oversight

Saraland Manor Apartments Gulfport, Mississippi

Published by the Department of Housing and Urban Development, Office of Inspector General on 2004-03-05.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                     U.S. Department of Housing and Urban Development
                                                     Office of the Inspector General for Audit, Region 4
                                                     Richard B. Russell Federal Building
                                                     75 Spring Street, SW, Room 330
                                                     Atlanta, GA 30303-3388
                                                     (404) 331-3369




                                                     Memorandum No.
March 5, 2004                                        2004-AT-1802


MEMORANDUM FOR:              Ziva James, Acting Director, Jackson Multifamily Program Center,
                               4GHMLAV, and

                             Elizabeth Hanson, Director, REAC, PX




FROM:           Sonya D. Lucas
                Acting Regional Inspector General for Audit, 4AGA

SUBJECT:        Saraland Manor Apartments
                Gulfport, Mississippi


                                      INTRODUCTION

This memorandum report presents the results of an Office of Inspector General (OIG) inspection
of the Saraland Manor Apartments, 8010 Highway 49, Gulfport, Mississippi. The OIG
conducted a physical inspection of the project in response to a complaint forwarded by Senator
Trent Lott. The complaint, signed by numerous tenants, cited declining and substandard living
conditions.

Saraland is a multifamily apartment project consisting of 2 3-story buildings with 101 apartment
units. Saraland serves elderly and handicapped residents and 100 percent of the apartments are
Section 8 subsidized. Saraland was first occupied 22 years ago in December 1981.

In accordance with the Department of Housing and Urban Development (HUD) Handbook
2000.06 REV-3, OIG concurs with the management decisions taken or planned in response to
the recommendations in this report. The management decisions are included in the Jackson field
office and Real Estate Assessment Center (REAC) written replies to the draft report, which are
attached herein as Appendices C and D, respectively. Please provide us with a copy of the field
office management review report when that planned review has been completed.
                                METHODOLOGY AND SCOPE

An OIG appraiser-construction specialist inspected the property during the week of August 18,
2003. Deficiencies identified by OIG’s inspector were documented in photographs and written
record. Our inspection included the exteriors and common areas of the 2 apartment buildings, and
interiors of 32 apartment units. A project maintenance man accompanied us during our inspection.
During our inspection, maintenance personnel informed us that they had fixed some of the
deficiencies we had identified. OIG observed that certain deficiencies, such as replacing light bulbs
in exit signs and stairways, were made. However, OIG did not verify all repairs cited by the
maintenance personnel.

We also compared the deficiencies we identified to the results of the HUD REAC’s last inspection
on July 1, 2003.

                                    RESULTS OF REVIEW

Our inspection identified numerous deficiencies in building exteriors, common areas, and in the
32 apartments. Most of the deficiencies were the result of the project’s age and inadequate
maintenance and repairs. The most significant and frequently noted deficiencies are cited below.
Numerous health (sanitation) and safety deficiencies we identified in the apartment units were
not cited in the last REAC inspection. We concluded that the last REAC inspection did not
identify all significant health and safety deficiencies and that the owner/management agent did
not operate an adequate maintenance program. Appendix A lists all the deficiencies we noted,
and Appendix B contains photographs illustrating the deficiencies.

We discussed the apparent disparities between our inspection results and the July 1, 2003,
inspection by a REAC contract inspector, with a REAC official. He stated that REAC has
quality assurance procedures in place, and REAC would be agreeable to review and, if
necessary, re-inspect the property to assess whether the REAC inspection did not properly
identify deficient conditions.

HUD regulations, 24 Code of Federal Regulations, Part 5, Subpart G, and Part 200, require that
HUD housing, as defined in the rule, must meet Uniform Physical Condition Standards (UPCS)
to ensure that the HUD housing is decent, safe, sanitary, and in good repair.

Apartment Units

We noted significant deficiencies in the condition of kitchen cabinets, stove vent hoods, and
bathroom vanities that were observed in most of the 32 apartment units we inspected. In our
opinion, these conditions are health and safety deficiencies under HUD Regulations.
Furthermore, these conditions were not reflected in the REAC inspection on July 1, 2003.

   •   Nearly all of the 32 apartment units inspected had severely deteriorated kitchen sink
       cabinets and countertops, making it impossible for tenants to maintain sanitary food
       preparation areas. Cabinets were delaminating and had rotted shelves. Countertops were
       worn or heavily marred and the underlay material was crumbling. In a few apartments,
       replacement cabinets had been installed with numerous unfinished surfaces.

                                                 2
   •   Stove vent hoods were rusting and/or had exposed wiring and light bulbs in 25 apartment
       units. The exposed wires and bulbs are directly over the cook tops where they are
       exposed to steam condensation and food spatters, which we consider safety hazards. The
       rusting vent hoods are an unsanitary condition over the cook tops. We also noted
       exposed wires on a garbage disposal unit in one apartment.

   •   Bathroom vanities in 22 units were deteriorated with rotted shelves, and delaminating or
       unfinished surfaces. These conditions made it impossible for tenants to maintain sanitary
       bathrooms.

Other deficiencies we noted included the following.

Windows in living rooms and bedrooms were in poor condition despite recent repairs to some.
Windows were too difficult to operate (open, close, and lock), particularly for the elderly
residents. Missing or damaged trim and broken thermoseals allowed air and moisture
penetration from the outside.

In six apartments, in water heater closets, holes through the ceilings for water and drainpipes
were not sealed. The holes are a safety hazard and should be sealed as a fire barrier.

Numerous deficiencies in routine maintenance and repairs were noted. Examples included
excessively dirty Heat/Air Conditioning (HVAC) filters, water damaged ceilings and walls, and
loose and worn through floor tiles.

Building Exteriors & Common Areas

We noted exposed electrical wires at the connection to a roof Air Conditioner (AC) Unit on
Building B. This is an exigent safety hazard. REAC’s last inspection also noted two similar
exposed electrical connections. We also noted other loose AC electrical connections.

The meter room in Building A had exposed electrical wires due to a missing junction box cover
and an open breaker box slot. These are safety hazards.

Missing and burned out florescent light tubes and missing tube covers were noted in stairways
and halls throughout both buildings. Light bulbs in emergency exit signs were also burned out in
multiple locations in both buildings. Poor lighting in these areas is a safety hazard for residents.
The prior REAC inspection did not cite these conditions.

Non-functioning AC condensation lines and pooling water were noted on the roofs of both
buildings. The conditions made the roofs slippery and hazardous for maintenance personnel, and
can cause water damage to interior areas.

There was a large crack and upheaval in the concrete walkway for Building A. This is a tripping
hazard for the elderly residents.

The trash dumpster at Building B was missing one cover and the second cover was open and
damaged. This is a health hazard.

                                                 3
Damaged, missing, and heavily worn floor tile was noted in several common area hall and
stairwell locations. These conditions could present a tripping hazard to elderly residents.

The entryway light fixtures were missing light bulb covers on both buildings.

HUD Jackson Field Office Comments

The field office proposed to conduct a management review of the property by July 1, 2004, to
verify that deficiencies noted in the latest REAC report have been corrected and to verify that
acceptable management controls are in place and are being implemented properly.

REAC Comments

On February 5, 2004, REAC Quality Assurance performed a re-inspection of the property and
determined that the physical inspection score resulting from the prior (July 1, 2003) inspection
accurately reflected the condition of the property.

REAC noted that: “In most instances where the PIH-REAC inspection results differ from the
results of the OIG inspection, the differences are attributable to disparities in inspection
standards between the OIG and the Uniform Physical Condition Standards (UPCS) related to
definitions and proportionality.”

OIG Evaluation of HUD Comments

OIG concurs with the field office management decisions.

OIG also concurs with the action taken by REAC, however, we are troubled by the inspection
results. REAC confirmed a passing physical condition score of 67. REAC notes that its UPCS
does not recognize many of the conditions noted in this report as deficiencies. For example,
REAC’s inspection did not identify any deficiencies related to (1) unit kitchen sink cabinets,
(2) unit stove hoods, (3) living room and bedroom windows, and (4) burned out lights in
common areas. REAC cited the following UPCS criteria for these four conditions:

   1. A deficiency exists when cabinets are missing or the laminate is separating. “The
      criticality level is based on proportionality, i.e.; for Level 2: 10 to 50 percent of the
      cabinets, doors, or shelves are missing or the laminate is separating.” Level 3 is for more
      than 50 percent. There is no level 1 deficiency for cabinets.

   2. The UPCS does not define rust and the absence of a lens cover over exposed wires and
      light bulbs as defects in stove vent hoods.

   3. A window deficiency is a Level 2 when most of the window shows missing or
      deteriorated caulk, or Level 3 when there is missing or deteriorated caulk or seals with
      evidence of leaks or damage to the window or surrounding structure.




                                               4
   4. In common areas where light bulbs are inoperable, light bulbs are not to be considered in
      the cumulative percentage if the fixture is proven operable. The definition addresses
      broken fixtures; bulbs are not addressed.

The UPCS criteria cited by REAC does not explain why no deficiencies were noted in sink
cabinets, and few were noted in living room and bedroom windows. As illustrated in the
Appendix B photos, sink cabinets had severe delaminations, crumbling underlay material, and
rotted shelves; and some of the windows exhibited damage due to moisture intrusion. Exposed
wiring and light bulbs directly over cook tops are subject to steam condensation and food
splatters, and in our opinion are safety hazards. We also note that the vent hoods were designed
to have lens covers over the wires and bulbs. We believe that numerous burned out lights in
common areas is one clear indicator of inadequate routine maintenance and should be addressed
by the HUD inspection standard. Many of the burned out bulbs were replaced because of our
inspection.

REAC concurred that certain other conditions found by our inspection in August 2003 were
defects under the UPCS, but noted that its July 2003 inspection and its February 2004 re-
inspection did not find them. Examples include water pooling on roofs, tape over electrical box
slot openings, and defective electrical Ground Fault Interrupters (GFI).

It is beyond the scope of this inspection report to address these concerns with the REAC
inspection system and the UPCS. OIG will consider these concerns in its annual audit planning
process.

                                   RECOMMENDATIONS

Recommendations for HUD’s Jackson Multifamily Program Center:

1A. Conduct a management review of Saraland as soon as possible in fiscal 2004. Assess why
management has not performed routine maintenance and repairs, and whether management
scheduled repairs of deficiencies identified by REAC inspections.

1B. Require the owner/management agent to implement adequate management controls to
ensure health and safety hazards and other routine maintenance needs are timely identified and
promptly corrected. For example, management should continually maintain a log of needed
repairs including the date each item was reported or identified, and the date each repair was
completed. Management should also post instructions for employees and tenants to report safety
and health hazards and other maintenance needs as soon as they are noticed.

Recommendation for REAC:

1C. Re-inspect Saraland Manor to determine whether: (1) a revised physical condition score
and correlating revisions of the repairs required by REAC are needed, and (2) corrective actions
to address the contract inspector’s performance are warranted.




                                                5
                                                                                    Appendix A

                           SARALAND MANOR APARTMENTS
                                 Gulfport, Mississippi


                     Building Exterior and Common Area Deficiencies

Building A: Exterior
   • Loose electrical connections to roof AC units.
   • Roof AC condensation lines are not in working order. Water pools on the roof.
   • Exterior T-111 siding panels are deteriorated.
   • Exterior stucco wall panels show some damage near the foundation. Probable cause is
       lawn maintenance equipment.
   • Tree limbs have not been trimmed away from the roof and siding.
   • The front entry canopy light fixtures are missing the globe covers.
   • The front entry aluminum canopy roof has had little or no maintenance since the roof was
       installed. The roof exhibits an excessive amount of rust and an accumulation of pine
       needles and leaves.
   • The concrete walkway has a large crack and upheaval, creating a tripping hazard.

Building A: Common Areas
   • Light fixtures in exit stairwells have missing or burned out bulbs and no lens covers.
   • The exit signs throughout building had no working bulbs or only one working bulb.
   • The laundry room floor has several chipped and/or damaged tiles near the drain.
   • The Common Social Room for tenants has a sink cabinet in disrepair – rotted out bottom
       shelf, drawers that will not open and close properly, and delaminations.
   • The common hallway has an electrical outlet cover plate that is not properly secured to
       the wall.
   • Each common hall vent fan is either missing or inoperative.

Building A: Maintenance & Utility Room
   • The tub faucet will not turn off the water.
   • The cover for the electrical junction box is missing. Electrical wiring is exposed.
   • The electrical panel box is missing a slot cover for a breaker opening.

Building B: Exterior
   • The electrical cable sheathing is disconnected at the AC unit on the roof, exposing
       electrical wiring. This is an exigent safety hazard.
   • The roof turbine vent cover is not secured in place.




                                               6
                                                                                     Appendix A

   •   The tree limbs are endangering the roof and siding.
   •   The gutter on the elevator tower roof is rusted out and partially filled with gravel.
   •   There are several broken roof drain caps.
   •   The roof AC condensation lines are not in working order, causing water to pool on the
       roof.
   •   The exterior T-111 siding panels are deteriorated.
   •   The front entry canopy light fixtures are missing the globe covers.
   •   The front entry aluminum canopy roof has had little or no maintenance since it was
       installed. The roof exhibits excessive rust and an accumulation of pine needles and
       leaves.
   •   The exterior stucco has been damaged in many areas.
   •   An AC compressor unit is rusting from sitting on the ground. Also, there is a loose
       wiring connection at the wall.
   •   The roof flashing is not sealed on the attached storeroom. Water is seeping under the
       flashing and onto the siding.

Building B: Common Areas
   • The exit signs throughout this building either had no working bulbs or only one working
       bulb.
   • The exit stairwells have several light fixtures with missing or burned out light bulbs and
       no lens covers.
   • An electrical wall outlet is not adequately secured to, and is not flush with the wall.
   • The tenant’s arts and craft room:
           o exposed electrical wiring.
           o missing light fixture globe covers.
           o missing kitchen vent hood light cover with electrical wiring exposed.
           o kitchen sink cabinet and counter top in disrepair.
           o plumbing leak that has created a mold and mildew health hazard.
   • The tenant’s game/social room:
           o window sashes with broken seals, allowing air and moisture to enter the thermo
               pane areas. Glass in these sashes was recently replaced, but was not adequately
               trimmed and sealed by the contractor.
           o the sink bottom shelf is completely rotted out.

   •   Each common hall vent fan is either missing or inoperative.

Building B, Maintenance Room:
   • The cover for the wall vent fan is missing.

Exterior Deficiencies Affecting All Units:
   • The asphalt drive has deteriorated; resurfacing is needed in lieu of sealing.
   • Trash dumpsters do not have covers.
   • Parking signs for the handicapped are rusted out or missing.



                                                7
    Appendix A




8
                                                                          Appendix B


                     Photo Examples of Cited Conditions




No.1, Building A Roof – Pooling water due to defects in AC condensation lines.




              No. 2, Building A – Exterior siding panel is rotted.
                 This condition was noted in several places.


                                       9
                                                                          Appendix B




No. 3, Building A – Crack and upheaval in walkway is a tripping hazard.




No. 4, Building B – Trash dumpster with missing and damaged covers.




                                  10
                                                        Appendix B




No. 5 & 6, Buildings A and B, stairwells – Burned out
      or missing bulbs and missing lens covers.



                         11
                                                             Appendix B




No. 7, Unit 101A – Water heater closet – plumbing holes in
         ceiling not sealed to provide fire barrier.




     No. 8, Building A- Meter room – exposed wiring

                           12
                                                                                 Appendix B




No. 9, Building A Meter room – Electrical breaker box, open breaker slot covered with tape.




 No. 10, Building B Roof – Exposed AC electrical wires due to separated cable sheathing.


                                            13
                                                                 Appendix B




No. 11, Unit 101A – Electrical breaker slot covered with tape.




No. 12, Unit 318B – GFI breaker for bathroom was defective.



                             14
                                                                             Appendix B




No. 13, Building A Common room – sink cabinet sides and bottom shelf are rotted out.




             No. 14, Unit 112B – Arts and Crafts room – sink cabinet is
                delaminating and countertop underlay is crumbling.

                                        15
                                                                        Appendix B




No. 15, Unit 112B – Arts and Crafts room – exposed electrical wiring.




No. 16, Unit 309A – Stove vent hood is rusted, bulb cover is missing, and
  wiring exposed. This condition was similar in most apartment units.


                                   16
                                                                      Appendix B




No. 17, Unit 214A – Kitchen sink cabinet is delaminating. Countertop underlay is
     crumbling. Similar conditions were noted in nearly all units inspected.




   No. 18, Unit 314A – Kitchen sink cabinet, sidewall and bottom
                 shelf are rotted out and mildewed.

                                 17
                                                                     Appendix B




    No. 19, Unit 318B – Wall under kitchen sink is in disrepair.
      Mold is accumulating. Plumbing holes are not sealed.




No. 20, Unit 203B – Kitchen sink cabinet has delaminated. Underlay
         material for doors and countertop are crumbling.

                                18
                                                                         Appendix B




  No. 21, Unit 103B – Kitchen cabinets were replaced, but staining
             was incomplete and shelving was omitted.




No. 22, Unit 203B – Bathroom vanity is delaminating. Side finish and
 inside shelf surface are deteriorated and not impervious to moisture.
                                 19
                                                                        Appendix B




No. 23, Unit 101B – Bathroom floor has damaged and missing tiles.
    Wall repairs were not painted. Vinyl baseboard is missing.




No. 24, Building B, east stairwell – missing and damaged floor tiles.

                                 20
                                                                           Appendix B




No. 25, Unit 308A – Dining area floor tiles are completely worn through.




  No. 26, Unit 301A – Peeling paint in utility closet. Tenant stated the
              apartment had not been painted in 16 years.

                                   21
                                                                           Appendix B




No. 27, Unit 301A – The living room ceiling to wall joint has separated.




     No. 28, Unit 303A – Water damage to living room ceiling has
           not been repaired. Trim molding was not painted.

                                  22
                                                                                   Appendix B




        No. 29, Unit 214 A – Living room window shows deterioration and mildew due
              to moisture damage. The glass panes were not adequately sealed.




No. 30, Unit 203B – Moisture damaged drywall at window frame. The age and condition of
      window units makes them too difficult to operate, and subject to moisture intrusion.

                                              23
                                                                                     Appendix C



                                          U. S. Department of Housing and Urban
                                                       Development

                                        Mississippi State Office, Southeast / Caribbean
                                      Dr. A. H. McCoy Federal Building, Room 910
                                      100 West Capitol Street
                                      Jackson, Mississippi 39269-1096

February 20, 2004



MEMORANDUM FOR: Sonya Lucas, Acting Regional Inspector General for Audit, 4AGA


FROM: Ziva M. James, Acting Director, Jackson Multifamily Program Center, 4GHM


SUBJECT: Project No.065-EH006
           Saraland Manor Apartments
    Gulfport, Mississippi


Attached is the Jackson Mississippi Program Center’s written response to the Draft

OIG Memorandum Report for the subject property. Included are the proposed corrective actions

and dates of completion for each recommendation. If you have any questions, please feel free to

contact Bill Duckworth at (601) 965-4700, extension 3022.


Attachment




                                             24
                                                                                             Appendix C


Recommendation                         Proposed Corrective Action by        Proposed Date of Completion
                                       Jackson Field Office
1A.    Conduct a management            During fiscal year 2004, the         July 1, 2004
      review of Saraland as soon       Jackson Multifamily Program
      as possible in fiscal 2004.      Center (JMFPC) will conduct a
      Assess why management has        management review of the
      not    performed      routine    property to verify that
      maintenance and repairs,         deficiencies noted in the latest
      and whether management           REAC report have been
      scheduled     repairs      of    corrected. In addition, JMFPC
      deficiencies identified by       will secure and review the
      REAC inspections.                project’s standard written
                                       procedure that explains the
                                       process for inspecting units and
                                       the timeframe for completing
                                       repairs under the procedure.

1B.      Require      the     owner/   During fiscal year 2004, the         July 1, 2004
      management         agent    to   Jackson Multifamily Program
      implement             adequate   Center (JMFPC) will conduct a
      management controls to           management review of the
      ensure health and safety         property to verify that acceptable
      hazards and other routine        management controls are in
      maintenance       needs    are   place and are being implemented
      timely      identified    and    properly. If deficiencies are
      promptly corrected.        For   uncovered in management
      example,          management     controls, project management
      should continually maintain      will be instructed to correct all
      a log of needed repairs          deficiencies.
      including the date each item
      was reported or identified,
      and the date each repair was
      completed.        Management
      should also post instructions
      for employees and tenants to
      report safety and health
      hazards        and       other
      maintenance needs as soon
      as they are noticed.




                                                     25
     Appendix D




26
     Appendix D




27
     Appendix D




28
                                                                                              Appendix D


                                            APPENDIX A

                               SARALAND MANOR APARTMENTS
                                   GULFPORT, MISSISSIPPI

         OIG FINDING                                        PIH-REAC RESPONSE
Building A: Exterior

  •   Loose electrical connections to   This deficiency was identified by the contract inspector during
      roof A/C units                    Inspection Number 185691 and by OIG. The defect may have
                                        been repaired, as it was not identified during the re-inspection by
                                        PIH-REAC QA.

  •   Roof A/C condensation lines       The PIH-REAC definition of pooling is that there is evidence of
      are not in working order.         areas of standing water--roof depression, mold ring, or
      Water pools on the roof.          effervescence water ring. The only criticality level is Level 3,
                                         which requires evidence of standing water on the roof, causing
                                        potential or visible damage to roof surface or underlying
                                        materials. This condition was not reported by either the contract
                                        inspector or QA inspector.

  •   Exterior T-111 siding panels      REAC inspector recorded Level 2 – Walls (Building Exterior) –
      are deteriorated                  Missing Pieces/Holes/Spalling The defect may have been
                                        repaired, as it was not identified during the re-inspection by PIH-
                                        REAC QA..

  •   Exterior stucco wall panels       The contract inspector recorded this condition as a Level 1 –
      show some damage near the         Walls (Building Exterior) - Missing/Damaged Caulking/Mortar.
      foundation. Probable cause        The defect may have been repaired, as it was not identified during
      is lawn maintenance               the re-inspection by PIH-REAC QA.
      equipment.

  •   Tree limbs have not been          The PIH-REAC definition for a deficiency is Site -
      trimmed away from the roof        Overgrown/Penetrating Vegetation (Grounds); plant life has
      and siding.                       spread to unacceptable areas, unintended surfaces, or has grown
                                        in areas where it was not intended to grow. Criticality levels can
                                        be Levels 2 or 3. To be reported as a Level 2 deficiency, the
                                        vegetation is extensive and dense; it is difficult to see broken
                                        glass, holes, and other hazards or vegetation contacts or
                                        penetrates an unintended surface--buildings, gutters, fences/walls,
                                        roofs, HVAC units, etc.--but you see no visible damage. To be
                                        reported as a Level 3 deficiency, plants have visibly damaged a
                                        component, area, or system of the property or have made them
                                        unusable/unpassable. Neither condition was reported by either
                                        the contract inspector or the QA inspector.




                                                    29
                                                                                                Appendix D


   •   Front entry canopy light         Based on REAC definitions, missing globe covers, while
       fixtures are missing the globe   unsightly, do not constitute a defect, unless the condition
       covers                           constitutes an obvious safety hazard. This condition was not
                                        reported by the QA inspector.

   •   Front entry aluminum canopy      The contract inspector recorded a Level 2 – Building Exterior –
       roof has had little or no        Walls - Stained/Peeling/Needs Paint. This appears to be the
       maintenance since the roof       correct categorization for such a deficiency. This condition was
       was installed. The roof          not reported by the QA inspector.
       exhibits an excessive amount
       of rust and an accumulation
       of pine needles and leaves.

   •   Concrete walkway has a           Based on the photograph provided by the OIG, the upheaval
       large crack and upheaval,        does not appear to be severe. This property houses senior citizens
       creating a tripping hazard.      and the definition of a deficiency for walkways includes the note
                                        “…when observing traffic ability, consider the capacity to
                                        support pedestrians, wheelchairs, and people using walkers”.
                                        Although the single crack would not meet the definition of a
                                        deficiency due to the required proportionality of a minimum of
                                        5% being met, it could constitute a tripping hazard. Apparently,
                                        in the contract inspector’s judgment, the crack was not significant
                                        enough to report as a health and safety defect.. This condition
                                        was not reported by the QA inspector.


Building A: Common Areas
.
   • Light fixtures in exit             Based on REAC definition and Compilation Bulletin; in common
       stairwells have missing or       areas where light bulbs are inoperable, light bulbs are not to be
       burned out bulbs and no lens     considered in the cumulative percentage if the fixture is proven
       covers                           operable. The definition addresses broken fixtures; bulbs are not
                                        addressed. 20%-50% of the permanent lighting fixtures must be
                                        missing or damaged for it to be categorized as a Level 2
                                        deficiency. This condition was not reported by the QA inspector.

   •   Exit signs throughout            Missing Exit Signs (Emergency/Fire Exit) are recorded as
       building had no working          deficiencies when exit signs that clearly identify all emergency
       bulbs or only one working        exits are missing or there is no illumination in the area of the sign
       bulb.                            (this would include if there is a window near the sign). This
                                        condition was not reported by either the contract inspector or the
                                        QA inspector.




                                                     30
                                                                                                  Appendix D


   •   Laundry room floor has             The contract inspector recorded a Level 1 deficiency for this
       several chipped and/or             condition. This condition was not reported by the QA inspector.
       damaged tiles near the drain.


   •   Common Social Room for             Based on UPCS inspection protocol, the correct place to record
       tenants has a sink cabinet in      this deficiency is under Common Areas – Kitchen. According to
       disrepair – rotted out bottom      the definition for Cabinets - Missing/Damaged (Common Areas),
       shelf, drawer that will not open   a deficiency exists when cabinets are missing or the laminate is
       and close properly,                separating. This includes cases, boxes, or pieces of furniture with
       delaminations.                     drawers, shelves, or doors--primarily used for storage--mounted
                                          on walls or floors. The criticality level is based on
                                          proportionality, i.e.; for Level 2: 10-50% of the cabinets, doors,
                                          or shelves are missing or the laminate is separating. The contract
                                          inspector reported Common Area – Kitchen as not applicable.
                                          This condition was not reported by the QA inspector, however he
                                          did identify a Level 1 – Walls – Water Stains/Water
                                          Damage/Mold/Mildew and an H&S Air Quality for
                                          Mold/Mildew.

   •   Common hallway has an              UPCS inspection protocol does not address where to record an
       electrical outlet cover plate      unsecured outlet cover plate. The definition for
       that is not properly secured to    Outlets/Switches/Cover Plates (Common Areas) states that a
       the wall.                          deficiency exists when the flush plate that covers the opening
                                          around a switch or outlet is damaged or missing, or a switch or
                                          outlet is missing. This condition was not reported by the QA
                                          inspector

   •   Each common hall vent fan is       The contract inspector did not associate this HVAC condition
       either missing or inoperative      with hallways; however, he did record two Level 3 HVAC –
                                          Inoperable defects for the Lobby and the Laundry room. The QA
                                          inspector recorded a Level 2 defect for Restrooms/Pool
                                          Structures - Ventilation/Exhaust System – Inoperable.


Building A: Maintenance &
Utility Room

   •   Tub faucet will not turn off the   Based on UPCS inspection protocol, the only place this
       water                              deficiency could have been recorded is under Common Areas –
                                          Kitchen or Bathroom. The defect may have been repaired, as it
                                           was not identified during the re-inspection by the QA inspector.




                                                        31
                                                                                                  Appendix D


    •   The cover for the electrical    Based on the photograph provided by OIG, it appears that all of
        junction box is missing.        the wires are capped, which is acceptable. The definition for
        Electrical wiring is exposed.   Electric Hazard notes that if the accompanying authority has
                                        identified abandoned wiring, capped wires do not pose a risk and
                                        should not be recorded as a deficiency. A deficiency was not
                                        reported by the QA inspector.

    •   The electrical panel box is     Based on the photograph provided by OIG, the slot is covered by
        missing a slot cover for a      a piece of tape, which is not an appropriate method of blanking
        breaker opening.                off the slot. This condition was not reported by either the
                                        contract inspector or the QA inspector.


Building B: Exterior

    •   Electrical cable sheathing is   The contract inspector recorded this deficiency as Electrical
        disconnected at the A/C unit    Hazards – Exposed Wires/Open Panels (LT) – Location; roof,
        on the roof, exposing           with the comment “exposed wire in unsecured a/c disconnect
        electrical wiring.              box”. The defect may have been repaired, as it was not
                                        identified during the re-inspection by PIH-REAC QA.
.
    •   Roof turbine vent cover is      This condition would be a deficiency if a potential Electric
        not secured in place.           Hazard exists due to exposed wires or the possibility of water
                                        leaking, puddling, or ponding on or immediately near the device
                                        which could pose a risk of fire, electrocution, or explosion. This
                                        condition was not reported by either the contract inspector or the
                                        QA inspector.

    •   The tree limbs are              The PIH-REAC definition of a deficiency is Site –
        endangering the roof and        Overgrown/Penetrating Vegetation (Grounds); plant life has
        siding                          spread to unacceptable areas, unintended surfaces, or has grown
                                        in areas where it was not intended to grow. Criticality levels can
                                        be Levels 2 or 3. To be reported as a Level 2 deficiency, the
                                        vegetation is extensive and dense; it is difficult to see broken
                                        glass, holes, and other hazards or vegetation contacts or
                                        penetrates an unintended surface--buildings, gutters, fences/walls,
                                        roofs, HVAC units, etc.--but you see no visible damage. To be
                                        reported as a Level 3 deficiency, plants have visibly damaged a
                                        component, area, or system of the property or have made them
                                        unusable/unpassable. Neither condition was reported by either
                                        the contract inspector or the QA inspector.




                                                        32
                                                                                            Appendix D


•   Gutter on the elevator tower   Rusted gutters are not addressed in the definition of
    roof is rusted out and         Missing/Damaged Components from Downspout/Gutter (Roofs).
    partially filled with gravel   A deficiency exists when the components of the drainage system-
                                   including gutters, leaders, downspouts, splashblocks, and drain
                                   openings--are missing or damaged. The criticality levels for a
                                   deficiency are Level 1: splashblocks are missing or damaged;
                                   Level 2: drainage system components are missing or damaged,
                                   but there is no visible damage to the roof, structure, exterior wall
                                   surface, or interior; and Level 3: drainage system components are
                                   missing or damaged, causing visible damage to the roof,
                                   structure, exterior wall surface, or interior. Note: This does not
                                   include clogged drains, which are addressed in “Building Exterior –
                                   Roofs - Clogged Drains.” The definition specifically states that
                                   this deficiency does not include gutters and downspouts. Neither
                                   the contract inspector, nor the QA inspector, reported a
                                   deficiency.

    •   Broken roof drain caps     The contract inspector did not record this deficiency, which
                                   should have been recorded as Level 2 - Missing/Damaged
                                   Components from Downspout/Gutter (Roofs). The defect may
                                   have been repaired, as it was not identified during the re-
                                   inspection by the QA inspector.

    •   Roof of A/C                The PIH-REAC definition of pooling is that there is evidence of
        condensation lines are     areas of standing water--roof depression, mold ring, or
        not in working order,      effervescence water ring. The only criticality level is Level 3,
        causing water to pool      which requires evidence of standing water on the roof, causing
        on the roof                potential or visible damage to roof surface or underlying
                                   materials. This condition was not reported by either the contract
                                   inspector or the QA inspector.

    •   Exterior T-111 siding      Both the contract inspector and the QA inspector recorded this
        panels are deteriorated    deficiency as Level 2 – Walls (Building Exterior) - Missing
                                   Pieces/Holes/Spalling.

    •   Front entry canopy light   Based on REAC definitions, missing globe covers, while
        fixtures are missing the   unsightly, do not constitute a defect, unless the condition
        globe covers               constitutes an obvious safety hazard. This condition was not
                                   reported by the QA inspector.




                                                  33
                                                                                               Appendix D


       •   Front entry aluminum         The contract inspector did not record a deficiency reflecting this
           canopy roof has had little   condition, he did, however, record a Level 1 deficiency for
           or no maintenance since      Building Exterior – Walls - Stained/Peeling/Needs Paint. The
           it was installed. The roof   defect may have been repaired, as it was not identified during the
            exhibits excessive rust     re-inspection by the QA inspector.
           and an accumulation of
           pine needles and leaves

       •   Exterior stucco siding       The contract inspector recorded Level 1 – Walls (Building
           has been defaced in many     Exterior) - Missing/Damaged Caulking/Mortar.. The defect may
           areas                        have been repaired, as it was not identified during the re-
                                        inspection by the QA inspector.

       •   A/C compressor unit is       The contract inspector did not identify a deficiency for this
           rusting from sitting on      condition. The issue is whether the compressor functions as
           the ground. Also, there      designed. A health and safety deficiency would exist if the loose
           is a loose wiring            wiring includes any exposed wires that may create a health and
           connection at the wall       safety hazard. No photograph was provided, so the exact
                                        condition is unclear. The QA inspector identified a deficiency for
                                        HVAC – General Rust/Corrosion – Level 2 for Building B (2)
                                        Building Systems.

       •   Roof flashing is not         The contract inspector recorded a deficiency as Level 1 – Roofs –
           sealed on the attached       Damaged Soffits/Fascia, which may have been the same
           storeroom. Water is          condition referenced in the draft OIG report. The defect may
           seeping under the            have been repaired, as it was not identified during the re-
           flashing and onto the        inspection by the QA inspector.
           siding

       •   Exterior stucco wall         The contract inspector recorded Level 1 – Walls (Building
           panels show some             Exterior) - Missing/Damaged Caulking/Mortar. The defect may
           damage near the              have been repaired, as it was not identified during the re-
           foundation area              inspection by the QA inspector.



Building B: Common Areas

   •   Exit signs throughout this       Based on REAC definition and Compilation Bulletin; in common
       building either had no working   areas where light bulbs are inoperable, light bulbs are not to be
       bulbs or only one bulb was       considered in the cumulative percentage if the fixture is proven
       working                          operable. The definition addresses broken fixtures; bulbs are not
                                        addressed. 20%-50% of the permanent lighting fixtures must be
                                        missing or damaged for it to be categorized as a Level 2
                                        deficiency. This condition was not reported by the QA inspector.




                                                     34
                                                                                               Appendix D


•   Exit stairwells have several     Based on REAC definition and Compilation Bulletin; in common
    light fixtures with missing or   areas where light bulbs are inoperable, light bulbs are not to be
    burned out light bulbs and no    considered in the cumulative percentage if the fixture is proven
    lens covers                      operable. The definition addresses broken fixtures; bulbs are not
                                     addressed. 20%-50% of the permanent lighting fixtures must be
                                     missing or damaged for it to be categorized as a Level 2
                                     deficiency. This condition was not reported by the QA inspector,


•   Electrical wall outlet is not    UPCS inspection protocol does not address where to record an
    adequately secured to, and is    unsecured outlet cover plate. The definition for
    not flush with the wall          Outlets/Switches/Cover Plates (Common Areas) states that a
                                     deficiency exists when the flush plate that covers the opening
                                     around a switch or outlet is damaged or missing, or a switch or
                                     outlet is missing. This condition was not reported by the QA
                                     inspector. The contract inspector recorded a deficiency for
                                     Outlet Switches/Cover Plates Missing Broken in the Lobby. The
                                     QA Inspector recorded a missing switchplate cover near the front
                                     entry of the building. It is unclear if these are the same defect to
                                     which OIG refers.

    •   The tenant’s arts and
        craft room:

        - Exposed electrical         Although the cover is clearly missing in the photograph provided
        wiring                       by OIG, it appears that the wires are all capped, therefore, no
                                     deficiency appears to exist. The definition of Electric Hazard
                                     notes that if the accompanying authority has identified abandoned
                                     wiring, capped wires do not pose a risk and should not be
                                     recorded as a deficiency. This condition was not reported by the
                                     QA inspector.

        - Missing light fixture      Based on REAC definitions, missing globe covers, while
        globe covers                 unsightly, do not constitute a defect, unless the condition
                                     constitutes an obvious safety hazard. This condition was not
                                     reported by the QA inspector.




                                                    35
                                                                                            Appendix D


    - Missing kitchen vent        Based on REAC Inspection definition of Range Hood/Exhaust
    hood light cover with         Fans - Excessive Grease/Inoperable, a deficiency exits when the
    electrical wiring exposed     apparatus that draws out cooking exhaust does not function as it
                                  should. Criticality levels include Level 1: An accumulation of dirt
                                  threatens the free passage of air; and Level 3: the exhaust fan
                                  does not function or it is estimated that the flue may be
                                  completely blocked. The definition does not specifically identify
                                  rust as a deficiency. Further, there is no specific deficiency for
                                  the light not having a cover. Concerning the exposed wires, no
                                  photograph was provided to document this condition. Based on
                                  a review of a photograph for another of the units, it did not
                                  appear that the wires were bare, but rather ran from the light
                                  back into the fan device. The contract inspector recorded
                                  Common Areas – Kitchen as N/A. A deficiency was not
                                  reported by either the contract inspector or the QA inspector.

    - Kitchen sink cabinet and    The contract inspector recorded Common Areas – Kitchen as
    countertop in disrepair       N/A. The QA inspector confirmed that there exists a kitchen in
                                  the Common Area, but cited no deficiency.

    - Plumbing leak that has      Neither the contract inspector, nor the QA inspector, recorded a
    created a mold and            deficiency for Air Quality – Mold/Mildew at this location. If a
    mildew health hazard          deficiency existed at the time of the original inspection, it may
                                  have been corrected prior to the re-inspection.

•   Tenant’s game/social
    room:

    -window sashes with           The REAC inspector identified no Common Area window
     broken seals, allowing air   defects. The REAC Inspector did identify a Level 3 – Window –
     and moisture to enter the    Missing/Deteriorated Caulking/Seals defects for Building
     thermo pane areas. Glass     Exterior for Building 2 (B); it appears they should have been
     in these sashes was          placed under Common Areas based on REAC protocol
     recently replaced, but       concerning inspectable buildings, however it is unclear if these
     was not adequately           are the same windows the OIG inspector refers to. The REAC
     trimmed and sealed by        inspector stated for location; front of building. The REAC
     the contractor               definition states, that the caulking or seals that resists weather is
                                  missing or deteriorated. The levels of deficiency are either Level
                                  2 when most of the window shows missing or deteriorated caulk,
                                  but there is no evidence of damage to the window or surrounding
                                  structure or Level 3 when there are missing or deteriorated caulk
                                  or seals--with evidence of leaks or damage to the window or
                                  surrounding structure. Based on the description provided by the
                                  OIG inspector there was evidence of leaks.




                                                36
                                                                                                    Appendix D


            - the sink bottom shelf is   The contract inspector recorded Common Areas – Kitchen as
            completely rotted out        N/A.

        •   Common hall vent fans        The contract inspector did not identify this deficiency, however
            are missing or               he reported a Level 3 – HVAC deficiency in the Laundry Room.
            inoperative


Building B, Maintenance Room:

        •   Cover for the wall vent      The actual condition referenced by OIG is unclear and no
            fan is missing               photograph was provided for reference. If the condition creates
                                         a potential health and safety hazard, it should have been reported.
                                         There is nothing in either inspection report that appears
                                         to identify this condition.


Exterior Deficiencies Affecting All      Based on REAC definition, the criticality level is either Level 1 or
Units                                    Level 3. Level 1 addresses potholes or loose material that has
                                         caused the pavement to fail, exposing the subsurface; Level 3
        •    Asphalt drive has           addresses potholes or loose material that has made a parking
            deteriorated; resurfacing    lot/driveway unusable/unpassable for vehicles and/or
            is needed in lieu of         pedestrians. Both the contract inspector and the QA inspector
            sealing                      recorded a Level 1 deficiency for Site - Parking
                                         Lots/Driveways/Roads - Potholes/Loose Material.


        •   Trash dumpsters do not       The definitions do not specifically address trash dumpsters. The
            have covers                  deficiency definition states that the outdoor enclosed area used as
                                         a trash/refuse site is either broken or damaged, including its walls
                                         or is too small to properly store refuse until disposal. The only
                                         criticality level for this deficiency is Level 2, the definition for
                                         which states that a single wall or gate of the enclosure has
                                         collapsed or is leaning and is in danger of falling or trash cannot
                                         be stored in the designated area because it is too small to store
                                         refuse until disposal. The QA inspector did not record a
                                         deficiency for this condition.

Parking signs for the handicapped        The definitions do not specifically address this condition and
are rusted out or missing                neither the contract inspector, nor the QA inspector recorded a
                                         deficiency.




                                                         37
     Appendix D




38
     Appendix D




39
     Appendix D




40
                                                                                         Appendix D


                                         APPENDIX C


                            SARALAND MANOR APARTMENTS
                                GULFPORT, MISSISSIPPI

Photo Examples of Cited Conditions

NOTE: OIG removed duplicate copies of the 30 photographs in Appendix B from this REAC
appendix. OIG also added the “REAC Response” captions below to distinguish between the OIG
photo captions and REAC comments.

No. 1, Building A Roof – Pooling water due to defects in AC condensation lines.
REAC Response: REAC inspector did not identify.

No. 2, Building A – Exterior siding panel is rotted. This condition was noted in several places.
REAC Response: REAC inspector recorded Level 2 – Missing Pieces/Holes/Spalling

No. 3, Building A – Crack and upheaval in walkway is a tripping hazard.
REAC Response: Questionable as tripping hazard, however based on definition note; when
observing traffic ability, consider the capacity to support pedestrians, wheelchairs, and
people using walkers

No. 4, Building B – Trash dumpster with missing and damaged covers.
REAC Response: REAC inspector did not identify, potentially fit as Level 2 – Broken/Damaged
Enclosure – Inadequate Outside Storage Space (Refuse Disposal)

No. 5-6, Buildings A and B, stairwells – Burned out or missing bulbs and missing lens covers.
REAC Response: Does not constitute a deficiency based on REAC definitions as long as there
is no safety concern.

No. 7, Unit 101A – Water heater closet – plumbing holes in ceiling not sealed to provide fire
barrier
REAC Response: REAC inspector did not inspect this unit.

No. 8, Building A- Meter room – exposed wiring.
REAC Response: REAC definition for Electric Hazard notes that if the accompanying
authority has identified abandoned wiring, capped wires do not pose a risk and should not be
recorded as a deficiency.

No. 9, Building A – Meter room – Electrical breaker box, open breaker slot covered with tape.
REAC Response: REAC inspector did not identify, should have been recorded.




                                                41
                                                                                         Appendix D


No. 10, Building B – Roof – Exposed AC electrical wires due to separated cable sheathing.
REAC Response: REAC inspector identified as Electrical Hazard (LT).

No. 11, Unit 101A – Electrical breaker slot covered with tape.
REAC Response: REAC inspector did not identify, should have been recorded.

No. 12, Unit 318B – GFI breaker for bathroom was defective.
REAC Response: REAC inspector did not identify, should have been recorded. He did inspect
this unit.

No. 13, Building A Common room – sink cabinet sides and bottom shelf are rotted out.
REAC Response: REAC inspector did not identify. He reported Common Area – Kitchen as
N/A.

No. 14, Unit 112B – Arts and Crafts room – sink cabinet is delaminating and countertop
underlay is crumbling.
REAC Response: (REAC comment: do not believe highlighted unit # is correct as common
area is indicated.) REAC inspector did not identify. He reported Common Area – Kitchen as
N/A. If it is a unit then the following applies; concerning Countertops; 20% or more of the
countertop-working surface is missing, deteriorated, or damaged below the laminate for a
deficiency; and concerning cabinets, the REAC definition states that; 10-50% of the cabinets,
doors, or shelves are missing or the laminate is separating for Level 2 and over 50% for
Level 3.

No. 15, Unit 112B – Arts and Crafts room – exposed electrical wiring.
REAC Response: REAC definition for Electric Hazard notes that if the accompanying
authority has identified abandoned wiring, capped wires do not pose a risk and should not
be recorded as a deficiency. Appear wires capped.

No. 16, Unit 309A – Stove vent hood is rusted, bulb cover is missing, and wiring exposed.
This condition was similar in most apartment units.
REAC Response: See comments on Page 2 and 3 dealing with vent covers. (Refers to
Page 36 of OIG report.)

No. 17, Unit 214A – Kitchen sink cabinet is delaminating. Countertop underlay is crumbling.
Similar conditions were noted in nearly all units inspected.
REAC Response: REAC inspector did not inspect unit. However, concerning Countertops;
20% or more of the countertop-working surface is missing, deteriorated, or damaged below
the laminate for a deficiency; and concerning cabinets, the REAC definition states that;
10-50% of the cabinets, doors, or shelves are missing or the laminate is separating for Level 2
and over 50% for Level 3.




                                                42
                                                                                       Appendix D


No. 18, Unit 314A – Kitchen sink cabinet, sidewall and bottom shelf are rotted out
and mildewed.
REAC Response: REAC inspector did inspect this unit and did not record deficiency. Did not
record Air Quality – Mold/Mildew anywhere during inspection.

No. 19, Unit 318B – Wall under kitchen sink is in disrepair. Mold is accumulating. Plumbing
holes are not sealed.
REAC Response: REAC inspector did inspect this unit and did not record deficiency. Did not
record Air Quality – Mold/Mildew anywhere during inspection.

No. 20, Unit 203B – Kitchen sink cabinet has delaminated. Underlay material for doors and
countertop are crumbling.
REAC Response: REAC inspector did not inspect. However, he recorded NO Unit –
Kitchen – Cabinet defects in any of the 21 units he inspected.

No. 21, Unit 103B – Kitchen cabinets were replaced, but staining was incomplete and shelving
was omitted.
REAC Response: REAC inspector did not inspect. However, he recorded NO Unit –
Kitchen –Cabinet defects in any of the 21 units he inspected.

No. 22, Unit 203B – Bathroom vanity is delaminating. Side finish and inside shelf surface are
deteriorated and not impervious to moisture.
REAC Response: Inspector did not inspect this unit, however he did record 2 – Level 1
deficiencies for bathroom cabinets in other units.

No. 23, Unit 101B – Bathroom floor has damaged and missing tiles. Wall repairs were not
painted. Vinyl baseboard is missing.
REAC Response: Inspector did not inspect unit. Recorded 1 – Level 1 OD for Unit – Floors
deficiency.

No. 24, Building B, east stairwell – missing and damaged floor tiles.
REAC Response: Inspector did not identify Floor Damage in Common Area –
Halls/Corridors/Stairs in this bldg. However, he would have had to believed that 5-10% of all
floor coverings in the Halls/Corridors/Stairs areas were damaged for it to be a deficiency.

No. 25, Unit 308A – Dining area floor tiles are completely worn through.
REAC Response: Inspector did not inspect unit. Recorded 1 – Level 1 OD for Unit - Floors
deficiency. However, the same proportionality of 5-10% of all floors applies for it to be
considered a deficiency, unless it could constitute an H&S issue.




                                               43
                                                                                       Appendix D


No. 26, Unit301A – Peeling paint in utility closet. Tenant stated the apartment had not been
painted in 16 years.
REAC Response: REAC inspector did not inspect this unit, however did report one Level 2 –
Unit – Walls – Peeling/Needs Paint deficiency in another unit.

No. 27, Unit 301A – The living room ceiling to wall joint has separated.
REAC Response: REAC inspector did not inspect unit.

No. 28, Unit 303A – Water damage to living room ceiling has not been repaired. Trim molding
was not painted.
REAC Response: REAC inspector did not inspect unit. Inspector did report one Level 1 –
Unit – Ceiling – Peeling/Needs Paint and one Level 2 – Ceiling – Water Stains/Water
Damage in other units.

No. 29, Unit 214A – Living room window shows deterioration and mildew due to moisture
damage. The glass panes were not adequately sealed.
REAC Response: Did not inspect, however did not record any window deficiencies in any of
the units inspected.

No. 30, Unit 203B – Moisture damaged drywall at window frame. The age and condition of
Window units makes them too difficult to operate, and subject to moisture intrusion.
REAC Response: Did not inspect unit.




                                               44