EP 1110-1-30
3130 Aug 01 Nov 00
identifying information on Forms 1, 2, or 3 (Figure B-1, B-2, or B-3, Appendix B) [for approval
by the Contracting Officer prior to the start of sampling]. The marked facility [CADD] floor
plans, sketches, drawings and forms indicating the sample locations shall be attached at the
completion of the survey to the Survey Report.
2.2.3
Lead Sampling
******************************************************************************
NOTE: It is important to understand that OSHA does not consider X-Ray
Fluorescence (XRF) to be an acceptable method of analysis for lead in paint for
evaluating worker exposure and the applicability of OSHA 1926.62 to a project.
However, as a matter of cost effectiveness, the XRF can be used to back-up an
assumption that lead IS present for a given project (but not to document that lead
is not present for a project). See Decision Chart, Table B-5 of this SOW.
Generally, for structures to be demolished that were built before 1960, allow the
use of the XRF to screen for lead, concentrating on exterior surfaces, interior door
and window systems, and "wet rooms" (kitchen and bathrooms, and trim).
If a structure was built between 1960 and 1978, and is to be demolished, use the
XRF to screen for lead, primarily concentrating on exterior painted components
and interior wet rooms.
For both pre-1960, and 1960 through 1978 testing, stop the XRF screening when
a positive result has been noted.
For structures to be demolished that were built after 1978, and for structures to be
renovated, perform paint chip testing in all cases where objective historical data
available to the designer does not eliminate the possible presence of lead in paint.
In addition, for buildings to be renovated, paint chip sample only those painted
surfaces impacted by the renovation.
XRF results must be obtained by using the instrument in accordance with the
published Performance Characteristics Sheet for the instrument and the ASTM
Provisional Standard PS95-98. If no XRF readings are positive, inconclusive and
negative readings require paint chip sampling with analysis by the analytical lab.
Check with the XRF Manufacturer/NIST/ASTM for soil sampling using the XRF
instrument.
Should a TCLP test determine that a demolition waste stream is hazardous waste,
it is advisable to perform XRF testing to determine which components contain
lead-based paint. Components that test positive by XRF should be identified in
the survey for removal using abatement procedures and disposed of as hazardous
waste. Additional TCLP testing should be performed on the remaining waste
stream to ensure that it is not hazardous waste.
In general, TCLP testing of whole building demolition waste streams are not
positive for hazardous waste. Waste streams generated by renovations
(particularly component) are more likely to result in hazardous waste, however,
by chip sampling, you will know lead content of each component, and can
A-12
Previous Page
