Purpose - Michigan · Web viewThe treatment technique for the rule requires systems to monitor...

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Lead Inspection & Risk Assessment Report For the Property at : Address City, State ZIP Year Built Prepared For : Occupant Occupant Name Occupant Phone Owner Owner Name Owner Address Owner City, State, ZIP Owner Phone Report Prepared and Submitted by : Inspector Name Certified Lead Inspector/Risk Assessor, Michigan Certification P-Cert Number XRF Serial Number: Company Name Address Phone # Date of Inspection: Date of Report:

Transcript of Purpose - Michigan · Web viewThe treatment technique for the rule requires systems to monitor...

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Lead Inspection & Risk Assessment Report

For the Property at:

AddressCity, State ZIP

Year Built

Prepared For:Occupant

Occupant NameOccupant Phone

OwnerOwner Name

Owner AddressOwner City, State, ZIP

Owner Phone

Report Prepared and Submitted by:Inspector Name

Certified Lead Inspector/Risk Assessor, Michigan Certification P-Cert NumberXRF Serial Number:

Company NameAddressPhone #

Date of Inspection: Date of Report:

Version 1.2018

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Table of Contents

1.0 Purpose..............................................................................................................................42.0 Conclusions.......................................................................................................................53.0 Conclusions.......................................................................................................................94.0 Occupancy Information...................................................................................................105.0 Limitations, Difficulties and Excluded Components..........................................................126.0 Re-Evaluation and Monitoring Schedule............................................................................137.0 Additional Resources..........................................................................................................148.0 Inspector Certification........................................................................................................169.0 Representative Photographs................................................................................................1610.0 Supplemental Information..................................................................................................1611.0 All XRF Results for XRF #.............................................................................................1712.0 Appendices......................................................................................................................18Performance Characteristic Sheet..................................................................................................27FIELD OPERATION GUIDANCE..............................................................................................27BACKGROUND INFORMATION..............................................................................................27

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1.0 Purpose

The purpose of the investigation was to determine the existence of lead-based paint (LBP) and lead in water hazards at the subject property and to determine the location, type, and severity of existing or potential health hazards associated with exposures to lead.

The following report details the results of the investigation. A summary of this report must be provided to each new lessee (tenant) or purchaser of this property under Federal law (24 CFR part 35 and 40 CFR part 745) before they become obligated under a lease or sales contract. The complete report must also be provided to purchasers and made available to tenants. Landlords (lessors) and sellers are also required to distribute an educational pamphlet approved by the U.S. Environmental Protection Agency (EPA), entitled “Protect Your Family from Lead in Your Home”, and include standard warning language in their leases or sales contracts to ensure that parents have the information they need to protect their children from lead hazards. For more information regarding your obligations under federal regulations, contact 800-424-LEAD (5323).

LANDLORD PENALTY LAWAttention Landlords:

If a child with an elevated blood lead level is identified in your rental unit you are responsible for ensuring that lead hazards identified in the elevated blood lead level report have been properly addressed. The following must be followed to avoid receiving penalties assessed through the Michigan Lead Abatement Act.

If you conduct the work on your rental unit you must be certified through the EPA RRP Program or certified through the Michigan Lead Abatement Program. Depending on the method used to correct the hazard, you must follow applicable laws to ensure appropriate work practices are followed.

Hire a lead abatement contractor, please see the certified list, located at www.michigan.gov/leadsafe. Check eligibility for work through the Lead Safe Home Program, please see webpage for details. Any questions regarding compliance with the Landlord Penalty Act please

email [email protected] or call 517-335-9390.

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2.0 Conclusions

During the lead inspection and risk assessment the identified hazards are listed in the following Table 3.1. Specific locations of identified LBP, lead in water and/or lead hazards are detailed within the report. Refer to Section 13.0 for floor plans. Only those persons who are trained and certified to work with lead paints can disturb the surfaces that are identified as having lead paint and lead paint hazards. Refer to General Cost Estimate Table 3.3 for an estimate of costs.

2.1 Table of LBP Hazards and Recommended Corrective Action

Component Location of Hazard

Level of Severity/ Priorit

y*

Recommendation

Abatement:Interim Control:Abatement:Interim Control:Abatement:Interim Control:Abatement:Interim Control:Abatement:Interim Control:

*Priority: 1 – most severe, 2 – very severe, 3 – somewhat severe

2.2 General Cost Estimates: The following are cost estimates for lead hazard control work performed by a certified Lead Abatement Contractor. Costs will vary depending upon area and availability of certified contractors.

Control Options Approximate Cost Control Options Approximate CostEncapsulant paint application $3.50 / square-foot Enclosure with wood or metal $5.00 / square-foot

Wet plane friction & impact points $2.75 / square-foot Enclosure with drywall $2.50 / square-footWindow replacement $300-500 each Soil abatement $10.00 / square-footDoor paint-stripping [off-site] $300-400 each Paint stabilization $0.25-1.00 / sq.-ft.Door replacement (exterior) $300-500 each Painting (exterior) $0.75-2.00 / sq.-ft.Door replacement (interior) $100-250 each Painting (interior) $0.50-0.75 / sq.-ft.Exterior vinyl siding $3.00 / square-foot Lead dust cleaning $0.50-2.00 / sq.-ft.Service line replacement $6000Faucet replacement $250 / faucet to shut-off

2.3 Positive XRF Readings

Component Substrate Side Condition

Color Floor Room Results*

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*HUD Reporting Limits for positive XRF results are ≥ to 1.0 mg/cm2for painted or glazed surfaces

2.4 Dust Wipe Sample Results- Those dust wipes representing a hazard are listed in BOLD.

Sample Number

Room Component(window trough, stool,

carpeted floor, hard floor)

Smooth/CleanableSurface (Y/N)

Results*µg/sf

*HUD Grantee Action Levels for Dust: Floor = 10 µg/sf, Window Sills = 100 µg/sf, Window Troughs = 100 µg/sf *HUD/EPA Hazard reporting limits for dust: Floor = 40 µg/sf, Window Sills = 250 µg/sf, window troughs = 400 µg/sf*BRL = Below Reporting Limit

2.5 Soil Sample Results

*HUD Reporting Limits for Soil: Play Areas = 400 ppm, Other Bare Soil = 1,200 ppm, BRL = Below Reporting Limit

2.6 Potential Hazards

This table represents components that were positive for LBP, but in good condition and therefore did not present a hazard at them time of investigation. These components should be monitored for deterioration regularly.

[RFC add in Excel table of potential hazards]

2.7 Non-Typical Components

XRF testing of non-typical building components and personal items: This table represents components that may not be tested as part of the typical lead paint risk assessment guidelines. Items in this may include (but not limited to) components that have coatings other than “paint”, plumbing components or personal items.

ITEM DESCRIPTION AND LOCATION MATERIAL RESULT mg/cm2

Use this table or paste excel data

*The items above were tested using the XRF but do not comply with the Performance Characteristics Sheet as they represent different substrates (i.e. plastic, porcelain, etc or are non-painted). The XRF indicated the presence of lead in several items listed and are included in this report as potential sources of lead.

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Sample Number Location Results*parts per million

(ppm)

Approximate Area of Bare

Soil

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The amounts of lead present by this form of testing are qualitative only. A precise determination of the lead content for the listed items can only be made by laboratory analysis. These results are not acceptable for use in legal actions. Levels of between 0.05 and 0.1 mg/cm2 should be considered as potentially containing lead. Levels of 0.1 mg/cm2 or greater should be considered as containing lead. HUD Reporting Limits for positive XRF results (Paint and Coatings) are 1.0 mg/cm2 or greater

2.8 Water Sample ResultsYes No

What is source of household water? Municipal Name Well

Was there verification with the occupant that water has NOT been used for a minimum of 6 hours prior to sample collection?

When was the last time water was used? (Occupant response)

Is there evidence of recent water usage?

Is there evidence of municipal water system disturbances in the area (i.e. service line replacement, water main work, ect.)?

Sample Number

Location Is lead present in sample?

Does sample exceed EPA

drinking water levels?

Results*Milligrams per

Liter (mg/L)

System samples Yes/No Yes/No Lead(Pb)KF A1 Kitchen faucetKF A2 Kitchen faucetKF A3 Kitchen faucetKF A4 Kitchen faucetKF A5 Kitchen faucetKF A6 Kitchen faucetKF A7 Kitchen faucetKF A8 Kitchen faucetKF A9 Kitchen faucetKF A10 Kitchen faucet

Faucet First Draw SamplesKF P1 Kitchen FaucetKF P1 Kitchen FaucetBF P1 Bath Sink faucetBF P2 Bath Sink faucet

RFC Add or delete rows as needed for additional locations

*EPA Reporting Limits for Drinking Water-Lead (Pb) = 0.001 mg/L EPA Action Limits for Drinking Water- Lead (Pb) = 0.015 mg/LN/D-Not DetectedSamples above EPA reporting limit in Bold

Recommendations for this address based on water sampling-Address, City, State ZIP

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RFC to select and/or modify the appropriate option (FLINT ONLY IN RED) All water samples results received indicate that lead was not present in water. Please continue to follow

the recommendations below to minimize potential future exposure to lead in water.

Water sample results received indicate that lead was present in water. Samples taken indicate lead in water, however levels are below the EPA established standard of 15 ppb (parts per billion). Please follow the recommendations below to minimize potential future exposure to lead in water.

Samples taken indicate lead in water levels are above the EPA established standards at the following locations: XXX

Please refer to hazards list in above Section 2.2 for recommendations on remediation.

The remainder of the water samples analyzed indicate that there is lead in the, however levels are below the current EPA established standard of 15 ppb. Please follow the recommendations below to minimize potential future exposure to lead in water.

It has been determined that as repairs to the water supply system throughout the City of Flint take place lead particles may be released into the drinking water. The following actions should be taken to minimize your exposure to lead in the water until such time as it has been determined that repairs to the City of Flint water supply system have been sufficiently completed:

The following actions should be taken to minimize your exposure to lead in the water: Flush the drinking water taps for 30 seconds to 2 minutes before using water for drinking or cooking.

Use cold water only for drinking and cooking.

Use a NSF-53 filter that is certified for lead removal. Water filter must be used per manufacturer’s recommendations, including recommended filter replacement intervals. Flush unfiltered water (through the filter bypass). See Appendix G for Information about Water Filters fact sheets and website link.

Free water filters are for City of Flint residents. Call 211 to find out where you can pick up a filter and replacement filter cartridges.

All aerators should also be inspected regularly and cleaned of any debris. (See instructions enclosed with packaging on how to clean your aerators-contractor should provide this for new faucets).

Upgrade all existing drinking water supply system components to comply with current standards implemented in 2014. Current standards for drinking water supply plumbing components are NSF/ANSI 61G and NSF/ANSI 372. See Appendix

Exterior faucets, laundry faucets and heating system faucets are not considered to be drinking (potable) water faucets, therefore they are not regulated the same as drinking water faucets and may contain lead. Do not use these faucets for drinking water purposes. It is also recommended warning signs be placed at these locations informing persons (or pets) not to drink from these faucets.

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not considered sources for drinking water. However, there are hose bibs and laundry faucets that are manufactured to be “lead-free”. It is recommended that the hose bib and laundry faucet be replaced with a “lead-free” component or not use for water consumption. The 2015 Michigan Plumbing Code requires that each non potable water source must be demarked with the following verbiage: CAUTION: NON POTABLE WATER – DO NOT DRINK.

Example:

3.0 ConclusionsProvide description of site, including, but not limited to, single/multi-family, occupancy (rental/owner occupied), vacant/occupied, child-occupied facility, age of construction (including additions), siding type, type and age of windows, roof, porches, play areas and previous investigations. Interior descriptors including, but not limited to, architectural components, carpet, attics, and basements.

3.1 Building Condition FormCondition Yes No

ExteriorRoof missing parts of surface covering?

Roof has holes or large cracks?

Gutters or downspouts broken?

Chimney or masonry cracked, with loose or missing components, out of plumb or otherwise deteriorated?

Exterior or interior walls have large cracks, or damage requiring more than routine painting?

Exterior siding missing components?

Two or more windows or doors missing, broken or boarded up?

Porch or steps have major cracks, missing materials, structural leans, or visibly unsound?

Foundation has damage, structural leans or is unsound?

InteriorWater stains on interior walls or ceilings?

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Plaster walls deteriorated?

Mold present?

Other Conditions:

Water risk factors and Plumbing condition

Has water ever been tested for lead?

Does the home have leaded brass plumbing components, faucets or copper pipes soldered with lead? (Document/Photograph locations)

Do any faucets have an aerator? (Document/Photograph locations)

Was the aerator able to be removed to inspect?

Were particles found in aerator? (Document/Photograph)

Are any faucets leaking, toilet running or are rust stains present in sinks or tub?

What material is service line made of? (Document/Photograph location)

Has the service line been replaced or repaired? If yes, which year?

How many feet is the meter from the curb or edge of road?

Are there any water treatment devices currently in place? (Document/Photograph locations)

Other conditions:

4.1 Faucet and Fixture StatusLocation Material(s) Condition Installed <2014 Installed >2014

and certification is verified

ReplaceY/N

See attached “How to Identify Lead Free Certification Marks for Drinking Water System and Plumbing Products” fact sheet.

4.0 Occupancy Information

This house is currently:

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4.1 Resident Questionnaire

Interview Question Interviewee ResponseChildren’s Habits and Behavioral FactorsDo you have children that live in your home or visit on a regular basis?

Where are toys stored?

Are there any areas of peeling paint on walls, ceilings, stairs, woodwork, furniture or toys?

Does the child put painted objects into his/her mouth such as crayons, paint chips, chew on crib railing, chew on window sills, etc? If yes please explain.

What is source of drinking water for child?Does child/children drink water from bathtub faucet or bathwater?Does child/children drink water from exterior faucet or hose?Does child drink water from laundry tub?Is hot tap water or first draw water used for drinking, cooking, or baby formula preparation?For children under the age of 6 complete the chart below indicating where the children eat, sleep, play indoors and play outdoors.

Child Age Bedroom Location

Location of Where Child

Eats

Primary Location

Where Child Plays

Indoors

Primary Location

Where Child Plays

OutdoorChild 1Child 2Child 3Child 4Child 5Child 6Child 7

Interview Question Interviewee ResponseFamily Use PatternsWhich entrances are used most frequently?

Which windows are opened most frequently?

Do you use window air conditioners? If yes, where?

Do any household members have a vegetable garden? If yes where?

Are you planning any landscaping activities? If yes where and what type?

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Is there a pet such as a dog or cat?

How often is the household cleaned?

What cleaning methods are used?

Did you recently complete any building renovations? If yes, where and what was done?

Was building debris stored in the yard? If yes, where?

Are you planning any building renovations? If yes, where?

Do any household members work in a lead-related industry or have hobbies that use lead such as making fishing weights, make bullets, stained glass windows, etc?

If yes, where are dirty clothes placed and cleaned?

Is hot tap water or first draw tap water used for drinking, cooking or baby formula preparation?Who was interviewed for this section? Relation to Child:

Additional Notes

5.0 Limitations, Difficulties and Excluded ComponentsThis investigation requires testing of every unique painted surface. However, some surfaces could not be tested because of limitations such as inaccessible areas, windows not operable, clutter, unsafe building conditions, etc. All untested areas are assumed to contain lead paint. Lead safe work practices should be used if those surfaces are disturbed.

The following table lists those components and areas that the investigator was not able to test and the reason why they were not tested.

AREA / LOCATION COMPONENT REASON NOT TESTED

6.0 Re-Evaluation and Monitoring Schedule

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All painted components require periodic re-evaluation and monitoring that is comprised of two parts: Re-evaluation and Owner Visual Survey.

Re-evaluation is a bi-annual follow-up risk assessment completed by a certified Risk Assessor to determine the integrity of the corrective action performed, as described below:

Leaded-dust above applicable standards Deteriorated paint films with lead-based paint Lead-based paint on friction, impact and chewable surfaces Deteriorated or failed interim controls, or encapsulant or enclosure treatments New bare soil with lead levels about application standards Deteriorated faucets, plumbing and service line

The Owner Visual Survey should be completed one month after the lead hazards have been fixed, again six months later, and if not problems are found, once each year thereafter. An Owner Visual Survey identifies:

New deterioration to painted surfaces that contain lead Areas where lead hazards were fixed but have deteriorated since Problems with the building that could cause new lead hazards

6.1 Health Effects of Lead Exposure

Lead is a soft metal, naturally occurring in the earth’s crust. It has been determined; however, that lead has no useful purpose in the human body and acts as a toxin. It takes the place of essential minerals such as calcium, potassium, and iron, which are vital to the construction and repair of bones, organs and blood. Lead exposures have become a major health concern, especially in young children under the age of six.

Children, due to their smaller body mass and higher metabolism, are affected by lead exposures much more severely than adults. They ingest lead through daily hand-to-mouth activities and may develop severe attention deficit disorders, irreversible brain injury, learning disabilities and aggressive behaviors. The symptoms of lead poisoning often mimic other afflictions such as flu, colic or general malaise. It is important to have young children’s blood tested for lead burden.

6.2 Sources of Lead Poisoning

Since lead is ingested by routine daily activities such as eating, playing and working, it is important to understand the sources of lead exposures. The most common places to find lead in household settings are interior and exterior paint, and contaminated dust or soil. LBP is most hazardous when it is chipping, peeling, cracking, or chalking; or applied to friction surfaces of components such as doors, windows, and floors. The abrasive action of painted surfaces rubbing together causes LBPs to be ground into a fine dust. Lead dust can also be created from decaying vinyl mini blinds. Lead dust then settles on furniture, play area floors, and children’s toys, where children are exposed during regular activities.

Several other sources of lead in the home include lead dust brought into the home from occupational exposures, water pipes, fixtures, and joints; decorative china, “leaded” crystal, fishing lures and sinkers, firearms ammunition, wine bottles and cosmetics. Some hobbies may also contribute to lead contamination within the home. Exposures to all sources of lead should be minimized or eliminated.

6.3 Methods to Reduce Exposure to Lead Hazards

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The simplest and often most effective way to reduce lead exposures is through regular washing of hands, toys, and horizontal surfaces in the home with a liquid soap and water. It is highly recommended that disposable cleaning materials (i.e. paper towel) be used to wash surfaces, so as not to re-contaminate them with a used mop or cloth.

Other ways of reducing lead hazards within the home include taking shoes off before entering living areas, letting cold water run at least 30 seconds prior to drinking or cooking, covering exposed soil with plant materials, and vacuuming with a High Efficiency Particulate Air (HEPA) filtered vacuum.

For more information regarding lead poisoning and prevention, contact your local health department or the National Lead Information Center (800-424-LEAD (5323). Contact the Michigan Department of Health and Human Services, Healthy Homes Section at (866) 691-5323 for information regarding lead hazard remediation or selection of qualified lead professionals.

7.0 Additional Resources

For further information regarding LBP hazards and poisoning prevention, consult the following resources:

Contacts:National Lead Information Center: ...............................................800-424-LEAD (5323)Michigan Lead Safe Home Program: ...........................................866-691-LEAD (5323)

Publications:“Lead in Your Home: A Parent’s Reference Guide” U.S. Environmental Protection Agency“Protect Your Family From Lead in Your Home” U.S. Environmental Protection Agency “Lead Paint Safety: A Field Guide for Painting, Home Maintenance, and Renovation Work”U.S. Department of Housing and Urban Development

Websites:State of Michigan, Healthy Homes Section www.michigan.gov/leadsafe HUD – Office of Lead Hazard Control Healthy and Homes www.hud.gov/offices/leadU.S. Environmental Protection Agency www.epa.gov/leadNational Safety Council www.nsc.org/issues/lead

Applicable Laws:Michigan Compiled Law 333.5475a requires rental property owners to address lead hazards within 90 days of receiving this report on a property where a lead poisoned child was identified.

The Federal Residential Lead-Based Paint Hazard Reduction Act, 42 U.S.C. 4852(d), requires sellers and landlords of residential pre-1978 housing to disclose all records and reports concerning lead-based paint or lead-based paint hazards, including the test results in this report, to purchasers and tenants at the time of sale or lease or upon lease renewal.

EPA Lead and Copper Rule, 40 CFR Part 141 Subpart I

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Lead and copper enter drinking water primarily through plumbing materials. Exposure to lead and copper may cause health problems ranging from stomach distress to brain damage.

In 1991, EPA published a regulation to control lead and copper in drinking water. This regulation is known as the Lead and Copper Rule (also referred to as the LCR). Since 1991 the LCR has undergone various revisions, see the Rule History section below.

The rule established a maximum contaminant level goal of zero for lead in drinking water and a treatment technique to reduce corrosion of lead and copper within the distribution system.

The treatment technique for the rule requires systems to monitor drinking water at customer taps. If lead concentrations exceed an action level of 15 ppb or copper concentrations exceed an action level of 1.3 ppm in more than 10% of customer taps sampled, the system must undertake a number of additional actions to control corrosion.

If the action level for lead is exceeded, the system must also inform the public about steps they should take to protect their health and may have to replace lead service lines under their control.

Reduction of Lead in Drinking Water Act

While the LCR rule applies to water utilities, the Reduction of Lead in Drinking Water Act   sets standards for:  Pipe, Plumbing fittings, Fixtures, Solder and flux

Section 1417 of the Safe Drinking Water Act (SDWA) establishes the definition for “lead free” as a weighted average of 0.25% lead calculated across the wetted surfaces of a pipe, pipe fitting, plumbing fitting, and fixture and 0.2% lead for solder and flux. The Act also provides a methodology for calculating the weighted average of wetted surfaces.

 The Act prohibits the “use of any pipe, any pipe or plumbing fitting or fixture, any solder, or any flux, after June 1986, in the installation or repair of (i) any public water system; or (ii) any plumbing in a residential or non-residential facility providing water for human consumption, that is not lead free.” 

 Additionally there is a prohibition on introducing a pipe, any pipe or plumbing fitting or fixture, any solder, or any flux that is not lead free into commerce; unless the use is for manufacturing or industrial purposes. 

The SDWA includes several exemptions from the lead free requirements, specifically for plumbing devices that are used exclusively for nonpotable services, as well as a list of specific products: toilets, bidets, urinals, fill valves, flushometer valves, fire hydrants, tub fillers, shower valves, service saddles, or water distribution main gate valves that are 2 inches in diameter or larger.

8.0 Inspector CertificationThe information contained in this report is a true and accurate representation of the conditions and activities at this property at the time of this investigation, based on the professional judgment of the person(s) who

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conducted and reported this Environmental Investigation. If soil samples were not collected as indicated in Table 3.5 due to snow, these samples will be collected at the earliest opportunity. An amended report will be sent with any soil hazards found and corrective action options.

_____________________________________________________________, Michigan Lead Inspector/Risk Assessor # P-Risk Assessor E-Mail

9.0 Representative Photographs

10.0 Supplemental Information

10.1 Sampling Procedures

10.1.1 Laboratory

Dust and soil samples were analyzed by State of Michigan Department of Health and Human Services Trace Metals Laboratory located at 3335 Martin Luther King Jr. Blvd., Lansing, Michigan 48909, (517) 335-9490. The Michigan Department of Health and Human Services Environmental Lead Laboratory participates in the Environmental Lead Proficiency Analytical Testing (ELPAT) quality control rounds and is approved by the National Lead Laboratory Accreditation Program (NLLAP).

Water samples were analyzed by State of Michigan Department of Environmental Quality Drinking Water Laboratory located at:

3350 Martin Luther King Jr. Blvd., Lansing, Michigan 48909

(517-335-8184). OR

The following Michigan Department of Environmental Quality Certified Drinking Water Laboratory approved by the LSHP for Lead and Copper was used and is located at:

NameAddressPhone

10.1.2 Soil Sampling

Soil samples, if deemed appropriate by the Risk Assessor, were collected following HUD guidelines from areas Address, City, State ZIP

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of exposed soil located within the boundaries of the property, such as sandbox, play areas, and foundation drip line. Composite samples from the upper 1/2 inch of soil were collected and analyzed by State of Michigan Department of Health and Human Services Trace Metals Laboratory. Results are reported in parts of lead per million parts of sampled soil.

10.1.3 Dust Wipe Sampling

Dust wipe samples, where deemed appropriate by the Risk Assessor, were collected according to HUD Guidelines, as follows:

An area location on the surface to be sampled was measured and marked. A single approved sampling wipe (disposable towelette) was opened with a gloved hand and wiped

across the sampling area in a series of “S” patterns. Composite dust wipe samples are prohibited in Michigan.

The wipe was then placed into a container labeled with the site location identification, sample location and size of area sampled.

Samples were analyzed by the State of Michigan Department of Health and Human Services Trace Metals Laboratory. The results reported in micrograms per square foot (μg/ ft2).

10.1.4 XRF Analysis

The instrument used for this Risk Assessment was an X-Ray Fluorescence unit (XRF) manufactured by NITON. The unit was operated according to Performance Characteristic Sheet recommendations, which is appended. XRF technology utilizes low level radiation to excite atoms within painted surfaces. The XRF unit interprets the gamma radiation rebound to determine whether or not lead is present and if so to what degree. If the unit detects lead at the HUD defined threshold limit of 1.0 µg/cm2 or more, then a positive reading is reported.

10.1.5 Water Sampling

Water samples were collected according to the Michigan Department of Health and Human Services- Residential Lead Hazard Control-Lead in Water Protocol.

11.0 All XRF Results for XRF #

[RFC INSERT ALL XRF TABLE HERE]

12.1 XRF Interpretation

There are eight columns in the XRF table. The interpretation of each column is as follows:

Component: This column identifies the surface that was tested. Some examples are doors, door trim, walls, ceiling, exterior siding etc.

Substrate: This column defines what material the paint was applied to. Substrates are most commonly plaster or wood but could be other material such as metal.

Side: This column determines where the item being tested is located in the room. Side A is always the address side of the building. Then, proceeding in a clockwise direction the adjacent sides are labeled B, C and D. Sides A, B, C and D are identified on the Floor Plan in Section 10.3. For example, if you were

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standing in a bedroom that had two windows on different walls these windows would be identified by the side location such as Window Side A and Window Side B.

Condition: This column identifies the condition of the paint on the surface being tested. Intact or Deteriorated are used to describe the paint condition.

Color: This is the color of the surface of the component being tested with the XRF. Also listed in this column is the XRF calibration. The XRF must be calibrated before inspection and at the end of the inspection. Additionally, the XRF needs to be calibrated every four hours if the inspection exceeds four hours.

Floor: This simply corresponds to the floor of the building. Basements are identified as “floor 0”.Room: This column identifies the room where XRF testing occurred. Rooms are always identified by a number,

except for kitchens and bathrooms. Numbers are used because room usage may change (i.e. a bedroom may become an office).

Result: This column indicates whether or not the paint tested Positive or Negative for the presence of lead.

12.0 Appendices

12.1 Glossary of Lead Terms and Definitions

Abatement: A measure or set of measures designed to permanently eliminate lead-based paint hazards or lead-based paint. Abatement strategies include the removal of lead-based paint, enclosure, encapsulation, replacement of building components coated with lead-based paint, removal of lead contaminated dust, and removal of lead contaminated soil or overlaying of soil with a durable covering such as asphalt (grass and sod are considered interim control measures). All of these strategies require preparation; cleanup; waste disposal; post-abatement clearance testing; recordkeeping; and, if applicable, monitoring. (For full EPA definition, see 40 CFR 745.223).

Bare soil: Soil not covered with grass, sod, some other similar vegetation, or paving, including the sand in sandboxes.

Chewable surface: An interior or exterior surface painted with lead-based paint that a young child can mouth or chew. A chewable surface is the same as an “accessible surface” as defined in 42 U.S.C. 4851b(2). Hard metal substrates and other materials that cannot be dented by the bite of a young child are not considered chewable.

Deteriorated paint: Any paint coating on a damaged or deteriorated surface or fixture, or any interior or exterior lead-based paint that is peeling, chipping, blistering, flaking, worn, chalking, alligatoring, cracking, or otherwise becoming separated from the substrate.

Drip line/foundation area: The area within 3 feet out from the building wall and surrounding the perimeter of a building.

Dust-lead hazard: Surface dust in residences that contains an area or mass concentration of lead equal to or in excess of the standard established by the EPA under Title IV of the Toxic Substances Control Act. EPA standards for dust-lead hazards, which are based on wipe samples, are published at 40 CFR 745.65(b); as of the publication of this edition of these Guidelines, these are 40 μg/ft2 on floors and 250 μg/ft2 on interior window sills. Also called lead-contaminated dust.

Friction surface: Any interior or exterior surfaces, such as a window or stair tread, subject to abrasion or friction.

Garden area: An area where plants are cultivated for human consumption or for decorative purposes. Address, City, State ZIP

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Impact surface: An interior or exterior surface (such as surfaces on doors) subject to damage by repeated impact or contact.

Interim controls: A set of measures designed to temporarily reduce human exposure or possible exposure to lead-based paint hazards. Such measures include, but are not limited to, specialized cleaning, repairs, maintenance, painting, temporary containment, and the establishment and operation of management and resident education programs. Monitoring, conducted by owners, and re-evaluations, conducted by professionals, are integral elements of interim control. Interim controls include dust removal; paint film stabilization; treatment of friction and impact surfaces; installation of soil coverings, such as grass or sod; and land use controls. Interim controls that disturb painted surfaces are renovation activities under EPA’s Renovation, Repair and Painting Rule.

Lead-based paint: Any paint, varnish, shellac, or other coating that contains lead equal to or greater than 1.0 mg/cm2 as measured by XRF or laboratory analysis, or 0.5 percent by weight (5000 mg/g, 5000 ppm, or 5000 mg/kg) as measured by laboratory analysis. (Local definitions may vary.)

Lead-based paint hazard: A condition in which exposure to lead from lead contaminated dust, lead contaminated soil, or deteriorated lead-based paint would have an adverse effect on human health (as established by the EPA at 40 CFR 745.65, under Title IV of the Toxic Substances Control Act). Lead-based paint hazards include, for example, paint-lead hazards, dust-lead hazards, and soil-lead hazards.Paint-lead hazard: Lead-based paint on a friction surface that is subject to abrasion and where a dust-lead hazard is present on the nearest horizontal surface underneath the friction surface (e.g., the window sill, or floor); damaged or otherwise deteriorated lead-based paint on an impact surface that is caused by impact from a related building component; a chewable lead-based painted surface on which there is evidence of teeth marks; or any other deteriorated lead-based paint in any residential building or child-occupied facility or on the exterior of any residential building or child-occupied facility.

Play area: An area of frequent soil contact by children of under age 6 as indicated by, but not limited to, such factors including the following: the presence of outdoor play equipment (e.g., sandboxes, swing sets, and sliding boards), toys, or other children’s possessions, observations of play patterns, or information provided by parents, residents, care givers, or property owners.

Potable/Drinking water: Drinking water, also known as potable water or improved drinking water, is water that is safe to drink or to use for food preparation, without risk of health problems. The Safe Drinking Water Act (SDWA) is the federal law that protects public drinking water supplies throughout the nation. Under the SDWA, EPA sets standards for drinking water quality and with its partners implements various technical and financial programs to ensure drinking water safety.

Soil-lead hazard: Bare soil on residential property that contains lead in excess of the standard established by the EPA under Title IV of the Toxic Substances Control Act. EPA standards for soil-lead hazards, published at 40 CFR 745.65(c), as of the publication of this edition of these Guidelines, is 400 μg/g in play areas and 1,200 μg/g in the rest of the yard. Also called lead-contaminated soil.

Water-lead hazard: Water ample results exceed the EPA-Lead and Copper Rule’s established action level 15 ppb.

Key Units of Measurement

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Gram (g or gm): A unit of mass in the metric system. A nickel weighs about 1 gram, as does a 1 cube of water 1 centimeter on each side. A gram is equal to about 35/1000 (thirty-five thousandths of an ounce). Another way to think of this is that about 28.4 grams equal 1 ounce.µg (microgram): A microgram is 1/1000th of a milligram. To put this into perspective, a penny weighs 2 grams. To get a microgram, you would need to divide the penny into 2 million pieces. A microgram is one of those two million pieces.µg/dL (microgram per deciliter): used to measure the level of lead in children’s and worker’s blood to establish whether intervention is needed. A deciliter is a little less than a half a cup.µg/ft2 (micrograms per square feet): the unit used to express levels of lead in dust samples. All reports should report levels of lead in dust in µg/ft2.mg/cm2 (milligrams per square centimeter): used to report levels of lead in paint thru XRF testing.ppm (parts per million): Typically used to express the concentrations of lead in soil. Can also be used to express the amount of lead in a surface coating on a mass concentration basis. This measurement can also be shown as: µg/g, mg/kg or mg/l.

ppb (parts per billion): Typically used to express the amount of lead found in drinking water. This measurement is also sometimes expressed as: µg/L (micrograms per liter).

12.2 Housing Component Identification

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Housing Component Identification Continued

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13.2 Property Floor Plan – First Floor

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13.3 Property Floor Plan – Second Floor

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13.4 Property Floor Plan – Basement

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13.4 Site Plan for Error: Reference source not found, Error: Reference source not found

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13.5 Location Map for Error: Reference source not found, Error: Reference source not found

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13.6 Performance Characteristic Sheet (PCS) for X-Ray Fluorescence Portable Lead Analyzer

HEURESIS PCS December 2015

Performance Characteristic Sheet EFFECTIVE DATE: December 1, 2015

MANUFACTURER AND MODEL: Make: Heuresis Models: Model Pb200i Source: 57Co, 5 mCi (nominal – new

source)

FIELD OPERATION GUIDANCE OPERATING PARAMETERS: Action Level mode

XRF CALIBRATION CHECK LIMITS:

0.8 to 1.2 mg/cm2 (inclusive)

SUBSTRATE CORRECTION: Not applicable

INCONCLUSIVE RANGE OR THRESHOLD:

ACTION LEVEL MODE READING DESCRIPTION

SUBSTRATE THRESHOLD (mg/cm2)

Results not corrected for substrate bias on any substrate

Brick Concrete Drywall

1.0 1.01.0

Metal 1.0

Plaster 1.0

Wood 1.0

Page 1 of 4

BACKGROUND INFORMATION

EVALUATION DATA SOURCE AND DATE:

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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 using test results on building components in the HUD archive. Testing was conducted on 146 test samples in November 2015, with two separate instruments running software version 2.1-2 in Action Level test mode. The actual source strength of each instrument on the day of testing was approximately 2.0 mCi; source ages were approximately one year.

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/cm2 in the NIST Standard Reference Material (SRM) used (e.g., for NIST SRM 2579, use the 1.02 mg/cm2 film).

If the average (rounded to 1 decimal place) of three readings is outside the acceptable calibration check range, follow the manufacturer's instructions to bring the instrument 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/cm2 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 1.0 mg/cm2 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/cm2. 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/cm2 NIST SRM is shown in this example; use the actual lead loading of the NIST SRM used for substrate correction):

Correction value = (1st + 2nd + 3rd + 4th + 5th + 6th 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. 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 Address, City, State ZIP

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

TESTING TIMES: In the Action Level paint test mode, the instrument takes the longest time to complete readings close to the Federal standard of 1.0 mg/cm2. The table below shows the mean and standard deviation of actual reading times by reading level for paint samples during the November 2015 archive testing. The tested instruments reported readings to one decimal place. No significant differences in reading times by substrate were observed. These times apply only to instruments with the same source strength as those tested (2.0 mCi). Instruments with stronger sources will have shorter reading times and those with weaker sources, longer reading times, than those in the table.

Mean and Standard Deviation of Reading Times in Action Level Mode by Reading Level

Reading (mg/cm2) Mean Reading Time (seconds)

Standard Deviation (seconds)

< 0.7 3.48 0.47 0.7 7.29 1.92 0.8 13.95 1.78

0.9 – 1.2 15.25 0.66 1.3 – 1.4 6.08 2.50

> 1.5 3.32 0.05

CLASSIFICATION OF RESULTS: Address, City, State ZIP

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XRF results are classified as positive if they are greater than or equal to the stated threshold for the instrument (1.0 mg/cm2), and negative if they are less than the threshold.

Although the XRF instrument is not designed to analyze non-painted surfaces, according to the State of California (Department of Toxic Substances Control, Feb 2012), it can be an effective screening tool to determine lead content in metal.

DOCUMENTATION:

A report titled Methodology for XRF Performance Characteristic Sheets (EPA 747-R-95-008) 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. The report may be downloaded at http://www2.epa.gov/lead/methodology-xrf-performance-characteristic-sheets-epa-747-r-95008-september-1997. This XRF Performance Characteristic Sheet (PCS) was developed by QuanTech, Inc., under a contract with the XRF manufacturer.

Department of Toxic Substances Control. (Feb 2012). Testing and Evaluation of Lead Content in Plumbing Products, Materials and Components. State of California. Retrieved from http://www.dtsc.ca.gov/PollutionPrevention/upload/lead-in-plumbing-testing-protocol.pdf

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