Bldg. 2010 Lead Paint Survey (1).pdf

Lead Paint Survey

FORT BLISS - BUILDING 2010

November 23, 2020

Prepared for:

Paul Raisch

Bldg. 622 Taylor Rd.

Fort Bliss, Texas 79916

Prepared by:

Cherokee Nation Management and Consulting

Bldg. 622 Taylor Rd.

Fort Bliss, Texas 79916

November 23, 2020

Attention: Paul Raisch Phone: (915) 568-2638

Re: Lead Paint Inspection Fort Bliss - Building 2010 Fort Bliss, Texas

Mr. Raisch

The purpose of this report is to present the results of a lead-based paint (LBP) survey conducted on November 23, 2020, to establish lead levels present in the building materials for building 2010. We understand that this survey was requested due to the possibly planned demolition and/or renovation activities which may involve the structure.

Twenty two (22) of the paint materials sampled as part of this survey were found to contain lead in concentrations greater than 1 mg/cm^2, which would render the coatings “lead-based paint” as established by EPA and HUD. Please refer to the attached report for details.

CNMC appreciates the opportunity to provide this service to DPW - Fort Bliss. If you have any questions regarding this report, or if you need assistance with project oversight and sampling during demolition or renovation of this building, please contact the undersigned at (915) 568-7986.

Respectfully Submitted, Cherokee Nation Management and Consulting

Francisco Lujan Lead Inspector TDSHS Certification No. 2070664

TABLE OF CONTENTS

Page

1.0 SUMMARY………….…………….…...………………………………………..1

2.0 BUILDING DESCRIPTION…………………………………………………….1

3.0 REGULATIONS…………………..…………………………………………….1

4.0 SAMPLING AND TESTING…….……………………………………………..2

4.1 Review of Previous Inspection report(s)……………………………..2

4.2 Methodology……...…………………….……………………………….2

4.3 XRF Instrumentation…………….……..………………………………2

5.0 LEAD INSPECTION RESULTS……………………..………………………..3

6.0 FINDINGS AND RECOMMENDATIONS…………………………………….3

7.0 GENERAL COMMENTS……………………………...…………….....………4

APPENDIX A SITE DRAWING(S)

APPENDIX B LEAD-BASED PAINT SAMPLE LOG AND RESULTS

APPENDIX C LICENSES AND CERTIFICATIONS

LEAD SURVEY REPORT

Fort Bliss - Building 2010 Fort Bliss, Texas

1.0 SUMMARY

Cherokee Nation Management and Consulting (CNMC) has completed this report for the lead-based paint inspection conducted on November 23, 2020, at building 2010. Our report presents project information, inspection procedures, visual observations, survey results, building drawings, conclusions, and recommendations.

The survey was conducted to establish lead levels present in the building materials associated with this specific building. The survey was performed by Omar Vallez and Miguel Flores Hernandez, Environmental Protection Agency (EPA) accredited lead inspectors employed by

CNMC.

The lead-based paint survey was conducted in general accordance with Texas Environmental Lead Reduction Rules (TELRR) and the US Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based paint Hazards in Housing (Chapter 7 - Lead-based Paint Inspection) with the 1997 and 2000 revisions. The lead-based paint inspection was performed to identify lead hazards and lead-based paint that may be present in the aforementioned building prior to renovation/demolition activities. This information is necessary in order for contractors to comply with OSHA regulation 29 CFR 1926.62 Safety and Health Regulations for Construction - Lead.

2.0 BUILDING DESCRIPTION

The building is a single story, stone masonry structure with a slab-on-grade foundation. The roof was a pitched design with an asphaltic membrane. The interior of walls of the building consisted of painted drywall. The floor area throughout the building was made up of resilient floor tile.

Ceilings throughout the approximately 1,659 square foot building, were covered in plaster or consisted of painted gypsum board systems. The building was constructed in 1908.

3.0 REGULATIONS

HUD has issued guidelines titled Guidelines For the Evaluation and Control of Lead-Based Paint Hazard in Housing (Chapter 7 - Lead-Based Paint Inspection) pursuant to Title X of the Housing and Community Development Act of 1992. The US Environmental Protection Agency (EPA)/HUD action level for lead-based painted surfaces is 1.0 milligrams per square centimeter (1.0 mg/cm^2) using the X-ray fluorescence analyzer (XRF) method, or 0.5% dry weight using the atomic absorption analytical method.

The State of Texas currently issues certifications for lead-based paint related activities and has adopted the HUD Guidelines as the standard for lead-based paint related activities.

The Occupational Safety and Health Administration (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 work.

4.0 SAMPLING AND TESTING

4.1 PRIOR LEAD-BASED PAINT REPORTS

No previous LBP reports were available for review.

4.2 METHODOLOGY

A VIKEN Pb200i XRF was used to determine if a surface coating contained lead-based paint. The inspection was conducted by Miguel Flores Hernandez, an EPA accredited lead inspector, employed by CNMC. Inspector credentials are contained in Appendix C.

The building was evaluated to identify the different testing combinations present. CNMC conducted a visual assessment of each area where lead-based paint sampling would be conducted. The visual assessment included evaluating the condition of painted surfaces throughout the building. Per HUD Guidelines for testing housing, individual tests are to be classified as part of a group, based on the testing combination (substrate and component color may be used). Substrates are classified as brick/masonry, concrete, drywall, metal, plaster, or wood. A component is defined as a particular item, such as doors, windows, walls, etc. When using testing combinations, lead-based paint results are classified by summing the individual component test results of positive, negative, or inconclusive.

For detailed information, including testing location, component, color, and substrate, refer to the inspection results table found in Appendix B.

4.3 XRF INSTRUMENTATION

An X-ray fluorescence (XRF) analyzer was used to obtain direct results of lead content in painted surfaces on select interior and exterior surfaces of the building. XRF values are read and recorded in the field.

The XRF was calibrated with two samples before each inspection was performed. This calibration involves measurement of known lead films (NIST reference standards). 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 factor is the quality of the reference standard lead film prepared by NIST. The second factor is the accuracy of the mathematical function, that is, 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.

Calibration checks are performed at least once daily, each time prior to the inspection. (see XRF results in Appendix B for calibration results), using protocols provided by HUD and the instrument manufacturer according to the NIST reference standard. 254.222.

The instrument was used in general accordance with HUD inspection guidelines and the procedures detailed in the manufacture’s XRF Performance Characteristics Sheet (PCS).

According to 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.

5.0 LEAD INSPECTION RESULTS

Forty-Nine (49) readings from various paint combinations were obtained from the coatings applied to the building materials related to this study. The lead survey was conducted in general accordance with TELRR and HUD guidelines and was intended to identify and assess suspect paint materials which may contain lead. The locations and types of samples collected were at the discretion of the certified lead inspector. Materials not sampled include ceramic tile, unfinished wood, rubber, and hidden/inaccessible components i.e. materials within walls, unsafe areas, beyond reach from available ladders, etc.

All results were obtained from the surfaces within the building utilizing an XRF. XRF technology allows for the detection of lead in a painted surface, even several layers below the surface, without disturbing the painted surface. Lead-based paint means paint that contains lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm^2) or more than 0.5% or 5000 parts per million by weight as established by EPA and HUD regulations.

22 of the paint materials sampled and analyzed as part of this survey were found to contain lead in detectable concentrations and would be considered a potential hazard under OSHA regulations.

6.0 CONCLUSIONS AND RECOMMENDATIONS

In areas where a renovation or demolition project, which could disturb the paint materials applied to the facility is to be conducted, it is recommended that contracting personnel who may disturb the paint coatings associated with the facility be made aware of the findings of this study so that they may exercise proper OSHA procedures for personnel protection.

As the facility is not a child-occupied facility or target housing, HUD and TDSHS lead regulations do not apply to removal operations within the facility. It is, however, recommended that they be consulted as a general guideline for occupant protection and that OSHA notification be made to all employees or contractors working on any repair, renovation or demolition projects within the facilities.

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 EPA Renovation, Repair, and Painting Final Rule (40 CFR 745) or applicable portions of the Structural Steel Painting Council (SSPC) Guidelines.

7.0 GENERAL COMMENTS

This lead-based paint inspection 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 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 inspections was performed, and should not be relied upon to represent conditions at a later date.

Contractors, consultants, or others reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. CNMC 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, expressed or implied is made.

APPENDIX A

SITE DRAWING(S)

APPENDIX B

LEAD-BASED PAINT SAMPLE LOG AND RESULTS

APPENDIX C

LICENSES AND CERTIFICATIONS