Elevated Blood Lead (EBL) - Michigan



Elevated Blood Lead (EBL)

Environmental Investigation Report

For the Property at:

STREET ADDRESS

CITY, STATE AND ZIP

DATE OF CONSTRUCTION

Property Owner:

OWNER’S NAME

STREET ADDRESS

CITY, STATE AND ZIP

PHONE #

Prepared for:

Parent’s Name

Parent’s PHONE

Parent’s address

Report prepared and submitted by:

EBL Investigator’s Name

Michigan Certification Number P-XXXX

If a second investigator, list also

Company Name

Address

Phone#

517-335-9390

Day Month Year Day Month Year

Date of Investigation Date of Report

Table of Contents

1.0 Purpose of the Environmental Investigation 5

2.0 Executive Summary 6

3.0 Project Limitations, Difficulties, and Excluded Components 14

4.0 Site Information 15

5.0 Paint Condition 17

6.0 Household Interview 18

7.0 Re-Evaluation and Monitoring Schedule 20

8.0 Additional Resources 22

9.0 Inspector Certification 24

10.0 Representative Photographs 24

11.0 Supplemental Information 24

12.0 All XRF Results for XRF # 25

13.0 Appendices 26

14.0 Performance Characteristic Sheet (PCS) for X-Ray Fluorescence Portable Lead Analyzer 28

15.0 Housing Component Identification 32

16.0 Floor Plans / Site Map 33

LANDLORD PENALTY LAW

Attention 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 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 HHSInfo@ or call 517-335-9390.

1.0 Purpose of the Environmental Investigation

The purpose of this Environmental Investigation was to look for lead paint, lead in water and lead in personal items and lead hazards at this property, and to determine the location, type, and severity of existing or potential health hazards associated with exposures to lead. Any of the identified areas in this report could have contributed to the child’s poisoning. The report will also explain the most likely areas of exposure to lead.

This report can help owners develop a plan for eliminating identified lead hazards to protect the poisoned child, current and future occupants, and aid in establishing an ongoing lead maintenance and re-evaluation program, if needed.

As part of the investigation, a visual survey of the property and structure was conducted, dust wipe sampling was performed on interior surfaces, soil samples and water samples were collected. In addition, on-site paint testing using x-ray fluorescence (XRF) analyzer was performed.

The following report details the results of the investigation. The Executive Summary and Table 2.1 list all of the lead paint hazards, soil hazards, dust hazards and water hazards found during this investigation, and options for correcting these hazards. Consult the appendices for additional information on how to interpret XRF results, definition of terms, measurement standards, and names of building and plumbing components.

Rental property owners and maintenance staff cannot make any of these lead repairs themselves now that a lead poisoned child has been associated with the property, unless they have received proper training through a state accredited or nationally accredited training program. It is highly advised that a certified lead abatement company be hired to fix all of the lead paint hazards listed in this report. Rental property owners are obligated to correct identified hazards using abatement and/or interim control techniques within 90 days of receiving this report per MCL 333.5475a.

A copy 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-based paint hazards. For more information regarding your obligations under federal lead-based paint regulations, call 800-424-LEAD (5323).

Lead Abatement: Lead abatement activities (MCL 333.5453(1) and (2)), which are permanent repairs to lead paint hazards, must be performed by a Michigan-certified lead abatement company with Michigan-certified lead abatement supervisors and workers. Examples are window and door replacement, enclosing the lead hazards with siding or paneling, coating hazards with an ASTM-approved encapsulant, and replacing lead-containing soil. Certified companies can be found at leadsafe.

Interim Controls: Interim control activities (non-abatement lead hazard control activities) (MCL 333.5457(5)) are temporary repairs that are regulated by the EPA’s Renovation, Repair and Painting Rule (40 CFR §745 Subpart E) and Michigan’s lead laws (MCL 333.5451-333.5477). Examples of interim controls are specialized cleaning, coating lead hazards with house paint, laying garden mulch or landscape fabric, and planting grass. If the rental property owner chooses to perform interim control activities personally or with maintenance staff, then the owner’s business entity must be certified as a Renovation Firm, and anyone working on the lead repairs must be certified as an Abatement Supervisor (4-day training class), Abatement Worker (3-day training class) or Renovator (1-day training class). In addition, a certified Lead Abatement Supervisor must be present during set-up and cleaning activities. If the rental property owner uses a property management company or hires an outside company to perform the work, they also must be certified as explained above.

Lead Dust Clearance: A lead dust clearance examination must be performed immediately after these corrections have been made (R325.99407). The rental property owner must hire a certified Lead Inspector or Risk Assessor to perform a clearance. Certified individuals can be found at leadsafe.

Homeowners: Although homeowners/parents do not have any regulatory restrictions as far as making lead-related repairs on their own homes, it is highly recommended that they take, at a minimum, certified renovator training before doing the work. Doing repairs involving lead paint without training and using lead-safe work practices can further poison your child.

2.0 Executive Summary

The purpose of the Executive Summary is to summarize where the lead hazards were found at this property. For each paint, soil, dust and water hazard identified, a corrective action option is also provided. The two types of corrective actions are abatement which is a permanent long-term solution or interim control which is a shorter term solution as defined in Section 1.0. All identified lead paint and lead paint hazards should always be properly addressed by professionally certified lead workers and companies.

Since lead is ingested by 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 are interior and exterior paint, and contaminated dust or soil. Lead-based paint is most hazardous when it is chipping, peeling, cracking, or chalking; or applied to friction surfaces of components such as doors, windows, and floors. Painted surfaces rubbing together causes lead paint 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.

Some of the other sources of lead can include lead dust brought into the home from worksites, water pipes, plumbing fixtures and soldered joints, colorful cups and dishes, leaded crystal, fishing sinkers, firearms ammunition, and cosmetics. Some hobbies may also contribute to lead contamination within the home. Exposures to all sources of lead should be eliminated.

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. Disposable cleaning towels and mops should be used to wash surfaces and thrown away so that recontamination does not occur.

Other ways of reducing lead hazards within the home include taking shoes off at the door, letting water run cold prior to drinking or cooking, filtering water for consumption, covering exposed soil with plants or mulch, 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 Michigan Department of Health and Human Services at (866) 691-5323 (or leadsafe) for information regarding lead hazard repair grants or a list of Michigan-certified lead paint removal contractors.

To conform to accepted industry standards, each interior space (known as a room equivalent) was assigned a unique room number during the investigation. The various interior room numbers assigned and the exterior soil sampling locations are shown on the diagrams on pages XX-XX of this report.

Provide a summary of the findings here. Include information on secondary sites, if any, and items testing positive from the household interview. If there are things that the occupant can do now to reduce critical hazards (window systems, toys, dishes, etc.) to protect the child, discuss them here.

1.

2.

2 Existing Lead Paint Hazards and Corrective Action Options

The following items describe the existing lead-based paint hazards identified at ADDRESS. Each hazard has options for corrective actions known as abatement (long term) and interim control (short term) solutions. The owner or owner’s agent must select the most appropriate and affordable solution to address each of the identified hazards. Note that these hazards may become more severe over time and additional hazards may be created with changing conditions at this property.

|Table 2.1 Lead Hazards and Corrective Action Options |

|Component | |Severi|Prio|Lead Hazard Corrective Action Options |

| |Location of Hazard |ty |rity| |

|Severity: 1 = Most Severe, 2 = Very Severe, 3 = Somewhat Severe – Priority: 1 = Highest Priority, 2 = High Priority, 3 = Priority |

|List specific components |List room, side, or |1 |1 |List at least one abatement and one interim control option per hazard. Consult the Table 2.1 |

|that are hazards. |other locations |or |or |Corrective Actions template on the leadsafe>EBL Environmental Investigator |

| | |2 |2 |website for further guidance. |

|Unless all sides are | |or |or | |

|tested, this testing | |3 |3 | |

|method is representative. | | | | |

|Data should be | | | | |

|extrapolated to other like| | | | |

|components here. | | | | |

| | | | | |

Unless specifically stated by side, lead hazards listed by component are representative of all other similar component types in that location.

All contractors performing abatement activities are required to be certified by the State of Michigan; ask to see their certification card. Most interim control activities require an EPA-certified renovator; ask to see their certification.

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 Cost |

|Encapsulant 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-foot |

|Window replacement |$300-500 each |Soil abatement |$10.00 / square-foot |

|Door 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 |$6,000 | | |

|Faucet replacement |$250/faucet to shut-off | | |

3 Potential Lead Hazards and Corrective Action Options

The following table lists potential lead paint hazards identified at the time of the investigation, but these potential hazards do not need to be repaired immediately as of this date. The items listed below tested positive for lead but were not in deteriorated condition at the time of testing. These potential hazards are not hazards unless paint conditions worsen or renovation activities disturb these areas. A control option is provided for each potential lead hazard. Lead safe work practices must be used if any of these surfaces are disturbed.

|Table 2.2 Potential Lead Hazards |

|Location |Component |Abatement/Interim Control Options |

|List room or other locations |List specific components |List at least one abatement and one interim control option per hazard. Consult|

|including side |List all positive XRF readings with |the Table 2.1 Corrective Actions template on the leadsafe>EBL|

| |intact paint condition |Environmental Investigation website for further guidance. |

| | | |

All contractors performing abatement activities are required to be certified by the State of Michigan; ask to see their certification card. Most interim control activities require an EPA-certified renovator; ask to see their certification.

4 Dust Lead Hazards

Dust samples were collected from window sills, troughs (wells), and floors in rooms where young children can come in contact with dust. Michigan law requires a minimum of 6 rooms with floor and window samples taken in each room. The following table lists the locations where all dust samples were taken and identifies which ones are positive for dust lead hazards. Corrective action options for each identified dust hazard are listed in Table 2.1. All dust hazards are considered “most severe” and should be corrected immediately.

| Table 2.3 Dust Wipe Sample Results |

|Sample #|Room/Wipe Location |Surface Tested (hard floor, |Lead Hazard? |Lab Result |

| |Floor wipe should be taken w/in 3’ of a door or window unless |carpet, trough, stool/sill, other)|Yes/No |(µg/sq-ft) |

| |professional judgment calls for another location in the room to be | | | |

| |sampled | | | |

| |{Example- Room 1 - Living Room, floor} | | | |

| |{Example- Room 2 - Dining Room, window} | | | |

| |{Example- Room 2 - Dining Room, floor} | | | |

| |{Example- Room 3 - Kitchen, window} | | | |

| |{Example- Room 3 - Kitchen, floor} | | | |

| |{Example- Room 4 - Child’s Bedroom, window} | | | |

| |{Example- Room 4 - Child’s Bedroom, floor} | | | |

| |{Example- Room 5 - Bedroom, window} | | | |

| |{Example- Room 5 - Bedroom, floor} | | | |

| |{Example- Room 6 - Back Entrance, window} | | | |

| |{Example- Room 6 - Back Entrance, floor} | | | |

| |{Example- Room # - Front Entryway floor} | | | |

| |{Example- Room # - Cellar Stairway or landing} | | | |

*HUD Grant 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

6 Soil Lead Hazards

The following table lists all soil samples taken and which ones are positive for soil lead hazards. The samples were collected from bare soil areas (if present) at the house drip line, child play areas, and bare soil areas of 9 square feet or larger. Corrective action options for each identified soil hazard are listed in Table 2.1. Any soil hazard is considered “severe” and should be corrected immediately.

|Table 2.4 Soil Sample Results |

|Sample #|Location of Bare Soil Area |Approximate Area in |No sample due |Hazard? |Lead Level in |

| | |Square-Feet |to snow |Yes/No |parts per |

| | | | | |million |

| |House drip line Side B | | | | |

| |House drip line Side C | | | | |

| |House drip line Side D | | | | |

| |Bare Soil - child play area 1 | | | | |

| |Bare Soil - child play area 2 | | | | |

| |Bare Soil – non-play area 1 | | | | |

| |Bare Soil – non-play area 2 | | | | |

| |Garden | | | | |

| |Sand box | | | | |

| | | | | | |

| | | | | | |

EPA and HUD lead hazard levels: Soil at 1,200 ppm or more. Child play areas and gardens at 400 ppm or more. BRL = below reporting limits.

7 Lead in Water Sampling

Lead can leach into water when it moves through older pipes and plumbing fixtures that have lead in them. Lead sources and lead levels can be different even in homes next door to each other. That is why it is important to identify and remove any lead sources in each household.

Your water was tested for lead. Several small samples were taken to see what you might be exposed to when drinking water straight from the tap (faucets). Ten larger samples were taken to help identify if your services line or home pipes/solder may be adding lead to your water. The results in Table 2.6 below show if and where lead pipes or fixtures might be located in your home.

|Table 2.5 Pre-Water Sample Collection Verification |Yes |No |

|What is the source of household water supply? 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.)? | | |

|Table 2.6 Water Sample Results |

|Sample Number |Location |Is lead present in |Does sample exceed EPA |Results* |

| | |sample? |drinking water levels? |Milligrams per Liter (mg/L) |

|KF A1 |Kitchen faucet | | | |

|KF A2 |Kitchen faucet | | | |

|KF A3 |Kitchen faucet | | | |

|KF A4 |Kitchen faucet | | | |

|KF A5 |Kitchen faucet | | | |

|KF A6 |Kitchen faucet | | | |

|KF A7 |Kitchen faucet | | | |

|KF A8 |Kitchen faucet | | | |

|KF A9 |Kitchen faucet | | | |

|KF A10 |Kitchen faucet | | | |

| |Faucet First Draw Samples | | | |

|KF P1 |Kitchen Faucet | | | |

|KF P1 |Kitchen Faucet | | | |

|BF P1 |Bath Sink faucet | | | |

|BF 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/L

N/D-Not Detected

Samples above EPA reporting limit in Bold

Recommendations for this address based on water sampling

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 water of the home, 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, per manufacturer’s recommendations. Flush unfiltered water (through the filter bypass). See Appendix G for Information about Water Filters fact sheets and website link.

• Continue to use a water filter meeting NSF-certified standards (NSF 53). Water filtration MUST be used per manufacturer’s recommendation including recommended intervals to change filter. 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.

• Use only bottled water for drinking, making baby formula, cooking, and for rinsing fruits and vegetables if you have children under age 6, are pregnant, or are breastfeeding (see enclosed Lead Fact Sheet).

• 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.

Hose bibs (outside faucets) and laundry faucets are not required by plumbing code to be “lead-free” as they are 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:

[pic]

8 Positive XRF Readings

The table in Appendix D identifies all of the painted surfaces that tested positive for lead paint by XRF. Appendix C explains how to interpret this table, while Appendix E contains all positive and negative XRF testing results. The paint condition at the time of testing was determined to be either “intact” or “deteriorated”. All painted components in deteriorated condition testing positive for lead represent a lead paint exposure hazard and are listed in Table 2.1. All deteriorated lead based paint conditions should be corrected immediately. Lead paint determined to be intact at the time of testing may become a lead hazard in the future and will require routine monitoring as recommended in Section 8.0. Use lead safe work practices every time a lead paint surface is disturbed.

The XRF device (serial #XXXXX) used to conduct this investigation was used in accordance with the manufacturer’s operating procedures and field operation guidance. The XRF was used in accordance with the Niton XLp-300A Performance Characteristic Sheets, which are included in Appendix F.

9 Non-Typical Building Components and Personal Property Testing Results

It may be possible that the Consumer Product Safety Commission has announced a recall on a personal item that has tested positive for lead and was reported in this section. The Commission Recall Hotline is 800-638-2772. The website address is , where lead-contaminated items can be researched.

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. Items included on this list may not be remediated with the use of federal funding.

|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.

• 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

• 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.

10 Sampling Protocols

The investigator used one or more of the following protocols to sample paint chips, dust and/or soil: U.S. Department of Housing and Urban Development Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing; U.S. Environmental Protection Agency Guidance on Residential Lead-Based Paint, Lead-Contaminated Dust, and Lead-Contaminated Soil; U.S. Environmental Protection Agency Residential Sampling for Lead: Protocols for Dust and Soil Sampling, Report Number EPA 747-R-95-001; ASTM E1727 Standard Practice for Field Collection of Soil Samples for Lead Determination by Atomic Spectrometry Techniques; and ASTM E1728 Standard Practice for Field Collection of Settled Dust Samples Using Wipe Sampling Methods for Lead Determination by Atomic Spectrometry Techniques.

Dust wipe and soil samples were analyzed by the Michigan Department of Health and Human Services/Trace Metals Laboratory, located at

3335 Martin Luther King Jr. Blvd.,

Lansing MI 48909

(517-335-9490)

The Trace Metals Laboratory meets the requirements of the National Lead Laboratory Accreditation Program (NLLAP) and EPA. It has demonstrated the capability to accurately analyze dust and soil samples for lead. The lab is required to undergo on-site audits and to perform successfully on a continuing basis in the Environmental Lead Proficiency Analytical Testing (ELPAT) Program. ELPAT is a laboratory performance proficiency testing program mandated by the American Industrial Hygiene Association. The lead laboratory reported the dust wipe sample results on DATE, the soil samples on DATE and the water samples on DATE.

Water samples were collected according to the Michigan Department of Health and Human Services Protocol for Collecting Residential Drinking Water Samples for Lead Analysis. Water samples were analyzed by Michigan Department of Environmental Quality Drinking Water Laboratory using Lead/Copper for corrosion control test on DATE, 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:

Name

Address

Phone

3.0 Project Limitations, Difficulties, and Excluded Components

This 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 |

| | | |

| | | |

| | | |

| | | |

| | | |

| | | |

| | | |

4.0 Site Information

General Property Description: Describe the site, date of construction, construction type, owner occupied, rental and number of units, general condition, outbuildings, neighborhood, neighboring structures, street traffic and other related items.

4.1 Building Condition

The purpose of the building condition survey is to document and evaluate whether the building is in good enough condition to justify the lead hazard control corrective action options. Any column marked “yes” represents a major condition that needs to be corrected before lead hazard control actions can be followed. This information provides the investigator with insight into possible causes of existing or future paint or substrate deterioration and may also provide clues about how a child was exposed to lead. For example, a roof in disrepair should be noted since moisture can cause paint deterioration. The Water Risk Factors identify sources and potential areas of concerns regarding the home’s faucets, plumbing and service line.

|Table 4.2 Building Condition |Yes/No |

|Is roof missing parts of surface covering? | |

|List all locations: | |

|Does the roof have holes or large cracks? | |

|List all locations: | |

|If present, are gutters or downspouts broken? | |

|Where? | |

|Are chimney blocks or masonry joints cracked, with loose or missing components, out of plumb or otherwise deteriorated? Explain: | |

|Do exterior or interior walls have large cracks, or damage requiring more than routine painting? | |

|List all locations: | |

|Is more than a ‘very small’ amount of paint in a room deteriorated? | |

|Is exterior siding missing components? | |

|List all locations: | |

|Are there water stains on interior walls or ceilings? | |

|List all locations: | |

|Are plaster walls or ceilings deteriorated? List all locations: | |

|Are there two or more windows or doors missing, broken or boarded up? | |

|List all locations: | |

|Does the porch or steps have major cracks, missing materials, structural leans, or is it visibly unsound? | |

|List all locations: | |

|Does the foundation have damage, structural leans or is it visibly unsound? | |

|Explain: | |

|Is bathtub cast iron, porcelain or old? Does the child bathe in it? | |

|Test with XRF? | |

|Is lavatory cast iron, porcelain or old? | |

|Test with XRF? | |

|Is kitchen sink cast iron, porcelain or old? | |

|Test with XRF? | |

|Does the home have lead or copper pipes soldered with lead? | |

|Test joints of copper pipes with XRF: | |

|Are there ceramic tiles in bath or kitchen? | |

|Test with XRF? | |

|Has there been any recent water damage in the home? | |

|Location: | |

|Were any external renovations done on a neighboring property? Repainting, remodeling, renovation, window replacement, sanding, scraping | |

|or power washing painted surfaces inside or outside of the home? | |

|Were any home renovations done to your home within the past year? | |

| | |

|If yes, where? | |

|What was done? | |

|When? | |

|Was the household given an information booklet about lead? | |

|Who did the work? | |

|Company name: Contractor license number: | |

|Phone: Address: | |

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

|Are you or the landlord planning any landscaping activities? | |

|Where? What type? | |

| Is building debris stored in the yard? If yes, where? | |

|Have nearby buildings or structures (bridge, water tower, homes, etc.) recently been repainted, demolished or burned? Specify: | |

|Are vinyl mini blinds present? Does child have access? | |

|Test with XRF? | |

|Date of construction of the residence: | |

|Has there been any lead testing of the property to your knowledge or within the previous year? If yes, ask for report. | |

|Water Risk Factors and Plumbing Condition | |

|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: | |

|TABLE 4.3 FAUCET AND FIXTURE STATUS |

|Location |Material(s) |Condition |Installed 2014 and |Replace |

| | | | |certification is verified |Y/N |

| | | | | | |

| | | | | | |

5.0 Paint Condition

The purpose of the visual assessment is to locate potential interior and/or exterior lead paint hazards. . The investigator conducts a visual assessment of all rooms, as well as examining exterior painted surfaces such as fences, garages, storage sheds, and outbuildings that are part of the residential property and built before 1978. The result is a complete inventory of the location and approximate size of each potential lead paint hazard.

|Table 4.3 Paint Condition |

|Building Component |Deteriorated Paint |

|Children’s Habits and Behavioral Factors |

|Do 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 |Primary Location Where |Primary Location Where |

| | | |Child Eats |Child Plays Indoors |Child Plays Outdoor |

|Child 2 | | | | | |

|Child 3 | | | | | |

|Child 4 | | | | | |

|Child 5 | | | | | |

|Child 6 | | | | | |

|Child 7 | | | | | |

|Interview Question |Interviewee Response |

|Family Use Patterns |

|Which 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? | |

|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 |

7.0 Re-Evaluation and Monitoring Schedule

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

7.1 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.

7.2 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.

7.3 Methods to Reduce Exposure to Lead Hazards

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.

8.0 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 leadsafe

HUD – Office of Lead Hazard Control Healthy and Homes offices/lead

U.S. Environmental Protection Agency lead

National Safety Council 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

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.

9.0 Inspector Certification

The 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 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

10.0 Representative Photographs

11.0 Supplemental Information

11.1 Sampling Procedures

11.1.1 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:

Name

Address

Phone

11.1.2 Soil Sampling

Soil samples, if deemed appropriate by the Risk Assessor, were collected following HUD guidelines from areas 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/( 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.

11.1.3 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).

11.1.4 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.

11.1.5 Water Sampling

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

12.0 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 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.

13.0 Appendices

13.1 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.

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

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).

14.0 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 |1.0 |

| |Concrete Drywall |1.0 |

| | |1.0 |

| |Metal |1.0 |

| |Plaster |1.0 |

| |Wood |1.0 |

Page 1 of 4

BACKGROUND INFORMATION

EVALUATION DATA SOURCE AND DATE:

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 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:

15.0 Housing Component Identification

16.0 Floor Plans / Site Map

Insert a drawing of the floor plan for each level of the structure - include sides ABCD, all windows, doors, stairs, porches, etc. Label each room by number and use (i.e., Room 1 – Child’s bedroom). Label the locations of dust wipe samples collected. Make legend. Use one page for each floor.

Floor Plans – Second Floor

Floor Plans – Basement

Site Plan

Insert drawing of all structures, sheds, play areas, gardens, driveways, fence lines and bare soil areas. Label North, sides ABCD and mark the locations of the soil samples collected. Designate where soil is positive. If a building on another property abuts the property, include it here.

Site Map

-----------------------

[?]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[pic]ABW using the recommended inconclusive ranges or thresholds for specific XRF instruments. The report may be downloaded at .

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

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