed lead workers should address all identified LBP and lead hazards. The following report presents the information collected during this assessment.

ENVIRONMENTAL CONSULTANT:

AAT Environmental Incorporated

SIGNATURE OF RISK ASSESSOR 11/17/2025

Mr. Blake J. Rindahl Date

Identifying Information and Purpose of Risk Assessment

For the Murfreesboro Community Development, a Lead Hazard Risk Assessment and LBP Testing (Assessment) were conducted at 519 East State Street, Murfreesboro, TN 37129. AAT performed the Assessment Environmental Incorporated, located at 2515 Burgess Street, Murfreesboro, Tennessee 37128 (Tennessee State Certification #LBP-F-132-163356), by Blake J. Rindahl, a Certified Risk Assessor (Tennessee License # LBP-RA-46457-1649494). This Assessment aimed to identify the presence of lead-based paint hazards.

A visual survey of the property and structure was conducted as part of this assessment. Dust wipe sampling was performed on interior and exterior surfaces, and composite soil samples were collected.

Additionally, on-site paint testing was conducted using an X-ray fluorescence (XRF) lead-in-paint analyzer.

Murfreesboro Community Development (615) 890-4660 contracted for this assessment. This agency can provide further details about the project. The results of the Assessment are summarized below.

Identified Lead Hazards While the house and its paint were in good condition during the Assessment, the XRF results from the deteriorated paint on the substrate indicated the presence of lead-based paint hazards.

These hazards are defined in the Residential LBP Hazard Reduction Act of 1992 (Title X) and as outlined by the Environmental Protection Agency (EPA) regulations published on January 5, 2001, in the Federal Register. The XRF results revealed lead levels that exceed the criteria established by the EPA and the US Department of Housing and Urban Development (HUD) in the following locations:

Existing Lead Hazards

The areas noted in the Executive Summary are coated with deteriorated Lead-Based Paint (LBP) and present lead-based paint hazards. The component substrates include wood, metal, dust, and soil. XRF testing found lead-based paint enclosed in bent metal behind this home's exterior trim. Special care should be taken if this metal is ever removed. The paint may delaminate from the substrate, creating a hazard.

1. Potential Lead Hazards

Exterior lead-based paint containing less than <1.0 mg/cm² can still pose a lead dust hazard. Materials can be found behind bent metal or on interior fireplaces and tiles, as well as on baseboards, doors, jambs, frames, fascia, soffits, exterior window components, internal window components, exterior doors, exterior jambs, and exterior casings.

Ongoing Monitoring

Ongoing monitoring is essential for all lead-based paint (LBP) dwellings.

In this dwelling, there is significant potential for developing LBP hazards.

Lead paint hazards can arise from various factors, including failures in lead hazard control measures. Previously intact LBP can deteriorate, leading to dangerous levels of lead-in-dust (dust lead) re-accumulating due to friction, impact, and paint deterioration or by introducing contaminated exterior dust and soil into the structure's interior. Ongoing monitoring typically involves two key activities: re-evaluation and annual visual assessments. A reevaluation is a risk assessment that entails a limited sampling of soil and dust, as well as a visual examination of paint films and any existing lead hazard controls. Re-evaluations are complemented by visual evaluations conducted by the client or owner.

Lead-based paint inspections and risk assessments should take place annually. If the client or management agent is managing rental housing in the future, they should address any complaints from residents. This is particularly critical if deteriorated paint or other potential lead hazards are present when the residence is occupied or if the house contains more than one dwelling unit. Any unit that turns over becomes vacant or experiences significant damage—such as flooding, vandalism, or fire— could compromise the integrity of hazard control treatments.

The visual assessment should encompass the entire dwelling unit; if the housing includes multiple units, each unit and all common areas accessible to residents must be included. This also applies to exterior painted surfaces and ground covering if controlling soil-lead hazards is necessary or recommended. Visual assessments should ensure that all paint with known or suspected LBP is not deteriorating and that hazard control methods remain intact. They should also verify that structural issues do not jeopardize the integrity of any remaining known, presumed, or suspected LBP.

Visual assessments do not substitute for professional re-evaluations that a certified risk assessor conducts. The re-evaluation should involve:

1. A review of prior reports to identify where lead-based paint and lead-based paint hazards have been found, the implemented controls, and the timeline of these findings and control methods.

2. A visual assessment to identify deteriorated paint, failures of previous hazard controls, visible dust and debris, and bare soil.

3. Environmental testing for lead in dust, newly deteriorated paint, and newly exposed soil.

4. A report detailing the re-evaluation findings, including the location of any lead-based paint hazards, areas of any failures in previous hazard controls, and, if necessary, acceptable options for managing threats, repairing prior controls, and modifying monitoring and maintenance practices.

The first re-evaluation should be conducted no later than two years after the completion of hazard controls. If specific rules or treatments have not been implemented within two years of initiating ongoing lead-based paint monitoring and maintenance activities, a re-evaluation should also occur. Subsequent re-evaluations should occur every two years, plus or minus 60 days. Once two consecutive re-evaluations have been completed, re-inspections may be discontinued for lead-based paint inspection. Please consult your community development department, housing authority, or other relevant agencies for additional local or regional regulations and guidelines governing re-evaluation.

Disclosure Regulations A copy of this complete report must be provided to new lessees (tenants) and property purchasers under Federal Law. This provision must occur before they become obligated under any future lease or sales contract transaction (section 1018 of Title X – found in 24 CFR part 35 and 40 CFR part 745) until the demolition of this property. Landlords, lessors, and sellers must also distribute an educational pamphlet developed by the Environmental Protection Agency (EPA) titled "Protect Your Family from Lead in Your Home." This document will include standard warning language in leases or sales contracts to ensure parents have the information to protect their children from lead-based paint hazards.

Future Remodeling Precautions It is essential to note that during this Assessment, only a limited number of areas were tested for the presence of lead-based paint (LBP). All identified LBP dust lead hazards, along with dust and soil hazards, are addressed in this report. However, other locations on the property may also present risks related to LBP, soil, and lead hazards. Additional paint testing should be conducted before any future remodeling activities in areas that were not tested. Additional dust and soil sample collection and analysis should be conducted following any hazard control activity, repair, remodeling, or renovation efforts. Any other work may disturb LBP and any lead-containing materials. These Assessment activities will aid the Client and owner in ensuring the health and safety of the occupants and the neighborhood. Details concerning lead-safe work techniques and approved hazard control methods can be found in the HUD publication entitled: "Guidelines for the Evaluation and Control of LBP Hazards in Housing" (www.hud.gov/offices/lead). Remodeling, repair, renovation, and painting at the residence, beyond the scope of minor repair and maintenance activities, must be conducted in accordance with the EPA's Lead Repair, Remodeling, and Painting Rule (40 CFR Part 745). For the scope and requirements of that rule, see the EPA's website on the RRP Rule at http://www.epa.gov/lead/pubs/renovation.htm. Lead-based paint abatement or lead-based paint hazard reduction at the residence must follow the EPA's Lead Abatement Rule (also within 40 CFR 745). Refer to the EPA's website for Lead Abatement Procedures at http://www.epa.gov/lead/pubs/traincert.htm

Conditions and Limitations

The staff of AAT have thoroughly and professionally performed the tasks requested by the Client, which is consistent with commonly accepted industry standards. It employs state-of-the-art practices and the best available technology as of the date of the Assessment.

AAT Environmental cannot guarantee that the Assessment/LBP testing has identified all adverse environmental factors or conditions affecting the subject property as of the Assessment date. AAT Environmental does not guarantee that the assessments or tests requested by the Client will comply with any environmental laws or regulations or provide a legal defense. The Client acknowledges and complies with all applicable laws, rules, and standards, including the EPA's Renovation, Repair, and Painting Regulations.

The results reported and conclusions drawn by AAT Environmental are solely for the Client's benefit.

This report's content, results, and opinions are based solely on the reader's interpretation.

The conditions identified on the property as of the assessment date will only be valid at that specific time and date.

AAT Environmental assumes no obligation to inform the Client of any changes in actual or potential lead hazards at this residence that may or may not come to our attention later. Other conditions and limitations regarding the contracted report are included in the general terms and conditions provided to this Client with the service contract.

Site Information and Field Testing

Residential Questionnaire

A resident questionnaire was completed as part of this assessment to help the client identify specific usage patterns related to potential LBP hazards. The questionnaire included questions regarding the opening and closing of windows painted with LBP. Responses were gathered during an interview with the current occupant. Below is a summary of the information collected during the interview:

Children in the household: N/A Children’s bedroom locations: N/A Children’s eating locations: N/A Primary interior play area(s): N/A Primary exterior play area(s): N/A Toy Storage: N/A Pets: NO Children’s blood lead level testing history: N/A Observed chewed surfaces: N/A Women of childbearing age: N/A Previous lead testing: N/A Most frequently used entrances: N/A Most frequently opened windows: N/A Structure cooling method: N/A Gardening Type and Location: N/A Plans for Landscaping: ` N/A Cleaning Regimen: N/A Cleaning Methods: N/A Recent Completed Renovations: N/A Demolition Debris on Site: N/A Resident(s) with work lead exposure: N/A

Scheduled Renovations: The preliminary scope of work document for this residence has not been provided.

Building Condition Survey

Date of Construction: 1912 Apparent Building Use: Residential Setting: Residential Front Entry Faces: South Design: Early Ranch Construction Type: Wood Frame Lot Type: Sloped, drains back Roof: Asphalt Shingle Foundation: Crawlspace Front Lawn Condition: Good Rear Lawn Condition: Good Drip Line Condition: Good Site Elevation: N/A Exterior Structural Condition: Good Interior Structural Condition: Good Overall Building/Site Condition: Good

Paint Condition Survey

Please note: The EPA and HUD have provided a specific definition of "deteriorated paint." Deteriorated paint refers to any interior or exterior paint or coating that is peeling, chipping, flaking, or cracking, or any paint coating on an interior or exterior surface or fixture damaged or separated from the substrate. This definition typically pertains to surface conditions only. Neither the EPA nor HUD has defined any terms that describe conditions other than those associated with a surface coating. Identified Deteriorated Paint, Paint Conditions, Lead Content, & Most Apparent Cause of Deterioration:

Lead hazards were identified on the exterior of this home.

The remaining paint showed no apparent deterioration as of the assessment date.

Paint Sampling and Testing

Lead-based paint testing, as per HUD regulation 24 CFR 35.930 (c), (d), was conducted on surfaces with deteriorated paint at this residence or where the Assessor indicated that planned renovations would occur. No paint chip samples were collected at this home on November 17, 2025. Eighty (80) essays were taken from random surfaces inside and outside the residence using an X-ray fluorescence NITON Analyzer. Deteriorated paint and areas that could be disturbed during the planned renovation project were tested. Lead concentrations that meet or exceed the HUD-published levels are identified as potentially dangerous (e.g., greater than or equal to 1.0 milligrams per square centimeter [>1.0 mg/cm2]). These levels were found on one (1) of the home's substrate components.

Some of the remaining test locations showed lead-in paint levels below HUD thresholds but in quantities significant enough to be detectable by our XRF analyzer. Lead concentrations below the lead-based paint (LBP) level can still pose health risks of lead poisoning.

Should these or any potential LBP-painted components and surfaces be disturbed in any way that generates dust, extreme care must be exercised to limit their spread. It should be assumed that any painted surfaces, components, or areas not explicitly requested will be tested as part of this investigation. Any previous studies indicate the presence of LBP. Renovations or repair activities in these areas require implementing safe work practices to minimize dust generation and area contamination.

Interior Dust Sampling

Testing was conducted by Blake J. Rindahl, a Certified Risk Assessor in the State of Tennessee, using the Niton X-ray fluorescent analyzer (S/N, State of Tennessee License #96243). Please refer to the detailed analytical reports for XRF, dust, and soil sampling in the appendices. Leads were detected in dust samples. These samples were collected in compliance with ASTM Standard E-1728, which outlines the Standard Practice for Field Collection of Settled Dust Samples Using Wipe Sampling Methods for Lead Determination by Atomic Spectrometry Techniques. The regulatory standards set by the EPA, HUD, and the State of Tennessee define hazardous levels of lead dust in residential settings as follows: >10 mg/ft² (micrograms per square foot) for interior floors and >100 mg/ft² (micrograms per square foot) for interior windowsills. There is currently no EPA lead-dust standard for window troughs. Refer to Appendix B for Dust Wipe Analytical Results. Laboratory reports can be found in Appendix I under Lead and Lead Safety Information and Resources. Both appendices are included at the end of the report, which lists publications and resources concerning lead hazards and their health effects. As indicated below, none (0) of the lead dust tested above the EPA and HUD Lead dust detection levels.

Laboratory Information Environmental Hazard Services, 7469 Whitepine Road, Richmond, Virginia 23237 Dust Wipe Analysis Method, EPA Method SW846, 7420, implementing microwave-assisted digestion.

Dust Wipe Medium used: Lead Wipes, ASTM # E1792-96aqq.

National Lead Laboratory Accreditation Program Serial # 100527

Sample # Type Location Side Component Sample

Size (Ft2) Test

Results (ug/ft2)

519-1 Dust Wipe Front Porch A Floor 1’x1’ <8.00

519-2 Dust Wipe Back Porch C Floor 1’x1’ <8.00

519-3 Dust Wipe Livingroom A Floor 1’x1’ <8.00

519-4 Dust Wipe Livingroom A Windowsill 2’x 18” <32.0

519-5 Dust Wipe Bedroom 1 D Floor 1’x1’ <8.00

519-6 Dust Wipe Bedroom 1 A Windowsill 2”x18” <32.0

519-7 Dust Wipe Bedroom 2 A Floor 1’x1’ <8.00

519-8 Dust Wipe Bedroom 2 B Windowsill 2”x18” <32.0

519-9 Dust Wipe Blank 1’x1’ <8.00

519-10 Dust Wipe Spike 1”x1’ 14.8

519-11 Dust Wipe 4’ Out A Floor 1’x1’ <8.00

519-12 Dust Wipe Spike C Floor 1’x1’ 89.9

Soil Sampling and Laboratory Information

Four (4) composite soil samples were collected at this residence following the requirements of ASTM Standard E-1727, Standard Practices for Field Collection of Soil Samples for Lead Determinations by Atomic Spectrometry Techniques. A composite sample consists of soil from multiple locations mixed to create a single sample. The first sample was taken from four areas in the front yard, specifically on side A, at the front dripline of the house, positioned 1 foot out and centered. The second sample was obtained from four separate locations on side B of the house, which was also 1.5 feet out and centered. The third sample was gathered from four areas on side C of the house, 2 feet out and centered. The fourth sample was collected from four separate locations on side D of the house, positioned 2 feet out and centered. Only bare soil areas were sampled. The analytical results revealed lead concentrations at or above the levels the EPA and HUD classify as hazardous.

Refer to the following table for a summary of the soil sampling results. Please see Appendix C – Soil Sample Analytical Data for detailed analytical reports. Testing data in bold indicates soil lead levels at or above the EPA's hazardous lead levels, as published in the regulations on January 5, 2001. There were no positive soil readings.

Sample # Type Location Side Comments Test Results (mg/kg2)

519-S-1 Composite Front Perimeter A Bare Soil sample 320

519-S-2 Composite Side Perimeter A Bare Soil sample 320

519-S-3 Composite Rear Perimeter C Bare Soil sample 300

519-S-4 Composite Side Perimeter C Bare Soil sample 340

Laboratory Information

Environmental Hazard Services, 7469 Whitepine Road, Richmond, Virginia 23237 Soil Analysis Protocol: EPA Method SW846, 7420, implementing microwave-assisted digestion process.

National Lead Laboratory Accreditation Program Serial # 100527

Lead Hazard Control Options and Cost Estimates

Lead-safe work and worker occupant protection practices adhere to current EPA, HUD, and OSHA standards. These practices are essential for safely completing all tasks involving the disturbance of lead-based paint (LBP)-coated surfaces and components. Furthermore, any work considered lead hazard control will employ interim control (temporary) methods and reduction (permanent) methods. It is essential to note that all lead hazard control activities may introduce additional risks that were not previously present.

The HUD publication Guidelines for the Evaluation and Control of LBP Hazards in Housing provides detailed information on the listed lead hazard control options and related occupant/worker protection practices. This publication includes the Environmental Protection Agency (EPA), lead paint regulations, and the Occupational Safety and Health Administration (OSHA) codes in the Lead in Construction Industry Standard.

The associated cost estimates encompass the labor and materials needed for the specified activities. Additional funds are typically required to ensure worker protection, site containment, and clean-up procedures are in place. These are approximate estimates only, and due to various factors, they may not accurately represent all local cost components. A precise estimate must be obtained from a certified LBP contractor or a contractor trained in lead-safe work practices. All abatement/interim control activities conducted at this residence should be performed by suitably qualified and licensed individuals as mandated.

As defined by HUD, interim control refers to measures designed to temporarily reduce human exposure to LBP hazards and lead-containing materials. These activities include, but are not limited to component and substrate repairs; paint and varnish repairs; the removal of lead dust hazards; renovation; remodeling; maintenance; temporary containment;

the placement of seed, sod, or other vegetation materials over bare soil areas; the application of 6 inches of appropriate mulch over impervious material; tilling of bare soil areas; extensive specialized cleaning; and ongoing maintenance.

Abatement, as defined by HUD, involves a set of measures intended to permanently reduce human exposure to LBP hazards and lead-containing materials. The product manufacturer and contractor must guarantee that the abatement methods will last twenty (20) years, with a minimum design life of twenty (20) years. These activities include, but are not limited to, the removal of LBP substrates and components; replacing parts or fixtures containing lead and lead-based paint; permanently enclosing LBP with construction materials; encapsulated LBP with approved products; permanently covering soil-lead hazards with concrete or asphalt; and extensive specialized cleaning activities. (EPA's definition is the same.)

Specification Excerpts:

SPECIAL CLEANING PRECEDING LEAD HAZARD CONTROL ACTIVITIES

See Chapter 11 of the 2012 HUD Guidelines for Lead Interim Controls.

LBPH-13.PDF (hud.gov)

Hazard 1: Pre-Cleaning Lead-based Coated Materials:

a) The structure and site must be inspected and pre-cleaned before beginning hazard control activities. The required steps include removing large debris and paint chips, followed by HEPA vacuuming all horizontal surfaces (floors, windowsills, troughs, etc.). The cleaning protocols described in this publication can help contractors perform preliminary cleaning and increase the likelihood of passing clearance inspections after remediation.

Pre-cleaning: $2.25 S.F.

Final cleaning: $3.25 S.F.

Hazard 2: Stabilize Delaminated Peeling Paint

a. ABATEMENT/REMOVAL: The HUD Guidelines, August 2012 Revision, recommend addressing future hazards first. Begin by HEPA vacuuming all visible paint chips and dust around the areas. Next, six million plastic pieces will be laid out, signage will be posted, and designated areas will be established. Identify the lead source to ensure you do not re-contaminate the abatement areas. Although the potential for lead dust contamination is low with this remediation method, exceptional attention to work practices is necessary to minimize dust generation. Clean all affected horizontal areas (window stools/porches) with a tri-sodium phosphate substitute (two cleaning applications). Allow HUD-recommended drying times. Call for Lead Paint clearance testing.

Stabilize paint properly and dispose of chips and materials: $500.00 each.

Clean Areas: $500.00 each.

Chapter 11, Section VI covers soil interim controls. This section describes soil treatments that are expected to be effective for at least 20 years.

Temporary and Permanent Soil Treatments: Interim measures for controlling soil lead hazards include surface coverings with grass, gravel, mulch, wood chips, or similar materials, as well as land use controls such as fences, thorny bushes, or decks, to prevent contact with the contaminated soil.

These interim controls are designed to temporarily reduce exposure.

Their effectiveness depends on several factors, including the durability and maintenance of the cover, the level of foot traffic, and the local climate.

Soil abatement measures are described in Chapter 12, Section V. If the control measure involves replacing soil that presents a lead hazard (see Section A above) with soil of acceptable lead levels or includes installing a permanent cover such as asphalt or concrete, the method is classified as abatement.

Appendix A XRF Lead-based Paint Testing Results

Appendix B - Dust Sample Analytical Data

Appendix C - Soil Sample Analytical Data

Appendix D - Site and Floor Plan (sides of a home)

Appendix E: Scope of Renovation Work, as Provided to Assessor

To be provided.

Appendix F: Copy of Risk Assessor's License/Certification

Appendix G: Copy of Firm's Activity License/Certification

Appendix H: Copy of XRF Training Certificate and Performance Characteristic Sheet

Appendix I: Copy of "LEAD Speak" –A Brief Summary

Appendix J: Additional Lead and Lead Safety Resource Data

Appendix K: Photographs of Paint Films and Condition