140P2022R0036-0009_Att01b-Q39_HazMatTestingReport_211119_0009.pdf

Ellis Island Main Immigration Building Exterior Rehabilitation

Beyer Blinder Belle Architects & Planners

Hazardous Materials Testing Report Prepared by Mabbett & Associates, Inc.

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HAZARDOUS MATERIALS SURVEY REPORT

Ellis Island Main Immigration Building Exterior Systems Rehabilitation

Ellis Island National Museum New York, NY

Mabbett Project No. R2021044.000

November 19, 2021

Prepared for:

Beyer Blinder Bell Architects & Planners, LLP 120 Broadway, 20th Floor New York, NY 10271

Mabbett & Associates, Inc. www.mabbett.com 105 Central Street, Suite 4100 Stoneham, MA 02180-1260 T. 781-275-6050 F: 781-954-5155 Massachusetts | Virginia | Rhode Island | New York

© 2021, Mabbett & Associates, Inc.

Ellis Island Main Immigration Building Exterior Systems Rehabilitation ǀ New York, NY

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ACKNOWLEDGEMENT

This Hazardous Materials Survey Report has been prepared by Mabbett & Associates, Inc. (Mabbett®) for the design services to rehabilitate exterior components of the Main Immigration Building on Ellis Island, New York, NY, including exterior window finishes, exterior re-pointing, replacing deteriorated clerestory windows, and replacing failing skylights. The information presented herein is based on the facts and information conveyed to or received by Mabbett during the preparation of this report. If any of the information provided to Mabbett that was used in preparing this report is incorrect, incomplete, or subject to change, Mabbett would wish to alter its opinion(s) accordingly. In addition, the professional opinions and information contained in this report are based solely on the requirements of the applicable regulations and technical data as known to Mabbett as of the date of this report and considered applicable to this report.

The attached Hazardous Materials Survey Report was prepared by Mr. Kevin Donovan, Sr. Environmental, Health & Safety Specialist of Mabbett & Associates, Inc.

This report has been reviewed and approved by:

Michael F. Delaney Director, Building Sciences Group

MFD/rsg

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TABLE OF CONTENTS

SECTION PAGE

1.0 INTRODUCTION

1.1 Site Description

2.0 ASBESTOS SURVEY

2.1 Sampling Methodology

2.2 Analytical Methodology

2.3 Summary of Asbestos Containing Materials Findings

3.0 LEAD CONTAINING PAINT SAMPLING

4.0 CONCLUSIONS AND RECOMMENDATIONS

4.1 Asbestos

4.2 Lead Containing Paint

5.0 LIMITATIONS

TABLES

TABLE 1 – Summary of Identified ACM (in text) TABLE 2 - Summary of Lead Paint Chip Analytical Results (in text)

FIGURES

RBM-1 - Asbestos and Pb Sampling Location Plan, West Elevation RBM-2 - Asbestos and Pb Sampling Location Plan, North and South Elevations RBM-3 - Asbestos and Pb Sampling Location Plan, East Elevation RBM-4 - Asbestos and Pb Sampling Location Plan, North and South Clerestory Elevations RBM-5 - Asbestos and Pb Sampling Location Plan, Roof Plan

APPENDICES

APPENDIX A – Summary of ACM Survey Results, Including Negative Results APPENDIX B – PLM & TEM Laboratory Report and Chain of Custody APPENDIX C – Lead Paint Chip Laboratory Report and Chain of Custody APPENDIX D – Representative Photographs of ACM

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1.0 INTRODUCTION

Mabbett and Associates, Inc. (Mabbett®) performed a survey for hazardous materials as part of the design services to rehabilitate exterior components of the Main Immigration Building on Ellis Island, in accordance with the established scope of work for National Park service (NPS) project STLI 312431. Site survey work was performed by appropriately credentialed regulated building materials inspectors, and consisted of the following activities:

A review of the existing project documents;

An Asbestos Containing Material (ACM) survey of suspect materials (Analysis by Polarized Light Microscopy

[PLM] and Transmission Electron Microscopy [TEM]); and Limited Lead Containing Paint (LCP) sampling (Analysis by atomic absorption [AA]).

The survey was limited to the exterior façade, windows, skylight, and roof areas that might be disturbed by the proposed renovation. Areas and materials outside of this scope of work were not surveyed by Mabbett.

1.1 Site Description

The Main Immigration Building is a three-story structure and was opened in 1900. It is a rectangular steel framed masonry building with a facade of red brick and limestone trim. It has four masonry towers and terra cotta and rubber membrane roof systems. The east and west wings are partly enclosed by glass skylights at the roof which date back to the 1980’s.

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2.0 ASBESTOS SURVEY

On August 16 and September 29, 2021, visual screening and surveying activities at the Main Immigration Building at Ellis Island were conducted by Mabbett personnel to determine locations and areas of concern for regulated materials, including ACM and LCP. Only areas that were accessible during the field work phase were inspected, with reasonable efforts made both during the initial site visit and the subsequent site survey to access and document areas and materials as necessary to complete the asbestos survey and sampling program.

2.1 Sampling Methodology

Site inspection work and sampling was performed on September 29, 2021, by EPA trained and accredited asbestos inspectors Mr. Kevin Donovan and Mr. Dominic Fiore. Bulk asbestos samples were collected using EPA National Emissions Standards for Hazardous Air Pollutants (NESHAP), 40 CFR Part 763, and Asbestos Hazard Emergency Response Act (AHERA) protocols. The inspection was limited to areas that may be impacted by the proposed exterior rehabilitation project. Bulk suspect ACM sampling was generally conducted according to the following sampling protocol:

Miscellaneous materials:

• At least two bulk samples shall be collected from each homogeneous area that is less than 100 ft2.

• At least three bulk samples shall be collected from each homogeneous area that is greater than 100 ft2.

2.2 Analytical Methodology

The collected bulk samples were submitted under chain of custody (COC) procedures to AmeriSci of New York, NY for PLM and TEM analysis as required by the New York State Environmental Laboratory Approval Program (ELAP).

PLM analysis of friable materials was performed using NYS ELAP Method 198.1. Samples of Non-Friable Organically Bound (NOB) materials were analyzed by PLM (NYS ELAP Method 198.6) subsequent to matrix reduction. NOB samples that were identified as non-ACM by PLM methods were re-analyzed by TEM (NYS ELAP Method 198.4) for confirmation purposes. AmeriSci is accredited by the American Industrial Hygiene Association (AIHA) and participates in the National Voluntary Laboratory Accreditation Program (NVLAP).

Bulk sample results from this inspection are summarized in Appendix A, Summary of ACM Survey Results. The EPA, Occupational Safety and Health Administration (OSHA), and Part 56 of Title 12 of the Official Compilation of Codes, Rules and Regulations of the State of New York (12 NYCRR Part 56) defines any material that contains greater than one percent (>1%) asbestos as being an ACM. As such, the analytical laboratory identified bulk samples as positive for asbestos that met the regulatory criteria of greater than one percent (>1%) asbestos.

Laboratory reports and COC documentation are provided in Appendix B of this report.

2.3 Summary of Asbestos Containing Materials Findings

Mabbett collected eighty-one (81) representative bulk ACM samples. Bulk sampling locations and results are identified on Figures RBM-1, RBM-2 RBM-3, RBM-4 and RBM-5. The laboratory reported analytical data indicated that two (2) of the homogenous materials sampled had greater than 1% asbestos and was considered ACM.

Estimated quantities and locations of identified asbestos containing material are presented in Table 1 below:

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TABLE 1

Summary of Identified ACM

Rehabilitate Exterior Systems of Main Immigration Building Ellis Island, Statue of Liberty National Monument, New York

Location Description of Material Percent and Type of Asbestos

Estimated Quantity

Amount Units Front and Rear Flat Roof

Parapet Black Tar Waterproofing on Brick 7.9% Chrysotile 340 SF

Front and Rear Flat Roof at Roof Transition

Remnant Tar Flashing Under Limestone Cap 6.5% Chrysotile 180 SF

Notes: SF = Square Feet

Representative photographs of identified ACM locations are provided in Appendix D.

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3.0 LEAD CONTAINING PAINT SAMPLING

The limited LCP sampling included the collection of paint chips from painted surfaces in the areas surveyed that may be impacted by the planned renovation. Ten (10) samples of different homogenous areas of paint were collected during this survey. Paint chip samples were submitted under standard COC procedures to ProScience Analytical Services Inc. of Woburn, Massachusetts. Analysis was conducted using EPA Method SW846 7000B/3051: Flame Atomic Absorption Spectrophotometry.

The results of the limited LCP sampling are summarized in Table 2, with laboratory reports provided in Appendix C.

TABLE 2

Summary of Lead Paint Chip Analytical Results

Rehabilitate Exterior Systems of Main Immigration Building Ellis Island, Statue of Liberty National Monument, New York

Sample No. Location Substrate and Component Color

Result (% Pb by Weight)

Pb-01 Main Entrance Exterior Metal Window Light Green 13.9 Pb-02 Roof - Rear Section Wood Window Light Green 0.03 Pb-03 Roof Stairwell Wood Door Green 0.25 Pb-04 Roof Stairwell Wood Door Frame Light Green 1.7 Pb-05 Roof-Front Side Wood Windows Light Green 0.37 Pb-06 Roof-Front Stairwell Wood Door Green 0.19 Pb-07 Roof-Front Stairwell Wood Door Frame Light Green 1.19 Pb-08 Roof-Front Section Metal Wall Grate Green 20.3 Pb-09 Roof Front Stairwell Wood Circular Window Green 0.65

Pb-10 3rd Floor Bob Hope Library (West side) Wood Window Frame Green <RL

Notes: RL = Laboratory Reporting Limit

The Occupational Safety & Health Administration (OSHA) does not recognize a “safe” level of lead in paint.

Depending on the method of removal used, even trace amounts of lead in paint may result in airborne concentrations of lead during removal. An employer or contractor who disturbs or removes lead paint must comply with OSHA Standard 29 CFR 1926.62, “Lead Exposure in Construction; Interim Final Rule.”

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4.0 CONCLUSIONS AND RECOMMENDATIONS

4.1 Asbestos

Roof tar/waterproofing materials were determined to be ACM. If planned work will disturb the identified ACM, the material must be abated and properly disposed of by state licensed and properly trained contractors.

Abatement must be performed in accordance with federal, state, and local requirements. Any suspect materials encountered during demolition or renovation activities that were not identified in this report as being non-ACM, should be assumed to be ACM unless sample results prove otherwise.

4.2 Lead Containing Paint

The purpose of the limited LCP survey was to identify similar areas of LCP. During the on-site survey, representative samples of similar areas of exterior coatings were collected and analyzed for lead content. The regulations addressing LCP in non-residential buildings are focused on occupational exposures involved with paint-disturbing activities and related waste-disposal activities.

Occupational exposure to lead during construction is regulated by OSHA regulation 29 CFR 1926.62 “Lead in Construction,” as well as other applicable state and local regulations. These regulations involve air monitoring to determine worker exposure levels when disturbing paint containing measurable levels of lead. This LCP survey cannot determine a safe level of lead for the purpose of paint-disturbing activities. However, this report is intended to provide guidance as to the location of LCP so it can be controlled, abated, or disposed of properly during this project’s construction related activities. Information gathered during this LCP survey should be used to determine where worker exposures to airborne lead may occur. Additionally, this information should also be used to assess the potential for exposure to workers, and for determining appropriate controls necessary to limit his or her health risks during this project.

A concentration of lead greater than or equal to 0.5 percent by weight or 1.0 mg/cm2 exceeds EPA and HUD residential standards and is considered an indicator of risk. Representative samples of LCP waste to be generated during building renovation, or following demolition but prior to disposal, should be collected and analyzed using toxicity characteristic leaching procedure (TCLP) in accordance with 40 CFR Part 261. Management and disposal of lead containing waste must be done in accordance with all applicable local, state, and federal regulations.

OSHA regulations may require certain procedures for any paint that contains lead, even if it is below these levels.

All LCP identified, regardless of the lead content, should either be sampled and analyzed by TCLP and then handled/disposed of accordingly, or segregated from other large-scale debris and then managed as hazardous waste in accordance with federal, state, and local hazardous waste disposal regulations.

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5.0 LIMITATIONS

This survey report is the result of an inspection for regulated materials of the designated areas and materials that may be impacted by the renovation project. Inaccessible areas were not included in this survey. Although a comprehensive inspection of these areas was performed, Mabbett does not claim to have identified all hazardous materials that could be present in the facility (for example, materials potentially located within the inaccessible areas). Mabbett has conducted this assessment with reasonable care and has performed this project in accordance with generally accepted industry standards. There can be no assurances, and Mabbett makes no assurances, that the information, research, and technology used to prepare this report may not change in the future, thus affecting the results reported herein.

© 2021, Mabbett & Associates, Inc. FIGURES November 19, 2021 Project No. R2021044.000 Ellis Island Hazardous Materials Survey Rev 1- Final

FIGURES

LEGEND

02A*

02A**

02A

02A

(Pb-01)

WEST ELEVATION

REGULATED BUILDING MATERIAL

SURVEY PLAN

APPROXIMATE ASBESTOS SAMPLE LOCATION

SAMPLE POSITIVE FOR ASBESTOS STOP

POSITIVE SAMPLE FOR ASBESTOS NO

ASBESTOS DETECTED (NAD) APPROXIMATE

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12B

26C, 27C

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LEAD SAMPLE LOCATION

26B, 27B

12A

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(Pb-02)

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01A, 02A

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