Ft. Wilkins SP Environmental Report.pdf

LEAD INSPECTION AND RISK ASSESSMENT

FOR THE PROPERTY LOCATED AT:

15223 US-41

Copper Harbor, MI 49918

Prepared For:

Fort Wilkins State Park Michigan Department of Natural Resources

P.O. Box 71 Copper Harbor, MI 49918

(906) 289-4215

Report Prepared and Submitted by:

Andrew Lahti Certified Lead Inspector / Risk Assessor P – 06103

ALL Environmental Solutions LLC

921 Ohio St Hancock MI 49930

906-370-3596 lahticontracting@gmail.com

Date of Inspection:

4-12-2017

TABLE OF CONTENTS

Page #

1. Scope of Work 2

2. Executive Summary 3

a. 2.1 Existing lead based paint hazards and control options 3

b. 2.2 Positive XRF readings 4

c. 2.3 Table of Paint Chip hazards and control options 5

d. 2.4 Laboratory Information 6

e. 2.5 Project limitations, difficulties and excluded components 7

3. Site information and field testing

a. 3.1 General property description 7

b. 3.2 Building Condition Survey 8

c. 3.3 Paint Condition form 9

d. 3.4 Photographs of Property 10

4. Ongoing monitoring and re-evaluation schedule

a. 4.1 Maintenance and monitoring schedule for encapsulants and enclosures 11

b. 4.2 Recommendations for Building Operations and Maintenance 11

5. Background information and educational information

a. 5.1 Health effects of lead exposure 12

b. 5.2 Sources of lead poisoning 13

c. 5.3 Methods to reduce exposure to lead hazards 13

6. Additional resources

a. 6.1 Phone contacts 14

b. 6.2 Publications 14

c. 6.3 Web sites 14

7. Certification

a. 7.1 Training certificates and copies of State of Michigan certifications 15

8. Appendix

a. Appendix A – “Lead Speak” a brief EPA glossary 18

b. Appendix B - XRF analysis and Performance Characteristics Sheet 20

c. Appendix C - Paint chip sample Lab Report 30

d. Appendix E – Key units of measurement 44

e. Appendix F – Site and floor plans 42

921 Ohio St Hancock MI 49930 906-370-3596 andrewlahti@hotmail.com

SCOPE OF WORK:

The Scope of Work for this project was to perform a XRF testing and Lead-Based Paint Sampling Report. ALL Environmental Solutions was on-site at 15223 US-41 Copper Harbor, MI 49918 on April 12, 2017 to conduct sampling of suspected Lead-Based paint. The intent of these inspections is to assist Fort Wilkins State Park to determine where lead-based paint hazards exist and to provide options for removing or controlling the hazards.

LEAD INSPECTION AND RISK ASSESSMENT:

A lead inspection and risk assessment was conducting for the buildings located at 15223 US-41 in Copper Harbor, MI 49918. The sampling was performed by Andrew Lahti, a State of Michigan Licensed Lead Inspector/Risk Assessor on April 12, 2017. Wayne Burnett and Paul Ketola were present and gave us access to the property.

The structure that was inspected is an Historical State Park, approximate building date is 1844 and has had updates during different times over the last 170 years. During the walkthrough, buildings were numbered and samples were then taken from separate homogenous areas. A homogenous area is defined as an area of Lead-Based Paint, or suspected Lead-Based Paint which appears similar throughout in terms of color, texture, and date of material application.

ALL Environmental Solutions properly containerized each sample and shipped them to GPI Laboratories, Inc. in Grand Rapids, Michigan for analysis using inductively coupled plasma-atomic emission spectrometry (ICP-AES). Analytical results are attached in Appendix C.

Thirty-Seven (37) samples of suspected Lead-Based Paint were taken and analyzed. The Paint Chip Sample Report lists the areas where the samples were taken. Of the tested materials, Lead was found in 35 of the 37 samples. The separate components of the fort appear to be around the same age and composition, with a few variances. Areas of paint not tested or not accessible should be considered Lead paint. The paint on the chimneys tested positive for lead-based paint, as well as the paint on the windows, window casings, doors, walls/siding and foundation.

We made every reasonable attempt to access all exterior areas of the buildings, however, with all lead inspections there is a potential for the discovery of additional Lead-Based Paint not addressed by this report during renovation or demolition activities. In the event that additional materials are identified during on-site activities, all work should stop and the materials sampled. ALL Environmental Solutions will return and sample any additional materials found during renovation or demolition at the building owners’ request.

mailto:andrewlahti@hotmail.com

EXECUTIVE SUMMARY

(2.0) Executive Summary – The purpose of the Executive Summary is to summarize where the lead hazards were found at this property. For each identified paint, soil or dust hazard a recommended corrective action is also provided. The two types of corrective actions are 1 – abatement which is a permanent long term solution or 2 – interim control which is a shorter term solution. For example, painting the exterior of the house is an interim control as paint will need to be re-applied after a few years, however, applying vinyl siding is an abatement measure as it is considered permanent. All identified lead based paint and lead based paint hazards should always be properly addressed by professionally certified lead workers and firms.

(2.1) Existing Lead-based paint hazards and Available Control Options There were multiple components tested for lead-based paint hazards at the property located at 15223 US-41 Copper Harbor, MI 49918. They are listed in priority order i.e. what hazards should be addressed first. Each hazard also has corresponding options for corrective actions known as abatement (long term) and interim control (shorter term) solutions. The owner or owner’s representative must select the most appropriate and affordable solution to address each of the identified hazards. Please note that these hazards may become more severe over time and additional hazards may be created with changing conditions at this property.

COMPONENT SEVERITY

ABATEMENT OPTIONS INTERIM CONTROL OPTIONS

Chimney 4

1. Remove chimney and replace.

2. Needle scale or grind with local exhaust connected to a HEPA vacuum

3. Remove paint using an approved solvent.

Wet scrape and properly prepare surfaces then repaint

Wall/Siding 4

1. Remove siding and replace with new siding.

2. Remove paint with a grinder or power sander connected to a local exhaust with HEPA vacuum.

Foundation 4 1. Needle scale or grind with local exhaust connected to a HEPA vacuum.

2. Remove paint using an approved solvent.

Window 4 1 Remove windows and replace with new windows.

2. Remove paint from window by power sanding or grinding with local exhaust connected to a HEPA vacuum.

3. Remove paint using an approved solvent.

Wet scrape and properly prepare and repaint all non-opening windows. For any functional windows, there are no interim control options. All impact or friction surfaces must have lead-based paint abated.

Window Casing 4 1. Remove and replace casing.

2. Remove paint from window casing by power sanding or grinding with local exhaust connected to a HEPA vacuum.

3. Remove paint using an approved solvent.

Wet scrape and properly prepare and repaint all non-opening windows. Any windows that are functional, there are no interim control options. All impact or friction surfaces must have lead-based paint abated.

Door 4 1. Remove and replace door.

2. Remove paint from door by sanding or grinding with local exhaust connected to a HEPA vacuum.

3. Remove paint using an approved solvent.

Interim control options do not exist. All impact or friction surfaces must have lead-based paint abated.

Facia 4 1. Remove and replace facia.

2. Grind or sand paint off with local exhaust connected to a HEPA vacuum.

3. Remove paint using an approved solvent.

Wet scrape and properly prepare surfaces and repaint.

4 is most severe and 1 is less severe. Any questions about Abatement or Interim Control options should be directed to the inspector before work begins.

(2.2) Positive XRF Readings - This table identifies all of the painted surfaces that tested positive for lead-based paint. The paint condition at the time of testing was determined to be either “intact” or “deteriorated”. All deteriorated paint conditions represent a lead-based paint exposure hazard and are listed in Table 2.1. All deteriorated lead-based paint conditions should be corrected immediately. Lead-based paint determined to be intact at the time of testing may become lead-based paint exposure hazardous in the future and therefore require routine monitoring as recommended in Section 5. Use lead safe work practices every time a lead-based paint surface is disturbed.

POSITIVE

XRF Readings

Fort Wilkins State Park

15223 US-41

Copper Harbor MI 49918

Date of testing – 4-12-2017

A total of 116 Positive XRF Readings were taken at the site. The results are located in the Appendix and are highlighted to provide easy identification.

(2.3) Table of Paint Chip Sample Hazards and control options.

ALL Environmental Solutions took at total of 37 paint chip samples at the property. Each sample was then sent to an NLLAP certified lab for analysis. The following table identifies all paint chip samples taken and identifies those samples that represent lead hazards. Control options are provided in chart (2.1).

Lead-Based Paint containing materials are generally managed in place until renovation or demolition. Employers doing any renovation work should develop an Initial Exposure Assessment when working with Lead-Based paint. Contractors are required to ensure that all employees who may be exposed to lead are provided with the appropriate training in accordance with Part 603, Lead exposure in Construction.

Date Sampled: April 12, 2017

Sample # Sample Location Lead Concentration in percent by weight

Hazard Control Option

4001 BUILDING # 1 CHIMNEY 0.053 % See chart (2.1).

4002 BUILDING #2 CHIMNEY 0.0034 % See chart (2.1).

4003 BUILDING #3 CHIMNEY < RL See chart (2.1).

4004 BUILDING #4 CHIMNEY 6.4 % See chart (2.1).

4005 BUILDING #5 CHIMNEY 0.70 % See chart (2.1).

4006 BUILDING #5 SIDE A WALL 0.0027 % See chart (2.1).

4007 BUILDING #5 FOUNDATION 9.3 % See chart (2.1).

4008 BUILDING #6 SIDE B WALL 0.0044 % See chart (2.1).

4009 BUILDING #7 CHIMNEY < RL See chart (2.1).

4010 BUILDING #7 FOUNDATION 0.21 % See chart (2.1).

4011 BUILDING #7 SIDE B WALL 0.16 % See chart (2.1).

4012 BUILDING #8 SIDING 5.2 % See chart (2.1).

4013 BUILDING #9 FOUNDATION 0.023 % See chart (2.1).

4014 BUILDING #10 SIDE A WALL 8.0 % See chart (2.1).

4015 BUILDING #10 FOUNDATION 0.15 % See chart (2.1).

4016 BUILDING #11 SIDE B WALL 6.5 % See chart (2.1).

4017 BUILDING #11 CHIMNEY 3.2 % See chart (2.1).

4018 BUILDING #12 SIDE B WALL 8.2 % See chart (2.1).

4019 BUILDING #13 CHIMNEY 0.0061 % See chart (2.1).

4020 BUILDING #15 CHIMNEY 0.51 % See chart (2.1).

4021 BUILDING #15 SIDE C WALL 0.053 % See chart (2.1).

4022 BUILDING #13 FOUNDATION 0.056% See chart (2.1).

4023 BUILDING #16 SIDE C WALL 0.099 % See chart (2.1).

4024 BUILDING #16 FOUNDATION 0.028 % See chart (2.1).

Sample # Sample Location Lead Concentration in

Abatement Control Option

4025 BUILDING #16 CHIMNEY 0.73 % See chart (2.1).

4026 BUILDING #17 FOUNDATION 0.047 % See chart (2.1).

4027 BUILDING #17 CHIMNEY #4 1.2 % See chart (2.1).

4028 BUILDING #17 SIDE D WALL 0.16 % See chart (2.1).

4029 BUILDING #18 SIDE D WALL 0.030 % See chart (2.1).

4030 BUILDING #18 SIDE A WALL 6.4 % See chart (2.1).

4031 BUILDING #18 CHIMNEY #4 9.7 % See chart (2.1).

4032 BUILDING #19 SIDE A WALL 3.9 % See chart (2.1).

4033 BUILDING #19 FOUNDATION 12 % See chart (2.1).

4034 BUILDING #19 CHIMNEY #1 0.68 % See chart (2.1).

4035 BUILDING #20 SIDE D WALL 5.6 % See chart (2.1).

4036 BUILDING #21 SIDE D WALL 0.056 % See chart (2.1).

4037 BUILDING #22 SIDE D WALL 0.050 % See chart (2.1).

Reporting Limit (RL): 0.0025 %

(2.4) Laboratory Information

Laboratory Name: GPI Laboratories, Inc.

Street Address 4403 Donker CT SE City, State Zip

Grand Rapids, MI 49512

Phone number: 616-940-3112

(2.5) Project limitations, difficulties and excluded components A lead inspection requires testing of every unique painted surface. However, some surfaces could not be tested because of limitations such as inaccessible areas, windows not operable, clutter, unsafe building conditions, etc. All untested components should be assumed to contain lead-based paint. Lead safe work practices should always be used if those surfaces are disturbed.

The following table lists those components and areas which the inspector was not able to test and the reason for which it was not tested.

AREA / LOCATION COMPONENT REASON NOT TESTED

Inside of all buildings All components Not in scope of work

(3.1) General Property Description

The property is an Historical State Park. Approximate building date is 1844. There are 24 structures on the property, which have been historically preserved. The property is 1.09 mi2.

Date of construction: 1844 Apparent building use: SF residential rental other Historic State Park Setting: residential neighborhood mixed use other ________ Front Entry Faces: S W N E Design: 1 story 2 story duplex multi-family other Construction type: brick wood stucco other ___________________ Lot Type: small narrow large other ___________________ Roof: flat asphalt tile/slate other: wood Foundation: crawl space stone cement slab Front lawn condition: good poor some bare areas other ____________ Back lawn condition: good poor some bare areas other ____________ Drip line condition: no bare soil some bare soil paint chips other ___ Exterior structural condition: OK house unsound other _____________________ Porch(s) front porch rear porch side porch(es)

Overall building/site condition: poor marginal OK, well maintained Garage none detached attached poor condition good condition other ________________________________

(3.2) Building Condition Survey The purpose of the building condition survey is to document and evaluate whether or not the building is in good enough condition to justify the lead hazard control recommendations. Any column marked “yes” represents a major condition that needs to be corrected before lead hazard control recommendations can be followed. This information provides the Risk Assessor with insight into possible causes of existing or future paint or substrate deterioration. For example, a roof in disrepair should be noted since moisture could cause paint deterioration.

Condition Yes No Comments Roof missing parts of surface covering? X Small shingles missing on various roofs.

Roof has holes or large cracks? X

Gutters or downspouts broken? X

Chimney or masonry cracked, with loose or missing components, out of plumb or otherwise deteriorated?

X Various chimneys deteriorated and cracked.

Exterior walls have large cracks, or damage requiring more than routine painting or pointing if masonry?

X Lead-based paint is chipping, peeling, flaking, and cracking on multiple walls throughout the Fort.

Exterior siding missing boards, shingles, components? X

Walls or ceilings deteriorated? X

More than “very small” amount paint on siding deteriorated?

X Lead-based paint is chipping, peeling, flaking, and cracking on multiple walls throughout the Fort.

Two or more windows or doors missing, broken or boarded up?

X

Porch or steps have major elements missing, broken, or boarded up?

X

Foundation has major cracks, missing material, structural leans, or visibly unsound.

X Some buildings have signs of deterioration.

Other conditions not listed:

Total number: 6 6

(3.3) Paint Condition form (visual inspection of selected surfaces)

The purpose of the visual assessment is to locate potential exterior and interior lead-based paint hazards. A visual assessment is conducted in all rooms. The risk assessor also examines other exterior painted surfaces such as fences, garages, storage sheds and outbuildings that are part of the residential property and built before 1978. The risk assessor also examines the grounds to identify areas of bare soil. The result is a complete inventory of the location and approximate size of each potential lead-based paint hazard.

Building Component

Paint Condition (intact or deteriorated)

Probable cause of deterioration

Condition is common to all/most similar components

Friction or impact surface

Siding D Age/Water Y N Soffits D Age/Water Y N Exterior siding D Age/Water Y N Exterior windows

I Y Y

Window casing I Y Y Exterior doors I Y Y Foundation D Age/Water Y N Walls D Age/Water Y N Facia D Age/Water Y N Bare soil areas D Age/Water Y N

(3.4) Photographs of Property

(4.0) Ongoing monitoring and Re-evaluation schedule

All painted components containing or assumed to contain lead-based paint require periodic re-evaluation and monitoring. A visual re-evaluation is typically performed annually by the owner.

More frequent re-evaluations may be required depending on site conditions. If the property was HUD assisted then the re-evaluation schedule should comply with the Lead Safe Housing Rule (24CFR35.1355(b)(4). All painted surfaces must remain in intact condition. Painted surfaces that are peeling, cracking, blistering or causing dust from friction or impact must be corrected immediately to prevent hazardous exposure from possible lead based paint sources. All repairs must follow the lead safe work practices of the HUD Guidelines, EPA Renovation, Repair and Painting rule and State of Michigan regulations for abatement of lead based paint hazards.

(4.1) Maintenance and monitoring schedule for encapsulants and enclosures.

All surfaces encapsulated or enclosed should be re-evaluated no later than two years after completion of encapsulation or enclosure.

(4.2) Recommendations for Building Operations and Maintenance

Disturbing lead-based paint surfaces may cause new and additional lead hazards. Therefore, building operations and maintenance personnel should always follow the lead safe work practices of the HUD Guidelines, EPA Renovation, Repair and Painting rule and State of Michigan regulations for abatement of lead based paint hazards every time a lead-based paint surface is disturbed. All employers should develop an Initial Exposure Assessment when working with Lead-Based paint. Contractors are required to ensure that all employees who may be exposed to lead are provided with the appropriate training in accordance with Part 603, Lead exposure in Construction. Materials containing Lead-Based Paint should be handled in accordance with the State of Michigan and EPA regulations. Any building built before 1978, the contractor must be EPA Renovation Repair and Paint (RRP) trained.

In discussions with Wayne Burnett, there is going to be a masonry repointing of the painted brick chimneys. There are two recommended construction practices for this type of work:

1.) Use shrouded grinding tools, with a high-efficiency particulate air (HEPA) equipped vacuum attachment.

All workers should be outfitted in the proper PPE, including but not limited to: disposable coveralls, gloves, goggles, and any air-purifying respirator with an N100, R100, or P100 filter. Work wet to avoid generating lead dust.

2.) Full containment of work area, meaning the work area be protected by plastic sheeting in a total enclosure where lead-based paint will be disturbed that extends a minimum 10 feet in all directions from the location where paint will be disturbed. Negative air machines must be attached to the enclosure area and the workers outfitted in PPE including coveralls, gloves, goggles, and a PAPR full face respirator or a half-faced respirator with a P100 filter based on initial on site air monitoring.

(5.0) Background information and Educational Information

All Environmental Solutions is a technical service company covering areas in the Midwest including the U.P of Michigan and Northern Wisconsin. We employ fully trained and educated professionals in the areas of Lead Risk Assessing and Inspections. Andrew Lahti is a state certified Lead Inspector/Risk Assessor and conducted this risk assessment personally, paying close attention to detail.

(5.1) Health Effects of Lead Exposure

Lead is a soft metal, naturally occurring in the Earth’s crust. It has been determined, however, that lead has no useful purpose in the human body, and acts as a toxin. It takes the place of essential minerals such as calcium, potassium, and iron, which are vital to the construction and repair of bones, organs and blood. Lead exposures are a major health concern, especially in young children under the age of six.

Children, due to their smaller body mass and higher metabolism, are affected by lead exposures much more severely than adults. They ingest lead through daily hand-to-mouth activities and may develop severe attention deficit disorders, irreversible brain injury, learning disabilities and aggressive behaviors. The symptoms of lead poisoning often mimic other afflictions such as flu, colic or general malaise. It is important to have young children’s blood tested for lead burden.

(5.2) Sources of Lead Poisoning

Since lead is ingested by routine daily activities such as eating, playing and working, it is important to understand the sources of lead exposures. The most common places to find lead in household settings are interior and exterior paint, and contaminated dust or soil. Lead-based paint is most hazardous when it is chipping, peeling, cracking, or chalking; or applied to friction surfaces of components such as doors, windows, and floors. The abrasive action of painted surfaces rubbing together causes lead-containing paints to be ground into a fine dust. Lead dust can also be created from decaying vinyl mini blinds. Lead dust then settles on furniture, play area floors, and children’s toys, where children are exposed during regular activities.

Several other sources of lead in the home include lead dust brought into the home from occupational exposures, water pipes, fixtures and soldered joints; decorative china, “leaded” crystal, fishing lures and sinkers, firearms ammunition, wine bottles and cosmetics. Some hobbies may also contribute to lead contamination within the home. Exposures to all sources of lead should be minimized or eliminated.

(5.3) Methods to Reduce Exposure the Lead Hazards

The simplest and often most effective way to reduce lead exposures is through regular washing of hands, toys, and horizontal surfaces in the home with a liquid hand soap or dish soap and water. It is highly recommended that disposable cleaning materials be used to wash surfaces, so as not to re-contaminate them with a used mop or cloth.

Other ways of reducing lead hazards within the home include taking shoes off before entering living areas, letting water run prior to drinking or cooking, covering exposed soil with plant materials, and vacuuming with a High Efficiency Particulate Air (HEPA) filtered vacuum.

For more information regarding lead poisoning and prevention, contact your local health department or the National Lead Information Center (800-424-LEAD (5323)). Contact the Michigan Department of Community Health, Lead Hazard Remediation Program at (866) 691- 5323 for information regarding lead hazard remediation or selection of qualified lead professionals

ALL Environmental Solutions 921 Ohio St.

Hancock MI 49930 906-370-3596 andrewlahti@hotmail.com

(6.0) ADDITIONAL RESOURCES

For further information regarding lead-based paint hazards and poisoning prevention, consult the following resources:

(6.1) PHONE CONTACTS

Hearing- or speech-challenged individuals may access the federal agency numbers through TTY by calling the toll-free Federal Relay Service at 800-877-8339; see also http://www.federalrelay.us/tty

National Lead Information Center: ...............................................800-424-LEAD (5323) U.S. Department of Housing and Urban Development: ...............888-532-3547 (LEADLIST) State of Michigan – Healthy Homes Section...: ............................866-691-LEAD (5323) National Lead Information Center & Clearinghouse: 1-800-424 LEAD HUD Office of Healthy Homes and Lead Hazard Control: 202-402-7698 Centers for Disease Control and Prevention Lead Program: 800-232-4636 Consumer Product Safety Commission: 800-638-2772;

TTY 301-595-7054

Environmental Protection Agency Lead Program: 202-566-0500

(6.2) PUBLICATIONS

(available online)

“Lead in Your Home: A Parent’s Reference Guide” U.S. Environmental Protection Agency “Protect Your Family From Lead in Your Home” U.S. Environmental Protection Agency “Lead Paint Safety: A Field Guide for Painting, Home Maintenance, and Renovation Work” U.S. Department of Housing and Urban Development

(6.3) WEB SITES:

• Michigan Dept of Community Health – Healthy Homes Section www.michigan.gov/leadsafe

• HUD – Office of Healthy Homes and Lead Hazard Control www.hud.gov/offices/lead

• EPA - www.epa.gov/lead

• National Safety Council - www.nsc.org/issues/lead

7.0) CERTIFICATION

The information contained in this report is a true and accurate representation of the lead-based paint conditions at the subject property at the time of the investigation, based on the professional judgment of the person(s) who conducted and reported this lead-based paint inspection and risk assessment:

Name Andrew Lahti Date 4/24/2017

State of Michigan Certified Lead Inspector and Risk Assessor, Andrew Lahti P-06103

(7.1) Training Certificates and copies of State Of Michigan certifications attached.

(8.0)

APPENDIX

Appendix A “LEAD SPEAK:” a brief EPA glossary

Abatement: A measure or set of measures designed to permanently eliminate lead-based paint hazards or lead-based paint. Abatement strategies include the removal of lead-based paint, enclosure, encapsulation, replacement of building components coated with lead-based paint, removal of lead contaminated dust, and removal of lead contaminated soil or overlaying of soil with a durable covering such as asphalt (grass and sod are considered interim control measures).

All of these strategies require preparation; cleanup; waste disposal; post-abatement clearance testing; recordkeeping; and, if applicable, monitoring. (For full EPA definition, see 40 CFR 745.223).

Bare soil: Soil not covered with grass, sod, some other similar vegetation, or paving, including the sand in sandboxes.

Chewable surface: An interior or exterior surface painted with lead-based paint that a young child can mouth or chew. A chewable surface is the same as an “accessible surface” as defined in 42 U.S.C. 4851b(2). Hard metal substrates and other materials that cannot be dented by the bite of a young child are not considered chewable.

Deteriorated paint: Any paint coating on a damaged or deteriorated surface or fixture, or any interior or exterior lead-based paint that is peeling, chipping, blistering, flaking, worn, chalking, alligatoring, cracking, or otherwise becoming separated from the substrate.

Drip line/foundation area: The area within 3 feet out from the building wall and surrounding the perimeter of a building.

Dust-lead hazard: Surface dust in residences that contains an area or mass concentration of lead equal to or in excess of the standard established by the EPA under Title IV of the Toxic Substances Control Act. EPA standards for dust-lead hazards, which are based on wipe samples, are published at 40 CFR 745.65(b); as of the publication of this edition of these Guidelines, these are 40 μg/ft2 on floors and 250 μg/ft2 on interior windowsills. Also called lead-contaminated dust.

Friction surface: Any interior or exterior surface, such as a window or stair tread, subject to abrasion or friction.

Garden area: An area where plants are cultivated for human consumption or for decorative purposes.

Impact surface: An interior or exterior surface (such as surfaces on doors) subject to damage by repeated impact or contact.

Interim controls: A set of measures designed to temporarily reduce human exposure or possible exposure to lead-based paint hazards. Such measures include, but are not limited to, specialized cleaning, repairs, maintenance, painting, temporary containment, and the establishment and operation of management and resident education programs. Monitoring, conducted by owners, and reevaluations, conducted by professionals, are integral elements of interim control. Interim controls include dust removal; paint film stabilization; treatment of friction and impact surfaces;

installation of soil coverings, such as grass or sod; and land use controls. Interim controls that disturb painted surfaces are renovation activities under EPA’s Renovation, Repair and Painting Rule.

Lead-based paint: Any paint, varnish, shellac, or other coating that contains lead equal to or greater than 1.0 mg/cm2 as measured by XRF or laboratory analysis, or 0.5 percent by weight (5000 mg/g, 5000 ppm, or 5000 mg/kg) as measured by laboratory analysis. (Local definitions may vary.)

Lead-based paint hazard: A condition in which exposure to lead from lead contaminated dust, lead contaminated soil, or deteriorated lead-based paint would have an adverse effect on human health (as established by the EPA at 40 CFR 745.65, under Title IV of the Toxic Substances Control Act). Lead-based paint hazards include, for example, paint-lead hazards, dust-lead hazards, and soil-lead hazards.

Paint-lead hazard: Lead-based paint on a friction surface that is subject to abrasion and where a dust-lead hazard is present on the nearest horizontal surface underneath the friction surface (e.g., the window sill, or floor); damaged or otherwise deteriorated lead-based paint on an impact surface that is caused by impact from a related building component; a chewable lead-based painted surface on which there is evidence of teeth marks; or any other deteriorated lead-based paint in any residential building or child-occupied facility or on the exterior of any residential building or child-occupied facility.

Play area: An area of frequent soil contact by children of under age 6 as indicated by, but not limited to, such factors including the following: the presence of outdoor play equipment (e.g., sandboxes, swing sets, and sliding boards), toys, or other children’s possessions, observations of play patterns, or information provided by parents, residents, care givers, or property owners.

Soil-lead hazard: Bare soil on residential property that contains lead in excess of the standard established by the EPA under Title IV of the Toxic Substances Control Act. EPA standards for soil-lead hazards, published at 40 CFR 745.65(c), as of the publication of this edition of these Guidelines, is 400 μg/g in play areas and 1,200 μg/g in the rest of the yard. Also called lead-contaminated soil.

Appendix B XRF Analysis

HOW TO INTERPRET XRF READINGS:

There are 11 columns in the XRF table. The interpretation of each column is as follows:

Column 1 – Number (#): This is simply the shot number that was taken during the inspection.

On occasion, the number may not start at “1” if XRF shots from previous inspections are still in the XRF device.

Column 2 – Time: This is the time and date the readings were taken

Column 3 – Building: This is the building number assigned to each building. Buildings are always identified by a number. Numbers are used because building usage may change.

Column 4 – Component: This is the item that was tested (e.g. wall, window, ceiling)

Column 5 – Substrate: This column defines what material the paint was applied to. Substrates are most commonly plaster or wood but could be other material such as metal or drywall.

Column 6 – Side: This column determines where the item being tested is located in the room.

Side A is always the address side of the building. Then, proceeding in a clockwise direction the adjacent sides are labeled B, C and D. Sides A,B,C and D are identified on the Floor Plan in Section 9.2. For example, if you were standing in a bedroom that had two windows on different walls these windows would be identified by the side location such as Window Side A and Window Side B.

Column 7 – Condition: This column identifies the condition of the paint on the surface being tested. The terms “intact” or “deteriorated” are used to describe the paint condition for HUD funded projects.

Column 8 – Color: This is the color of the surface of the component being tested with the XRF.

Column 9 – Depth Index: The XRF has the capability to detect lead in many layers of paint, not just surface layers. A depth index reading of less than 1.5 indicates that lead is near the surface of the material tested. A depth index reading between 1.6 and 4 indicates that lead was found at a moderate depth. A depth index reading of 4 or higher indicates that lead was found deeply buried in the material tested.

Column 10 – Reading: This column identifies the resulting reading. Anything over 1.0 mg/cm2 is considered positive.

Column 11 – Result: This column indicates whether or not the paint tested Positive or Negative for the presence of lead.

XRF Readings

The instrument used for this Risk Assessment was an X-ray fluorescence unit (XRF) manufactured by NITON serial number 4534_.

(Model _XRF 300____ Serial #_4545____

ALL Environmental Solutions LLC

921 Ohio St Hancock MI 49930

Date of testing 4-12-2017

Appendix E Key Units of Measurement

Gram (g or gm): A unit of mass in the metric system. A nickel weighs about 1 gram, as does a 1 cube of water 1 centimeter on each side. A gram is equal to about 35/1000 (thirty-five thousandths of an ounce). Another way to think of this is that about 28.4 grams equal 1 ounce.

ug (microgram): A microgram is 1/1000th of a milligram. To put this into perspective, a penny weighs 2 grams. To get a microgram, you would need to divide the penny into 2 million pieces. A microgram is one of those two million pieces.

ug/dL (microgram per deciliter): used to measure the level of lead in children’s and worker’s blood to establish whether intervention is needed. A deciliter is a little less than a half a cup.

ug/ft2 (micrograms per square feet): the unit used to express levels of lead in dust samples. All reports should report levels of lead in dust in ug/ft2.

mg/cm2 (milligrams per square centimeter): used to report levels of lead in paint thru XRF testing.

ppm (parts per million): Typically used to express the concentrations of lead in soil. Can also be used to express the amount of lead in a surface coating on a mass concentration basis. This measurement can also be shown as: ug/g, mg/kg or mg/l.

ppb (parts per billion): Typically used to express the amount of lead found in drinking water. This measurement is also sometimes expressed as: ug/L (micrograms per liter).

EPA/HUD Lead-Based Paint and Lead-Based Paint Hazard Standards

Lead-Based Paint (may be determined in either of two ways) Surface concentration (mass of lead per area) 1.0 μg/cm2 Bulk concentration (mass of lead per volume) 0.5%, 5000 g/g, or 5000 ppm

Dust-thresholds for Lead-Contamination

Floors 40 ug/ft2 Interior Window Sills 250 ug/ft2 Window Troughs (clearance examination only) 400 ug/ft2

Soil-thresholds for Lead Contamination

Play areas used by children under age 6 400 ug/g, or 400 ppm Other areas 1200 ug/g, or 1200 ppm

Vegetable gardens no permissible limit

Overhead Map:

Individual building maps from which paint chip samples were taken:

Maps are not drawn to scale. Location of paint chip samples indicated with a triangle and sample number