Lead Survey.pdf

LEAD BASED PAINT RENOVATION SURVEY

NAS WHITING FIELD

BUILDINGS 2977 & 2978

MILTON, SANTA ROSA COUNTY, FLORIDA

UES PROJECT NO. 1740.1900083.0000

UES REPORT NO. 1734802

REPORT DATE: DECEMBER 24, 2019

PREPARED FOR:

MR. GILES YOKEL

Prime AE Group 1700 West Main Street

Pensacola, Florida 32502

PREPARED BY:

UNIVERSAL ENGINEERING SCIENCES, INC.

5561 FLORIDA MINING BOULEVARD

JACKSONVILLE, FLORIDA 32257

(904) 296-0757

COA #00000549

CONDUCTED AND PREPARED BY:

JAMES E. BLYTHE, CIAQP ROB SPORT, CIAQP

SENIOR PROJECT MANAGER EPA CERTIFIED LEAD RISK ASSESSOR (LBP-R-6414-2)

Consultants in: Geotechnical Engineering • Environmental Sciences • Construction Materials Testing • Threshold Inspection Offices in: Orlando • Daytona Beach • Fort Myers • Gainesville • Jacksonville • Ocala • Palm Coast • Rockledge • Sarasota • Miami

St. Augustine • Panama City • Fort Pierce • Leesburg • Tampa • West Palm Beach • Atlanta, GA

UNIVERSAL

ENGINEERING SCIENCES

TABLE OF CONTENTS

PAGE

1.0 INTRODUCTION

1.1 GENERAL

1.2 PURPOSE AND SCOPE

1.3 INSPECTION PROCEDURES

2.0 X-Ray FluorescencE (XRF) TESTING

2.1 XRF SPECIFICATION AND TESTING PROTOCOL

2.2 XRF CALIBRATIONS

2.3 XRF OPERATIONS

3.0 FINDINGS

3.1 “Positive” XRF Readings

3.2 “Negative” XRF Readings IN THE RANGE OF 0.1 mg/cm2 TO 0.9 mg/cm2

4.0 LABORATORY ANALYSIS (PAINT CHIP SAMPLES)

5.0 SUMMARY

6.0 REGULATORY INFORMATION

7.0 CONTROLLING AGENCIES

8.0 CONDITIONS AND LIMITATIONS

LIST OF APPENDICES

APPENDIX A

XRF FIELD FORMS .................................................................................................... A

APPENDIX B

LEAD SITE PLAN ........................................................................................................ B

APPENDIX C

UES CERTIFICATIONS ............................................................................................... C

Buildings 2977 & 2978 Project No. 1740.1900083.0000 Lead Based Paint Survey – NAS Whiting Field Report No. 1734802

1.0 INTRODUCTION

In this report, Universal Engineering Sciences, Inc. (UES) presents the results of the lead based paint (LBP) and lead coatings evaluation performed on December 9, 2019 of the interior and exterior of Buildings 2977 and 2978 located at NAS Whiting Field in Milton, Florida. Building 2977 was approximately 28,068 square feet and Building 2978 was approximately 2,388 square feet in size. This service was conducted according to proposal 1740.1019.00008, dated October 24, 2019.

1.1 GENERAL

Lead Based Paint (LBP), as defined by the United States Department of Housing and Urban Development (HUD), is dried paint film with a lead concentration equal to or greater than 1.0 mg/cm2 (milligrams of lead per square centimeter) when measured by a portable X-Ray Fluorescence (XRF) Lead Paint Analyzer, or a lead concentration equal to or greater than 5,000 parts per million (ppm) or equal to or greater than 0.5 percent by weight when analyzed by an American Industrial Hygiene Association (AIHA) laboratory participating in the Environmental Lead Laboratory Accreditation Program (ELLAP).

1.2 PURPOSE AND SCOPE

The purpose of this study was to perform an evaluation of the renovation areas of the above referenced structures for the presence of LBP or any lead containing coatings. The activities and procedures used to accomplish this task are as follows:

1. Review available information concerning the structures including the initial dates of construction, significant renovations, types of construction, and information regarding the use of the structures.

2. Walk-through and observe accessible areas within the renovation areas of the structures to identify, locate, and assess suspect LBP.

3. Measure suspect LBP with a portable XRF Lead Paint Analyzer on all combinations of assessable painted, glazed, shellacked, and/or stained components.

4. Due to the size, shape and/or location of some components, XRF readings of these component coatings may not be possible. Typically, collections of paint chip samples from these component coatings are obtained. Analysis of any collected paint chip samples are performed by an AIHA/ELLAP accredited laboratory using Flame Atomic Absorption (FAA) Environmental Protection Agency (EPA) method SW-846, 3rd edition, 7420 for the presence of lead. However, all of the assessable component coatings were able to be tested by the portable XRF Lead Paint Analyzer. Therefore, no laboratory testing was conducted during this LBP evaluation.

5. Prepare and submit a report of our findings.

Complete destructive observation and sampling procedures were not generally used during our evaluation of the renovation areas of the structures. Inaccessible areas within the renovation areas of the structures, such as inside partitions, inside crawl-spaces, inside other sealed areas and behind architectural details are beyond the scope of this study. The scope of our investigation did not include an evaluation of components on the roof, fixtures, equipment, or stored materials.

1.3 INSPECTION PROCEDURES

The lead evaluation was performed on December 9, 2019 by UES’s inspector, Mr. James Blythe. A portable Radiation Monitoring Devices, Inc. (RMD) LPA-1A XRF analyzer was used to analyze designated building components for the presence of lead. Mr. Blythe is certified by RMD to operate the LPA-1A Analyzer. The UES manufacturer certification is presented in Appendix B.

2.0 X-RAY FLUORESCENCE (XRF) TESTING

2.1 XRF SPECIFICATION AND TESTING PROTOCOL

The RMD LPA-1B XRF Analyzer method of measurement is based on spectrometric analysis of lead K-shell XRF within a controlled depth of interrogation. K-shell measurements of lead in paint are the EPA/HUD’s preferred method of XRF measurement. The K-Shell line (the higher energy emission) is normally used for paint analysis because it measures lead in all layers of paint films, including those layers nearest the substrate where higher lead levels are often found. K-shell X-rays can penetrate multiple layers of paint and/or various other coatings without being affected by the thickness and composition of the layers. The RMD LPA-1 XRF Analyzer uses a controlled depth concept which restricts the penetration of the energetic K-shell X-rays into the substrate so that the analyzer will not locate objects deep in a wall or component such as lead pipes. The RMD LPA- 1 XRF Analyzer distinguishes the lead X-ray from interfering X-ray radiation from other metals. The RMD LPA-1 XRF Analyzer calculates and then displays the specific lead content as milligrams per square centimeter (mg/cm2) of surface area.

The portable RMD LPA-1 XRF Analyzer was operated in general accordance with the manufacturer's specifications. The testing of the selected areas was performed in general conformance with the United States Department of Housing and Urban Development Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, (HUD Guidelines) dated June 1995. The sampling was limited to the components expected to be disturbed by any planned renovation and/or demolition.

2.2 XRF CALIBRATIONS

The EPA/HUD protocol requires calibration checks on the portable XRF analyzer. The calibration checks are performed at the beginning of the inspection, and/or every four hours, and at the conclusion of the inspection. Calibration checks were performed in order to determine if the instrument was operating properly. Three calibration test measurements lasting a minimum of 32 seconds per measurement are collected on a selected National Institute of Standards and Technology (NIST) lead standard. The average of the three readings are recorded and compared to the known value of the standard provided by the manufacturer. All calibration checks for the portable RMD LPA-1A XRF Analyzer (Serial No. 1972) were within the manufacturer's parameters.

Refer to Appendix A for calibration documentation.

2.3 XRF OPERATIONS

The portable RMD LPA-1A XRF Analyzer was operated utilizing the "Quick Mode" (95% confidence) sampling mode with an "action" level of 1.0 mg/cm2 as described in the EPA/HUD Guidelines.

Each XRF result (K-Shell reading) was categorized as negative or positive. XRF readings equal to or greater than 1.0 mg/cm2 are classified as positive. XRF readings less than 1.0 mg/cm2 are classified as negative as described in the EPA/HUD Guidelines.

3.0 FINDINGS

A total of twenty-eight (28) XRF readings, including calibrations, were performed. Refer to the XRF field forms in Appendix A for information pertaining to the locations of the XRF readings.

3.1 “POSITIVE” XRF READINGS

Two of the XRF readings of component coatings, from the structures, tested had XRF readings equal to or greater than the “positive” classification of 1.0 mg/cm2. A summary of the XRF readings are presented in Appendix A. Table 1 presents “positive” XRF readings.

Table 1 “Positive” XRF Readings Equal to or Greater than 1.0 mg/cm2

Reading No.

Room Name/Location Substrate Color Component Results

(mg/cm2)

20 Bldg 2977 - Mech Rm Metal Yellow Gas Line/Pipe 1.0

21 Bldg 2978 – Exterior Door Metal Tan Door 1.0

3.2 “NEGATIVE” XRF READINGS IN THE RANGE OF 0.1 MG/CM2 TO 0.9 MG/CM2

A total of two (2) component coatings tested had XRF readings in the “negative” range of 0.1 mg/cm2 to 0.9 mg/cm2, which is below the HUD “positive” standard of 1.0 mg/cm2. A summary of this XRF readings are presented in Appendix A. Should these color/components be disturbed, they are subject to regulation by OSHA.

All other component coatings had XRF readings below the portable XRF detection limit for lead.

4.0 LABORATORY ANALYSIS (PAINT CHIP SAMPLES)

Every assessable component coating was able to be tested by the portable XRF Lead Paint Analyzer. Therefore, no laboratory testing was conducted during this survey.

5.0 SUMMARY

Inspection of the structures indicated that two of the component coatings tested had XRF readings equal to or greater than the “positive” classification of 1.0 mg/cm2. Two (2) of the component coatings tested had a XRF readings in the “negative“ range of 0.1 mg/cm2 to 0.9 mg/cm2. The remainder of the component coatings had XRF readings below the portable XRF detection limit for lead.

6.0 REGULATORY INFORMATION

LBP activities are governed by various regulations and guidelines. The regulations and guidelines are focused on the protection of building occupants, protection of the environment, disposal procedures, and worker protection.

The disturbance of LBP coatings is regulated by the Occupational Safety and Health Administration (OSHA), which has noted that the HUD LBP definition may not be applicable to regulations. The OSHA regulation does not define lead content of the coating, but instead, regulates the disturbance of the materials with any lead content.

The demolition of buildings is regulated under the National Emissions Standards for Hazardous Air Pollutants (NESHAP) statue for general dust control. Specifications for the proper work practices, controls and disposal should be developed to document compliance with all applicable regulations.

Specifications for the proper work practices, controls and disposal should be developed to document compliance with all applicable regulations. Those components/colors not tested, or in locations not inventoried in this report, should be tested for lead content prior to any disturbance (repair, renovation, abatement, or demolition) that may cause airborne release of lead. Components/colors that may be identified to contain the presence of lead should not be disturbed in any uncontrolled manner, such as during repair, renovation or demolition. Any disturbance of these materials should only be done by properly trained personnel in a controlled and documented manner.

The disposal of commercial waste materials containing lead from renovation, abatement, and/or demolition is regulated by the Resource Conservation and Recovery Act (RCRA). RCRA requires a waste toxicity characteristic on the waste by using Toxicity Characteristic (TC) Leaching Procedure (TCLP) (40 CFR 261.24). The TCLP extract is analyzed for lead (or other constituents) to determine if it is above or below the allowable TC regulatory threshold, which for lead is 5 parts per million (ppm) (milligrams/liter).

The Florida Department of Environmental Protection (FDEP) issued Memorandum # SWM-

21.36 on February 13, 2002 regarding Management of Lead-Based Paint Debris. This FDEP memo states the following:

This memo is intended to give counties guidance on the management of lead-based paint (LBP) debris. LBP debris includes lead-based paint building components plus chips, dust, contaminated soils and sludges generated from lead abatement projects.

The EPA’s Office of Solid Waste issued a memo on July 31, 2000 clarifying that LBP debris from residences, whether generated by the homeowner or by contractors, is considered “household waste” and is thus exempt from regulation as hazardous waste under the Resource Conservation and Recovery Act (RCRA). As such, this material can be disposed of as household waste in a Municipal Solid Waste (MSW) landfill or Waste-to- Energy facility, and is exempt from hazardous waste testing requirements. This memo also includes several suggested for the proper handling and disposal of LBP debris.

The Department believes that designing a system that expedites the LBP debris remediation in a cost effective matter, removes the exposure risk that LBP poses to human health, and gets this material into a proper and regulated management system that is protective of the environment is a sound approach that offers more protection and less process. The Department concurs with the EPA’s interpretation that LBP debris from a residence (including single family homes, apartment buildings, public housing, and military barracks) is “household waste” and is thus not subject to hazardous waste regulations. LBP debris generated from a commercial or industrial source is not entitled to this same exemption.

It is the Department’s experience that demolition debris which includes wood, concrete, or metal painted with lead based paint will generally not fail a Toxicity Characteristic Leaching Procedure (TCLP) test and so will not be regulated as a hazardous waste.

Because of this, the Department will not expect generators of large pieces of LBP debris to characterize the waste stream through testing prior to disposal. Large sized pieces created from demolition jobs should be stored in containers, preferably covered, until ready for disposal in a Class I or III landfill or a C&D disposal facility, provided that the owner or operator is willing to accept them. All demolition contractors and others dealing with LBP debris should check with the facility owner where they intend to dispose of this material.

Generators of chips, dust, contaminated soils and sludges from commercial or industrial sources which may be contaminated with LBP continue to be responsible for the proper characterization of the waste stream prior to disposal. Such materials generated from renovation or remodeling jobs that can be vacuumed, swept up, or otherwise easily collected should be subjected to the TCLP test. If the materials are determined to be hazardous, they must be managed accordingly. If they are not hazardous, the materials should be placed into plastic bags or similar containers and taken to a class I landfill for proper disposal.

Dust, paint chips and other small LBP materials from households are not regulated as hazardous waste. Because this material can be “hazardous in nature” even though it may not be regulated as a hazardous waste, the Department does not consider it to be construction and demolition debris, and thus it cannot be disposed of at a Class III landfill or C&D disposal facility. These materials should be placed into plastic bags or similar containers and taken to a Class I landfill for disposal.

This memo addresses only the disposal aspects of LBP debris. The reader should be aware that other aspects of LBP abatement and management may be regulated by other entities. For example, EPA and HUD have issued health and safety management practices for the handling of this material, which recommend the use of gloves, dust masks, respirators when appropriate, and other Personal Protection Equipment.

Therefore, it has been our past experience that the FDEP and OSHA allows components with lead containing coatings to remain in-place during general demolition provided that wet techniques and/or other engineering controls are employed during the process. Further, components that have lead containing coatings and debris mixed with lead containing coatings cannot be recycled and must be disposed in an appropriate landfill. With respect to lead related tasks such as any manual demolition of structures, manual scraping, manual sanding, heat gun applications, and power tool cleaning with dust collection systems, OSHA requires employee protective measures until the employer performs an employee exposure assessment and documents that the employee performing any of the lead related tasks is not exposed above the Permissible Exposure Limit (PEL) of 50 micrograms of lead per cubic meter of air (µg/m3) averaged over an 8-hour period. UES recommends employee exposure monitoring during any lead related tasks.

The EPA regulations are as follows:

Residential Lead Based Paint Hazard Reduction Act of 1992, Public Law 102-550: Title X of the Housing & Community Development Act of 1992

Deals with training requirements for managing and procedures for evaluating the risks of identified lead based paint.

40 CFR 745 - Subpart L - Lead-Based Paint Activities

Includes a "Model Accreditation Plan" outlining the training and certification program applicable to personnel performing lead-based paint activities.

40 CFR 745 - Subpart F - Disclosure of Known Lead-Based Paint and/or Lead-Based Paint Hazards Upon Sale or Lease of Residential Property

Requires disclosure and an allowance for gathering of information concerning the presence or potential of lead-based paint hazards during a residential property sale.

Resource Conservation & Recovery Act (RCRA)

Deals with the waste and disposal requirements associated with lead based paint materials.

The OSHA regulations are as follows:

29 CFR 1926.62, Lead Exposure in Construction: Interim Final Rule

Deals with the potential exposure to lead based paint materials to which construction workers may be subjected.

29 CFR 1910.134: Use of Respirators

The OSHA Respiratory Protection Rule defines the program and requirements as to when personnel are allowed to wear respirators, maintenance of respirators, etc.

In general, OSHA coverage extends to all private sector employer and employees. Those not covered under the standard typically include self-employed persons and federal, state and local municipal employees.

The Office of Public & Indian Housing, Department of Housing & Urban Development Regulation are as follows:

Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (1995)

Deals with requirements for testing and managing the potential for lead based paint exposure in public housing, primarily focused to the safety of children.

24 CFR 35 - Subpart H - Disclosure of Known Lead-Based Paint and/or Lead-Based Paint Hazards Upon Sale or Lease of Residential Property

Requires disclosure and an allowance for gathering of information concerning the presence or potential of lead-based paint hazards during a residential property sale.

7.0 CONTROLLING AGENCIES

The Controlling Agency for the coordination of projects involving NESHAP renovation and demolition regulations for Santa Rosa County is the DEP Northwest District Office located at 160 W. Government Street, Suite 308 in Pensacola, Florida. The telephone number is (850) 595- 0616.

The Federal controlling agency is EPA Region 4, Sam Nunn Atlanta Federal Building, 61 Forsyth Street, Atlanta, Georgia 30303, (404) 347-4727.

8.0 CONDITIONS AND LIMITATIONS

A representative of Universal Engineering Sciences, Inc. performed the lead evaluation on December 9, 2019. This evaluation is applicable for the time that the inspection was conducted.

UES offers no warranty, express or implied. Component surface coatings that were not identified during the evaluation by the UES’s inspector should be tested for lead before any disturbance to the components (such as repair, renovation, or demolition). The disturbance of these component coatings may be regulated by OSHA. Inaccessible areas within the structures, such as inside partitions, inside crawl-spaces, inside other sealed areas and behind architectural details are beyond the scope of this study. The scope of our investigation did not include an evaluation of components on the roof, fixtures, equipment or stored materials. This report is not intended for compliance with the Environmental Protection Agency (EPA) 40 Code of Federal Regulations (CFR) part 745.

Appendix A XRF Field Forms

Universal Engineering Sciences, Inc, 5561 Florida Mining Boulevard, Jacksonville, Florida (904) 296-0757 Fax: (904)-296-0748

XRF LEAD-BASED PAINT INSPECTION FORM

Unit # XRF Report No. 1734800 Building Name Buildings 2977 & 2978 Page: 1 of 2

Client Prime AE Group Project Number 1740.1900083.0000 Date 12/9/19

Project Name NAS Whiting Field Project Location Milton, Florida XRF Serial No. RMD – 1972

Notes/Comments: Inspector Name Jim Blythe Signature JEB

Reading

Number

Room

Number/Name Substrate Color Paint

Condition Component Test Location

Left,Right,Center – Top,Middle,Bottom

XRF

Reading Units

Classification

(Pos,Neg)

1 Equipment Test Test Block -- -- -- -- 1.0 mg/cm2 Test OK

2 2977- Hall CB Tan I Wall Right, Middle -0.1 mg/cm2 Negative

3 2977 –Hall CB White I Wall Left, Middle -0.0 mg/cm2 Negative

4 2977 –Hall CB Red I Wall Center, Middle -0.1 mg/cm2 Negative

5 2977 – Rm 24 Metal Brown I Door Frame Right, Middle -0.2 mg/cm2 Negative

6 2977 – Rm 25 Drywall White I Wall Right, Middle -0.3 mg/cm2 Negative

7 2977 – Rm 26 Drywall White I Wall Right, Middle -0.1 mg/cm2 Negative

8 2977 – Rm 26 Metal Brown I Door Frame Right. Middle -0.1 mg/cm2 Negative

9 2977 –S Hall CB Blue I Wall RIght, Middle -0.2 mg/cm2 Negative

10 2977 - S Hall Cb White I Wall Left, Middle -0.2 mg/cm2 Negative

11 2977 – S Hall CB Red I Wall Right, Bottom -0.1 mg/cm2 Negative

12 2977 – Rm 41 Drywall White I Wall Right. Top -0.1 mg/cm2 Negative

13 2977 – Rm 41 Drywall Gray I Wall Right, Bottom -0.4 mg/cm2 Negative

14 2977 – Rm 43 Drywall Blue I Wall Right, Bottom -0.1 mg/cm2 Negative

15 2977 – Rm 47 Drywall Gray I Wall Left, Middle -0.1 mg/cm2 Negative

16 2977 – E Hall CB Blue I Wall Right, Top -0.4 mg/cm2 Negative

17 2977 – E Entry CB White I Wall Left, Middle 0.2 mg/cm2 Negative

18 2977 – Rm 9 Drywall White I Wall Right, Bottom 0.1 mg/cm2 Negative

19 2977 – Rm 18 Metal Brown I Door Frame Right, Middle -0.2 mg/cm2 Negative

20 2977 – Mech Rm Metal Yellow I Gas Line/Pipe Center, Middle 1.0 mg/cm2 Positive

I = Intact F = Fair, P = Poor

Universal Engineering Sciences, Inc, 5561 Florida Mining Boulevard, Jacksonville, Florida (904) 296-0757 Fax: (904)-296-0748

XRF LEAD-BASED PAINT INSPECTION FORM

Unit # XRF Report No. 1734800 Building Name Buildings 2977 & 2978 Page: 2 of 2

Client Prime AE Group Project Number 1740.1900083.0000 Date 12/9/19

Project Name NAS Whiting Field Project Location Milton, Florida XRF Serial No. RMD – 1972

Notes/Comments: Inspector Name Jim Blythe Signature JEB

Reading

Number

Room

Number/Name Substrate Color Paint

Condition Component Test Location

Left,Right,Center – Top,Middle,Bottom

XRF

Reading Units

Classification

(Pos,Neg)

21 2978 - Exterior Metal Tan I Door Center, Middle 1.0 mg/cm2 Positive

22 2978 Metal Tan I Door Frame Right, Middle 0.0 mg/cm2 Negative

23 2978 –Rm 4 CB White I Wall Left, Middle -0.3 mg/cm2 Negative

24 2978 – Rm 4 Metal Tan I Door Frame Right, Middle -0.1 mg/cm2 Negative

25 2978 – Rm 2 CB White I Wall Right, Bottom 0.0 mg/cm2 Negative

26 2978 – Rm 8 CB White I Wall Left, Middle -0.2 mg/cm2 Negative

27 2978 – Rm 8 M Tan I Door Center, Middle -0.2 mg/cm2 Negative

28 Equipment Test Test Block -- -- -- -- 1.0 mg/cm2 Test OK

I = Intact F = Fair, P = Poor

Appendix B Lead Site Plan

SITE LOCATION PLAN

BUILDINGS 2977 and 2978

Site Location Plan Whiting Field NAS

Santa Rosa County, FL

FOR :

PRIME AE Group, Inc.

DRAWN BY : JB DATE : 12/20/19

CHECKED BY : JB DATE : 12/20/19

AERIAL PHOTOGRAPH (2018)

SCALE : Not To Scale FIGURE: 1

PROJ NO : 1740.1900083.0000

SITE

Appendix C UES Certifications