Asbestos and lead survey report cover, 130 Cedar Street, July

NYC 9/11 Public Portal Document

Asbestos and Lead Paint Inspection Report for 130 Cedar Street, New York, NY 10006

3.1 LEAD PAINT INSPECTION AND SAMPUNG PROCEDURES:

The U.S. Department of Housing and Urban Development (HUD) and the U.S. Environmental Protection Agency (EPA) define an inspection as a surface-by surface Investigation to determine the presence of lead-based paint (see 40 CFR part 745 and Title X of the 1992 Housing and Community Development Act).

As per the EPA & HUD guidelines lead based paint is defined as a dried paint film with a lead concentration of greater than or equal to 1.0 mg/cm2 or 0.5 percent by weight for this survey. Lead paint amounts were reported mg/cm2 because this unit of measurement does not depend on the number of layers of non-lead based paint.

A. Portable XRF Testing Machines

Portable XRF lead-based paint analyzers are the most common primary analytical method for inspections because of their demonstrated abilities to:

1. Determine if lead-based paint is present on many different types of surfaces 2. Measure the paint without destructive sampling or paint removal 3. Provide sample results Immediately and at a relatively low cost per sample

• Portable XRF instruments expose a building component to X rays or gamma radiation, which causes lead to emit X rays with a characteristic frequency or energy. The intensity of this radiation is measured by the instrument. The inspector must then compare this displayed value (reading) with the inconclusive range or threshold specified in the XRF Performance Characteristic Sheet for the specific substrate beneath the painted surface. If the reading is less than the lower boundary of the inconclusive range, or less than the threshold, then the reading is considered negative. If the reading is greater than the upper boundary of the inconclusive range, or greater or equal to the threshold, then the reading is considered positive. Readings within the inconclusive range, including its boundary values, are considered inconclusive. Because the inconclusive ranges and/or thresholds shown in the Performance Characteristic Sheet are based on 1.0 mg/cm2, positive and negative readings are consistent with the HUD definition of lead-based paint for identification and disclosure purposes.

B. XRF Inspection Methodology

JLC conducts LBP Inspections using XRF methodology in a strict and rigorous manner. Our inspection methodology is based on Chapter 7 of the U.S. Department of Housing and Urban Development's (HUD) Guidelines For the Evaluation and Control ofLead Based Paint Hazards in Housing. A typical Lead- Based Paint Inspection involves several distinct tasks:

Prepared for Masterworks Development Corp. By JLC Environmental Consultants, Inc. Project No. 04-3271 Page 36

NYC-WTC 000125241