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USDA Appendix A
The Johnson – McAdams Firm, PA 16 October 2018 Greenwood, MS 38930
Regulated Materials Report
Environmental Testing
Demo Building 152 Change House
Regulated Materials Survey
USDA Building #152 2300 Dayton Avenue
Ames, IA September 13, 2018
Terracon Project No. 08187184
Prepared for:
The Johnson – McAdams Firm
Collierville, TN
Prepared by:
Terracon Consultants, Inc.
Des Moines, IA
Terracon Consultants, Inc. 600 SW 7th Street, Suite M, Des Moines, Iowa 50309
P [515] 244 3184 F [515] 244 5249 terracon.com
September 13, 2018
The Johnson – McAdams Firm 340 Poplar View Lane East, Suite 4 Collierville, TN 3817
Attn: Mr. Chip Johnson, P.E.
P: (901) 861-4200 E: chip.johnson@jmcfirm.com
Re: Regulated Materials Survey
USDA Building #152 2300 Dayton Avenue Ames, IA Terracon Project 08187184
Dear Mr. Johnson:
Terracon Consultants, Inc. (Terracon) is pleased to submit the attached report for the above referenced site to The Johnson – McAdams Firm. The purpose of this report is to present the findings of a regulated materials survey conducted on August 20 and 21, 2018. We understand the services were requested due to the planned demolition of the building on site.
Terracon appreciates the opportunity to provide this service to The Johnson – McAdams Firm. If you have questions regarding this report, please contact Adam at 515-244-3184 or Adam.Corcoran@Terracon.com.
Sincerely, Terracon Consultants, Inc.
Adam Corcoran Cindy A. Baldwin, CIH, FAIHA Project Environmental Scientist Senior Industrial Hygienist
Copies to: Addressee (1) The Johnson – McAdams Firm (Electronic Only)
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION
1.1 Project Objectives
1.2 Reliance
2.0 BUILDING DESCRIPTION
3.0 FIELD ACTIVITIES
3.1 Asbestos Survey
3.1.1 Asbestos Visual Assessment
3.1.2 Asbestos Physical Assessment
3.1.3 Asbestos Sample Collection
3.1.4 Asbestos Sample Analysis
3.2 Lead-Based Paint Screening
3.3 Polychlorinated Biphenyls Equipment Inventory and Sampling
3.4 Visual Survey for Other Possible Hazardous Materials
4.0 REGULATORY OVERVIEW
4.1 Asbestos
4.2 Lead
4.3 Mercury
4.4 PCBs
4.5 Ozone-Depleting Chemical (ODC) Containing Items
5.0 FINDINGS AND RECOMMENDATIONS
5.1 Asbestos Survey
5.2 LBP Screening
5.3 Hazardous / Regulated Materials Survey
5.3.1 PCBs
5.3.3 Hg-Containing Items
5.3.4 Ozone-Depleting Chemical (ODC) Containing Items
5.3.5 Miscellaneous Hazardous / Universal Waste Materials
6.0 LIMITATIONS / GENERAL COMMENTS
APPENDICES
APPENDIX A ASBESTOS-CONTAINING MATERIAL LOCATIONS
APPENDIX B TABLE 1 – ASBESTOS SAMPLE SUMMARY
TABLE 2 – LEAD-BASED PAINT SAMPLE SUMMARY
TABLE 3 – MERCURY, PCBS, AND OTHER POTENTIALLY
REGULATED MATERIALS SURVEY SUMMARY
APPENDIX C LABORATORY ANALYTICAL REPORTS
APPENDIX D ASBESTOS INSPECTORS’ LICENSES
APPENDIX E PHOTO LOG
APPENDIX F AMES ENVIRONMENTAL INC. ASBESTOS SURVEY
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REGULATED MATERIALS SURVEY
USDA Building #152 2300 Dayton Avenue
Ames, Iowa September 13, 2018
Terracon Project No. 08187184
1.0 INTRODUCTION
Terracon Consultants, Inc. (Terracon) was retained by the Johnson – McAdam Firm to conduct a regulated materials survey for the United States Department of Agriculture (USDA) Building #152 located at 2300 Dayton Avenue, Ames, Iowa. Terracon understands the building will be demolished. The purpose of this survey was to determine if asbestos-containing materials (ACMs), lead-based paint (LBP), and other regulated materials were present in the building. The scope of Terracon’s services for the survey included discrete destructive sampling for suspect ACMs, LBP, and polychlorinated biphenyls (PCBs) in caulk; a visual assessment for potential PCB and mercury (Hg)-containing materials and equipment and other hazardous/regulated materials; and the completion of this report. The survey was conducted on August 20 and 21, 2018 in accordance with Terracon Proposal P08187184, executed on August 3, 2018. The survey was conducted by the following Terracon representatives: Mr. Kris Sommer and Mr. Jake Haden.
The building was unoccupied at the time of the survey.
1.1 Project Objectives
Terracon understands that the USDA is the owner of the property. Terracon understands the survey was requested due to planned demolition activities that will require management and documentation of various building materials, wastes, and/or chemicals present within the building.
The project objectives are to satisfy the following regulatory requirements:
The United States Environmental Protection Agency (USEPA) regulation 40 Code of Federal Regulations (CFR) 61-National Emission Standards for Hazardous Air Pollutants (NESHAP), Subpart M-Asbestos, prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities. The asbestos NESHAP requires that potentially regulated ACM (RACM) be identified, classified, and quantified prior to planned disturbances or demolition activities.
The Resource Conservation and Recovery Act (RCRA) and the Toxic Substances
Control Act (TSCA) impact some construction and demolition projects with respect to regulated waste (i.e., solvent/thinner, fuel, stains, unused paint, oil/lubricants, compressed gas cylinders, and unpunctured aerosol cans) and universal waste (i.e., fluorescent lights, high intensity discharge (HID) lamps, mercury-containing
Regulated Material Survey USDA Building #152■ Ames, IA September 13, 2018 ■ Terracon Project 08187184
Responsive ■ Resourceful ■ Reliable 2 thermostats, batteries, pesticides). Materials referenced here are referred to as regulated materials in the report.
The Occupational Safety and Health Administration (OSHA) regulates asbestos exposure in construction under 29 CFR 1926.1101-Asbestos. The standard regulates asbestos exposure during renovation/demolition activities and requires building and facility owners to determine the presence, location, and quantity of ACMs and/or presumed ACM (PACM) prior to renovation/demolition activities.
OSHA 29 CFR 1926.62-Lead applies to renovation/demolition operations where an employee may be occupationally exposed to lead. The employer must evaluate employee exposures and communicate information concerning lead hazards and appropriate protective measures to employees.
The objective of the report is to present the results of the survey at the time of the field assessments, subject to the stated reporting limitations.
1.2 Reliance
This report is for the exclusive use of the Johnson - McAdams Firm. Reliance by any other party on this report is prohibited without written authorization of Terracon and the Johnson - McAdams Firm. Reliance on this report by the Johnson – McAdams Firm and authorized parties will be subject to the terms, conditions, and limitations stated in the proposal, this report, and Terracon’s Agreement for Services. The limitations of liability defined in Terracon’s Agreement for Services are the aggregate limit of Terracon’s liability to the Johnson - McAdams Firm.
2.0 BUILDING DESCRIPTION
The USDA Building #152 is a 7,600 ft2 facility constructed in 1959. The building is constructed mainly of brick or masonry with a steel frame. The interior of the building consists of a locker room and break areas.
3.0 FIELD ACTIVITIES
3.1 Asbestos Survey
The survey was conducted by Mr. Kristopher Sommer and Mr. Jacob Haden, State of Iowa licensed asbestos inspectors, on August 20 and 21, 2018. Copies of their inspectors’ licenses are provided in Appendix D. The asbestos survey was conducted in accordance with the sample collection protocols established in USEPA regulation 40 CFR 763-Asbestos. A summary of the asbestos survey activities is provided below.
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3.1.1 Asbestos Visual Assessment
Asbestos survey activities began with visual assessments of the interior and exterior of the building to identify homogeneous areas of suspect ACM. A homogeneous area consists of building materials that appear similar throughout in terms of color and texture, with consideration given to the date of application. The interior assessment was conducted in visually accessible areas of the building. Building materials identified as concrete, glass, wood, metal, or rubber are not considered suspect ACM and therefore, were not sampled.
3.1.2 Asbestos Physical Assessment
A physical assessment of each homogeneous area of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the USEPA as a material that can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect ACM.
3.1.3 Asbestos Sample Collection
Based on results of the visual assessments, bulk samples of suspect ACM were collected in general accordance with USEPA protocols. Random samples of suspect ACM were collected in each homogeneous area. Bulk samples were collected using wet methods as applicable to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.
Terracon collected 137 bulk samples from 49 homogeneous areas (HA) of suspect ACM.
Laboratory analysis separated the bulk samples into 228 distinct layers for analysis. A summary of the samples collected including the distinct layers analyzed by the laboratory is provided in Table 1 in Appendix B.
Exhibits showing the asbestos sample locations are provided in Appendix A.
Please note that suspect ACMs might be present in inaccessible areas that may be discovered during renovation activities. Prior to disturbance, these materials should be sampled to determine if they contain asbestos or they can be assumed asbestos-containing and abated by a licensed asbestos abatement firm.
3.1.4 Asbestos Sample Analysis
Bulk samples were submitted under chain of custody (COC) to International Asbestos Testing Laboratory (IATL) of Mount Laurel, NJ for analysis by polarized light microscopy with dispersion staining techniques per USEPA’s Method for the Determination of Asbestos in Bulk Building Materials (600/R-93/116). The percentage of asbestos, if present, was determined by microscopic
Responsive ■ Resourceful ■ Reliable 4 visual estimation. IATL is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP Accreditation No. 101165-00). Refer to Appendix C for the laboratory analytical report.
3.2 Lead-Based Paint Screening
The LBP screening was conducted by Mr. Kris Sommer on August 20, 2018. The LBP screening activities included a visual assessment of coated surfaces in and on the building to identify areas/materials to be tested by an x-ray fluorescence analyzer (XRF) to analyze for lead content.
The purpose of the LBP screening was to assess for the presence of LBP that might present a potential airborne exposure hazard to workers involved in the renovation activities.
3.3 Polychlorinated Biphenyls Equipment Inventory and Sampling
Terracon inventoried the presence and/or quantity of building materials and equipment that could contain PCBs. Terracon collected samples of suspect PCB-containing caulks and submitted them under COC to TestAmerica Laboratories, Inc. (TestAmerica), Cedar Falls, IA for PCB analysis using extraction techniques in accordance with USEPA Method 8082 Polychlorinated Biphenyls by Gas Chromatography.
Terracon also conducted a representative visual assessment of interior light fixtures to characterize PCB content. Typically, ballasts manufactured prior to 1979 are presumed to contain PCBs unless clearly marked as containing “No PCBs.” Ballasts that do not contain a “No PCBs” label are presumed to be PCB-containing.
3.4 Visual Survey for Other Possible Hazardous Materials
A visual survey for other possible hazardous and/or regulated materials was conducted by Mr.
Sommer and Mr. Haden. The results of the visual survey for other possible hazardous and/or regulated materials is provided in Appendix B.
4.0 REGULATORY OVERVIEW
4.1 Asbestos
In Iowa, asbestos activities are regulated by the Iowa Department of Natural Resources (IDNR) and the Division of Labor, Iowa Workforce Development (IWD). IDNR regulates asbestos fiber emissions under Iowa Administrative Code 567 Chapter 23 (IAC 567 23) and asbestos-containing waste disposal under IAC 567 109. IWD regulates occupational exposure to asbestos under IAC 875 10 and asbestos removal and encapsulation activities under IAC 875 155.
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IAC 567 23.1(3) adopts USEPA’s asbestos NESHAP regulation (40 CFR Part 61, Subpart M) by reference. Subpart M regulates asbestos fiber emissions and asbestos waste disposal practices. It also requires the identification and classification of existing building materials prior to demolition or renovation activities. Under NESHAP, ACMs are classified as friable, Category I nonfriable, or Category II nonfriable. Friable materials are those that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. Category I nonfriable ACM includes packing, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1% asbestos. Category II nonfriable ACMs are any materials other than Category I materials that contain more than 1% asbestos.
Regulated ACM (RACM) must be removed before renovation or demolition activities that will disturb the materials. RACM includes:
Friable ACM;
Category I nonfriable ACM that has become friable or will be subjected to drilling, sanding, grinding, cutting, or abrading; and Category II nonfriable ACM that could be crumbled, pulverized, or reduced to powder during renovation or demolition activities.
The owner or operator must provide the IDNR and IWD with written notification of planned removal activities at least 10 working days prior to the commencement of asbestos abatement activities.
Removal of RACM must be conducted by an Iowa-permitted asbestos abatement contractor.
IAC 875 155 Asbestos Removal and Encapsulation requires that any asbestos-related activity conducted in a public building must be performed by personnel licensed by the IWD. Inspections for ACM must be conducted by IWD-licensed inspectors. Asbestos abatement must be conducted by IWD-licensed asbestos abatement contractors. Management plans developed for the in-place management of ACMs must be developed by an IWD-licensed management planner. If an abatement project design is prepared, it must be prepared by an IWD-licensed project designer.
IAC 875 10 adopts the OSHA Asbestos standard for construction (29 CFR 1926.1101) by reference. The OSHA standard establishes permissible exposure limits (PELs) of 0.1 asbestos fiber per cubic centimeter of air (0.1 f/cc) as an 8-hour time-weighted average (TWA) and 1.0 f/cc as a 30-minute excursion limit (EL). The OSHA standard classifies construction and maintenance activities that could disturb ACM and specifies work practices and precautions that employers must follow when engaging in each class of regulated work.
4.2 Lead
Lead is found in paints and coatings, batteries, solders, pipes, mortar, metals, x-ray shielding, acoustic materials, and flashing around windows and roof vents.
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Lead is regulated by the USEPA and OSHA. USEPA regulates lead use, removal, and disposal, and OSHA regulates worker exposure to lead. USEPA defines LBP as paint, varnish, stain, or other applied coatings that contain lead equal to or greater than 1.0 milligram per square centimeter (mg/cm2), 5,000 milligrams per kilogram (mg/kg) or 0.5% by dry weight as determined by laboratory analysis. For the purpose of the OSHA lead standard, lead includes metallic lead, all inorganic lead compounds, and organic lead soaps. The federal OSHA standard does not define the amount of lead in paint that constitutes lead-based paint.
USEPA regulates disposal of hazardous materials. USEPA has stated that components removed with intact LBP that is not delaminating from the substrate may be disposed as general demolition debris. If the LBP is stripped from components, or if it is delaminating from the substrate, the waste may be subject to hazardous waste rules [i.e., Toxicity Characteristic Leaching Procedure (TCLP)].
Other materials containing lead (e.g., batteries, flashings, etc.) must be properly disposed.
The OSHA Lead Standard for Construction (29 CFR 1926.62) applies to all construction work where an employee may be occupationally exposed to lead. Work related to construction, alteration, or repair (including painting and decorating) is included. The lead-in-construction standard applies to any detectable concentration of lead in paint, as even small concentrations of lead can result in unacceptable employee exposures depending on the method of removal and other workplace conditions. As per this standard, construction includes, but is not limited to, the following:
Demolition or salvage of structures where lead or materials containing lead are present.
Removal or encapsulation of materials containing lead.
New construction, alteration, repair, or renovation of structures, substrates, or portions containing lead, or materials containing lead.
Installation of products containing lead.
Lead contamination/emergency clean up.
Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are conducted.
Maintenance operations associated with construction activities described above.
Employees may not be exposed to lead at concentrations greater than the PEL of 50 micrograms per cubic meter ( g/m3) averaged over an 8-hour period without adequate protection. The OSHA standard also establishes an action level of 30 g/m3, which if exceeded, triggers certain requirements, including periodic exposure monitoring and medical monitoring.
4.3 Mercury
Metallic Hg is a silver-white liquid at room temperature. Elemental and inorganic Hg compounds are used in the manufacture of scientific instruments, electric equipment, and mercury vapor and
Responsive ■ Resourceful ■ Reliable 7 fluorescent electric lamps. Hg-containing equipment, such as fluorescent light tubes, must be sent to an approved recycling facility that recovers mercury. USEPA considers Hg a hazardous waste.
USEPA regulates the disposal of Hg-containing fluorescent lights tubes as universal waste under 40 CFR 273. Disposal of Hg from other sources is regulated under 40 CFR 260-262. Hg-containing lamps are managed under both federal and state regulations. Under federal regulations, the majority of Hg-containing lamps are considered a hazardous waste. If Hg-containing lamps are not tested to prove they are non-hazardous, they must be considered hazardous waste and handled accordingly.
The amount of mercury in a low-Hg bulb can range from 3.5 to 4 milligrams compared to a standard fluorescent bulb, which ranges from 8 to 14 milligrams of Hg. Low-Hg lamps may be identified by green end caps (often referred to as green-tipped lamps) or green etchings on the lamps.
Under federal regulations, a lamp is considered a hazardous waste if it exhibits the characteristic of hazardous waste toxicity. Waste generators must determine whether a lamp exhibits this characteristic by conducting a Toxicity Characteristic Leaching Procedure (TCLP) test. This test measures the leachability of certain metals, including mercury and organic constituents. Under this procedure, the waste leachate must contain less than 0.2 milligrams per liter (mg/L) of Hg in order to pass the test.
Lamps that pass the TCLP are not hazardous and therefore, are not subject to federal regulations.
If the mercury concentration exceeds 0.2 mg/L, the lamp fails the toxicity test and must be managed as hazardous waste.
OSHA regulates occupational exposure to mercury under 29 CFR 1910.1000 Air Contaminants, Table Z 1 – Limits for Air Contaminants. The PEL for mercury is 0.1 milligram per cubic meter (mg/m3) as an 8-hour TWA.
4.4 PCBs
PCBs are clear, oily liquids to white or yellowish waxy solids, depending on the degree of chlorination. They are stable, thermoplastic, and nonflammable materials that were used in hundreds of industrial and commercial applications including electrical, heat transfer, and hydraulic equipment; as plasticizers in paints, caulks, sealants and coatings, plastics, and rubber products; in pigments, dyes, and carbonless copy paper and many other applications. USEPA regulates transportation, disposal, and spill cleanup of PCB-containing ballasts under TSCA, which can be found in 40 CFR 761. Typically, fluorescent light ballasts manufactured prior to 1979 are assumed to contain PCBs unless clearly marked as containing “NO PCB.”
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OSHA regulates occupational exposure to some PCBs under 29 CFR 1910.1000 Air Contaminants, Table Z 1 – Limits for Air Contaminants. The PEL for chlorodiphenyl (42% chlorine) is 1.0 mg/m3 and for chlorodiphenyl (54% chlorine) is 0.5 mg/m3, both as 8-hour TWAs.
4.5 Ozone-Depleting Chemical (ODC) Containing Items
USEPA regulates the use, release, and disposal of chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) under Section 608 of the Clean Air Act. Section 608 prohibits individuals from intentionally venting ozone-depleting refrigerants (including CFCs and HCFCs) and their substitutes (such as HFCs), while maintaining, servicing, repairing, or disposing of air conditioning or refrigeration equipment.
5.0 FINDINGS AND RECOMMENDATIONS
5.1 Asbestos Survey
The Johnson – McAdams Firm provided a previous asbestos survey report for USDA Building #152 that was completed by Ames Environmental Inc. (Ames) in 2011 for Terracon’s review. The Ames report identified several ACMs including multiple colors of 9”x9” floor tile and mastic and pipe fitting insulation. Terracon did not resample these materials. They are included in Table 1 (in italics). The Ames report has been included in Appendix F.
Laboratory analysis of the bulk samples confirmed the presence of asbestos in samples collected from the building. Table 1 summarizes the identified ACMs. A drawing showing the locations of identified ACMs are included in Appendix A. A photolog with the ACMs has been included as Appendix E.
Table 1. Asbestos-Containing Materials
HA1 Material Description Material Location NESHAP Classification
Estimated Quantity2
003 Mastic associated with gray 9’’x9’’ vinyl floor tile
Electrical equipment 13 Category I 100 square feet (SF)
Brown mastic associated with black covebase
Electrical equipment 13 Category II 450 linear feet (LF)
007 White joint compound West hallway 20A Category II 1,200 SF
1 HA = homogeneous area 2 Estimated quantities are based on a cursory field evaluation, and actual quantities may vary significantly, especially if asbestos containing materials are present in hidden and/or inaccessible areas not evaluated as part of this survey.
3 Tan mastic found only in one sample 011 of HA 004. This may represent a patched/repaired area.
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HA1 Material Description Material Location NESHAP Classification
Estimated Quantity2
008 Gray texture Locker room 23 Category II 4,200 SF 013 Gray window glazing West window south Category II 250 LF 014 Gray interior sealant Interior window vestibule 19 Category II 10 LF
015 Gray interior caulking Interior window vestibule 9 Category II 20 LF
017 Gray exterior window/wall caulking
North interior window vestibule Category II 250 LF
020 Gray/white caulking Exterior windows office 10 Category II 20 LF
022 Gray with brown sealant South exit door Category II 50 LF
Gray, white, and yellow joint wrap Mech. equip. 5 Category II 20 joints
026 Silver, white paper, with brown mastic Locker rooms Category II 20 joints
042 Black roofing tar Ventilation hoods Category I 6 SF
047 White hard joints with black sealant Storage 23A Category II 50 joints
048 White hard joints Storage 23A Category II 54 joints 11L092901A 9”x9” floor tile red
Break room Category I 800 SF 11L092902A Mastic
11L09203A 9”x9” floor tile tan Break room Category I 800 SF
11L092904A Mastic
11L092904A 9”x9” floor tile black Break room Category I 800 SF
11L092904A Mastic
11L092918A
Pipe fitting insulation Mechanical room Category II/
RACM
20 joints 11L092918B
11L092918C
To see the sample results for each layer of each sample of each homogeneous area, please refer to Table 1 in Appendix B or the laboratory analytical report in Appendix C.
Materials identified to contain asbestos greater than 1% must be removed by appropriately trained and State of Iowa licensed personnel.
Category I nonfriable ACMs must be removed prior to renovation activities if they are damaged or have a high probability of becoming crumbled, pulverized, or reduced to powder during the aforementioned activities in accordance with applicable federal and state regulations. IDNR believes that most renovation activities will subject such Category I nonfriable ACMs to the
Responsive ■ Resourceful ■ Reliable 10 regulation. Friable ACM must be removed by an Iowa permitted asbestos abatement contractor prior to renovation activities and disposed in an approved landfill.
If Category I and II nonfriable ACMs cannot be removed without making them friable, they are considered RACM. RACMs must be removed by an Iowa permitted asbestos abatement contractor prior to demolition of the structure and disposed in an approved landfill. An Iowa permitted asbestos abatement contractor should be contacted to remove identified ACM.
USEPA does not regulate materials containing 1% or less asbestos; however, the OSHA personal exposure limits (0.1 f/cc of air as an 8-hour time-weighted average or 1.0 f/cc of air over 30 minutes) for asbestos apply when materials containing 1% asbestos or less are disturbed during renovations or demolitions. Table 2 provides listing of materials that contain 1% asbestos or less to enable the renovation contractor to make appropriate decisions concerning compliance issues with applicable OSHA regulations.
Table 2. Materials Containing 1% or Less Asbestos
HA Terracon Material Description Material Location
39 Black non fibrous in fuse box Mechanical room
It should be reemphasized that although reasonable efforts were made to survey accessible suspect materials, additional suspect but unsampled materials could be located under existing building materials, in isolated areas, or in other concealed areas of the building. Therefore, if suspicious materials are encountered during renovation activities that do not appear to have been characterized as ACM or non-ACM, samples should be collected and analyzed prior to disturbing these materials or the materials can be assumed to contain asbestos and abated.
Terracon recommends that a State of Iowa licensed asbestos Project Designer be retained to prepare a project specific specification for the abatement of ACM identified in this survey report, in accordance with applicable regulatory requirements. Terracon recommends abatement oversight by a qualified consultant in order to confirm that ACMs are properly removed and disposed.
Under OSHA and USEPA regulations, employees or contractors working in proximity to ACMs in the building must be made aware of the presence and location of ACMs prior to commencing renovation activities.
5.2 LBP Screening
Terracon identified coated surfaces on substrates that may be affected by the renovation. The painting history of a given location in older buildings often will vary from place to place due to
Responsive ■ Resourceful ■ Reliable 11 factors including variability in paints used, paint film thickness, variable retention of older paint layers before repainting, demolition/installation of walls during renovations, and unknown historic non-homogenous painting schemes. As such, a given color and building component combination that is apparent often will not provide consistent testing results for lead.
Terracon attempts to conduct lead paint testing in a sufficient number of areas to establish trends in lead content based on distinguishable characteristic such as color or building component, subject to time and budget constraints.
Terracon utilized a LPA-1 XRF analyzer to conduct direct reading measurements of lead content in interior and exterior surface coatings. An XRF is a portable electronic device containing a small, sealed nuclear source. The device emits x-rays at various energy levels. The x-ray energy excites electrons in the outer orbits of lead atoms. The detector in the XRF unit reads this excitation and translates it into a semi-quantitative reading of lead present by surface area. XRF technology allows detection of lead in a painted surface, even several layers below the surface, without disturbing the painted surface. XRF is an industry standard for determining lead in painted surfaces. Terracon calibrated the LPA-1 (serial number 00856) using the manufacturer’s provided calibration block to approximately 1.0 milligram per square centimeter (mg/cm2) prior to conducting the screening activities.
Using the XRF, Terracon measured 26 surface coatings. Of the 26 surface coatings analyzed, zero tested at a level the would be considered lead based paint. The LBP screening summary is included in Table 2 in Appendix B.
Individuals conducting work that will disturb the materials should be notified of the presence of lead-containing paint so that necessary precautions can be taken to protect personnel from potential exposures as per the OSHA lead standard.
5.3 Hazardous / Regulated Materials Survey
5.3.1 PCBs
Terracon identified 78 light ballasts in fluorescent, neon, or high-intensity discharge (HID) light fixtures within the building. Terracon attempted to check approximately 10% of the ballasts for information regarding PCB content. Light ballasts potentially contain PCB-containing oils. Most of the ballasts checked stated “No PCBs” on their label; however, several ballasts were observed with no mention of PCB content. These ballasts were a General Electric Trigger Start Ballast (CAT. 6G3512) and a Universal Therm-O-Matic (Cat. No. 446-L-TC-P).
Two transformers were identified in the building, one outside the building and one inside. The outside transformer was observed to have a placard that stated, “Filled with Non-PCB Fluid That Contained Less Than 1 PPM PCB At Time of Manufacturing.” The transformer located inside the
Responsive ■ Resourceful ■ Reliable 12 building was observed to be a dry transformer. No other potential PCB-containing equipment (i.e., capacitors, hydraulic lifts, etc.) was identified during the survey on the interior of the building.
During the survey, five samples of caulk were collected for analysis. The concentrations reported for the five samples were below laboratory reporting limits. A copy of the laboratory analytical report has been included in Appendix C.
Prior to the start of renovation activities, light fixtures with ballasts that will require removal will need to be examined. Ballasts not clearly marked “No PCBs” must be placed in a properly labeled metal drum for management as PCB-containing waste and disposed of in accordance with state and federal regulations. The contractor taking possession of known or suspected PCB-containing items for disposal must have a valid USEPA identification number for regulated waste activity.
5.3.3 Hg-Containing Items
Terracon identified fluorescent light lamps of various sizes, compact fluorescent lamps (CFLs), and HID lamps. Mercury-containing thermostats were also identified.
Refer to Appendix B for a summary of the above listed items.
Prior to the start of renovation activities, Hg-containing light bulbs must be removed undamaged and stored in an undamaged condition until they are reused or recycled in accordance with state and federal regulations. Devices that contain mercury (i.e., thermostats and switches) must be reused or removed and disposed of in accordance with state and federal regulations.
5.3.4 Ozone-Depleting Chemical (ODC) Containing Items
Terracon identified items during the survey that may contain ozone-depleting chemicals including a refrigerator and water fountains.
Refer to Appendix B for a summary of items containing ODCs.
Items that contain ODCs must be removed and disposed in accordance with federal, state, and local regulations prior to demolition.
5.3.5 Miscellaneous Hazardous / Universal Waste Materials
During the survey, Terracon identified cleaning chemicals and emergency exit signs (may contain batteries) in the building. These materials are not accepted at demolition debris landfills and require special disposal or recycling.
Refer to Appendix B for a summary of these miscellaneous materials.
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Terracon inventoried items and materials that may present an environmental issue during the planned renovation. These items and materials must be removed undamaged and stored in an undamaged condition until they are reused/recycled or disposed in accordance with state and federal regulations.
6.0 LIMITATIONS / GENERAL COMMENTS
The survey was conducted using limited destructive sampling techniques. Although efforts were made to determine if multiple layers of materials were present (e.g., flooring), sample collection was limited to the extent of allowable access points via the use of hand tools so as not to affect security, fire, and life safety; create slip, trip and/or fall hazards; or prevent unacceptable aesthetic or functional damage to building surfaces and materials, as per the judgment of the inspector at the time of the survey. Therefore, suspect ACM might be present in concealed spaces, cavities, and plenums of the building. Additional inspection by a licensed asbestos inspector is required by the IDNR prior to renovation activities that would impact such materials not identified in the survey or the materials can be assumed to contain asbestos and abated by an Iowa permitted asbestos abatement firm.
This survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions, and recommendations expressed in this report are based on conditions observed during our survey of the building. The information contained in this report is relevant to the dates the survey was conducted and should not be relied upon to represent conditions at a later date. This report has been prepared on behalf of and exclusively for use by the Johnson – McAdams Firm for specific application to their project as discussed.
This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories, or other third parties supplying information that may have been used in the preparation of this report. No warranty, express or implied is made.
APPENDIX A
ASBESTOS-CONTAINING MATERIAL LOCATIONS
M ul ti-co lo re d 9'
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APPENDIX B
TABLE 1. ASBESTOS SAMPLE SUMMARY
TABLE 2. LEAD-BASED PAINT SAMPLE SUMMARY
TABLE 3. MERCURY, PCBS, AND OTHER POTENTIALLY
REGULATED MATERIALS SURVEY SUMMARY
Responsive ■ Resourceful ■ Reliable B-1
Regulated Materials Survey USDA Building #152 2300 Dayton Avenue
Ames, IA
Table 1 – Asbestos Sampling Location Summary by Homogeneous Area (HA)
Asbestos containing materials are in indicated bold and materials containing less than 1% asbestos are italicized. Table 1 includes layers separated by the laboratory during their analysis.
Sample # Sample Location Material Description Lab Results
001-FC5-001
(Layer 1)
Shower room 2
Red ceramic None detected
001-FC5-001
(Layer 2) Off-white grout None detected
001-FC5-001
(Layer 3) Gray mortar None detected
001-FC5-002
(Layer 1)
Bathroom west of toilet room 21 Red ceramic None detected
001-FC5-002
(Layer 2) Off-white grout None detected
001-FC5-003
(Layer 1)
Shower room 22A Red ceramic None detected
001-FC5-003
(Layer 2) Off-white grout None detected
002-FT2-004
(Layer 1)
Toilet room 21 Gray floor tile None detected
002-FT2-004
(Layer 2) Tan mastic None detected
002-FT2-005
(Layer 1)
Toilet room 21 Gray floor tile None detected
002-FT2-005
(Layer 2) Tan mastic None detected
002-FT2-006
(Layer 1)
Toilet room 21 Gray floor tile None detected
002-FT2-006
(Layer 2) Tan mastic None detected
003-FT1-007
(Layer 1) Electrical equipment 13
Gray floor tile None detected
003-FT1-007
(Layer 2) Tan mastic PC1 1.2% chrysotile
1 PC = point count
USDA Building #152 ■ Ames, IA
Responsive ■ Resourceful ■ Reliable B-2
003-FT1-008
(Layer 1) Electrical equipment 13 Gray floor tile None detected
003-FT1-008
(Layer 2) Tan mastic PC 1.1% chrysotile
003-FT1-009
(Layer 1) Electrical equipment 13 gray floor tile None detected
003-FT1-009
(Layer 2) Tan mastic PC 1.2% chrysotile
004-FC3-010
(Layer 1)
Electrical equipment 13
Black cove base None detected
004-FC3-010
(Layer 2) Brown mastic None detected
004-FC3-010
(Layer 3) Tan mastic PC 1.1% Chrysotile
004-FC3-011
(Layer 1)
Toilet room 21 Black cove base None detected
004-FC3-011
(Layer 2) Brown mastic None detected
004-FC3-012
(Layer 1)
Lunch room 20 Black cove base None detected
004-FC3-012
(Layer 2) Brown mastic None detected
005-MA5-013
(Layer 1)
Shower room 22A SW stall White ceramic None detected
005-MA5-013
(Layer 2) Gray grout None detected
005-MA5-014
(Layer 1)
Shower room 22A central stall White ceramic None detected
005-MA5-014
(Layer 2) Gray grout None detected
005-MA5-015
(Layer 1)
Shower room 2 SE stall White ceramic None detected
005-MA5-015
(Layer 2) Gray grout None detected
006-HP1-016
(Layer 1)
Vestibule 19 NE corner White plaster None detected
006-HP1-016
(Layer 2)
Gray plaster None detected
006-HP1-017
(Layer 1)
Corridor 17 north wall west White plaster None detected
006-HP1-017
(Layer 2) Gray plaster None detected
Responsive ■ Resourceful ■ Reliable B-3
006-HP1-018
(Layer 1) Corridor 17 north wall center
White plaster None detected
006-HP1-018
(Layer 2) Gray plaster None detected
007-WB1-019
(Layer 1)
Northwest wall room 20B White drywall None detected
007-WB1-019
(Layer 2) White joint compound None detected
007-WB1-020
(Layer 1)
West wall hallway 20A
White drywall None detected
007-WB1-020
(Layer 2) White joint compound PC 2.8% Chrysotile
007-WB1-020
(Layer 3) Gray plaster None detected
007-WB1-021
(Layer 1)
North wall of room 1A White drywall None detected
007-WB1-021
(Layer 2) White joint compound None detected
008-HP1-022
(Layer 1) Locker room 23
Gray plaster None detected
008-HP1-022
(Layer 2) Gray texture PC 1.1% Chrysotile
008-HP1-023
(Layer 1)
Room 22A White plaster None detected
008-HP1-023
(Layer 2) Gray plaster None detected
008-HP1-024
(Layer 1)
Locker room 4 Gray plaster None detected
008-HP1-024
(Layer 2) Gray texture None detected
009-HP1-025
(Layer 1)
North wall lunch room 1
White plaster None detected
009-HP1-025
(Layer 2) Gray plaster None detected
009-HP1-025
(Layer 3) Gray texture None detected
009-HP1-026
(Layer 1)
Corridor 17 north wall center
White plaster None detected
009-HP1-026
(Layer 2) Gray plaster None detected
009-HP1-026
(Layer 3) Gray texture None detected
Responsive ■ Resourceful ■ Reliable B-4
009-HP1-027
(Layer 1)
Corridor 17 north wall east
White plaster None detected
009-HP1-027
(Layer 2) Gray plaster None detected
009-HP1-027
(Layer 3) Gray texture None detected
10-HP3-028
(Layer 1)
South side room 1A
White plaster None detected
10-HP3-028
(Layer 2) Gray plaster None detected
10-HP3-028
(Layer 3) Gray texture None detected
10-HP3-029
(Layer 1)
North side lunch room 20
White plaster None detected
10-HP3-029
(Layer 2) Gray plaster None detected
10-HP3-029
(Layer 3) Gray texture None detected
10-HP3-030
(Layer 1)
East side room 20C
White plaster None detected
10-HP3-030
(Layer 2) Gray plaster None detected
10-HP3-030
(Layer 3) Gray texture None detected
11-CT3-031 NW side of toilet room 3 Tan ceiling tile None detected 11-CT3-032 Center of toilet room 3 Tan ceiling tile None detected 11-CT3-033 NE side of toilet room 3 Tan ceiling tile None detected 12-CT4-034 NW side of office 24 Tan ceiling tile None detected 12-CT4-035 NE side of office 24 Tan ceiling tile None detected 12-CT4-036 SE side of office 24 Tan ceiling tile None detected 13-SC1-037 West window south Gray glazing PC 1.5% Chrysotile 13-SC1-038 West windows south north Gray glazing PC 1.6% Chrysotile 13-SC1-039 West windows north central Gray glazing PC 1.6% Chrysotile 14-SC7-040 Interior window vestibule 19 Gray sealant PC 1.2% chrysotile 14-SC7-041 Gray sealant PC 1.1% chrysotile 14-SC7-042 Interior window vestibule 9 Gray sealant PC 1.1% chrysotile 15-CA5-043 SE corner vestibule 19 Gray caulk 10% chrysotile 15-CA5-044 NE corner vestibule 19 Gray caulk 10%chrysotile 15-CA5-045 NE corner vestibule 9 Gray caulk 10% chrysotile
16-SC7-046
North interior window vestibule
Gray sealant None detected 16-SC7-047 Gray sealant None detected 16-SC7-048 Gray sealant None detected
Responsive ■ Resourceful ■ Reliable B-5
17-CA5-049
(Layer 1) N-W window N side Gray caulk PC 1.1% chrysotile
17-CA5-049
(Layer 2) Lt gray caulk None detected
17-CA5-050
(Layer 1) N-W window S side
Gray caulk PC 1.2% chrysotile
17-CA5-050
(Layer 2) Lt gray caulk None detected
17-CA5-051
(Layer 1) S-W window central
Gray caulk PC 1.2% chrysotile
17-CA5-051
(Layer 2) Lt gray caulk None detected
18-CA1-052
Exterior office 10 window
White caulk None detected 18-CA1-053 White caulk None detected 18-CA1-054 White caulk None detected 19-SC1-055 W-S window Gray glazing None detected 19-SC1-056 Upper south office 10 window Gray glazing None detected 19-SC1-057 W-N window Gray glazing None detected 20-CA5-058 Exterior windows office 10 Gray caulk None detected
20-CA5-059
(Layer 1) Exterior windows office 10 Gray caulk None detected
20-CA5-059
(Layer 2) Tan caulk PC 2.1% chrysotile
20-CA5-060
(Layer 1) Exterior windows office 10
Gray caulk None detected
20-CA5-060
(Layer 2) Tan caulk PC 1.8% chrysotile
21-CA2-061
North exit door
Gray caulk None detected 21-CA2-062 Gray caulk None detected 21-CA2-063 Gray caulk None detected
22-SC7-064
(Layer 1) South exit door Gray sealant PC 1.2% chrysotile
22-SC7-064
(Layer 2) Brown sealant PC 1.4% chrysotile
22-SC7-065
(Layer 1) South exit door
Gray sealant PC 1.1% chrysotile
22-SC7-065
(Layer 2) Brown sealant PC 1.2% chrysotile
22-SC7-066
(Layer 1) North exit door
Gray sealant PC 1.1% chrysotile
22-SC7-066
(Layer 2) Brown sealant PC 1.3% chrysotile
Responsive ■ Resourceful ■ Reliable B-6
23-CA6-067
East side entrances Gray caulk None detected
23-CA6-068 Gray caulk None detected 23-CA6-069 Gray caulk None detected
24-MS5-070
(Layer 1) Mech. equip. 5 Yellow wrap None detected
24-MS5-070
(Layer 2) Gray/white coating PC 1.5% chrysotile
24-MS5-071
(Layer 1)
Mech. equip. 5 Yellow wrap None detected
24-MS5-071
(Layer 2) White coating None detected
24-MS5-072
(Layer 1)
Mech. equip. 5
Yellow wrap None detected
24-MS5-072
(Layer2) White wrap None detected
24-MS5-072
(Layer 3) Gray/white coating PC 1.7% chrysotile
25-MS5-073 Mech. equip. 5 Yellow/silver wrap None detected 25-MS5-074 Mech. equip. 5 Yellow/silver wrap None detected 25-MS5-075 Mech. equip. 5 Yellow/silver wrap None detected 26-MS5-076 Locker rooms Silver/off-white paper 30% chrysotile 26-MS5-077 Locker rooms Silver/off-white paper 30% chrysotile 26-MS5-078 Locker rooms Silver/off-white paper 30% chrysotile
27-MI1-079
(Layer 1)
Mech. equip. 5
White woven material None detected
27-MI1-079
(Layer 2) Off-white insulation None detected
27-MI1-079
(Layer 3) Brown/yellow insulation None detected
27-MI1-080
(Layer 1)
Mech. equip. 5
White woven material None detected
27-MI1-080
(Layer2) Off-white insulation None detected
27-MI1-080
(Layer 3) Brown insulation None detected
27-MI1-081
(Layer 1)
Mech. equip. 5 Off-white insulation None detected
27-MI1-081
(Layer2) Brown/yellow insulation None detected
28-MA1-082
(Layer2)
Throughout the exterior Red brick None detected
28-MA1-082
(Layer2) Gray mortar None detected
Responsive ■ Resourceful ■ Reliable B-7
28-MA1-083
(Layer 1) Throughout the exterior
Red brick None detected
28-MA1-083
(Layer2) Gray mortar None detected
28-MA1-084
(Layer 1)
Throughout the exterior Red brick None detected
28-MA1-084
(Layer2) Gray mortar None detected
29-MA2-085
(Layer 1)
Throughout the interior Gray cementitious None detected
29-MA2-085
(Layer2) Gray mortar None detected
29-MA2-086
(Layer 1)
Throughout the interior Gray cementitious None detected
29-MA2-086
(Layer2) Gray mortar None detected
29-MA2-087
(Layer 1)
Throughout the interior Gray cementitious None detected
29-MA2-087
(Layer 2) Gray mortar None detected
30-WP6-088
(Layer 1)
Bldg. 152 junction box Black woven material None detected
30-WP6-088
(Layer 2) Black rubber None detected
30-WP6-089
(Layer 1)
Bldg. 152 junction box Black woven material None detected
30-WP6-089
(Layer 2) Black rubber None detected
30-WP6-090
(Layer 1)
Bldg. 152 junction box Black woven material None detected
30-WP6-090
(Layer2) Black rubber None detected
31-WP6-091
(Layer 1)
Mechanical room power leads Black woven material None detected
31-WP6-091
(Layer2) Black rubber None detected
31-WP6-092
(Layer 1)
Mechanical room power leads Black woven material None detected
31-WP6-092
(Layer2) Black rubber None detected
31-WP6-093
(Layer 1) Mechanical room power leads Black woven material None detected
Responsive ■ Resourceful ■ Reliable B-8
31-WP6-093
(Layer2) Black rubber None detected
32-WP6-094
(Layer 1)
Mech room Red rubber None detected
32-WP6-094
(Layer2) Black rubber None detected
32-WP6-095
(Layer 1)
Mech room Red rubber None detected
32-WP6-095
(Layer2) Black rubber None detected
32-WP6-096
(Layer 1)
Electrical room Red rubber None detected
32-WP6-096
(Layer2) Black rubber None detected
33-WP5-097
(Layer 1)
Mech room Tan insulation None detected
33-WP5-097
(Layer2) Red mastic None detected
33-WP5-098
(Layer 1)
Mech room Tan insulation None detected
33-WP5-098
(Layer2) Red mastic None detected
33-WP5-099
(Layer 1)
Mech room Tan insulation None detected
33-WP5-099
(Layer2) Red mastic None detected
34-WP5-100 Mech room Red insulation None detected 34-WP5-101 Mech room Red insulation None detected 34-WP5-102 Mech room Red insulation None detected 35-WP5-103 Mech room Black insulation None detected 35-WP5-104 Mech room Black insulation None detected 35-WP5-105 Mech room Black insulation None detected 36-WP5-106 Mech room Tan insulation None detected 37-WP6-107 Throughout the building Red/white/black rubber None detected
38-WP6-108
(Layer 1) Office areas (clocks)
Brown paper None detected
38-WP6-108
(Layer 2) Black non-fibrous None detected
39-WP6-109
(Layer 1)
Mech room Black non-fibrous None detected
39-WP6-109
(Layer 2) Gray non-fibrous None detected
Responsive ■ Resourceful ■ Reliable B-9
39-WP6-109
(Layer 3) Gray/tan non-fibrous None detected
39-WP6-109
(Layer 4) Black tar None detected
39-WP6-109
(Layer 5)
Black non-fibrous PC 0.75% Chrysotile
40-WP6-110 Mech room Dk brown non-fibrous None detected
41-HP5-111
(Layer 1) 20B
Off-white plaster None detected
41-HP5-111
(Layer 2) Brown paper None detected
41-HP5-112
(Layer 1)
20B Off-white plaster None detected
41-HP5-112
(Layer 2) Brown paper None detected
41-HP5-113 Lunch room 1 by sink Brown paper None detected 42-RF1-114 Ventilation hoods Black tar PC 1.6% chrysotile 42-RF1-115 Ventilation hoods Black tar PC 1.7% chrysotile 42-RF1-116 Ventilation hoods Black tar PC 1.5% chrysotile
43-RF5-117
(Layer 1) West center of roof
Black roof material None detected
43-RF5-117
(Layer 2) Black tar None detected
43-RF5-118
(Layer 1)
West center of roof Black roof material None detected
43-RF5-118
(Layer 2) Black tar None detected
43-RF5-119
(Layer 1)
West center of roof
Black roof material None detected
43-RF5-119
(Layer 2) Black tar None detected
43-RF5-119
(Layer 3) Brown insulation None detected
44-SC7-120 Along west roof edge Gray putty None detected 44-SC7-121 Along west roof edge Gray putty None detected 44-SC7-122 Along west roof edge Gray putty None detected 45-SC7-123 Center vent pipe Gray caulk None detected 45-SC7-124 Center vent pipe Gray caulk None detected 45-SC7-125 Center vent pipe Gray caulk None detected 46-CA5-126 West overhang ridge Gray caulk None detected 46-CA5-127 West overhang ridge Gray caulk None detected 46-CA5-128 West overhang ridge Gray caulk None detected
Responsive ■ Resourceful ■ Reliable B-10
47-MJ5-129 Storage 23A Off-white insulation PC 4.3% Chrysotile/ 2.2% Amosite
47-MJ5-130 Locker room 23 White insulation PC 5.1% Chrysotile/ 4.3% Amosite
47-MJ5-131 Locker room 4 Off-white insulation PC 2.2% Chrysotile/ 4.5% Amosite
48-MJ5-132 Storage 23A Off-white insulation PC 2.8% Chrysotile/ 1.8% Amosite
48-MJ5-133 Locker room 23 White insulation PC 4.1% Chrysotile/ 3.2% Amosite
48-MJ5-134 Locker room 4 White insulation PC 2.2% Chrysotile/ 4.4% Amosite
49-PI5-135
(Layer 1)
Storage 23A Yellow insulation None detected
49-PI5-135
(Layer 2)
White/black mastic / paper None detected
49-PI5-136
(Layer 1)
Locker room 23 Yellow insulation None detected
49-PI5-136
(Layer 2)
White/black mastic / paper
None detected
49-PI5-137
(Layer 1)
Locker room 4 Yellow insulation None detected
49-PI5-137
(Layer 2)
White/black mastic / paper None detected
Responsive ■ Resourceful ■ Reliable B-11
Table 2 – Lead-Based Paint Screening Summary
Samples 1-6 and 33-37 were calibration shots and were not included in the summary. XRF results between 0.7 and 1.3 mg/cm2 are considered inconclusive; therefore, results less than 1.3 mg/cm2 are considered lead-containing. Negative values are interpolated as zero lead content due to the statistical nature of the XRF measurement. This does not mean that the coatings do not contain lead.
Location Building
Component Sample Number Substrate Color Condition
Analysis Result
(mg/cm2) Lunch room Wall 7 Plaster Off-white G -0.3 Lunchroom Wall 8 Plaster Off-white G -0.3 Lunchroom door Door 9 Metal Blue G -0.2 Room 20C interior door Door 10 Metal Blue G -0.1 Room 20C wall Wall 11 Plaster Off-white G -0.2 Room 20C exterior door Door 12 Metal Blue G -0.1 Room 23A door Door 13 Metal Green G -0.2 Room 23A wall Wall 14 Plaster Lime green G 0.0 Room 23 ceiling Ceiling 15 Plaster Off-white G -0.1 Room 21 wall Wall 16 Plaster Off-white G -0.2 Room 23 door to Room 2 Door 17 Metal Light blue G -0.2 Room 17 door to Room 16 Door 18 Metal Light blue G…
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