Regulated Material Investigation Lead Base Paint Sampling. KVAL Broadcasting Eugene, Oregon. April 30, 2018

Transcription

1 Regulated Material Investigation Lead Base Paint Sampling KVAL Broadcasting Eugene, Oregon April 30, 2018 By: Douglas International LLC Douglas J. Moore 1

2 DOUGLAS INTERNATIONAL PO Box 1524 Veneta, Oregon (541) (541) fax KVAL May 03, Blanton Rd. Eugene, Oregon Attn: Ben Wong Chief Engineer Re: Pre demolition and proposed remodel lead paint survey at 4575 Blanton Rd. Eugene, Oregon Mr. Wong, Thanks for the opportunity to assist with your groups potential property developments. On April 30, 2018 at your request paint samples (thirteen) from selected ceilings / walls, and various other building components that may be impacted during the described remodel project at identified location were collected and submitted to an accredited lab for analysis for Lead content. The results from the lab indicate that none of the samples collected during this investigation were above and the current regulated limit of 5000 ppm. Occupational Safety & Health Administration: - Both Federal OSHA and Oregon OSHA acknowledge the Lead in Construction Standard, 29 CFR which is invoked if any Lead is present in materials sampled. This assessment was limited to the described areas of this structure. It did not encompass any material investigation of any of the other areas in the building, structures or their components. It is therefore by all means not to be considered or assumed to be a full facility survey. Locations of the various samples collected, photos of the materials and laboratory analysis / results are included in this report. 2

3 Lead Definitions: Typical Laboratory Analysis Reporting Limit: 10.0 ug Environmental Protection Agency (EPA): - Lead Base Paint contains 0.5% lead by weight / 500 parts per million per Federal statute. Consumer Product Safety Commission: - Lead-free paint is defined as < 0.06% by weight. Oregon State Department of Health: - Follows / EPA RRP Standard (0.05% by weight) invokes requirement for accredited training and abatement practices in any environment that meets the Target Housing definition. EPA, DEQ, and OR-OSHA define asbestos containing materials as containing greater than 1% asbestos by weight. If you or any of your staff have any questions about this investigation, please feel free to call me at the numbers below: (541) phone (541) fax (541) mobile drdintl@hotmail.com Respectfully, Douglas J. Moore Sole Proprietor, Douglas International LLC Superintendent, Pacific Environmental Group Inc. 3

4 Lab Results 4

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12 Sample Locations Exterior NW corner Exterior West center 12

13 Exterior South side Interior NW corner 13

14 Interior North side center Interior floor / center walkway 14

15 Interior floor NW corner (yellow) Interior floor NW corner (black) 15

16 Interior floor NW corner (red) Interior North center 16

17 Interior darkroom door Interior SW corner 17

18 Interior floor green room 18

19 DOUGLAS INTERNATIONAL PO Box 1524 Veneta, Oregon (541) (541) fax Douglas International contracts labs that provide accredited testing of metals in dust wipes, paint chips, soil, bulk and air samples by Inductively Coupled Plasma Optical Emission Spectroscopy (ICP- OES). The methodology utilized offers total concentration of lead as well as of a variety of metals, TCLP for lead, and TCLP for RCRA 8 metals. The labs are all participants in the Environmental Lead Proficiency Analytical Testing program and provide services with consistently fast turn-around times and accurate results. All chemistry departments have the following instrumentation and capabilities to meet metals testing and analyses needs: ICP-OES Microwave and hot-block digestion Mercury Analyzer 19

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22 Governing Rules and Regulations United Sates Department of Labor (Federal OSHA) General Industry (29 CFR 1910) 1910 Subpart I, Personal protective equipment o , Respiratory protection 1910 Subpart Z, Toxic and hazardous substances o , Access to employee exposure and medical records o , Lead Appendix A, Substance data sheet for occupational exposure to lead Appendix B, Employee standard summary Appendix C, Medical surveillance guidelines Shipyard Employment (29 CFR 1915) 1915 Subpart Z, Toxic and hazardous substances o , Lead. Requirements applicable to shipyard employment under this section are identical to those set forth in 29 CFR Part Number: 1926 Part Title: Safety and Health Regulations for Construction Subpart: D Subpart Title: Occupational Health and Environmental Controls Standard Number: Title: Lead Appendix: A, B, C, D Environmental Protection Agency Residential Lead-Based Paint Hazard Reduction Act of Title X Public Law nd Congress -- 2nd Session [H.R. 5334] 102 P.L. 550; 106 Stat Enacted H.R. 5334; 102 Enacted H.R DATE: OCT. 28, PUBLIC LAW SEC SHORT TITLE. This title may be cited as the "Residential Lead-Based Paint Hazard Reduction Act of 1992." 22

23 EPA Lead; Renovation, Repair, and Painting Program (79 pp) [Federal Register: April 22, 2008 (Volume 73, Number 78)] [Rules and Regulations] [Page ] From the Federal Register Online via GPO Access [wais.access.gpo.gov] [DOCID:fr22ap08-11] [[Page 21692]] ENVIRONMENTAL PROTECTION AGENCY 40 CFR Part 745 [EPA-HQ-OPPT ; FRL ] RIN 2070-AC83 Lead; Renovation, Repair, and Painting Program AGENCY: Environmental Protection Agency (EPA). ACTION: Final rule. HAVING WORK DONE ON YOUR PLACE? USE A LEAD-SAFE CERTIFIED CONTRACTOR. The Danger Lead paint hazards have not gone away. If your home or apartment was built before 1978, unqualified workers could spread lead paint dust. Even doing a small job. Kids: Lead exposure can cause lower intelligence, behavior problems and learning disabilities. Pregnant women: Lead paint dust can be harmful to your developing fetus. All adults: Exposure to lead paint dust can cause nervous system effects, high blood pressure, fertility problems, and kidney effects. The Renovation, Repair and Painting Rule The EPA is requiring that contractors be Lead-Safe Certified. Contractors include: renovators, electricians, HVAC specialists, plumbers, painters and maintenance staff who disrupt more than six square feet of lead paint. This rule covers schools, day care centers, or any buildings where children gather. 23

24 The Solution Protect your family and loved ones. Make sure to hire a contractor who is Lead-Safe Certified. It may cost just a little more but you ll get the job done right. EPA s 2008 Lead-Based Paint Renovation, Repair and Painting (RRP) Rule (as amended in 2010 and 2011), aims to protect the public from lead-based paint hazards associated with renovation, repair and painting activities. These activities can create hazardous lead dust when surfaces with lead paint, even from many decades ago, are disturbed. The rule requires workers to be certified and trained in the use of lead-safe work practices, and requires renovation, repair, and painting firms to be EPA-certified. These requirements became fully effective April 22, Child-occupied facility means a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years of age, on at least two different days within any week (Sunday through Saturday period), provided that each day's visit lasts at least 3 hours and the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours. Child-occupied facilities may include, but are not limited to, day care centers, preschools and kindergarten classrooms. Child-occupied facilities may be located in target housing or in public or commercial buildings. With respect to common areas in public or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only those common areas that are routinely used by children under age 6, such as restrooms and cafeterias. Common areas that children under age 6 only pass through, such as hallways, stairways, and garages are not included. In addition, with respect to exteriors of public or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only the exterior sides of the building that are immediately adjacent to the child-occupied facility or the common areas routinely used by children under age 6. Renovation means the modification of any existing structure, or portion thereof, that results in the disturbance of painted surfaces, unless that activity is performed as part of an abatement as defined by this part (40 CFR ). The term renovation includes (but is not limited to): The removal, modification or repair of painted surfaces or painted components (e.g., modification of painted doors, surface restoration, window repair, surface preparation activity (such as sanding, scraping, or other such activities that may generate paint dust)); 24

25 The removal of building components (e.g., walls, ceilings, plumbing, windows); weatherization projects (e.g., cutting holes in painted surfaces to install blown-in insulation or to gain access to attics, planning thresholds to install weatherstripping), and interim controls that disturb painted surfaces. A renovation performed for the purpose of converting a building, or part of a building, into target housing or a child-occupied facility is a renovation under this subpart. The term renovation does not include minor repair and maintenance activities. Minor repair and maintenance activities are activities, including minor heating, ventilation or air conditioning work, electrical work, and plumbing, that disrupt 6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities where none of the work practices prohibited or restricted by (a)(3) are used and where the work does not involve window replacement or demolition of painted surface areas. When removing painted components, or portions of painted components, the entire surface area removed is the amount of painted surface disturbed. Jobs, other than emergency renovations, performed in the same room within the same 30 days must be considered the same job for the purpose of determining whether the job is a minor repair and maintenance activity. Oregon State Oregon State Department of Health Oregon Administrative Rules RRP (OAR ) and Lead-Based Paint Activities ( ) OR OSHA Oregon Administrative Rules Oregon Occupational Safety and Health Division Lead... D-139 Appendix A to Substance Data Sheet for Occupational Exposure to Lead... D-165 Appendix B to Employee Standard Summary... D-171 Appendix C to Medical Surveillance Guidelines... D

26 Oregon Department of Environmental Quality DEQ OAR 300 thru 340 all Divisions Oregon Lead Abatement Lead poisoning from old paint causes a variety of health problems, especially in children. According to the Oregon Lead Poisoning Prevention Program, lead poisoning causes lowered IQ and behavioral disorders. Houses built before 1978 often have lead paint. Oregon has abatement rules that limit lead exposures in the state. Prohibited Activities 1. The state of Oregon lead abatement rules prohibit workers from torching, hydroblasting or using uncontained power washers on surfaces with lead paint. Machine sanding, sandblasting, grinding or abrasive blasting is illegal on lead-based paint unless the machine has a high efficiency particulate air exhaust control that can remove at least percent of particles 0.3 microns or larger from the air. Certification 2. Before a person in Oregon can perform lead abatement, she must get a certification from the Department of Human Services Lead Based Paint Program and a license from the Construction Contractors Board. Firms must get a certification from the Lead Based Paint Program and a license with a lead endorsement from the Construction Contractors Board. The DHS certification includes a training course, an application and an exam. People can only take the certification examination up to three times in six months. Renewals 3. Lead abatement certifications and permits require annual renewals, according to Oregon lead abatement rules. 26

27 Abatement Notice 4. Before a person or firm begins a lead abatement project in Oregon, the Oregon Department of Human Services requires a filled-out copy of its Lead-Based Paint Notice of Abatement at least seven days before the project starts. Contractors must submit any changes in abatement notices, including changes in project end dates, at least 24 hours before starting an abatement project. Testing 5. Before abatement or construction activities take place in child-occupied facilities or target housing, each individual section of paint should have a lead test if the area was painted before In multi-family dwellings, paint in common areas should have lead tests, unless the paint is from after 1978 or has already tested negative for lead. Paint test inspection records should include information regarding the date of the test, the date of building construction, the address of the building, the names and contact information for the building owners, the names and contact information for the inspectors and the testing methods and locations. Soil Testing 6. Soil in kids' play areas and bare yard soil should be tested for lead. Read more: Oregon Lead Abatement Rules ehow.com 27

28 LIMITATIONS AND DECLARATIONS Professional services of Douglas International LLC have been performed using the degree of care and skill ordinarily exercised under similar circumstances by reputable environmental research and consulting firms practicing in this or similar localities. No other warranty expressed or implied is made as to the professional advice included in this report. The findings of this investigation should not be considered as scientific certainties but rather as professional opinion based on selected and limited data. This evaluation did not address any structural condition of the building. Completion of this environmental assessment and issuance of a final report does not compel Douglas International LLC to provide testimony or attend any legal proceedings without separate arrangements. Absolutely no portion of this report shall be disseminated to the public or published in any way without prior written consent of Douglas international LLC. 28