APPENDIX E-9: LEAD SURVEY REPORT - Los Angelescityplanning.lacity.org/eir/BundyVillage/DEIR/DEIR Appendices... · APPENDIX E-9: LEAD SURVEY REPORT . LIMITED LEAD-BASED PAINT INSPECTION

APPENDIX E-9: LEAD SURVEY REPORT

LIMITED LEAD-BASED PAINT INSPECTION

Commercial Building(s) 12333 Olympic Boulevard

West Los Angeles, California 90064

AEG Project No. 108208KTTJ1

September 7, 2008

Submitted To:

Mr. Brett Bowyer Bowyer Environmental Consulting

16458 Bolsa Chica Street, #422 Huntington Beach, California 92649

Prepared by:

AMERICAN ENVIRONMENTAL GROUP, INC. 5655 Lindero Canyon Road, Suite 604

Westlake Village, California 91552 T. 888.699.6653 F. 818.865.7906

[email protected]

Prepared by:

Todd Johnson, #12848 Kenneth A. Thornburgh, Ph.D. EPA / DHS Inspector/Assessor Executive Vice President Industrial Hygiene Division

Page i

EXECUTIVE SUMMARY On August 20, 2008, Mr. Todd Johnson, a DHS Certified Lead Inspector/Risk Assessor # 12848 and a representative of American Environmental Group, Inc. (AEG) conducted a Limited Lead-Based Paint (LBP) Inspection of the interior and exterior of the commercial building(s) located at 12333 Olympic Boulevard, West Los Angeles, California (“the Site”). This document is prepared for the sole use of AEG, it’s client, and any regulatory agencies that are directly involved in this project. No other party should rely on the information contained herein without prior written consent of AEG. The scope of work as provided to AEG by Mr. Brett Bowyer was to conduct a limited U.S. Department of Housing and Urban Development (HUD) LBP Inspection of the exterior and interior substrates of the Site building. Additional regulations with federal, State, and regional laws or regulations include the following: • 24 CFR Part 35.80-35.98 and 35.3120(b) – U.S. Department of Housing and Urban Development

(HUD) • Toxic Substances Control Act (TSCA) Section 406 • 40 CFR 745.103 – Environmental Protection Agency (EPA) • Title 17 Section 35000 – Code of California Regulations • Cal/OSHA Title 8 Section 1532.1 – California Occupational Safety and Health Administration • Cal/OSHA Title 8 Section 5194 – California Occupational Safety and Health Administration In compliance with Title 17, CCR, Division 1, Chapter 8 and 24 CFR Subtitle A, Part 35.125, AEG filed the 8552 form for the building as required to notify the California Department of Health Services the findings of the LBP Inspection conducted on the Site property. Currently, the State of California, HUD, and the Environmental Protection Agency (EPA) define lead-based paint as paint or other surface coating with lead content equal to or greater than 1.0 milligram per square centimeter (mg/cm2) of surface area. However, a more stringent level is established by the Los Angeles County Department of Health Services which defines "dangerous level of lead-bearing substances" as paint or other surface coating with lead in excess of 0.7 mg/cm2 (Los Angeles County Code, Title 11, Chapter 11.28, Section 11.28.010 C). Based on the location of the subject property in Los Angeles County, the "abatement" level” (threshold) setting of 0.7 mg/cm2 was chosen for the inspection. XRF Paint Readings: A total of 266 XRF readings were obtained from the building. Of the 266 XRF readings collected, forty (40) of the readings were analyzed at or greater than 0.7 mg/cm2. Six of the 266 XRF readings were noted to be for calibration purposes, as per RMD LPA-1 and HUD protocol. The following areas represent the painted surfaces or substrates with the reading equal to or greater than 0.7 mg/cm² that is regulated under the Los Angeles County Department of Health Services. All quantities will be needed to be verified by a lead abatement contractor prior to removal. Building 1 • Exterior, Sides A and B, Beige Stucco (~2,000 S.F.) • Exterior, Side B, Beige Wood Paneling (~1,000 S.F.) • Exterior, Side B, Blue and Brown Wood Fascia (~600 L.F.) • Exterior, Sides A, B and D, Beige and Brown Metal Windows (~2,000 S.F.) • Exterior, Side B, Beige Metal Door Casing, ( 1 Each) • Exterior, Side B, Beige Metal Downspout, (~50 S.F.) • Interior, Rooms 11, 12 and 13, White and Green Ceramic Wall Tile in Bathrooms (~3,000 S.F.)

Building 2 • Exterior, Side A, Beige Door and Door Casing (1 Each) • Exterior, Side A, Beige Ceiling Horizontal Beams and Metal Braces/Brackets (~1,000 S.F.) • Exterior, Sides B and C, Beige Metal Windows (~2,000 S.F.) • Interior, Rooms 8 and 9, White and Green Ceramic Wall Tile in Bathrooms (~1,200 S.F.) • Interior, Side A, Room 10, Green Wood Door, ( 1 Each) • Interior, Side A, Room 10, Yellow Metal and Wood Columns, (~20 Each) • Interior, Side A, Room 10, White Wood Horizontal Beams, (~20,000 S.F.) • Interior, Side C, Rooms 3 and 10, White Metal Braces/Brackets (~50 Each) • Interior, Side C, Room 3, White Wood Door ( 2 Each) • Interior, Side C, Hallway 7, Red Metal Door ( 1 Each).) Building 3 • Exterior, Side C, Beige Metal Windows (~2,000 S.F.) • Exterior, Side B, Hallway H11, Blue Metal Door ( 1 Each) Building 3 Mezzanine • Interior, Room 5, Peach Ceramic Wall Tile (~400 S.F.) • Interior, Room 5, Black Ceramic Baseboard Tile (~60 L.F.) • Interior, Room 6, White and Green Ceramic Wall Tile (~600 S.F.) • Interior, Room 6, Black Ceramic Baseboard Tile (~60 S.F.) Based on the results of the LBP Inspection, AEG concludes: • Work activities impacting LBP or lead contaminated paint pose an exposure risk for workers and/or

building occupants. All construction work where an employee may be occupationally exposed to lead must comply with Cal/OSHA requirements set forth in 8 CCR 1532.1. This regulation requires initial employee exposure monitoring to evaluate worker exposure during work that disturbs lead-containing materials (lead present in any detectable concentration).

• According to Federal Regulations and Guidelines, LBP abatement is the permanent (defined as

designed to last at least 20 years, or, in case of encapsulation, a 20-year product warranty) elimination of LBP hazards through replacement, enclosure, encapsulation, paint removal, and cleaning to remove lead-contaminated dust. Lead abatement specifications by a Lead Project Monitor/Designer is required for all demolition activities to prevent further contamination of lead dust and OSHA requirements.

• Some painted surfaces contain levels of lead below 0.7 mg/cm², which can create lead dust or lead-

contaminated soil hazards if the paint is turned into dust by abrasion scraping or sanding and exposure to the residents.

• Additionally, waste items generated during an abatement or demolition project should be properly

sampled and profiled to determine the final disposition of the waste. AEG suggests that engineering controls, respiratory protection and personal protective equipment be employed at the start of a project that may disturb LBP.

• This report should be maintained as a permanent maintenance record for these properties.

American Environmental Group, Inc. Lead-Based Paint Inspection September 7, 2008

Page ii

TABLE OF CONTENTS Description Page No. EXECUTIVE SUMMARY............................................................................................................ i

1.0 Inspection....................................................................................................................1

2.0 Scope of Work ............................................................................................................1

3.0 Property Description ...................................................................................................1

4.0 Testing Protocol ..........................................................................................................2

5.0 Method of Sampling ....................................................................................................2

6.0 Summary of Results....................................................................................................3

7.0 Recommendations ......................................................................................................4

8.0 Title X Requirements ..................................................................................................4

9.0 Inspection Limitations .................................................................................................5 Appendices

A FIELD DATA • XRF Data

B CERTIFICATES

• Inspector’s Certificate(s)

C DHS 8552 FORMS

D SITE MAP(S)


Page 1

1.0 Inspection On August 20, 2008, Mr. Todd Johnson, a DHS Certified Lead Inspector/Risk Assessor # 12848 and a representative of American Environmental Group, Inc. (AEG) conducted a Limited Lead-Based Paint (LBP) Inspection of the interior and exterior of the commercial building(s) located at 12333 Olympic Boulevard, West Los Angeles, California (“the Site”). A copy of the inspector’s certificates is included in Appendix B. This document is prepared for the sole use of AEG, it’s client, and any regulatory agencies that are directly involved in this project. No other party should rely on the information contained herein without prior written consent of AEG. 2.0 Scope of Work The scope of work as provided to AEG by Mr. Brett Bowyer was to conduct a limited U.S. Department of Housing and Urban Development (HUD) limited LBP Inspection of the exterior and interior substrates of the Site building(s). Additional regulations with federal, State, and regional laws or regulations include the following: • 24 CFR Part 35.80-35.98 and 35.3120(b) – U.S. Department of Housing and Urban Development

(HUD) • Toxic Substances Control Act (TSCA) Section 406 • 40 CFR 745.103 – Environmental Protection Agency (EPA) • Title 17 Section 35000 – Code of California Regulations • Cal/OSHA Title 8 Section 1532.1 – California Occupational Safety and Health Administration • Cal/OSHA Title 8 Section 5194 – California Occupational Safety and Health Administration In compliance with Title 17, CCR, Division 1, Chapter 8 and 24 CFR Subtitle A, Part 35.125, AEG filed the 8552 form for the building as required to notify the California Department of Health Services the findings of the LBP Inspection conducted on the Site properties. Currently, the State of California, HUD, and the Environmental Protection Agency (EPA) define lead-based paint as paint or other surface coating with lead content equal to or greater than 1.0 milligram per square centimeter (mg/cm2) of surface area. However, a more stringent level is established by the Los Angeles County Department of Health Services which defines "dangerous level of lead-bearing substances" as paint or other surface coating with lead in excess of 0.7 mg/cm2 (Los Angeles County Code, Title 11, Chapter 11.28, Section 11.28.010 C). Based on the location of the subject property in Los Angeles County, the "abatement" level” (threshold) setting of 0.7 mg/cm2 was chosen for the inspection. 3.0 Property Description The building(s) is/are comprised of as three connected buildings w a mezzanine and two smaller buildings that were constructed in the 1950’s.


Page 2

4.0 Testing Protocol XRF Testing: Testing of the painted surfaces was patterned after the inspection protocol in Chapter 7 of the HUD Guidelines. In every “room equivalent” within the tested property, one representative surface of each “testing combination” was tested. Commonly encountered interior components tested (if painted or varnished) included walls, baseboard, doors, door trim, jambs, windows assemblies, and trim (including sashes), and windowsills. Typical exterior components that were tested included the walls, fascias, doors and assemblies, and window assemblies. A hand-held RMD XRF unit was used to determine the presence of lead in painted surfaces throughout the structures. An appropriate number of readings were collected from interior and exterior building components and common areas. Multiple readings were collected to resolve inconsistencies in the test results. Regulatory Compliance: Several public (government) agencies have a published “regulatory action level” to classify LBP. Additionally, some of the established levels are quantified in different units of measurement. Listed in the following table are the current regulatory agencies that have defined LBP, along with the respective level. Agency Reference # Action Level (mg/cm²) Action level (ppm1) HUD/EPA LA County DHS

24 CFR 35.86 & 40 CFR 745.103

1.0 mg/cm

0.7 mg/cm² 5,000 ppm

Fed OSHA Cal/OSHA2

29 CFR 1926.62 Title 8, 1532.1

Not Specified 600 ppm

In recognition of the various action levels, the testing results are classified as follows for this report: • In Los Angeles County painted surfaces with readings equal to or greater than 0.7 mg/cm² are

considered Positive. • Painted surfaces with readings less than 0.7 mg/cm² are considered Negative. • Painted surfaces with readings between 0.1 mg/cm² and 0.6 mg/cm² can pose a dust contamination

risk to the building and are regulated under Cal/OSHA for worker exposure. 5.0 Method of Sampling Paint Testing: The various painted surfaces of the building were tested for lead using a portable x-ray fluorescence (XRF) spectrum analyzer. The XRF used was the LPA-IA, manufactured by Radiation Monitoring Devices (RMD) of Watertown, Massachusetts. XRF readings were taken by using the device "20 Second/Quick Mode” option. No time setting is required with this option since the device automatically adjusts its reading time to the different paint substrates for precision. The duration of each test result was determined by the substrate density in combination with the age of the radioactive source of the device and the actual reading relative to the "abatement" level (threshold) chosen. The testing combination includes a unique combination of room equivalent, building component type, and substrate. An XRF Performance Characteristic Sheet (PCS) developed jointly by HUD and the Environmental Protection Agency (EPA) for the RMD LPA-I was used. The PCS provides information necessary to conduct an inspection of LBP using specific XRF. Based on the PCS, no inconclusive readings in the "Quick Mode” were encountered for LBP on brick, concrete, drywall, plaster, or wood substrates. Inconclusive readings, however, may be encountered for LBP on metal substrates. The inconclusive range for metal in the "Quick" mode is 1.0 mg/cm2 to 1.2 mg/cm2 for an "abatement" level setting of 1.0 mg/cm2 (milligrams per square centimeter). 1 Parts Per Million 2 Applies to Construction related activities


Page 3

Field calibration checks were performed prior, during, and after each XRF lead inspection to determine that the device is functioning within acceptable limits (tolerance) determined by the manufacturer. Three readings of a red 1.02 mg/cm2 Standard Reference Material (SRM) paint film, developed by the National Institute of Standard and Technology (NIST) were taken in the "3D-Second Standard" mode option during each calibration check. Each set of readings were averaged and compared to the PCS calibration check limit for the device. The readings from this instrument produce a 95% confidence level that the “lead” reading accurately reflects the actual level off lead in the tested surfaces, relative to the federal action level. Interpretation of Site Map The exterior side identification were designated with letters A, B, C, and D. Side A corresponds with the address side of the building, and Sides B, C, and D were identified clockwise from Side A. For interior side identification was designated with letters A, B, C, and D. Side A corresponds with the exterior Side A and Sides B, C, and D were identified clockwise from Side A. A copy of the Site Map(s) is contained in Appendix C. 6.0 Summary of Results XRF Paint Readings: A total of 266 XRF readings were obtained from the building. Of the 266 XRF readings collected, forty (40) of the readings were analyzed at or greater than 0.7 mg/cm2. Six of the 266 XRF readings were noted to be for calibration purposes, as per RMD LPA-1 and HUD protocol. The following areas represent the painted surfaces or substrates with the reading equal to or greater than 0.7 mg/cm² that is regulated under the Los Angeles County Department of Health Services. All quantities will be needed to be verified by a lead abatement contractor prior to removal. Building 1 • Exterior, Sides A and B, Beige Stucco (~2,000 S.F.) • Exterior, Side B, Beige Wood Paneling (~1,000 S.F.) • Exterior, Side B, Blue and Brown Wood Fascia (~600 L.F.) • Exterior, Sides A, B and D, Beige and Brown Metal Windows (~2,000 S.F.) • Exterior, Side B, Beige Metal Door Casing, ( 1 Each) • Exterior, Side B, Beige Metal Downspout, (~50 S.F.) • Interior, Rooms 11, 12 and 13, White and Green Ceramic Wall Tile in Bathrooms (~3,000 S.F.) Building 2 • Exterior, Side A, Beige Door and Door Casing (1 Each) • Exterior, Side A, Beige Ceiling Horizontal Beams and Metal Braces/Brackets (~1,000 S.F.) • Exterior, Sides B and C, Beige Metal Windows (~2,000 S.F.) • Interior, Rooms 8 and 9, White and Green Ceramic Wall Tile in Bathrooms (~1,200 S.F.) • Interior, Side A, Room 10, Green Wood Door, ( 1 Each) • Interior, Side A, Room 10, Yellow Metal and Wood Columns, (~20 Each) • Interior, Side A, Room 10, White Wood Horizontal Beams, (~20,000 S.F.) • Interior, Side C, Rooms 3 and 10, White Metal Braces/Brackets (~50 Each) • Interior, Side C, Room 3, White Wood Door ( 2 Each) • Interior, Side C, Hallway 7, Red Metal Door ( 1 Each)


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Building 3 • Exterior, Side C, Beige Metal Windows (~2,000 S.F.) • Exterior, Side B, Hallway H11, Blue Metal Door ( 1 Each). Building 3 Mezzanine • Interior, Room 5, Peach Ceramic Wall Tile (~400 S.F.) • Interior, Room 5, Black Ceramic Baseboard Tile (~60 L.F.) • Interior, Room 6, White and Green Ceramic Wall Tile (~600 S.F.) • Interior, Room 6, Black Ceramic Baseboard Tile (~60 S.F.) The field data and results for paint sampling are found in the Appendix B and the correlating Site Map is included in Appendix C. 7.0 Recommendations Based on the results of the LBP Inspection, AEG concludes: • Work activities impacting LBP or lead contaminated paint pose an exposure risk for workers and/or

building occupants. All construction work where an employee may be occupationally exposed to lead must comply with Cal/OSHA requirements set forth in 8 CCR 1532.1. This regulation requires initial employee exposure monitoring to evaluate worker exposure during work that disturbs lead-containing materials (lead present in any detectable concentration).

• According to Federal Regulations and Guidelines, LBP abatement is the permanent (defined as

designed to last at least 20 years, or, in case of encapsulation, a 20-year product warranty) elimination of LBP hazards through replacement, enclosure, encapsulation, paint removal, and cleaning to remove lead-contaminated dust. Lead abatement specifications by a Lead Project Monitor/Designer is required for all demolition activities to prevent further contamination of lead dust and OSHA requirements.

• Some painted surfaces contain levels of lead below 0.7 mg/cm², which can create lead dust or lead-

contaminated soil hazards if the paint is turned into dust by abrasion scraping or sanding and exposure to the residents.

• Additionally, waste items generated during an abatement or demolition project should be properly

sampled and profiled to determine the final disposition of the waste. AEG suggests that engineering controls, respiratory protection and personal protective equipment be employed at the start of a project that may disturb LBP.

• This report should be maintained as a permanent maintenance record for these properties. 8.0 Title X Requirements Not applicable to commercial buildings. This report should be maintained as a permanent maintenance record for this property.


Page 5

9.0 Inspection Limitations This inspection/risk assessment was planned, developed, and patterned after the HUD Guidelines in Chapter 7. AEG utilized state-of-the-art practices and techniques in accordance with regulatory standards while performing this inspection/risk assessment and the needs of Mr. Brett Bowyer. AEG’s evaluation of the relative risk of exposure to lead identified during this inspection/risk assessment is based on conditions observed at the time of the inspection. AEG cannot be responsible for changing conditions that may alter the relative exposure risk or for future changes in accepted methodology.

APPENDIX A

FIELD DATA

XRF Data

APPENDIX B

CERTIFICATES

Inspector’s Certificate(s) Equipment Training Certificate(s)

APPENDIX C

DHS 8552

APPENDIX D

MAP(S)

Site Building Map12333 Olympic BoulevardWest Los Angeles, CA

2008American Environmental

Group, Inc.

Bldg. 5 Bldg. 4

Bldg. 1

Bldg. 3Bldg. 2

Side A

Side C

Side B Side D

Side A

Building 3 Mezzanine

Building 1 Map12333 Olympic BoulevardWest Los Angeles, CA


Group, Inc.

1

2

3

45

67

8

9 10 11 121314

15

16

17

181920

21

22

23

24

25

26

27

28

29

30

31 32

33

H1

H2

H3

H4

H5

Legend

10 = Room NumberH1 = Hallway Number North

Side A



Group, Inc.

7

121314

15

16

17 18

19

2021

22

23

24

25

26

27

28

29

30

31 32

33

H1

H2

H3

H4

H5

Legend

10 = Room NumberH1 = Hallway Number

1

23

4

5

6

1011

8

9

H7

North

Side A



Group, Inc.

7

121314

15

16

17 18

19

2021

22

23

24

25

26

27

28

29

30

31 32

33

H1

H2

H3

H5

Legend


1011

8

9

North

Side A

H11

H10

H9

H8

1 2

3

4

56

Building 3 Mezzanine Map12333 Olympic BoulevardWest Los Angeles, CA


Group, Inc.

7

121314

15

16

17 18

19

2021

22

23

24

25

26

27

28

29

30

31 32

33

H1

H3

H5

Legend


1011

8

9

North

Side A

H11

H10

H9

H8

H12

2

3

4

56

1

Buildings 4 and 5 Map12333 Olympic BoulevardWest Los Angeles, CA


Group, Inc.

Legend

1 = Room NumberNorth

Side A

Building 4 Building 5

1 1

APPENDIX E-9: LEAD SURVEY REPORT - Los Angelescityplanning.lacity.org/eir/BundyVillage/DEIR/DEIR Appendices... · APPENDIX E-9: LEAD SURVEY REPORT . LIMITED LEAD-BASED PAINT INSPECTION

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