Lead-Based Paint Interim Control Plan 356 Rood Avenue

Windsor, CT

Town of Windsor Housing Rehabilitation Loan Program

Windsor Connecticut

October 10, 2025

EnviroPlan LLC 27 Trotwood Dr.

West Hartford, CT 06117

October 10, 2025

Flavia Rey de Castro Community Development Specialist Town of Windsor 275 Broad Street Windsor, CT 06095

RE: Lead Based Paint Interim Control Plan 356 Rood Ave., Windsor, CT EnviroPlan Project No. 2019-152-27

Dear Ms. Rey de Castro:

Enclosed please find the Lead-Based Paint Interim Control Plan required for the above-referenced site. The plan has been prepared in accordance with the requirements of Title X 1012/1013 regulations 24 CFR Part 35. For the purpose of this interim control plan, all building components with toxic levels of lead based paint in a deteriorated condition are included.

If you have any questions regarding the contents of the Plan, please do not hesitate to contact us.

Sincerely, Neal B. Freuden President Connecticut Certified Lead Inspector/Risk Assessor 000152 Connecticut Certified Lead Planner Project Designer 000989 EPA Certified Lead Abatement Supervisor EPA Certified Lead Safe Renovator EPA Certified Instructor for the following Courses: Lead Inspector, Risk Assessor, Planner Project Designer, Abatement Supervisor and Renovator.

1 Introduction

Work outlined in this Plan includes scraping and repainting (paint stabilization) of Exterior Building Components that have been tested and determined to be to be coated with lead-based paint in a defective condition. The work shall be conducted in conformance with EPA regulations (40 CFR Part 745-Lead-Based Paint Poisoning Prevention In Certain Residential and Child-Occupied Structures, Subpart E-Residential and Child-Occupied Property Renovation.) and the HUD Lead Safe Housing Rule of Title X 1012/1013 regulations 24 CFR Part 35.

2 Property Information

Property Address: 356 Rood Ave.

Windsor, Connecticut Property Owner(s): Deborah Relph Owner's Address: 356 Rood Ave.

Windsor, Connecticut

3 Lead Consultant Contractor

Name: EnviroPlan LLC Address: 27 Trotwood Dr.

West Hartford, Connecticut 06117 License Number 002085

4 Lead Inspector/Risk Assessor

Inspector/Risk Assessor’s Name: Neal B. Freuden Certificate Number: 000152 Date of Testing: 9/24/2025

Inspection/Risk Assessment Methodology: On-site x-ray fluorescence utilizing an RMD spectrum analyzer was used for the inspection Testing performed in accordance with HUD Guidelines and State of Connecticut regulations. Dust wipe and bare soil samples were collected as a part of the risk assessment.

Clearance inspection will entail a visual of the interim control work on the exterior of the house to confirm that its has been done in accordance with the plan. In addition, the lead inspector will conduct a visual of the soil areas within the vicinity of where the work has taken place to confirm that lead safe work practices have been used and the soil is free of lead based paint contamination.

5. Lead Planner Project

Designer

Name: Neal B. Freuden Firm/Address: EnviroPlan LLC

27 Trotwood Dr.

West Hartford, Connecticut 06117 Certificate Number: 000989

6 Work Procedures for Exterior Work

Interim controls are defined as a set of measures designed to temporarily reduce human exposure or likely exposure to lead paint hazards, including specialized cleaning, repairs, maintenance, painting, and temporary containment. The following containment preparations and safe work practices shall be utilized during interim control procedures involving standard treatments and corrective procedures that disturb paint that exceeds the following (de-minimus) quantities:

• Exterior large surfaces cumulatively greater than 20 square feet

• Exterior small components where more than 10% of the paint is to be disturbed.

• Any amount of demolition requires lead safe work practices regardless of quantity. .

Note: this exception to de-minimus quantities also applies to windows. Any amount of window removal and replacement requires lead safe work practices

Work involving the disturbance of paint that does not exceed the above quantities or does not involve demolition does not require the use of safe work practices or training of workers performing work as listed herein.

A. Exterior Preparation

1. Restrict access to the work area. Request any building occupants to leave the area where work will be performed. Request that they not return until work is completed. Place warning tape behind a 10 foot “buffer zone” measured from the edge of the containment (see item 3 below). Place warning signs along the taped perimeter.

2. Moveable objects belonging to residents must be removed from the work area.

This includes but is not limited to any outdoor furnishings, etc. The belongings should be stored in an easily accessible location.

3. Protective disposable plastic sheeting placed on ground or exterior flooring or stairs shall extend 10’-0” in all directions from work surface or as space permits.

If area working on is less than 10’-0” from a neighboring property or the street, use vertical shrouds to prevent dust and debris from impacting these adjacent areas. Build a small curb using 2 X 4 boards or similar materials at perimeter of sheeting to contain any paint chips or dust. Doors and windows within 20’-0” of the work area should be closed and sealed with protective sheeting.

4. Place all required tools and equipment in the work area so that area will not have to be left in order to complete the work. This will avoid stepping off the protective sheeting.

5. Use protective shoe covers, tack pads or have available cleaning materials to wipe off shoes prior to stepping off of protective sheeting.

B. Interim Control Procedures

1. Paint Stabilization:

• Wet scrape any loose flaking or peeling paint utilizing hand scraper and a spray bottle.

• If removal of damaged edges is necessary mist surface prior to removing.

skim and fill holes and cracks less than 1/16” wide with non shrink spackle compound. Nail heads exposed should be countersunk and holes filled with compatible wood putty. Alternatively nail heads at a minimum should be coated with an exterior primer that will prevent rusting of exposed nail heads.

• If sanding of surface is necessary to feather edges, use wet abrasive sponge or wet dry sandpaper with water.

• Prepare entire surface for re-painting, by cleaning with high grade detergent (such as TSP) including de-glossing as necessary. Allow surface to completely dry before priming.

• Provide paint and/or stain in accordance with the Town of Windsor Housing Rehabilitation Program program requirements.

2. Component Removal: Mist the surface prior to removing. Care should be taken to mist areas thoroughly if demolition work is to be performed to minimize the creation of airborne dust and debris.

7. Worker Protection and Training

There must be at least one person performing the work who is an EPA Certified Renovator. Other workers on the site, under the direction of the Certified Renovator, must have either the EPA Renovation, Repair and Painting (RRP) training certification (Certified Renovator training) or the HUD Lead Safe Work Practices training and certification.

Workers shall utilize eye protection, use disposable coveralls or coveralls that are to be laundered by employer, and respiratory protection. If respiratory protection is to be used worker must have a medical exam including pulmonary function test, questionnaire and receive additional training in accordance with OSHA regulations.

Workers shall ensure that dust is removed from protective clothing prior to leaving the work area, and wash hands and face prior to eating or drinking.

8 Clean Up Procedures (Work Involving Interim Control and to Eliminate Dust Hazards Identified at the Site)

A. General Cleaning Procedures

1. Debris - removed debris shall be wrapped in polyethylene sheeting for transport out of the interim control area.

2. Sheeting. Exterior polyethylene sheeting shall be wet misted and then folded over upon itself to trap any remaining debris.

3. The exterior surfaces shall be visually inspected by the Certified Renovator and any paint chips and other debris picked up and properly disposed.

9 Waste Disposal

A. Lead construction waste shall be properly disposed of. Disposal of lead waste shall be accordance with all local, state, and federal regulations. Resulting waste must be tested to determine disposal requirements and properly disposed unless the building owner agrees to take possession in writing of up to 10 cubic yards of waste and dispose of it as ordinary household waste under the Connecticut household hazardous waste exemption. Any waste in excess of 10 cubic yards must be characterized or assumed to be hazardous waste and disposed of properly.

Waste characterization shall be determined by the Toxic Characteristic Leachate Procedure (TCLP).before the interim control work starts. The collection of the TCLP sample will be performed by a certified lead inspector with the assistance of the contractor.

1. Hazardous Waste is characterized as greater than 5mg/L of leachable lead by the TCLP analyses.

2. Non-hazardous Solid Waste is characterized as 0-5mg/L by the TCLP analysis.

According to CTDPH, waste characterization is the responsibility of the Lead Consulting Contractor who can be assisted by the Lead Safe Renovator in identifying the proper proportions of building components and substrates that comprise the waste stream.

Under the direction of the lead consultant, the contractor can use various tools to create subsamples which will make up the ultimate sample which will be sent to a laboratory for TCLP analysis.

Owner

Signature ______

Date ______

LEAD-BASED PAINT INTERIM CONTROLS

356 ROOD AVENUE, WINDSOR, CT

SCOPE OF WORK

GENERAL NOTES:

1. The property is a single-story wood frame house with a finished basement Window systems are primarily constructed of wood. The exterior has aluminum siding. There is a detached garage.

2. The workers must be properly trained and certified to perform lead safe work practices. A certified lead safe renovation contractor must be utilized in performing the required work.

3. All required lead paint interim control work shall be conducted in compliance with HUD regulation 24 CFR Part 35.

4. Lead safe renovation work involving removal of doors and related components (casings, jambs, kickboards and thresholds) and windows (sashes, trim, sills, etc.)

must be performed in strict coordination with general trades work. Resulting waste must be tested to determine disposal requirements and properly disposed.

5. All defective lead based painted surfaces shall be interim controlled per this plan. Any remaining lead-based paint in an intact condition, is to be included in an in-place management plan and periodically inspected for defective paint.

LOCATION

COMPONENT CONDITION REMEDIATION METHOD

EXTERIOR

C Side of the House

Metal Bulkhead Doors (provides entry to the basement from the outdoors)

Defective Remove and replace in accordance with the specifications for this project in the Town of Windsor Housing Rehabilitation Loan Program

In addition, in any other areas of the bulkhead, stabilize the paint, using lead safe work practices, rendering it intact and re-painting,