Exhibit C SampleSitePlan___6450.pdf

LCCHP – LEAD-BASED PAINT & LEAD CONTAMINATED DUST

REMEDIATION RESPONSE ACTION SCOPE OF WORK

AND SITE PLAN

in Leadville, Colorado

PROJECT PARTICIPANTS

CDPHE Representatives:

Project Consultant:

Lead Inspector & Risk Assessor:

Senior Project Manager:

Lead Abatement Contractor:

Contractor Lead Supervisor:

Contractor Project Manager:

GENERAL SCOPE OF WORK:

Introduction-

Section 5.5 Dust Response Actions-

5.5.1 – Contractor Requirements

5.5.2 – Site Controls

5.5.3 – Dust Removal Actions

5.5.4 – Dust Abatement Actions

5.5.5 – Dust Clearance Sampling

Section 5.6 Interior/Exterior Paint Response Actions-

5.6.1 – Contractor Requirements

5.6.2 – Site Controls and Containment Procedures

5.6.3 – Interior/Exterior Paint Remediation Procedures

5.6.4 – Interior Paint Clearance Sampling

5.6.5 – Exterior Paint Clearance Sampling

5.6.6 – Soil Response Actions Related to Exterior Paint Action

Site-Specific Scope of Work Summary

• Interior/Exterior Deteriorated LBP Abatement (Window Friction Points, Sash/Frame/Troughs):

• Interior Deteriorated LBP Stabilization

• Exterior Deteriorated LBP Stabilization

• Interior Lead Contaminated Dust Cleaning & Final Visual Inspection and

Clearance Sampling

Exhibit C

Introduction:

The Lake County Community Health Program (LCCHP) Phase 2 Work Plan functions as the primary blood lead reduction program for Lake County and acts as the institutional control for Operable Unit 9 (OU for Residential Populated Areas) of the California Gulch Superfund site. The purpose of the LCCHP Phase 2 is to provide reduction in lead exposure from a wide range of potential sources for young children and pregnant or nursing women, thereby reducing blood lead levels in children who reside within Lake County. The LCCHP is operated via a collaboration between the Lake County Public Health Agency (LCPHA), the Lake County Commissioners, the Environmental Protection Agency (EPA), and the Colorado Department of Public Health and Environment (CDPHE).

Based on a previous LCCHP Environmental Investigation conducted at the residence located at (the “subject property”) (LCCHP Phase 2 Lead Risk Assessment, Environmental Investigation for Leadville, CO 80461), various media was identified throughout the subject property with lead levels exceeding the LCCHP Phase 2 action levels (i.e., trigger criteria/standards) and met the criteria for conducting remediation response actions per the LCCHP Phase 2 Work Plan guidelines. These media consisted of interior/exterior lead-based paint, interior lead-contaminated dust, and exterior lead-contaminated soil. The exterior lead-contaminated soil was addressed separately and remediated during the Fall of 2016 by the EPA’s Removal Program, with the final report issued under a separate cover from this document.

The objective of the following Lead-Based Paint and Lead Contaminated Dust Remediation Response Action Scope of Work document is to abate the damaged/deteriorated lead-based paint within the interior/exterior of the subject property, and to abate the lead contaminated dust within the interior of the subject property in an effort to decrease and/or eliminate the pathway of lead exposure to the residents. In general, paint stabilization methods will be applied within the interior and exterior of the home to abate the currently exposed and damaged/deteriorated lead-based paint. Alternatively, there is the potential for replacement or cover material to be utilized to stabilize the current lead-based paint and would be similar in kind to the existing materials to be removed or enclosed, with consideration given to property owner/resident preferences. The lead contaminated dust abatement will consist of LCCHP Phase 2 Work Plan accepted work practices conducted by a state of Colorado certified Lead Abatement Contractor (LAC), which consists of cleaning and clearance sampling to verify the removal/abatement of interior lead contaminated dust. At the conclusion of interior/exterior lead-based paint stabilization and lead contaminated dust cleaning, GHP’s State of Colorado Certified Lead Inspector/Risk Assessor will visually clear the work areas and conduct clearance sampling in strict accordance to the LCCHP Phase 2 Work Plan guidelines.

The LAC will comply with and perform all work in strict accordance with the LCCHP Phase 2 Work Plan guidelines, including but not limited to Section 5.5 Dust Response Actions, Section 5.6 Interior/Exterior Paint Response Actions and comply with all Occupational Safety and Health Administration (OSHA) Construction Standard and OSHA Lead Standard 1926.62, EPA, and CDPHE – Air Pollution Control Division (APCD) Regulations where applicable.

In the process of identifying appropriate options and making recommendations for response actions, GHP evaluated the condition of existing lead-based paint conditions, the use patterns/high traffic areas within the interior of the subject property in regard to possible elevated dust levels and exterior roof/drainage patterns. In general, lead based paint stabilization, friction point adjustment, as well as an interior lead contaminated dust cleaning/clearance, will be the preferred response action options.

All work will be carried out as detailed in this Remediation Scope and Site Plan and in accordance with the provisions of the Contractors Agreement and the General Conditions of the Contractors Agreement.

5.5 Dust Response Actions:

Introduction: This section outlines the requirements and procedures common to all dust response actions and provides general requirements or specifications for each type of action selected. The general categories of action options available, other than no action, are as follows:

• Education

• Physical Protective Measures

• Removal and Disposal

Per the LCCHP Phase 2 Work Plan guidelines, the most commonly recommended and implemented dust response options, for situations where dust-lead concentrations exceed the trigger criterion of 2,000 milligrams per kilogram (mg/Kg), will be removal options. For the purposes of the LCCHP Phase 2 there are two categories of removal response actions. One is defined as a dust removal action and the other as a dust abatement action. A dust removal will typically be recommended in situations where there are no exceedances of trigger criteria for lead in interior paint and the paint is in good condition. A dust abatement, which includes some additional activities, will typically be recommended if paint is identified as a potential contributor to lead in dust and will always be implemented following the completion of a paint removal or abatement action which potentially generates lead-containing dust inside the home.

Where dust lead levels are found between 500 and 2,000 mg/Kg, residents will also be informed about lead dust abatement methods.

It is important to note that during the previous Environmental Investigation conducted at the subject property, dust wipe samples were collected, which is the preferred methodology, in order to verify if the dust media contained lead above the LCCHP Phase 2 Trigger Criteria. Results for the dust wipe sampling methodology are reported in micrograms per square foot (µg/ft²). However, the LCCHP Phase 2 Trigger Criteria for lead in dust is reported in mg/kg (Trigger Criteria = ≥2,000 mg/kg), as stated above. The LCCHP Phase 2 Work Plan does, however, also include Clearance Values for dust with levels reported in µg/ft² (see list below for clearance values). Therefore, these clearance values were utilized to identify locations within the subject property where dust levels exceed the LCCHP Phase 2 Work Plan guidelines for lead contamination, and will be utilized for the dust removal/abatement response actions.

The LCCHP Phase 2 Work Plan defines the following clearance (acceptable) values for lead dust in residences:

Interior floor samples <100 µg/ft2 Interior window samples <500 µg/ft2

Exterior window sill <500 µg/ft2 Exterior surface samples <800 µg/ft2

Educational support will always be provided to residents where lead in dust is a concern. Residents will be provided educational materials on how to effectively reduce lead-dust through cleaning activities (e.g., regular cleaning routines, wet dusting, etc.).

The LCPHA has already been working closely with the subject property homeowners/parents in order to share such educational material. Annual (and potentially monthly) blood lead monitoring for young children is strongly recommended through the LCPHA.

Physical protective measures such as sealing off unfinished attic, crawlspace or cellar areas, as referenced in the California Gulch Superfund Site Record of Decision, will not constitute a typical dust response action. These areas of a home are not sampled during LCCHP Phase 2 dust sampling efforts as described in Section 4.1.3 of the LCCHP Phase 2 Work Plan. Specific physical protective measures to be considered will be developed, if necessary, and evaluated on a property specific basis using the results of additional investigative and sampling efforts.

5.5.1 Contractor Requirements

The LAC firm shall hold and retain certification as a State of Colorado Lead Evaluation Firm, in accordance with Section III.B. of CDPHE Regulation 19. All personnel performing dust abatement or dust removal activities must have successfully completed an accredited training course for lead-based paint abatement workers, in accordance with Section III.B. of Colorado Regulation 19. Supervisors are required to complete an accredited supervisor training course and be certified by the State of Colorado, in accordance with Section III.B. of Colorado Regulation 19. Evidence of appropriate training and required certifications for the firm and all personnel will be kept on record with CDPHE.

5.5.2 Site Controls

The following general site controls and containment procedures will be followed during dust removal and dust abatement response actions.

• Whenever dust removal/dust abatement activities are conducted, residents (especially children) will be asked to stay out of the house. If residents must stay inside the house during remediation, the appropriate barrier systems will be erected.

• “Lead Hazard” warning signs will be posted at the entry to each area being treated. A physical barrier is required to prevent access to the work area by the resident(s).

• The ventilation system will be turned off during cleaning activities.

• A State-certified supervisor is required to be on the site during work-site preparation and abatement activities and during post-abatement cleaning activities.

• A site Health and Safety Plan, including a Lead Compliance Plan, will be developed by the LAC to address worker health and safety at properties where dust removal and abatement actions are performed.

• Prior to performing remediation activities, the abatement supervisor will determine the appropriate work-site containment level (based on the requirements specified by Regulation 19). The work-site containment level is based on the size of the area to be disturbed and the type of remediation activities performed. For dust abatement actions following a paint action, the containment established for the paint action (refer to Section 5.6 of the LCCHP Phase 2 Work Plan) will be maintained during dust abatement actions.

• All waste generated by removal/abatement activities should be removed from the house and stored in a secure, locked area. Disposal will be performed as discussed in Section 6.

5.5.3 Dust Removal Actions

Dust removal response actions will be conducted to remove the lead dust accumulation generated by lead-containing soils, lead-based paint, and other materials that have been tracked into a residence from an on-site or off-site source. In general, on-site sources of lead dust come from the property’s lead-containing soils and lead-based paint. Dust removal for an on-site source of lead can be conducted as an interim control measure or after soil remediation activities have been performed.

Dust removal actions consist of thoroughly cleaning all horizontal surfaces with the exception of ceilings. The detailed procedures for dust removal activities as described in Chapter 11, Section IV.b.2. of Housing and Urban Development’s (HUD’s) 1995 Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (HUD Guidelines) will be followed. All hard surfaces will be cleaned with a minimum of two passes with a HEPA-filter-equipped vacuum cleaner (HEPA vacuum) and then wet-washed with a tri-sodium phosphate (TSP) detergent and rinsed with clean water.

Cleaning should begin with the highest horizontal surface and end with the lowest. Tops of windows would be cleaned first followed by tops of sashes, mullions, interior window sills and troughs. Areas that tend to trap dust should also be cleaned (i.e., radiators, baseboards, vents/registers, mini-blinds, and all horizontal components of ventilation ducts).

Wall-to-wall carpeting and area rugs are cleaned with a HEPA vacuum equipped with a beater bar or agitation attachment. Area rugs are first vacuumed on the pile side at a rate no faster than one (1) minute for every 10 square feet. The rug is then folded in half, exposing the backing. The backing is vacuumed at the same rate as before without using the beater bar. The rug is unfolded and folded in half the other direction exposing the backing on the other half of the rug. The vacuuming procedure is repeated on the second half. The top or pile side of the rug is then vacuumed again using the beater bar at a rate no faster than 2 minutes for every 10 square feet. Wall-to-wall carpeting is vacuumed in two segments using the beater bar attachment. The two segments are in perpendicular directions. The vacuum rate is no faster than 2 minutes for each 10 square feet.

After all cleaning activities have been completed, a State-certified Lead-Based-Paint Inspector or Risk Assessor will perform a visual inspection and conduct clearance sampling, as described in Section 5.5.6. and the SOP for Clearance Dust Sampling (Appendix A of the LCCHP Phase 2 Work Plan).

5.5.4 Dust Abatement Actions

Dust abatement actions are generally associated with lead-based-paint abatement activities. The procedures for dust abatement activities, as described in Chapter 14, Section V of the HUD Guidelines and Section V.H. of Colorado’s Regulation 19, will be followed. All surfaces (horizontal and vertical) are cleaned during dust abatement.

Procedures are generally the same as those for dust removal actions. Cleaning begins with the highest surface and ends with the lowest surface. Ceilings are cleaned first, then the tops of walls and so on working downward to the floor. The surfaces are first cleaned with a HEPA vacuum then wet-washed with TSP detergent and then rinsed with clean water. The rinsed surfaces are allowed to dry and one final pass is made with the HEPA vacuum. Wall-to-wall carpeting and area rugs will be cleaned using the same procedures outlined above for dust removal actions. After all cleaning activities have been completed, a State-certified Lead-Based Paint Inspector or Risk Assessor will perform a visual inspection that will then be followed up by clearance sampling, as described in Section 5.5.6. and the SOP for Clearance Dust Sampling (Appendix A of the LCCHP Phase 2 Work Plan).

A dust abatement should be performed a minimum of one hour after all paint-related activities have ceased to let dust particles settle. All containment plastic placed prior to remediation activities should be misted with water and cleaned. Plastic used to isolate contaminated rooms from non-contaminated rooms should be left in place and are the last to be removed.

5.5.5 Dust Clearance Sampling

Following response actions to address lead-dust, samples will be collected to confirm that the actions performed have been effective in reducing the exposure to identified lead-dust hazards. A visual inspection will also be performed to confirm that all areas adjacent to the work area and used to access the work area are visibly free of dust, debris or residue and to confirm that work was conducted as specified in the Response Action Plan. The clearance samples will be collected from within the work area at least one hour after the completion of remediation and cleaning activities.

Clearance dust samples are collected using the wipe method described in the SOP for Clearance Dust Sampling (Appendix A of the LCCHP Phase 2 Work Plan).

Clearance samples will be collected by a trained and State-certified Lead-Based Paint Inspector or Risk Assessor. One wipe sample will be collected from the floor and one from a window sill, if present, in each room of the work area. If any paint sealants were used as part of the response action, then the clearance samples will be collected at least one hour after the sealant has dried. All clearance samples will be submitted to a National Lead Laboratory Accreditation Program (NLLAP)-recognized laboratory for analysis of lead.

Each wipe sample must meet the following clearance levels for lead in order for work to be considered complete: floor samples <100 μg/ft2 and window samples <500 μg/ft2. If a clearance sample exceeds these levels, dust response actions will be repeated and clearance samples will be collected again.

5.6 Interior/Exterior Paint Response Actions:

Introduction: The objective of a paint response action is to provide an appropriate level of risk reduction from potential exposure to lead in paint. A wide range of options may be considered in response to lead in paint and, as with other media responses, an appropriate action will be determined on a case-by-case basis considering the preferences of the property owner/resident. This section outlines the requirements and procedures common to most paint response actions and provides general requirements or specifications for each type of action selected. References are provided, as appropriate, to specific requirements contained in other guidance or regulations.

The general categories of action options available and sub-categories are as follows:

• Education

• Source Control, Containment, or Covering

-Paint film stabilization -Encapsulation -Enclosure of a painted area -Friction and impact surface treatments

• Paint Removal and Replacement -Paint removal

Because of the dual trigger criteria for paint, education is an important component of all paint response actions. In situations where paint contains lead above 1 milligram per centimeter (mg/cm2) and is in poor/deteriorating condition or coating a friction surface, education will be the primary intervention provided to help reduce potential risks associated with lead-based paint. In situations where paint has lead levels greater than 6 mg/cm2 and is in poor/deteriorating condition, active remediation will be recommended, but education will continue to play an important role in overall risk reduction.

Active remediation may consist of one or more of the source control and paint removal options listed above. Several options provide risk reduction through ‘source control’ (i.e., through actions other than removal) including paint film stabilization, encapsulation, enclosure, and friction and impact surface treatments. Paint film stabilization is the process of applying a protective coating over existing lead-based paint surfaces. Encapsulation is the process of applying a liquid coating or adhesively bonded covering material to act as a barrier between lead-based paint and the environment. Enclosure is the installation of a rigid barrier over lead-based paint surfaces in order to prevent access and exposure. The treatment of friction and impact surfaces by repairing, replacing or covering the affected components may also be implemented. Removal options consist of either removing the paint alone or the entire painted component (e.g., door, window, or trim).

Certain activities or work practices, as described in Section V.B.1 of Colorado’s Regulation 19, will be prohibited for use in activities related to lead-based paint. In general, these restricted activities include: open-flame burning or torching; dry sanding or scraping; machine sanding, grinding, abrasive blasting, sandblasting; drilling or cutting; and high-pressure water washing. Machine sanding, grinding or abrasive blasting may only be used if equipped with HEPA exhaust control devices which are capable of continually capturing all particulates generated. Similarly, high-pressure water washing, or hydro blasting, may only be used if the point of operation is completely self-contained and the water is captured within a local shroud. Chemical stripping methods will be used only to remove paint from highly decorative or ornate components or surfaces that are otherwise difficult to abate by any other method, and to accommodate the preference of the homeowner.

For properties investigated by the LCCHP, paint testing and assessment results will be available on request to future property owners. In addition, any information provided by CDPHE or the LCCHP Work Group, to a property owner regarding the presence of lead-based paint must be disclosed to future purchasers of that property in accordance with HUD’s lead-based-paint disclosure rules. Educational materials targeting homeowners and remodelers will provide relevant information about methods to reduce exposure to lead from lead-based paint in the home (refer to Section 3.3 in the LCCHP Phase 2 Work Plan).

5.6.1 Contractor Requirements

All personnel performing lead-based paint remediation activities must have successfully completed an accredited training course for lead-based paint abatement workers, in accordance with Colorado Regulation 19. Supervisors are required to complete the accredited supervisor training and be certified by the State of Colorado as described in Section III.B. of Colorado Regulation 19. Evidence of appropriate training and required certifications for all personnel will be kept on record with CDPHE. Personnel performing work not directly involved in lead-based paint abatement (e.g., the installation of enclosures or the replacement of building components) must be skilled in their respective trade but will not be required to have specific training for lead-based paint activities. A State-certified lead-based paint abatement supervisor will supervise such personnel.

5.6.2 Site Controls and Containment Procedures

This section addresses general site controls and containment procedures that will be implemented prior to and during paint abatement activities.

As part of the Response Action Plan for response actions addressing lead-based paint, measures to be taken during the response action to protect the residents from exposure to any lead-based paint hazards will be identified, consistent with the requirements of an “Occupant Protection Plan,” described in Section V.A.6 of Colorado Regulation 19. At a minimum, residents will be required to stay out of work and containment areas and asked to stay out of the house during active operations. The need for temporary relocation of the residents during interior paint response actions will be considered on a case-by-case basis, depending on the area of the home affected by activities, the level of containment required, the anticipated duration of activities, and the preferences of the residents.

Prior to performing remediation activities, the abatement supervisor will determine the appropriate worksite containment level based on the type of activities to be performed, the size of the area affected, and other requirements specified by Colorado Regulation 19. The appropriate level of containment will be selected in accordance with the following sections of Colorado Regulation 19: Section V.C. for interior abatement (excluding window abatements); Section V.D. for exterior abatement; and Section V.E. for window abatements. In general, the containment activities addressed will include the following items:

1. Warning Signs

2. Warning Barriers

3. Ventilation System Shutdown (interior abatements only)

4. Protection of Objects

5. Floor or Ground Protection

6. Cleanup Activities

7. Special Work Area Egress Requirements (if any)

8. Conditions Requiring the Use of a Negative Air Flow Machine

The integrity of all containment systems will be inspected regularly and maintained to prevent the potential spread of lead contamination outside the work area. In the event of a breach or malfunction of any containment component, appropriate measures will be taken to remedy the situation and the area potentially contaminated will be cleaned in accordance with the procedures described in Section

5.5.4 of the LCCHP Phase 2 Work Plan as soon as the condition is observed.

A State-certified Lead-Abatement Supervisor is required to be on site during remediation activities. The abatement supervisor will ensure that work is conducted in accordance with the Health and Safety Plan and Lead Compliance Plan developed for the project. Oversight will be performed by CDPHE or their representative, certified as a Lead-Based Paint Inspector or Risk Assessor to monitor the performance of the work in accordance with the Response Action Plan and applicable provisions of Colorado Regulation 19.

During remediation or abatement activities, all horizontal surfaces in the work area will be cleaned of visible dust and debris prior to ceasing work each day. Following the completion of activities, dust abatement will be performed as described in Section

5.5.4 of the LCCHP Phase 2 Work Plan and in accordance with Section V.H. of Colorado Regulation 19. Waste generated by remediation activities will be handled in accordance with Section V.K. of Regulation 19. In general, lead contaminated waste will be wrapped and sealed in 6-mil polyethylene sheeting prior to removing the waste from the work area and will be stored in a covered container in a locked area if not transported off-site immediately for disposal. Disposal activities are addressed in Section 6 of the LCCHP Phase 2 Work Plan.

5.6.3 Interior/Exterior Paint Remediation Procedures

Lead-based paint response actions utilize the same basic techniques for performing both interior and exterior remediation. Following are general procedures for each type of remedial response listed above in Section 5.6.

5.6.3.1 Education

When lead-based paint is present, the LCCHP (via the LCPHA) will provide educational materials to the property owner and current residents (if different) to explain the risks related to lead-based paint and ways to reduce exposure to lead originating from lead-based paint. Relevant educational materials provided by the LCCHP may include USEPA publications such as: Reducing Lead Hazards When Remodeling Your Home (USEPA, 1994) and Protect Your Family from Lead in Your Home (USEPA, 1999a). At the same time that educational materials are provided, LCCHP staff will explain risks and methods to reduce those risks to the family.

In addition, before starting any response actions that are likely to disturb lead-based paint, the owner and/or residents will be informed of the dangers associated with these types of activities due to the potential for increased exposure during these activities.

5.6.3.2 Source Control, Containment, or Covering

This section describes the general procedures and references relevant specific regulations and guidelines for source control actions, including paint film stabilization, encapsulation, enclosure, and friction and impact surface treatments.

For any and all source control actions performed as part of this Response Action Plan, the LAC will utilize floor (interior) and ground (exterior) coverings (i.e., drop cloths) to prevent lead-based paint from contaminating the floor or ground surface(s) during abatement activities. Upon completion of activities, drop cloths will be wrapped in 6-mil plastic and sealed with tape. Waste management and disposal will be performed as outlined in Section 6.2, Lead-Based Paint, Dust and Associated Debris of the LCCHP Phase 2 Work Plan.

Paint Film Stabilization

Paint film stabilization is the process of painting over existing lead-based painted surfaces with a non-toxic, protective coating and will be performed in accordance with Section V.I.1 of Colorado Regulation 19. The types of finish coats to be used for lead-based paint stabilization include varnish, acrylic latex, polyurethane and deck enamel.

Prior to coating, the substrate will be inspected and items such as loose wall or ceiling plaster, loose trim or wallpaper, missing hinges or doorknobs, etc. should be repaired or replaced by the homeowner. In addition, the source of any water damage should be identified and repaired by the homeowner. All surfaces will be prepared, as necessary, to help ensure adequate adhesion or bonding. Steps to be taken to prepare the surface may include: (1) removing all loose surface material by wet scraping or wet sanding; (2) removing all surface contaminants that will reduce the adhesion of the paint with degreasers or detergents; (3) treating (roughening) glossy surfaces by wet sanding, HEPA-vacuum-assisted sanding or chemical etching; and (4) enhancing substrate adhesion by chemical etching, wet sanding, spot sealing and applying rust inhibitors.

After the affected surface has been prepared for painting, it will be vacuumed with a HEPA-filter-equipped vacuum cleaner to eliminate any lead dust. To maximize the life of the paint cover, a system of compatible coatings is necessary. In selecting an appropriate coating or paint, the following factors will be considered; the type of substrate involved, type of the existing substrate coating, type of primer to be used, whether it will be applied inside or outside and the type of topcoat.

Encapsulation

Encapsulation is a process that makes lead-based paint inaccessible by providing a barrier between the lead paint and the environment. The requirements for encapsulation systems provided in Section V.G. of Colorado Regulation 19 will be followed. The barrier is formed using a reinforced or non-reinforced liquid-applied coating (e.g., LeadMaster, L-B-C Lead Barrier Compound and Insl-Cap Lead Encapsulating Compound) or an adhesively bonded covering material (e.g., sheet vinyl systems, floor tile, wall systems and other adhesively bonded systems). Liquid encapsulants are usually applied with brushes, rollers, sprayers or trowels. Only surfaces with non-deteriorated substrates may be considered for encapsulation. Deteriorated components or paint films (i.e., rotten wood, rusted steel, spalled plaster, masonry in need of repainting, and areas that are subject to moisture problems) are not recommended for encapsulation.

Friction surfaces, such as window jambs, interior floors, exterior wood flooring and stairs, are also unsuitable for encapsulation. The surface preparation procedures described above for paint film stabilization will be performed prior to applying an encapsulant.

Because most lead-based paint films are made up of many paint layers, a measure of how well these layers adhere to each other and to the base substrate will be a good indicator of whether or not the surface should be encapsulated. The paint film must demonstrate adequate adhesion between the layers and to the substrate, as determined by a certified inspector, using appropriate methods in accordance with HUD Guidelines.

To determine whether or not an existing painted surface is a viable candidate for encapsulation and to determine the proper encapsulant, a “patch test” will be performed. A patch test is a field test procedure in which a small area of the existing lead-based paint surface is prepared and the encapsulant applied. At least one patch test should be performed for each type of component in each room or exterior location where the encapsulant is to be used. Patch tests should also be performed on those surfaces that are the most likely to fail. For instance, patch tests should be performed in areas that have been identified with potential adhesion problems due to moisture or on load-bearing walls because they are subject to higher stresses.

In general, encapsulants must not be applied over dirt, rust, oil, grease, mildew, chalk or other surface contaminants. The painted surface should be cleaned with a tri-sodium phosphate (TSP) detergent. After washing, the surface is rinsed with clean water. Some lead-based paint films are glossy and should be deglossed to improve adhesion with the selected encapsulant. Special deglossing materials are usually suggested by the encapsulant manufacturer. In some cases, wet sanding may be the only effective method of de-glossing. All loose paint should be removed from the surface by wet-scraping. The area prepared for the patch test should be at least 2 inches larger in each direction than the area to be encapsulated for the test. For liquid applied encapsulants, a patch test will be conducted on a 6-inch by 6-inch area on one wall of each room being treated unless it has been established that both rooms have the same paint history. For fiber-reinforced encapsulants, a smaller 3-inch by 3-inch area may be used. After the surface has been prepared, the encapsulant is applied and cured according to the manufacturer’s recommendations. After the encapsulant has cured, the patch is examined for adhesion and compatibility with the existing lead-based paint. There are a number of tests that may be employed to evaluate encapsulant adhesion, as described in Chapter 13, Section V.I.C of the HUD Guidelines, including the X-Cut Adhesion Method, the Patch Edge Method or the Soundness Method. The decision to proceed with an encapsulation response action and selection of the encapsulant may depend on the results of such a patch test.

Enclosure

Enclosure is the installation of a rigid, durable barrier that is mechanically attached to building components. Surfaces with lead-based paint are enclosed in order to prevent access and exposure and to provide a “dust-tight” system. Enclosure is normally implemented for large surfaces such as walls, ceilings, floors and siding.

Enclosure systems will be installed following the procedures presented in Section V.G. of Colorado Regulation 19 and Chapter 12, Section III of the HUD Guidelines.

All unsound substrates and structural members that will support the enclosure will be repaired prior to constructing the enclosure. All lead-based painted surfaces to be enclosed will be labeled with warning signs (“Danger: Lead-Based Paint”) every 2 feet, both vertically and horizontally. A drawing of the building’s floor plan that shows where the lead-based paint has been enclosed will be prepared and included with the Property Documentation Report provided to the property owner. A copy of this drawing, covered with plastic, will be placed within the building in an easily accessible area such as a utility room or closet.

The following materials can be used to construct interior surface enclosures:

wood paneling, gypsum drywall/fiberboard and certain types of laminated wall sheeting products. Wood paneling is commonly used for wall enclosures but cannot be used for ceiling enclosures. There should be no gaps in seams, around outlets, boxes and registers. All seams should be caulked. Drywall/fiberboard may be used for wall and ceiling enclosures. The drywall is usually glued directly onto the affected surface with construction adhesives and then mechanically fastened to the studs or structure behind the plaster. All joints will be taped and sealed with joint compound. In areas where moisture is a problem, moisture-resistant drywall should be installed. Wherever the drywall meets wood framing or any other finish material, the seams should be sealed with caulk or other sealant.

Lead-based painted floors should be enclosed with ½-inch-thick or thicker plywood (or other underlayment). The plywood is then covered with the desired floor covering. Wooden steps with lead-based paint should be completely covered with vinyl or rubber treads and risers. Painted pipes can be enclosed with the same kind of tape that is used to make plaster casts. The wrapped tape should overlap itself so that it is not dependent on adhering to the painted surface. Frame covers may be used to enclose both wood and metal doors.

The following materials can be used to construct exterior surface enclosures:

vinyl or aluminum siding, board products made of synthetic fiberboard or wood composites, natural or synthetic brick and stone veneers and stucco. Vinyl or aluminum siding may be used to enclose exterior painted surfaces. Any defective substrates must be repaired or replaced prior to attaching siding. Siding may not provide an airtight enclosure; to ensure that dust doesn’t “leak” through enclosure systems, a breathable cloth material such as Tyvek (or an equivalent material) can be installed prior to placing siding. Aluminum coil stock can be used to cover soffits, facia, decorative crown molding, door and window frames, parapets and other moldings.

All enclosures should be designed to be dust-tight for at least 20 years. All crevices, holes, seams, edges, joints and cracks shall be caulked. The underside of all enclosures shall be back-caulked to further prevent leaded dust and lead residues from escaping the abated surface.

Friction and Impact Surface Treatment

Friction surfaces are those surfaces usually subjected to abrasion, which creates the potential to generate dust from lead-based painted surfaces. Common friction surfaces include parts of a window that are rubbed when the window is opened and closed, tight-fitting doors, cabinet doors, drawers, stairway treads, and railings. Floors may also be considered friction surfaces, however, the methods described in this section typically apply only to the components listed above.

Impact surfaces are those that protrude outward and tend to be bumped and banged. The most common impact surfaces are doors, doorjambs, door trim, door stops, outside corners of walls, baseboards, shoe moldings, stair risers and chair-rail moldings.

Subject to the preferences of the property owner and an evaluation of cost, the most effective option may be to remove and replace the friction or impact component or to perform a paint removal. If the components or paint are removed, the procedures described below in Section 5.6.3.3 will be followed. However, in some cases, friction or impact surfaces may be covered/enclosed, or otherwise treated, to adequately eliminate or control potential dust generation caused by abrasion. For window systems, it is possible to install replacement window channels or slides made of aluminum, vinyl and polyvinyl chloride (PVC). These components will be back-caulked and nailed into place to provide an adequate seal. For door systems, where the door rubs or sticks, the simplest solution is to remove the door and plane down all friction points using appropriate dust-control methods (e.g., wet methods or HEPA-filter-equipped tools).

Installation of rubber tread guards, carpet or tile is recommended to lessen the friction on stair treads, provided that the lead-based paint is in good condition or is adequately sealed or encapsulated.

5.6.3.3 Paint Removal and Replacement

This section describes the general procedures and references relevant specific regulations and guidelines for removal and replacement actions, including paint removal and painted component removal.

Paint Removal

Paint removal involves separating the lead-based paint from the substrate using heat guns, chemicals or certain contained abrasive measures. Paint removal must be conducted using appropriate methods and control technologies, as described in Section V.B. of Colorado Regulation 19 and Chapter 12, Section IV of the HUD Guidelines, to contain particulate matter and dust which may be generated.

Removing lead-based paint with a heat gun works well on wood surfaces but will usually damage drywall and plaster surfaces. Heat guns should be operated at a maximum heat setting of 1,100 degrees Fahrenheit. For most heat guns, the optimal distance from the end of the heat gun to the working surface is 3 to 6 inches. Heat should be applied to just soften the paint, not allowing the paint film to scorch or smoke. At the very first sign of paint softening, blistering or bubbling, the use of the heat gun will be discontinued and the loose paint will be scraped off the surface. When performing lead-based paint removal with a heat gun, a fully charged, ABC-type, 20-pound fire extinguisher must be available within 100 feet of the work area.

Abatement personnel are required to wear powered air-purifying respirators with HEPA-filtered cartridges and organic-vapor cartridges when performing abatement activities with a heat gun.

Paint may be removed from most surfaces by wet scraping. Wet scraping can be accomplished by using a spray bottle or sponge attached to a paint scraper. The surface may also be misted with water and scraped with a putty knife or similar instrument. Wet scraping is generally used to remove flaking paint prior to paint-film stabilization or encapsulation. Wet scraping will not be performed around live electrical circuits/outlets.

If electrical outlets are present within a building component to be removed, the circuits must be turned off and disconnected prior to wet-misting. Dry scraping of lead-based paint is allowed only when working with heat guns.

HEPA sanding uses traditional electric sanders (disc, orbital or vibrating sanders) equipped with a specially designed containment system that is placed under a partial vacuum. All exhaust air is passed through a HEPA filter to reduce the amount of airborne lead dust and particulates. As discussed previously, chemical stripping methods shall only be used to remove lead-based paint from highly decorative or ornate components or surfaces that are otherwise difficult to abate by any other method. If chemical removal is the desired action, on-site or off-site paint stripping may be performed.

General procedures for using chemical removers are as follows. The paint remover is applied with a spatula, trowel or brush and allowed to sit for the required period of time following all manufacturers’ directions. The remover should not be allowed to dry out during this process. After waiting the required period of time, the softened paint is removed with a scraper or putty knife and deposited into a watertight and corrosion-proof container. The waste will be disposed of in accordance with Section

6.2 of the LCCHP Phase 2 Work Plan. The stripped surface is then thoroughly cleaned to remove lead and paint-remover residues. The treated surfaces must then undergo a neutralization process (this must be accomplished immediately for wood surfaces before they dry out). After the neutralization process, the damp surface is cleaned with a high phosphate detergent or cleaner and followed up with a clean water rinse. If the rinse water exhibits a pH greater than 8, the neutralization process should be repeated.

After neutralization is achieved, the surface may be repainted. Surfaces that have undergone the removal process should be repainted using latex paint only. Cleanup and clearance sampling are performed after removal activities. When using chemical paint removers: (1) products that contain methylene chloride will be avoided and (2) a portable eyewash station capable of providing a 15-minute flow will be available on site.

Personal protective equipment required for this method includes chemically resistant clothing; long neoprene, nitrile, rubber or PVC gloves; and face shields.

Off-site stripping may be performed, provided that the off-site stripper is qualified to handle lead-based paint. For off-site stripping, the component will be removed and tagged to indicate its original location within the house, wrapped in 6-mil plastic and sent to the off-site stripping location. The treated item should be cleaned using a HEPA vacuum, washed with a phosphate-containing detergent, allowed to dry and cleaned again with the HEPA vacuum prior to replacement.

Removal and Replacement of a Building Component

Component replacement may involve the removal of items such as doors, windows, trim, baseboards, chair-rail molding, exterior fascia, soffits, shutters, crown moldings and other components that represent lead-based-paint hazards. All replacement components shall be free of lead-based paint.

The building component to be removed will be misted with water to minimize the amount of lead dust generated during removal activities. Frequent vacuuming with a HEPA-filter equipped vacuum cleaner is recommended during the removal process.

After removal, the component will be wrapped in 6-mil plastic and sealed with tape. Smaller debris generated by replacement activities will be wet-misted and placed into 6-mil plastic bags and sealed with tape. Waste management and disposal will be performed as outlined in Section 6.2, Lead-Based Paint, Dust and Associated Debris of the LCCHP Phase 2 Work Plan.

5.6.4 Interior Paint Clearance Sampling

As discussed previously, all interior paint response actions will be followed by dust abatement as described in Section 5.5.4 to meet the cleaning requirements of Section V.H. of Colorado Regulation 19. Both a visual clearance inspection and clearance sampling will be performed following response actions for interior paint and subsequent dust abatement. The final visual inspection will be performed to confirm the completion of paint abatement and subsequent cleaning activities and to confirm that work was conducted as specified in the Response Action Plan. A certified Lead-Based Paint Inspector or Risk Assessor for lead-based paint activities will perform the inspection. The work area and adjacent areas used for access to the work area will be inspected to identify the remains of any deteriorated paint, visible dust and/or debris. If problems are noted during the visual inspection, clearance sampling will be postponed until additional cleaning has been performed.

Because component and paint removal and replacement and/or encapsulation activities can create dust containing lead-based paint, dust samples will be used for clearance sampling after paint actions. The clearance samples will be collected using the same wipe methods as used for clearance sampling following dust control and abatement actions, as described in Section 5.5.4 and in the SOP for Dust Clearance Sampling (Appendix A of the LCCHP Phase 2 Work Plan). One wipe sample will be collected from the floor and one from a windowsill, if present, in each room of the work area. If any paint sealants were used as part of the response action, then the clearance samples will be collected at least one hour after the sealant has dried. All clearance samples will be submitted to an NLLAP-recognized laboratory for analysis of lead.

Each wipe sample must meet the following clearance levels for lead in order for work to be considered complete: floor samples less than 100 μg/ft2 and window samples less than 500 μg/ft2. If the results of the clearance sampling exceed these levels, dust abatement procedures will be repeated and clearance samples will be collected again.

5.6.5 Exterior Paint Clearance Sampling

Following exterior paint abatement actions, both visual inspection and clearance sampling will be performed. Clearance samples will include dust wipe samples and soil samples which will be collected in accordance with the SOPs for Clearance Dust Sampling and Clearance Soil Sampling (Appendix A of the LCCHP Phase 2 Work Plan), respectively.

The clearance dust samples will be collected using the wipe method. A minimum of two clearance samples will be collected from the work area. One sample will be collected from an exterior windowsill and one from a hard surface such as a patio, walkway, or deck, if present, within the work area. The wipe samples will be submitted to an NLLAP-recognized laboratory for lead analysis.

Each wipe sample must meet the following clearance levels for lead in order for work to be considered complete: exterior window sill samples less than 500 μg/ft2 and exterior surface samples less than 800 μg/ft2. If the result for a clearance sample exceeds these levels, additional cleaning will be performed and clearance samples will be collected again.

Clearance soil samples will also be collected. Whenever an exterior paint response action is taken, soil samples will be collected both prior to and following that action to confirm that the response action does not result in higher lead concentrations in soil around the work area. Both the pre-abatement and post-abatement soil samples will be taken using procedures that are consistent with Colorado’s Regulation 19, as described in Section V.J.1.e.(2) and the SOP for Clearance Soil Sampling (Appendix A of the LCCHP Phase 2 Work Plan).

At least one pre-abatement soil sample will be collected from the planned work area by obtaining a composite sample consisting of at least 5 and no more than 10 subsamples collected along the building perimeter/dripline within the designated work area. The lead concentration in the pre-abatement soil sample will be used as the basis for comparison with the post-abatement samples. The post-abatement samples will be collected following completion of all paint abatement and associated clean-up activities.

At least two post-abatement soil samples will be collected from within the designated work area by obtaining composite samples of at least 5 and no more than 10 subsamples collected along the building perimeter/dripline. Both pre- and post-abatement samples will be analyzed for lead by an NLLAP-recognized laboratory.

The exterior abatement work will be considered complete when the lead concentration of the post-abatement soil is less than or equal to the lead concentration of the pre-abatement soil. If the soil clearance level is not met, then a response action to address the residual lead level in soil may be required.