36C78619R0043-005.pdf

ASBESTOS AND LEAD BASED PAINT SURVEY

CULPEPER NATIONAL CEMETERY

305 US AVENUE

CULPEPER, VIRGINIA 22701

ECS PROJECT NO. 47:7046

FOR: MILLER-REMICK, LLC

OCTOBER 29, 2018

October 29, 2018

Mr. Bill Holden Miller-Remick, LLC 1010 Kings Highway South Cherry Hill, New Jersey 08034

ECS Project No. 47:7046

Reference: Asbestos and Lead Based Paint Survey, Culpeper National Cemetery, 305 US Avenue, Culpeper, Virginia

Dear Mr. Holden:

ECS Mid-Atlantic, LLC (ECS) is pleased to provide Miller-Remick, LLC with the results of the above referenced Asbestos and Lead Based Paint Survey performed at Culpeper National Cemetery bathroom located at 305 US Avenue in Culpeper, Virginia. This report summarizes our observations, analytical results, findings, and recommendations related to the work performed. The work described in this report was performed by ECS in general accordance with the Scope of Services described in ECS Proposal Number 47:8785-EP and the terms and conditions of the agreement authorizing those services.

ECS appreciates this opportunity to provide Miller-Remick, LLC with our services. If we can be of further assistance to you, please do not hesitate to contact us.

Sincerely, ECS Mid-Atlantic, LLC

Israel Santana, III Christopher J. Chapman, CIH Environmental Project Manager Director of Industrial Hygiene isantana@ecslimited.com cchapman@ecslimited.com 703-471-8400 804-353-6333

EXECUTIVE SUMMARY

The site is located at 305 US Avenue in Culpeper, Virginia. The site is utilized as a cemetery for US Military Veterans. The survey was conducted on the information center building for the cemetery.

The building is a one story brick building with an A-Frame roof with asphalt shingles. At the time of our survey the subject building was occupied and is currently scheduled to be have bathroom renovations.

The purpose of the survey was to determine if asbestos-containing materials (ACMs) and lead-based paints (LBPs) are present in the Men's and Women's bathroom of the building. No other areas of the building were surveyed.

Based on the laboratory analysis of the bulk samples collected during the survey no materials tested contained asbestos.

The lead-based paint survey was performed by a Commonwealth of Virginia licensed Lead Inspector.

Painted and/or glazed surfaces were assessed for lead content using a Direct-Read X-Ray Fluorescence (XRF) Spectrometer. Lead-Based Paint/Glazing was not detected on the materials tested at the time of the survey.

The executive summary is an integral portion of this report, however, ECS recommends the report be read in its entirety.

ECS Project # 47:7046

PAGETABLE OF CONTENTS

1.0 SITE DESCRIPTION

2.0 PURPOSE

3.0 METHODOLOGY

3.1 Asbestos-Containing Materials

3.2 Lead in Paint and Surface Coatings

4.0 RESULTS

4.1 Asbestos-Containing Materials

4.2 Suspect or Assumed Asbestos-Containing Materials

4.3 Lead in Paint and Surface Coatings

5.0 RECOMMENDATIONS AND REGULATORY REQUIREMENTS

5.1 Asbestos-Containing Materials

5.2 Lead in Paint and Surface Coatings

6.0 LIMITATIONS

TABLE OF APPENDICES

Appendix I: Site Photographs

Appendix II: Bulk Sampling of Suspect ACMs

Appendix III: XRF Lead-Based Paint Readings

Appendix IV: Laboratory Report(s)

Appendix V: Certifications/Licenses

1.0 SITE DESCRIPTION

The site is located at 305 US Avenue in Culpeper, Virginia. The site is utilized as a cemetery for US Military Veterans. The survey was conducted on the information center building for the cemetery.

The building is a one story brick building with an A-Frame roof with asphalt shingles. At the time of our survey the subject building was occupied and is currently scheduled to be have bathroom renovations.

2.0 PURPOSE

The purpose of the Asbestos and Lead Based Paint Survey was to identify asbestos-containing materials (ACMs) and lead-based paint (LBP) in only the bathroom of the building that is scheduled for renovations which may require special handling and/or disposal if removed during construction activities. The identification of ACMs may require trained labor, regulated work practices, and special disposal. The identification of LBP or other lead hazards may require disclosure to contractors and monitoring of lead exposure.

3.0 METHODOLOGY

ECS performed the authorized Scope of Services in general accordance with our proposal, standard industry practice(s) and methods specified by regulation(s) for the identification of ACMs and LBPs.

3.1 Asbestos-Containing Materials

The non-destructive asbestos survey was performed by asbestos inspectors who have received EPA accredited training licensed by the Commonwealth of Virginia. Samples of suspect ACMs were collected utilizing hand tools and placed into individual, labeled plastic bags. Unique bulk suspect ACM samples were submitted to EHS in Richmond, Virginia for analysis via Polarized Light Microscopy (PLM) in accordance with current EPA-600 methodology. Materials consisting of additional layers were analyzed separately. EHS is listed as an accredited laboratory by the National Voluntary Laboratory Accreditation Plan (NVLAP) managed by the National Institute of Standards and Technology (NIST) for bulk sample analysis by currently approved EPA methodology by PLM.

During the survey, ECS attempted to identify suspect ACMs in readily accessible areas. However, due to the destructive means required to identify some materials, certain areas were deemed inaccessible (i.e. behind walls or sub grade materials) and were not surveyed for suspect ACMs. Unidentified suspect ACMs may be located in these and/or other inaccessible areas.

Samples were collected in general accordance with EPA Standard 40 CFR 763 Subpart E, Asbestos Hazard Emergency Response Act (AHERA) and OSHA Standard 29 CFR 1926.1101 Inspection Protocol.

Multiple samples of each unique material were submitted. Samples were analyzed using “Positive Stop” methodology. If one sample of a homogeneous material is reported to contain asbestos, the remaining samples of that material are not analyzed. EPA regulations stipulate that if one sample contains asbestos the entire quantity of that material contains asbestos, regardless of additional analysis.

3.2 Lead in Paint and Surface Coatings

The Lead-Based Paint (LBP) survey was performed by a licensed Lead Risk Assessor using a X-Ray Fluorescence (XRF) Spectrometer to identify lead concentrations in painted and glazed surfaces.

The survey was conducted utilizing the U.S. EPA definition of LBP. Under this definition, painted surfaces which contain lead in concentrations equal to or greater than 1.0 milligrams per square centimeter (≥ 1.0 mg/cm2) are classified as coated with LBP. Paints with concentrations of lead detectable by the XRF are considered lead-containing paints. Additionally, fixtures or components that are manufactured with a factory applied glazing (i.e., sinks, toilets, ceramic tiles, etc.) are tested as these factory-applied finishes often contain lead. Activities which disturb lead-containing paints and glazing (while not lead-based paints by the U.S. EPA definition) are regulated by OSHA (29 CFR 1926.62).

Because the current or proposed use of the property is not residential or child-occupied, the scope of the LBP survey was not conducted in accordance with HUD Chapter 7 requirements. This representative survey included taking readings from walls, windows, doors, and miscellaneous components. Walls are listed by letter with wall “A” being the entrance of the subject building, proceeding clockwise to “B, C, D”, etc.

4.0 RESULTS

The following is a summary of laboratory results, findings and observations.

4.1 Asbestos-Containing Materials

None of the materials submitted for analysis to EHS were reported to contain asbestos.

Asbestos-Containing Material (ACMs) are defined as any material containing more than one percent (>1%) asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, PLM. A list of materials sampled and submitted for analysis and their reported analytical results can be found in the Appendix.

4.2 Suspect or Assumed Asbestos-Containing Materials

Due to the inaccessibility or the destructive means that asbestos sampling requires, additional suspect ACMs may remain within the building hidden behind inaccessible areas that include, but are not limited to, sub-grade walls, structural members, topping slabs, sub-grade sealants, flooring located below underlayments, areas behind exterior walls, pipe trenches, and subsurface utilities, etc.

These areas were deemed inaccessible and were not assessed.

If these materials are discovered during construction activities, they should be presumed to contain asbestos and be treated as ACMs or be sampled immediately upon discovery and prior to disturbance for asbestos content by a certified asbestos inspector in accordance with 29 CFR 1926.1101.

Based upon our past experience in the identification of ACMs in similarly constructed buildings, the following additional suspect ACMs may also be located in inaccessible areas of the structure:

• Duct mastic behind solid walls;

• Roofing Material.

4.3 Lead in Paint and Surface Coatings

Paint and surface coatings which contain detectable concentrations of lead are considered “lead-containing paints”. Since OSHA has no specific action level for lead in paint, all paint on the site found to have a measurable concentration of lead should be assumed to be lead containing. Work performed which may disturb lead-containing paint is regulated under OSHA as referenced under 29 CFR 1926.62. A total of 17 readings were collected during the survey, including calibration readings.

Some of the painted surfaces sampled contained detectable levels of lead. ECS did not detect lead based painted or glazed surfaces during the survey however.

5.0 RECOMMENDATIONS AND REGULATORY REQUIREMENTS

Based on our understanding of the purpose of the Asbestos and Lead Based Paint Survey, the results of laboratory analysis, and our findings and observations, ECS presents the following recommendations.

5.1 Asbestos-Containing Materials

None of the bulk samples submitted to EHS were reported to contain detectable concentrations of asbestos. If additional suspect asbestos-containing materials are uncovered which were not accessible during this sampling event, it is recommended that these materials be sampled or tested immediately upon discovery for asbestos content by an asbestos inspector in accordance with 29 CFR 1926.1101.

ECS notes that during the site visit a small 2' x 2' whole was cut on the drywall above the ceiling between both bathrooms to evaluate the wall cavity of the renovations area. ECS observed that the pipes were PVC material with no insulation and a duct with foil wrap insulation and mastic. ECS has assumed the duct wrap and mastic to potentially contain asbestos since we were unable to test the material. ECS recommends that this material be tested if it is to be disturbed by this project by a Virginia licensed asbestos inspector. This will involve destructive testing.

5.2 Lead in Paint and Surface Coatings

Based on the findings of this report, detectable concentrations of lead were identified on some paints and surface coatings.

The presence of lead is a concern primarily when conditions exist where it may inhaled or ingested.

Regardless of the analytical results of a material, all painted and/or glazed surfaces may still contain concentrations of lead in the paint, which when disturbed, may generate lead dust greater than the Permissible Exposure Limit (PEL) of 50 micrograms per cubic millimeter (ug/m3) as an 8-hour Time Weighted Average (TWA) established by the OSHA “Lead Exposure in Construction Rule (29 CFR 1926.62).”

The OSHA standard gives no guidance on acceptable levels of lead in paint at which no exposure to airborne lead (above the action level) would be expected. 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 any removal/demolition process (as appropriate) to verify that actual personal exposures are below the Permissible Exposure Limit (PEL) of 50 micrograms per cubic millimeter (µg/m3) as an 8-hour Time Weighted Average (TWA). Under OSHA requirements, the contractor performing renovation work will be required to conduct this monitoring and follow applicable requirements under 29 CFR 1926.62 if disturbing lead-containing paint.

6.0 LIMITATIONS

The conclusions and recommendations presented within this report are based upon a reasonable level of assessment within normal bounds and standards of professional practice for a site in this particular geographic setting. ECS is not responsible or liable for the discovery and elimination of hazards that may potentially cause damage, accidents, or injuries.

During this study, samples were submitted for analysis at an accredited laboratory via polarized light microscopy. As with any similar survey of this nature, actual conditions exist only at the precise locations from which samples were collected. 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. No warranty, expressed or implied, is made.

The observations, conclusions, and recommendations pertaining to environmental conditions at the subject site are necessarily limited to conditions observed, and/or materials reviewed at the time this study was undertaken. No warranty, expressed or implied, is made with regard to the conclusions and recommendations presented within this report. This report is provided for the exclusive use of the client. This report is not intended to be used or relied upon in connection with other projects or by other unidentified third parties without the written consent of ECS and the client.

Our recommendations are in part based on federal, state, and local regulations and guidelines. ECS does not assume the responsibility of the person(s) in charge of the site, or otherwise undertake responsibility for reporting to any local, state, or federal public agencies, any conditions at the site that may present a potential danger to public health, safety, or the environment. Under this scope of services, ECS assumes no responsibility regarding any response actions initiated as a result of these findings. General 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.

Appendix I: Site Photographs

1 - View of wall cavity between both bathrooms with Assumed Mastic Associated with Duct Work.

Appendix II: Bulk Sampling of Suspect ACMs

Culpeper National Cemetery ECS Project No. 47:7046

Sample # Sampling Location Material/Description Analytical Results

1-1A Mens Bathroom Drywall NAD

1-1B Mens Bathroom Joint Compound NAD

1-2A Womans Bathroom Drywall NAD

1-2B Womans Bathroom Joint Compound NAD

1-3A Hallway Drywall NAD

1-3B Hallway Joint Compound NAD

2-1A Hallway 2" x 2" Wall Tile NAD

2-1B Hallway Gray Grout Associated with 2" x 2" Wall Tile NAD

2-1C Hallway Off White Mortar Associated with 2" x 2" Wall Tile NAD

2-2A Mens Bathroom 2" x 2" Wall Tile NAD

2-2B Mens Bathroom Gray Grout Associated with 2" x 2" Wall Tile NAD

2-2C Mens Bathroom Off White Mortar Associated with 2" x 2" Wall Tile NAD

3-1 Mens Bathroom 2' x 2' Fissure Ceiling Tile NAD

3-2 Womans Bathroom 2' x 2' Fissure Ceiling Tile NAD

4-1 Mens Bathroom Caulk (White) Around Sink NAD

4-2 Womans Bathroom Caulk (White) Around Sink NAD

5-1A Mens Bathroom Wall Paper NAD

5-1B Mens Bathroom Joint Compoudn Associated with Wall Paper NAD

5-2A Womans Bathroom Wall Paper NAD

5-2B Womans Bathroom Joint Compoudn Associated with Wall Paper NAD

6-1 Exterior Exterior Window Caulk NAD

6-2 Exterior Exterior Window Caulk NAD

TABLE 1

BULK SAMPLING OF SUSPECT ASBESTOS-CONTAINING MATERIALS

Table Notes:

NAD = No Asbestos Detected N/A = Sample Not Analyzed; Positive Stop Bold - Asbestos Containing Materials

Appendix III: XRF Lead-Based Paint Readings

Table 2 XRF Lead Based Paint Results

Culpeper National Cemetery ECS Project No. 47:7046

Line No. Date Reading Bldg Area/Room Substrate Color Component Pb Pb +/-

1 9-Oct-18 2 VA Cemetery 1.06 0.03 2 9-Oct-18 3 VA Cemetery 1.32 0.1 3 9-Oct-18 4 VA Cemetery 1.19 0.08 4 9-Oct-18 5 VA Cemetery Hallway Metal Beige D Casing 0 0 5 9-Oct-18 6 VA Cemetery Hallway Wood Beige Door 0 0 6 9-Oct-18 7 VA Cemetery Hallway Drywall Off White Wall 0.03 0.01 7 9-Oct-18 8 VA Cemetery Women Bathroom Wood Beige W Casing 0.05 0.03 8 9-Oct-18 9 VA Cemetery Women Bathroom Wood Beige W Sash 0.06 0.08 9 9-Oct-18 10 VA Cemetery Women Bathroom Wood Red Stall Door 0.03 0.04 10 9-Oct-18 11 VA Cemetery Women Bathroom Ceramic Green Floor 0 0 11 9-Oct-18 12 VA Cemetery Men's Bathroom Ceramic Green Floor 0 0 12 9-Oct-18 13 VA Cemetery Men's Bathroom Ceramic Beige Wall 0 0.01 13 9-Oct-18 14 VA Cemetery Men's Bathroom Wood Green Stall Door 0.01 0.01 14 9-Oct-18 15 VA Cemetery Hallway Ceramic Brown Floor 0 0.01 15 9-Oct-18 16 VA Cemetery 0.86 0.06 16 9-Oct-18 17 VA Cemetery 0.87 0.06 17 9-Oct-18 18 VA Cemetery 0.8 0.06

Calibration Calibration Calibration

Calibration Calibration Calibration

Notes:

Bold - Lead Based Paint Pb - Lead in milligrams per square centimeter

Appendix IV: Laboratory Report(s)

Asbestos Bulk Analysis Report

Client:

Report Number:

Project/Test Address:

Client Number:

Reported Date:

Received Date:

Analyzed Date:

ECS Mid-Atlantic - Chantilly 10/15/2018

201119

10/16/2018

18-10-02263

7469 Whitepine Rd

Telephone: 800.347.4010

Richmond, VA 23237

Environmental Hazards Services, L.L.C.

Vet Cemetary; Culpeper, VA

Laboratory Results Fax Number:

14026 Thunderbolt Pl Suite 100 Chantilly, VA 20151

10/15/2018

Layer Type Asbestos Client Sample Number

Other Materials

Lab Gross DescriptionLab Sample Number

Client Sample Description

Off-White Brittle; Tan Fibrous; Beige Pliable to Brittle; Inhomogeneous

18-10-02263-001A

1-1

15% Cellulose 5% Fibrous Glass 80% Non-Fibrous

Drywall NAD

Drywall/Joint Compound

White Brittle; Homogeneous18-10-02263-001B

1-1

1% Cellulose 99% Non-Fibrous

Joint Comp.

NAD

Drywall/Joint Compound

Off-White Brittle; Tan Fibrous; Inhomogeneous18-10-02263-002A

1-2

15% Cellulose 5% Fibrous Glass 80% Non-Fibrous

Drywall NAD

Drywall/Joint Compound

White Brittle; Homogeneous18-10-02263-002B

1-2

1% Cellulose 1% Fibrous Glass 98% Non-Fibrous

Joint Comp.

NAD

Drywall/Joint Compound

1 of 5Page

Off-White Brittle; Tan Fibrous; Inhomogeneous18-10-02263-003A

1-3

17% Cellulose 3% Fibrous Glass 80% Non-Fibrous

Drywall NAD

Drywall/Joint Compound

White Brittle; Homogeneous18-10-02263-003B

1-3

1% Cellulose 99% Non-Fibrous

Joint Comp.

NAD

Drywall/Joint Compound

Pale Tan/Pale Gray Brittle; Light Beige Pliable;

Inhomogeneous

18-10-02263-004A

2-1

100% Non-FibrousOther * NAD

2" x 2" Wall Tile and Mastic

* Ceramic Tile/Integral Acrylic Mosaic Spacing Lug

Pale Gray Cementitious; Homogeneous18-10-02263-004B

2-1

100% Non-FibrousGrout NAD

2" x 2" Wall Tile and Mastic

Off-White Cementitious; Homogeneous18-10-02263-004C

2-1

1% Cellulose 99% Non-Fibrous

Mortar NAD

2" x 2" Wall Tile and Mastic

No mastic observed in sample.

Pale Tan/Pale Gray Brittle; Light Beige Pliable;

Inhomogeneous

18-10-02263-005A

2-2

100% Non-FibrousOther * NAD

2" x 2" Wall Tile and Mastic

* Ceramic Tile/Integral Acrylic Mosaic Spacing Lug

Pale Gray Cementitious; Homogeneous18-10-02263-005B

2-2

100% Non-FibrousGrout NAD

2" x 2" Wall Tile and Mastic

Off-White Cementitious; Homogeneous18-10-02263-005C

2-2

1% Cellulose 99% Non-Fibrous

Mortar NAD

2" x 2" Wall Tile and Mastic

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201119 18-10-02263

Vet Cemetary; Culpeper, VA

Other Materials

AsbestosLab Gross Description

Client Sample Number Client Sample Description

Lab Sample Number Layer Type

2 of 5Page

No mastic observed in sample.

Pale Gray to Pale Tan Fibrous; White Brittle;

Inhomogeneous

18-10-02263-006

3-1

40% Cellulose 35% Fibrous Glass 25% Non-Fibrous

NAD

2' x 2' Fissure Ceiling Tile

Pale Gray to Pale Tan Fibrous; White Brittle;

Inhomogeneous

18-10-02263-007

3-2

40% Cellulose 35% Fibrous Glass 25% Non-Fibrous

NAD

2' x 2' Fissure Ceiling Tile

White Pliable; Homogeneous18-10-02263-008

4-1

100% Non-FibrousNAD

Caulk (White) Around Sink

White Pliable; Homogeneous18-10-02263-009

4-2

100% Non-FibrousNAD

Caulk (White) Around Sink

Beige/Blue/Pink Vinyl-Like; White Fibrous;

Inhomogeneous

18-10-02263-010A

5-1

20% Cellulose 25% Synthetic 55% Non-Fibrous

Other * NAD

Wall Paper

* Textile-Reinforced Vinyl Wall Covering

White Brittle; Homogeneous18-10-02263-010B

5-1

2% Cellulose 1% Synthetic 97% Non-Fibrous

Other * NAD

Wall Paper

* Joint Compound-Type Substrate

Beige/Blue/Pink Vinyl-Like; White Fibrous;

Inhomogeneous

18-10-02263-011A

5-2

20% Cellulose 25% Synthetic 55% Non-Fibrous

Other * NAD

Wall Paper

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201119 18-10-02263

Vet Cemetary; Culpeper, VA

Other Materials

AsbestosLab Gross Description

Client Sample Number Client Sample Description

3 of 5Page

* Textile-Reinforced Vinyl Wall Covering

White Brittle; Homogeneous18-10-02263-011B

5-2

1% Cellulose 1% Fibrous Glass 1% Synthetic 97% Non-Fibrous

Other * NAD

Wall Paper

* Joint Compound-Type Substrate

White Pliable; Homogeneous18-10-02263-012

6-1

100% Non-FibrousNAD

Exterior Window Caulk

White Pliable; Homogeneous18-10-02263-013

6-2

1% Cellulose 99% Non-Fibrous

NAD

Exterior Window Caulk

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201119 18-10-02263

Vet Cemetary; Culpeper, VA

Other Materials

AsbestosLab Gross Description

Client Sample Number Client Sample Description

4 of 5Page

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201119 18-10-02263

Vet Cemetary; Culpeper, VA

Other Materials

AsbestosLab Gross Description

Client Sample Number Client Sample Description

Lab Sample Number Layer Type

Missy Kanode

1% Asbestos

Analyst:

Reporting Limit:

Method:

QC Blank:

QC Sample:

Mark Case

EPA Method 600/R-93/116, EPA Method 600/M4-82-020

QA/QC Clerk

Reviewed By Authorized Signatory:

28-M12010-2

SRM 1866 Fiberglass

NAD = no asbestos detectedLEGEND:

The condition of the samples analyzed was acceptable upon receipt per laboratory protocol unless otherwise noted on this report. Each distinct component in an inhomogeneous sample was analyzed separately and reported as a composite. Results represent the analysis of samples submitted by the client. Sample location, description, area, volume, etc., was provided by the client. This report cannot be used by the client to claim product endorsement by NVLAP or any agency of the U.S. Government. This report shall not be reproduced except in full, without the written consent of the

Environmental Hazards Service, L.L.C. California Certification #2319 NY ELAP #11714 NVLAP #101882-0 VELAP 460172. All information concerning sampling location, date, and time can be found on Chain-of-Custody. Environmental Hazards Services, L.L.C. does not perform any sample collection.

Environmental Hazards Services, L.L.C. recommends reanalysis by point count (for more accurate quantification) or Transmission Electron Microscopy

(TEM), (for enhanced detection capabilities) for materials regulated by EPA NESHAP (National Emission Standards for Hazardous Air Pollutants) and found to contain less than ten percent (<10%) asbestos by polarized light microscopy (PLM). Both services are available for an additional fee.

400 Point Count Analysis, where noted, performed per EPA Method 600/R-93/116 with a Reporting Limit of 0.25%.

* All California samples analyzed by Polarized Light Microscopy, EPA Method 600/M4-82-020, Dec. 1982.

5 of 5Page

Appendix V: Certifications/ Licenses