2022-04-14 PN 2033108 Cheetah Conservation Station - LBP and ACM Survey Report.pdf

Froehling & Robertson, Inc. 3015 Dumbarton Road Richmond, Virginia 23228 T 804.264.2701 www.fandr.com

A Minority-Owned Business

Update 2022 ‐ spring

LIMITED LEAD‐BASED PAINT & ASBESTOS CONTAINING MATERIALS

SURVEY REPORT

Cheetah Conservation Station 3001 Connecticut Avenue NW

Washington D.C. 20008

Prepared For:

Architrave PC Architects

420 10th Street SE Washington D.C. 20003 Phone: 240.432.9432

Attention: Batul Abbas, Designer Email: Batul.abbas@architravepc.com

Issue Date: April 14, 2022

F&R Project Number: 59A‐0135

Conducted/Prepared By:

Samuel D. Bedinger, MA Industrial Hygienist II

Reviewed By:

E. Glenn Hargrove, CIH Practice Leader, Industrial Hygiene Services

Director of Industrial Hygiene

Architrave PC Architects Cheetah Conservation Station F&R Project Number 59A‐0135 i April 14, 2022

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1. PURPOSE

1.2. SITE DESCRIPTION

1.3. BACKGROUND

2.0 SCOPE OF SERVICES

3.0 LIMITED ASBESTOS‐CONTAINING MATERIALS SURVEY

3.1. ASBESTOS‐CONTAINING MATERIALS (ACM) METHODOLOGY

3.2. ASBESTOS‐CONTAINING MATERIALS FINDINGS

3.3. ASBESTOS‐CONTAINING MATERIALS INVENTORY

3.3.1. Presumed Asbestos‐Containing Materials

3.4. ASBESTOS‐CONTAINING MATERIALS RECOMMENDATIONS

3.5. APPLICABLE REGULATIONS

3.5.1. EPA/NESHAP Regulations for Asbestos‐Containing Materials

3.5.2. Washington D.C. Department of Energy & Environment Asbestos Laws and Regulations

3.5.3. OSHA Asbestos Regulations

3.5.4. Smithsonian Institute Policy

4.0 LIMITED LEAD‐BASED PAINT SURVEY

4.1. LEAD‐BASED PAINT SURVEY METHODOLOGY

4.1.1. XRF Testing

4.2. LEAD‐BASED PAINT SURVEY FINDINGS

4.2.1. XRF Survey Results

4.2.1.1. Locations of Detected Lead‐Based Paint

4.2.1.2. Inaccessible or Presumed Lead‐Based Paint

4.3. LEAD‐BASED PAINT CONCLUSIONS & RECOMMENDATIONS

4.4. APPLICABLE REGULATIONS

4.4.1. OSHA Regulations for Lead‐Based Paint

4.4.2. EPA Regulations for Lead‐Based Paint

4.4.2.1. Disposal

4.4.3 Washington D.C. Department of Energy & Environment Lead Laws and Regulations

4.4.4 Smithsonian Institute Policy

5.0 LIMITATIONS

F&R Project Number 59A‐0135 ii April 14, 2022

APPENDICES

Appendix A

F&R Personnel and Laboratory Accreditations

Appendix B

Facility Diagram:

Appendix C

Laboratory Certificates of Analysis

Bulk Sample Chain of Custody Forms

Appendix D

Photographic Documentation

Section 1 Overview

Section 2 Asbestos‐Containing Materials

Section 3 Lead‐Based Paint

Appendix E

Explanation of XRF Data Table

XRF Data Table XRF Performance Characteristic Sheet

F&R Project Number 59A‐0135 1 April 14, 2022

1.0 INTRODUCTION

Froehling & Robertson, Inc. (F&R) conducted limited regulated materials consulting services on April 4, 2022 and April 5, 2022 at the Cheetah Conservation Station (CCS) located at 3001 Connecticut Avenue NW in Washington D.C. It is F&R’s understanding that the facility structures are the subject of planned renovation and selective demolition which is anticipated to impact building materials. The following sections document the survey procedures and results. Refer to Appendix A for Personnel Accreditation documentation of F&R personnel associated with this survey.

1.1. Purpose

The purpose of the Limited Asbestos‐Containing Materials and Lead‐Based Paint Surveys is to identify Asbestos‐Containing Materials (ACMs) and Lead‐Based Paint (LBP) coatings that may require appropriate removal, handling, and disposal procedures prior to scheduled renovation and selective demolition activities at the subject property. This survey is to aid in the determination of health and safety requirements during the conduct of work which may impact identified materials.

1.2. Site Description

The CCS facility is located in the northwest area of the Smithsonian National Zoological Park (NZP) and is comprised of 130,000 square feet of animal barns, animal yards, and staff support areas.

The facility was constructed in the 1970s and much of the infrastructure is outdated and scheduled for renovations. The facility includes eight distinct structures with asphalt shingles on pitched roofs. All structures are built on concrete pads with concrete masonry unit (CMU) block perimeter walls and interior demising walls. The topography around the building slopes from southwest to northeast. Interior finishes within the animal barns include concrete floors, CMU block walls, and area carpeting/padding. Interior finishes within the Keeper’s Office include gypsum board walls, vinyl composite tile (VCT), lay‐in acoustic ceiling tiles (ACT), among others.

Refer to Appendix B for site diagrams of the facility, including asbestos sample locations.

Note that F&R utilizes United States Housing and Urban Development (HUD) methodology for location identification modifiers: Side A is always the address side or the main entry side of the building or space. Then, proceeding in a clockwise direction the adjacent sides are labeled B, C and D; for example, the wall on the left side as one enters the building would be denoted as side B. Rooms with similar use patterns are numbered sequentially, unless room numbers were clearly identified on‐site. Note that F&R utilized building and stall numbers as they were labeled on‐site; such designations are expected to persist throughout the project. Facility drawings were provided by the Client under the title “Exhibit Design – New Work – Renew Cheetah Conservation Station (CCS)”, dated March 17, 2022. Refer to Appendix B for facility diagrams including asbestos sample locations created by F&R utilizing the Client provided drawings.

F&R Project Number 59A‐0135 2 April 14, 2022

It should be noted that material and color descriptions are subjective and that, due to the nature of the environment, identical materials and colors may have been labeled as different or the same depending on the lighting, other colors in the area, and other factors. Additionally, acoustic ceiling panels were described subjectively and differentiated as possible based on aesthetic details such as texture variations.

1.3. Background

F&R was provided with Attachment A of the A/E Scope of Work (AE100) for the Renew Cheetah Conservation Station (CCS), Smithsonian National Zoological Park, 3001 Connecticut Avenue, Washington DC, date December 22, 2020 and revised December 15, 2021 and January 13, 2022 detailing known issues with the CCS facility. Attachment A of A/E Scope of Work indicates select structures within the CCS facility will be the focus of scheduled renovations. No additional documentation including previously conducted hazardous material surveys has been provided to F&R. The aforementioned A/E Scope of Work (AE100) is not included for reference in this report.

2.0 SCOPE OF SERVICES

As outlined in F&R proposal number 2259‐00052, the survey included the following services with respect to the proposed renovation and selective demolition activities associated with the facility structures identified as the; barn (open holding), zebra barn, barns (multiple), kudu barn, maned wolf/gazelle barn, oryx, vulture barn, hog and sitatunga barn, cheetah and hog nighthouse, hoofstock/cheetah holding, keeper office, and loading zone:

Identification and sampling, as necessary, of suspect ACMs for analysis.

Determination of the presence and location of identified ACMs.

Testing, as necessary, of surface coatings for the presence of Lead.

Based on information provided by the client, it is F&R’s understanding that the extent of the renovation and/or selective demolition is removal and replacement of the facility infrastructure in order to update the facility and modify the layout of the space to provide a more efficient layout at the facility. Consequently, only those areas which are anticipated to be impacted by the renovation and selective demolition scope of work were included in this survey; the animal yards/exhibits were excluded, as was building B6‐A and building B3‐A due to the areas being occupied by animals. Buildings B6‐A and B3‐A were visually assessed in a limited manner and determined homogeneous in construction to the other structures included in this survey. As such, this survey as performed does not constitute a comprehensive building survey and this report shall not be utilized for the determination of presence or absence of Regulated Materials outside of the renovation area should the scope of work be altered or expanded beyond that of the currently scheduled upgrades and renovations.

F&R Project Number 59A‐0135 3 April 14, 2022

3.0 LIMITED ASBESTOS‐CONTAINING MATERIALS SURVEY

F&R’s EPA accredited Asbestos Building Inspector, Samuel D. Bedinger (EPA/AHERA Training Certification #FR22‐6111), conducted the Asbestos Survey of the current site structures located at 3001 Connecticut Avenue NW on April 4, 2022 and April 5, 2022.

Federal Regulations (40 CFR Part 61, Subpart M – National Emission Standard for Asbestos (NESHAP)), as well as the District of Columbia (DC) regulations require a thorough asbestos inspection of the structure to be conducted prior to the commencement of renovation and/or demolition activities. An ACM is defined by the Occupational Safety & Health Administration (OSHA) and the Environmental Protection Agency (EPA) as material containing greater than one percent (1%) asbestos.

3.1. Asbestos‐Containing Materials (ACM) Methodology

This survey was conducted in general accordance with the Federal NESHAP and applicable DC regulations for the presence of ACMs. The survey was characterized by a visual inspection and sampling of suspect building components at the subject property to be impacted by the proposed renovation/demolition activities.

Guidelines utilized in the asbestos survey were established by the EPA, ASTM International (ASTM), and The Environmental Information Association, Inc. (EIA). Utilized guidelines included:

the Asbestos Hazard Emergency Response Act (40 CFR Part 763, Subpart E – Asbestos‐Containing Materials in Schools (cited as AHERA)), ASTM Standard E2356‐14 Standard Practice for Comprehensive Building Asbestos Surveys, and the EIA publication Managing Asbestos in Buildings: A Guide for Owners and Managers – A Revision to the United States Environmental Protection Agency’s 1985 document Guidance for Controlling Asbestos‐Containing Materials in Buildings (EPA 560/5‐85‐024) Known as the Purple Book.

F&R’s aforementioned Industrial Hygienist collected and submitted suspect asbestos‐containing bulk samples to the laboratory, of which, a total of sixty‐three (63) suspect asbestos‐containing bulk samples with discernable layers were analyzed by the Laboratory. Due to multiple layers, a total of one‐hundred and one (101) samples were analyzed.

Samples of suspect ACMs were organized as per the AHERA concept of Homogeneous Area (HA), collected, and transported to the Environmental Hazards Services, L.L.C. (EHS) testing laboratory.

EHS is a National Institute for Standards and Technology (NIST) National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory (NVLAP Lab Code: 101882‐0) for analysis by Polarized Light Microscopy (PLM) following EPA Method 600/R‐93/116 and 600/M4‐82‐020.

Refer to Appendix A for Laboratory Certificates of Accreditations. Refer to Appendix C for Laboratory Certificates of Analysis and Bulk Sample Chain of Custody Forms for further description of sampled materials/analytical results.

F&R Project Number 59A‐0135 4 April 14, 2022

F&R collected bulk samples of roofing materials during this survey. Samples were collected from the corners of each structure represented in this survey. Sample locations were not temporarily patched, however the sample was collected in a manner that should not compromise the roof’s ability to prevent water intrusion into the underlying structure. Sampling activities were not coordinated with a professional roofing contractor; no contact information was provided or indicated as preferred by the Client.

Building materials considered not suspect for asbestos were excluded from the sampling approach at the discretion of our inspector. Masonry materials which constitute a surfacing or troweled on finish such as concrete patches and packings were included, where observed. If masonry or other materials were observed which were clearly associated with a construction application where asbestos was historically utilized, such as a cementitious material utilized in a TSI application, these materials were collected for analysis.

3.2. Asbestos‐Containing Materials Findings

The following material types were identified, sampled, and accordingly homogenized based upon similar construction discovered during bulk sampling:

Asphalt Shingle Roofing Materials Pipe Insulation Components

Block/Brick/Mortar Flooring Materials

Concrete – Various Applications Mastics ‐ Various Applications

Caulking ‐ Sealants – Various Applications Gypsum Wallboard Systems

The following table presents a summary of survey results from sampling events performed on April 4, 2022 and April 5, 2022. Refer to Appendix B for illustration of the locations of collected bulk samples. Positive asbestos samples (samples containing >1% asbestos) are in BOLD type.

SUSPECT ASBESTOS‐CONTAINING MATERIALS SAMPLE INFORMATION

HA

Sample

Situation1 Sample Location(s) Material

Description/Function Laboratory Description

Percent Asbestos

A E B10, Side A, Door 3

Pliable White Door Frame Caulk

Off‐White to Rust Brown Pliable to Brittle3

2% Chrysotile

White Pliable; Green/Gray Pliable to Brittle4

NAD5

B E AT7, Stall 1, Side C Tan Brittle3 4% Chrysotile

White Pliable; Multi‐Colored Pliable to Brittle5

NAD

C E CCS 8, Stall 2, Side A Tan Brittle; Multi‐Colored

Pliable to Brittle6 3% Chrysotile

D E Keeper’s Office, Side A Off‐White to Tan Pliable to

Brittle3 3% Chrysotile

F&R Project Number 59A‐0135 5 April 14, 2022

HA

Sample

Situation1 Sample Location(s) Material

Description/Function Laboratory Description

Percent Asbestos

Off‐White Pliable; Light Blue/Pale Gray Pliable to

Brittle5

NAD

A 1 B10, Side A, Door 1

White Brittle Door Frame Caulk

White Brittle; Multi‐Colored Pliable to Brittle; Dark Gray to

Rust Orange Metallic7 4% Chrysotile

B 1 CCS 8, Stall 3, Side A Pale Tan Brittle; Multi‐Colored

Pliable to Brittle8 4% Chrysotile

C 1 AT 7, Stall 5, Side A Pale Tan Brittle; Multi‐Colored

Pliable to Brittle8 4% Chrysotile

A 1 B10, Side A, D/A Corner

CMU Block and Mortar

Tan Cementitious (Inner Masonry Layer and

Surface Paint)

NAD

Pale Gray Cementitious; Multi‐ Colored Pliable to Brittle (Outer Masonry Layer and Surface

Paint)

NAD

B 1 Night House, Stall 2, Side A Pale Gray Cementitious; Green

Pliable to Brittle

NAD

C 1 CCS 8, Stall 2, Side D Pale Gray Cementitious; Green

Pliable to Brittle

NAD

D 1 Boiler Room, Side A

Pale Gray Cementitious (Inner Masonry Layer)

NAD

Pale Beige‐Gray Cementitious;

Pale Beige Pliable to Brittle (Outer Masonry Layer and

Surface Paint)

NAD

A 1 B10, Side A, A/B Corner Cementitious Patch‐

Like Cap on CMU Block Wall

Pale Beige‐Gray Cementitious;

Multi‐Colored Pliable to Brittle

NAD

B 1 B10, Side A Pale Gray Cementitious; Multi‐

Colored Pliable to Brittle

NAD

A 1 B10, Side A, A/B Corner

CMU Block Corner Joint Caulk

Pale Gray Cementitious; Multi‐ Colored Pliable to Brittle

NAD

B 1 AT 7, Stall 1, Corner B/A Pale Gray Cementitious; Multi‐

Colored Pliable to Brittle

NAD

C 1 Keeper’s Office, Corner

C/D Multi‐Colored Pliable to Brittle;

Pale Gray Cementitious

NAD

A E B10, Side A, Exterior at

Door

Concrete Walkway Expansion Joint Caulk

Black Brittle9 NAD

White Pliable (Outer Caulk‐Material)

NAD

B E CCS 8, Stall 2, Side A Black Pliable to Brittle9 NAD

White Pliable (Outer Caulk‐Material)

NAD

C E AT 6, Stall 1, Side A Black Brittle9 NAD

Off‐White Pliable (Outer Caulk‐Material)

NAD

F&R Project Number 59A‐0135 6 April 14, 2022

HA

Sample

Situation1 Sample Location(s) Material

Description/Function Laboratory Description

Percent Asbestos

Pale Pink Cementitious (Masonry Substrate Material)

NAD

Pale Gray Cementitious (Masonry Substrate Material)

NAD

A 1 B10, Side C, Corner C/D

Leveling Compound

Tan Cementitious to Coarse Powder (Inner Masonry

Material)

NAD

Pale Gray Cementitious; Off‐ White Brittle (Outer Masonry

Layer and Surface Paint)

NAD

B 1 B10, Side C

Tan Cementitious to Coarse Powder (Inner Masonry

Material)

NAD

Pale Gray Cementitious; Off‐ White Brittle (Outer Masonry

Layer and Surface Paint)

NAD

A 1 B10, Side C

Concrete Stall Floor

Pale Gray to Pale Tan‐Gray Cementitious

NAD

B 1 CCS 8, Stall 2, Side C Pale Gray to Pale Tan‐Gray

Cementitious

NAD

C 1 AT 7, Stall 4, Side C Pale Gray to Pale Tan‐Gray

Cementitious

NAD

A E Adjacent B10, Side A Pink Concrete Walkway with Pebble Aggregate

Pale Pink Cementitious NAD

B E Adjacent CCS, Stall 3 Pale Pink Cementitious NAD

C E Adjacent AT 7, Stall 5 Pale Pink Cementitious NAD

A 1 Night House, Stall 1, Side A

Brittle Carpet Mastic Tan Pliable to Brittle NAD

B 1 Night House, Stall 2, Side A Tan Pliable NAD

A 1 Night House, Stall 7, Side C

Older 5” TSI and Bridging Compound

Off‐White/White Fibrous; Silver Metallic; Yellow Adhesive

(Covering/Jacket)

NAD

White Pliable (Surface Sealant‐ Type Material)

NAD

B 1 CCS 8, Stall 2, Side C

Off‐White/White Fibrous; Silver Metallic; Yellow Adhesive

(Covering/Jacket)

NAD

White Pliable (Surface Sealant‐ Type Material)

NAD

C 1 Boiler Room, Side C

Yellow Fibrous (Insulation) NAD

Off‐White/White Fibrous; Silver Metallic; Yellow Adhesive

(Covering/Jacket)

NAD

Beige Pliable (Surface Sealant‐ Type Material)

F&R Project Number 59A‐0135 7 April 14, 2022

HA

Sample

Situation1 Sample Location(s) Material

Description/Function Laboratory Description

Percent Asbestos

A 1 Night House, Stall 7, Side C

Newer 5” TSI and Bridging Compound

Off‐White/White Fibrous; Silver Metallic; Yellow Adhesive

(Covering/Jacket)

NAD

White Pliable (Surface Sealant‐ Type Material)

NAD

B 1 AT 7, Stall 1, Side D

Yellow Fibrous NAD

Off‐White/White Fibrous; Silver Metallic; Yellow Adhesive

(Covering/Jacket)

NAD

White Pliable (Surface Sealant‐ Type Material)

NAD

C 1 Boiler Room, Side C

Yellow Fibrous NAD

Off‐White/White Fibrous; Silver Metallic; Yellow Adhesive

(Covering/Jacket)

NAD

White Pliable (Surface Sealant‐ Type Material)

NAD

A 1 Filtration, Side A Beige Pliable Door

Casing Caulk

White Pliable NAD

B 1 Electrical Closet, Side A Off‐White Pliable NAD

A 1 Electrical Closet, Side D

Light Gray Cementitious Patch

Pale Gray Cementitious NAD

B 1 AT 7, Stall 5, Side D Gray Cementitious NAD

C E Sidewalk, Adjacent to

AT 7, Stall 5 Pale Tan‐Gray Cementitious NAD

A 1 Electrical Closet, Side D

Dark Gray Cementitious Patch

Pale Gray Cementitious NAD

B E AT 7, Stall 5, Side D Pale Gray Cementitious NAD

C E Sidewalk Adjacent to AT 7, Stall 5 Gray Cementitious NAD

A R CCS 8, Side B

Older Asphalt Shingle and Tar Paper

Black Pliable to Brittle Black Fibrous; Multi‐Colored

Aggregate (Roofing Shingle‐ Type Material)

NAD

Black Pliable; Black Fibrous;

Black Aggregate (Roofing Roll Membrane‐Type Material)

NAD

B R AT 7, Side D

Black Pliable to Brittle; Black Fibrous; Multi‐Colored

Aggregate (Roofing Shingle‐ Type Material)

NAD

Black Pliable; Black Fibrous;

Black Aggregate (Roofing Roll Membrane‐Type Material)

F&R Project Number 59A‐0135 8 April 14, 2022

HA

Sample

Situation1 Sample Location(s) Material

Description/Function Laboratory Description

Percent Asbestos

A R Keeper’s House, Side B

Newer Asphalt Shingle and Tar Paper

Black Pliable to Brittle; Black Fibrous; Multi‐Colored

Aggregate (Roofing Shingle‐ Type Material)

NAD

Black Pliable; Black Fibrous;

Turquoise Vinyl‐Like (Roofing Roll Membrane‐Type Material)

NAD

Off‐White Pliable10 NAD

B R Keeper’s House, Side B

Black Pliable to Brittle; Black Fibrous; Multi‐Colored

Aggregate (Roofing Shingle‐ Type Material)

NAD

Black Pliable; Black Fibrous;

Turquoise Vinyl‐Like (Roofing Roll Membrane‐Type Material)

NAD

Off‐White Pliable10 NAD

A 1 Electrical Closet, Side C

Red Fireproof Caulk Red Pliable NAD

B 1 Electrical Closet, Side C Red Pliable NAD

A 1 Keeper’s Office, Side B

Gypsum Wallboard and Joint Compound

Off‐White/White Brittle;

Tan/Light Beige Fibrous; Pale

Beige Pliable to Brittle (Drywall)

NAD

White Brittle (Joint Compound)

NAD

B 1 Keeper’s Office, Side B

Off‐White/White Brittle;

Tan/Light Beige Fibrous; Pale

Beige Pliable to Brittle (Drywall)

NAD

White Brittle (Joint Compound)

NAD

A 1 Keeper’s Office, Center

12” Beige Marbled VCT with Yellow Mastic

Pale Tan/Pale Tan‐Gray Granular (Flooring)

NAD

Yellow Adhesive (Mastic) NAD

Off‐White Cementitious11 NAD

B 1 Keeper’s Office, Side A

Pale Tan/Pale Tan‐Gray Granular (Flooring)

NAD

Yellow Adhesive (Mastic) NAD

Off‐White Cementitious11 NAD

A 1 Keeper’s Office, Side B 6” Beige CB with Cream

Mastic

Tan Vinyl‐Like (Cove Base) NAD

Off‐White Adhesive (Mastic) NAD

B 1 Keeper’s Office, Side D Tan Vinyl‐Like (Cove Base) NAD

Off‐White Adhesive (Mastic) NAD

A 1 Keeper’s Office, Ceiling

2’ X 4’ Pinhole ACT

Pale Tan‐Gray Fibrous; White Brittle

NAD

B 1 Keeper’s Office, Ceiling Pale Tan‐Gray Fibrous; White

Brittle

F&R Project Number 59A‐0135 9 April 14, 2022

HA

Sample

Situation1 Sample Location(s) Material

Description/Function Laboratory Description

Percent Asbestos

A 1 Keeper’s Office, Ceiling

2’ X 4’ Pinhole and Wormhole ACT

Pale Gray to Tan Fibrous; White Brittle

NAD

B 1 Keeper’s Office, Ceiling Pale Gray to Tan Fibrous; White

Brittle

NAD

A 1 Keeper’s Office, Ceiling

2’ X 4’ Act with Horizontal Fissures

Pale Gray to Brown Fibrous;

White Brittle

NAD

B 1 Keeper’s Office, Ceiling Pale Gray to Brown Fibrous;

White Brittle

NAD

A 1 Keeper’s Office, Side A

12” White Marbled VCT with Yellow Adhesive

Pale Gray/Gray Granular (Flooring)

NAD

Yellow Adhesive (Mastic) NAD

B 1 Keeper’s Office, Side A

Pale Gray/Gray Granular (Flooring)

NAD

Yellow Adhesive (Mastic) NAD 1Situation: 1 –First; 2 – Second; B – Basement; R ‐ Roof; E – Exterior; S ‐ Shed 2Bold: Asbestos Containing Material or Trace (<1%) Asbestos Present 3Sample HA #1A/1B/1D: Inner Caulk/Glazing Compound‐Type Material 4Sample HA #1A/1B/1D: Outer Caulk‐Type Material and Surface Paint 5NAD: No Asbestos Detected 6Sample HA #1C: Chrysotile present in tan brittle caulk/glazing compound‐type (main) layer.

7Sample HA #2A: Chrysotile present in white brittle caulk/glazing compound‐type (main) layer.

8Sample HA #2B/2C: Chrysotile present in pale tan brittle caulk/glazing compound‐type (main) layer.

9Sample HA #6A/6B/6C: Inner Bituminous Sealant/Mastic‐Type Material 10Sample HA #17A/17B: Sealant/Mastic‐Type Material Atop Roofing Roll Membrane‐Type Material.

11Sample HA #20A/20B: Leveling Compound‐Type Substrate Material

3.3. Asbestos‐Containing Materials Inventory

F&R conducted a survey of the reasonably and safely accessible portions of the CCS facility to be impacted by the planned demolition/renovation. Animal exhibit enclosures and the exterior holding areas were excluded due to those limitations presented onsite at the time of F&R’s site visits. Buildings B6‐A and B3‐A were inaccessible during the site visits; suspect ACM in this space which were not represented during this survey should be presumed positive.

The following table presents identified materials containing greater than 1% or trace (<1%) concentrations of asbestos, as well as presumed materials with regard to F&R survey activities.

Further, comprehensive delineation/quantification was not performed; therefore, the table below may not completely represent locations of identified ACMs. It is the responsibility of the client or contractor to verify material locations. Photographic documentation of ACMs for reference is provided as Appendix D.

F&R Project Number 59A‐0135 10 April 14, 2022

ASBESTOS‐CONTAINING MATERIALS INVENTORY

HA

Material Description Sample Location(s) Result (Percent Asbestos)

EPA/NESHAP Category1 Condition2

Off‐White to Rust Brown; Pliable to Brittle Door Frame Caulk Building B10, Stall 3 2% Chrysotile Category II, Non‐Friable G

1 Tan Brittle Door Frame Caulk Building AT 7, Stall 1 4% Chrysotile Category II, Non‐Friable G

Tan Brittle, Multi‐Colored Pliable to Brittle Door Frame Caulk Building CCS 8, Stall 2 3% Chrysotile Category II, Non‐Friable G

Off‐White to Tan; Pliable to Brittle Door Frame Caulk

Keeper’s Office, Side A 3% Chrysotile Category II, Non‐Friable G

White Brittle; Multi‐Colored Pliable to Brittle; Dark Gray to Rust Orange Metallic Door

Frame Caulk

Building B10, Stall 1 4% Chrysotile Category II, Non‐Friable G

Pale Tan Brittle; Multi‐Colored Pliable to Brittle Door Frame

Caulk

Building CCS 8, Stall 3, Building AT 7, Stall 5

4% Chrysotile Category II, Non Friable G

1EPA/NESHAP Category: See Section 3.5.1 for details.

2Condition: G: Good (No damage);

D: Damaged (<10% distributed or <25% localized);

SD: Significantly Damaged (>10% distributed or >25% localized)

F&R presumes that, where materials have been documented to be ACMs and where those materials are similar to other materials which have not been found to be positive, those similar materials will be considered to be ACMs (i.e. where one material was analyzed and found to be positive, it is prudent to consider other similar materials positive, despite potential analytical data to the contrary).

3.3.1. Presumed Asbestos‐Containing Materials

During the conduct of this survey, sampling was limited to those materials which were within the areas designated by the client, which were safely accessible, and which were able to be sampled without damaging systems or structures. As such, some materials should be presumed to be positive, unless sampling is conducted and shown to be negative. Such presumed asbestos containing materials (PACMS) include, but are not limited to:

Gaskets and packing materials in plumbing or hydraulic systems, where present, Electrical panel backing/arc deflectors/spark arresters, Vermiculite within masonry cells, Wiring insulation or other live electrical system components, Cementitious masonry patches not represented in this survey, Water fountain components, Et cetera.

F&R Project Number 59A‐0135 11 April 14, 2022

As noted above, select building materials were excluded from the sampling and analysis;

however, without confirmation sampling, F&R cannot definitively affirm that detectable concentrations of asbestos in such materials are absent.

Note that asbestos was used in over 3,000 known products and was used extensively in construction materials including in insulation and finish materials such as gypsum board‐based systems, acoustical tiles, caulks and mastics, vinyl‐based materials, and specialty products.

Asbestos also continues to be used in new construction because, as stated by the EPA, "the manufacture, importation, processing, and distribution in commerce of [various] products […] are not banned.”

3.4. Asbestos‐Containing Materials Recommendations

As detailed above, several materials were identified as asbestos‐containing, utilized in various instances throughout the structure. Prior to impacting the identified or presumed ACMs via renovation and demolition, F&R recommends that the ACMs be appropriately removed, handled, and disposed of by an appropriately licensed/accredited Abatement Contractor utilizing appropriately licensed/accredited personnel. Best practices dictate that an asbestos abatement specification document be prepared which details project‐specific work plans and requirements.

This abatement specification document should incorporate delineation/quantification of identified or presumed ACMs and should be furnished by the client or building owner to contractors for bidding purposes. Appropriately licensed or accredited personnel must prepare and/or review such specification documents. This survey report should not be used for bidding purposes.

F&R further recommends that a third party Asbestos Professional be retained to provide on‐site surveillance and guidance of the Asbestos Abatement Contractor to confirm complete and proper removal/disposal of ACMs in accordance with applicable federal, state, and local regulations. This recommendation is made as a best practice to reduce potential exposure to workers and limit liability.

The Client should note that F&R has encountered instances in which materials were analyzed by Polarized Light Microscopy (PLM) (following EPA Method 600/R‐93/116) for the presence of asbestos with a result of “None Detected”, but when analyzed by Transmission Electron Microscopy (TEM) for Non‐friable Organically Bound (NOB) bulk material, analytical results have indicated that asbestos is present in quantities greater than 1%. The client should be aware that F&R has samples analyzed by the PLM method for a number of reasons (including financial and time considerations) and that this method is considered acceptable in DC; however, some firms employ the more stringent TEM method which is required in some states. Therefore, it is possible that some materials identified as containing no asbestos within this report may, if subjected to a more stringent analytical method, reveal the presence of asbestos at concentrations of 1% or greater.

F&R Project Number 59A‐0135 12 April 14, 2022

In addition, it should be noted that through NESHAP Applicability Determinations, asbestos bulk samples composed of friable materials which indicate a result of asbestos content to be less than ten (10) percent, including trace amounts (<1%) when analyzed via PLM, the material in question shall either be assumed to be an ACM or further analyzed via PLM Point Count or TEM to verify asbestos content. Quantitative results obtained via PLM Point Count or TEM analysis shall supersede previous qualitative results obtained by standard PLM analysis. Samples with analytical results via PLM which indicate that no asbestos was detected are not required to be further analyzed via PLM Point Count or TEM.

Should additional suspect ACMs be discovered during renovation and/or demolition activities that have not been sampled and which will be disturbed, F&R recommends the work be temporarily halted. Samples of suspect materials should be collected, analyzed, and handled accordingly prior to the resumption of renovation and/or demolition activities.

3.5. Applicable Regulations

3.5.1. EPA/NESHAP Regulations for Asbestos‐Containing Materials

The U.S. Environmental Protection Agency promulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP) [40 CFR Part 61], which addresses the application, removal, and disposal of asbestos‐containing materials (ACM). Under NESHAP the following categories are defined for asbestos‐containing materials:

Friable ‐ When dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Non‐friable ‐ When dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Category I Non‐friable ACM ‐ Packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1% asbestos.

Category II Non‐friable ACM – Material, excluding Category I Non‐friable ACM, which contains more than 1% asbestos.

Regulated Asbestos Containing Material (RACM) – One of the following:

1. Friable ACM

2. Category I Non‐friable ACM that has become friable.

3. Category I Non‐friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading.

F&R Project Number 59A‐0135 13 April 14, 2022

4. Category II Non‐friable ACM that has a high probability of becoming, or has become, friable by the forces expected to act on the material in the course of demolition or renovation operations.

Under NESHAP, the following actions are required:

1. Prior to the commencement of demolition or renovation activities, the building owner must inspect the affected facility or part of the facility where the demolition or renovation activities will occur for the presence of asbestos.

2. Remove RACM from the facility before activities begin that would break up, dislodge, or similarly disturb the material or preclude access for subsequent removal.

3. ACM need not be removed before demolition if:

a) It is Category I non‐friable ACM that is not in poor condition.

b) It is on a facility component that is encased in concrete or other similar material and is adequately wet whenever exposed.

c) It was not accessible for testing and was therefore not discovered until after demolition began and because of the demolition the material cannot be safely removed.

d) It is Category II non‐friable ACM and the probability is low that the material will become crumbled, pulverized, or reduced to powder during demolition.

3.5.2. Washington D.C. Department of Energy & Environment Asbestos Laws and

Regulations

The Washington D.C. Department of Energy & Environment (DDOE) administers the Asbestos Program which accredits and certifies individuals and issues permits for asbestos removal projects on behalf of the Federal NESHAP program which has been delegated to Washington D.C.

For more information, visit the Washington D.C. Asbestos Laws and Regulations website at:

https://doee.dc.gov/service/asbestos‐laws‐and‐regulations.

3.5.3. OSHA Asbestos Regulations

The Occupational Safety and Health Administration (OSHA) regulates employee exposure to asbestos under 29 CFR 1926.1101 and 29 CFR 1910.1001. Work associated with known or suspect ACMs must be conducted according to these regulations in addition to the noted EPA regulations.

F&R Project Number 59A‐0135 14 April 14, 2022

3.5.4. Smithsonian Institute Policy

The Smithsonian Institute may have internal policy regarding ACM and activities that pose the potential for disturbance. The appropriate environmental division of the SI should be contacted for guidance.

4.0 LIMITED LEAD‐BASED PAINT SURVEY

F&R’s Virginia Licensed Lead‐Based Paint Inspector/Risk Assessor, Samuel D. Bedinger (VA LBP or License #3356001218), performed the testing of surface coatings for lead content on April 4, 2022. Refer to Appendix A for F&R Personnel Accreditation Documentation.

4.1. Lead‐Based Paint Survey Methodology

The survey was conducted in general accordance with EPA’s work practice standards for conducting LBP activities (40 CFR 745.227), and the HUD Guidelines for the Evaluation and Control of Lead‐Based Paint Hazards in Housing (Second Edition, July 2012); however, this was not a comprehensive surface‐by‐surface investigation for LBP, but rather a screening survey of major coated surfaces where the presence of LBP is suspected. Vinyl finishes or other components which were not painted were generally not included in our inspection.

Several components, particularly exterior components within the animal enclosures were not safely accessible for testing during the survey. Therefore, F&R has employed professional judgment in making determinations about the homogeneity of components determined to be “positive.”

4.1.1. XRF Testing

Testing of surface coatings was conducted utilizing a Viken (formerly Heuresis) Pb200i X‐Ray Fluorescence (XRF) Lead Paint Analyzer (Serial Number 1460). Only accessible painted, coated, and/or varnished surfaces were tested using the XRF.

The XRF contains a small radioisotopic source and operates on the principle of x‐ray fluorescence, whereby lead atoms in a surface coating are stimulated to emit characteristic x‐rays, which are subsequently detected by the instrument. Levels of lead are reported in units of milligrams per square centimeter (mg/cm2). The XRF can measure surface or non‐surface concentrations of lead with 95% accuracy at the HUD action level of 1.0 mg/cm2. The XRF is able to accurately detect a concentration as low as 0.1 mg/cm2 of lead. The XRF classifies coated surfaces as “positive”, “negative”, or “null” for lead content based on the action level (1.0 mg/cm2) and the performance characteristics of the XRF. The XRF was checked for calibration before and after the survey. The calibration was checked against a standard reference material (1.04 mg/cm2 NIST Standard)

F&R Project Number 59A‐0135 15 April 14, 2022 supplied by the XRF manufacturer. A copy of the XRF Performance Characteristic sheet is included as an attachment to this report.

Positive: Lead is present at or above the action level of 1.0 mg/cm2 on one or more of the components tested.

Negative: Lead is not present at or above the action level of 1.0 mg/cm2 on any of the components tested.

Null: Insufficient data was collected by the XRF during the sample time to determine if the surface is positive or negative (i.e. – premature removal or instrument slippage, terminating the test).

4.2. Lead‐Based Paint Survey Findings

4.2.1. XRF Survey Results

A total of seventy (70) XRF readings, excluding calibration readings, were collected from the interior and exterior of the CCS facility. Sixteen (16) of the readings collected at the Project site were positive for LBP when compared to the action level of 1.0 mg/cm². Refer to Appendix E, XRF Data Table for a listing of the readings and respective information as well as an explanation of the data table and the Performance Characteristic Sheet. The following table presents the positive readings collected.

XRF READINGS FOR LEAD‐BASED PAINT

Reading Number

Component Substrate Side Condition Color Room Floor

12 Door Casing Wood A Good Off‐White E7, Stall 1 Exterior

19 Wall CMU B Good Off‐White E7, Stall 1 1st

20 Wall CMU D Good Off‐White E7, Stall 1 1st

23 Door Casing Metal C Good Olive E7, Stall 1 1st

27 Door Casing Metal A Good Olive E7, Stall 3 1st

28 Door Jamb Wood A Good Gray E7, Stall 3 1st

32 Wall CMU B Good Off‐White E7, Stall 3 1st

38 Door Jamb Metal A Deteriorated Olive E8, Stall 2 Exterior

39 Wall CMU C Deteriorated Off‐White E8, Stall 2 Exterior

41 Wall CMU C Good Red Electrical Closet 1st

50 Door Casing Metal A Good Brown B10 1st

51 Door Jamb Metal A Good Gray B10 1st

53 Wall CMU B Good Off‐White B10 1st

55 Wall CMU C Good Green Night House, Stall 2 1st

56 Wall CMU C Good Gray Night House, Stall 7 1st

66 Wall CMU C Good Off‐White Filtration Room 1st

F&R Project Number 59A‐0135 16 April 14, 2022

4.2.1.1. Locations of Detected Lead‐Based Paint

Based on the detection of LBP on specific component types and our observation of an apparent homogenous painting history, the following building components should be considered to be coated with LBP:

LEAD‐BASED PAINT MATERIALS INVENTORY

Material Description Color Substrate Material Location(s)

Interior

CMU Block Wall Off‐White CMU Building E7;

Building B10;

Filtration Room

Door Casing Olive Metal Building E7

Door Jamb Gray Wood Building E7

CMU Block Wall Red CMU Electrical Closet

Door Casing Brown Metal Building B10

Door Jamb Gray Metal Building B10

CMU Block Wall Green CMU Night House

CMU Block Wall Gray CMU Night House

Exterior

Door Casing Off‐White Wood Building E7

Door Jamb Olive Metal Building E8

Wall Off‐White CMU Building E8

The above table details only those building materials with painted and/or coated surfaces with a reported lead concentration greater than or equal to 1.0 mg/cm2. However, readings of the majority of painted or coated surfaces indicated a lead content between 0.1 mg/cm2 and 0.9 mg/cm2.

F&R presumes that, where materials have been documented to be LBP and where those materials are similar to other materials which have not been found to be positive, those similar materials will be considered to be LBP (i.e. where one material was analyzed and found to be positive, it is prudent to consider other similar materials positive, despite potential data to the contrary unless heterogeneity can be reasonably inferred).

Note that some positive readings were collected from metal components or CMU block walls, specifically in the animal stalls. The positive results were likely yielded as a result of the XRF reading through the surface paint coating to the lead‐based paint coated surface below.

Caulking materials associated with interior and exterior door components may additionally contain asbestos. See appropriate sections of this Report for additional details regarding asbestos content.

F&R Project Number 59A‐0135 17 April 14, 2022

4.2.1.2. Inaccessible or Presumed Lead‐Based Paint

During the conduct of this survey, testing was limited to those materials which were safely accessible and readily visible. As such, some materials should be presumed to be positive, unless sampling is conducted and shown to be negative. Such presumed LBP coated components include, but are not limited to:

Painted components within the interstitial ceiling space in each structure;

Roofing components, which were not safely accessible;

Painted components within animal enclosures, which are not represented herein and/or were not accessible at the time of F&R’s site‐visits.

4.3. Lead‐Based Paint Conclusions & Recommendations

This survey concludes that building components located on both the exterior and interior of the structures do contain lead‐based paint/coatings. Photographic documentation of select lead‐ containing paint/coatings on building materials is presented in Appendix D: Section 3. However, readings of several painted or coated surfaces indicated a detectable lead content of 0.9 mg/cm2 or below (refer to Section 4.4.1 below for details regarding OSHA requirements for lead exposure). F&R recommends that activities which may disturb such coatings be conducted following appropriate Federal and State regulations. Federal regulations with regard to worker safety and disposal requirements are summarized in the following Section – Applicable Regulations; this is not an exhaustive list.

Should additional suspect LBP coated components be discovered during renovation and/or demolition activities that have not been evaluated but will be disturbed, F&R recommends work that affects these materials be temporarily halted. Testing results of suspect coatings should be evaluated and handled accordingly prior to the resumption of renovation and/or demolition activities.

4.4. Applicable Regulations

4.4.1. OSHA Regulations for Lead‐Based Paint

While some materials tested at the site were negative for lead based paint and/or surface coatings, other painted and/or coated surfaces or materials containing lead may contain sufficient concentrations of lead, which when disturbed, may generate lead dust greater than the “Action Level” concentration of 30 micrograms per cubic meter (µg/m3) or greater than the “Permissible Exposure Limit” of 50 micrograms per cubic meter established by the OSHA “Lead Exposure in Construction Rule” (29 CFR 1926.62). The OSHA standard does not define acceptable levels of lead in paint at which no exposure to airborne lead (above the action level) would be expected; however, guidance is available for work practices which present the highest risk for

F&R Project Number 59A‐0135 18 April 14, 2022 lead exposure to workers. Rather, OSHA defines airborne concentrations and references specific types of work practices and operations from which a lead hazard may be generated (reference 29 CFR 1926.62, section d). Environmental and personnel monitoring should be conducted during removal or demolition processes (as applicable) to determine actual personal exposure.

This monitoring information can be used to determine the levels of personnel protection and environmental controls required for work involving specific removal/demolition processes on specific structures. Under OSHA requirements, the Contractor performing the work will be required to conduct this monitoring. It is important to note that environmental controls will vary dependent upon the content of lead in paint, the process used to remove it, duration of the work, and the amount of paint to be removed.

F&R recommends that workers disturbing painted (or coated) surfaces as part of this project where detectable concentrations of lead were identified receive OSHA Lead in Construction Awareness training and that engineering controls and hygiene practices described in 29 CFR

1926.62 be followed during the disturbance of painted (or coated) surfaces.

4.4.2. EPA Regulations for Lead‐Based Paint

4.4.2.1. Disposal

For disposal of construction/demolition debris, particularly material coated with LBP, testing may be required as specified by the Environmental Protection Agency (EPA) for lead content to determine proper disposal. EPA regulations require that a generator of waste determine if that waste is hazardous by performing testing in accordance with the requirements of 40 CFR 261.11 or, for wastes that may be RCRA hazardous (such as items with high lead content), the generator may assume that the waste is hazardous and comply with the hazardous waste regulation. The need for determination of disposal may be additionally subject to the disposal and/or recycling facility utilized.

Characterization of the waste stream for lead is typically performed by the collection of a sample for analysis by the toxicity characteristic leaching procedure, referred to as a TCLP. The sample should be representative of the various components of the waste stream and of a sufficient quantity to meet the testing laboratory’s requirement to provide reliable data, approximately 5 parts per million lead. Recycling of materials with LBP are generally not subject to these disposal requirements.

4.4.3 Washington D.C. Department of Energy & Environment Lead Laws and Regulations

The Washington D.C. Department of Energy & Environment (DDOE) administers lead regulations in Washington D.C. The regulations are primarily concerned with target housing and protection of children under the age of six years.

F&R Project Number 59A‐0135 19 April 14, 2022

For more information, visit the Washington D.C. Lead in the District website at:

https://doee.dc.gov/lead

4.4.4 Smithsonian Institute Policy

The Smithsonian Institute may have internal policies that regard activities that could potentially disturb lead‐based paint. The appropriate environmental division of the SI should be contacted for any additional guidance.

5.0 LIMITATIONS

This report has been prepared for the exclusive use of the Architrave PC Architects and/or their agents. This service was performed in accordance with generally accepted environmental practices. No other warranty, expressed or implied, is made. Conclusions and recommendations are based, in part, upon information provided to us by others and site observations. We have not verified the completeness or accuracy of the information provided by others, unless otherwise noted. Observations and recommendations are based upon conditions readily visible at the site at the time of the site visit, and upon current industry standards.

During this study, suspect asbestos samples were submitted for analysis at a NVLAP‐accredited laboratory via polarized light microscopy; suspect LBP was field characterized using industry standard methods and practices. Invasive and destructive sampling methods were used;

however, these were not exhaustive. Inaccessible areas, such as behind solid ceilings or behind solid walls were not surveyed; therefore, some target materials may not have been identified. As with similar surveys of this nature, actual conditions exist only at the precise locations from which samples were collected or tested. Areas inspected were limited to those designated by the scope of services by the Client. Certain inferences are based on the results of this sampling and related testing to form a professional opinion of conditions in areas beyond those from which the samples were collected. Unless otherwise noted, F&R does not claim to have performed exhaustive delineation and/or quantification of identified materials; it is the responsibility of the client or abatement contractor to verify locations and quantities of regulated materials. It is also understood that this is a not an exhaustively invasive survey so that it is possible that concealed materials may be present that were not accessible during the original survey. No other warranty, expressed or implied, is made. Reasonable effort was made by inspection personnel to locate and sample suspect materials within the structure with regard to the scope of services. However, for a facility, the existence of unique or concealed ACMs or LBP and debris is a possibility. F&R does not warrant, guarantee or profess to have the ability to locate or identify all ACMs, LBP, or other chemicals of concern in a facility.

Under this scope of services, F&R assumes no responsibility regarding response actions (e.g.

O&M Plans, Encapsulation, Abatement, Removal, Tenant Notification, etc.) initiated as a result

F&R Project Number 59A‐0135 20 April 14, 2022 of these findings. F&R assumes no liability for the duties and responsibilities of the Client with respect to compliance with appropriate regulations. Compliance with regulations and response actions are the sole responsibility of the Client and should be conducted in accordance with local, state, and/or federal requirements and should be performed by appropriately qualified and licensed/accredited personnel, as warranted.

Froehling & Robertson, Inc. by virtue of providing the services described in this report, does not assume the responsibility of the person(s) in charge of the site, or otherwise undertake responsibility for reporting to local, state, or federal public agencies conditions at the site that may present a potential danger to public health, safety, or the environment. The Client agrees to notify the appropriate local, state, or federal public agencies as required by law, or otherwise to disclose, in a timely manner, information that may be necessary to prevent danger to public health, safety, or the environment. The contents of the report should not be construed in any way as a recommendation to purchase, sell, or develop the project site. F&R retains the right to revise this report if new information is later discovered or made available. The report must be presented in its entirety.

Appendix A

F&R Personnel and Laboratory Accreditations

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