B08_Attachment_3_Lewis_Barn_Lead_Report.pdf

LIMITED LEAD-BASED PAINT INSPECTION

FINAL TECHNICAL REPORT

Conducted at:

MONOCACY NATIONAL BATTLEFIELD

LEWIS BARN

4403 Baker Valley Road Frederick, Maryland 21704

Prepared for:

MONOCACY NATIONAL BATTLEFIELD

4801 Urbana Pike

Attention: Mr. Vincent Gentilcore, Facilities Management Specialist Vincent_gentilcore@nps.gov

BEC Project #MD22131

Fieldwork Conducted: December 7, 2022

Final Technical Report Date: December 12, 2022

Prepared by:

Middletown, MD ~ Morgantown, WV Corporate Office: 200 W Main Street, Middletown, MD 21769 Tel: (301) 694‐5687 ~ Fax: (301) 694‐9799

ENVIRONMENTAL SCIENCE, ENGINEERING & INDUSTRIAL HYGIENE SERVICES

mailto:Vincent_gentilcore@nps.gov

LIMITED LEAD-BASED PAINT INSPECTION

Conducted at:

MONOCACY NATIONAL BATTLEFIELD - LEWIS BARN

TABLE OF CONTENTS

SECTION 1.0 SUBJECT SITE DESCRIPTION & SCOPE OF WORK 1

SECTION 2.0 LIMITED LEAD-BASED PAINT INSPECTION 1

Section 2.1 Background 1

Section 2.2 LPB Inspection Procedures 1

Section 2.3 LBP Testing Combinations 2

Section 2.4 LBP Inspection Limitations 2

SECTION 3.0 LIMITED LEAD-BASED PAINT TESTING RESULTS 3

Section 3.1 Lead-Based Paint Films 3

Section 3.2 Paint Containing Lead Films 3

Section 3.3 LBP and PCL Management 3

SECTION 4.0 CONCLUSIONS & RECOMMENDATIONS 3

Section 4.1 Conclusions 3

Section 4.2 Recommendations 4

TABLES

TABLE A: LEAD BASED PAINT FILMS

TABLE B: PAINT CONTAINING LEAD FILMS

APPENDICES

APPENDIX A PROTEC “LPA-1” RADIOACTIVE ENERGY RESOURCING DATA

APPENDIX B XRF PERFORMANCE CHARACTERSTIC SHEET

APPENDIX C XRF TESTING DATA

APPENDIX D BEC STAFF QUALIFICATIONS

APPENDIX E BEC FIELD DOCUMENTATION

APPENDIX F BEC PHOTOSHEET

BOGGS ENVIRONMENTAL CONSULTANTS, INC.

Final Technical Report & Onsite Fieldwork Conducted By:

Patricia Higbee Environmental Scientist State of Maryland Lead Inspector (#100233)

Page | 1

SECTION 1.0 SUBJECT SITE DESCRIPTION & SCOPE OF WORK

Project Site: MONOCACY NATIONAL BATTLEFIELD - LEWIS BARN

Frederick, MD 21704

Requester Name: Mr. Vincent Gentilcore, Facilities Management Specialist

Requestor Address: MONOCACY NATIONAL BATTLEFIELD

4801 Urbana Pike

Subject Site Description & Scope of Work:

The focus of this inspection was to conduct a limited lead-based paint (LBP) inspection to identify building components for the presence of lead-based paint (LBP) and/or paint-containing lead (PCL) on exterior components of the Lewis Barn prior to an upcoming planned repainting, located at 4403 Baker Valley Road, Frederick Maryland 21704; hereinafter referred to as the subject site.

BEC received authorization from Mr. Vincent Gentilcore, Facilities Management Specialist with Monocacy National Battlefield, to provide industrial hygiene services to determine the presence of lead-based paint (LBP) and/or paint-containing lead (PCL) at the subject site. BEC advises, the limited LBP inspection was conducted on exterior building components to determine applicability (and impact) of US EPA/US HUD/Maryland Department of the Environment (MDE) and US OSHA worker protection regulations.

SECTION 2.0 LIMITED LEAD-BASED PAINT INSPECTION

2.1 Background

BOGGS ENVIRONMENTAL CONSULTANTS, INC. (BEC) conducted the LBP inspection utilizing an US EPA/HUD/DOEE accredited LBP inspector and all necessary sampling equipment to perform the LBP inspection, by evaluating the representative building components within each functional space located at the structure to gain an understanding of the locations of LBP and/or PCL within the subject site. The lead-based paint (LBP) inspection was conducted strictly adhering to the US HUD guidance document entitled “Guidelines for the

Evaluation and Control of Lead-Based Paint Hazards in Housing” with the 1997 and 2012 revisions.

BEC staff member, Mr. Patricia Higbee, whom possesses valid United States Environmental Protection Agency (US EPA), US Housing and Urban Development (US HUD), State of Maryland approved “Lead Inspector” training certification conducted the inspection for LBP and/or PCL-finished building components on December 7, 2022.

2.2 LBP Inspection Procedures

The LBP inspection consisted of critical visual inspection and surface-by-surface investigation utilizing an X-Ray Fluorescence (XRF) in situ testing of paint films present at the structure. PROTEC "LPA-1" XRF manufactured by PROTEC Instrument Corporation, 38 Edge Hill Road, Waltham, Massachusetts. The PROTEC LPA-1 is a hand-held portable lead detector, designed to make accurate, non-destructive measurements of lead concentrations in paint. The LPA-1 (SN #1677) underwent resourcing of the Cobalt-57 radioactive isotope-based energy source on December 6, 2021. (See Appendix A - PROTEC “LPA-1” Radioactive Energy Resourcing Data).

The “LPA-1” is a hand-held portable lead detector, designed to make accurate, non-destructive measurements of lead concentrations in paint films, coatings, and/or finishes. BEC adhered to the XRF manufacturer’s specifications and directives contained in the “XRF Performance Characteristic Sheet” (PCS) in the conduct of the lead-based paint inspection. (See Appendix B – XRF Performance Characteristic Sheet) http://www.boggsenvironmental.com/

Page | 2

SECTION 2.0 LIMITED LEAD-BASED PAINT INSPECTION

2.2 LBP Inspection Procedures (continued)

Prior to beginning the XRF testing, BEC performed the manufacturer's recommended warm up procedures and calibrated the XRF device. BEC performed six calibration check readings using a National Institute of Standards and Technology (NIST) Standard Reference Material (SRM) paint film test strip (NIST SRM #2579), which possesses a lead level of 1.02 mg/cm2. All measurements were within the range of the calibration check limits; 0.7 to 1.3 mg/cm2, inclusive. The XRF instrument was deemed in calibration and testing began.

BEC advises, based upon visual inspection and XRF testing activities, a total of twenty (20) readings were collected from painted surfaces including: walls, and window components. A complete listing of all XRF results is included in Appendix C – XRF Testing Data.

According to the State of Maryland, an XRF reading of greater than 0.7 milligrams of lead (Pb+2) per square centimeter (mg/cm2) is considered positive; lead-based paint (LBP). An XRF reading equal to or less than 0.7 mg/cm2 is considered negative. It is relevant to note, the XRF testing did not result in any inconclusive readings.

The United States Occupational Safety and Health Administration (US OSHA) does not define lead paint based on content; paint-containing lead (PCL). Any detectable mass and/or concentration of lead in a paint film categorizes it as lead paint for purposes of complying with US OSHA regulations to determine worker exposure. Refer to “OSHA Lead in Construction Advisor”, Office of the Assistant Secretary for Policy / Office of Compliance Assistance Policy: https://www.dol.gov/elaws/osha/lead/glossary.asp

2.3 LBP Testing Combinations

A Testing Combination is characterized by the room equivalent, component, and substrate. The Testing Location is a specific area on a testing combination where the XRF instrument measures for lead-based paint.

A Room Equivalent is an identifiable part of a building, such as a room, exterior sides, or an exterior area.

Hallways, stairways, and exterior areas are all examples of room equivalents. Walls are identified as A, B, C and D. The “A” wall in each room corresponds with the wall on which the main entrance or street side of the building is located. The remaining walls are located in order proceeding clockwise from “A” wall. Side A faced the entrance to each apartment building. Windows and/or doors are identified as #1, #2, #3, etc. with the Window #1 and/or Door #1, located at the extreme left-hand side of a room with additional windows and/or doors encountered at the same wall, numbered in ascending order; left to right naming convention.

Each room equivalent is made up of Components. Components may be located inside or outside a building. For example, components in a room are the ceiling, floor, walls, a door and its casing, the window sash, and window casing. The Substrate is the material underneath the paint. Many substrates exist; however US HUD Final Guidelines recommend classifying substrates into one of six substrate types: brick, concrete, drywall, metal, plaster, and wood. These substrate types are intended to include a broad range of materials. If the true substrate is not one of the six types, the substrate that most closely matches the true substrate is selected. For substrates on top of substrates, such as plaster on concrete, the substrate directly beneath the paint surface is used.

2.4 LBP Inspection Limitations

The above inspection was characterized by close visual inspection of subject site, in accordance with US HUD regulations and generally accepted engineering work practices associated with the conduct of a LBP inspection. It is relevant to note, BEC did NOT conduct exploratory demolition to gain access to enclosed building conditions (e.g., wall cavities, pipe chases, HVAC ductwork shafts, ceiling plenums, etc.).

Accordingly, BEC makes no warranty, expressed or implied that all LBP and/or PCL-finished building components present at the building have been identified. BEC represents the XRF testing to identify LBP and/or PCL-finished building components, have been conducted in accordance with accepted engineering work practices and Federal/State regulations.

https://www.dol.gov/elaws/osha/lead/glossary.asp

Page | 3

SECTION 3.0 LIMITED LEAD-BASED PAINT TESTING RESULTS

3.1 Lead-Based Paint Films

BEC concludes, based upon review of the LBP inspection findings, “lead based paint” WAS detected (via XRF in situ testing) as the subject site and are listed in Table A –Lead Based Paint Films.

TABLE A – LEAD BASED PAINT FILMS

Paint Color

Building Component Location Wall Substrate

Lead (mg/cm²)

White Wall Building Exterior A, B, D Wood 0.8 – 1.2 White Soffit Building Exterior A Wood >9.9 White Rake Board Building Exterior A Wood >9.9

3.2 Paint Containing Lead Films

BEC concludes, based upon review of the LBP inspection findings, “paint-containing lead” WAS detected (via XRF in situ testing at the subject site and are listed in Table B – Paint Containing Lead Films.

TABLE B – PAINT CONTAINING LEAD FILMS

Paint Color

Building Component Location Wall Substrate

Lead (mg/cm²)

White Window Casing Building Exterior C Wood 0.1 Red Wall Building Exterior D Wood 0.4

3.3 LBP and PCL Management

Notwithstanding the absence of specific measurement (data gap) on the lead content of particular paint-finished building component placed within a LBP or PCL group, BEC recommends, in an abundance of caution, the Owner manage the building component present at planned work areas (eg, renovation, demolition) and/or building areas subject to routine maintenance, as LBP or PCL finished. Alternatively, BEC recommends further discrete (actual) XRF testing and/or paint chip sampling of the particular paint-finished building component to definitively reveal the lead concentration at those not evaluated during this testing event. It is relevant to note, US OSHA worker protection regulations govern the disturbance of both LBP and PCL building components.

SECTION 4.0 CONCLUSION AND RECOMMENDATIONS

4.1 Conclusions

1. BEC concludes, based upon review of the LBP inspection findings, “lead based paint” WAS detected (via XRF in situ testing) at the subject site.

2. BEC concludes, based upon review of the LBP inspection findings, “paint containing lead” WAS detected (via XRF in situ testing) at the subject site.

3. Moreover, BEC concludes, based upon the common construction (renovation) and painting histories observed at the subject site - presumptive classification of all paint films (of which were not individually tested during the Limited LPB Inspection) - as “lead based paint” is warranted, until testing rebuts this presumption

Page | 4

SECTION 4.0 CONCLUSION AND RECOMMENDATIONS

4.2 Recommendations

1. BEC recommends compliance with US OSHA “Lead-in-General Industry” standard (29 CFR 1910.1025) is required for all employers whose employees perform any maintenance activities, which involve making or keeping a structure, fixture, or foundation in proper condition on a routine, scheduled, or in an anticipated fashion, that disturbs “lead-based paint”.

2. BEC advises the US OSHA regulation “Lead Exposure in Construction” (29 CFR §1926.62) applies to all construction activities, in which employees might be exposed to lead and all related construction activities, currently excluded from the general industry standard for lead (29 CFR §1910.1025).

3. Additionally, BEC advises the State of Maryland, all work, of which an employee may be occupationally exposed to lead - falls within the authority (purview) of US OSHA. It is relevant to note, paint with any measurable lead content may, when subjected to various construction or demolition actions, yield airborne particulate levels that exceed the regulatory Permissible Exposure Level (PEL). OSHA policy explicitly requires compliance with the applicable standard for detectable levels of lead that are below the abatement levels. OSHA policy also recognizes XRF data for establishing a positive determination only. Only those surfaces, which have been determined by an accredited laboratory to be below the detection limit for lead, are exempted from these standards.

4. BEC advises that the building owner is required to communicate (i.e., specify in the contract documents) the presence of “lead-based paint” and/or “paint-containing lead” within the phase limits of the renovation/demolition work area to the general contractor.

Contract specifications governing renovation/demolition work, should explicitly require that the general contractor, and any subcontractor engaged in work that may involve contact with existing paint, make an initial exposure assessment and comply with all other pertinent provisions of 29 CFR 1926.62; notwithstanding the low potential for demolition workers’ exposures to airborne lead concentrations, in excess of the legally-enforceable Action Limit (AL, 30 µg/m3) and/or Permissible Exposure Limit (PEL, 50 µg/m3).

5. In an abundance of caution and prudent risk management, BEC recommends, at a minimum, a General Contractor- whom possesses current and valid US EPA “Renovation, Repair, and Painting (RRP)” [40 C.F.R §745.80] training certifications and contractor registration (accreditation)- conduct any and all renovation work, of which will, or can reasonably anticipated to, result in the disturbance of these PCL films.

6. Alternative to the use of RRP-accredited General Contractor, the Owner may elect to engage a bona fide professional and licensed State of Maryland “Lead Abatement Contractor” – to conduct any and all renovation work, of which will, or can reasonably anticipated to, result in the disturbance of these lead-based paint and/or paint-containing lead films. Additionally, based upon extensive historical project experience, the Owner should review internal risk management and environmental health/safety standard operating procedures (EHS SOP) programs, prior to selection of the performing contractor. A lead abatement contractor will provide the Owner with a higher level of risk management

7. BEC recommends conducting representative sampling of the comprehensive waste stream generated from (associated with) any and all renovation work, of which will, or can reasonably anticipated to, result in the disturbance of these “lead based paint” and/or “paint-containing lead” films; ensure bulk samples of both LBP and PCL-finished as well as all unpainted building components are collected to form one composite sample.

Submit the composite bulk sample to a US EPA-accredited laboratory to undergo Toxic Characteristic Leachate Procedure (TCLP) analysis to reveal appropriate disposal requirement; general construction debris versus lead-containing hazardous waste.

Page | 5

WORK PRODUCT DISCLAMER

XRF readings and/or samples collected during an investigation reflect the lead level of that particular area.

Readings and samples are collected at random in accordance with established procedures to obtain a representative overview of lead levels within or around a building. Therefore, it should not be construed that every surface, or area in or around a building was sampled or measured for lead content. Testing included exposed and accessible surfaces only, and lead-based paint may be present on securely enclosed or inaccessible surfaces, such as beneath enclosed window wells.

APPENDIX A

PROTEC “LPA-1 RADIOACTIVE ENERGY RESOURCING DATA

APPENDIX B

XRF PERFORMANCE CHARACTERISTIC SHEET

RMD LPA-1, PCS Edition 5 Page 1 of 4

Performance Characteristic Sheet

EFFECTIVE DATE: October 25, 2006 EDITION NO.: 5

MANUFACTURER AND MODEL:

Make: Radiation Monitoring Devices Model: LPA-1

Source:

Co

Note: This sheet supersedes all previous sheets for the XRF instrument of the make, model, and source shown above for instruments sold or serviced after June 26, 1995. For other instruments, see prior editions.

FIELD OPERATION GUIDANCE

OPERATING PARAMETERS:

Quick mode or 30-second equivalent standard (Time Corrected) mode readings.

XRF CALIBRATION CHECK LIMITS:

0.7 to 1.3 mg/cm

(inclusive)

SUBSTRATE CORRECTION:

For XRF results below 4.0 mg/cm , substrate correction is recommended for:

Metal using 30-second equivalent standard (Time Corrected) mode readings.

None using quick mode readings.

Substrate correction is not needed for:

Brick, Concrete, Drywall, Plaster, and Wood using 30-second equivalent standard (Time Corrected) mode readings Brick, Concrete, Drywall, Metal, Plaster, and Wood using quick mode readings

THRESHOLDS:

30-SECOND EQUIVALENT STANDARD

MODE READING DESCRIPTION

SUBSTRATE

THRESHOLD

(mg/cm

Results corrected for substrate bias on metal substrate only

Brick Concrete Drywall Metal

Plaster Wood

1.0 1.0 1.0 0.9 1.0 1.0

QUICK MODE

READING DESCRIPTION

SUBSTRATE

THRESHOLD

(mg/cm

Readings not corrected for substrate bias on any substrate

Brick Concrete Drywall Metal

Plaster Wood

1.0 1.0 1.0 1.0 1.0 1.0

RMD LPA-1, PCS Edition 5 Page 2 of 4

BACKGROUND INFORMATION

EVALUATION DATA SOURCE AND DATE:

This sheet is supplemental information to be used in conjunction with Chapter 7 of the HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing ("HUD Guidelines").

Performance parameters shown on this sheet are calculated from the EPA/HUD evaluation using archived building components. Testing was conducted on approximately 150 test locations in July 1995.

The instrument that performed testing in September had a new source installed in June 1995 with 12 mCi initial strength.

OPERATING PARAMETERS:

Performance parameters shown in this sheet are applicable only when properly operating the instrument using the manufacturer's instructions and procedures described in Chapter 7 of the HUD Guidelines.

XRF CALIBRATION CHECK:

The calibration of the XRF instrument should be checked using the paint film nearest 1.0 mg/cm in the

NIST Standard Reference Material (SRM) used (e.g., for NIST SRM 2579, use the 1.02 mg/cm film).

If readings are outside the acceptable calibration check range, follow the manufacturer's instructions to bring the instruments into control before XRF testing proceeds.

SUBSTRATE CORRECTION VALUE COMPUTATION:

Chapter 7 of the HUD Guidelines provides guidance on correcting XRF results for substrate bias.

Supplemental guidance for using the paint film nearest 1.0 mg/cm for substrate correction is provided:

XRF results are corrected for substrate bias by subtracting from each XRF result a correction value determined separately in each house for single-family housing or in each development for multifamily housing, for each substrate. The correction value is an average of XRF readings taken over the NIST SRM paint film nearest to 1.02 mg/cm at test locations that have been scraped bare of their paint covering. Compute the correction values as follows:

Using the same XRF instrument, take three readings on a bare substrate area covered with the

NIST SRM paint film nearest 1 mg/cm . Repeat this procedure by taking three more readings on a second bare substrate area of the same substrate covered with the NIST SRM.

Compute the correction value for each substrate type where XRF readings indicate substrate correction is needed by computing the average of all six readings as shown below.

For each substrate type (the 1.02 mg/cm

NIST SRM is shown in this example; use the actual lead loading of the NIST SRM used for substrate correction):

Correction value = (1 st

+ 2 nd

+ 3 rd

+ 4 th

+ 5 th

+ 6 th

Reading) / 6 - 1.02 mg/cm²

Repeat this procedure for each substrate requiring substrate correction in the house or housing development.

EVALUATING THE QUALITY OF XRF TESTING:

Randomly select ten testing combinations for retesting from each house or from two randomly selected units in multifamily housing. Use either the Quick Mode or 30-second equivalent standard (Time Corrected) Mode readings.

RMD LPA-1, PCS Edition 5 Page 3 of 4

Conduct XRF re-testing at the ten testing combinations selected for retesting.

Determine if the XRF testing in the units or house passed or failed the test by applying the steps below.

Compute the Retest Tolerance Limit by the following steps:

Determine XRF results for the original and retest XRF readings. Do not correct the original or retest results for substrate bias. In single-family and multi-family housing, a result is defined as a single reading. Therefore, there will be ten original and ten retest XRF results for each house or for the two selected units.

Calculate the average of the original XRF result and retest XRF result for each testing combination.

Square the average for each testing combination.

Add the ten squared averages together. Call this quantity C.

Multiply the number C by 0.0072. Call this quantity D.

Add the number 0.032 to D. Call this quantity E.

Take the square root of E. Call this quantity F.

Multiply F by 1.645. The result is the Retest Tolerance Limit.

Compute the average of all ten original XRF results.

Compute the average of all ten re-test XRF results.

Find the absolute difference of the two averages.

If the difference is less than the Retest Tolerance Limit, the inspection has passed the retest. If the difference of the overall averages equals or exceeds the Retest Tolerance Limit, this procedure should be repeated with ten new testing combinations. If the difference of the overall averages is equal to or greater than the Retest Tolerance Limit a second time, then the inspection should be considered deficient.

Use of this procedure is estimated to produce a spurious result approximately 1% of the time. That is, results of this procedure will call for further examination when no examination is warranted in approximately 1 out of 100 dwelling units tested.

BIAS AND PRECISION:

Do not use these bias and precision data to correct for substrate bias. These bias and precision data were computed without substrate correction from samples with reported laboratory results less than 4.0 mg/cm lead. The data which were used to determine the bias and precision estimates given in the table below have the following properties. During the July 1995 testing, there were 15 test locations with a laboratory-reported result equal to or greater than 4.0 mg/cm lead. Of these, one 30-second standard mode reading was less than 1.0 mg/cm and none of the quick mode readings were less than 1.0 mg/cm

The instrument that tested in July is representative of instruments sold or serviced after June 26, 1995.

These data are for illustrative purposes only. Actual bias must be determined on the site. Results provided above already account for bias and precision. Bias and precision ranges are provided to show the variability found between machines of the same model.

RMD LPA-1, PCS Edition 5 Page 4 of 4

30-SECOND STANDARD MODE

READING MEASURED AT

SUBSTRATE BIAS (mg/cm ) PRECISION* (mg/cm

0.0 mg/cm

Brick Concrete Drywall Metal

Plaster Wood

0.0 0.0 0.1 0.3 0.1 0.0

0.1 0.1 0.1 0.1 0.1 0.1

0.5 mg/cm

Brick Concrete Drywall Metal

Plaster Wood

0.0 0.0 0.0 0.2 0.0 0.0

0.2 0.2 0.2 0.2 0.2 0.2

1.0 mg/cm

Brick Concrete Drywall Metal

Plaster Wood

0.0 0.0 0.0 0.2 0.0 0.0

0.3 0.3 0.3 0.3 0.3 0.3

2.0 mg/cm

Brick Concrete Drywall Metal

Plaster Wood

-0.1 -0.1 -0.1 0.1 -0.1 -0.1

0.4 0.4 0.4 0.4 0.4 0.4

*Precision at 1 standard deviation.

CLASSIFICATION RESULTS:

XRF results are classified as positive if they are greater than the upper boundary of the inconclusive range, and negative if they are less than the lower boundary of the inconclusive range, or inconclusive if in between. The inconclusive range includes both its upper and lower bounds. Earlier editions of this XRF Performance Characteristics Sheet did not include both bounds of the inconclusive range as "inconclusive." While this edition of the Performance Characteristics Sheet uses a different system, the specific XRF readings that are considered positive, negative, or inconclusive for a given XRF model and substrate remain unchanged, so previous inspection results are not affected.

DOCUMENTATION:

An EPA document titled Methodology for XRF Performance Characteristic Sheets provides an explanation of the statistical methodology used to construct the data in the sheets, and provides empirical results from using the recommended inconclusive ranges or thresholds for specific XRF instruments. For a copy of this document call the National Lead Information Center Clearinghouse at 1-800-424-LEAD. A HUD document titled A Nonparametric Method for Estimating the 5th and 95th Percentile Curves of Variable-Time XRF Readings Based on Monotone Regression provides supplemental information on the methodology for variable-time XRF instruments. A copy of this document can be obtained from the HUD lead web site, www.hud.gov/offices/lead.

This XRF Performance Characteristic Sheet was developed by QuanTech, Inc., under a contract from the U.S. Department of Housing and Urban Development (HUD). HUD has determined that the information provided here is acceptable when used as guidance in conjunction with Chapter 7, Lead-Based Paint Inspection, of HUD’s Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing.

Limit of Detection (LOD)

Statistically, LOD = 3 STD (Standard Deviation) or as it is called 3Sigma. You have to be careful about LOD detection calculations. It is the calculation of Sigma (STD) that is a bit tricky. The Sigma (STD.) is not a constant; it depends on time, %Pb, substrate, etc.

One can, as some XRF manufacturers do, base the calculation of the STD on counting statistics. Scientifically, the STD calculation for XRF application should not be based solely on statistical counting or precision calculations (Random error) due to the fact that one can achieve excellent precision by measuring for a long time. So, in this model, the square root of the longest measurement time count rate is used to represent the Sigma.

Numbers as low as 0.05 mg/cm can be achieved by most XRF systems including the

LPA-1 analyzer.

The true measurement of LOD should also include the Systematic errors into the calculation of STD. The most dominating factor into the Systematic error contributor is the NIST Standard.

No one can measure better than what the calibration standards represent. The uncertainty of the NIST 1.04 sample is ± 0.064 mg/cm2. This means the STD for this sample is

0.032. Therefore, the contribution from this sample’s error alone to LOD is 3 X (.032) =

0.096 or almost 0.1 mg/cm

We suggest that you also read the “Methodology for XRF Performance Characteristic

Sheet”, EPA 747-R-95-008 that details how the HUD/EPA attempted these calculations.

You can get a copy by calling 800-424-LEAD.

We hope this note is helpful to you.

RMD Instruments, LLC

Operation of the LPA-1 analyzer and its operational statistics

Zero measurements and negative values

XRF analysis, like all other methods of measurements, is influenced by both random and systematic errors. The random errors are those that their magnitude can be reduced but not eliminated such as the effect of the radioactive decay of the source in measurements. The systematic errors are those that can be avoided, or at least corrected for. For example the effect of calibration samples, electronics, substrate, and mathematical algorithms.

The statistical terms such as precision, bias, accuracy, and uncertainty refer to these errors and are mathematical approaches for defining and measuring the contribution of each parameter. The uncertainty of a measurement is the summation of the contribution of precision, accuracy, and bias for that measurement.

The scatter on a single substrate represents random errors. We define this to be the precision. Strictly speaking, precision is the standard deviation of this scatter. The error in the mean value of lead, for a single substrate, represents a systematic error. Some would refer to this as the bias for this particular substrate, i.e., a particular piece of wood. We use the word bias to refer to the average of systematic errors for substrates class not only a particular component in that class.

The scatter in the systematic errors (strictly speaking, the standard deviation in the errors in the mean) we call accuracy. For any single reading obtained by the LPA-1, there will be some uncertainty which results from the counts used in this reading (i.e., the precision) and the systematic error in our algorithm (which is quantified by the accuracy). Because these two factors are statistically independent, the total uncertainty is given by the square of the sum of the squares of precision and accuracy.

The contribution of random and systematic errors in an analysis is best represented by a statistical distribution curve. A series of replicate measurements results in a statistical distribution curve represented by Gaussian or Normal distribution. The curve is characterized by number of measurements, range or spread, mean, and scatter or divergence. The standard deviation (sigma) for such a curve is calculated to be the square root of the variance. In practice it can be stated that the probability is 68.3% (1 sigma or 1 standard deviation) that any individual measurement will have a value between the average of all readings plus and minus the standard deviation. For 2sigma or 2 standard deviation the probability is 95.4%.

From the above explanation, one can conclude that a set of repeated measurements for a zero lead sample would result in a Guassian distribution curve with mean value of zero. This curve implies that for a perfect zero sample fifty out of one hundred measurements would be to the negative side of the curve as the other fifty would lay on the positive side. Therefore, depending on the standard deviation and degree of confidence a zero lead sample can have measured values ranging from negative to positive numbers.

Therefore, the existence of negative values should be expected and interpolated as zero lead content due to statistical nature of the XRF measurements. The lack of such negative values suggests that data have been manipulated and should be questioned.

Both the HUD and the EPA recognize the statistical nature of the analytical measurements and the possibility of obtaining negative values where the lead content is around zero. In practice, the interpretation of a negative number has been as a reading that is below the regulatory Action Level threshold and as a result is negative lead.

APPENDIX C

XRF TESTING DATA

THE PROTEC LPA-1 XRF LEAD PAINT SPECTRUM ANALYZER

LEAD PAINT INSPECTION REPORT

REPORT NUMBER: S#01677 - 12/07/22 13:23

INSPECTION FOR: MONOCACY NATIONAL BATTLEFIELD

Attn: Vincent Gentilcore – Facility Management Specialist 4801 Urbana Pike, ABATEMENT LEVEL: 0.8

TOTAL READINGS: 20

JOB STARTED: 12/07/22 13:23

JOB FINISHED: 12/07/22 14:23

PERFORMED AT: LEWIS BARN MONOCACY NATIONAL BATTLEFIELD

4403 Baker Valley Road, INSPECTION DATE: December 7, 2022

INSTRUMENT TYPE: PROTEC

MODEL LPA-1

XRF TYPE ANALYZER

Serial Number: #01677

OPERATOR LICENSE: Patricia Higbee

State of Maryland Inspector Technician (#100233) Exp: 08/19/2024

SIGNED: DATE: December 7, 2022

Patricia Higbee, Lead Inspector

SEQUENTIAL REPORT OF LEAD PAINT INSPECTION

Inspection Date: 12/07/22

Report Date: 12/7/2022

Abatement Level: 0.8

Report No. S#01677 - 12/07/22 13:23

Total Readings: 20

Job Started: 12/07/22 13:23

Job Finished: 12/07/22 14:23

Read Room Paint Paint Lead

No. Rm Name Wall Structure Location Member Cond Substrate Color (mg/cm²) Mode

1 CALIBRATION 0.8 QM

2 CALIBRATION 0.8 QM

3 CALIBRATION 0.8 QM

4 001 Number Only A Wall U Lft D Wood White 0.8 QM

5 001 Number Only A Rake Board Lft D Wood White >9.9 QM

6 001 Number Only A Fascia I Wood White 0.0 QM

7 001 Number Only A Soffit D Wood White >9.9 QM

8 001 Number Only B Window Rgt Rgt casing F Wood White -0.2 QM

9 001 Number Only B Window Ctr Sash F Wood White 0.0 QM

10 001 Number Only B Wall U Ctr D Wood White 1.2 QM

11 001 Number Only C Door Ctr L Ctr I Wood Red 0.0 QM

12 001 Number Only C Window Ctr Lft casing F Wood White 0.1 QM

13 001 Number Only C Window Ctr Sash F Wood White -0.2 QM

14 001 Number Only C Door Stop Ctr F Wood Red 0.0 QM

15 001 Number Only D Wall L Lft D Wood Red 0.4 QM

16 001 Number Only D Wall L Ctr D Wood White 0.8 QM

17 001 Number Only D Door Ctr L Ctr D Wood White -0.1 QM

18 CALIBRATION 0.8 TC

19 CALIBRATION 1.0 TC

20 CALIBRATION 0.8 TC

---- End of Readings ----

SUMMARY REPORT OF LEAD PAINT INSPECTION

Abatement Level: 0.8

Report No. S#01677 - 12/07/22 13:23

Total Readings: 20 Actionable: 5

Read Paint Paint Lead

No. Wall Structure Location Member Cond Substrate Color (mg/cm²) Mode

Exterior Room 001 Number Only

004 A Wall U Lft D Wood White 0.8 QM

007 A Soffit D Wood White >9.9 QM

005 A Rake Board Lft D Wood White >9.9 QM

010 B Wall U Ctr D Wood White 1.2 QM

016 D Wall L Ctr D Wood White 0.8 QM

Calibration Readings

DETAILED REPORT OF LEAD PAINT INSPECTION

Abatement Level: 0.8

Report No. S#01677 - 12/07/22 13:23

Total Readings: 20

Read Paint Paint Lead

No. Wall Structure Location Member Cond Substrate Color (mg/cm²) Mode

Exterior Room 001 Number Only

004 A Wall U Lft D Wood White 0.8 QM

006 A Fascia I Wood White 0.0 QM

007 A Soffit D Wood White >9.9 QM

005 A Rake Board Lft D Wood White >9.9 QM

010 B Wall U Ctr D Wood White 1.2 QM

009 B Window Ctr Sash F Wood White 0.0 QM

008 B Window Rgt Rgt casing F Wood White -0.2 QM

013 C Window Ctr Sash F Wood White -0.2 QM

012 C Window Ctr Lft casing F Wood White 0.1 QM

011 C Door Ctr L Ctr I Wood Red 0.0 QM

014 C Door Stop Ctr F Wood Red 0.0 QM

015 D Wall L Lft D Wood Red 0.4 QM

016 D Wall L Ctr D Wood White 0.8 QM

017 D Door Ctr L Ctr D Wood White -0.1 QM

Calibration Readings

001 0.8 QM

002 0.8 QM

003 0.8 QM

018 0.8 TC

019 1.0 TC

020 0.8 TC

DISTRIBUTION REPORT OF LEAD PAINT INSPECTION

Abatement Level: 0.8

Report No. S#01677 - 12/07/22 13:23

Total Reading Sets: 14

-------- Structure Distribution --------

Structure Total Positive Negative Inconclusive

Door L Ctr 2 0 <0%> 2 <100%> 0 <0%>

Door Stop 1 0 <0%> 1 <100%> 0 <0%>

Fascia 1 0 <0%> 1 <100%> 0 <0%>

Rake Board 1 1 <100%> 0 <0%> 0 <0%>

Soffit 1 1 <100%> 0 <0%> 0 <0%>

Wall 4 3 <75%> 1 <25%> 0 <0%>

Window Lft casing 1 0 <0%> 1 <100%> 0 <0%>

Window Rgt casing 1 0 <0%> 1 <100%> 0 <0%>

Window Sash 2 0 <0%> 2 <100%> 0 <0%>

Inspection Totals: 14 5 < 36%> 9 < 64%> 0 < 0%>

APPENDIX D

BEC STAFF QUALIFICATIONS

THIS IS TO CERTIFY THAT

Patricia Higbee

HAS MET THE LEAD PAINT SERVICES

ACCREDITATION REQUIREMENTS FOR

Inspector Technician

EXPIRATION DATE: 08/19/2024

TRAINING PROVIDER: Aerosol Monitoring & Analysis, Inc.

COURSE DATE: 03/28/2022

Certificate # 100233 08/19/2022 ADMINISTRATOR, LEAD PAINT ACCREDITATION Date

MARYLAND DEPARTMENT OF THE ENVIRONMENT

STATE OF MARYLAND

APPENDIX E

BEC FIELD DOCUMENTATION

APPENDIX F

BEC PHOTOSHEET

Lewis Barn – Exterior Side A

Lewis Barn – Exterior Side B

Lewis Barn – Exterior Side C

Lewis Barn – Exterior Side D

Lead Based Paint: Exterior Wall, Rake Board, and Soffit

Lead Based Paint: Exterior Wall, Rake Board, and Soffit

Paint Containing Lead – Exterior Window Casing

Paint Containing Lead – Exterior Wall