LIMITED HAZARDOUS MATERIALS SURVEY (Asbestos, Lead, PCB ...

LIMITED

HAZARDOUS MATERIALS SURVEY

(Asbestos, Lead, PCB, & Mercury)

Salado Creek Water Recycling Center 12901 Blue Wing Rd.

San Antonio, Texas 78223

for

Ila E. Drzymala

San Antonio Water System

by

AEHS, Inc.

4402 Centergate St.

San Antonio, Texas 78217

(210) 656-9300

www.aehs-sa.com

Asbestos and Lead Inspections AEHS, Inc.

Salado Creek WRC, San Antonio, Texas Environmental, Health, and Safety Consulting

April 2019

1

Hazardous Conditions/Hazardous Materials Survey

Salado Creek Water Recycling Center

12901 Blue Wing Rd.

San Antonio, Texas

A. GENERAL

This report is divided into four sections corresponding to the Media addressed.

The respective assessment media included Asbestos, Lead, Polychlorinated

Biphenyls, and Mercury. The on-site inspections were performed by Matthew

Bishop and Matthew Louderback under the overall direction of Ronald M.

Bishop. Matt Bishop is a Texas Department of State Health Services (TDSHS)

licensed Asbestos Individual Management Planner (No. 205572), and Lead Risk

Assessor (No. 2070727). Matt Louderback is a Texas Department of State Health

Services (TDSHS) licensed Asbestos Inspector (No. 60-2816) and Lead Risk

Assessor (No. 2070871). Ron Bishop is a TDSHS licensed Asbestos Consultant,

Lead Risk Assessor, Lead Project Designer, and Mold Consultant as well as a

Certified Industrial Hygienist, Certified Safety Executive, Registered Sanitarian,

Diplomate in Environmental Health, and Registered Environmental Professional,

Registered Environmental Manager, Certified Environmental and Safety

Compliance Officer, and Green Consultant.

B. ASBESTOS

1.0. GENERAL.

1.1. Construction materials containing asbestos have been used extensively in buildings

because it possesses excellent properties for fire-proofing, insulation, and condensation

control. Asbestos may be found in: (1) cement products; (2) spray applied or trowel applied

materials on ceiling, walls, and other surfaces; (3) insulation on pipes, boilers, tanks, ducts,

and other equipment; (4) vinyl floor tiles; (5) roofing; (6) flooring coatings; and (7) other

miscellaneous products.

1.2. Friable materials are those materials that when dry can be crumbled, pulverized, or

reduced to powder by hand pressure. Material that contains more than one percent asbestos by

weight is considered to be asbestos containing material. Some of these asbestos-containing



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building materials are not considered friable now, but could become friable if not properly

managed and maintained under an asbestos management program.

1.3. The concern about exposure to asbestos in buildings is based on evidence linking

various respiratory diseases with occupational exposure in the shipbuilding, mining, milling,

and fabricating industries. The presence of asbestos in a building does not mean that there is a

significant health risk to building occupants. As long as asbestos-containing materials remain

in good condition and are not disturbed, exposure is unlikely. Through proper control of

building operations and maintenance activities, disturbance or damage to asbestos-containing

materials is minimized, thus limiting the building occupant's exposure to airborne asbestos

fibers.

1.4. Building alterations and/or demolition require knowledge of what materials contain

asbestos and if they will be removed or disturbed during the project. Under the Clean Air Act,

EPA has issued a National Emission Standard for Asbestos (40 CFR 61.140 - 61.156). This

Standard regulates reporting requirements, work practices, waste disposal, and emissions from

facility modification and/or demolition operations. The Standard applies only to materials

containing more than one percent asbestos. The State of Texas has adopted a set of

regulations (25 TAC 295.31 - 295.70) known as "Texas Asbestos Health Protection Rules"

which govern asbestos removal, encapsulation, or enclosure, including licensing and

regulation, in all buildings of public occupancy or access. Any disturbance or removal of

ACBM in the building or facilities are subject to this Texas Statute.

2.0. BACKGROUND.

2.1. AEHS, Inc. was contacted by Ila Drzymala to perform Hazardous Materials inspections

at Salado Creek WRC, 12901 Blue Wing Rd., San Antonio, Texas.

2.2. The area houses pump stations, water treatment areas, covered areas, and loading

dock areas.

3.0. SCOPE OF WORK.

3.1. The asbestos inspection was performed on 2 April 2019 and consisted of visual

assessments to determine the presence of suspect ACBM. Bulk samples of suspect ACBM

(materials which possibly contain asbestos, as determined by an accredited EPA AHERA

Building Inspector/Consultant) were collected. The visual inspection, bulk sampling, and

inspection documentation was performed by Matt Bishop [Asbestos Individual Management

Planner (No. 20-5572)].

3.2. AEHS, Inc. is a TDSHS Licensed Asbestos Constant Agency (No.10-0335), PCM

Laboratory (No. 30-0295), and Training Provider (No. 00-0068).



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3.3. The specific objectives of the survey were to:

Perform a visual inspection and physical assessment following the Asbestos

Hazard Emergency Response Act (AHERA) protocol as a guideline to identify,

quantify, and assess accessible friable and non-friable ACBM;

Collect and analyze bulk samples of suspect material for asbestos content and

identification by an American Industrial Hygiene Association Accredited

Laboratory that is also licensed by the Texas Department of State Health Services;

Ensure the technical quality of all work by using the AHERA protocol and a

TDSHS licensed consultant and inspector for the inspection.

ssue a final report that includes findings, bulk sample locations, and confirmed

asbestos-containing building materials.

4.0. DESCRIPTION.

4.1. The inspection was of the exterior surfaces as specified by the memorandum written by

the engineer of the renovations, Garver USA.

4.2. The specific requirements included representative Lead Base Paint Measurements,

Asbestos Sampling, PCB Inspection, and Mercury Inspection.

5.0. INVESTIGATIVE METHODS.

5.1. Visual Inspection.

5.1.1. Building materials were inspected and assessed using the methods presented

in the federal AHERA regulations (40 CFR, Part 763) as a guideline. The procedures

mandated are considered the industry standard and are applied to all surveys performed by

AEHS, Inc.

5.1.2. The suspect ACBM within the space consisted of pipe mastic and pipe wrap.

5.1.3. Other materials were observed but were not suspect upon close examination.

5.2. Bulk Sampling.

5.2.1. Bulk samples of all homogeneous materials from identified functional spaces

containing suspect ACBM were collected. A homogeneous material is defined as a



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surfacing material, thermal system insulation, or miscellaneous material that is uniform in

use, color and texture. Examples of homogeneous materials include:

Pipe insulation produced by the same manufacturer and installed during the same

time period;

Floor or ceiling tile of identical size, color and/or pattern;

Sprayed-on acoustical ceiling materials located in contiguous areas; and

Trowelled on plaster of same texture and location.

5.2.2. A functional space is defined as any spatially distinct unit within a building that

contains identifiable populations of current or previous building occupants. Examples of

functional spaces include:

Office areas,

Exam Rooms, and

Locker rooms.

The functional space concept is helpful in determining the use and occupancy of building

areas containing confirmed ACBM. Knowing the types of occupants and their use of an

area also may influence the selection of an asbestos management option and/or corrective

action. If multiple corrective actions are necessary, the occupancy and use of individual

areas may also become important factors when establishing the priority, or ranking, of each

corrective action.

5.2.3. Prior to obtaining the samples, all friable suspect material are sprayed with amended

(surfactant added) water to minimize fiber release. Small pieces of the suspect material

were sampled by cutting off a sufficient quantity of the wetted suspect material in an

inconspicuous location and securing the sample in a plastic bag. Samples were extracted

from the center of the wetted area. The tool used to collect the suspect sample was then

cleaned to ensure no cross-contamination occurred between samples. A plastic bag was

used to contain the samples of the suspect material and quickly sealed to prevent the escape

of the material or the introduction of ACBM contamination from outside sources.

5.3. Bulk Sample Analysis.

5.3.1. All bulk samples collected during this survey were analyzed by Environmental

Hazards Services, Inc.’s Laboratory in Richmond, Virginia. Environmental Hazards

Services laboratory is accredited under the National Institute of Standards and

Technology’s National Voluntary Laboratory Accreditation Program (NVLAP) and the

American Industrial Hygiene Association. Additionally, the laboratory is a TDSHS

licensed (No. 30-0188) Asbestos Laboratory (Polarized Light Microscopy). Their address,

telephone number, and quality assurance review are depicted on their laboratory reports.



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5.3.2. All asbestos samples were analyzed using Polarized Light Microscopy/Dispersion

Staining (PLM/DS) techniques in accordance with methodology approved by the U.S.

Environmental Protection Agency (EPA), method number 600/R-93/116. The percentage

of asbestos present in the samples was determined on the basis of a visual area estimation

as set forth in 40 CFR Part 763, Appendix A, Subpart F, Section 1.2 and 1.7.2.4. The

lower limit of reliable detection for asbestos using the PLM/DS method is approximately

1% by volume.

5.3.2.1. The Environmental Protection Agency considers materials with greater than

one percent (>1%) asbestos content to be asbestos containing. Therefore, when asbestos

containing building material (ACBM) appear in this report, it should be interpreted as

meaning the sample(s) taken contained greater than (>1%) asbestos and is considered a

regulated material. However, material that contains equal to or less than one percent is

not considered to be asbestos containing material. If the results of sampling indicate

that the asbestos containing material is a trace or up to 10% asbestos, the results must be

verified by polarized light microscopy point counting or presumed to be asbestos. For

this survey, AEHS personnel used their experience with similar materials.

5.3.2.2. When “No Asbestos Detected” (NAD) appears in this report, it should be

interpreted as meaning no asbestos was observed in the sample material above the

reliable limit of detection for the PLM/DS method.

5.3.2.3. The Texas Department of State Health Services requires a minimum of three

samples to be collected from each homogeneous area. In order for a material to be

considered negative, all samples must be negative. On the other hand, if one of the

three samples is positive, then the material is considered positive.

6.0. RESULTS OF INSPECTION.

6.1. Analytical Results. The analytical results from the inspection and chain of custody are

at Appendix A. A total of six (6) samples were collected which resulted in six (6) analyses

6.2. Photographs. Photographs are at Appendix B.

6.3. Summary Positive Asbestos Containing Building Materials. None. The laboratory

results indicated “NAD – No Asbestos Detected” in all samples.

7.0. ASSESSMENT.

7.1. Friable Asbestos Material. None.



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7.2. Non-Friable Materials. None.

8.0. RECOMMENDATIONS. Maintain a copy of this report with the project files.

C. LEAD BASE PAINT

1.0. GENERAL.

1.1. Background.

1.1.1. Inspections and risk assessments for lead base paint (LBP) hazards emerged in

response to an insurance problem in the nation’s public housing programs after children in

housing units throughout the nation were found to contain elevated blood lead levels.

When investigations pursued, the houses were found to contain LBP where deterioration

was extensive and the children were ingesting the paint directly (chewing on the sills, etc.)

or indirectly by placing contaminated items into their mouths.

1.1.2. At the present time, many of the standards used in lead hazard assessments are not

health-based standards. A limit that will not produce adverse health affects has not been

established for lead content of paint, dust or in soil. This is due in part to differences in

individual behavior, particularly with respect to hand-to-mouth activity. However, the

limits that are established in the various standards will significantly reduce the health

impacts. Also, these limits dictate requirements for action, if exceeded.

1.1.3. The reason lead base paint inspections are conducted for commercial facilities is to

determine potential worker exposure and environmental insult during demolition and

disposal of the wastes based on the lead content.

1.2. Standards. As indicated in the Table 1 below, there are various standards that currently

define lead base paint. The applicable standards to this project include the OSHA

requirements, for worker protection performing the renovation, and the environmental

requirements for disposal of materials painted with lead base paint.

Table 1

Lead Standards

Standard/Regulation Level Remarks

Consumer Product Safety Commission 600 ppm

0.06%

parts per million

% by weight



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Standard/Regulation Level Remarks

HUD – 24 CFR Part 35 0.5% by weight

1.0 mg/cm2

NLLAP Accredited Lab

XRF

TELLR - Texas Environmental Lead

Reduction Rules

0.5% by weight

1.0 mg/cm2

NLLAP Accredited Lab

XRF

OSHA - 29 CFR 1926.62 - Lead in

Construction; Interim Final Rule Any amount Worker Protection

EPA - 40 CFR 261 - Identification and

Listing of Hazardous Wastes 5 ppm TCLP

TCLP - Toxicity Characteristic

Leaching Procedure

1.3. Lead Risk Assessment.

1.3.1. A Lead Risk Assessment is to determine, and then report on the existence, nature,

severity, and location of lead base paint hazards in residential dwellings through on-site

investigations. Normally, risk assessments determine the immediately available sources of

lead in a dwelling and provides advice on long-term and/or short-term responses to any

hazards found. In general, inspections measure lead base paint concentrations while risk

assessments measure lead base paint hazards.

1.3.2. The specific differences between an Inspection and a Risk Assessment are depicted

in Table 2 below.

Table 2

Inspections/Risk Assessments

Inspections Risk Assessments

Measure the concentration of

lead in the paint on a surface-by-

surface basis

Measure the level of lead in dust and soil and

deteriorated paint

Identify the presence of lead

base paint on all components

Identity the location and nature of all lead base

paint hazards (primary prevention)

Allow the owner to avoid

treating paint that is not lead

base paint

Consider information about past maintenance

and management practices

Allow the owner to treat all lead hazards

present

Limited Risk Assessment/Inspection

A combination of the Inspection and Risk Assessment tailored to the specific

renovations to be performed under the specifications.



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2.0. APPROACH.

2.1. Limited Inspection. A limited lead base paint inspection was conducted on 2 April

2019 at the location as described in paragraph 4 of the Asbestos Section.

2.2. Credentials.

2.2.1. The Limited Inspection was performed by Matthew Louderback. Matt is a TDSHS

certified Lead Risk Assessor (No. 2070871).

2.2.2. AEHS, Inc. is a TDSHS certified/licensed Lead Firm (No. 21100283) and Lead

Training Provider (No. 20439)

2.3. Methodology. XRF measurements were taken at representative locations on interior

painted surfaces. XRF Niton Model XLp 300A (Serial No. 10381) was used in the testing for

lead base paint. Calibrations were performed prior to and after testing each building in

accordance with Performance Characteristics Sheets (PCS). See Appendix C for a table of the

results.

3.0. RESULTS.

3.1. Measurements. Twenty-seven (27) measurements were made with the XRF for lead

content.

3.2. Results. Based on the XRF measurements, AEHS, Inc. has determined that the

following components contain lead in the exterior and interior surfaces tested during the LBP

inspection or should be considered positive due to the mixture of surfaces:

Blue Metal Pipes

Yellow Metal Light Poles

Yellow Concrete Light Pole Base

Yellow Metal Bollards

Gray Metal Pipes

Yellow Concrete Walls

Yellow Concrete Column Base

Yellow Metal Covers

4.0. DISCUSSION/CONCLUSIONS.

4.1. The HUD/EPA guidance for target housing is 1 mg/cm2 while the EPA Toxic

Characteristic Leaching Procedure (TCLP) limit for lead is 5 parts per million (ppm).



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4.2. The OSHA requirements, as promulgated in 29 CFR 1926.62 (Lead Standard for the

Construction Industry), considers any amount of lead as lead containing paint; however, any

measured surface below 0.1 mg/cm2 should be considered negative for lead base paint.

5.0. RECOMMENDATIONS. Maintain a copy of this report with the project files.

5.1. Maintain a copy of this report with the project files.

5.2. Provide a copy of this report to the contractor performing the renovation and inform them

that they must comply with all provisions of 29 CFR 1926.62.

D. POLYCHOLORINATED BIPHENYLS (PCBs)

1.0 GENERAL.

1.1. Background.

1.1.1. Polychlorinated Biphenyls (PCBs) are synthetic chemicals that were manufactured

for use in various industrial and commercial applications - including oil in electrical and

hydraulic equipment, and plasticizers in paints, plastics and rubber products - because of

their non-flammability, chemical stability, high boiling point and electrical insulation

properties. PCBs (polychlorinated biphenyls) belong to a broad family of organic

chemicals known as chlorinated hydrocarbons.

1.1.2. Light ballasts are the primary electric components of fluorescent light fixtures and

are generally located within the fixture under a metal cover plate. The ballast units are

generally composed of a transformer to reduce the incoming voltage, a small capacitor

(which may contain PCBs), and possibly a thermal cut-off switch, capacitors, or a safety

fuse. These components are surrounded by a tar-like substance that is designed to muffle

the noise that is inherent in the operation of the ballast. This tar-like coating covers the

small capacitor. When a ballast unit fails, excessive heat can be generated which will melt

or burn the tar material, creating a characteristic foul odor.

1.2. Standards.

1.2.1. Congress enacted the Toxic Substances Control Act (TSCA) to control the

distribution, use, and disposal of harmful chemicals, including PCBs. Through TSCA,

Congress established a number of requirements for identifying and controlling toxic

chemical hazards that pose risks to human health and the environment.



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1.2.2. With respect to transformers, the following was extracted from 40 CFR 761.2: “Any person must assume that a capacitor manufactured prior to July 2, 1979, whose PCB

concentration is not established contains ≥500 ppm PCBs. Any person may assume that a

capacitor manufactured after July 2, 1979, is non-PCB (i.e., < 50 ppm PCBs). If the date of

manufacture is unknown, any person must assume the capacitor contains ≥500 ppm PCBs. Any

person may assume that a capacitor marked at the time of manufacture with the statement ‘No

PCBs’ in accordance with §761.40(g) is non-PCB.”

2.0. APPROACH. Based on DoD requirements, the approach taken for this inspection was to

view a representative sample of transformers to determine if they were labeled “No PCBs”. If

they were not, then the dates of manufacturing would be the determining factor as to sample or

not.

3.0. RESULTS. All of the transformers/ballasts sampled indicated “No PCBs”. See

Photographs, Appendix B.

4.0. RECOMMENDATIONS. Maintain a copy of this report.

E. MERCURY

1.0. GENERAL.

1.1. Background.

1.1.1. Mercury thermostats contain bimetal coils that contract and expand with the room

temperature. When the coil contracts or expands, it moves the mercury bulb (switch) that

opens or closes a circuit to activate the heat or cooling source. A mercury thermostat may

contain one or more switches, depending on how many heating and cooling systems it

activates. Additionally, some equipment switches contain mercury or have mercury

thermometers.

1.1.2. It is estimated that the total amount of mercury used in a thermostat is four (4)

grams.

1.2. Standard.

1.2.1. There are various environmental standards for mercury to include limits for ambient

water, drinking water, sludge, fish, ground water, and hazardous waste. The hazardous

waste standard is the Toxic Characteristic Leaching Procedure limit of 0.2 ppm.



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1.2.2. Thermostats would have to be disposed of as hazardous waste.

1.2.3. Switches containing mercury would have to be disposed of as hazardous waste.

1.2.4. Fluorescent and Mercury vapor lamps would have to be disposed of as Universal

waste.

2.0. APPROACH. Heating and cooling control devices would be visually observed to

determine if they contained mercury. Additionally, lamps would be assessed.

3.0. FINDINGS. None of the thermostats present contained mercury. See Photographs,

Appendix B.

4.0. RECOMMENDATIONS. Maintain a copy of this report.

DISCLAIMER

This report, which contains inspections/measurements for hazardous material is given for the

sole benefit of the aforementioned client(s). The client expressly confirms their understanding

that the conclusions/ recommendations stated in this report are limited to and based solely upon

the scope of the assignment, and samples and field measurements taken. In addition, the client

understands that any field observations contained herein reflect the conditions present on the date

and time of inspection. No representations or warranties are made or may be implied as to the

validity of their applicability to any other days or times.

Ronald M. Bishop, MPH, CIH

ABIH (814)

TDSHS Asbestos Consultant (10-5492)

TDSHS Lead Risk Assessor/Project Designer (20-70124)/(20-90015)

25 April 2019

Appendix A

Asbestos Lab Results

Asbestos BulkAnalysis Report

Client:

Report Number:

Project/Test Address:

Client Number:

Reported Date:

Received Date:

Analyzed Date:

AEHS 04/04/2019

45-5371

04/05/2019

19-04-00642

7469 Whitepine Rd

Telephone: 800.347.4010

Richmond, VA 23237

Environmental Hazards Services, L.L.C.

Salado Creek WRC (SAWS); San Antonio, TX

Laboratory ResultsFax Number:

210-656-8499

4402 Center GateSan Antonio, TX 78217

04/04/2019

Layer Type AsbestosClient SampleNumber

OtherMaterials

Lab Gross DescriptionLab SampleNumber

Brown Fibrous; SilverMetallic; Inhomogeneous

19-04-00642-001 PM-A1 35% Cellulose5% Fibrous Glass60% Non-Fibrous

NAD

No mastic present.

Brown Fibrous; SilverMetallic; Inhomogeneous

19-04-00642-002 PM-A2 35% Cellulose5% Fibrous Glass60% Non-Fibrous

NAD

No mastic present.

White Adhesive;Homogeneous

19-04-00642-003 PM-A3 3% Wollastonite97% Non-Fibrous

NAD

Black Pliable;Homogeneous

19-04-00642-004 PW-A4 100% Non-FibrousNAD



1 of 2Page

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:45-5371 19-04-00642

Salado Creek WRC (SAWS); SanAntonio, TX

OtherMaterials

AsbestosLab SampleNumber

Layer Type Lab Gross DescriptionClient SampleNumber



Missy Kanode

1% Asbestos

Analyst:

Reporting Limit:

Method:

QC Blank:

QC Sample:

Araceli Enzler

EPA Method 600/R-93/116, EPA Method 600/M4-82-020

QA/QC Clerk

Reviewed By Authorized Signatory:

21-M12011-4

SRM 1866 Fiberglass

NAD = no asbestos detectedLEGEND:

The condition of the samples analyzed was acceptable upon receipt per laboratory protocol unless otherwise noted on this report. Each distinct

component in an inhomogeneous sample was analyzed separately and reported as a composite. Results represent the analysis of samples submitted

by the client. Sample location, description, area, volume, etc., was provided by the client. This report cannot be used by the client to claim product

endorsement by NVLAP or any agency of the U.S. Government. This report shall not be reproduced except in full, without the written consent of the

Environmental Hazards Service, L.L.C. California Certification #2319 NY ELAP #11714 NVLAP #101882-0 VELAP 460172. All information concerning

sampling location, date, and time can be found on Chain-of-Custody. Environmental Hazards Services, L.L.C. does not perform any sample collection.

Environmental Hazards Services, L.L.C. recommends reanalysis by point count (for more accurate quantification) or Transmission Electron Microscopy

(TEM), (for enhanced detection capabilities) for materials regulated by EPA NESHAP (National Emission Standards for Hazardous Air Pollutants) and

found to contain less than ten percent (<10%) asbestos by polarized light microscopy (PLM). Both services are available for an additional fee.

400 Point Count Analysis, where noted, performed per EPA Method 600/R-93/116 with a Reporting Limit of 0.25%.

* All California samples analyzed by Polarized Light Microscopy, EPA Method 600/M4-82-020, Dec. 1982.

2 of 2Page

Appendix B

Photographs

Salado Creek WRC

12901 Blue Wing Road

San Antonio, TX

1. No Mercury Switches 2. No Mercury Switches 3. No Mercury Switches

No PCB’s No PCB’s No PCB’s

4. Pipe Wrap - No Asbestos 5. Pipe Mastic - No Asbestos 6. Blue Metal Pipes

Detected (NAD) Detected (NAD) Positive Lead Based Paint

7. Yellow Metal Bollards 8. Yellow Metal Bollards 9. Gray Metal Pipes

Positive Lead Based Paint Positive Lead Based Paint Positive Lead Based Paint

10. Yellow Concrete Wall 11. Yellow Concrete Column 12. Yellow Metal Column

Positive Lead Based Paint Base Positive Lead Based Paint

Positive Lead Based Paint

Appendix C

XRF Measurements

Salado Creek

Water Recycling Center

No. Time Room Component Feature Substrate Cond. Color Results PbC

1 4/2/19 9:12 1.76

2 4/2/19 9:14 Calibration Pos 1

3 4/2/19 9:15 Calibration Pos 1.1


5 4/2/19 9:17 Exterior Column Metal Det Blue Neg 0

6 4/2/19 9:18 Exterior Pipe Metal Det Blue Neg 0

7 4/2/19 9:18 Exterior Pump Metal Det Blue Neg 0

8 4/2/19 9:19 Exterior Pipe Metal Det Blue Neg 0

9 4/2/19 9:20 Exterior Pipe Metal Det Gray Neg 0

10 4/2/19 9:20 Exterior Pipe Metal Det Blue Neg 0.01

11 4/2/19 9:21 Exterior Pipe Stand Metal Det Blue Neg 0



14 4/2/19 9:23 Exterior Pipe Metal Det Blue Pos 0.15


16 4/2/19 9:25 Exterior Light Pole Metal Det Yellow Pos 0.6

17 4/2/19 9:26 Exterior Light Pole Base Concrete Det Yellow Pos 1.3

18 4/2/19 9:27 Exterior Bollard Metal Det Yellow Pos 0.6

19 4/2/19 9:28 Exterior Pipe Metal Det Beige Neg 0

20 4/2/19 9:28 Exterior Pipe Metal Det Gray Pos 0.26


22 4/2/19 9:30 Exterior Wall Concrete Det Yellow Pos 0.6

23 4/2/19 9:32 Exterior Column Base Concrete Det Yellow Pos 1.2






29 4/2/19 9:35 Exterior Bollard Metal Det Yellow Pos 2

30 4/2/19 9:36 Exterior Cover Metal Det Yellow Pos 0.2

31 4/2/19 9:37 Exterior Cover Casing Concrete Det Yellow Neg 0




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