1614696spc15of19_APP-C.pdf

APPENDIX - C

HAZARDOUS MATERIALS

SURVEY REPORT

FY21 MCON PROJECT P-095

REPLACE SUBMARINE PIER 3

NAVAL STATION NORFOLK, NORFOLK, VA

eProjects Work Order No. 1614696 A-E Contract No. N40085-18-D-1100

Delivery Order N40085-19-F-4195

Prepared For:

Hazardous Material Inspection Report Piers 3 and 3T, Buildings CEP77 and CEP199, and

Bulkheads CEP102 and CEP176 Naval Station Norfolk, VA

March 2019

Environmental Consultants

FY21 MILCON PROJECT P-095

This page left blank intentionally

HAZARDOUS MATERIAL INSPECTION

REPORT

Piers 3 and 3T, Buildings CEP77 and CEP199, and Bulkheads CEP102 and

CEP176

Naval Station Norfolk Norfolk, VA

Prepared For:

NAVFAC Mid-Atlantic and

Moffatt & Nichol

FY21 MILCON Project P-095 Contract No. N40085-18-D-1100 Task Order No. N4008518F4639 AH Project Number: 130-06

FINAL

March 2019

AH Environmental Consultants, Inc.

11837 Rock Landing Drive, Suite 300

Newport News, VA 23606 757.873.4959 solutions@ahenv.com

NSN PIER 3 DEMOLITION TABLE OF CONTENTS

AH Environmental Consultants i March 2019 130-06/ P095

EXECUTIVE SUMMARY ........................................................................................ iii

1. ASBESTOS .......................................................................................... 1-1

1.1 ASBESTOS INSPECTIONS .......................................................................... 1-3

1.1.1 Pier 3 Samples............................................................................ 1-3

1.1.2 CEP77 Samples .......................................................................... 1-4

1.1.3 CEP199 Samples ........................................................................ 1-5

1.1.4 CEP102/ CEP176 Samples......................................................... 1-6

1.2 RECOMMENDATIONS ................................................................................. 1-7

1.3 CERTIFICATION ........................................................................................ 1-7

2. LEAD .................................................................................................... 2-1

2.1 SAMPLING ................................................................................................ 2-2

2.2 RANGES OF METALS ................................................................................. 2-2

2.3 RESULTS ................................................................................................. 2-3

2.3.1 Pier 3 Paint Testing ..................................................................... 2-3

2.3.2 Pier 3T Paint Testing................................................................... 2-5

2.3.3 Bulkhead Paint Testing ............................................................... 2-6

2.4 COMMENTS/RECOMMENDATIONS .............................................................. 2-7

2.5 CERTIFICATION ........................................................................................ 2-9

3. OTHER HAZARDS ............................................................................... 3-1

3.1 MERCURY ................................................................................................ 3-1

3.1.1 Mercury Lamps ........................................................................... 3-2

3.1.2 Mercury Switch Inspection .......................................................... 3-2

3.2 PCBS ...................................................................................................... 3-2

3.3 SOILS ...................................................................................................... 3-3

3.4 OTHER ITEMS OF NOTE............................................................................. 3-3

3.5 RECOMMENDATIONS ................................................................................. 3-4

AH Environmental Consultants ii March 2019

TABLES

TABLE PAGE

Table 1-1 Pier 3 Asbestos Summary .................................................................... 1-4 Table 1-2 P3/ CEP77 Asbestos Summary ............................................................ 1-5 Table 1-3 P3T/ CEP199 Asbestos Summary ........................................................ 1-6 Table 1-4 CEP102/ West Bulkhead Asbestos Summary ...................................... 1-6 Table 2-1 Pier 3 Paint Samples ............................................................................ 2-4 Table 2-2 Pier 3T Paint Samples .......................................................................... 2-5 Table 2-3 Bulkhead Paint Samples ....................................................................... 2-6

APPENDICES

A. HAZMAT Inspection Drawings

B. Photo Log

C. Lab Reports of Analysis

D. Abatement Specifications

AH Environmental Consultants ii March 2019

TABLES

TABLE PAGE

Table 1-1 Pier 3 Asbestos Summary ................................................................... 1-4 Table 1-2 P3/ CEP77 Asbestos Summary ........................................................... 1-5 Table 1-3 P3T/ CEP199 Asbestos Summary ....................................................... 1-6 Table 1-4 CEP102/ West Bulkhead Asbestos Summary ...................................... 1-6 Table 2-1 Pier 3 Paint Samples ........................................................................... 2-4 Table 2-2 Pier 3T Paint Samples ......................................................................... 2-5 Table 2-3 Bulkhead Paint Samples ...................................................................... 2-6

APPENDICES

A. HAZMAT Inspection Drawings

B. Photo Log

C. Lab Reports of Analysis

NSN PIER 3 DEMOLITION EXECUTIVE SUMMARY

AH Environmental Consultants iii March 2019

EXECUTIVE SUMMARY

AH Environmental Consultants (AH) has prepared this Hazardous Material Inspection

Report for the use of the Naval Facility Engineering Command (NAVFAC) Mid-

Atlantic and Moffatt and Nichol (MN) engineers to provide information concerning asbestos containing materials, paints containing hazardous metals, or other recognized hazardous materials (HAZMAT) identified at Naval Station Norfolk (NSN) structures that may be impacted by work associated with the planned demolition and renovation of Pier 3 and 3T and bulkheads CEP102 and CEP176.

This site inspection and assessment was conducted by AH staff and involved sampling of suspect asbestos containing materials (ACM), testing of paint/coatings, investigation for other potentially hazardous materials (OPHM) anticipated to be impacted by the proposed work.

The primary HAZMAT concern for planned work activities appears to be paint coatings of some components that contain barium, chromium, and/or lead in good to fair condition. The precise means and methods to handle the identified hazardous materials are covered under project specifications separate from this document. This inspection cannot verify nor attest to components not accessible (e.g. encased in concrete or presently underneath piers).

Inspections at the facility were conducted 29-31 January 2019 and included identification, sampling and analysis, evaluation of paint coatings and suspect ACM, and inventory of OPHM that could impact planned work actions. Work included all components of the main pier and bulkhead structures and guard houses.

Asbestos inspection information is provided in Section 1. Lead inspection information is provided in Section 2. Section 3 contains information pertaining to additional

HAZMAT issues.

NSN PIER 3 DEMOLITION EXECUTIVE SUMMARY

AH Environmental Consultants iv March 2019

Site drawings indicating sample locations and information concerning the location of

HAZMAT are provided in Appendix A, photos (as permitted) in Appendix B, and the laboratory reports of analysis for all samples collected are provided in Appendix C. It should be noted that photography was permitted in very limited circumstances at this location.

HAZARDOUS MATERIAL INSPECTION SECTION 1

NSN PIER 3 DEMOLITION ASBESTOS

AH Environmental Consultants 1-1 March 2019

1. ASBESTOS

There is a well-known link between the inhalation of asbestos fibers and various diseases such as asbestosis, mesothelioma, lung and other cancers. As a result, the

Asbestos Hazard Emergency Response Act (AHERA, 40 CFR Part 763) was enacted. An AHERA inspection requires an accredited inspector to visually inspect and assess the condition of all known or assumed friable asbestos-containing building materials (ACM); to visually inspect non-friable ACM and touch it to determine friability; and to identify homogeneous areas of friable materials. The

National Emission Standards for Hazardous Air Pollutants (NESHAPs) require thorough inspections for asbestos in structures before renovation or demolition.

The intent of the inspection was to provide sufficient information to involved parties that may impact the renovations of project buildings and to prepare adequate abatement specifications for such. Bulk sampling of suspect ACM was performed.

Samples were analyzed utilizing Polarized Light Microscopy (PLM) with dispersion staining (EPA method 600/M4/82/020). The accredited laboratory reports of analysis are provided in Appendix B.

The sample identification system of this report consists of a three-unit sample identification number. The first set of digits indicates the location designation, the next set indicates the homogenous material grouping for the building, and the last two numbers indicate the consecutive sample number as collected in the field. For example, 44-01-03 would indicate that the sample was collected from location 44, homogenous area one, and was the third sample collected [of that homogenous material] during the inspection. These sample numbers match the chain-of-custody, lab reports of analysis, and sample identification numbers on the drawings (Appendix

A). No historical sample data was provided or referenced for this project.

Sample result summaries are provided in table format. Note that NAD in the % asbestos column indicates that there was No Asbestos Detected in the sample.

AH Environmental Consultants 1-2 March 2019

Some sample results in this column may be displayed in this report with a slash between two numbers, (#/#). The first number represents the first material listed under the material location/description and the second number represents the second material listed. Sampled materials that contain asbestos are highlighted in bold red and underlined.

The samples are also grouped into homogeneous material/area groups.

Homogeneous materials are suspect materials that are uniform by color, texture, construction/application date and general appearance. Photos of ACM could not be provided for site security reasons.

Sample summary tables also distinguish whether materials are considered friable

(able to be crushed or pulverized by hand pressure) or non-friable (not able to be crushed or pulverized by hand pressure) for the purpose of determining the ACM category. The collected samples were at least one cubic centimeter and were placed in a sealed container at the time of collection. Appropriate precautions were taken to prevent exposure to those present in or around the facility during the collection of samples, including wet collection methods.

As previously mentioned, the asbestos NESHAP (40 CFR 61, subpart M) requires a thorough inspection for asbestos in structures before the renovation or demolition of those structures. Materials determined to be ACM (containing greater than one percent asbestos) must also be categorized for removal and demolition purposes.

The various categories for ACM are shown in the following chart.

AH Environmental Consultants 1-3 March 2019

ACM Category (NESHAP)

Categories Typical Material

Type Guidance for RACM

Friable ACM Pipe insulation fittings

Able to crush with hand pressure

Cat I, Non-friable

Floor coverings, Roofing products, Gaskets

Non-friable materials that have become friable, or Non-friable material that is or will be damaged due to sanding, grinding, cutting, or abrading

Cat II, Non-friable

Cement siding (Transite), Significantly damaged tile

Non-friable material that has a high probability of becoming or has become friable by forces expected to act on the material in the course of renovation or demolition

Any ACM that is Friable, or Category I and II Non-friable that meets the qualifications to be considered a Regulated Asbestos-Containing Material (RACM), must be removed prior to demolition or disturbance that would break up, dislodge, or similarly destroy the material or preclude access to the material for subsequent removal. This includes gasket materials.

The findings of the asbestos inspections are detailed in the following section, including recommendations for action.

1.1 ASBESTOS INSPECTIONS

The inspections were conducted for demolition required for future capital improvements of the site. A visual survey was performed of accessible suspect ACM identified at Pier 3, CEP77 (Pier 3 guard shack), Pier 3T, CEP199 (Pier 3T guard shack), CEP102 (West Bulkhead), and CEP176 (North Bulkhead).

1.1.1 Pier 3 Samples

Inspections of Pier 3occurred on 29 January 2019. The construction date of Pier 3 is not known, but estimated 1980s and is substantially concrete. There various utilities, steam supply, and other various supporting components running along the pier.

AH Environmental Consultants 1-4 March 2019

No known previous comprehensive inspection was conducted and no official supporting documentation was provided. The guard shack is discussed independently.

The current asbestos survey identified three (3) homogenous suspect materials including:

Cloth lagging material

Tar sealant material

Non-skid surface coating

Bulk sampling was performed on the suspect ACM found in the survey area. Three

(3) samples were collected that included three (3) individual layers for analysis. A summary of sample results, current and previous, are provided in Table 1-1. Graphic depiction of ACM locations are shown on drawings (Appendix A). No asbestos containing materials (ACM) were identified.

Table 1-1 Pier 3 Asbestos Summary

Sample # Description [location] Asbestos

Friable?

P3-01-01 Cloth lagging on SS line NAD N/A

P3-02-01 Tar sealant, black NAD N/A

P3-03-01 Black non-skid NAD N/A

1.1.2 CEP77 Samples

Inspection of the Pier 3 guard shack [designated CEP77] was conducted 29 January

2019. No records of a previous inspection were provided. The current asbestos survey identified eight (8) homogenous suspect materials. The homogenous materials identified during the inspection included:

Drywall and joint compounds

Caulking

Vinyl sheet flooring

12” Beige floor tile and adhesive

Roofing materials

AH Environmental Consultants 1-5 March 2019

Bulk sampling was performed on the suspect ACM found in the survey area. Ten

(10) samples were collected which included fourteen (14) layers for analysis. A summary of sample results, current and previous, are provided in Table 1-2.

Table 1-2 P3/ CEP77 Asbestos Summary

Sample # Description [location] Asbestos

Friable

P3/CEP77-04-01

P3/CEP77-04-02

Drywall, soffit Drywall, soffit

NAD N/A

P3/CEP77-05-01 Caulking, brown, window (exterior) NAD N/A P3/CEP77-06-01 Caulking, white, window (interior) NAD N/A

P3/CEP77-07-01

P3/CEP77-07-02

Drywall and joint material, ceiling Joint material, soffit

NAD N/A

P3/CEP77-08-01 Vinyl sheet flooring, brown NAD N/A P3/CEP77-09-01 12” Beige tile and adhesive (under HM08) NAD N/A P3/CEP77-10-01 Rolled roofing and tar NAD N/A P3/CEP77-11-01 Roof sealant, gray NAD N/A

1.1.3 CEP199 Samples

Inspection of the Pier 3T guard house structure (CEP199) was conducted on 30

January 2019. The current asbestos survey identified six (6) homogenous suspect materials. The homogenous materials identified during the inspection include:

Drywall and joint material

Caulking

12” Blue w/white floor tile and adhesive

4” Black vinyl base and adhesive

Rolled roofing and tar

Tar sealant

Bulk sampling was performed on the suspect ACM found in the survey area. Eight

(8) samples were collected which included fourteen (14) layers for analysis. A summary of sample results, current and previous, are provided in Table 1-3.

AH Environmental Consultants 1-6 March 2019

Table 1-3 P3T/ CEP199 Asbestos Summary

Sample # Description [location] Asbestos

Friable

CEP199-01-01

CEP199-01-02

CEP199-01-03

Drywall and joint material, ext. soffit Drywall and joint material, int. ceiling Drywall and joint material, int. ceiling

NAD N/A

CEP199-02-01 Caulking, white, plug NAD N/A

CEP199-03-01 12” Blue w/white tile and adhesive NAD N/A

CEP199-04-01 4” Black vinyl base and adhesive NAD N/A

CEP199-05-01 Asphalt rolled roofing and tar NAD N/A

1.1.4 CEP102/ CEP176 Samples

Inspection of the west and north bulkhead areas (CEP102 and CEP176) was conducted on 29 and 30 January 2019. The current asbestos survey identified seven

(7) homogenous suspect materials. The homogenous materials identified during the inspection include:

Pipe insulation

Fiberglass sealant

Caulking

Expansion joint material

Bulk sampling was performed on the suspect ACM found in the survey area. Eight

(8) samples were collected which included eight (8) layers for analysis. A summary of sample results, current and previous, are provided in Table 1-4.

Table 1-4 CEP102/ West Bulkhead Asbestos Summary

Sample # Description [location] Asbestos

Friable

CEP102-01-01 Pipe insulation, 12” NAD N/A

CEP102-02-01 Fiberglass sealant, white/gray NAD N/A

CEP102-03-01

CEP102-03-02

Pipe insulation, 3” Pipe insulation, 3”

NAD N/A

CEP102-04-01 Pipe insulation, pad NAD N/A

CEP102-05-01 Pipe insulation, 24” NAD N/A

CEP102-06-01 Caulking, gray, concrete joints NAD N/A

CEP102-07-01 Expansion joint material, brown NAD N/A

AH Environmental Consultants 1-7 March 2019

1.2 RECOMMENDATIONS

No asbestos containing materials were identified. Note that any building material that is not identified as homogenous with those addressed in this report must be considered as an ACM unless additional testing indicates otherwise. Areas under the pier structures and encased in the bulkheads were not accessible for inspection.

Locations of samples are indicated on the inspection drawings (Appendix A).

Additional inspection information is included in the appendices on the lab reports of analysis chain of custody documents and on building drawings.

1.3 CERTIFICATION

The American Industrial Hygiene Association (AIHA) and National Voluntary

Laboratory Accreditation Program (NVLAP) laboratory selected to analyze the bulk samples for asbestos content by PLM and NIOSH method 7402 methods, equivalent to the "Interim Method for the Determination of Asbestos in Bulk Insulation Samples”

(Appendix A to Subpart F in 40 CFR Part 763) was:

SanAir Technologies Laboratory, Inc.

1551 Oakbridge Dr, Suite B

Powhatan, VA 23139

(804) 897-1177

The EPA-approved and trained inspector and management planner who supervised the project and prepared the inspection report is:

David Dobson, CSM AH Environmental Consultants, Inc.

Newport News, VA 23606

(757) 873-4959

SIGNATURE:

The above-signed inspector certifies information contained within this asbestos inspection report is true and correct concerning site conditions at the time of survey only. Every reasonable attempt was made to identify all ACM. However, locations not accessible such as encased concrete or subgrade locations may contain materials not yet identified.

AH Environmental Consultants 1-8 March 2019

HAZARDOUS MATERIAL INSPECTION SECTION 2

NSN PIER 3 DEMOLITION LEAD

AH Environmental Consultants 2-1 March 2019

2. LEAD

Since 1971, the construction industry has been required to protect workers from exposure to lead through engineering and work practice controls. Since lead-based paint has been determined to be a health threat, assessment of buildings and structures for the presence of lead-based paint is required in order to prevent occupational exposure to personnel or the general public, and to enact appropriate control measures for lead hazards.

OSHA and EPA regulations must be followed when renovation or demolition work affects any lead based paint (LBP) or paints with detectable lead levels referred to as paint containing lead (PCL). Additionally, industrial settings are also known to have potential for Resource Conservation and Recovery Act (RCRA) metals within paints or coatings. Testing included the RCRA metals Barium/ Ba, Cadmium/Cd, Chromium/

Cr, and Lead/Pb, as being likely used in marine grade paints. Samples collected were tested for some or all, dependent on the location and type of coating present.

The preconstruction inspections primary purpose is to identify major building components containing lead in order to properly address the RCRA metals in coatings during renovation or demolition that may be impacted by the proposed work for the purpose of OSHA compliance. The inspection was conducted using the EPA’s work practice standards for conducting lead-based paint activities (40 CFR 745.227) as a guide and all State and local regulations.

Disturbance of paint containing lead or RCRA metals requires special training and initial exposure monitoring at a minimum. Above 0.5% by weight (bulk paint), paint is considered to be lead-based. However, in the interest of safety, lower thresholds are utilized in construction since OSHA regulations are invoked if any lead is present in the paint; there is no minimum concentration level. This standard is also applied to the presence of RCRA metals in paints for the purpose of this report. The following governing standards will apply:

AH Environmental Consultants 2-2 March 2019

OSHA Chromium standards 29 CFR 1910.1026

OSHA Lead standards 29 CFR 1926.62

OSHA Gas, vapor, fume, dust, and mist standards 29 CRF 1926.55

These standards set forth the regulations that apply with regards to construction or renovation of painted materials or structures that contain detectable amounts of lead and/or RCRA metals.

2.1 SAMPLING

Most components tested are believed to contain several layers of paint film and are difficult to interpret. Bulk paint analysis does not differentiate which layer of paint may contain lead or RCRA metals. The results only indicate the amount of heavy metal that is present in the sample. Lead or other RCRA metals are likely to be present at a higher percentage in a particular layer than reported due to averaging the weight of other layers of paint into the calculation. For this reason, OSHA standards apply to any sample with detectable RCRA metals. Construction activities that impact these paints may result in exposure, even though they are not technically considered lead-based or RCRA classified paints.

Results of the lead testing conducted are presented in the following sections.

2.2 RANGES OF METALS

An inspection was performed on painted components to be suspect for the presence of lead or RCRA metals found at the project site, including painted components on

Pier 3, Pier 3T, CEP102, and CEP176. Samples were then taken of a representative number of surfaces, dependent on the quantity of the particular material present.

Although OSHA utilizes the term “any detectable lead”, the amount detectable is relevant in order to determine the potential for exposure. Information is presented in a range format to assist in determining protective measures and special procedures that may be required during renovation/ demolition activities.

The readings were categorized as follows:

AH Environmental Consultants 2-3 March 2019

Lead/RCRA based paint [L] or 0.5% by weight or 5000 ppm lead/ RCRA metals;

Containing elevated lead or RCRA metal levels [E] or 0.499-0.10% or 4999-

1000 ppm lead/ RCRA metals; and

Containing lead or RCRA metals of concern [C] or 0.099-0.050 or 990-50 ppm lead. [OSHA detectable]

Readings below the laboratory Minimum Reporting Level (MRL) or 25 ppm lead were considered insignificant.

2.3 RESULTS

Paint inspections were conducted 29-31 January 2019. A summary of the components tested and determined to contain lead are presented in the following sections. A description of the location, component (including color and substrate) is listed.

The complete results of analysis is presented in Appendix B.

2.3.1 Pier 3 Paint Testing

Bulk paint sampling was conducted of representative coatings throughout the Pier 3 area. Sampling included eleven (11) samples analyzed for Ba, Cd, Cr, and Pb.

Results are shown in the following table. Note: the MRL/ lab detection limit for the

RCRA metals shown is 25.0 micrograms. Results are shown in Table 2-1.

AH Environmental Consultants 2-4 March 2019

Table 2-1 Pier 3 Paint Samples

Sample Description Metal/

Analyte Result in ug/g or ppm

P3-L01 White, metal bollard (010’ N)

Ba 1,324

Cd <25.0

Cr 230

Pb 148

P3-L02 White, concrete curb (275’ N)

Ba 881

Cd <25.0 Cr <25.0 Pb 119

P3-L03 Yellow, metal rail (470’ N)

Ba 165

Cd <25.0

Cr 106

Pb 281

P3-L04 Blue, metal piping (525’ N)

Ba 2,772

Cd <25.0 Cr <25.0 Pb 69

P3-L05 White, metal cleat (1180’ S)

Ba <25.0 Cd <25.0 Cr 276 Pb <25.0

P3-L06 Gray, metal column (1040’ S)

Ba 1,703

Cd <25.0 Cr <25.0 Pb 69

P3-L07 Gold, metal piping (875’ S)

Ba 73

Cd <25.0 Cr <25.0 Pb 844

P3-L08 Black/ white, concrete curb (525’ S)

Ba 4,694

Cd <25.0 Cr <25.0 Pb 198

P3-L09 Yellow/Green, metal railing (315’ S)

Ba 153

Cd <25.0

Cr 186

Pb 536

AH Environmental Consultants 2-5 March 2019

Table 2-2 Pier 3 Paint Samples (continued)

Sample Description Metal/

Analyte Result in ug/g or ppm

P3-L10 Yellow, concrete striping (225’ S)

Ba <25.0 Cd <25.0 Cr 3,663

Pb 10,285

P3-L11 Black/green, metal door (CEP77)

Ba 1,270

Cd <25.0

Cr 58

Pb <25.0

2.3.2 Pier 3T Paint Testing

Bulk paint sampling was conducted of representative coatings throughout the Pier 3T area. Sampling included six (6) samples analyzed for Cd, Cr, and Pb. Results are shown in Table 2-2.

Table 2-2 Pier 3T Paint Samples

Sample Description Metal/

Analyte Result in ug/g or ppm

3T-L01 White, concrete curb

Ba NT

Cd <25.0

Cr <25.0

Pb 57.0

3T-L02 Yellow, concrete markings

Ba NT

Cd <25.0

Cr 2,806

Pb 8,755

3T-L03 Yellow, metal piping

Ba NT

Cd <25.0 Cr <25.0 Pb 50.0

3T-L04 White/ green, metal bollard

Ba NT

Cd <25.0 Cr <25.0 Pb 9,482

AH Environmental Consultants 2-6 March 2019

Table 2-2 Pier 3T Paint Samples (continued)

Sample Description Metal/

Analyte Result in ug/g or ppm

3T-L05 Blue, metal piping

Ba NT

Cd <25.0 Cr <25.0 Pb <25.0

3T-L06 Red, metal pull box (CEP199)

Ba NT

Cd <25.0

Cr 2,959

Pb 11,518

NT = Not Tested

2.3.3 Bulkhead Paint Testing

Bulk paint sampling was conducted of representative coatings throughout the West

Bulkhead (WB= CEP102) and North Bulkhead (NB= CEP176) area. Sampling included eight (8) samples analyzed for Ba, Cd, Cr, and Pb. Results are shown in

Table 2-2.

Table 2-3 Bulkhead Paint Samples

Sample Description Metal/

Analyte Result in ug/g or ppm

WB-L01 White, concrete curb

Ba 716

Cd <25.0

Cr 9,139

Pb 16,403

WB-L02 Yellow, concrete markings

Ba 6,316

Cd <25.0

Cr 137

Pb 406

WB-L03 Yellow, metal piping

Ba <25.0

Cd <25.0

Cr <25.0

Pb <25.0

WB-L04 White/ green, metal bollard

Ba <25.0

Cd <25.0

Cr <25.0

AH Environmental Consultants 2-7 March 2019

Table 2-3 Bulkhead Paint Samples (continued)

Sample Description Metal/

Analyte Result in ug/g or ppm

NB-L05 Yellow, metal piping

Ba <25.0

Cd <25.0

Cr <25.0

Pb <25.0

NB-L06 White/ green, metal bollard

Ba <25.0

Cd <25.0

Cr 65.0

2.4 COMMENTS/RECOMMENDATIONS

Based upon the RCRA metals sampling results, lead, chromium, and barium in paints is present at the site. The present condition of paints is good to fair. The quantities of such coatings that do contain RCRA metals is limited and is the opinion of the inspector that paint hazards are not eminent, but will be a consideration when conducting demolition.

Worker exposure testing would be required during the construction/ demolition activities for areas known to have bulk lead [or RCRA metals] paint and debris. Areas containing loose and peeling paints and may pose additional hazards when disturbed.

Under no circumstances should torch cutting of metals coated with lead since it poses an immediate hazard as heavy metal vapors resulting from the intense heat and are acutely more toxic than airborne particulates.

Occupational exposure to persons conducting disturbance or removal of paint can result in elevated blood lead levels. Lead paint becomes an increased hazard when it deteriorates and oxidizes and/or is present as lead dust. Ingestion and potentially inhalation of resulting dusts may cause lead related health problems.

A toxicity characteristic leachate procedure (TCLP) test was not conducted on bulk structural components of this project since the mass of debris for disposal will substantially be recycled steel and metal components or unpainted materials. Note:

when scrap metal is disposed of at a reclamation facility, the materials are exempt

AH Environmental Consultants 2-8 March 2019 from regulation as a potentially hazardous waste [EPA 40 CFR 261.6 (a)(3)(ii)]. The planned reuse of materials from demolition debris is acceptable in most cases provided the reused materials do not exhibit hazardous characteristics based on

Resource Conservation and Recovery Act (RCRA) guidelines listed in 40 CFR 257.

A TCLP sample will be required for disposal of loose debris and materials destined for a construction/ demolition landfill or reuse. Any debris containing loose paint should be collected, segregated from other debris, and tested for disposal classification.

The following measures are recommended to conduct operations safely during demolition operations.

Remove bulk loose and flaky lead paint [debris] and perform HEPA vacuum and wash of major metal components prior to commencing renovation/ demolition operations.

Recycle all metal components of the waste stream.

TCLP all fill material for adequate documentation of hazard characteristics per

40 CFR 261.

Follow OSHA and EPA regulations when performing construction operations affecting paints containing lead.

Inform facility personnel of the inspection findings.

Conduct personal air monitoring when performing construction work on painted surfaces until a negative exposure assessment can be completed and approved by appropriate personnel.

AH Environmental Consultants 2-9 March 2019

2.5 CERTIFICATION

The AIHA and NVLAP Accredited laboratory selected to analyze the bulk material samples for lead and RCRA metals content, using EPA Methods M3050B/ 6010C/ and 7471B was:

SanAir Technologies Laboratory, Inc.

1551 Oakbridge Dr, Suite B

Powhatan, VA 23139

(804) 897-1177

The EPA-approved and trained inspector who managed the project and prepared the inspection report is:

David Dobson, CSM AH Environmental Consultants, Inc.

Newport News, VA 23606

(757) 873-4959

SIGNATURE:

The above-signed inspectors certify information contained within this inspection report is true and correct concerning site conditions at the time of survey only.

AH Environmental Consultants 2-10 March 2019

HAZARDOUS MATERIAL INSPECTION SECTION 3

NSN PIER 3 DEMOLITION OTHER HAZARDS

AH Environmental Consultants 3-1 March 2019

3. OTHER HAZARDS

In addition to asbestos, lead, various additional issues relevant to the project may be present and should be considered present unless proven otherwise. Other potentially hazardous materials (OPHM) to be aware of during the assessment are described in this section.

Older building and structure demolition creates additional items of concern;

fluorescent lighting fixtures have elemental mercury in the fluorescent bulbs and may also contain polychlorinated biphenyls (PCB) ballasts or high voltage wire sheathing.

Buildings may also contain mercury switches inside of thermostats, lead or other chemical containing batteries, and other materials of special concern. Underground storage tanks (USTs) and area soils are also a special concern. A brief narrative concerning the other hazards to be cognizant of are discussed below.

3.1 MERCURY

Mercury is a toxic elemental metal with unique properties, including being in a liquid state at room temperatures. Human intake of mercury is primarily through oral means. Inhalation of mercury vapor is another source of human exposure. Once absorbed, mercury in all forms is distributed via the blood steam to all tissues in the body. Chronic exposure to mercury primarily affects the central nervous system and kidneys.

Mercury is used in a wide variety of common products including:

Fluorescent and neon lamps, Mercury vapor and high pressure sodium lamps, Switches and relays, Thermostats and regulators, and

Thermometers and manometers.

AH Environmental Consultants 3-2 March 2019

3.1.1 Mercury Lamps

In recent years, the use of fluorescent and high-intensity discharge (HID) lamps has become the standard choice for lighting sources since they can use up to 50 percent less energy than incandescent lighting. However, fluorescent and HID lamps contain mercury and therefore must be properly managed. This includes new “low mercury” lamps. Although low mercury lamps contain approximately one-tenth the amount of mercury as standard lamps, they still must be handled properly.

3.1.2 Mercury Switch Inspection

Areas were inspected for older style thermostats that are likely to contain mercury tilt switches. When an older thermostat was identified, the cover was removed to determine if a mercury-filled glass vial was present. The number and location of each mercury switch identified was noted on the field sketches.

No such old style thermostats containing mercury vial were identified.

3.2 PCBS

Another potential concern associated with structural demolition in industrial or shipyard confines is the presence of PCBs. Inspections included a visual survey.

Fluorescent lighting fixtures have the potential to contain ballasts with PCB capacitors. High voltage wiring is also suspected to contain PCB oil soaked sheathing.

PCBs are synthetic organic chemicals that were produced in the United States from

1929 to 1977. Due to their non-flammability, chemical stability, high boiling point and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications including electrical, heat transfer, and hydraulic equipment;

as plasticizers in paints, plastics and rubber products, in pigments, dyes and carbonless copy paper and many other applications. A major use of PCBs was also in fluorescent light fixture ballasts (in the capacitor).

AH Environmental Consultants 3-3 March 2019

PCBs have been demonstrated to cause a variety of adverse health effects including cancer and a number of serious non-cancer health effects in animals. These effects include damage to the immune system, reproductive system, nervous system, and endocrine system. Studies in humans provide evidence for carcinogenic and non-carcinogenic effects of PCBs. Concern over PCBs in the environment led Congress in 1976 to enact §6(e) of the Toxic Substances Control Act (TSCA) that included among other things, prohibitions on the manufacture, processing, and distribution in commerce of PCBs.

3.3 SOILS

Since demolition and excavation of the area will occur, the issue of soil disturbance is relevant. The site is primarily asphalt or concrete and observations of subgrade materials was not conducted. There is a reported underground storage tank (UST) at the northwest extent of bulkhead CEP176.

Any excavated materials of the general NSN base should always be considered suspect, as various hazardous waste sites have been identified at the location. Fuel distribution lines are also considered likely underground. Soil sampling will be required of material excavated to determine any hazardous constituents present that may require special handling and disposal.

Testing of the soils at the area should include:

Total petroleum hydrocarbons (TPH) as diesel range organics (DRO);

Benzene, Toluene, Ethylbenzene, Xylene (BTEX), volatile organic compounds (VOCs) found in petroleum products;

RCRA metals; and

Verification of any hazardous, toxic, or reactive waste (HTRW) characteristics.

3.4 OTHER ITEMS OF NOTE

Additional OPHM that would require special handling or disposal, includes coal tar pitch (creosote) identified on some wood structure at Pier 3T.

AH Environmental Consultants 3-4 March 2019

3.5 RECOMMENDATIONS

Broken or crushed, fluorescent and HID lamps must be managed as a hazardous waste. The Federal Government and most locales, have adopted disposal regulations for handling fluorescent and HID lamps as a universal waste based upon a “recycling presumption”. Through recycling and proper handling of spent lamps as a universal waste, the burdens and liabilities placed upon disposers are reduced.

The universal waste rule does not authorize disposal of mercury containing lamps in landfills, but has created a cost effective alternative for disposal through recycling.

All fluorescent light tubes (including those deemed low mercury), HID lights, and all ballasts should be packaged intact and sent to an approved recycling facility for disposal/recycling. If older power supply lines are uncovered, testing of coatings should be made to determine the presence of PCBs.

Implementation of a dust control plan is recommended to prevent dusts which may contain hazardous constituents from becoming airborne. Dust control is an integral part of demolition work. A monitoring of crystalline silica dust levels should be conducted during concrete demolition.

Per NAVSTA Norfolk Public Works Department, a fuel tank and pump were added to the CEP176 bulkhead to support Port Security Vessels following the September 11, 2001 terrorist attacks. The pump has been removed, but it is believed that the underground storage tank (UST) remains in place. No documentation is available to provide information with respect to the tank’s size and construction. It is recommended that the tank be removed in accordance with Virginia Department of

Environmental Quality regulation 9VAC25-5800-320 Permanent Closure.

Specification 02 65 00 Underground storage Tanks Removal will be prepared and included in the design.

Properly trained personnel using adequate protective equipment should perform work on-site in the event unforeseen hazards are identified.

HAZARDOUS MATERIAL INSPECTION APPENDIX A

NSN PIER 3 DEMOLITION HAZMAT INSPECTION DRAWINGS

AH Environmental Consultants March 2019

APPENDIX A

HAZMAT Inspection Drawings

HAZARDOUS MATERIAL INSPECTION APPENDIX A

NSN PIER 3 DEMOLITION HAZMAT INSPECTION DRAWINGS

HAZARDOUS MATERIAL INSPECTION APPENDIX B

NSN PIER 3 DEMOLITION PHOTO LOG

APPENDIX B

Photo Log

HAZARDOUS MATERIAL INSPECTION APPENDIX B

NSN PIER 3 DEMOLITION PHOTO LOG

Hazardous Material Inspection

Piers 3 and 3T, CEP77, 102, 176, and 199

Naval Station Norfolk

AH Environmental

Newport News, VA

PAINT: Pier 3T, L04; Lead paint on metal components (typical).

PAINT: CEP102/ West Bulkhead, L01;

High chromium and lead in paints.

PAINT: Pier 3, L08; Elevated Barium in coatings.

PAINT: Pier 3, L10; High chromium and lead in yellow coatings.

OPHM: Pier 3T; coal tar pitch/ creosote present on wood.

OPHM: Fuel pits, underground utilities/ distribution not known.

Hazardous Material Inspection

Piers 3 and 3T, CEP77, 102, 176, and 199

Naval Station Norfolk

AH Environmental

Newport News, VA

OPHM: CEP176, reported location of

UST (abandoned in place).

HAZARDOUS MATERIAL INSPECTION APPENDIX C

NSN PIER 3 DEMOLITION LAB REPORTS

APPENDIX C

Lab Reports

HAZARDOUS MATERIAL INSPECTION APPENDIX C

NSN PIER 3 DEMOLITION LAB REPORTS

Analyst: Vaughan, Nathaniel

Asbestos Bulk PLM EPA 600/R-93/116 Stereoscopic Components

SanAir ID / Description Appearance % Fibrous % Non-fibrous Asbestos Fibers

3-01-01 / 19004649-001 White Fibrous

Homogeneous

95% Glass 5% Other None Detected

3-02-01 / 19004649-002 Black Non-Fibrous

Homogeneous

100% Other None Detected

3-03-01 / 19004649-003 Black Non-Fibrous

Heterogeneous

100% Other None Detected

3-04-01 / 19004649-004 White Non-Fibrous

Homogeneous

5% Glass 95% Other None Detected

3-05-01 / 19004649-005 Brown Non-Fibrous

Homogeneous

100% Other None Detected

3-06-01 / 19004649-006 White Non-Fibrous

Homogeneous

100% Other None Detected

3-07-01 / 19004649-007 , Drywall

White Non-Fibrous

Homogeneous

3% Cellulose 97% Other None Detected

3-07-01 / 19004649-007 , Joint Material

White Non-Fibrous

Heterogeneous

100% Other None Detected

3-08-01 / 19004649-008 , Tile

Brown Non-Fibrous

Homogeneous

100% Other None Detected

3-08-01 / 19004649-008 , Adhesive

Clear Non-Fibrous

Homogeneous

100% Other None Detected

Analyst:

Analysis Date: 2/6/2019 Date: 2/6/2019

Approved Signatory:

AH #130-06 BurnsProject Number:

P.O. Number:

Project Name: Naval Station Norfolk Pier 3

1/29/2019Collected Date:

1/31/2019 10:20:00 AMReceived Date:

2/6/2019 6:05:17 PM

19004649 SanAir ID Number

FINAL REPORT

AH Environmental Consultants, Inc.Name:

Address: 11837 Rock Landing Drive

Suite 300

Newport News, VA 23606

757-873-4959Phone:

Stereoscopic Components

SanAir ID / Description Appearance % Fibrous % Non-fibrous Asbestos Fibers

3-09-01 / 19004649-009 , Tile

Beige Non-Fibrous

Homogeneous

100% Other None Detected

3-09-01 / 19004649-009 , Adhesive

Brown Non-Fibrous

Homogeneous

100% Other None Detected

3-07-02 / 19004649-010 White Non-Fibrous

Homogeneous

100% Other None Detected

3-04-02 / 19004649-011 White Non-Fibrous

Homogeneous

5% Cellulose 2% Glass

93% Other None Detected

3-10-01 / 19004649-012 , Roofing

Black Non-Fibrous

Heterogeneous

100% Other None Detected

3-10-01 / 19004649-012 , Tar

Black Non-Fibrous

Homogeneous

100% Other None Detected

3-11-01 / 19004649-013 Gray Non-Fibrous

Homogeneous

100% Other None Detected

Analyst:

Analysis Date: 2/6/2019 Date: 2/6/2019

Approved Signatory:

1551 Oakbridge Dr. Suite B, Powhatan, VA 23139 | 804.897.1177 | Fax: 804.897.0070 | www.SanAir.com | IAQ@SanAir.com

AH #130-06 BurnsProject Number:

P.O. Number:

Project Name: Naval Station Norfolk Pier 3

1/29/2019Collected Date:

1/31/2019 10:20:00 AMReceived Date:

2/6/2019 6:05:17 PM

19004649 SanAir ID Number

FINAL REPORT

AH Environmental Consultants, Inc.Name:

Address: 11837 Rock Landing Drive

Suite 300

Newport News, VA 23606

Disclaimer

The final report cannot be reproduced, except in full, without written authorization from SanAir.

Fibers smaller than 5 microns cannot be seen with this method due to scope limitations. The accuracy of the results is dependent upon the client’s sampling procedure and information provided to the laboratory by the client. SanAir assumes no responsibility for the sampling procedure and will provide evaluation reports based solely on the sample and information provided by the client. This report may not be used by the client to claim product endorsement by NVLAP or any other agency of the U.S. government. Samples are held for a period of 60 days.

For NY state samples, method EPA 600/M4-82-020 is performed.

Polarized- light microscopy is not consistently reliable in detecting asbestos in floor covering and similar non-friable organically bound materials. Quantitative transmission electron microscopy is currently the only method that can be used to determine if this material can be considered or treated as non-asbestos containing.

Asbestos Certifications NVLAP lab code 200870 City of Philadelphia: ALL-460 PA Department of Environmental Protection Number: 68-05397 California License Number: 2915 Colorado License Number: AL-23143 Connecticut License Number: PH-0105 Massachusetts License Number: AA000222 Maine License Number: LB-0075 New York ELAP lab ID: 11983 Rhode Island License Number: AAL-126 Texas Department of State Health Services License Number: 300440 Commonwealth of Virginia 3333000323 Washington State License Number: C989 West Virginia License Number: LT000566 Vermont License: AL166318

Revision Date: 11/30/2017

Analyst: Marko, Jared

Stereoscopic Components

SanAir ID / Description Appearance % Fibrous % Non-fibrous Asbestos Fibers

WB-01-01 / 19004650-001 Yellow Fibrous

Homogeneous

99% Glass 1% Other None Detected

WB-02-01 / 19004650-002 White Non-Fibrous

Homogeneous

5% Wollastonite 95% Other None Detected

WB-03-01 / 19004650-003 Brown Fibrous

Homogeneous

99% Glass 1% Other None Detected

WB-04-01 / 19004650-004 White Fibrous

Homogeneous

99% Glass 1% Other None Detected

WB-03-02 / 19004650-005 White Fibrous

Homogeneous

99% Glass 1% Other None Detected

WB-05-01 / 19004650-006 Yellow Fibrous

Homogeneous

99% Glass 1% Other None Detected

WB-06-01 / 19004650-007 Gray Non-Fibrous

Homogeneous

100% Other None Detected

WB-07-01 / 19004650-008 Brown Fibrous

Homogeneous

90% Cellulose 10% Other None Detected

Analyst:

Analysis Date: 2/6/2019 Date: 2/6/2019

Approved Signatory:

AH #130-06 BurnsProject Number:

P.O. Number:

Project Name: Naval Station Norfolk Pier 3 West Bulkhead

(WB)

1/29/2019Collected Date:

1/31/2019 10:20:00 AMReceived Date:

2/6/2019 5:52:21 PM

19004650 SanAir ID Number

FINAL REPORT

AH Environmental Consultants, Inc.Name:

Address: 11837 Rock Landing Drive

Suite 300

Newport News, VA 23606

Stereoscopic Components

SanAir ID / Description Appearance % Fibrous % Non-fibrous Asbestos Fibers

CEP199-01-01 / 19004826-001

, Drywall

White Non-Fibrous

Heterogeneous

10% Cellulose 90% Other None Detected

CEP199-01-01 / 19004826-001

, Joint Material

White Non-Fibrous

Heterogeneous

100% Other None Detected

CEP199-02-01 / 19004826-002 White Non-Fibrous

Heterogeneous

100% Other None Detected

CEP199-01-02 / 19004826-003

, Drywall

White Non-Fibrous

Heterogeneous

10% Cellulose 90% Other None Detected

CEP199-01-02 / 19004826-003

, Joint Material

White Non-Fibrous

Heterogeneous

100% Other None Detected

CEP199-01-03 / 19004826-004

, Drywall

White Non-Fibrous

Heterogeneous

10% Cellulose 90% Other None Detected

CEP199-01-03 / 19004826-004

, Joint Material

White Non-Fibrous

Heterogeneous

100% Other None Detected

CEP199-03-01 / 19004826-005

, Tile

Blue Non-Fibrous

Heterogeneous

100% Other None Detected

CEP199-03-01 / 19004826-005

, Adhesive

Yellow Non-Fibrous

Heterogeneous

100% Other None Detected

CEP199-04-01 / 19004826-006

, Vinyl Base

Black Non-Fibrous

Heterogeneous

100% Other None Detected

Analyst:

Analysis Date: 2/8/2019 Date: 2/8/2019

Approved Signatory:

AH #130-06, MN-BMCDProject Number:

P.O. Number:

Project Name: Naval Station Norfolk, Pier 3T, CEP 199

1/30/2019Collected Date:

2/1/2019 10:05:00 AMReceived Date:

2/8/2019 6:55:22 PM

19004826 SanAir ID Number

FINAL REPORT

AH Environmental Consultants, Inc.Name:

Address: 11837 Rock Landing Drive

Suite 300

Newport News, VA 23606

Stereoscopic Components

SanAir ID / Description Appearance % Fibrous % Non-fibrous Asbestos Fibers

CEP199-04-01 / 19004826-006

, Adhesive

White Non-Fibrous

Heterogeneous

100% Other None Detected

CEP199-05-01 / 19004826-007

, Roofing

Black Non-Fibrous

Heterogeneous

8% Cellulose 92% Other None Detected

CEP199-05-01 / 19004826-007

, Tar

Black Non-Fibrous

Heterogeneous

100% Other None Detected

CEP199-06-01 / 19004826-008 Black Non-Fibrous

Heterogeneous

100% Other None Detected

Analyst:

Analysis Date: 2/8/2019 Date: 2/8/2019

Approved Signatory:

1551 Oakbridge Dr. Suite B, Powhatan, VA 23139 | 804.897.1177 | Fax: 804.897.0070 | www.SanAir.com | IAQ@SanAir.com

AH #130-06, MN-BMCDProject Number:

P.O. Number:

Project Name: Naval Station Norfolk, Pier 3T, CEP 199

1/30/2019Collected Date:

2/1/2019 10:05:00 AMReceived Date:

2/8/2019 6:55:22 PM

19004826 SanAir ID Number

FINAL REPORT

AH Environmental Consultants, Inc.Name:

Address: 11837 Rock Landing Drive

Suite 300

Newport News, VA 23606

SanAir Technologies Laboratory, Inc 1551 Oakbridge Dr, Suite B Powhatan, VA 23139

804.897.1177 Toll Free 888.895.1177 Fax: 804.897.0070

www.sanair.com email:iaq@sanair.com

Name: Project Number: AH #130-06

Address: 11837 Rock Landing Drive P.O. Number:

Suite 300 Project Name:

Newport News, VA 23606

Collected Date:

Received Date:

Report Date:

Analyst :

Test Method: EPA M3050B/6010C

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb)

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb)

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb)

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb)

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb)

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb) ug/g=ppm MRL: Method Reporting Limit based on 0.1g

Certification

Signature: Reviewed:

Date: Date: 2/5/2019

<25.0 25.0

25.0

<25.0 25.0

119 25.0

165 25.0

2 P3-L02 White, Concrete, Curb (275) N

881 25.0

<25.0

2/1/2019

SanAir ID Number

19004652

Final Report

Naval Station Norfolk Pier 3

Abisola O. Kasali

Analytes Requested: Paint: Barium(Ba),Cadmium(Cd),Chromium(Cr),Lead(Pb)

AH Environmental Consultants, Inc.

1/29/2019

1/31/2019 10:20 AM

2/7/2019 9:05 AM

REPORT OF ANALYSIS

1 P3-L01

Lab Sample #

White, Metal, Bollard (010) N 25.0

1,324 25.0

Results in ug/g Field Sample

Analyte

MRL

ug/Sample Sample Description

25.0

25.0<25.0

3 P3-L03 Yellow, Metal, Rail (470) N 106 25.0

281 25.0

4 P3-L04 Blue, Metal, Piping (525) N

2,772 25.0

<25.0 25.0

<25.0 25.0

69.0 25.0

5 P3-L05 White, Metal, Cleat (1180) S

<25.0 25.0

<25.0 25.0

276.0 25.0

<25.0 25.0

6 P3-L06 Gray, Metal, Column (1040) S

1,703 25.0

<25.0 25.0

<25.0 25.0

69.0 25.0

Test Method: EPA M3050B/6010C

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb)

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb)

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb)

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb)

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb) ug/g=ppm MRL: Method Reporting Limit based on 0.1g

Certification

Signature: Reviewed:

Date: Date: 2/5/2019

Analytes Requested: Paint: Barium(Ba),Cadmium(Cd),Chromium(Cr),Lead(Pb)

REPORT OF ANALYSIS

Lab Sample # Field Sample

Analyte Sample Description Results in ug/g

MRL

ug/Sample

7 P3-L07 Gold, Metal, Piping (875) S

73.0 25.0

<25.0 25.0

<25.0 25.0

844 25.0

8 P3-L08 Black/ White, Concrete, Curb

(525) S

4,694 25.0

<25.0 25.0

<25.0 25.0

198 25.0

9 P3-L09 Yellow/ Green, Metal, Railing

(315) S

153 25.0

<25.0 25.0

186 25.0

536 25.0

10 P3-L10 Yellow, Concrete,Striping (225)

S

<25.0 25.0

<25.0 25.0

3,663 25.0

10,285 25.0

11 P3-L11 Black/ Green, Metal, Door (GS)

1,270 25.0

<25.0 25.0

58.0 25.0

<25.0 25.0

2/1/2019

0.5% by weight HUD definition of lead based paint

1.0 mg/cm2

5000 ppm

Disclaimer

Lead Exposure Limits

Paint

SanAir Technologies Laboratory, Inc. participates in the Environmental Lead Accreditation Program (ELAP) administered by

AIHA-LAP, LLC (Lab ID162952). Refer to our accreditation certificate or www.aihaaccreditedlabs.org for an up to date list of the Fields of Testing for which we are accredited. SanAir also participates in the State of New York’s DOH-ELAP (Lab Id

11983), and has met the EPA's NLLAP program standards.

Final reports cannot be reproduced, except in full, without written authorization from SanAir Technologies Laboratory, Inc.

SanAir is not responsible for sample collection or interpretation made by others. This report does not constitute endorsement by

AIHA-LAP, LLC and/or any other U.S. governmental agencies; and may not be accredited by every local, state or federal regulatory agency.