02 41 00-B Asbestos Re-Inspection Report.pdf

ASBESTOS RE-INSPECTION REPORT FOR BUILDING No. 65

AT

DEFENSE LOGISTICS AGENCY

DEFENSE SUPPLY CENTER RICHMOND

RICHMOND, VIRGINIA

June 21, 2018

Revision 1

Prepared by

U.S. ARMY CORPS OF ENGINEERS, BALTIMORE DISTRICT

Environmental and Munitions Design Center Environmental and Explosive Safety Section

2 Hopkins Plaza Baltimore, Maryland 21201

Asbestos Re-inspection Report Building No. 65 June 21, 2018

This report describes specific activities and findings related to the asbestos re-inspection for the interior and exterior of Building 65. This report was reviewed and approved by the following individuals:

Stephen B. Epps

Project Lead Industrial Hygienist Asbestos Inspector/ Management Planner VA Asbestos Inspector No. 3303004379 Management Planner No. 3304001667 Environmental and Munitions Design Center Environmental Safety Office United States Army Corps of Engineers-Baltimore District

Genet A. Tulu

Industrial Hygienist Asbestos Inspector VA Asbestos Inspector No. 3303004380 Environmental and Munitions Design Center Environmental Safety Office United States Army Corps of Engineers-Baltimore District

TABLE OF CONTENTS

EXECUTIVE SUMMARY

1.0 INTRODUCTION

1.1 Scope of Work

1.2 Purpose

2.0 PROCESS

2.1 Sample Collection Procedures

2.2 Analytical Standards and Result Evaluation

Table 1. ACM Hazard Ranking

3.0 BUILDING DESCRIPTION

5.0 RECOMMENDATION

Table 2. Summary of Asbestos Containing Homogenous Areas (2006-2018) Table 3. Hazard Assessment of ACM

Table 4. Non Asbestos Homogenous Areas (2006-2013)

Figure 1. Location of ACM or PACM

APPENDIX A. PHOTGRAPHS OF ACM

APPENDIX B. INSPECTOR LICENSES

EXECUTIVE SUMMARY

The United States Army Corps of Engineers (USACE), Baltimore District personnel have been tasked with conducting an installation wide, comprehensive Asbestos re-inspection for non-school and non-childcare facilities located at the Defense Supply Center Richmond (DSCR).

This installation is located at 8000 Jefferson Davis Highway in Richmond, Virginia and supports the Defense Logistics Agency (DLA).

This re-inspection is a requirement under the approved installation Asbestos Management Plan that covers all federal buildings on the installation (Zia, 2013) and will provide the necessary surveillance information to identify and assess the condition of known Asbestos Containing Building Materials (ACBM), also referred in this report as Asbestos Containing Materials (ACM) and identify ACM that is new or missed on previous surveys. This report will serve the DSCR, DF-Free Environmental Management Division in ensuring that their operation and maintenance (O&M) program minimizes or eliminates the exposure to asbestos fibers during routine operations in or around ACBM. Additionally, this report will provide the preliminary information necessary in the planning process during projects that may involve renovation or demolition of ACBM in compliance with provisions of the Clean Air Act.

Mr. Stephen Epps (VA Asbestos Inspector No. 3303004379) and Ms. Genet Tulu (VA Asbestos Inspector No. 3303004380) conducted the re-inspection of Building No. 65 on May 3, 2018. The survey was conducted in accordance with State and Federal regulations. During the survey building materials known to be ACBM were verified and additional homogenous areas suspected to be Asbestos Containing Materials (ACM) were visually identified, their quantity measured, and sampled for analysis, where necessary in accordance with EPA regulation 40 CFR 763 and the Asbestos Hazard Emergency Response Act.

During this survey ACM material, preformed pipe insulation, which was identified during the previous survey in 2013 and 2006 was visually inspected and quantity verified. Additional homogenous areas and ACM were not identified during this survey.

1.0 INTRODUCTION

1.1 Scope of Work

An asbestos re-inspection survey was completed for Building No. 65 located at the Defense Supply Center Richmond in Richmond, Virginia. The re-inspection was conducted by personnel from the U.S. Army Corps of Engineers (USACE), Baltimore District, Environmental and Explosives Safety Section (EESS) at the request of USACE Norfolk District on behalf of Defense Logistics Agency Installation Support at Richmond. This re-inspection was conducted on May 3, 2018 by Virginia licensed asbestos inspectors and in accordance with all applicable state and federal regulations.

1.2 Purpose

This survey identifies and evaluates ACM, PACM, or suspect materials that were not previously identified, if any. The re-inspection incorporates findings from a previous survey that was conducted on June 18, 2013 by Zia Engineering & Environmental Consultants, LLC (Zia). The goal of this re-inspection is to assess the condition of previously identified ACM, PACM, and to conduct visual and physical assessments on any previously un-sampled suspect homogenous areas. If ACM or PACM is found, the report identifies the areas and materials that contain ACM or PACM, the quantity of the material, current condition, hazard assessment, and updated diagrams that show the materials location.

2.0 PROCESS

The asbestos re-inspection was performed in accordance with 40 CFR Part 763, Asbestos Hazard Emergency Response Act (AHERA) and EPA 40 CFR Part 61 National Emissions Standard for Hazardous Air Pollutants (NESHAP). The re-inspection included visual identification of existing and accessible suspect homogenous building materials. In addition, an assessment of condition, friability, and estimate of material quantity was made. Field information was organized as per the AHERA concept of homogenous area. A homogenous area is defined as a suspect material of similar age, appearance, function and texture. Homogenous areas were grouped building-wide to determine if additional or new samples need to be collected.

A thorough attempt was made to access all areas for visual and physical verification of suspect ACM. However, due to the partial destructive nature of collecting building samples for asbestos analysis and some areas may be inaccessible or conditions may present a challenge to safe entry or access to the materials, EESS personnel do not guarantee that all ACM or PACM in the building were located and identified. Additionally, this report details suspect ACM or PACM as identified at the time of inspection only. Quantities of suspect ACM listed in this report are rough field measurements only and if removal is necessary they must be verified by contractors prior to commencement of work.

Initially the 2013 Asbestos report from the inspection from Zia was reviewed by EESS inspectors. If the materials found to be ACM or PACM were re-located and quantity verified, their condition will be assessed and reported. It is possible that some ACM or PACM materials identified on previous survey were not located or were ruled out through further sampling and analysis during this survey.

2.1 Sample Collection Procedures

If additional suspect homogenous areas that were not sampled or considered during the previous survey were located during this re-inspection, their size will be quantified and the material may be sampled for verification. Bulk confirmatory samples of suspect ACM will then be collected in the following manner;

1) Materials will be divided into homogenous areas.

2) Representative samples of each of the following homogeneous area categories may be collected or material may be assumed to contain asbestos.

• Thermal System Insulation (TSI) is insulation material applied to boilers, pipes, fittings, tanks, ducts, or on other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes. For suspect TSI a minimum of three bulk samples are required to be collected for verification.

• Surfacing material means material that is sprayed-on, troweled-on, or otherwise applied to surfaces, such as acoustical plaster on ceiling and fireproofing materials on structural members or other materials on surfaces for acoustical, fireproofing, or other purposes. For suspect surfacing material a minimum of three bulk samples are required to be collected for homogenous area less than 1,000 square feet, a minimum of 5 bulk samples are required for a homogenous area greater than 1,000 square feet and less than 5,000 square feet, and a minimum of 7 bulk samples are required for a homogenous area greater than 5,000 square feet.

• Miscellaneous material means interior building material on structural components, structural members or fixtures, such as floor and ceiling tiles, and does not include surfacing material or thermal system insulation. For suspect miscellaneous material a minimum of two bulk samples are required to be collected for verification.

3) After collection, each sample will be packaged in a sealed plastic bag, labeled, and a sample Chain of Custody will be prepared. Additionally a field sampling log with the sample number, sampled material type, location where the sample was collected, and quantity of the material will be maintained.

2.2 Analytical Standards and Result Evaluation

Bulk samples of suspect ACM collected will be analyzed by the accepted method of polarized light microscopy (PLM) using the Environmental Protection Agency’s method, EPA-600 visual estimate. Some samples may be prepared using gravity tracked matrix reduction method (ELAP 198.6) since the binding material may be obstructing the view of asbestos fibers. Additionally, for non-friable or organically bound bulk samples, when trace amount asbestos is identified during the PLM analysis the inspector may choose to submit these samples for Transmission Electron Microscopy (TEM) with the NY ELAP198.4 method for a definitive assessment. The bulk samples were analyzed by Aerosol Monitoring and Analytical Services, Inc. (AMA Inc.).

This laboratory is accredited by the National Voluntary Laboratory Accredited Program (NVLAP Accreditation No. 101143-0) an accreditation sponsored by the National Institute of Standards and Technology (NIST)).

Samples analyzed having no identified asbestos are reported as “NAD” (No Asbestos Detected).

Those containing less than 1% asbestos are reported as “TR” (Trace). Those containing asbestos were reported with the type and percentage of asbestos. In compliance with the AHERA regulations, material is considered an ACM when it contains greater than one percent asbestos.

The one percent cut off is consistent with EPA's definition under the asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP). However, the Occupational Safety and Health Act (OSHA) has a standard with a definition for both "asbestos" and "asbestos-containing materials." This definition of asbestos does not have a one percent cut off, therefore, asbestos that is present in percentages less than one percent continues to be covered by the OSHA standard. Work operations conducted in areas where the asbestos or asbestos product is below one percent is considered an "unclassified" operation and would need to adhere to some of the requirements under OSHA, therefore results that have trace asbestos will be considered ACM for worker protection purposes.

Materials found to contain asbestos will then be assessed utilizing the following hazard ranking table (Table 1).

Table 1. ACM Hazard Ranking Assessment Category ACM Condition ACM Disturbance Potential

7 Significantly Damaged* Any 6 Damaged Significant Damage 5 Damaged Damage 4 Damaged Low 3 Good Significant Damage 2 Good Damage 1 Good Low

* The difference between damage and significantly damaged is that significantly damaged means damage evenly distributed across 10% or more of the functional space or localized over 25% of the functional space

3.0 BUILDING DESCRIPTION

Building No. 65 was constructed in approximately 1953 and has since been renovated. This building is approximately 701,430 square feet in size. It is mainly of concrete block construction on a concrete foundation with flat roof. Interior finished include ceramic and vinyl floor tile, concrete floors, fiberglass batting insulation, suspended in-lay ceiling tile, and sheetrock and concrete block walls.

4.0 SUMMARY OF FINDINGS

Mr. Stephen Epps (VA Asbestos Inspector No. 3303004379) and Ms. Genet Tulu (VA Asbestos Inspector No. 3303004380) conducted the re-inspection of this building on May 3, 2018. Upon reviewing the 2013 inspection report prepared by Zia and conducting the building walkthrough, one type of material was verified ACM, preformed pipe insulation. During the re-inspection no additional homogenous areas were identified. All ACM from previous survey was verified and the materials condition assessment can be found in Tables 2 and 3. A consolidated list of materials that were ruled out as ACM to date, either through the experience and knowledge of an accredited inspector or sample analysis can be found in Table 4.

5.0 RECOMMENDATION

Pipe Insulation and Pipe Fitting

Asbestos containing pipe insulation and fittings were found in the restroom along E Bay. This material was found in damaged condition throughout this area. A few areas were found in poor condition. During the inspection a few areas were found with frayed ends that were not encapsulated. This material should be repaired or encapsulated to maintain its integrity until such time that removal is scheduled. Refer to the AMP for specific guidance on maintenance, removal, and disposal of asbestos containing materials

Table 2. Summary of Asbestos Containing Homogenous Areas (2006-2018) Homogenous Area Description Assumed Verified

ACM

Quantity % Asbestos

Preformed pipe fitting x 25 LF NA

NA= Not Assessed, LF =Linear Feet, SF= Square Feet, EA= each, “=inches, ‘=feet, %=percent, >=greater than, <= less than

Table 3. Hazard Assessment of ACM

M at er ia l

L oc at io n

Fr ia bi lit y

A ss es sm en t

C at eg or y*

Ju st ifi ca tio n

C ha ng e in

A ss es sm en t

Preformed pipe fitting

Wrapped around exposed pipes in restroom along E Bay, Room E-03

Friable 5 Pipe ends were frayed will need to be encapsulated until such time they are removed

No

Table 4. Non Asbestos Homogenous Areas (2006-2013) Homogenous Areas Non Suspect Not ACM

Expansion joint x Fiberglass pipe insulation x White insulation mastic x Fiberglass roof panels x

Foil duct wrap x Vinyl vibration dampener x

12” x 12” black/blue speckled floor tile/mastic x 6” tan cove base and mastic x

Sheetrock and joint compound x Window caulking x

12” x 12” tan smear floor tiles/mastic x 4” tan cove base and mastic x

4” brown cove base and mastic x White door caulking x

Tile grout x 4” black cove base and mastic x

Window glazing x Plaster x

2’x 4’ fissured/pinhole ceiling tile x Black fiberglass paper backing x

12” x 12” brown/ pink floor tiles/mastic x 12” x 12” mauve smear vinyl floor tiles with yellow mastic (installed

2013) x

4” mauve cove with yellow mastic (installed 2013) x White painted sheetrock and joint compound (installed 2013) x

Foil wrapped fiberglass batting insulation x Fiberglass pipe insulation (installed 2013) x PVC elbows with fiberglass/wool batting x

12” x 12” cream/white smear vinyl floor tiles/ mastic (installed 2013) x 4” tan cove with yellow mastic (installed 2013) x

Figure 1. Location of ACM or PACM

APPENDIX A. PHOTGRAPHS OF ACM

4” preformed pipe insulation, (Restroom E-03 along E Bay)

APPENDIX B. INSPECTOR LICENSES

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