August 18, 2006

FINAL DISPOSITION OF PEER REVIEW COMMENTS FOR 

CHARACTERIZATION OF DUST LEAD LEVELS AFTER RENOVATION, REPAIR, AND
PAINTING ACTIVITIES 

GENERAL COMMENTS FROM EPA REVIEWERS

Prepared By

BATTELLE

505 King Avenue

Columbus, Ohio  43201

EPA Contract No. EP-W-04-021

Work Assignment 2-10

Prepared For

Sineta Wooten, Project Officer

John Schwemberger, Work Assignment Manager

Samuel Brown, Deputy Work Assignment Manager

Program Assessment and Outreach Branch

National Program Chemicals Division

Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue NW (7404T)

Washington, D.C.  20460

GENERAL COMMENTS ON RRP QAPP FROM EPA REVIEWERS

TABLE OF CONTENTS

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc139429704"  TABLE OF
CONTENTS	  PAGEREF _Toc139429704 \h  1  

  HYPERLINK \l "_Toc139429705"  Comments from Reviewer FR6	  PAGEREF
_Toc139429705 \h  2  

  HYPERLINK \l "_Toc139429706"  Comments from Reviewer FR7	  PAGEREF
_Toc139429706 \h  5  

  HYPERLINK \l "_Toc139429707"  Comments from Reviewer FR8	  PAGEREF
_Toc139429707 \h  6  

  HYPERLINK \l "_Toc139429708"  Comments from Reviewer FR9	  PAGEREF
_Toc139429708 \h  7  

 Comments from Reviewer FR6

Comments on full dust study Plan

A very thorough Plan!  I have just a few comments:

See my June 5 comments on the dust study site selection Plan, some of
those apply here as well.  In addition, I have the following remarks:

In section 1.5.3, Study Question #3, a “by” is missing in the first
paragraph.

In section 1.5.5, Study Question #5, regarding the use of plastic ground
covering for exterior jobs—isn’t there a possibility that some of
the dust on the plastic will migrate to the edges and leave a dust
concentration at the perimeter?  Perhaps a visual inspection could be
included to check for that following the work activity.

Response:

The dust collection pans will be spread out on the plastic such that
they are representative of the area, including the perimeter.

In Table 2-4, isn’t the 2 phase/2 rooms (same unit) approach at the
Low work level 1 job and 1 site instead of 2 and 2?

Response:

Yes, this has been corrected.

Section 2.2.4 specifies the “scoop” sampling method for bare soil,
but I find the Appendix E 13.3 Soil Sampling Protocol confusing (and
I’m a former soil scientist).  On page 137 the scoop and core methods
are mentioned but the description only appears to be for the core
method.    Also, the core sampling technique as stated is
nonsensical—the text states that the samples are taken by driving the
sampler ½ inch(!) into the ground; I suggest that it should be ½ foot,
as subsequent text refers to shaving off the top ½ inch, and also
collecting a sample from the bottom inch of the six inch core.  

Also in Appendix E, page 138 section C. Bare Soil Sampling Procedures,
#5 has the following text “No special effort should be made to collect
visible paint chips.  If paint chips are present, they should not be
avoided and should be included in the sample.”  Obviously, the goal of
the Procedure is a representative sample, but this guidance is
problematic—if there is only one or a few paint chips present at the
sampling location, should the inspector include it (them) because the
other samples in the composite had no chips?  In such small composites,
might a large chip significantly bias the results?  If so, perhaps a
sampling template should be used so all samples are objectively taken in
the exact same locations in reference to the center of the work.  Or
perhaps the sample taker should seek an exact sampling location that is
visually representative of the general location (assuming the eye is
good at averaging paint chips). 

Response:

We will be using a standard protocol for soil collection, ASTM E1727-05
Standard Practice for Field Collection of Soil Samples for Subsequent
Lead Determination.  The soil coring tool is first driven into the
ground ½ inch before being pushed in further to 2 inches.  Only the top
½ inch of soil is retained for the sample.  

Paint chips can greatly influence a soil sample.  The soil samples are
being taken before the work begins and after the containment has been
removed and the work area cleaned. Therefore, paint chips should not
have a large effect on the soil samples or the technician’s decision
on where to take the soil samples.  Note that general locations for the
soil samples are pre-specified.

Comments on dust study site selection Plan

Figure 1-1, Organizational Structure: It appears that the EPA WAM sends
direction through the contractor’s principal investigator.  Is this
correct?  In later sections of the Plan, the WAM’s point of contact is
the contractor’s project manager.

Response:  

The WAM and DWAM typically interact with the principal investigator.  On
occasion, there may be interaction with the project manager.

p. 1-4: In Table 1-2’s Low Level Work column, one bullet repeats; also
in that column, should the exterior sanding and scraping be for
approximately 2 square feet, or 2 to an upper-bound-value of area?  At
what point does the area become significant enough to become a medium
level?

Response:

The list of jobs has been revised to better span the spectrum of jobs
covered by the proposed rule.  Both jobs and square footages have been
updated to be more representative of the three work levels

p. 1-4 and throughout document: the listed schedule must be updated

Response:  

This has been updated.

p. 1-5: how is “reasonably cleanable condition” defined?

Response:  

The initial assessment of the unit will be made by a certified risk
assessor, clearance technician, or lead abatement firm.

p. 2-5, Substrate Correction section: temperature and humidity are cited
as factors for XRF reading bias, but neither here nor later are there
indications of how these factors are accounted for.  In the instrument
calibration?  Monitored and corrected later?

Response:  

The XRF testing will be completed by certified XRF technicians who are
knowledgeable about the instrument and calibration activities.  The XRF
testing will include QC checks on the operation of the instrument. 
Paint lead concentrations measured by the XRF instrument will be
confirmed with paint chip samples taken prior to the start of the work. 


p. 2-9, section 2.5.3 Laboratory Spikes: one NIST procedure based on
0.5% lead is cited for the preparation of one spiked sample per batch. 
The spiked sample must be of similar concentration to the field samples
to be valid—is there any reason to believe that any other spiking
concentration may be needed?  If so, how will the spike be adjusted?

Response

The spike sample will include a NIST standard reference material at a
concentration that is on the same order of magnitude as what we expect
the results to be for the dust wipes.  This may include having spike
samples with ‘low’ and ‘high’ concentrations to represent the
range of dust lead we would expect from the study.  This will help
evaluate the validity of the laboratory’s analytical process.   

Comments from Reviewer FR7

There is a statement in section 1.5.2 of the QAPP for the site selection
plan that "The floors of all three rooms are desired to be smooth and
cleanable, i.e., wood, vinyl, or other non-carpeted surface is strongly
desired."  I believe I have mentioned before that the calculations for
the economic analysis indicated that carpeting may be a major route of
exposure in houses with RRP jobs.  Because carpeting is harder to clean
than a non-carpeted surface, it take much longer for dust levels to fall
to background levels.  I can imagine that introducing carpeted floors
would complicate the dust study due to the difficulty in testing for
dust levels on carpeting; the problem of cleaning or replacing carpeting
after the job to ensure protection of the occupants; and the issue of
reduced robustness of the replicates created by introducing another
variable.  But screening out sites with carpeting will exclude jobs that
may have a high potential to expose residents to significant dust
levels.

Response:

We agree that carpets are an important route of exposure to leaded dust,
however, budget and time constraints do not allow us to include these
samples in the current study in a manner that will yield definitive
results to address this question.  Including carpeted surfaces in the
study would likely understate the levels of lead dust from an RRP job
due to the pre-cleaning that is necessary to obtain comparable data
across the phases of an interior job.

Comments from Reviewer FR8

It is difficult to find items in the draft study design. I came across
an item called the “cleaning verification card (see photo)”. I could
not find the photo, and I think there should be some text indicating how
the card generated is obtained.  The pages should be numbered, the
inserted chapter 9 should be an insert and not an appendix. 

Response:

The photos of the cleaning verification cards are included in the Full
Study QAPP.  The cards are currently obtained from the docket of the
proposed rule found at   HYPERLINK "http://www.regulations.gov" 
www.regulations.gov , Docket ID: EPA-HQ-OPPT-2005-0049.  The page
numbering system has been modified so that all study and appendix pages
are easy to identify.

Comments from Reviewer FR9

Additional Comments on documentation provided: “Study Design and QAPP
for RRP Field Study”:

p. 1-1 Sec. 1.6 The contractors that will be conducting the renovation
work for this study are required to be certified as Lead Safe
Renovators. How will the impact of their high skill level relative to
other renovation workers be evaluated?

Response:   

All contractors will undergo Lead Safe Renovation training.  In the
state of Ohio, only one member of the contractor crew must be certified
as a Lead-Safe Renovator.  We are not hiring lead abatement firms to do
the job and do not anticipate that the contractors will have a high
skill level with respect to lead based paint activities. Study
contractors will follow the protocol laid out in the training materials
for the study and all activities will be monitored by the site
supervisor.

p. 1-7 Sec. 1.7 and Appendix C. Form 2. Will the property sketch for
exterior sites show neighboring buildings? If neighboring buildings are
close and contain flaking/chipping LBP they could cross-contaminate the
test site.

Response: 

The property sketch will include the distances to property lines or
other boundaries, including neighboring buildings.  The study protocol
also includes an evaluation of background concentrations due to
cross-contamination through sample collection trays set out prior to
starting an exterior job.

p. 2-10 Sec. 2.1.5.2 If TSP is not used, what is the recommendation for
the detergent?

Response:  

TSP will not be used for the cleaning in this study.  After consulting
with firms familiar with abatement cleaning, it has been decided that
Simple Green will be used as the cleaning detergent.

p. 2-15 Sec. 2.1.5.9 The description for cleaning verification of the
interior sills indicate that dry cloth wiping will be repeated until it
matches the cleaning verification card. No maximum number of repeats are
indicated in this section. However, on p.1-10 Sec 1.5.6, a maximum of 4
cleanings with a dry cloth are described as the cleaning verification
procedure.

Response:

The maximum number of attempts with the dry cloth is 4 for both
windowsills and floor surfaces.  This is reflected consistently in the
text.

p. 2-15 Sec. 2.1.5.9 What precautions are taken to prevent
cross-contamination of the cleaning cloths by the long-handled
application devices?

Response:

The cleaning cloths are used only for verification purposes.  A single
cleaning cloth is used only on one zone of the floor or one windowsill,
preventing any problems with cross-contamination.  Immediately after
each use, they will be placed in individual plastic bags to be saved for
quality assurance purposes.

p. 2-18, Sec. 2.2.3 NIOSH 7082 air sampling method is designed for
8-hour sampling period. If the job lasts longer than 8 hours, will the
filter be changed?

Response:   

The air monitor filters (for both indoor and personal) will be sampled
at three stages for interior jobs and only during the work stage for
exterior jobs.  No single stage should take more than eight hours to
complete, by study design.  If, however, eight hours pass during any
single stage, the air filter will be changed to ensure data quality.

p. 2-19 Sec. 2.2.6 Last sentence on page is incomplete.

Response:

Sentence has been revised.

p. 2-20 Sec. 2.4 Method D3335 is an atomic absorption spectroscopy
method not an ICP-MS method. D3335 is not included in Appendix F. EPA
Method 3050B, which is included in Appendix F, is an ICP-MS method.

Response:

The analytical methods have been revised and reflect the methods used by
Schneider Laboratories, Inc., the NLLAP-recognized laboratory selected
to analyze all environmental samples for this study.  

p. 2-23 Sec. 2.7 Soil should be added to the sample types to be
analyzed.

Response:  

 Soil samples are included in the study and all relevant information has
been updated in the QAPP.

Additional Comments on documentation provided: “QAPP for RRP Field
Study Site Selection”:

p. 2.7 Sec. 2.2.3 and p. 2-12 Sec. 2.10 Is the area of the paint chip
collected measured and recorded so that the lead levels can be reported
as mg/cm2 as well as   SEQ CHAPTER \h \r 1 g/g? This information
would be useful in estimating the total lead disturbed by a given RRP
job.

Response:

The detailed sampling protocol calls for 2 inch by 2 inch paint chip
samples.  The exact dimensions of the sampled chip will be recorded by
the field technician on the paint chip sample collection form.

p. 2-8, Sec 2.4 Method D3335 is an extraction procedure with atomic
absorption spectroscopy analysis not ICP-MS. D3335 is not included in
Appendix B but the extraction method E1645 is in Appendix B. No ICP-MS
procedure is included in the Appendices. 

Response:

The analytical methods have been revised and reflect the methods used by
Schneider Laboratories, Inc., the NLLAP-recognized laboratory selected
to analyze all environmental samples for this study.  

Appendix A. The E1729 – 99 method is no longer an active standard and
has been superseded by E1729-05. 

Response: 

 The appendix has been updated to reflect that paint chip samples will
be collected according to ASTM E1729-05 Standard Practice for Field
Collection of Dried Paint Samples for Subsequent Lead Determination.

Appendix B.  Analytical Methods.  E1645 is included in Appendix but is
not referenced in the text. E1645 is an extraction method not an
analytical method.

Response:  

The analytical methods have been revised and reflect the methods used by
Schneider Laboratories, Inc., the NLLAP-recognized laboratory selected
to analyze all environmental samples for this study.  

Appendix B.  Analytical Methods. There are no analytical methods
included in this Appendix.

Response:  

The analytical methods have been revised and reflect the methods used by
Schneider Laboratories, Inc., the NLLAP-recognized laboratory selected
to analyze all environmental samples for this study.  

Samples:

Samples that might provide additional information within the context of
the questions being asked: 

The design for the child-occupied facilities (COFs) would be improved by
conducting two jobs, rather than one, from each job category. 

Response:

While increasing the number of jobs performed would increase the amount
of data for analysis, time and budget constraints prohibit doubling the
number of jobs for COFs.

An estimate of potential lead cross-contamination from adjacent
buildings, roadways, air-entrained soil, etc. needs to be added to the
exterior sample collection design.  Prior to beginning work and setting
up containment, dust collection trays should be placed in the same
locations that will be used during the renovations. The length of
exposure should equal the time that the dust collection trays will be
exposed during the renovation. If no additional exterior samples can be
added to this study, I would recommend the substitution of these
cross-contamination check samples for the soil samples currently
included in the design.

Response:

 We agree that sampling background concentrations for
cross-contamination estimates is a valuable addition to the study. The
study protocol has now been modified to sample dust collection trays
before exterior experiments begin. 

There are no samples being collected during the renovation that will
provide lead concentrations of soil/dust tracked into the house from the
outside or from other parts of the building that might contribute to the
hallway lead concentrations

Response:

Soil samples from three exterior locations will be collected prior to
the start of interior jobs to evaluate potential track-in from the
outside. The three samples will be taken from bare soil nearest to (1)
the entryway to the building used by the workers, (2) the walkway from
the entryway to the street, and (3) a window closest to the work area. 
Track-in from other parts of the building should not be an issue due to
the thorough cleaning of the property prior to the start of the work.

Samples providing limited value in addressing the study questions:

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&determine if there was any contamination of soil due to study
activities.  For exterior jobs, soil samples are valuable in addressing
the effectiveness of the plastic containment, as well as assessing
potential track-in. 

 

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August 18, 2006

