EPA
REVIEW
"
Electrostatic
Cloth
and
Wet
Cloths
Field
Study
in
Residential
Housing"

Work
Assignment#:
Task
Order
110
CONSULTANT
NAME:
Sandy
M.
Roda
VERSAR
JOB
NUMBER:
110667.1000.110
GENERAL
IMPRESSIONS
The
EPA
draft
report
entitled
"
Electrostatic
Cloth
and
Wet
Cloths
Field
Study
in
Residential
Housing"
prepared
by
Battelle
presents
field
study
results
for
an
innovative
approach
to
lead
clearance
testing
that
may
be
appropriate
following
renovation
and
remodeling
projects.
The
report
includes
prior
work
leading
up
to
the
field
study
including
laboratory
analysis
development,
controlled
experiments
and
pilot
field
testing
studies.
The
presentation
of
all
preliminary
work
was
highly
crucial
to
understanding
the
background
and
execution
of
the
actual
field
study
protocols,
procedures,
and
results
available
in
this
final
report.
The
Appendices
also
contain
details
important
to
the
understanding
of
the
final
report
(
i.
e.
laboratory
QC
results
and
individual
lab
evaluation,
ECC
sampling
steps,
photographic
standards
for
dust
level
evaluation,
ect.)

Overall
the
final
report
contained
information
that
was
well
organized
and
accurately
presented
in
terms
of
confidence
intervals
and
probabilities.
The
DCC/
WG
relevance
and
implication
to
real­
world
situations,
however,
was
continually
discussed,
as
well
as
the
limited
sample
size
and
affect
of
surface
condition
for
floors
and
sills.
Conclusions
of
the
study
should
be
expanded
and
organized
to
state
all
concerns
of
the
field
study
components
as
they
relate
to
R
&
R
activities
in
either
bulleted,
table
or
itemized
form.

EPA
Response:
We
understand
the
point.
However,
we
found
that
the
large
number
and
complexity
of
such
issues
were
better
dealt
with
in
the
main
text.

It
is
suggested
that
conclusions
for
the
existing
study
be
separated
and
a
section
added
to
discuss
all
recommendations
for
future
studies.

EPA
Response:
Same
as
above.

Study
conclusions
did
identify
one
specific
treatment
that
was
clearly
better
than
another
but
the
wording
of
the
conclusions
were
not
convincing.

EPA
Response:
Statistically,
the
wet
treatment
was
not
proven
superior
in
the
small
sample
achieved
for
this
study.
However,
operational
issues
suggest
it
is
the
preferred
method.
The
clarity
of
this
conclusion
will
be
addressed
in
the
final
version
of
the
report.

The
conclusions
gave
the
impression
that
future
studies
would
be
necessary
to
further
evaluate
the
various
treatments
in
field
housing.

EPA
Response:
While
many
questions
were
answered
and
issues
resolved
by
this
Field
Study,
further
data
collection
may
be
necessary
to
answer
additional
questions
though
EPA
may
or
may
not
elect
to
perform
such
studies.

Several
areas
of
the
report
may
need
further
clarification.
On
page
7
the
basic
approach
of
the
first
controlled
room
study
may
be
better
understood
using
a
table
or
diagram.
In
addition,
it
is
not
clear
if
it
involves
two
wipe
methods
or
two
wipe
types
and
if
1
ft2
from
the
ASTM
or
both
ASTM
and
ECCs
of
the
sampling
regions.

EPA
Response:
We
will
attempt
to
clarify
any
ambiguities
in
these
descriptions.
However,
we
will
not
add
significantly
more
structure
at
this
point
to
explain
this
study.
Those
with
greater
interest
in
the
details
of
the
First
Controlled
Room
Study
would
be
better
served
to
go
directly
to
Appendix
C
for
a
full
description
of
the
study.

On
page
17,
second
paragraph,
the
report
states
"
Regardless
of
how
dirty
the
used
cloth
was,
a
fresh
DCC
was
instituted ".
Does
this
mean
even
if
the
wipe
was
not
dirty?

EPA
Response:
No.
This
paragraph
will
be
edited
to
make
its
point
more
clearly.

On
page
41,
if
a
regression
line
should
be
interpreted
cautiously
then
it
should
not
be
included
in
the
graph.

EPA
Response:
We
understand
the
reviewer's
point
but
we
still
believe
there
is
value
of
showing
a
plot
of
the
trend.

In
addition,
on
page
50
in
the
conclusions
section
under
"
Wet
Treatment
of
DCC/
WG 
,
the
third
sentence
may
be
referring
to
sills.
EPA
Response:
This
observation
is
correct.
The
text
will
be
corrected.

GENERAL
QUESTIONS
The
design
of
the
field
study
was
adequate
to
achieve
the
study's
objects
with
several
exceptions.
Since
the
sampling
size
was
small
the
selection
of
units
should
have
been
more
representative
of
R
&
R
locations.

EPA
Response:
This
is
a
legitimate
criticism
of
the
study,
but
recruiting
R&
R
sites
and
resolving
the
scheduling
treatment
and
sample
collection
would
have
been
extremely
difficult.
In
addition,
the
mix
of
work
activities
that
had
been
conducted
at
the
sites
used
in
this
study
appeared
to
EPA
to
be
reasonably
representative
of
the
work
activities
that
might
occur
at
typical
R&
R
sites.

The
units
did,
however,
present
a
worse
case
scenario
and
for
that
reason
was
appropriate
for
different
treatment
evaluations.

EPA
Response:
We
are
glad
to
hear
that
this
reviewer
accepts
this.

The
actual
study
itself
could
have
been
improved
by
providing
better
time
control
of
staff
so
that
protocols
could
be
completed
and
also
additional
training
and
oversee
for
execution
of
the
treatments
so
that
there
were
less
deviations
from
the
QAPP.

EPA
Response:
This
is
true.
However,
use
of
volunteers
was
a
cost­
containment
issue.
Any
additional
oversight
and
controls
would
have
reduced
the
size
of
study
that
could
have
been
done.

If
the
DCC/
WG
is
intended
to
serve
as
an
alternative
to
the
wipe
sampling
clearance
method
currently
recommended
after
R
&
R
projects
then
the
treatment
protocols
tested
in
this
field
study
should
be
evaluated
in
situations
following
documented
R
&
R
activities.
Specific
R
&
R
activities
need
to
be
defined
and
placed
into
categories
and
those
categories
evaluated
under
the
DCC/
WG
protocol.

EPA
Response:
EPA
agrees
with
the
value
of
this
suggestion.

The
variability
of
individuals
to
compare
a
wipe
to
the
various
photographic
standards
needs
to
be
defined.

EPA
Response:
This
issue
is
addressed
in
the
First
Controlled
Room
Study.

Further
laboratory
analysis
of
ECCs
should
be
conducted
including
a
more
definitive
extraction
comparison
of
types
of
ECCs.

EPA
Response:
This
is
a
good
suggestion
if
resources
permit.
EPA
did
conduct
laboratory
extraction
of
lead
from
ECCs
in
the
Round
Robin
Study
(
as
preparation
for
the
Field
Study).
This
type
of
analysis
proved
to
be
very
costly
since
the
standard
analytical
protocol
needed
to
be
modified.
There
also
were
serious
difficulties
encountered
with
digestion
of
ECCs.
The
limited
budget
for
this
research
effort
did
not
permit
this
type
of
analysis
for
the
Field
Study.

One
would
have
expected
the
recovery
of
lead
using
the
ASTM
collection
procedure
to
yield
a
higher
percent
recovery
particularly
if
the
surface
is
smooth.
It
is
really
not
clear
whether
the
ASTM
applies
to
the
wipe
or
collection
method.
What
was
the
ASTM
wipe
material
(
manufacturer
name)
used?
What
type
of
material
was
used
to
make
the
QC
spikes,
what
type
of
material
was
used
by
the
laboratory
to
make
their
internal
spikes,
were
both
spiked
ASTM
wipes
and
spiked
ECC
wipes
submitted
blindly
to
the
lab
at
the
same
time
as
field
study
samples,
and
were
digestates
analyzed
by
both
ICP­
MS
and
FAAS
to
see
if
a
difference
was
actually
exhibited
by
instrumental
analysis?

EPA
Response:
All
these
questions
could
be
answered
but
they
would
require
some
research.

Additional
evaluation
of
the
effectiveness
of
cleaning
agents
in
wet
ECCs
compared
to
water
is
needed.

EPA
Response:
If
the
research
budget
allowed,
this
would
be
one
area
that
EPA
would
like
to
explore.
It
is
noteworthy
that
wet
DCCs,
when
used
with
water
were
found
to
work
as
effectively
as
DCCs
used
with
the
cleaning
agent.

Evaluation
of
the
ability
of
those
performing
R
&
R
activities
to
conduct
a
DCC/
WG
protocol
including
instructions
for
cleanup
before
DCC/
WG
for
each
category
of
R
&
R
requires
more
study
EPA
Response:
This
information
would
be
useful.

Questions
and
discussions
have
been
posed
above
to
clarify
aspects
of
the
study
and
the
results.
The
report
contains
pictures
of
floor
conditions
and
should
either
contain
pictures
of
photographic
standards
or
both
should
be
part
of
the
Appendices.

EPA
Response:
The
photographic
standards
are
included
in
Appendix
A.
They
will
be
more
explicitly
referenced
in
the
main
report
text.
It
would
be
attractive
to
include
photographs
of
all
units
in
an
appendix.

Using
11
photographic
standards
may
be
too
many
and
the
number
should
be
perhaps
reduced
to
5
or
6.

EPA
Response:
The
larger
number
of
standards
was
used
in
the
earlier
Controlled
Room
Study
but
the
field
study
was
reduced
to
four
standards.

From
the
photographs
there
appears
to
be
a
degree
of
overlap
and
thus
may
not
be
very
easily
discernable
from
individual
to
individual.

EPA
Response:
The
subjective
difference
in
interpretation
of
standards
was
investigated
in
the
First
Controlled
Room
Study.

The
graphs
that
are
divided
into
quadrants
are
very
effective
at
illustrating
the
results
for
the
treatment
and
before
and
after
lead
loadings
with
respect
to
the
standard.

The
report
assesses
and
describes
the
variability,
uncertainties,
and
limitations
of
the
data
and
analysis.
As
previously
discussed,
certain
aspects
of
the
report
could
be
clarified.
The
individual
variability
associated
with
reading
the
photographic
standards
should
be
assessed.
EPA
Response:
This
is
covered
in
the
First
Controlled
Room
Study
Report.

References
to
limited
sample
size
and
choice
of
units
sampled
are
made
several
times
throughout
the
report.
Conclusions
from
the
study
indicate
further
work
is
needed
including
both
controlled
conditions
and
in
the
field.

SPECIFIC
QUESTIONS
1.
Yes,
to
some
extent
depending
on
if
future
studies
are
being
planned.
The
concerns
of
the
author
are
expressed
several
times
and
the
poorer
condition
of
the
floors
noted
as
being
an
important
aspect
that
may
interfere
with
the
DCC/
WG
procedure.
The
clean­
up
that
is
designated
prior
to
DCC/
WG
protocol
is
also
important
and
only
broom
sweeping
was
used.

2.
Additional
field
study
data
should
be
collected.
Statistical
significance
may
be
demonstrated
between
treatments
if
the
power
is
increased.
More
specific
questions
should
be
addressed,
such
as
vacuum
vs.
broom
cleanup,
and
each
room
subjected
to
only
one
individual
DCC/
WG
protocols
with
before
and
after
wipes.

3.
The
DCC/
WG
procedures
would
always,
in
my
opinion,
be
inferior
to
the
actual
collection
of
dust
wipe
samples
and
analysis
by
NLLAP
Laboratories
because
of
the
subjective
nature
of
the
WG
assessment.
However,
this
does
not
preclude
the
DCC/
WG
from
being
a
very
promising
alternative
in
some
or
all
situations
of
R
&
R
using
a
pass/
fail
assessment.
That
is
why
additional
research
is
needed
to
more
definitively
define
R
&
R
activities
vs.
specific
DCC
treatments
and
the
ability
of
individuals
to
apply
the
protocol.

4.
(
5)
No,
however,
this
also
appears
to
be
related
to
floor
condition
and
discoloration
present
from
some
surfaces
when
using
the
wet
protocol.
It
is
not
clear
whether
the
discoloration
was
seen
using
the
detergent,
water,
or
both.

5.
(
6)
The
DCC/
WG
protocols
do
seem
practical
for
clearance
testing
at
R
&
R
sites,
however,
it
may
depend
on
the
type
and
extent
of
the
work
that
has
been
performed.
Also,
the
additional
items
and
time
required
for
this
procedure
may
not
be
practical
depending
on
the
individuals
and
their
training
in
lead
assessment
work.

6.
(
7)
Yes,
on
poor,
deteriorated,
or
rough
surfaces
as
described
in
the
report
and
in
large
R
&
R
projects
where
high
levels
of
lead­
based
paint
are
known
to
exist
and
paint
removal
is
planned.
DCC/
WG
protocol
is
practical
for
smaller,
well­
contained
jobs
where
the
site
has
been
uninhabited
and
contamination
spread
into
other
areas
is
not
suspected.
It
may
be
practical
for
individuals
performing
R
&
R
activities
in
their
own
homes
or
property
because
not
only
does
it
provide
education
but
also
awareness
of
clean­
up
and
possible
lead
contamination.
Additional
research
would
be
necessary.

7.
(
8)
There
are
several
places
to
obtain
surface
condition
descriptions
or
codes.
One
is
the
HUD
Guidelines
and
the
other
in
an
ASTM
standard.
Condition
descriptions
should
indicate
deteriorated
conditions
on
both
the
floor
and
sill
such
as
chalking,
cracking
or
flaking
finishes
or
paint.
Presence
of
nails,
ect.
Or
damage
should
also
be
described.
Both
type
of
surface
of
the
floor
or
sill
and
condition
should
be
included
as
part
of
the
testing
procedure
and
noted
as
protocol
interferences.

8.
(
9)
Because
of
the
potential
for
larger
amounts
of
dust
a
cleaning
procedure
should
be
recommended
after
R
&
R
and
prior
to
initiating
DCC/
WG
protocols.
Broom
sweeping
of
large
debris
followed
by
vacuum
to
pick­
up
smaller
particles.
A
wet
mop
of
the
surface
would
also
be
a
viable
procedure,
however,
the
surface
would
have
to
be
allowed
to
dry
prior
to
sampling
with
dry
ECCs
or
the
same
results
may
not
be
seen
as
was
demonstrated
in
the
report.
A
wet
mop
of
the
surface
following
vacuum
would
be
indicated
if
implementing
the
wet
cloth
protocol.

9.
(
10)
Many
lead
hazard
control
and
lead
abatement
projects
are
conducted
because
high
to
very
high
lead
hazards
exist
in
the
dwellings.
The
only
protocol
demonstrated
in
the
field
study
that
had
success
at
higher
lead
levels
was
the
wet
cloth
protocol.
This
protocol
should
be
tested
for
both
a
clean­
up
and
possible
clearance
procedure.
