Amdmt 1_Reference C_HazMat Reports.pdf

ENVIRONMENTAL SCIENCE, ENGINEERING & INDUSTRIAL HYGIENE SERVICES

ENVIRONMENTAL HAZARDS ASSESSMENT: INSPECTION & TESTING REPORTS SUMMARY

REPORT DATE REPORT TITLE TRANSMITTED FINDINGS

28 July 2023 LIMITED MERCURY VAPOR SCREEN

FINAL TECHNICAL REPORT

28 July 2023

2140 EST

Mercury Vapor-Plumbing Traps: all of the plumbing drain traps underwent mercury vapor analysis (MVA); testing revealed ‘None Detect” for mercury vapor. No further action warranted.

28 July 2023 LIMITED BUILDING CONDITION

ASSESSMENT MICROBIAL (MOLD)

GROWTH

28 July 2023

1454 EST

A number of rooms will need to undergo mold remediation, once the building is not leaking. This is the work of UFGS Spec Section 02 85 00 (11/18, CHG

1: 05/22) Mold Remediation

26 July 2023 HAZARDOUS MATERIALS SCREEN FINAL

TECHNICAL REPORT

26 July 2023

2210 EST

No PCB-containing ballast are present. No further action warranted.

Mercury-containing fluorescent lamps will need to be removed and either protected for reuse or recycled. This is the work of UFGS Spec Section 02 84

16 (11/22) Handling of Lighting Ballasts and Lamps Containing PCBs and

Mercury. Additionally, the Owner must decide on declaring the removal and disposition (recycled or disposal) of mercury lamps, either via a Hazardous

Waste Generator permit OR recycle the mercury lamps under a Universal

Waste Handler permit.

Numerous RTU compressors contain ODP/GWP refrigerant gas the RTUs scheduled for removal/replacement (and the wall-mounted drinking water fountain) are required to undergo recovery/reclamation of the refrigerant gas.

This is the work of UFGS Spec Section 23 23 00 Refrigerant Piping.

Numerous other domestic refrigerators/freezer/portable water dispenser presumably are in good working order and will remain in service, if not refrigerant gas must be recovered/reclaimed.

24 July 2023 ASBESTOS-CONTAINING BUILDING

MATERIALS SURVEY FINAL TECHNICAL

REPORT

25 July 2023

1717 EST

No asbestos-containing building materials (ACBMs) present.

No further action warranted.

25 July 2023 LEAD-BASED PAINT INSPECTION FINAL

TECHNICAL REPORT

25 July 2023

1717 EST

Paint with lead (PWL) was determined to exist at one of two paint chip samples from typical metal doors and associated metal door casings present throughout Lab Building 3. No other paint films contain detectable levels of lead (Pb+2). The Owner should review their own internal risk management policies and environmental safety/health standard operating procedures (ESH

SOP), prior to their decision-making on their course of action and/or selection of contractor. The options available to the Owner are, as follows: Option 1:

Communicate the existence of the PWL workplace hazard and rely on contractor to comply with regulations, or Option 2: Engage an RRP-accredited

General Contractor to complete work involving the PWL-finished building components, or Option 3: Engage a professional lead abatement contractor to complete work involving the PWL-finished building components. Option 2 or Option 3 are the work of UFGS Spec Section 83 00 (11/18) Lead

Remediation

LIMITED MERCURY VAPOR SCREEN

FINAL TECHNICAL REPORT

Conducted at:

PUERTO RICO DEPARTMENT OF AGRICULTURE FACILITY

(PRDA)

Dorado, Puerto Rico

Prepared for:

5970 Greenwood Plaza Boulevard

Greenwood Village, Colorado 80111

Attention:

Mr. Jon C. DeLay, P.E., MS EMGT

Senior Project Director

BEC Project #PR23002

Fieldwork Conducted: June 8, 2023

Report Date: June 28, 2023

Final Report Review: July 28, 2023

Prepared by:

Middletown, MD ~ Morgantown, WV Corporate Office: 200 W Main Street, Middletown, MD 21769 Tel: (301) 694‐5687 ~ Fax: (301) 694‐9799

LIMITED MERCURY VAPOR SCREEN

TABLE OF CONTENTS

SECTION 1.0 SITE DESCRIPTION & SCOPE OF WORK 1

SECTION 2.0 LIMITED MERCURY VAPOR SCREEN

Section 2.1 Background 2

Section 2.2 Mercury Screening Rationale 2

Section 2.3 Regulatory Background 3

Section 2.4 Field Screening Protocol 3

Section 2.5 MVA Screening Results 4

Section 2.6 Limitations 5

SECTION 3.0 CONCLUSIONS & RECOMMENDATIONS

Section 3.1 Conclusions 5

Section 3.2 Recommendations 5

TABLES

TABLE A: Mercury Vapor Testing Results

APPENDICES

APPENDIX A: Field Documents

APPENDIX B: Mercury Vapor Analyzer

APPENDIX C: MVA Screening Photograph

BOGGS ENVIRONMENTAL CONSULTANTS, INC.

On-site Fieldwork & Final Technical Report By:

Andrew L. Hanson, CIEC Derrick A. Klein

Project Manager Project Manager

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USDA-APHIS PRDA LAB BUILDING 3 LIMITED MERCURY VAPOR SCREEN

DORADO, PUERTO RICO FINAL TECHNICAL REPORT

SECTION 1.0 SUBJECT SITE DESCRIPTION & SCOPE OF WORK

Project Site: USDA APHIS PRDA - Lab Building 3

Requester Name: Jon C. DeLay, P.E., MS EMGT, Senior Project Director

Requestor Address: MERRICK & COMPANY

Subject Site Description & Scope of Work:

Laboratory Building #3 (hereinafter referred to as Lab Building 3) is located at the Puerto Rico Department of

Agriculture (PRDA) complex, near Dorada in north-central Puerto Rico. Lab Building 3 is approximately 10,000

GSF and consists of two wings, one for administration offices and one for the laboratories; the lab wing was constructed in 1994 as a replacement of a smaller original wing.

USDA APHIS uses about half of the lab wing to support their ongoing diagnostic operations for monitoring the

African Swine Fever outbreaks in Haiti and the Dominican Republic. USDA APHIS use of Lab Building 3 includes two lab rooms, the Necropsy Room shared with PRDA, a storage room, and the Autoclave/Cleaning Room shared with PRDA. USDA APHIS staff also uses the male and female change rooms at the lab perimeter.

Merrick & Company (Merrick) subcontracted with BEC to conduct a preliminary environmental hazards assessment

(EHA) in support of the overall infrastructure assessment (IA) scope of work, as more fully described in the

‘Statement of Work for PRDA Infrastructure Assessment’ (USDA APHIS, January 7, 2022). The Infrastructure

Assessment (IA) statement of work outlined various deficient building conditions and malfunctioning operating systems and the need for major building system improvements, remediation work, mechanical/electrical system upgrades, etc. and requirements to correct those deficient conditions. It is the removal and replacement of existing building components and operating systems that prompted Merrick to subcontract with BEC to conduct preliminary environmental hazards assessment (EHA) of Lab Building 3.

Merrick/BEC team members visually inspected existing building conditions with PRDA and USDA personnel on

February 8/9, 2022. Meetings occurred to discuss conditions, operational requirements, and possible scopes for repair and/or upgrade. The objective of the preliminary EHA was two-fold: (1) evaluate existing conditions;

determine the location and extent of presumptive environmental hazards (i.e., hazardous building construction materials and/or hazardous substances) via technical visual inspection and (2) future disturbance; identify the location and extent of presumptive environmental hazards which will, or could be reasonably anticipated to, undergo disturbance or damage during renovation work activities with the potential to create environmental pollution and/or an unhealthy worker exposure condition.

A follow-up site visit was conducted by Merrick/BEC on January 18/19, 2023 to evaluate existing conditions (and any changes thereto) prior to preparation of Merrick’s response to USDA APHIS Request for Proposal (RFP) entitled ‘Design Services for Puerto Rico Department of Agriculture, Lab Building 3 Renovation and

Modernization’ via Merrick’s Indefinite Delivery Contract for ‘Nationwide AE Services’ (#12639521D0054, July 12, 2021).

Merrick submitted to USDA APHIS the “Building Condition Assessment- Draft, Dept. of Agriculture, Puerto Rico

– Lab Building 3” report on April 11, 2022. Subsequently, Merrick submitted to USDA APHIS the “Feasibility

Study- Draft, Dept. of Agriculture, Puerto Rico – Lab Building 3” report on May 18, 2022. The former report contained our preliminary EHA findings, which detailed the presence of the following presumptive adverse hazardous building construction materials and conditions observed during the February 8/9, 2022 site visit: visible mold growth; asbestos-containing building materials (ACBMs); lead-based paint/paint with lead (LBP/PWL);

polychlorinated biphenyl-containing compounds (PCBs) within fluorescent electrical lighting fixtures’ ballast;

mercury-containing lamps; mercury-containing plumbing P-traps; ozone depleting potential/global warming potential

(ODP/GWP) refrigerant gas.

Page | 2

The latter report investigated the impact of the presumptive adverse environmental conditions, as detailed in our preliminary EHA report, to three (3) proposed levels of renovation and associated costs.

BEC was subcontracted on April 12, 2023 by Merrick to support the scope of work detailed in the ‘Statement of

Work for Architectural & Engineering Services’ (USDA APHIS, November 28, 2022). The following tasks were included in the subcontracted services:

• NEPA Documentation- determination of categorical exclusion designation for the USDA APHIS proposed action (PA) or requirement for environmental assessment (EA) study for the PA;

• A-E Abatement Design Services- (i) technical visual inspections and/or physical sampling with laboratory analysis to rebut or confirm the presence of presumptive EHAs, as observed during the February 8/9, 2022 and January 18/19, 2023 site visits. These inspections/sampling protocols are statutorily required by

Federal environmental pollution and worker protection laws applicable to renovation and demolition construction projects. (ii) prepare abatement/remediation specifications to address all environmental hazards definitively confirmed to exist at Lab Building 3.

Limited Mercury Vapor Screen

This report addresses the findings of environmental testing for detectable levels of mercury vapor in plumbing P-traps present at Lab Building 3.

BEC received authorization from Jon C. DeLay, Senior Project Director with Merrick, to mobilize to the project site during the week of June 5, 2023. It is relevant to note, the mercury vapor screening was limited to readily-accessible plumbing drains and did not include exploratory demolition of enclosed construction conditions.

Therefore, BEC makes no references or representations regarding the presence or absence of mercury vapors potentially present at inaccessible plumbing systems and/or other building areas not included in this scope of work.

2.1 Background

BOGGS ENVIRONMENTAL CONSULTANTS, INC. (BEC) performed a limited mercury vapor screen within Laboratory

Building 3 of the Puerto Rico Department of Agriculture (PRDA) facility located in Dorado, Puerto Rico on June 8, 2023.

2.2 Mercury Screening Rationale

Mercury thermometers are still utilized in industries and processes that require precise temperature measurements. Mercury may be present in laboratory sewer pipes, sumps, and sink traps from the past use of mercury. Mercury enters pipes when items were broken, discarded or spilled in sinks. Mercury in plumbing can settle at a low point such as a sump or sink trap and remain in the plumbing of laboratories for many years. Often the slow release of the mercury accumulation in a pipe, sump, or sink trap is enough to cause violations of wastewater discharge standards even after Best Management Practices (BMPs) for mercury have been introduced into laboratory settings.

As plumbing lines serve a diagnostic laboratory, in operation since 1971, and breakage of mercury-containing thermometers routinely occurs, it was presumed some level of mercury existed within the associated plumbing ‘P-traps’. While the potential for USDA APHIS/PRDA staff’s mercury exposures to exceed legally-enforceable limits

(i.e., action level (AL), permissible exposure limit (PEL), and/or ceiling limit (CL)) was deemed low in the conduct of their routine daily tasks, planned renovation work will, or can be reasonably anticipated to, result in the disturbance of the plumbing system. Accordingly, environmental testing to determine residual mercury presence at plumbing systems was warranted, in accordance with United States Occupational Safety and Health Administration (US

OSHA) construction industry worker protection regulation entitled “Gases, Vapors, Fumes, Dusts, and Mists” (29

CFR 1926.55), among other US OSHA standards.

http://boggsenvironmental.com/

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2.3 Regulatory Background

BEC advises the “screening” threshold for designation of piping systems as “mercury contaminated” was established at ten thousand nanograms per cubic meter (10,000 ng/m3), measured as a 30-second Time Weighted Average (30-sec TWA). The United States Environmental Protection Agency (US EPA) list this “screening” threshold within their regulatory guidance document entitled “The Mercury Response Guidebook”, (US EPA, July 2004).

It is relevant to note, “The Mercury Response Guidebook” also lists an acceptable “post decontamination (abatement) level” of 1000 ng/m3; the maximum mercury vapor concentration following an actual remediation scope of work.

Additionally, US OSHA has established a legally-enforceable “Permissible Exposure Limit” (PEL) for mercury vapor at 100,000 ng/m3 of air, as a ceiling limit (CL); a worker's exposure to mercury vapor shall at no time exceed the CL.

The US OSHA permissible exposure limit (PEL) for mercury is a ceiling limit of 0.1 milligrams per cubic meter of air (mg/m³), which is currently enforced as an 8-hour time-weighted average. Other organizations suggest lower exposure levels. The National Institute for Occupational Safety and Health (NIOSH) recommends that exposures to mercury metal be limited to an average of 0.05 mg/m3 over a 10-hour workday, in addition to a ceiling limit of 0.1 mg/m3. The American Conference of Governmental Industrial Hygienists (ACGIH) recommends that metallic mercury exposures be limited to an average of 0.025 mg/m3 over an 8-hour workday.

2.4 Field Screening Protocol

BEC conducted sampling at all visible plumbing ‘P-Traps’ located within Lab Building 3 to determine mercury vapor concentrations. BEC used a field screening method via a direct-read mercury vapor analyzer (MVA) to detect mercury vapor. Vapor extraction from the headspace of the plumbing trap was facilitated by using an in-line air filter to seal the trap and to protect the instrument from gross contamination while the sample was collected. Each sampling event required about two (2) minutes to complete. BEC logged sampling location and mercury vapor concentrations measured at each sink. Disassembly of plumbing traps to remove and analyze contents for total mercury and/or dissolved mercury did not occur during this survey. If obliged, owing to detected mercury vapor, such disassembly and evaluation to determine correlation, if any, between vapor concentrations in the headspace and mercury concentration in pooled water was designated to be the work of others and addressed within a mercury remediation workplan.

Mercury Vapor Screening (Testing) Locations

BEC staff Andrew L. Hanson and Derrick A. Klein conducted the mercury vapor screening of all plumbing drain P-

Traps readily-visible within Lab Building 3. BEC conducted the environmental testing on June 8, 2023 at the following locations:

a. Toilet room lavatory sink drains,

b. Shower room floor drains

c. Janitor Closet utility sink drains

d. Laboratory bench sink drains

e. Laboratory floor drains

f. Laundry Room/Glassware sink drains and floor drains

Mercury Vapor Screening Equipment

BEC utilized the Jerome 405® mercury vapor analyzer (MVA), as manufactured by AMETEK Brookfield of

Middleboro, Massachusetts, to reveal mercury vapor concentrations present at each testing location. The Jerome®

J405 is direct-read MVA equipped with real-time display, an ambient air analyzer with a range of 0.5 to 999 micrograms of mercury vapor per cubic meter (µg/m3 Hg).

Page | 4

2.4 Field Screening Protocol

Mercury Vapor Screening Equipment (continued)

BEC staff performed the MVA manufacturer’s “regeneration test”; confirming the mercury vapor analyzer was operating within specifications, prior to initial use.

Additionally, BEC measured the relative humidity and ambient temperature at the testing locations. Ambient temperature and relative humidity levels were measured utilizing the DSP 1000 Digital Psychrometer, as manufactured by Sealed Unit Parts Company, Incorporated (SUPCO) of Allenwood, New Jersey. The DSP 1000 Digital Psychrometer is a hand-held, direct read, real time display analytical instrument.

2.5 MVA Screening Results

BEC provides the results of the MVA screening hereunder in Table A: Mercury Vapor Analyzer Testing Results:

TABLE A: MERCURY VAPOR ANALYZER TESTING RESULTS

Room # Testing Location Hg (mg/m3) Relative

Humidity (%)

Temperature

(F)

105 Sink #1 0.00 33.5 78.4

108 Sink #1 0.00 34.4 78.6

108 Sink #2 0.00 34.4 78.6

108 Floor #3 0.00 34.4 78.6

107 Sink #1 0.00 35.7 78.1

107 Sink #2 0.00 35.7 78.1

107 Floor #3 0.00 35.7 78.1

109 Floor #1 0.00 34.5 78.6

113 Sink #1 0.00 33.3 78.6

115B Sink #1 0.00 34.2 78.6

115B Sink #2 0.00 34.2 78.6

115B Floor #3 0.00 34.2 78.6

114 Sink #1 0.00 37.2 78.5

114 Floor #2 0.00 37.2 78.5

114 Floor #3 0.00 37.2 78.5

132 Sink #1 0.00 36.8 78.8

134 Sink #1 0.00 39.4 79.0

134 Flor #2 0.00 39.4 79.0

131 Sink #1 0.00 32.3 78.6

131 Sink #2 0.00 32.3 78.6

131 Floor #3 0.00 32.3 78.6

131 Floor #4 0.00 32.3 78.6

131 Sink #5 0.00 32.3 78.6

131 Floor #6 0.00 32.3 78.6

129 Sink #1 0.00 33.1 78.5

129 Floor #2 0.00 33.1 78.5

130 Sink #1 0.00 34.6 78.6

116 Floor #1 0.00 35.3 78.6

117 Sink #1 0.00 36.7 78.4

117 Sink #2 0.00 36.7 78.4

117 Floor #3 0.00 36.7 78.4

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2.5 MVA Screening Results (continued)

TABLE A: MERCURY VAPOR ANALYZER TESTING RESULTS

Room # Testing Location Hg (mg/m3) Relative

Humidity (%)

Temperature

(F)

117 Floor #4 0.00 36.7 78.4

117 Floor #5 0.00 36.7 78.4

117 Floor #6 0.00 36.7 78.4

125 Sink #1 0.00 38.1 78.6

125 Floor #2 0.00 38.1 78.6

126 Sink #1 0.00 39.4 78.8

120 Sink #1 0.00 37.7 78.7

120 Floor #2 0.00 37.7 78.7

118 Floor #1 0.00 37.4 78.6

2.6 Limitations

The above screening was limited to visible readily-accessible plumbing drains at the time of the screen. BEC advises additional plumbing drains may be present at the subject site owing to an enclosed construction condition. Therefore, BEC makes no warranty, expressed or implied, that all drains located a Lab Building 3 were tested in the conduct of this screening event.

3.1 Conclusions

1. BEC concludes, based upon onsite visual inspection, forty (40) visible readily accessible plumbing drains are present at Lab Building 3.

2. BEC concludes, based upon onsite environmental testing, mercury vapor was not detected at any of the forty (40) plumbing drains.

3.2 Recommendations

1. No further action is warranted at this time.

2. Should demolition of enclosed construction conditions result in discovery of plumbing drains, it is recommended

MVA screening be conducted to rule out the presence of residual mercury.

APPENDIX A:

BEC FIELD DOCUMENTS

APPENDIX B:

MERCURY VAPOR ANALYZER

APPENDIX C:

MVA SCREENING PHOTOGRAPH

Jerome 405 Mercury Vapor Analyzer (MVA)

Screening Operation of Typical Sink Drain

LIMITED BUILDING CONDITION ASSESSMENT

MICROBIAL (MOLD) GROWTH

Fieldwork Conducted: June 8, 2023

Final Report Review: July 28, 2023

LIMITED BUILDING CONDITION ASSESSMENT

MICROBIAL (MOLD) GROWTH

SECTION 2.0 VISUAL OBSERVATIONS

Section 2.2 Investigative Protocol 3

Section 2.3 Visual Inspection Findings 3

Section 3.1 Conclusions 4

Section 3.2 Recommendations 4

SECTION 4.0 LIMITED BUILDING CONDITION ASSESSMENT LIMITATIONS

Section 4.1 Limitations 5

TABLE A: Summary of Visual Inspection

TABLE B: Summary of Areas Requiring Interim Control and/or Remediation

APPENDIX A: Field Documents

APPENDIX B: Site Photographs

APPENDIX C: Staff Qualifications

Andrew L. Hanson, CIEC Derrick A. Klein

USDA-APHIS PRDA LAB BUILDING 3 LIMITED BUILDING CONDITION ASSESSMENT

Project Site: USDA APHIS PRDA - Laboratory Building #3

Requester Name: Jon C. DeLay, P.E., MS EMGT, Senior Project Director

Laboratory Building #3 (hereinafter referred to as Lab Building 3) is located at the Puerto Rico Department of

Agriculture (PRDA) complex, near Dorada in north-central Puerto Rico. Lab Building 3 is approximately 10,000

GSF and consists of two wings, one for administration offices and one for the laboratories; the lab wing was constructed in 1994 as a replacement of a smaller original wing.

USDA APHIS uses about half of the lab wing to support their ongoing diagnostic operations for monitoring the

African Swine Fever outbreaks in Haiti and the Dominican Republic. USDA APHIS use of Lab Building 3 includes two lab rooms, the Necropsy Room shared with PRDA, a storage room, and the Autoclave/Cleaning Room shared

Merrick & Company (Merrick) subcontracted with BEC to conduct a preliminary environmental hazards assessment

(EHA) in support of the overall infrastructure assessment (IA) scope of work, as more fully described in the

‘Statement of Work for PRDA Infrastructure Assessment’ (USDA APHIS, January 7, 2022). The Infrastructure

Assessment (IA) statement of work outlined various deficient building conditions and malfunctioning operating systems and the need for major building system improvements, remediation work, mechanical/electrical system upgrades, etc. and requirements to correct those deficient conditions. It is the removal and replacement of existing building components and operating systems that prompted Merrick to subcontract with BEC to conduct preliminary environmental hazards assessment (EHA) of Lab Building 3.

Merrick/BEC team members visually inspected existing building conditions with PRDA and USDA personnel on

February 8/9, 2022. Meetings occurred to discuss conditions, operational requirements, and possible scopes for repair and/or upgrade. The objective of the preliminary EHA was two-fold: (1) evaluate existing conditions;

determine the location and extent of presumptive environmental hazards (i.e., hazardous building construction materials and/or hazardous substances) via technical visual inspection and (2) future disturbance; identify the location and extent of presumptive environmental hazards which will, or could be reasonably anticipated to, undergo disturbance or damage during renovation work activities with the potential to create environmental pollution and/or an unhealthy worker exposure condition.

A follow-up site visit was conducted by Merrick/BEC on January 18/19, 2023 to evaluate existing conditions (and any changes thereto) prior to preparation of Merrick’s response to USDA APHIS Request for Proposal (RFP) entitled

‘Design Services for Puerto Rico Department of Agriculture, Lab Building 3 Renovation and Modernization’ via

Merrick’s Indefinite Delivery Contract for ‘Nationwide AE Services’ (#12639521D0054, July 12, 2021).

Merrick submitted to USDA APHIS the “Building Condition Assessment- Draft, Dept. of Agriculture, Puerto Rico –

Lab Building 3” report on April 11, 2022. Subsequently, Merrick submitted to USDA APHIS the “Feasibility Study-

Draft, Dept. of Agriculture, Puerto Rico – Lab Building 3” report on May 18, 2022. The former report contained our preliminary EHA findings, which detailed the presence of the following presumptive adverse hazardous building construction materials and conditions observed during the February 8/9, 2022 site visit: visible mold growth;

asbestos-containing building materials (ACBMs); lead-based paint/paint with lead (LBP/PWL); polychlorinated biphenyl-containing compounds (PCBs) within fluorescent electrical lighting fixtures’ ballast; mercury-containing lamps; mercury-containing plumbing P-traps; ozone depleting potential/global warming potential (ODP/GWP) refrigerant gas.

The latter report investigated the impact of the presumptive adverse environmental conditions, as detailed in our preliminary

EHA report, to three (3) proposed levels of renovation and associated costs.

BEC was subcontracted on April 12, 2023 by Merrick to support the scope of work detailed in the ‘Statement of

Work for Architectural & Engineering Services’ (USDA APHIS, November 28, 2022). The following tasks were included in the subcontracted services:

• NEPA Documentation- determination of categorical exclusion designation for the USDA APHIS proposed action

(PA) or requirement for environmental assessment (EA) study for the PA;

• A-E Abatement Design Services- (i) technical visual inspections and/or physical sampling with laboratory analysis to rebut or confirm the presence of presumptive EHAs, as observed during the February 8/9, 2022 and January

18/19, 2023 site visits. These inspections/sampling protocols are statutorily required by Federal environmental pollution and worker protection laws applicable to renovation and demolition construction projects. (ii) prepare abatement/remediation specifications to address all environmental hazards definitively confirmed to exist at Lab

Building 3.

Limited Building Condition Assessment Microbial (Mold) Growth

This report addresses the findings of technical visual inspections for visible microbial growth and contributory deficient building conditions, as previously observed within Lab Building 3 and/or discovered during the most recent site visit. Completion of corrective actions to address causative deficient building conditions and remediation of visible mold growth, with proper packaging/transfer/disposal of associated wastes, is required prior and/or during the renovation of the structure.

BEC received authorization from Jon C. DeLay, Senior Project Director with Merrick, to mobilize to the project site during the week of June 5, 2023. It is relevant to note, the building condition assessment was limited to visual inspections of readily-accessible materials and did not include exploratory demolition of enclosed construction conditions. Therefore, BEC makes no references or representations regarding the presence or absence of mold colonization potentially present at inaccessible building construction conditions and/or not included in this scope of work.

BOGGS ENVIRONMENTAL CONSULTANTS, INC. (BEC) performed a limited building condition assessment (BCA) of Lab Building 3 on June 8, 2023.

BEC conducted an interview with Dr. Alejandro E Perez Ramirez, Assistant Director of Veterinary Services and

Livestock Health, to become familiar with the building history and discuss the limits of the BCA, prior to proceeding with the field work activities.

Thereafter, BEC staff environmental specialists, Andrew L. Hanson and Derrick A. Klein, conducted critical visual inspections for signs of historic and/or ongoing water infiltration/moisture intrusion conditions (water damage) and visible mold growth upon building component surfaces at both the interior and exterior areas of Lab Building 3. BEC notes the BCA visual inspections were limited to readily-accessible materials Lab Building 3.

Background

Microbial growth (mold) is a natural part of the environment and can be found almost anywhere that moisture and oxygen are present. They belong to the kingdom Fungi and live in moist places such as soil, plants and dead or decaying matter. Outdoors, molds play a part in nature by breaking down dead organic matter however, indoors mold growth should be avoided.

Background (continued)

There are many types of mold – all of them need water or moisture to grow. When excessive moisture accumulates in buildings or on building materials, mold growth often occurs, particularly if the moisture problem remains undiscovered or unaddressed. Mold growth can occur on: wood, paper, carpet, foods, and insulation; organic material serves as ‘food source’ for molds.

Moisture in buildings is a major contributor to microbial (mold) growth, unhealthy buildings, and poor indoor air quality (IAQ); a condition sometimes referred to as ‘Sick Building Syndrome’. As mold grows, spores, cells, fragments, and unstable organic compounds can enter the air. They can produce allergens, irritants, and mycotoxins.

Some of these can be toxic, especially to individuals who have a sensitivity to them, creating deleterious health effects also known as ‘Building Related Illness’ (BRI). The most common causes of mold growth at the interior of buildings include water at the foundation, flooding, leaks in roofs, leaking pipes and poor humidity and ventilation.

2.2 Investigative Protocol

BEC conducted a non-intrusive (non-destructive) visual inspection for staining, deterioration, and/or other visible signs of water damage and microbial growth present at readily accessible building components located within

Laboratory Building #3. In addition, BEC visually inspected ceiling plenums and heating, ventilation, and air conditioning (HVAC) equipment fan coils, condensate collection pans, etc. BEC annotated drawings to depict location of water damage to building components and surfaces adversely- affected with visible mold growth.

2.3 Visual Inspection Findings

Technical visual inspections of both the Administration and Laboratory sections of Lab Building 3 revealed “spot locations” of visible signs of water damage and mold growth at building component surfaces. The area of visible mold growth observed at interior building components decreased from the 1074 square feet, previously identified during the February 8/9, 2022 site visit, to 446 square feet observed during the week of June 5, 2023 site visit. This decrease is largely attributable to removal/replacement of suspended acoustical ceiling tiles (ACT) adversely-affected with visible mold growth and completion of corrective actions which sealed, in part, historic moisture intrusion/water infiltration pathways originating at the roofline combined with presumed increased housekeeping levels of effort.

BEC presents the visual inspection findings hereunder in Table A: Summary of Visual Inspection Results:

TABLE A: SUMMARY OF VISUAL INSPECTION

Location Visual Inspection Observations Quantity

(estimates)

Hall (Room 102), adjacent to Room 103 water-stain: suspended ACT 6 each visible mold growth: concrete wall ~ 100 sf

Room 105 water-stain: suspended ACT 2 each Mechanical Equipment Room (MER) Room 106 visible mold growth: concrete ceiling ~ 16 sf

Room 107 water-stain: suspended ACT 6 each

Clerical Office, Room 112 visible mold growth: concrete wall ~ 6 sf

Laundry/Glassware, Room 117 visible microbial growth: concrete wall ~ 4 sf water-stain: suspended ACT 6 each

MER, Room 119 visible microbial growth: HVAC ductwork insulation ~ 300 sf

Necropsy, Room 131 visible microbial growth: HVAC ductwork insulation ~ 20 sf

1. BEC concludes, based on technical visual inspections, ‘spot locations’ of visible water infiltration/moisture intrusion damage to building components exist at Lab Building 3.

2. BEC concludes, based on technical visual inspections, ‘spot locations’ of suspect microbial growth on concrete walls/ceilings and HVAC fiberglass ductwork insulation exist at Lab Building #3.

3. BEC concludes Lab Building 3 is currently not in a weather-tight condition which directly contributes

(facilitates/promotes) to historic/ongoing water damage and associated mold growth at the interior of the building.

This deficient building envelope condition requires critical evaluation and correction prior to completing required mold remediation work activities.

4. BEC concludes, based on deficient building envelope and biology of mold, it is likely additional water damage and/or mold colonization will (or has) occurred since the June 8, 2023 site visit.

GENERAL

BEC recommends the following general corrective actions to address the adverse environmental conditions observed

(documented) at Laboratory Building 3:

1. Remedy (repair/seal) all water infiltration/moisture intrusion pathway present at the building.

2. Control relative humidity in accordance with the American Society of Heating, Refrigerating and Air-Conditioning

Engineers (ASHRAE) standard “Ventilation for Acceptable Indoor Air Quality” (ASHRAE 62.1-2016) recommended levels.

3. Preparation of a detailed workplan to govern temporary measures and permanent actions to address visible mold growth:

Interim Control (temporary measures) strategies include disinfection of building components deemed acceptable to remain in-place (i.e., intensive cleaning using US EPA -registered antimicrobial fungicidal agent until surfaces are free of visible mold growth) and return component to satisfactory moisture content. Application of mold resistant encapsulant, specially formulated with select US EPA registered antimicrobial agents, pursuant to satisfactory moisture content measurement and acceptable post remediation verification inspection results.

Remediation (permanent elimination) involves the removal of the adversely- affected building components, in their entirety, owing to unacceptable porosity, structural integrity, and inability to ‘dry out’. The workplan would include, but would not necessarily be limited, to listing the location and extent of the work, description of approved work practices, engineering controls, personal protection equipment, and ‘post remediation verification’ (PRV) procedures.

4. Conduct mold remediation project.

5. Complete active remediation surveillance

6. Engage third-party industrial hygiene firm to perform post remediation verification (PRV) inspections at the work areas.

SPECIFIC

BEC recommends the following corrective actions to address the adverse environmental conditions observed at Lab

Building 3:

1. Incorporate moisture-content mapping at the building to determine elevated moisture content of building components scheduled to remain -in-place, prior to beginning any renovation work at Lab Building 3. This testing should be completed during “Pre-Existing Damage Tour” to ensure the Schedule of Materials listed in an interim control or remediation work plan is complete, owing to likelihood of additional water damage and/or mold colonization to occur from the date of this report to commencement of the renovation work.

It is relevant to note, the judgment on the efficacy of a building component, adversely affected by water damage/visible mold colonization, to remain in-place is based upon the following contingent conditions:

intact structural integrity; non-porous or semi-porous composition; capability to reduce moisture content of the component.

2. BEC recommends the following interim controls and remediation detailed hereunder in Table B: Summary of Areas

Requiring Remediation:

TABLE B: SUMMARY OF AREAS REQUIRING INTERIM CONTROLS AND REMEDIATION

Location Visual Inspection Observations Quantity

(estimates)

Hall (Room 102), adjacent to Room 103 Remove/Replace: suspended ACT 6 each

Disinfect/Stabilize Paint Film: concrete wall ~ 100 sf

Room 105 Remove/Replace: suspended ACT 2 each Mechanical Equipment Room (MER) Room 106 Disinfect/Stabilize Paint Film: concrete ceiling ~ 16 sf

Room 107 Remove/Replace: suspended ACT 6 each

Clerical Office, Room 112 Disinfect/Stabilize Paint Film: concrete wall ~ 6 sf

Laundry/Glassware, Room 117 Disinfect/Stabilize Paint Film: concrete wall ~ 4 sf

Remove/Replace: suspended ACT 6 each

MER, Room 119 Remove/Replace: HVAC ductwork insulation ~ 300 sf

Necropsy, Room 131 Remove/Replace: HVAC ductwork insulation ~ 20 sf

SECTION 4.0 BUILDING CONDITION ASSESSMENT LIMITATIONS

4.1 Limitations

BEC notes the scope of this investigation was limited to visually inspecting only readily accessible building components located at the subject site. BEC cautions evaluation of enclosed wall cavities and interstitial spaces, and/or additional building spaces (wall voids, pipe chases, crawlspaces, etc.) was not within the scope of this non-intrusive investigation. Accordingly, BEC is incapable of making judgments and conclusions regarding the presence or absence of elevated building component’s moisture content and/or visible mold growth at enclosed construction areas of the building.

BEC does warrant this Limited Building Condition Assessment Microbial (Mold) Growth was conducted in accordance with generally-accepted engineering practices and observing the practices/procedures prescribed in the following regulatory and national consensus organizations guidance documents:

Page | 6

SECTION 4.0 BUILDING CONDITION ASSESSMENT LIMITATIONS

4.1 Limitations (continued)

• US EPA - "Mold Remediation in Schools and Commercial Buildings" (#6609-J. EPA 402-K-01-001, March 2001) and US OSHA "Mold Remediation Guidelines" (SHIB #03-10-10).

• United States Occupational Safety & Health Administration, “A Brief Guide to Mold in the Workplace” (US OSHA

Safety and Health Information Bulletin, SHIB #03-10-10)

• United States Environmental Protection Agency’s (US EPA) Office of Air and Radiation, Indoor Environments

Division, "Mold Remediation in Schools and Commercial Buildings" (EPA 402-K-01-001, March 2001).

• American Industrial Hygiene Association, "Final Report of AIHA Microbial Growth Task Force" (AIHA, May

2001, page 38).

• Institute of Inspection Cleaning and Restoration Certification, “Standard and Reference Guide for Professional

Water Damage Restoration” (IICRC S500)

• Institute of Inspection Cleaning and Restoration Certification, “Standard and Reference Guide for Professional

Mold Remediation” (IICRC S520)

APPENDIX A:

FIELD DOCUMENTS

APPENDIX B:

SITE PHOTOGRAPHS

Visible Microbial Growth on Concrete Ceiling in Mechanical Room #106

Visible Microbial Growth on Concrete Wall in Clerical Room #112

Suspect Visible Microbial Growth on Concrete Wall in Hall Room #102 Outside Room #103

Visible Microbial Growth on HVAC Duct Insulation in Necropsy Room #131

Visible Microbial Growth on Concrete Wall in Laundry/Glassware Room #117

Visible Microbial Growth on HVAC Duct Insulation in Mechanical Room #119

APPENDIX C:

STAFF QUALIFICATIONS

hereby certifies that

Andrew L. Hanson has met all the specific standards and qualifications of the re-certification process, including continued professional development, and is hereby re-certified as a

CIEC

Council-certified

Indoor Environmental Consultant

This certificate expires on July 31, 2024 e

This certificate remains the property of the American Council for Accredited Certification.

American Council for Accredited Certification

Charles F. Wiles, Executive Director Certificate Number

2007010

HAZARDOUS MATERIALS SCREEN

Fieldwork Conducted: June 6, 2023

Final Technical Report Date: June 28, 2023

Final Review: July 26, 2023

HAZARDOUS MATERIALS SCREEN

SECTION 2.0 HAZARDOUS MATERIALS SCREEN

Section 2.2 Polychlorinated-Biphenyl Containing Materials 3

Section 2.3 Mercury Containing Fluorescent Lights 3

Section 2.4 Ozone Depleting Potential/Global Warming Potential Refrigerant Gas 4

Section 3.1 Conclusions 5

Section 3.2 Recommendations 5

SECTION 4.0 HAZARDOUS MATERIALS SCREEN LIMITATIONS

Section 4.1 Limitations 6

TABLE A: Mercury Containing Light Tubes

TABLE B: Ozone Depleting Potential/Global Warming Potential Refrigerant Gas

APPENDIX A: BEC Field Documentation

APPENDIX B: BEC Photo Documentation

Andrew Hanson Derrick A. Klein

USDA-APHIS PRDA LAB BUILDING 3 HAZARDIOUS MATERIALS SCREEN

Project Site: USDA APHIS PRDA - Lab Building 3

Requester Name: Mr. Jon C. DeLay, P.E., MS EMGT, Senior Project Director

5970 Greenwood Plaza Boulevard, Laboratory Building #3 (hereinafter referred to as Lab Building 3) is located at the Puerto Rico Department of

Agriculture (PRDA) complex, near Dorada in north-central Puerto Rico. Lab Building 3 is approximately 10,000

GSF and consists of two wings, one for administration offices and one for the laboratories; the lab wing was constructed in 1994 as a replacement of a smaller original wing.

USDA APHIS uses about half of the lab wing to support their ongoing diagnostic operations for monitoring the

African Swine Fever outbreaks in Haiti and the Dominican Republic. USDA APHIS use of Lab Building 3 includes two lab rooms, the Necropsy Room shared with PRDA, a storage room, and the Autoclave/Cleaning Room shared

Merrick & Company (Merrick) subcontracted with BEC to conduct a preliminary environmental hazards assessment

(EHA) in support of the overall infrastructure assessment (IA) scope of work, as more fully described in the ‘Statement of Work for PRDA Infrastructure Assessment’ (USDA APHIS, January 7, 2022). The Infrastructure Assessment (IA) statement of work outlined various deficient building conditions and malfunctioning operating systems and the need for major building system improvements, remediation work, mechanical/electrical system upgrades, etc. and requirements to correct those deficient conditions. It is the removal and replacement of existing building components and operating systems that prompted Merrick to subcontract with BEC to conduct preliminary environmental hazards assessment

(EHA) of Lab Building 3.

Merrick/BEC team members visually inspected existing building conditions with PRDA and USDA personnel on

February 8/9, 2022. Meetings occurred to discuss conditions, operational requirements, and possible scopes for repair and/or upgrade. The objective of the preliminary EHA was two-fold: (1) evaluate existing conditions; determine the location and extent of presumptive environmental hazards (i.e., hazardous building construction materials and/or hazardous substances) via technical visual inspection and (2) future disturbance; identify the location and extent of presumptive environmental hazards which will, or could be reasonably anticipated to, undergo disturbance or damage during renovation work activities with the potential to create environmental pollution and/or an unhealthy worker exposure condition.

A follow-up site visit was conducted by Merrick/BEC on January 18/19, 2023 to evaluate existing conditions (and any changes thereto) prior to preparation of Merrick’s response to USDA APHIS Request for Proposal (RFP) entitled

‘Design Services for Puerto Rico Department of Agriculture, Lab Building 3 Renovation and Modernization’ via

Merrick submitted to USDA APHIS the “Building Condition Assessment- Draft, Dept. of Agriculture, Puerto Rico –

Lab Building 3” report on April 11, 2022. Subsequently, Merrick submitted to USDA APHIS the “Feasibility Study-

Draft, Dept. of Agriculture, Puerto Rico – Lab Building 3” report on May 18, 2022. The former report contained our preliminary EHA findings, which detailed the presence of the following presumptive adverse hazardous building construction materials and conditions observed during the February 8/9, 2022 site visit: visible mold growth; asbestos-containing building materials (ACBMs); lead-based paint/paint with lead (LBP/PWL); polychlorinated biphenyl-containing compounds (PCBs) within fluorescent electrical lighting fixtures’ ballast; mercury-containing lamps;

mercury-containing plumbing P-traps; ozone depleting potential/global warming potential (ODP/GWP) refrigerant gas.

The latter report investigated the impact of the presumptive adverse environmental conditions, as detailed in our preliminary EHA report, to three (3) proposed levels of renovation and associated costs.

BEC was subcontracted on April 12, 2023 by Merrick to support the scope of work detailed in the ‘Statement of Work for Architectural & Engineering Services’ (USDA APHIS, November 28, 2022). The following tasks were included in the subcontracted services:

• A-E Abatement Design Services- (i) technical visual inspections and/or physical sampling with laboratory analysis to rebut or confirm the presence of presumptive EHAs, as observed during the February 8/9, 2022 and

January 18/19, 2023 site visits. These inspections/sampling protocols are statutorily required by Federal environmental pollution and worker protection laws applicable to renovation and demolition construction projects. (ii) prepare abatement/remediation specifications to address all environmental hazards definitively confirmed to exist at Lab Building 3.

Hazardous Materials Screen

This report addresses the findings of technical visual inspections for the following hazardous materials:

polychlorinated biphenyl compounds (PCBs)-containing dielectric fluid storage vessels (e.g., contact switches, electrical lighting fixtures’ ballast, etc.); mercury-containing fluorescent light tubes (lamps); and refrigerant gas containing ozone depleting potential/global warming potential (ODP/GWP) compounds, as previously observed within Laboratory Building 3 and/or discovered during the most recent site visit.. These hazardous materials require proper removal and disposal prior to or during the renovation of the structure.

BEC received authorization from Jon C. DeLay, Senior Project Director with Merrick, to mobilize to the project site during the week of June 5, 2023. It is relevant to note, the hazardous materials survey was limited to visual inspections of readily-accessible materials and did not include exploratory demolition of enclosed construction conditions.

Therefore, BEC makes no references or representations regarding the presence or absence of hazardous materials potentially present at inaccessible building construction conditions and/or not included in this scope of work.

BOGGS ENVIRONMENTAL CONSULTANTS, INC. (BEC) conducted a hazardous materials screen within

Laboratory Building 3 of the Puerto Rico Department of Agriculture (PRDA) facility located in Dorado, Puerto

Rico on June 6, 2023.

BEC conducted interviews with Dr. Alejandro E Perez Ramirez, Assistant Director of Veterinary Services and

Livestock Health, to become familiar with the building history and the limits of the screen, prior to proceeding with the field work activities.

BEC notes, only readily accessible materials at the subject site were inspected during the course of this hazardous materials screen. BEC cautions that additional hazardous materials (eg, laboratory reagents/processing chemicals, laboratory biohazards, etc.) may exist outside this scope of work and were not inventoried during the conduct of this screen.

BEC staff members, Andrew L. Hanson and Derrick A. Klein, surveyed the subject site for the presence of PCB-containing storage vessels, mercury-containing fluorescent lamps, and ODP/GWP-containing refrigerant substances on

June 6, 2023

2.2 Polychlorinated-Biphenyl Containing Materials

Polychlorinated-Biphenyls, or PCBs, were extensively used prior to 1979 as dielectric and coolant fluids in electrical equipment, such as capacitors, transformers, and motors. The environmental toxicity and classification of PCBs as a persistent organic pollutant resulted in a ban on their production by the United States Congress in 1979.

US EPA required manufacturers of electrical fluorescent lighting fixture ballast, built between July 1, 1978 and July 1, 1998, to mark the ballasts that do not contain PCBs with the statement “No PCBs”. BEC advises electrical lighting fixtures’ ballast which are missing labels, or not labeled as “Non-PCB Containing” are statutorily presumed to contain

PCBs.

Investigative Protocol

BEC conducted a visual inspection for the presence of PCBs-containing dielectric fluid storage vessels (e.g., transformers, contact switches, etc.) and electrical lighting fixtures’ ballast located within Laboratory Building #3. The electrical fluorescent lighting fixtures were inspected and inventoried on ‘room by room’ basis. Thereafter, BEC disassembled ten percent (10%) of each unique group of electrical lighting fixtures to visually inspect the transformers for statutorily required ‘No PCBs’ inscription. BEC photographed each typical model/type of ballast encountered, which included manufacturer’s information.

Visual Inspection Findings

Technical visual inspection of both the Administration and Laboratory building sections revealed all electrical fluorescent lighting fixtures were equipped with either electronic control starters or were equipped with starter ballast inscribed with “No PCBs”.

Additionally, BEC did not observe any labeled or presumed PCB containing dielectric and coolant fluids in electrical equipment, such as capacitors, transformers, and motors, in the conduct of the visual inspections.

2.3 Mercury Containing Fluorescent Lights

Fluorescent lamps or fluorescent tubes are low-pressure mercury-vapor gas-discharge lamp that use fluorescence to produce visible light. An electric current in the gas excites mercury vapor which produces short-wave ultraviolet light that then causes a phosphor coating on the inside of the bulb to glow.

The average mercury content of a 4-foot-long bulb manufactured today is approximately 12 mg. Bulbs manufactured in the mid-1980s and earlier contained 40 mg or more. Low-mercury bulbs, containing 4 mg or less, are currently produced by at least one manufacturer. A typical fluorescent bulb discarded today is likely to contain an average of approximately 20 mg mercury

According to the US EPA, hazardous fluorescent bulbs and lamps can be managed under full Resource Conservation

Recovery Act (RCRA) hazardous waste regulations, or they can be managed under the RCRA’s Universal Waste Rule

(UWR), which is less stringent than hazardous waste regulations.

BEC conducted a survey for the presence of mercury-containing fluorescent light tubes (or lamps) located within

Laboratory Building #3 on a ‘room by room’ basis. BEC removed a representative number of lamps from their electrical lighting fixtures (~10%) and inspected for manufacturer’s identification numbers (mercury labeling) and/or cross-referenced manufacturer’s product technical data sheets (TDS) to determine mercury content. BEC photographed typical fluorescent lamps observed, of which depict manufacturer’s information and shape/dimensions of light tubes.

2.3 Mercury Containing Fluorescent Lights (continued)

Technical visual inspection of both the Administration and Laboratory building sections revealed mercury-containing fluorescent lamps were present. Note: stockpiles of ‘spent’ (defective) lamps remain in-place, as observed during the

February 2022 site visit. The mercury-containing lamps count increased from the 398 lamps inventoried during the

February 2022 site visit, to 447 lamps inventoried during the June 6, 2023 site visit.

BEC advises, during the course of the screen, fluorescent lamps were identified, throughout the subject site, which were labeled by their manufacturer as containing low-pressure mercury and internal phosphor-coating.