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City of South Bend— Former Gates Chevrolet/Toyota Facilities January 17, 2012 Page 6 of 7 TASK 3 — LEAD -BASED PAINT SURVEY From a regulatory perspective, there are no specific testing methods which specifically address non- residential housing. For performing the Lead -Based Paint Survey, Wightman Petrie proposes to use a portable X -Ray Florescence (XRF) spectrum analyzer. Wightman Petrie will test a wide -array of painted stained and varnished surfaces from the interior and exterior of the building. Three (3) XRF readings will be made on selected, representative, testing combinations within the building. A testing combination is comprised of a unique room equivalent, component, substrate and visible paint color. A room equivalent is an identifiable part of a building, such as a room, an exterior building side or other designated interior or exterior area. Hallways, stairways, and exterior areas such as sheds or outbuildings are considered as room equivalents. Adjoining rooms will be considered as separate room equivalents if they are obviously dissimilar from the adjoining room based on paint color or age of construction. Given the size of the structures there will be numerous room equivalents formed on the exterior, as easily documented break points. Building components typically include such items as the walls, floors, ceilings, doors, door casings, window frames, cabinets and other individual items used in the construction of the building. Substrate is the material underneath the paint. Substrates are generally classified as one of six types: brick, concrete, drywall, metal plaster or wood. For substrates on top of substrates, the substare directly beneath the painted surface will be identified. The Department of Housing and Urban Development (HUD) defines lead -based paint as a paint or other surface coating which contains lead equal to or greater than 1.0 mg /cm2, or 0.5 percent by weight (5,000 ug /g or 5,000 ppm by weight). In each test area, data will be recorded on data forms. XRF sample ID numbers will be associated with each component assayed in each room equivalent. For each testing combination, we will record the substrate type, component name and color. A general narrative description of the locations and the value for each XRF assay will be recorded. We do not intend to generate drawings to depict the assay locations within the buildings. Our report will include a discussion of our lead -based paint testing procedures and our findings. We will include a discussion of regulatory considerations and recommendations based on our findings. Our report will include an opinion as to the general location and extent of lead based paint in the facility. It is not the intent of the screening survey to perform a detailed take -off or to quantify the number or area components considered positive of being coated with lead paint. Our opinion will be based on extrapolation of our data, based on the percentage of similar building components which tested positive for lead -based paint. As Wightman Petrie is not a Lead Paint Abatement Contractor, our report will not include quantification or an opinion of costs for abatement of identified lead -based paint. QUALIFICATIONS The scope of lead -based paint survey services should be considered as a "screening" of the building components which are tested, and is limited by the number of components actually tested. Testing locations will be selected based on accessibility from random locations which are representative of the range of painted materials used in construction of the facility. Because HUD Guidelines are specifically applicable to testing of residential housing, our services are not intended to comply with current HUD guidelines, or any City, County or State regulatory requirement which may exist. Due to the limited nature of our services, lead -based paint may exist which is not identified during our testing. Please note that our services are not intended to characterize painted components to determine if potential waste streams are considered hazardous waste by the EPA.