I.B.08.2_21R0034 USDA-ARS Kerrville 4D3 - Lead Based Paint Inspections.pdf

ENVIRONMENTAL SCIENCE, ENGINEERING & INDUSTRIAL HYGIENE SERVICES

LEAD-BASED PAINT SCREEN

Conducted at:

UNITED STATES DEPARTMENT of AGRICULTURE

AGRICULTURAL RESEARCH SERVICE

KNIPLING-BUSHLAND

U.S. LIVESTOCK INSECTS RESEARCH LABORATORY

2700 FREDERICKSBURG ROAD

KERRVILLE, TEXAS 7808-9184

Prepared for:

BEC Project #TX18002

Fieldwork Conducted:

March 24, 2019 – April 3, 2019

Report Date: May 20, 2019

Prepared by:

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

USDA ARS KBUSLIRL LEAD-BASED PAINT SCREEN

KERRVILLE, TEXAS FINAL TECHNICAL REPORT

LEAD-BASED PAINT SCREEN

FINAL TECHNICAL REPORT

Knipling-Bushland U.S. Livestock Insects Research Laboratory

Kerrville, Texas 7808-9184

TABLE OF CONTENTS

SECTION 1.0 SITE DESCRIPTION 1

SECTION 2.0 LEAD-BASED PAINT SCREEN 1

Section 2.1 Background 1

Section 2.2 LPB Inspection Procedures 1

Section 2.3 LBP Testing Combinations 3

Section 2.4 LBP Inspection Limitations 4

SECTION 3.0 CONCLUSIONS & RECOMMENDATIONS 4

Section 3.1 Conclusions 4

Section 3.2 Recommendations 4

APPENDICES

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

APPENDIX B: XRF PERFORMANCE CHARACTERSTIC SHEET

APPENDIX C: XRF TESTING DATA

APPENDIX D: LBP FILMS & PCL FILMS

APPENDIX E BEC STAFF QUALIFICATIONS

BOGGS ENVIRONMENTAL CONSULTANTS, INC.

Onsite Fieldwork Conducted & Final Report Prepared By: Technical Report Reviewed By:

Andrew L. Hanson, Environmental Specialist Mark A. Boggs

US EPA Lead Risk Assessor President/CEO

SECTION 1.0 SUBJECT SITE DESCRIPTION & SCOPE OF WORK

Project Site: United States Department of Agriculture (USDA)

Agriculture Research Service (ARS), Plains Area (PA)

Knipling-Bushland U.S. Livestock Insects Research Laboratory (KBUSLIRL)

2700 Fredericksburg Road

Kerrville, Texas 7808-9184

Requester Name:

Requestor Address: Jon C. DeLay, P.E.

Sr. Project Manager

Subject Site Description & Scope of Work:

The subject site, Knipling-Bushland U.S. Livestock Insects Research Laboratory (KBUSLIRL), provides important tick and blood-feeding fly research capabilities supporting long-standing cooperative efforts among the

USDA ARS Animal Plant Health Inspection Service (APHIS), USDA ARS Veterinary Service (VS), and the U.S.

cattle industry.

The scope of work was to survey all improvements present at the KBUSLIRL grounds for lead-based paint finished building construction materials, in support of a major modernization project scheduled to commence at

KBUSLIRL in the near future. It is our understanding; nearly all existing structures are slated for demolition to accommodate the modernization project. The structures to undergo demolition include, but may not necessarily be limited to, the following: two barns; three research labs; two insect rearing facilities; three insect research labs;

storage garage; ten isolation pens; feed shed and related pens; and two animal shelters

BEC conducted the LBP screen of the buildings under contract to Merrick & Company (Merrick) of Denver, Colorado. Merrick is a prime contractor to the USDA ARS providing architectural/engineering (A/E) building design and construction period services. BEC understands USDA ARS requested the LBP screen to determine applicability (and impact) of (i) United States (US) Environmental Protection Agency (EPA) / (ii) Texas

Commission on Environmental Quality (TCEQ)/ (iii) Texas Department of State Health Services (TDSHS) environmental pollution/public health protective regulations, and (iv) US Occupational Safety and Health

Administration (US OSHA) worker protection regulations to the planned laboratory modernization project.

SECTION 2.0 LEAD-BASED PAINT SCREEN

2.1 Background

BOGGS ENVIRONMENTAL CONSULTANTS, INC. (BEC) conducted a screen for lead-based paint finished building construction materials present at KBUSLIRL structures located at 2700 Fredericksburg road, Kerrville, Texas between March 24, 2019 and April 3, 2019.

Initially, BEC staff field walked the campus, making observations for typical painting schemes employed at the subject site. The paint film testing was conducted, in strict accordance with the US Department of Housing and

Urban Development (US HUD) guidance document entitled “Guidelines for the Evaluation and Control of Lead-

Based Paint Hazards in Housing”, June 1995 (including the 1997 and 2012 revisions).

http://www.boggsenvironmental.com/

2.1 Background

BEC staff member, Andrew L. Hanson, whom possesses a valid US EPA/US HUD approved “Lead Risk Assessor” instructional training course certification conducted the inspection for lead-based paint (LBP) and paint-containing lead (PCL) applied to building construction materials.

2.2 LBP Inspection Procedures

The LBP inspection consisted of critical visual inspection and surface-by-surface testing of observed paint films applied to building components utilizing an x-ray fluorescence (XRF) analyzer for in situ testing of paint films present at the structures. The XRF employed for the LBP screen was the "LPA-1", as manufactured by PROTEC

Instrument Corporation, 38 Edge Hill Road, Waltham, Massachusetts. The LPA-1 is a hand-held portable direct-read instrument (DRI), designed to make accurate, non-destructive measurements of lead concentrations in paint.

The LPA-1 (SN #1701) underwent resourcing of the Cobalt-57 radioactive isotope-based energy source on May 16, 2018. (See Appendix A - PROTEC “LPA-1” Radioactive Energy Resourcing Data).

BEC adhered to the XRF manufacturer’s specifications and directives contained in the “XRF Performance

Characteristic Sheet” (PCS) in the conduct of the lead-based paint screen. (See Appendix B – XRF Performance

Characteristic Sheet)

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

BEC advises, based upon visual inspection and XRF testing activities, a total of one thousand three hundred ninety-four (1,394) readings were collected from paint-finished surfaces including: walls, ceilings, window components, door components, millwork, baseboards, closet components, and exterior building components. A complete listing of all XRF results is included in Appendix C – XRF Testing Data.

Federal & State Regulatory Applicability

Lead-Based Paint:

According to the US EPA and US HUD environmental pollution/hazard control regulations, an XRF reading of greater than or equal to 1.0 milligram per square centimeter ( > 1.0 mg/cm2) and/or 0.5% Pb+2 dry weight of paint film is considered positive for the presence of lead-based paint. These thresholds trigger compliance with legally-enforceable regulations intended to safeguard against unprotected exposure of humans to LBP hazards whom occupy/reside within single-family and multiple-family residential structures as well as child daycare facilities. A partial listing of regulations pertinent to residential and daycare living conditions is provided hereunder.

Federal Regulations

“Lead-Based Paint Poisoning Prevention in Certain Residential Structures”

40 C.F.R. Subpart L, § 745.225 & .226 - worker certification and training requirements

40 C.F.R. Subpart L, §745.227 -work practices standards

“Renovation, Repair, and Painting (RRP)”

40 C.F.R §745.80

“Methods and Standards for Lead-Paint Hazard Evaluation and Hazard Activities”

24 C.F.R. Part 35, Subpart R

2.2 LBP Inspection Procedures

Federal & State Regulatory Applicability (continued)

Lead in Workplace:

However, US OSHA is tasked with safeguarding work persons from unprotected lead (Pb+2) exposures in the workplace; any concentration of lead greater than the analytical Limit of Detection (LOD), in any form, triggers compliance with the US OSHA worker protection regulations. A partial listing of regulations pertinent to worker protection is provided hereunder.

Federal Regulations

“Lead in Construction”

29 CFR 1926.62

The US OSHA “Lead in Construction” standard applies to all construction work where an employee may be occupationally exposed to lead. All construction work excluded from coverage in the general industry standard for lead (Pb+2) by 29 CFR 1910.1025(a)(2) is covered by this standard.

Additional regulatory compliance information is available at “OSHA Lead in Construction Advisor”, Office of the Assistant Secretary for Policy / Office of Compliance Assistance Policy:

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

“Lead in General Industry”

29 CFR §1926.1025

“Hazard Communication Standard for the Construction Industry”

29 CFR §1926.59.

“Hazard Communication”

29 CFR §1910.1200

State Regulations

“Texas Environmental Lead Reduction”, Texas Department of State Health Services

§295.201 – §295.220, albeit these rules exclusively apply to lead-based paint activities in target housing and child-occupied facilities; the KBUSLIRL modernization project does not involve work target housing/child-occupied structures work.

2.3 LBP Testing Combinations

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

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

Hallways, stairways, and exterior areas are all examples of room equivalents. Walls are identified as A, B, C and

D. The “A” wall in each room corresponds with the wall on which the main entrance or street side of the building is located. The remaining walls are located in order proceeding clockwise from “A” wall. Side A faced the entrance to each apartment building.

Windows and/or doors are identified as #1, #2, #3, etc. with the Window #1 and/or Door #1, located at the extreme left-hand side of a room with additional windows and/or doors encountered at the same wall, numbered in ascending order; left to right naming convention.

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

2.3 LBP Testing Combinations (continued)

Each room equivalent is made up of Components. Components may be located inside or outside a building. For example, components in a room are the ceiling, floor, walls, a door and its casing, the window sash, and window casing. The Substrate is the material underneath the paint. Many substrates exist; however US HUD Final

Guidelines recommend classifying substrates into one of six substrate types: brick, concrete, drywall, metal, plaster, and wood. These substrate types are intended to include a broad range of materials. If the true substrate is not one of the six types, the substrate that most closely matches the true substrate is selected. For substrates on top of substrates, such as plaster on concrete, the substrate directly beneath the paint surface is used.

2.4 LBP Screen Limitations

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

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

Federal/State regulations.

SECTION 3.0 CONCLUSIONS & RECOMMENDATIONS

3.1 Conclusions

BEC concludes, based upon review of the LBP Screen data, “lead based paint” was detected (via in situ XRF testing) as listed in Appendix D – LPB Films & PCL Films

A. BEC concludes, based upon review of the LBP Screen findings, “lead based paint” (>1.0 mg/cm2) was detected

(via XRF in situ testing) at the subject site.

B. BEC concludes, based upon review of the LBP Screen findings, “paint containing lead” (i.e., Pb+2 concentration greater than the analytical LOD but < 1.0 mg/cm2) was detected (via XRF in situ testing) at the subject site.

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

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

Construction work is defined as work for construction, alteration and/or repair, including painting and decorating. It includes but is not limited to the following: demolition or salvage of structures where lead or materials containing lead are present; removal or encapsulation of materials containing lead; new construction, alteration, repair, or renovation of structures, substrates, or portions thereof, that contain lead, or materials containing lead; installation of products containing lead; lead contamination/emergency cleanup; transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are performed, and maintenance operations associated with the construction activities.

SECTION 3.0 CONCLUSIONS & RECOMMENDATIONS

3.1 Conclusions (continued)

E. Additionally, BEC concludes, in the State of Texas, all work, of which an employee may be occupationally exposed to lead - falls within the authority (purview) of US OSHA. It is relevant to note, paint with any measurable lead content may, when subjected to various construction or demolition actions, yield airborne particulate levels that exceed the regulatory Permissible Exposure Level (PEL). US OSHA policy explicitly requires compliance with the applicable standard for detectable levels of lead that are below the US

EPA/TCEQ/TDSHS abatement levels for residential and daycare regulated communities. US OSHA policy also recognizes XRF data for establishing a positive determination only. Only those surfaces, which have been determined by an accredited laboratory to contain lead concentrations less than the analytical instrument LOD, are exempt from these standards.

F. BEC concludes the building owner is required to communicate (i.e., specify in the contract documents) to the general contractor that regulated paint films (“lead-based paint” and/or “paint-containing lead”) are present within the renovation/demolition work area.

It is recommended contract specifications governing renovation/demolition work state the general contractor, and any lower tier subcontractor, are required to produce a US OSHA-compliant “Negative Exposure Assessment”

(NEA) for work which will, or can be reasonably anticipated, to result in disturbance of the regulated paint films.

Additionally, the contract specifications should state compliance with all other pertinent provisions of 29 CFR

1926.62 is required, owing to the potential worker exposures to airborne lead concentrations, in excess of the legally-enforceable Action Limit (AL, 30 µg/m3) and/or Permissible Exposure Limit (PEL, 50 µg/m3).

G. BEC concludes sampling of the anticipated construction and demolition (C&D) waste stream is required by

Federal law. BEC recommends ensuring both regulated and non-regulated paint finished building components bulk samples are collected and combined to form a composite sample of the total architectural building components wastestream. Submit the composite bulk sample to a US EPA-accredited laboratory to undergo

Toxic Characteristic Leachate Procedure (TCLP) analysis to reveal appropriate disposal requirement; general construction debris versus lead-containing hazardous waste.

3.2 Recommendations

BEC recommends the following corrective and compliance actions:

A. Prepare contract specifications language to effectively communicate regulated paint films are present at the subject site and use of lead-safe work practices (LSWP) are required

B. Conduct TCLP testing of the comprehensive C&D wastestream, prior to securing Bids for the modernization work.

C. In an abundance of caution and prudent risk management, BEC recommends, at a minimum, a General

Contractor- whom possesses current and valid US EPA “Renovation, Repair, and Painting (RRP)” [40 C.F.R

§745.80] training certifications and contractor registration (accreditation) - conduct any and all renovation work, of which will, or can reasonably anticipated to, result in the disturbance of these regulated paint films.

WORK PRODUCT DISCLAMER

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

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

APPENDIX A

PROTEC “LPA-1 RADIOACTIVE ENERGY RESOUCING DATA

APPENDIX B

XRF PERFORMANCE CHARACTERISTIC SHEET

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

Performance Characteristic Sheet

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

MANUFACTURER AND MODEL:

Make: Radiation Monitoring Devices Model: LPA-1

Source:

Co

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

FIELD OPERATION GUIDANCE

OPERATING PARAMETERS:

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

XRF CALIBRATION CHECK LIMITS:

0.7 to 1.3 mg/cm

(inclusive)

SUBSTRATE CORRECTION:

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

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

None using quick mode readings.

Substrate correction is not needed for:

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

THRESHOLDS:

30-SECOND EQUIVALENT STANDARD

MODE READING DESCRIPTION

SUBSTRATE

THRESHOLD

(mg/cm

Results corrected for substrate bias on metal substrate only

Brick Concrete Drywall Metal

Plaster Wood

1.0 1.0 1.0 0.9 1.0 1.0

QUICK MODE

READING DESCRIPTION

SUBSTRATE

THRESHOLD

(mg/cm

Readings not corrected for substrate bias on any substrate

Brick Concrete Drywall Metal

Plaster Wood

1.0 1.0 1.0 1.0 1.0 1.0

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

BACKGROUND INFORMATION

EVALUATION DATA SOURCE AND DATE:

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

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

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

OPERATING PARAMETERS:

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

XRF CALIBRATION CHECK:

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

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

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

SUBSTRATE CORRECTION VALUE COMPUTATION:

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

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

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

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

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

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

For each substrate type (the 1.02 mg/cm

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

Correction value = (1 st

+ 2 nd

+ 3 rd

+ 4 th

+ 5 th

+ 6 th

Reading) / 6 - 1.02 mg/cm²

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

EVALUATING THE QUALITY OF XRF TESTING:

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

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

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

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

Compute the Retest Tolerance Limit by the following steps:

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

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

Square the average for each testing combination.

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

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

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

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

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

Compute the average of all ten original XRF results.

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

Find the absolute difference of the two averages.

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

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

BIAS AND PRECISION:

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

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

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

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

30-SECOND STANDARD MODE

READING MEASURED AT

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

0.0 mg/cm

Brick Concrete Drywall Metal

Plaster Wood

0.0 0.0 0.1 0.3 0.1 0.0

0.1 0.1 0.1 0.1 0.1 0.1

0.5 mg/cm

Brick Concrete Drywall Metal

Plaster Wood

0.0 0.0 0.0 0.2 0.0 0.0

0.2 0.2 0.2 0.2 0.2 0.2

1.0 mg/cm

Brick Concrete Drywall Metal

Plaster Wood

0.0 0.0 0.0 0.2 0.0 0.0

0.3 0.3 0.3 0.3 0.3 0.3

2.0 mg/cm

Brick Concrete Drywall Metal

Plaster Wood

-0.1 -0.1 -0.1 0.1 -0.1 -0.1

0.4 0.4 0.4 0.4 0.4 0.4

*Precision at 1 standard deviation.

CLASSIFICATION RESULTS:

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

DOCUMENTATION:

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

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

Limit of Detection (LOD)

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

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

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

LPA-1 analyzer.

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

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

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

0.096 or almost 0.1 mg/cm

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

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

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

We hope this note is helpful to you.

RMD Instruments, LLC

Operation of the LPA-1 analyzer and its operational statistics

Zero measurements and negative values

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

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

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

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

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

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

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

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

APPENDIX C

XRF TESTING DATA

THE PROTEC LPA-1 XRF LEAD PAINT SPECTRUM ANALYZER

LEAD PAINT INSPECTION REPORT

INSPECTION FOR: MERRICK & COMPANY

ABATEMENT LEVEL: 1.0

TOTAL READINGS: 1,394

JOB STARTED: 03/25/19 09:03

JOB FINISHED: 04/03/19 14:33

PERFORMED AT: United State Department of Agriculture (USDA) Agriculture Research Service (ARS), Plains Area (PA) Knipling-Bushland U.S. Livestock Insect Research Laboratory 2700 Fredericksburg Road, Kerrville, Texas 7808-9184

INSPECTION DATE: March 24, 2019 – 3 April 2019

INSTRUMENT TYPE: PROTEC

MODEL LPA-1

XRF TYPE ANALYZER

Serial Number: #01701

OPERATOR LICENSE: Andrew L. Hanson

Lead Risk Assessor Certification #107347 Exp: 02/28/2021

SIGNED: DATE: 14 May 2019

Andrew L. Hanson, Project Manager

SEQUENTIAL REPORT OF LEAD PAINT INSPECTION FOR: Building #1 USDA Kerrville

Inspection Date: 03/26/19

Report Date: 4/8/2019

Abatement Level: 1.0

Report No. S#01701 - 03/26/19 09:49

Total Readings: 85

Job Started: 03/26/19 09:49

Job Finished: 03/26/19 10:52

Read Room Paint Paint Lead

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

1 CALIBRATION 0.8 TC

2 CALIBRATION 0.7 TC

3 CALIBRATION 0.7 TC

4 001 ReceptionRm A Wall U Ctr I Concrete White -0.2 QM

5 001 ReceptionRm B Wall U Ctr I Concrete White -0.4 QM

6 001 ReceptionRm C Wall U Ctr I Concrete White -0.1 QM

7 001 ReceptionRm D Wall U Ctr I Concrete White -0.2 QM

8 001 ReceptionRm A Baseboard Ctr I Wood White -0.1 QM

9 001 ReceptionRm A Door Ctr Lft casing I Metal White -0.3 QM

10 002 Office A Wall U Ctr I Sheetrock White -0.5 QM

11 002 Office B Wall U Ctr I Sheetrock White -0.3 QM

12 002 Office C Wall U Ctr I Sheetrock White -0.2 QM

13 002 Office D Wall U Ctr I Sheetrock White -0.3 QM

14 002 Office D Baseboard Ctr I Wood White -0.1 QM

15 002 Office D Window Ctr Sill I Wood White -0.2 QM

16 002 Office D Window Ctr Rgt casing I Wood White -0.2 QM

17 002 Office B Door Ctr Rgt casing I Wood White -0.2 QM

18 003 Lab A Wall U Ctr I Concrete Pink -0.3 QM

19 003 Lab B Wall U Ctr I Concrete Pink -0.4 QM

20 003 Lab C Wall U Ctr I Concrete Pink -0.2 QM

21 003 Lab D Wall U Ctr F Concrete Pink -0.4 QM

22 003 Lab D Floor I Concrete White -0.4 QM

23 003 Lab D Door Rgt Rgt casing I Wood White 0.0 QM

24 004 Kitchen A Wall U Ctr I Concrete White -0.5 QM

25 004 Kitchen B Wall U Ctr I Concrete White -0.1 QM

26 004 Kitchen C Wall U Ctr I Concrete White -0.3 QM

27 004 Kitchen D Wall U Ctr I Sheetrock White -0.3 QM

28 004 Kitchen C Door Ctr U Ctr I Metal White -0.4 QM

29 004 Kitchen C Door Ctr Rgt casing I Metal White -0.3 QM

30 005 Office A Wall U Ctr I Concrete White -0.2 QM

31 005 Office B Wall U Ctr I Concrete White -0.6 QM

32 005 Office C Wall U Ctr I Concrete White -0.1 QM

33 005 Office D Wall U Ctr I Concrete White -0.3 QM

34 005 Office C Pipe Ctr I Metal White -0.4 QM

35 005 Office A Door Rgt Rgt casing I Metal White -0.1 QM

36 006 MeetingRoom A Wall U Ctr I Sheetrock White -0.3 QM

37 006 MeetingRoom B Wall U Ctr I Sheetrock White -0.4 QM

38 006 MeetingRoom C Wall U Ctr I Sheetrock White -0.5 QM

39 006 MeetingRoom D Wall U Ctr I Sheetrock White -0.5 QM

40 006 MeetingRoom C Baseboard Ctr I Wood White -0.3 QM

41 006 MeetingRoom C Door Ctr U Ctr I Metal White -0.3 QM

42 006 MeetingRoom C Door Ctr Rgt casing I Wood White -0.3 QM

43 006 MeetingRoom D Vent Cover Rgt I Metal Brown -0.3 QM

44 007 Office A Wall U Ctr I Concrete White -0.4 QM

45 007 Office B Wall U Ctr I Concrete White -0.3 QM

46 007 Office C Wall U Ctr I Concrete White -0.3 QM

47 007 Office D Wall U Ctr I Concrete White -0.2 QM

48 007 Office D Door Ctr Rgt casing I Metal White -0.1 QM

49 008 MRestroom A Wall U Ctr I Sheetrock White -0.4 QM

50 008 MRestroom B Wall U Ctr I Sheetrock White -0.2 QM

51 008 MRestroom C Wall U Ctr I Sheetrock White -0.4 QM

52 008 MRestroom D Wall U Ctr I Concrete White -0.4 QM

53 008 MRestroom A Door Rgt Rgt casing I Metal White -0.4 QM

54 009 WRestroom A Wall U Ctr I Concrete White -0.5 QM

55 009 WRestroom B Wall U Ctr I Concrete White -0.2 QM

56 009 WRestroom C Wall U Ctr I Sheetrock White -0.2 QM

57 009 WRestroom D Wall U Ctr I Concrete White -0.7 QM

58 009 WRestroom A Door Rgt Rgt casing I Metal White -0.3 QM

59 010 Hallway A Wall U Ctr I Concrete White -0.2 QM

60 010 Hallway B Wall U Ctr I Concrete White -0.4 QM

61 010 Hallway C Wall U Ctr I Sheetrock White -0.3 QM

62 010 Hallway D Wall U Ctr I Concrete White -0.1 QM

63 010 Hallway C Baseboard Ctr I Wood White -0.4 QM

64 010 Hallway A Door Ctr Rgt casing I Metal White -0.1 QM

65 011 AC/Heat A Wall U Ctr I Concrete Yellow -0.4 QM

66 011 AC/Heat C Wall U Ctr I Concrete Yellow -0.1 QM

67 001 EXT 1 A Wall U Ctr I Concrete White -0.4 QM

68 001 EXT 1 A Door Rgt Rgt casing I Wood Green -0.1 QM

69 001 EXT 1 A Window Ctr Sill I Concrete White -0.5 QM

70 001 EXT 1 A Railing Ctr Railing I Metal Green 2.5 QM

71 001 EXT 1 A Soffit I Plaster White -0.6 QM

72 001 EXT 1 B Wall U Ctr I Concrete White -0.3 QM

73 001 EXT 1 B Window Ctr Sill I Concrete White -0.8 QM

74 001 EXT 1 C Wall U Ctr I Concrete White -0.4 QM

75 001 EXT 1 C Door Ctr U Ctr I Metal Green -0.3 QM

76 001 EXT 1 C Door Rgt Rgt casing I Metal Green -0.2 QM

77 001 EXT 1 C Window Rgt Sill I Concrete White -0.4 QM

78 001 EXT 1 C Soffit I Plaster White -0.4 QM

79 001 EXT 1 C JunctionBx Ctr I Metal White -0.5 QM

80 001 EXT 1 C Ramp Ctr I Concrete Grey -0.6 QM

81 001 EXT 1 D Wall U Ctr I Concrete White -0.4 QM

82 001 EXT 1 D Window Ctr Sill I Concrete White -0.6 QM

83 CALIBRATION 0.8 TC

84 CALIBRATION 0.8 TC

85 CALIBRATION 0.7 TC

---- End of Readings ----

SUMMARY REPORT OF LEAD PAINT INSPECTION FOR: Building #1 USDA Kerrville

Abatement Level: 1.0

Report No. S#01701 - 03/26/19 09:49

Total Readings: 85 Actionable: 1

Read Paint Paint Lead

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

Exterior Room 001 EXT 1

070 A Railing Ctr Railing I Metal Green 2.5 QM

DETAILED REPORT OF LEAD PAINT INSPECTION FOR: Building #1 USDA Kerrville

Abatement Level: 1.0

Report No. S#01701 - 03/26/19 09:49

Total Readings: 85

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

Exterior Room 001 EXT 1

067 A Wall U Ctr I Concrete White -0.4 QM

071 A Soffit I Plaster White -0.6 QM

069 A Window Ctr Sill I Concrete White -0.5 QM

068 A Door Rgt Rgt casing I Wood Green -0.1 QM

070 A Railing Ctr Railing I Metal Green 2.5 QM

072 B Wall U Ctr I Concrete White -0.3 QM

073 B Window Ctr Sill I Concrete White -0.8 QM

074 C Wall U Ctr I Concrete White -0.4 QM

078 C Soffit I Plaster White -0.4 QM

077 C Window Rgt Sill I Concrete White -0.4 QM

076 C Door Rgt Rgt casing I Metal Green -0.2 QM

075 C Door Ctr U Ctr I Metal Green -0.3 QM

079 C JunctionBx Ctr I Metal White -0.5 QM

080 C Ramp Ctr I Concrete Grey -0.6 QM

081 D Wall U Ctr I Concrete White -0.4 QM

082 D Window Ctr Sill I Concrete White -0.6 QM

Interior Room 001 ReceptionRm

004 A Wall U Ctr I Concrete White -0.2 QM

008 A Baseboard Ctr I Wood White -0.1 QM

009 A Door Ctr Lft casing I Metal White -0.3 QM

005 B Wall U Ctr I Concrete White -0.4 QM

006 C Wall U Ctr I Concrete White -0.1 QM

007 D Wall U Ctr I Concrete White -0.2 QM

Interior Room 002 Office

010 A Wall U Ctr I Sheetrock White -0.5 QM

011 B Wall U Ctr I Sheetrock White -0.3 QM

017 B Door Ctr Rgt casing I Wood White -0.2 QM

012 C Wall U Ctr I Sheetrock White -0.2 QM

013 D Wall U Ctr I Sheetrock White -0.3 QM

014 D Baseboard Ctr I Wood White -0.1 QM

016 D Window Ctr Rgt casing I Wood White -0.2 QM

015 D Window Ctr Sill I Wood White -0.2 QM

Interior Room 003 Lab

018 A Wall U Ctr I Concrete Pink -0.3 QM

019 B Wall U Ctr I Concrete Pink -0.4 QM

020 C Wall U Ctr I Concrete Pink -0.2 QM

021 D Wall U Ctr F Concrete Pink -0.4 QM

022 D Floor I Concrete White -0.4 QM

023 D Door Rgt Rgt casing I Wood White 0.0 QM

Interior Room 004 Kitchen

024 A Wall U Ctr I Concrete White -0.5 QM

025 B Wall U Ctr I Concrete White -0.1 QM

026 C Wall U Ctr I Concrete White -0.3 QM

029 C Door Ctr Rgt casing I Metal White -0.3 QM

028 C Door Ctr U Ctr I Metal White -0.4 QM

027 D Wall U Ctr I Sheetrock White -0.3 QM

Interior Room 005 Office

030 A Wall U Ctr I Concrete White -0.2 QM

035 A Door Rgt Rgt casing I Metal White -0.1 QM

031 B Wall U Ctr I Concrete White -0.6 QM

032 C Wall U Ctr I Concrete White -0.1 QM

034 C Pipe Ctr I Metal White -0.4 QM

033 D Wall U Ctr I Concrete White -0.3 QM

Interior Room 006 MeetingRoom

036 A Wall U Ctr I Sheetrock White -0.3 QM

037 B Wall U Ctr I Sheetrock White -0.4 QM

038 C Wall U Ctr I Sheetrock White -0.5 QM

040 C Baseboard Ctr I Wood White -0.3 QM

042 C Door Ctr Rgt casing I Wood White -0.3 QM

041 C Door Ctr U Ctr I Metal White -0.3 QM

039 D Wall U Ctr I Sheetrock White -0.5 QM

043 D Vent Cover Rgt I Metal Brown -0.3 QM

Interior Room 007 Office

044 A Wall U Ctr I Concrete White -0.4 QM

045 B Wall U Ctr I Concrete White -0.3 QM

046 C Wall U Ctr I Concrete White -0.3 QM

047 D Wall U Ctr I Concrete White -0.2 QM

048 D Door Ctr Rgt casing I Metal White -0.1 QM

Interior Room 008 MRestroom

049 A Wall U Ctr I Sheetrock White -0.4 QM

053 A Door Rgt Rgt casing I Metal White -0.4 QM

050 B Wall U Ctr I Sheetrock White -0.2 QM

051 C Wall U Ctr I Sheetrock White -0.4 QM

052 D Wall U Ctr I Concrete White -0.4 QM

Interior Room 009 WRestroom

054 A Wall U Ctr I Concrete White -0.5 QM

058 A Door Rgt Rgt casing I Metal White -0.3 QM

055 B Wall U Ctr I Concrete White -0.2 QM

056 C Wall U Ctr I Sheetrock White -0.2 QM

057 D Wall U Ctr I Concrete White -0.7 QM

Interior Room 010 Hallway

059 A Wall U Ctr I Concrete White -0.2 QM

064 A Door Ctr Rgt casing I Metal White -0.1 QM

060 B Wall U Ctr I Concrete White -0.4 QM

061 C Wall U Ctr I Sheetrock White -0.3 QM

063 C Baseboard Ctr I Wood White -0.4 QM

062 D Wall U Ctr I Concrete White -0.1 QM

Interior Room 011 AC/Heat

065 A Wall U Ctr I Concrete Yellow -0.4 QM

066 C Wall U Ctr I Concrete Yellow -0.1 QM

Calibration Readings

001 0.8 TC

002 0.7 TC

003 0.7 TC

083 0.8 TC

084 0.8 TC

085 0.7 TC

DISTRIBUTION REPORT OF LEAD PAINT INSPECTION FOR: Building #1 USDA Kerrville

Abatement Level: 1.0

Report No. S#01701 - 03/26/19 09:49

Total Reading Sets: 79

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

Structure Total Positive Negative Inconclusive

Baseboard 4 0 <0%> 4 <100%> 0 <0%>

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

Door Rgt casing 11 0 <0%> 11 <100%> 0 <0%>

Door U Ctr 3 0 <0%> 3 <100%> 0 <0%>

Floor 1 0 <0%> 1 <100%> 0 <0%>

JunctionBx 1 0 <0%> 1 <100%> 0 <0%>

Pipe 1 0 <0%> 1 <100%> 0 <0%>

Railing Railing 1 1 <100%> 0 <0%> 0 <0%>

Ramp 1 0 <0%> 1 <100%> 0 <0%>

Soffit 2 0 <0%> 2 <100%> 0 <0%>

Vent Cover 1 0 <0%> 1 <100%> 0 <0%>

Wall 46 0 <0%> 46 <100%> 0 <0%>

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

Window Sill 5 0 <0%> 5 <100%> 0 <0%>

Inspection Totals: 79 1 < 1%> 78 < 99%> 0 < 0%>

SEQUENTIAL REPORT OF LEAD PAINT INSPECTION FOR: Building #2 USDA Kerrville

Abatement Level: 1.0

Report No. S#01701 - 03/26/19 08:53

Total Readings: 99

Job Started: 03/26/19 08:53

Job Finished: 03/26/19 09:48

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

1 CALIBRATION 0.9 TC

2 CALIBRATION 0.9 TC

3 CALIBRATION 0.8 TC

4 001 Office A Wall U Ctr I Wood Brown -0.3 QM

5 001 Office B Wall U Ctr I Sheetrock White -0.5 QM

6 001 Office C Wall U Ctr I Sheetrock White -0.3 QM

7 001 Office D Wall U Ctr I Sheetrock White -0.3 QM

8 001 Office D Baseboard Ctr I Wood White -0.2 QM

9 001 Office A Window Ctr Rgt casing I Metal Brown -0.2 QM

10 001 Office A Door Lft U Lft I Wood Brown -0.2 QM

11 001 Office A Door Lft Lft casing I Wood Brown 0.0 QM

12 002 Office A Wall U Ctr I Sheetrock White -0.4 QM

13 002 Office B Wall U Ctr I Sheetrock White -0.3 QM

14 002 Office C Wall U Ctr I Sheetrock White -0.4 QM

15 002 Office D Wall U Ctr I Sheetrock White -0.4 QM

16 002 Office A Window Rgt Rgt casing I Wood Brown -0.3 QM

17 002 Office D Door Ctr Rgt casing I Wood Brown 0.0 QM

18 003 Office A Wall U Ctr I Sheetrock White -0.4 QM

19 003 Office B Wall U Ctr I Sheetrock White -0.5 QM

20 003 Office C Wall U Ctr I Sheetrock White -0.3 QM

21 003 Office D Wall U Ctr I Sheetrock White -0.4 QM

22 003 Office B Baseboard Ctr I Wood White -0.1 QM

23 003 Office B Window Ctr Rgt casing I Wood Brown -0.2 QM

24 003 Office D Door Ctr Rgt casing I Wood Brown -0.2 QM

25 004 Mail Room A Wall U Ctr I Sheetrock White -0.5 QM

26 004 Mail Room B Wall U Ctr I Sheetrock White -0.5 QM

27 004 Mail Room C Wall U Ctr I Sheetrock White -0.2 QM

28 004 Mail Room D Wall U Ctr I Sheetrock White -0.6 QM

29 004 Mail Room D Ceiling I Sheetrock White -0.3 QM

30 004 Mail Room B Baseboard Ctr I Wood White 0.0 QM

31 004 Mail Room C Door Lft U Lft I Metal Brown 3.7 QM

32 004 Mail Room C Door Lft Lft casing I Wood Brown -0.2 QM

33 005 Supply Room A Wall U Ctr I Sheetrock White -0.6 QM

34 005 Supply Room B Wall U Ctr I Sheetrock White -0.2 QM

35 005 Supply Room C Wall U Ctr I Sheetrock White -0.3 QM

36 005 Supply Room D Wall U Ctr I Sheetrock White -0.5 QM

37 005 Supply Room D Baseboard Ctr I Wood White -0.2 QM

38 005 Supply Room D Door Ctr Lft casing I Wood White -0.2 QM

39 006 Office A Wall U Ctr I Sheetrock White -0.4 QM

40 006 Office B Wall U Ctr I Sheetrock White -0.2 QM

41 006 Office C Wall U Ctr I Sheetrock White -0.3 QM

42 006 Office D Wall U Ctr I Sheetrock White -0.2 QM

43 006 Office C Baseboard Ctr I Wood White -0.5 QM

44 006 Office C Window Rgt Rgt casing I Wood Brown -0.3 QM

45 006 Office D Door Rgt Rgt casing I Wood Brown -0.2 QM

46 007 Restroom A Wall U Ctr I Sheetrock White -0.3 QM

47 007 Restroom B Wall U Ctr I Sheetrock White -0.4 QM

48 007 Restroom C Wall U Ctr I Sheetrock White -0.2 QM

49 007 Restroom D Wall U Ctr I Sheetrock White -0.1 QM

50 007 Restroom D Ceiling I Sheetrock White -0.4 QM

51 007 Restroom C Window Rgt Rgt casing I Wood Brown -0.2 QM

52 007 Restroom D Door Lft Lft casing I Wood Brown -0.4 QM

53 008 ServerRoom A Wall U Ctr I Sheetrock Blue -0.1 QM

54 008 ServerRoom B Wall U Ctr I Sheetrock Blue -0.5 QM

55 008 ServerRoom C Wall U Ctr I Sheetrock Grey -0.4 QM

56 008 ServerRoom D Wall U Ctr I Sheetrock Grey -0.3 QM

57 008 ServerRoom D Ceiling I Sheetrock White -0.3 QM

58 008 ServerRoom D Window Lft Lft casing I Wood Brown -0.3 QM

59 008 ServerRoom A Door Ctr Lft casing I Wood Brown -0.1 QM

60 008 ServerRoom B Closet Ctr Wall I Sheetrock White -0.4 QM

61 008 ServerRoom D Closet Ctr Wall I Sheetrock White -0.3 QM

62 008 ServerRoom D Closet Ctr Ceiling I Sheetrock White -0.2 QM

63 009 AC A Wall U Ctr I Sheetrock White -0.3 QM

64 009 AC B Wall U Ctr I Sheetrock White -0.2 QM

65 009 AC C Wall U Ctr I Sheetrock White -0.2 QM

66 009 AC D Wall U Ctr I Sheetrock White -0.2 QM

67 009 AC D Ceiling I Sheetrock White -0.7 QM

68 009 AC D Floor I Wood Brown -0.5 QM

69 009 AC B Door Rgt Rgt jamb I Wood Brown -0.1 QM

70 010 Office A Wall U Ctr I Sheetrock White -0.4 QM

71 010 Office B Wall U Ctr I Sheetrock White -0.2 QM

72 010 Office C Wall U Ctr I Sheetrock White -0.2 QM

73 010 Office D Wall U Ctr I Sheetrock White -0.5 QM

74 010 Office C Baseboard Ctr I Wood White -0.1 QM

75 010 Office D Window Rgt Rgt casing I Wood Brown -0.4 QM

76 010 Office B Door Ctr Lft casing I Wood Brown -0.2 QM

77 001 EXT 2 A Wall U Ctr I Plaster White -0.5 QM

78 001 EXT 2 A Beam Ctr I Wood Green -0.3 QM

79 001 EXT 2 A Window Lft Lft casing I Wood Green -0.2 QM

80 001 EXT 2 A Door Ctr U Ctr I Metal Brown -0.4 QM

81 001 EXT 2 A Railing Ctr Railing I Metal Black -0.5 QM

82 001 EXT 2 B Wall U Ctr I Plaster White -0.6 QM

83 001 EXT 2 B Wall U Ctr I Concrete White -0.3 QM

84 001 EXT 2 B Window Ctr Rgt casing I Wood Green -0.2 QM

85 001 EXT 2 C Wall U Ctr I Plaster White -0.3 QM

86 001 EXT 2 C Wall U Ctr I Concrete White -0.4 QM

87 001 EXT 2 C Beam Ctr I Wood Green -0.1 QM

88 001 EXT 2 C Soffit I Plaster White 2.6 QM

89 001 EXT 2 C Door Rgt U Rgt I Metal Brown 1.5 QM

90 001 EXT 2 C Door Rgt Rgt casing I Wood Green 0.0 QM

91 001 EXT 2 C Railing Ctr Railing I Metal Black -0.1 QM

92 001 EXT 2 C Window Rgt Rgt casing I Wood Green -0.3 QM

93 001 EXT 2 C ParkingLine Ctr I Concrete Yellow 3.7 QM

94 001 EXT 2 D Wall U Ctr I Plaster White -0.4 QM

95 001 EXT 2 D Wall L Ctr I Concrete White -0.2 QM

96 001 EXT 2 D Window Lft Lft casing I Wood Green -0.4 QM

97 CALIBRATION 0.8 TC

98 CALIBRATION 0.9 TC

99 CALIBRATION 0.7 TC

SUMMARY REPORT OF LEAD PAINT INSPECTION FOR: Building #2 USDA Kerrville

Abatement Level: 1.0

Report No. S#01701 - 03/26/19 08:53

Total Readings: 99 Actionable: 4

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

Exterior Room 001 EXT 2

088 C Soffit I Plaster White 2.6 QM

089 C Door Rgt U Rgt I Metal Brown 1.5 QM

093 C ParkingLine Ctr I Concrete Yellow 3.7 QM

Interior Room 004 Mail Room

031 C Door Lft U Lft I Metal Brown 3.7 QM

DETAILED REPORT OF LEAD PAINT INSPECTION FOR: Building #2 USDA Kerrville

Abatement Level: 1.0

Report No. S#01701 - 03/26/19 08:53

Total Readings: 99

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

Exterior Room 001 EXT 2

077 A Wall U Ctr I Plaster White -0.5 QM

079 A Window Lft Lft casing I Wood Green -0.2 QM

080 A Door Ctr U Ctr I Metal Brown -0.4 QM

081 A Railing Ctr Railing I Metal Black -0.5 QM

078 A Beam Ctr I Wood Green -0.3 QM

082 B Wall U Ctr I Plaster White -0.6 QM

083 B Wall U Ctr I Concrete White -0.3 QM

084 B Window Ctr Rgt casing I Wood Green -0.2 QM

085 C Wall U Ctr I Plaster White -0.3 QM

086 C Wall U Ctr I Concrete White -0.4 QM

088 C Soffit I Plaster White 2.6 QM

092 C Window Rgt Rgt casing I Wood Green -0.3 QM

090 C Door Rgt Rgt casing I Wood Green 0.0 QM

089 C Door Rgt U Rgt I Metal Brown 1.5 QM

091 C Railing Ctr Railing I Metal Black -0.1 QM

093 C ParkingLine Ctr I Concrete Yellow 3.7 QM

087 C Beam Ctr I Wood Green -0.1 QM

095 D Wall L Ctr I Concrete White -0.2 QM

094 D Wall U Ctr I Plaster White -0.4 QM

096 D Window Lft Lft casing I Wood Green -0.4 QM

Interior Room 001…