summary report - Spokane Public Facilities District

Transcription

GOOD-FAITH REGULATED AND HAZARDOUS
MATERIALS ASSESSMENT
FOR
C.I. SHENANIGANS RESTAURANT
LOCATED AT
332 NORTH SPOKANE FALLS COURT
SPOKANE WASHINGTON 99201
Project No: 12-074.02
Prepared for
Spokane Public Facility District
720 West Mallon Avenue
Spokane, WA 99201
(509) 279-7135
Prepared By
Mountain Consulting Services LLC
9922 E. Montgomery Drive, Suite 9
Spokane Valley, WA 99206
(509) 924-9236
Mountain Consulting Services, LLC
PROJECT NO: 12-074.01
GOOD FAITH HAZMAT SURVEY
CONTENTS
REPORT SUMMARY ..............................................................................................Section 1
GOOD FAITH ASBESTOS SURVEY......................................................................Section 2
LEAD MATERIALS INVESTIGATION ....................................................................Section 3
LIMITED OTHER HAZARDOUS MATERIALS INVESTIGATION ..........................Section 4
APPENDICES
A:
B:
C:
D:
E:
F:
G:
H:
October 25, 2012
Certifications and Accreditations
Asbestos Bulk Sample Analysis Report
Asbestos Bulk Sample Location Drawings
XRF Assay Data & Calibrations
XRF HUD Data (depicting paint colors)
Lead Bulk Paint Sample Location Drawings
Lead Paint and Analysis Reports
Site Photographs
TOC
SECTION 1
REPORT SUMMARY
March 21, 2012
REG/HAZ MATERIALS ASSESSMENT
REGULATED AND HAZARDOUS MATERIALS SURVEY
FOR C.I. SHENANIGANS RESTAURANT
LOCATED AT 332 NORTH SPOKANE FALLS COURT
SPOKANE, WASHINGTON
REPORT SUMMARY
Mr. David Gebhardt, representing Spokane Public Facility District contracted Mountain Consulting
Services, LLC (Mountain Consulting) to conduct a good-faith regulated and hazardous materials
survey for C.I. Shenanigans Restaurant located at 332 North Spokane Falls Court.
This project was conducted to facilitate the planned demolition of the structure. No prior survey
documentation was provided for this structure. The services conducted for this structure included:
good-faith asbestos containing materials survey; good-faith lead materials & lead based paints (LBPs)
survey, A follow-up visit will include a lead waste characterization sample (TCLP), Destructive
investigation to detect the presence of Asbestos hidden in walls and cavities; and, an
investigation for the presence of other potentially hazardous materials (Lighting) that may be
impacted by the proposed Demolition of this structure.
The field investigation activities for this structure were conducted on October 10&11, 2012 by
Mountain Consulting personnel Mr. David A. Jones.
SITE DESCRIPTION
The building included for this project is located north east of the Double Tree Inn and Just South of
the Spokane River. The closest main arterial is Spokane Falls BLVD to the South. The property is
bounded by commercial properties to the south, east and west and the Spokane River to the North.
C.I. Shenanigans is a brick and wood framed single story structure built on a concrete foundation.
The structure was used as a restaurant and brewery.
Interior finishes are varnished wood, painted drywall and ceramic tile over drywall. Floorings include
carpeting and ceramic tile. Exterior finishes are exposed concrete or brick walls, metal clad window
units, metal entry doors and a built up tar roof structure.
October 25, 2012
S-1
ASBESTOS CONTAINING MATERIALS SUMMARY
Mountain Consulting performed non destructive bulk materials testing of suspect building materials to
determine the presence of asbestos minerals. It should be noted that the restaurant was occupied at
the time of this inspection and a follow up visit will be performed by Mountain Consulting after the
property is vacated. Mountain Consulting collected seventeen (17) bulk samples from seventeen (17)
different homogeneous suspect building materials associated with the structure. Laboratory analysts
sub-divided two (2) submitted samples, resulting in a total of nineteen (19) samples analyzed for this
project.
No sampled homogeneous building materials collected from the structure were found to contain
greater than one percent (>1%) asbestos by laboratory analysis (Regulated ACM):
Microscopic examination of samples collected from the following suspect building materials did not
detect the presence of asbestos minerals (ACM-Free):











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

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
Grey Brick Mortar (Sample 01)
Grey Concrete Foundation (Sample 02)
Brown Rock Mortar (South Side) (Sample 03)
Black 3-Tab Roofing (Shed) (Sample 04)
Black Tar Paper (Shed) (Sample 05)
Drywall/Joint Compound (Sample 06, 06A, 15& 15A)
Off White/Green Cement Coating on Exterior Conduit (Sample 07)
Built-Up Tar Roofing (Sample 08)
Silver Silicone Vent Sealant (Roof Ducting) (Sample 09)
Black/Grey Roof Penetration Tar (Sample 10)
Grey Ducting Tape (Roof) (Sample 11)
24”x48’ Sheetrock Ceiling Panels (Sample 12)
Grey Ceramic Tile Grout and Mortar (Sample 13)
Dark Brown Tile Grout (Walls) (Sample 14)
Tan Panel Adhesive (Sample 16)
Off white/Brown/ Grey Ceramic Tile Grout and Mortar (Kitchen) (Sample 17)
The building owner or tenant is responsible, under OSHA regulations, to notify all maintenance and
custodial workers of the presence and location of ACM. Asbestos containing materials must be handled
and disposed of in accordance with OSHA, NESHAP, and local regulations.
LEAD CONTAINING MATERIALS SUMMARY
October 25, 2012
S-2
Mountain Consulting used a Scitec (now EDAX®) MAP 4 X-ray fluorescence (XRF) spectrum
analyzer, Serial Number M41299, for nondestructive sampling of suspect lead based paint (LBP) and
ceramic tile glazing. Mountain Consulting collected sixty nine (69) XRF assays from the structure.
Any paint films or ceramic tile glazing with lead concentrations of 1.0 mg/cm² (milligrams per square
centimeter) or greater were classified as regulated LBP or lead materials. In addition, the substrate
condition was visually assessed at each assay test site. Any paint coating or glazing that produced
results below the 1.0 mg/cm² threshold were bulk sampled using destructive methods.
All suspect paint and ceramic tile glaze coatings associated with the XRF assay testing portion
of this survey, produced results below the HUD-XRF regulated lead coating determination
limit of 1.0 mg/cm².
Mountain Consulting performed bulk paint and ceramic tile glaze sampling for this project.
Confirmatory bulk coating samples were collected from components that produced negative XRF
assay results. The results of the confirmation bulk coating samples collected for this project are listed
as follows:
Sample Number
Sample Description
1.0%wt
PPM
PPM
12-074.LBP01
Green Paint on Sheetrock
<0.010 %wt
<100 PPM
12-074.LBP02
Gold/Brown Varnish on Wood
<0.010 %wt
<100 PPM
12-074.LBP03
Brown Paint On Wood
<0.010 %wt
<100 PPM
12-074.LBP04
Yellow/Off White on Sheetrock
<0.015 %wt
<150 PPM
12-074.LBP05
Black on Wood Doors
<0.080 %wt
<800 PPM
12-074.LBP06
6x6 tan Ceramic Tile
<0.011 %wt
<110 PPM
<0.010 %wt
<100 PPM
<0.029 %wt
<290 PPM
Bath
12-074.LBP07
Brown Ceramic Tile
Floor
12-074.LBP08
Grey Paint on Cement Floor
Brewery
October 25, 2012
S-3
12-074.LBP09
White Paint On Wood Doors
<0.018 %wt
<180 PPM
12-074.LBP10
White paint On Drywall
<0.026 %wt
<260 PPM
12-074.LBP11
White Paint On Metal Doors &
<0.055 %wt
<550 PPM
Frames
12-074.LBP12
Black Paint on Metal Handrails
<0.014 %wt
<140 PPM
12-074.LBP13
Red/Brown Paint On Metal
<0.010 %wt
<100 PPM
<0.029 %wt
<290 PPM
<0.060 %wt
<600 PPM
Doors/Frames
12-074.LBP14
Yellow Paint On Metal Post
Exterior
12-074.LBP15
Brown Paint On Metal Post
Exterior
12-074.LBP16
Brown Paint On Concrete Foundation
<0.011 %wt
<110 PPM
12-074.LBP17
Brown Coating On Exterior Wood
<0.098 %wt
<980 PPM
12-074.LBP18
Red paint on Exterior of Storage Shed
<0.043 %wt
<430 PPM
Note: 1.0%wt = 10,000 parts per million; mg/Kg = ppm.
The bulk paint samples collected for this project were submitted following proper chain of custody
procedures to EMSL Analytical, Inc. located in Cinnaminson, New Jersey for analysis by methods
SW846, 3050B and 7420*. EMSL is an ACGIH accredited analytical laboratory.
All coatings identified as containing greater than >100 ppm lead from bulk paint analysis, proven LBP
by XRF or assumed lead containing associated with the structure are regulated by Federal and/or
Washington State regulations. Explanations of regulations are detailed as follows:
The Occupational Safety and Health Administration (OSHA) 29 CFR 1926.62 and the Washington
State Industrial Safety and Health Administration (WISHA) WAC 296-155 lead in construction
standards do not define a definition for LBP, but do establish safe airborne exposure limits for
employees working with lead containing materials including paint films by permissible exposure limit
(PEL).
October 25, 2012
S-4
So if any coating contains lead above the limit of detection by Flame Atomic Absorption (FAA)
analysis (>0.01 %wt), proven to be a LBP by XRF testing or assumed to be a LBP then abatement, or
demolition contractors must demonstrate worker health and safety due diligence.
This would include lead awareness training for all effected employees, establishment of proper
employee personnel protective equipment (PPE), proper demarcation of effected work area, and
performance of negative exposure assessment (NEA) lead air monitoring prior to downgrading any
established PPE.
The Washington State Dangerous Waste Regulation (WAC 173-303) requires that lead containing
materials with a lead content above 100 ppm threshold or proven LBP by XRF testing be treated as
hazardous waste, until toxic characterization leeching procedure (TCLP) bulk waste stream sampling
prove otherwise. The TCLP lead characterization threshold is 5 ppm.
Mountain Consulting will gather a TCLP for the structure on a subsequent visit.
OTHER HAZARDOUS MATERIALS SUMMARY
On a subsequent visit Mountain Consulting will performed an investigation of C.I Shenanigans to
determine the presence of specific hazardous materials and hazardous conditions present with the
structure.
The investigation will target the following potential hazardous building components:

Electrical Lighting

Mercury Containing Building Components

Polychlorinated Biphenyls (PCB's)
LIMITING CONDITIONS
A complete discussion of survey parameters and applied methods are enclosed in the following
sections of this report. Only general conclusions should be made from the information provided
within this summary.
During this regulated/hazard assessment, Mountain Consulting endeavored to observe, inventory, and
sample (if appropriate) potentially regulated and or hazardous materials associated with the structure
included for demolition activities.
October 25, 2012
S-5
During demolition activities for the included structure, if any unidentified suspect materials are
encountered that were not observed during this assessment may warrant additional sampling, analysis
or assumption.
CLOSURE
The results, conclusions, and recommendations presented in this report were prepared following our
inspection of suspected materials at the subject property. Methods used by Mountain Consulting for
this study are consistent with the standard of care and professionalism normally exercised by
consultants in the environmental science and engineering fields.
The Client acknowledges that Mountain Consulting has been retained for the sole purpose of assisting
the Client in identifying Regulated and Hazardous Materials, if any, associated with the subject
facility. It is agreed that Mountain Consulting has assumed responsibility only for performing this
assessment and presenting this report and conclusions to the Client.
The Client acknowledges that Mountain Consulting is not acting as an “agent” for the Client, or any
other user or entity, for work associated with any regulated and/or hazardous materials.
Mountain Consulting does not act or have authority to act for or in place of the Client or its
successors or assigns. Mountain Consulting does not represent the Client nor does it authorize or
allow any construction, renovation, remodeling, maintenance, repair, or demolition work by
performing this assessment. Mountain Consulting is not a licensed contractor or licensed asbestos
contractor.
October 25, 2012
S-6
SECTION 2
GOOD-FAITH ASBESTOS CONTAINING
MATERIALS SURVEY
October 25, 2012
ASBESTOS CONTAINING MATERIALS SURVEY – TABLE OF CONTENTS
1.0
INTRODUCTION ..........................................................................................................1
2.0
SCOPE OF WORK ......................................................................................................1
3.0
ASSESSMENT SURVEY PARAMETERS ...................................................................2
3.1 HOMOGENEOUS AREAS ...........................................................................................2
3.2 BULK SAMPLING .....................................................................................................2
3.3 LABORATORY AND ANALYTICAL METHODS..................................................................3
4.0
RESULTS ....................................................................................................................3
4.1
4.2
4.3
4.4
4.5
5.0
MATERIAL CONTAINING 1% OR MORE ASBESTOS .......................................................3
MATERIALS ASSUMED TO CONTAIN ASBESTOS ...........................................................4
MATERIALS WITH ASBESTOS CONCENTRATIONS OF LESS THAN 1% ..............................4
NON-ACM MATERIALS IDENTIFIED............................................................................4
MATERIALS ASSUMED NOT TO CONTAIN ASBESTOS ....................................................4
CONCLUSIONS AND RECOMMENDATIONS ............................................................5
5.1 CONCLUSIONS ........................................................................................................5
5.2 RECOMMENDATIONS................................................................................................5
APPENDICES
A:
B:
C:
H:
March 21, 2012
Asbestos Bulk Sample Analysis Report
Asbestos Bulk Sample Location Drawings
Site Photographs
TOC
PRE-DEMO ASBESTOS SURVEY
GOOD-FAITH REGULATED AND HAZARDOUS MATERIALS SURVEY FOR C.I.
SHENANIGANS RESTAURANTLOCATED AT 332 NORTH SPOKANE FALLS COURT
IN SPOKANE, WASHINGTON
ASBESTOS CONTAINING MATERIALS SURVEY REPORT
1.0
INTRODUCTION
Mr. David Gebhardt, representing Spokane Public Facility District of Spokane, Washington
contracted Mountain Consulting Services, LLC (Mountain Consulting) to conduct a good-faith pre
demo asbestos survey for C.I. Shenanigans Restaurant located at 332 North Spokane Falls Court in
Spokane, Washington.
This project was conducted to facilitate the planned Demolition of the single story brick and wood
structure. No prior survey documentation was provided.
Mr. David A. Jones, EPA-accredited AHERA building inspector, certification BIR-12-010, expiration
1/10/2013, conducted a field survey of the structure on October 10 & 11, 2012. (See Appendix A for
inspector certifications and laboratory accreditations.)
2.0
SCOPE OF WORK
The scope of work was designed to meet the requirements for asbestos inspection and due diligence
notification in the Occupational Safety and Health Administration (OSHA) Asbestos Standard (29
CFR 1926.1101), Washington Industrial Safety & Health Act (WISHA) standards (WAC 296-62077), the National Emission Standards for Hazardous Air Pollutants (NESHAP; 40 CFR 61), and
applicable portions of the Asbestos Hazardous Emergency Response Act (AHERA) and regulations
in 40 CFR 763.
The survey was conducted through visual evaluation, classification and analysis of suspected asbestos
containing materials (ACMs) used in the construction or remodeling of the surveyed structure. The
survey included the following tasks:

Visual survey and assessment of the location and condition of suspected materials.

Collection and analysis of bulk samples from suspected asbestos containing materials.
October 25, 2012
ACM - Page 1

Preparation of a report summarizing the identification and assessment of any asbestos
containing materials and material found not to contain asbestos.
3.0
3.1
ASSESSMENT SURVEY PARAMETERS
HOMOGENEOUS AREAS
Homogeneous materials are those considered to be consistent throughout an area based on color,
texture, and construction era. For the purpose of this survey, homogeneous areas were delineated
using the construction era, material composition, and material location as the primary considerations.
Material appearance, texture, size, color, and analytical results may support assumptions about each
material’s homogeneity.
3.2
BULK SAMPLING
Suspected ACMs were collected according to guidelines in 40 CFR 763.85 and were sampled to
determine the type and percentage of asbestos by volume. At least one sample was collected from
selected miscellaneous materials and at least three samples from thermal system insulation materials.
Suspect surfacing materials were sampled according to the AHERA “3/5/7 rule.”
For other types of suspect materials, or materials assumed to be non-ACM, regulations require the
on-site AHERA building inspector to determine the appropriate number of samples. The quantity of
material present, manufacturer’s labels, appearance, construction era, and inspector’s expertise were
used to determine the number of samples. A homogeneous material is considered to be an ACM if
one or more sample results are equal to or greater than 1% asbestos.
The EPA recommends that at least three samples be analyzed by polarized-light microscopy (PLM)
for the following types of materials in order to prevent false negative results (less then 1% asbestos):





Materials that contain low concentrations of asbestos fibers (less then 10%);
Materials with asbestos fibers tightly bound in a matrix;
Materials with milled asbestos fibers (fine fibers);
Materials with hand-mixed asbestos fibers; and
Materials with a combination of these characteristics.
All bulk samples must have results below 1% asbestos before the material may be classified in
accordance with AHERA rules as not being an ACM. However, if asbestos is detected in the material
at less than 1%, OSHA and WISHA worker health and safety regulations still apply.
October 25, 2012
ACM - Page 2
3.3
LABORATORY AND ANALYTICAL METHODS
Mountain Consulting performed non destructive bulk materials testing of suspect building materials to
determine the presence of asbestos minerals. It should be noted that the restaurant was occupied
when the inspection was performed and a follow up visit will be performed by Mountain Consulting
after the tenant has moved out to do a destructive investigation for Asbestos containing materials.
Mountain Consulting collected seventeen (17) bulk samples from seventeen (17) different
homogeneous suspect building materials associated with the structure. Laboratory analysts subdivided two (2) submitted samples, resulting in a total of nineteen (19) samples analyzed for this
project.
All samples were submitted for analysis to Mountain Laboratories of Spokane, Washington using
chain of custody procedures. Mountain Laboratories participates in the national voluntary laboratory
accreditation program (NAVLAP) and is a NAVLAP accredited asbestos testing laboratory,
NAVLAP code: 101890-0. All samples were analyzed to determine asbestos type and content using
PLM with dispersion staining in accordance with the following methods:
EPA
EPA 600/R-93/116, “Method for the Determination of Asbestos in Bulk Building
Materials” (July 1993).
EPA
“Interim Method for the Determination of Asbestos in Bulk Insulation Samples” (40 CFR
Part 763, Subpart F, Appendix A; May 27, 1982).
ASTM
Draft “Standard Method of Testing for Asbestos Containing Materials by Polarized Light
Microscopy” (ASTM Committee D22.05; January 14, 1988).
4.0
RESULTS
This section describes suspect materials that were found to be asbestos containing or proven to be
free of asbestos minerals. (Refer to the bulk sample analysis report in Appendix B for specific sample
composition and Appendix C for sample location drawings).
4.1
MATERIAL CONTAINING 1% OR MORE ASBESTOS
ACMs are materials proven to contain at least 1% asbestos or greater. AHERA and NESHAP
regulations distinguish between friable and nonfriable forms of ACM. A friable material is defined as
one that can be “crumbled, pulverized, or reduced to powder by hand pressure when dry.” Friability
is an indication of a material’s ability to release asbestos fibers into the air.
October 25, 2012
ACM - Page 3
Regulated ACMs are defined by NESHAP as all friable ACM and nonfriable ACM that may be
disturbed by renovation or demolition.

4.2
No sampled homogeneous building materials collected from the structure were found to contain
greater than one percent (>1%) asbestos by laboratory analysis (Regulated ACM):
MATERIALS ASSUMED TO CONTAIN ASBESTOS
No suspect building materials were ASSUMED to contain asbestos during this survey activity.
4.3
MATERIALS WITH ASBESTOS CONCENTRATIONS OF LESS THAN 1%
No homogeneous materials were proven to contain less than one percent (<1%) asbestos by
laboratory analysis during this survey activity.
4.4
NON-ACM MATERIALS IDENTIFIED
Microscopic examination of samples collected from the following suspect building materials did not
detect the presence of asbestos minerals (ACM-Free):


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
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
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Grey Brick Mortar (Sample 01)
Grey Concrete Foundation (Sample 02)
Brown Rock Mortar (South Side) (Sample 03)
Black 3-Tab Roofing (Shed) (Sample 04)
Black Tar Paper (Shed) (Sample 05)
Drywall/Joint Compound (Sample 06, 06A, 15& 15A)
Off White/Green Cement Coating on Exterior Conduit (Sample 07)
Built-Up Tar Roofing (Sample 08)
Silver Silicone Vent Sealant (Roof Ducting) (Sample 09)
Black/Grey Roof Penetration Ta (Sample 10)
Grey Ducting Tape (Roof) (Sample 11)
24”x48’ Sheetrock Ceiling Panels (Sample 12)
Grey Ceramic Tile Grout and Mortar (Sample 13)
Dark Brown Tile Grout (Walls) (Sample 14)
Tan Panel Adhesive (Sample 16)
Off white/Brown/ Grey Ceramic Tile Grout and Mortar (Kitchen) (Sample 17)
October 25, 2012
ACM - Page 4
4.5
MATERIALS ASSUMED NOT TO CONTAIN ASBESTOS
The following materials were assumed not to contain asbestos, based on manufacturers’ labels, age,
appearance, or inspector’s expertise:
Wood components – framing, walls, and cabinets.
 Glass – exterior and interior.
 Metal – structural support, furnace/ducting, and tanks.
 Fiberglass insulation – attic, walls, and pipes.

5.0
CONCLUSIONS AND RECOMMENDATIONS
Our findings are based strictly on information obtained from our site observations during survey
activities and from sample analysis. Consistent with our knowledge and understanding of
environmental regulations, particularly as they apply to the potential liabilities associated with
asbestos-containing building materials, we present the following conclusions and recommendations:
5.1
CONCLUSIONS
In accordance with regulatory protocol, all suspect materials identified as, or assumed to be, asbestos
containing must be managed as ACM until further sampling documents otherwise. The owner may
refute, by additional point-count analysis, the ACM status of materials found to contain less than 10%
asbestos. However, for materials such as vinyl tile and adhesive with concentrations between 1% and
10%, reanalysis by point counting typically does not decrease estimated concentrations enough to
justify non-ACM classification.
5.2
RECOMMENDATIONS
Regulated Asbestos Containing Material: Properly trained workers employed by a certified
asbestos-abatement contractor may work on, remove, or dispose ACM materials using wet methods,
appropriate work practices, and proper engineering controls. Depending on type of material (class I
or class II, friable or non-friable) and engineering controls used (mechanical or manual), workers need
either 8 or 32 hours of initial training and must be supervised by a competent person with 40 hours of
training. All asbestos certifications require annual refresher training.
October 25, 2012
ACM - Page 5
The materials proven to be free of asbestos minerals (ACM-Free) require no further action in regard
to asbestos regulations. These materials may be impacted without any specialized personnel training
and disposed of in a landfill that accepts standard construction debris.

It should be noted that the restaurant was occupied when the inspection was performed and a
follow up visit will be performed by Mountain Consulting after the tenant has moved out to do
a destructive investigation for Asbestos containing materials.

ACM must be handled in accordance with OSHA, NESHAP, and local regulations.

The building owner or tenant is required by OSHA regulations to notify all maintenance and
custodial workers of the presence and location of ACMs. Maintenance and custodial work
during which employees will contact but not disturb asbestos shall be performed by workers
with at least 2 hours of Class IV asbestos-awareness training.

The Spokane Regional Clean Air Agency (SRCAA), the local building department, and the local
fire department should be contacted regarding possible permit requirements.
October 25, 2012
ACM - Page 6
SECTION 3
LEAD MATERIALS INVESTIGATION
March 21, 2012
Mountain Consulting Services, LLC.
Lead Materials Survey
LEAD CONTAINING MATERIALS SURVEY – TABLE OF CONTENTS
1.0
INTRODUCTION AND SITE DESCRIPTION .............................................................1
2.0
X-RAY FLUORESCENCE TESTING .........................................................................1
2.1
2.2
2.3
2.4
3.0
Theory of X-Ray Fluorescence ............................................................................1
XRF Lead Based Paint Survey ............................................................................2
Bulk Paint Sampling ............................................................................................3
TCLP Bulk Sampling ...........................................................................................3
RESULTS ..................................................................................................................3
3.1
3.2
3.3
3.4
XRF Survey ..........................................................................................................3
Substrate Condition .............................................................................................4
Lead Containing Coatings by XRF.......................................................................4
Lead Paint Chip Sample Results .........................................................................4
4.0
RECOMMENDATIONS ..............................................................................................6
5.0
HEALTH EFFECTS OF LEAD EXPOSURE ..............................................................7
APPENDICES
A:
D:
E:
F:
G:
October 25, 2012
XRF Assay Data & Calibrations
XRF HUD Data (depicting paint colors)
Lead Bulk Paint Sample Location Drawings
Site Photographs
TOC
GOOD-FAITH REGULATED AND HAZARDOUS MATERIALS SURVEY FOR C.I.
SHENANIGANS RESTAURANT LOCATED AT 332 NORTH SPOKANE FALLS COURT
IN SPOKANE, WASHINGTON
LEAD CONTAINING MATERIALS SURVEY REPORT
1.0
INTRODUCTION
Mr. David Gebhardt, representing Spokane Public Facility District of Spokane, Washington
contracted Mountain Consulting Services, LLC (Mountain Consulting) to conduct lead materials
and lead based paint (LBP) survey for C.I. Shenanigans Restaurant located at 332 North Spokane
Falls Court, Spokane, Washington.
This project was conducted to facilitate the planned Demolition of the brick and wood framed
restaurant structure. No prior survey documentation was provided.
Mr. David A. Jones, Certified Washington State Lead Risk Assessor; Certification Number: 0567;
Expiration Date: February 16, 2013 conducted the fieldwork portion of the survey on October 10 &
11, 2012. (See Appendix A for inspector certifications.)
The survey process uses a surface-by-surface measurement of suspected lead based paint (LBP) film
by X-ray fluorescence (XRF). This survey complies with all applicable state and federal regulations
and is provided to help the property owner determine the impact of lead containing material hazards
for the scheduled Demolition project.
2.0
2.1
X-RAY FLUORESCENCE TESTING
THEORY OF X-RAY FLUORESCENCE
Fluorescence can be defined as the emission (giving off) of electromagnetic waves by an atom when
something excites it. An example of fluorescence is the visible light or glow given off by certain
paints when a black light (a purple-looking ultraviolet light) is shone on them. This is the concept
used in an X-ray lead-paint detector. The detector contains a source of radiation, a hermetically
sealed radioactive isotope of cobalt (Co 57) about the size of an aspirin tablet. The radiation is used to
excite the atoms of a painted surface. As the surface returns to its normal state, it fluoresces.
October 25, 2012
Lead Page 1
The detector works something like a radio. Radio stations are assigned different frequencies,
allowing the listener to select a single station.
Lead fluoresces at a known frequency and, like a radio; the detector can be tuned to it. The
fluorescence is sensed by the detector and displayed on a digital readout. The concentration of lead in
the paint is expressed as mass (milligrams) per unit area (square centimeter).
2.2
XRF LEAD BASED PAINT SURVEY
Mountain Consulting collected sixty five (65) XRF assays from the building coatings using the
procedures outlined in the EPA’s Standard Operating Procedures for Measurement of Lead in Paint
using the Scitec Map-3 X-Ray Fluorescence Spectrometer (EPA 600/8-91/214; 1991), the revised
Chapter 7 (November 1997) of HUD’s Guidelines for the Evaluation and Control of Lead-Based
Paint Hazards in Housing, and the Performance Characteristic Sheet for the Scitec MAP-4.
Components tested during this survey were averaged using the HUD averaging system included in the
ARM software used to generate the HUD tables located in Appendix E of this report.
Mountain Consulting used the Scitec (now EDAX®) MAP 4 XRF spectrum analyzer (Serial No:
M41299) to perform nondestructive sampling for suspect LBP and ceramic tile glaze coatings.
Over time, the instrument’s radiation source “decays,” requiring longer times to reach standard
precisions. Because of this, Mountain Consulting performs quality-control checks before, during, and
after collecting data (depending on the length of the survey) to ensure that the MAP 4 is functioning
properly and that assay results truly reflect lead levels at the sample points.
The instrument is calibrated using a standard from the National Institute of Standards and Technology
backed by a common building material. Results of the averaged calibration readings are compared to
the factory calibration results before the instrument was shipped to the owner.
Morning calibration results are plotted on a graph to detect trends that might indicate that the
instrument is not working properly. If the result of a daily calibration check differs from the factory
average by more than 0.2 mg/cm², the instrument is not functioning properly or the radiation source
may be too weak to provide accurate readings. See Appendix D for daily XRF calibration results.
An unlimited-test-length measurement was used to determine the lead concentration during the assays
of each identified painted surface. The unlimited-length assay has an average precision
(95% confidence) of about 0.2 mg/cm². The action level for this study was set at the standard of
1.0 mg/cm².
The unlimited-length test mode allows the inspector to continue to collect data until the action level
(1.0 mg/cm²) is met within the set precision limit of the device. If the desired results are not achieved
October 25, 2012
Lead Page 2
within a reasonable time, the inspector can end the assay, and the analyzer will report it as
inconclusive.
In conjunction with the Advanced Report Manager software, the MAP 4 produces a comprehensive
report based on the assay data. Each sample is given a unique code that identifies the room number,
wall number, component tested, substrate of the component, condition of the paint tested, substrate
condition, and amount of lead detected in milligrams per square centimeter (mg/cm²).
2.3
BULK COATING SAMPLING
Destructive bulk paint and ceramic tile glazed material sampling was conducted by Mountain
Consulting for suspect coatings that produced negative results from XRF screening. Mountain
Consulting collected eighteen (18) representative samples from majority component painted surfaces
and ceramic tile materials that produced XRF results of less than 1.0 mg/cm². The samples were
submitted following proper chain-of-custody procedures to EMSL Analytical in Cinnaminson, New
Jersey, for analysis by method SW846, 3050B and 7420*. EMSL Analytical, Inc. (phone 1-800-2203675) is accredited by the American Industrial Hygiene Association. The accreditation certificate is
provided in Appendix A.
2.4
TCLP BULK SAMPLING
The Washington State Dangerous Waste Regulation (WAC 173-303) requires that lead containing
materials with a lead content above 100 ppm threshold be treated as hazardous waste, until toxic
characterization leeching procedure (TCLP) bulk waste stream sampling prove otherwise. The TCLP
lead characterization threshold is 5 ppm (parts per million).
3.0
3.1
RESULTS
XRF LBP SURVEY
LBP is defined by EPA regulations under Title X (Residential Lead Based Paint Hazard Reduction
Act of 1992) as containing lead concentrations above 1.0 mg/cm² when measured by a portable XRF
instrument or 0.5% by weight (5,000 parts per million, or ppm) when measured by laboratory
analysis. Since this project is for demolition and not HUD target housing HUD regulations do not
apply, although the procedures for XRF testing can be utilized effectively for lead positive screens.
Unfortunately negative XRF screenings for Renovation or demolition project do require additional
testing protocol.
October 25, 2012
Lead Page 3
The Occupational Safety and Health Administration (OSHA) does not have a definition for LBP, if
any amount of lead is present in a material, OSHA worker health-and-safety due diligence does apply.
Positive Results – A “positive” result refers to a sample that has a lead concentration greater than or
equal to 1.0 mg/cm² by XRF analysis. No positive XRF assay results were recorded during this lead
survey.
Inconclusive Results – “Inconclusive” refers to a sample that has a lead concentration from
0.80 mg/cm² through 1.20 mg/cm². No inconclusive assay results were recorded during this
investigation.
Negative Results – A “negative” result refers to a sample that has an average lead concentration of
less than 1.0 mg/cm² by XRF analysis. Negative results indicate only that lead levels are below the
action level by HUD regulations, within the precision limit of the machine. A “negative” XRF result
does not mean that lead is not present under OSHA and WISHA regulations. See tables of XRF
Survey Results in Appendix D for a listing of all negative assays. Majority paint and ceramic tile
glaze coatings that produced negative XRF assay results were bulk tested to verify actual lead
content. Refer to Section 3.4 for the results of lead bulk sampling analysis.
3.2
SUBSTRATE CONDITION
Mountain consulting made a visual assessment of the coated sub straights throughout the structure
for this project. Substrate conditions were satisfactory for all tested coatings.
3.3
LEAD CONTAINING COATINGS BY XRF
All suspect paint and ceramic tile glaze coatings associated with the XRF assay testing portion of this
survey, produced results below the HUD-XRF regulated lead coating determination limit of 1.0
mg/cm². Refer to Section 3.4 for the results of bulk coating/materials testing and analysis
findings.
3.4
BULK PAINT SAMPLE RESULTS
The Occupational Safety and Health Administration (OSHA) and the Washington State Department
of Safety and Health (DOSH) do not define by regulation a definition for lead based paints.
The Housing & Urban Development (HUD) Federal Regulation action limit for the presence of lead
by bulk paint chip analysis is 0.5 percent by weight (%wt.) for target housing only and therefore does
not apply to Renovation or demolition projects.
October 25, 2012
Lead Page 4
Mountain Consulting performed bulk paint sampling for this project. Bulk coating samples were
collected from majority coatings that produced negative XRF assay results.
The results of the bulk paint and ceramic tile glazed material samples collected for this project are
listed as follows: [Refer to Appendix H for laboratory report and chain of custody].
Sample Number
Sample Description
1.0%wt
PPM
PPM
12-074.LBP01
Green Paint on Sheetrock
<0.010 %wt
<100 PPM
12-074.LBP02
Gold/Brown Varnish on Wood
<0.010 %wt
<100 PPM
12-074.LBP03
Brown Paint On Wood
<0.010 %wt
<100 PPM
12-074.LBP04
Yellow/Off White on Sheetrock
<0.015 %wt
<150 PPM
12-074.LBP05
Black on Wood Doors
<0.080 %wt
<800 PPM
12-074.LBP06
6x6 tan Ceramic Tile
<0.011 %wt
<110 PPM
<0.010 %wt
<100 PPM
<0.029 %wt
<290 PPM
Bath
12-074.LBP07
Brown Ceramic Tile
Floor
12-074.LBP08
Grey Paint on Cement Floor
Brewery
12-074.LBP09
White Paint On Wood Doors
<0.018 %wt
<180 PPM
12-074.LBP10
White paint On Drywall
<0.026 %wt
<260 PPM
12-074.LBP11
White Paint On Metal Doors &
<0.055 %wt
<550 PPM
Frames
12-074.LBP12
Black Paint on Metal Handrails
<0.014 %wt
<140 PPM
12-074.LBP13
Red/Brown Paint On Metal
<0.010 %wt
<100 PPM
Doors/Frames
October 25, 2012
Lead Page 5
12-074.LBP14
Yellow Paint On Metal Post
<0.029 %wt
<290 PPM
<0.060 %wt
<600 PPM
Exterior
12-074.LBP15
Brown Paint On Metal Post
Exterior
12-074.LBP16
Brown Paint On Concrete Foundation
<0.011 %wt
<110 PPM
12-074.LBP17
Brown Coating On Exterior Wood
<0.098 %wt
<980 PPM
12-074.LBP18
Red paint on Exterior of Storage Shed
<0.043 %wt
<430 PPM
Note: 1.0%wt = 10,000 parts per million; mg/Kg = ppm.
Components with a lead content greater than 100 ppm are a potential lead hazard. Lead hazards
could emerge if the paint or ceramic tile glaze coatings deteriorate or are impacted by Renovation or
demolition. Worker Health & Safety Lead Safe Work Practices should be employed for working with
or around these components.
4.0
RECOMMENDATIONS
All coatings/materials identified as containing greater than 100 parts per million (ppm) lead from bulk
paint or ceramic tile glazed material analysis or proven LBP by XRF associated with C.I. Shenanigans
Restaurant are regulated by Federal and/or Washington State regulations. Explanations of regulations
are detailed as follows:
The Occupational Safety and Health Administration (OSHA) 29 CFR 1926.62 and the Washington
State Industrial Safety and Health Administration (WISHA) WAC 296-155 lead in construction
standards do not define by regulation a definition for lead based paints, but do establish safe airborne
exposure limits for employees working with lead containing materials to include paint films by PEL
(permissible exposure limit).
So if any material contains lead above the limit of detection by Flame Atomic Absorption (FAA)
analysis (>0.01 %wt), proven to be a LBP by XRF testing or assumed lead containing then
abatement, Renovation or demolition contractors must demonstrate worker health and safety due
diligence.
October 25, 2012
Lead Page 6
This would include lead awareness training for all effected employees, establishing proper employee
personnel protective equipment (PPE), proper demarcation of effected work areas and performance
of negative exposure assessment (NEA) lead air monitoring prior to downgrading any PPE.
5.0
HEALTH EFFECTS OF LEAD EXPOSURE
For information concerning lead based paint and the health effects of lead, contact the
National Lead Information Clearing House at 1-800-424-Lead.
Lead can be absorbed into the body by inhalation (breathing) and ingestion (eating or drinking).
Inhaling or ingesting even small amounts of lead can be harmful.
Lead poisoning can occur at high exposure concentrations (acute) or at low exposure concentrations
over a long period of time (chronic) and can cause either temporary or permanent damage. Lead is a
poison that accumulates in the blood, bones, and organs, including the kidneys, brain, and liver. It
stays in the bones for decades and may be released slowly over time to cause toxic effects. An
increasing blood-lead level usually means that there has been recent exposure and that lead is building
up in the body faster than it is being eliminated. The early effects of lead poisoning are not specific
and resemble flu-like illnesses.
Cumulative exposure to lead, which is typical in home settings, may result in damage to the blood,
nervous system, kidneys, bones, heart, and reproductive system and contributes to high blood
pressure. It is especially toxic to young children and women of childbearing age.
The symptoms of lead poisoning include the following:










Headache
Poor appetite
Dizziness
Irritability or anxiety
Constipation
Pallor
Excessive tiredness
Numbness
Metallic taste in the mouth
Muscle or joint pain or soreness
October 25, 2012









Lead Page 7
Sleeplessness
Hyperactivity
Weakness
Reproductive difficulties
Nausea
Fine tremors
Insomnia
“Lead line” on the gums
“Wrist drop” [muscle weakness]
Project No. 12-031.02-B
Reg & HazMat Survey
APPENDIX A
CERTIFICATIONS AND ACCREDITATIONS
October 25, 2012
Reg & HazMat Survey
APPENDIX B
ASBESTOS BULK SAMPLE
ANALYSIS REPORT
October 25, 2012
Reg & HazMat Survey
APPENDIX C
ASBESTOS BULK SAMPLE
LOCATION DRAWINGS
October 25, 2012
Reg & HazMat Survey
APPENDIX D
XRF ASSAY DATA & CALIBRATIONS
October 25, 2012
Reg & HazMat Survey
APPENDIX E
XRF HUD DATA
(DEPICTING PAINT COLORS)
October 25, 2012
Reg & HazMat Survey
APPENDIX F
LEAD BULK PAINT SAMPLE
LOCATION DRAWINGS
October 25, 2012
Reg & HazMat Survey
APPENDIX G
SITE PHOTOGRAPHS
October 25, 2012
BROWN AND TAN CERAMIC FLOOR TILE
GREY CEMENT FLOOR IN BREWERY
GOLD/BROWN VARVISHED WOOD
EXTERIOR OF C.I. SHENANIGANS

summary report - Spokane Public Facilities District

Transcription

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