DPS CORP. April 14, 2011

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1 DPS CORP. April 14, 2011 Jeffrey A. Smith Lead Environmental Scientist South Florida Water Management District Infrastructure Systems Section, Dept Gun Club Road West Palm Beach, Florida RE: LEAD BASED PAINT COATINGS SURVEY REPORT Structure S-197 (Folio No.: ) US 1 at Canal C-111 Miami-Dade County, Florida DPS Project Number LBP1125 Mr. Smith: Diversified Professional Services Corp. (DPS) conducted a Lead Based Paint coating survey at the above referenced site on February 20, The purpose of this report is to present the findings of the survey. We understand that this survey was requested due to planned renovation of the structure. DPS appreciates the opportunity to provide this service to the District. If you have any questions regarding this report, please contact the undersigned at Sincerely, DIVERSIFIED PROFESSIONAL SERIVCES CORP. Donald R. Polanis, PSSC, CGC Environmental Specialist Johnston Road, Dade City, Florida * (352) * (352) fax

2 SFWMD District Structure S-197 April 2011 US 1at Canal C-111 Miami-Dade County, Florida DPS Project Number LBP1125 LEAD BASED PAINT SURVEY REPORT Structure S-197 US 1 and Canal C-111 Miami-Dade County, Florida DPS Project Number LBP1125 April 2011 Prepared for: South Florida Water Management District 3301 Gun Club Road West Palm Beach, Florida Prepared by: DPS Corp. Dade City, Florida

3 SFWMD District Structure S-197 April 2011 US 1at Canal C-111 Page 3 Miami-Dade County, Florida DPS Project Number LBP1125 TABLE OF CONTENTS Page No. 1.0 INTRODUCTION Project Objective STRUCTURE DESCRIPTION FIELD ACTIVITIES Sample Collection Sample Analysis REGULATORY OVERVIEW FINDINGS AND RECOMMENDATIONS GENERAL COMMENTS... 3 LIST OF APPENDICES Appendix A Appendix B Appendix C Sample location sketch Sample Photographs Laboratory Report

4 SFWMD District Structure S-197 April 2011 US 1at Canal C-111 Miami-Dade County, Florida DPS Project Number LBP1125 EXECUTIVE SUMMARY Structure S-197 Diversified Professional Services Corp. (DPS) conducted a Lead Based Paint (LBP) survey of water control structure S-197 at Canal C-111, located east of US Highway 1, in Miami-Dade County. The structure is identified as S-197 by the SFWMD. It is our understanding that the District is planning to renovate and or demolish the structure. The purpose of this survey was to identify and sample painted surfaces to determine if LBP was applied onto the materials scheduled for removal or modification and to provide information regarding the identity, location, condition of these materials so that proper remediation and disposal methods can be evaluated. The survey was conducted on March 20, 2011 by Don Polanis an environmental engineer with DPS Corp. Nine samples were collected from the structure at six homogeneous areas. Based on the results of the testing none of the samples exceed the USEPA threshold for LBP 0f 5,000 ppm. DPS recommends that the Contractor review the results and formulate a site specific health and safety plan (HASP) in accordance with federal, state and their company health and safety policies. Should the Contractor dispose of structures with painted surfaces testing and disposal of those materials should be conducted in accordance with the EPA definitions outlined herein. Should the Contractor recycle the structure no additional testing is required. All scrap metals (as defined in Title 40 Code of Federal Regulations (CFR), Part 261.1(c)(6) and (9)) that are generated during the demolition of the structure must be recycled by a permitted recycling company and are exempt from hazardous waste management standards.

5 SFWMD District Structure S-193 January 2011 US 1at Canal C-111 page 1 Miami-Dade County, Florida DPS Project Number ASB INTRODUCTION DPS, conducted a LBP survey of the water control structure over Canal C-111 located east of US Highway 1, in Miami-Dade County. The structure is identified as SFWMD Structure number S The survey was conducted on March 20, 2011 by an environmental engineer. 1.1 Project Objective We understand this LBP survey was requested due to the planned renovation and or demolition of the structure. The LBP study was completed to classify different painted surfaces prior to planned disturbances or demolition activities. 2.0 STRUCTURE DESCRIPTION The structure is an earthen dam with corrugated metal pipes to convey water through the earthen dam and vertical culverts located upgradiant with mechanical gates to control water flow. The water control structure functions by opening and closing the gates mounted to large galvanized steel culverts. Sheet piling and concrete headwalls are used on the upstream and downstream sides of the structure and native soil forms an earthen dam crossing the C-111 canal. Water is channeled through the earthen dam via large diameter galvanized culverts. 3.0 FIELD ACTIVITIES 3.1 Sample Collection Based on results of the visual observation, samples of various painted surfaces were collected placed into sealable containers and labeled with unique sample numbers using an indelible marker. Nine samples were obtained from the structure at locations identified on the attached sketch. 3.2 Sample Analysis All nine paint samples were submitted to PEL laboratories, a NELAC accredited lab, for analysis. A copy of the laboratory report is attached. 4.0 REGULATORY OVERVIEW Specific regulations regarding lead based paints have been developed by the United States Environmental Protection Agency (USEPA). Lead-based paint is defined as a surface coating or paint containing lead in excess of 1.0 milligram per square centimeter (mg/cm2) or 0.5% by weight (US EPA Toxic Substance Control Act, Section 401). 0.5% is equivalent to 5000 parts per million (ppm). Based on regulations contained in the Lead-Based Paint Poisoning Prevention Act (LBPPPA) and promulgated by the Consumer Product Safety Commission

6 SFWMD District Structure S-197 April 2011 US 1at Canal C-111 Page 3 Miami-Dade County, Florida DPS Project Number LBP1125 (CPSC), lead-based paint is defined as paint containing more than 0.06% lead as of June In 1978, the CPSC banned the sale of lead-based paint to consumers. Under EPA regulations lead impacted wastes generated during abatement activities are handled as either a solid waste or a hazardous waste, depending on the amount and form of each of the heavy metals. If the maximum level of the metal in an extract of a representative sample of the waste stream proposed for disposal, as determined by a Toxicity Characteristic Leaching Procedure (TCLP) laboratory analysis, is less than the regulatory level set in 40 CFR , then EPA regulations allow the material to be disposed of as solid waste at a solid waste landfill. If the TCLP analysis equals or exceeds the regulatory level, the material must be managed as a hazardous waste. The regulatory level for lead is 5.0 milligram per liter (mg/l). Impacted materials that are recycled, such as painted steel beams sent to a scrap metal yard, are not considered waste; therefore, they are exempt from waste disposal regulations, however other occupational and recycling regulations may apply. The Occupational Safety and Health Administration (OSHA) established the Lead Standard for the Construction Industry, 29 CFR , which applies to all construction work where an employee may be exposed to lead. These exposures include demolition and salvage of structures where lead or material containing lead are present and removal or encapsulation of materials containing lead, as well as alterations and repairs including painting and decorating. The standard defines the occupationally permissible exposure limit and specific requirements for construction work with and in lead materials. OSHA does not have a percentage lead in paint action level in their current construction lead standard. OSHA considers the lead regulation enforceable if the presence of any lead in paint at detectable concentrations is present when demolition or renovation activities are performed. Any abatement of the lead-based paint or cutting, sanding, and/or grinding of the structures painted with LBP should be performed in accordance with OSHA regulations. Demolition activities are 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. All scrap metals (as defined in Title 40 Code of Federal Regulations (CFR), Part 261.1(c)(6) and (9)) are exempt from being subject to hazardous waste management standards in accordance with 40 CFR 261.4(a) and 40 CFR 261.6(a)(3). 5.0 FINDINGS AND RECOMMENDATIONS Nine samples were collected from the structure at six homogeneous areas. Sample results ranged from not detected at Sample # 2 to 679 ppm at Sample #6. Based on the results of the testing none of the samples exceed the USEPA definition for LBP of 5,000 ppm.

7 SFWMD District Structure S-197 April 2011 US 1at Canal C-111 Page 3 Miami-Dade County, Florida DPS Project Number LBP1125 DPS recommends that the Contractor review the results and formulate a site specific health and safety plan (HASP) in accordance with federal, state and their company health and safety policies. Should the Contractor dispose of structures with painted surfaces testing and disposal of those materials should be conducted in accordance with the EPA definitions outlined herein. Should the Contractor recycle the structure no additional testing is required. All scrap metals (as defined in Title 40 Code of Federal Regulations (CFR), Part 261.1(c)(6) and (9)) that are generated during the demolition of the structure must be recycled by a permitted recycling company and are exempt from hazardous waste management standards. 6.0 GENERAL COMMENTS This survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our survey of the building. The information contained in this report is relevant to the date on which this survey was performed, and should not be relied upon to represent conditions at a later date. DPS does not warrant the work of regulatory agencies, laboratories or other third parties supplying information which may have been used in the preparation of this report. No warranty, express or implied is made.

8 APPENDIX A Sample Location Sketch

9

10 APPENDIX B Sample Photographs

11 View of sheet piling west side (Sample #1) View of sheet piling east side (Sample #2)

12 View of steel gate frame and gear box with black paint east side of structure (Sample #3) View of grey painted steel gate frame on east structure (Sample #4)

13 View of grey painted PVC gear protective cover (Sample #5) Grey Paint on gear box (Sample #6)

14 Black coating on large corrugated metal pipe West and Center (Samples #7 and 8) Black coating on large corrugated metal pipe East side, typical (Samples # 9)

15 APPENDIX C Laboratory Report

16 Florida Texas South Carolina North Dakota # E84207 # T # # R-178 California Louisiana Kansas Arkansas # 07253CA # # E # CERTIFICATE OF ANALYSIS - Report Date: 03/24/2011 To: Don Polanis DPS Corp Johnston Rd Dade City, FL Work FAX PROJECT ID: S-197 / LBP1125 WORK ORDER: DATE RECEIVED: Monday, March 21, 2011 Project Notes: ( ): Short Hold Time Analysis Date Samples reported on dry weight basis All test results in this report pertain only to the samples as submitted. PEL Contact: Mark Gudnason / extension: Benjamin Road, Suite A Tampa, Florida FAX: Website: 1 of 18

17 PEL a division of Spectrum Analytical, Inc. featuring Hanibal Technology DATA QUALIFIER CODES State of Florida, Department of Environmental Protection and Department of Health Rehabilitative Services / NELAC I J L Q U V Y The reported value is between the laboratory method detection limit and the laboratory practical quantitation limit. Estimated value; value not accurate. This code shall be used in the following instances: 1.Surrogate recovery limits have been exceeded. 2. No known quality control criteria exits for the component. 3.The reported value did not meet the established quality control criteria for either precision or accuracy but falls within the NELAC marginal exceedance range. 3M.The reported value did not meet the established quality control criteria for either precision or accuracy and falls beyond the NELAC range for marginal exceedances. 3R.The RPD for the LCSD exceeds the laboratory established control limits. 4.The sample matrix interfered with the ability to make an accurate determination. 5.The data is questionable because of improper laboratory or field protocols (e.g. composite sample was collected instead of a grab sample). Off-scale high. Actual value is known to be greater than the value given. To be used when the concentration of the analyte is above the acceptable limit for quantitation (exceeds the linear range of the highest calibration standard) and the calibration curve is known to exhibit a negative deflection. Sample held beyond acceptable holding time. This code shall be used if the value is derived from a sample that was prepared or analyzed after the approved holding time restrictions for the sample preparation or analysis. Indicates that the compound was analyzed for but not detected above the method detection limit (MDL). Indicates that the analyte was detected in both the sample and the associated method blank. Note: The value in the blank shall not be subtracted from associated samples. The laboratory analysis was from an unpreserved or improperly preserved sample. The data may not be accurate. RL - Reporing Limit. The PEL lowest Practical Quanititation Limit (PQL), defined by the lowest point in the calibration curve. 2 of 18

18 CASE NARRATIVE METALS PEL Lab Reference No./SDG: Client: DPS I. RECEIPT Exceptions encountered upon receipt are addressed in the Sample Receipt Confirmation Report, included with the Chain-of-Custody documentation, or communication included in the addendum with this package. II. HOLDING TIMES III. METHOD A. Sample Preparation: All holding times were met. B. Sample Analysis: All holding times were met. Analyses were performed according to the PEL, a Division of Spectrum Analytical, Standard Operating Procedures and EPA Method 6010B for ICP metals. IV. PREPARATION Soil samples were prepared according to PEL Laboratory's Standard Operating Procedures and EPA Method 3050B. V. ANALYSIS A. Calibration: All acceptance criteria were met. B. Blanks: C. Spikes: 1. Calibration Blanks: All acceptance criteria were met. 2. Method Blanks: All acceptance criteria were met. 1. Laboratory Control Spikes (LCS): An LCS/LCSD set was analyzed. All percent recovery and relative percent difference (RPD) criteria were met. 2. Post Digestion Spike: All acceptance criteria were met. 3 of 18

19 CASE NARRATIVE METALS PEL Lab Reference No./SDG: Client: DPS 3. Matrix Spike/Matrix Spike Duplicate Samples (MS/SD): No spikes requested by client. D. Duplicate: No sample duplicates are reported with this method. (Spike duplicates are referenced above in section C. Spikes.) E. Serial Dilution: All acceptance criteria were met. F. ICP Interference Check Samples: All acceptance criteria were met. G. Samples: Sample analysis proceeded normally. Sample Gr Paint on Valve required a 5X dilution due to high concentration of the following analyte(s): Lead. I certify that this data package is in compliance with the terms and conditions agreed to by the client and PEL, both technically and for completeness, except for the conditions noted above. Release of the data contained in this hardcopy data package has been authorized by the Laboratory Manager or designated person, as, verified by the following signature SIGNED: DATE: 03/24/ of 18

20 - CERTIFICATE OF ANALYSIS - FLDOH #E84207 To: Don Polanis DPS Corp WORK ORDER: PROJECT ID: S-197 / LBP1125 PEL Lab# : Client ID : Matrix : Sheet Pile-East End S Collection Information: Sample Date: 2/20/2011 5:00:00 PM Analysis Prep Parameter Method Results Date Date Units MDL RL Lead /24/2011 9:04 03/23/ :00 MG/KG Dilution Factor 5 of 18

21 - CERTIFICATE OF ANALYSIS - FLDOH #E84207 To: Don Polanis DPS Corp WORK ORDER: PROJECT ID: S-197 / LBP1125 PEL Lab# : Client ID : Matrix : Sheet Pile-West End S Collection Information: Sample Date: 2/20/2011 5:00:00 PM Analysis Prep Parameter Method Results Date Date Units MDL RL Lead U 03/24/2011 7:39 03/23/ :00 MG/KG Dilution Factor 6 of 18

22 - CERTIFICATE OF ANALYSIS - FLDOH #E84207 To: Don Polanis DPS Corp WORK ORDER: PROJECT ID: S-197 / LBP1125 PEL Lab# : Client ID : Matrix : Black Paint on Metal-East S Collection Information: Sample Date: 2/20/2011 5:00:00 PM Analysis Prep Parameter Method Results Date Date Units MDL RL Lead /24/2011 8:10 03/23/ :00 MG/KG Dilution Factor 7 of 18

23 - CERTIFICATE OF ANALYSIS - FLDOH #E84207 To: Don Polanis DPS Corp WORK ORDER: PROJECT ID: S-197 / LBP1125 PEL Lab# : Client ID : Matrix : Gr Paint on Galv-East Gate S Collection Information: Sample Date: 2/20/2011 5:00:00 PM Analysis Prep Parameter Method Results Date Date Units MDL RL Lead /24/2011 8:15 03/23/ :00 MG/KG Dilution Factor 8 of 18

24 - CERTIFICATE OF ANALYSIS - FLDOH #E84207 To: Don Polanis DPS Corp WORK ORDER: PROJECT ID: S-197 / LBP1125 PEL Lab# : Client ID : Matrix : Gr Paint on PVC Riser-East S Collection Information: Sample Date: 2/20/2011 5:00:00 PM Analysis Prep Parameter Method Results Date Date Units MDL RL Lead /24/2011 8:35 03/23/ :00 MG/KG Dilution Factor 9 of 18

25 - CERTIFICATE OF ANALYSIS - FLDOH #E84207 To: Don Polanis DPS Corp WORK ORDER: PROJECT ID: S-197 / LBP1125 PEL Lab# : Client ID : Matrix : Gr Paint on Valve S Collection Information: Sample Date: 2/20/2011 5:00:00 PM Analysis Prep Parameter Method Results Date Date Units MDL RL Lead /24/2011 9:10 03/23/ :00 MG/KG Dilution Factor 10 of 18

26 - CERTIFICATE OF ANALYSIS - FLDOH #E84207 To: Don Polanis DPS Corp WORK ORDER: PROJECT ID: S-197 / LBP1125 PEL Lab# : Client ID : Matrix : Large Galv Cul-West S Collection Information: Sample Date: 2/20/2011 5:00:00 PM Analysis Prep Parameter Method Results Date Date Units MDL RL Lead /24/2011 8:46 03/23/ :00 MG/KG Dilution Factor 11 of 18

27 - CERTIFICATE OF ANALYSIS - FLDOH #E84207 To: Don Polanis DPS Corp WORK ORDER: PROJECT ID: S-197 / LBP1125 PEL Lab# : Client ID : Matrix : Large Galv Cul-Center S Collection Information: Sample Date: 2/20/2011 5:00:00 PM Analysis Prep Parameter Method Results Date Date Units MDL RL Lead /24/2011 8:52 03/23/ :00 MG/KG Dilution Factor 12 of 18

28 - CERTIFICATE OF ANALYSIS - FLDOH #E84207 To: Don Polanis DPS Corp WORK ORDER: PROJECT ID: S-197 / LBP1125 PEL Lab# : Client ID : Matrix : Large Galv Cul-East S Collection Information: Sample Date: 2/20/2011 5:00:00 PM Analysis Prep Parameter Method Results Date Date Units MDL RL Lead /24/2011 8:57 03/23/ :00 MG/KG Dilution Factor 13 of 18

29 - CERTIFICATE OF ANALYSIS - FLDOH #E84207 To: Don Polanis DPS Corp QC SUMMARY WORK ORDER: PROJECT ID: S-197 / LBP1125 METHOD: 6010 Method Blank : 77291MB Matrix : SQ Associated Lab Samples : MB 77292LCS 77293LCSD Analysis Prep Parameter Results Date Date Units RL Lead U 3/24/2011 3/23/2011 MG/KG Dilution Factor LABORATORY CONTROL SAMPLE: 77292LCS Matrix : SQ SPIKE PARAMETER UNITS CONC LCS RESULT SPIKE % REC % REC LIMITS RPD RPD LIMIT Lead MG/KG (80-120) LABORATORY CONTROL SAMPLE: PARAMETER UNITS CONC 77293LCSD SPIKE LCS RESULT Matrix : SPIKE % REC SQ % REC LIMITS RPD RPD LIMIT Lead MG/KG (80-120) of 18

30 - CERTIFICATE OF ANALYSIS - FLDOH #E84207 To: Don Polanis DPS Corp WORK ORDER: PROJECT ID: S-197 / LBP1125 Brian C. Spann Mark Gudnason or Laboratory Manager Technical Director 15 of 18

31 16 of 18

32 17 of 18

33 End Of Report of 18

DPS CORP. May 15, 2011

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