1800 F Phase 2 Modernization Feasibility Study_Final Hazmat Report 02-06-2026.pdf

PHASE 2 FEASIBILITY ASSESSMENT

GSA HEADQUARTERS

1800 F STREET NW

WASHINGTON, DISTRICT OF COLUMBIA 20270

ECS PROJECT NO. 47:22408

FOR: SHALOM BARANES ASSOCIATES

NOVEMBER 20, 2025

REVISED:FEBRUARY 6, 2026

Nicholas G. Sapio Michael K. Smith, CSP Environmental Staff Project Manager Environmental Principal nsapio@ecslimited.com mksmith@ecslimited.com 703-471-8400 717-767-4788

November 20, 2025 Revised: December 31, 2025

Revised February 6, 2026

Ms. Melissa Hendrix Shalom Baranes Associates 1010 Wisconsin Avenue, NW Suite 900 Washington, District of Columbia 20007 mhendrix@sbaranes.com

ECS Project No. 47:22408

Reference: Phase 2 Feasibility Assessment, GSA Headquarters, 1800 F Street NW, Washington, District of Columbia

Dear Ms. Hendrix:

ECS Mid-Atlantic, LLC (ECS) is pleased to provide Shalom Baranes Associates with the observations and results of the above referenced Phase 2 Feasibility Assessment performed at GSA Headquarters located at 1800 F Street NW in Washington, District of Columbia. 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 47:39846 and the terms and conditions of the agreement authorizing those services.

ECS appreciates this opportunity to provide Shalom Baranes Associates with our services. If we can be of further assistance to you, please do not hesitate to contact us.

Sincerely, ECS Mid-Atlantic, LLC

14026 Thunderbolt Place, Suite 100, Chantilly, Virginia 20151 • T:703-471-8400 ECS Florida, LLC • ECS Mid-Atlantic LLC • ECS Midwest, LLC • ECS Pacific, Inc. • ECS Southeast, LLC • ECS Southwest, LLP

ECS New York Engineering, PLLC - An Associate of ECS Group of Companies • ecslimited.com

"ONE FIRM. ONE MISSION."

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

3.3 Universal Waste and Suspect Liquid PCB-Containing Equipment

4.0 RESULTS

4.1 Asbestos Sampling and Verification

4.2 Suspect or Assumed Asbestos-Containing Materials

4.3 Lead in Paint and Surface Coatings

4.4 Universal Waste and Liquid Suspect PCB-Containing Equipment

4.4.1 Suspect Polychlorinated Biphenyl (PCB) Containing Ballasts and Equipment

4.4.2 Mercury-Containing Components

4.4.3 Lead-Acid Batteries

5.0 RECOMMENDATIONS AND REGULATORY REQUIREMENTS

5.1 Asbestos-Containing Materials

5.2 Lead in Paint and Surface Coatings

5.3 Universal Waste and Liquid PCBs in Equipment

5.4 Radon

5.5 Gap Analysis

6.0 LIMITATIONS

TABLE OF APPENDICES

Appendix I: Site Photographs

Appendix II: Asbestos Bulk Sample Results

Appendix III: Laboratory Report(s)

Appendix IV: Previous Reports

November 20, 2025 ii

1.0 SITE DESCRIPTION

The subject property is improved with a nine-story GSA Headquarters building located at 1800 F Street NW in Washington,District of Columbia 20270. The building was reportedly originally constructed in 1917, and has undergone several renovations throughout its history. The Phase I renovations were reportedly completed in 2013, included the enclosure of the east courtyard, complete renovation of Wings 1 and 2, additional sustainability features, and major mechanical system upgrades. Based on information provided by the client, ECS understands that the Phase II project will consist of extensive renovations to Wings 0 and 3 of the subject building, as well as build-out of a new child care facility location. In addition, the Phase II Modernization will include updates to Heating, Ventilation, and Air Conditioning (HVAC) systems, electrical systems, and exterior repairs and restoration.

ECS was provided with several previous hazardous materials reports for the building. The asbestos reports included the Hazardous Materials Pre-Construction Survey for the Modernization Project by Cape dated May 2005; additional plaster sampling data by Cape dated June 2006; plaster sampling data by Tidewater Environmental Engineering, Inc. dated July 2006; and an Operations and Maintenance Inspection Report by Global Consulting, Inc. (Global) dated December 31, 2024.

Additionally, ECS was provided with a Lead-Based Paint Survey Report prepared by High Sierra, dated July 31, 2023. These reports, which contain previously identified asbestos-containing materials and lead-based paint readings, are appended to this report. The Hazardous Materials Pre-Construction Survey for the Modernization Project also contained the identification and location of mercury-containing lamps and suspect PCB-containing lamp ballasts.

According to the report provided by Global, the following materials were identified as asbestos-containing:

1. Pipe insulation

2. Pipe Fittings

3. AHU Insulation

4. 12" x 12" Floor Tile (White with Small Holes Pattern) Under Carpet

5. 9" x 9" Floor Tile (Red with Light Gray Streaks)

6. 9" x 9" Floor Tile (Gray with Dark Gray/Black Streaks

7. 9" x 9" Floor Tile (ash-Gray with Dark Gray Streaks)

8. Mastic Daubs (Brown) Associated with 1' x 1' Ceiling Tiles

9. Window Caulking

10. 9" x 9" Floor Tile (Beige with Brown and Pink Streaks)

11. 9" x 9" Floor Tile (Light Gray with Black Streaks)

November 20, 2025

ECS Project # 47:22408

12. 12" x 12" Floor Tile (Beige)

13. 9" x 9" Floor Tile (Tan - Painted Red) and Asssociated Black Mastic

14. 9" x 9" Floor Tile (Beige with Black shades) and Associated Black Mastic

15. Floor Tile (Off-White, Unknown Size - under Black Vinyl Tile)

16. Floor Tile (Light Green, Unknown Size - under Off-White Vinyl Tile)

17. 9" x 9" Floor Tile (Red with Black Streaks) under 12" x 12" Floor Tile (White with Small Holes Pattern)

18. 12" x 12" Floor Tile (Beige with Red/Brown Streaks)

19. 9" x 9" Floor Tile (Beige with Black Streaks - under 12" x 12") with Asssociated Black Mastic

20. Underlying Floor Tile (Unknown size, White/Gray) and Associated Tan Mastic)

21. 9" x 9" Floor Tile (Gray with Streaks)

According to the report provided by High Sierra, the following material was identified to have lead-based paint/coating:

1. White Painted Wood Window Sash

2.0 PURPOSE

The purpose of the survey was to identify asbestos-containing materials (ACMs), and verify the presence of previously documented ACMs, LBPs, universal waste and suspect liquid poly-chlorinated biphenyl (PCB) containing equipment in fixtures which require special handling and/or disposal if disturbed during construction activities. The identification of ACMs require trained labor, regulated work practices, and special disposal. The identification of LBP or other lead hazards requires disclosure to contractors and monitoring of lead exposure. The identification of other regulated materials such as universal waste may require personal protective equipment, training, special handling, packaging, and disposal. The survey was limited to interior portions of Wings 0 & 3 within the subject building.

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, LBPs, and universal waste and suspect liquid PCB-containing equipment and fixtures.

3.1 Asbestos-Containing Materials

The limited non-invasive asbestos survey was performed on November 17, 2025 by asbestos inspector Mr. Nicholas Sapio, who has received EPA-accredited training required by District of Columbia regulations. Samples of suspect ACMs were collected utilizing hand tools and placed into

November 20, 2025 individual, labeled plastic bags. Unique bulk suspect ACM samples were submitted to Scientific Analytical Institute (SAI) in Greensboro, North Carolina for analysis via Polarized Light Microscopy (PLM) in accordance with current EPA-600 methodology. Materials consisting of additional layers were analyzed separately. SAI 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 the “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

During the site visit, ECS reviewed the existing and planned construction documents for the Phase II project, which will include a new child-care center. ECS intended to perform lead paint testing on existing materials that would remain in the future child care center. However, the demolition plans for the library (prposed day care location) indicated that all existing accessible finish materials were scheduled to be demolished, with the exception of the windows, which had already been tested and found to contain lead-based paint. ECS was unable to access structural materials scheduled to remain (located behind walls or above ceilings). Portions of the south wall and the wall adjacent to the stairwell were shown to remain at the ground floor and basement levels; however, this wall was finished with wood paneling that was scheduled to be demolished, and ECS was unable to access materials behind the wood paneling. Based on these conditions, ECS did not collect paint chip samples or use an X-ray fluorescence (XRF) Spectrometer to identify lead-based paint (LBP) during the survey.

3.3 Universal Waste and Suspect Liquid PCB-Containing Equipment

ECS performed a visual survey of the interior for the presence of universal waste materials and suspect liquid PCB-containing equipment. ECS entered the accessible areas to identify universal waste materials, including batteries, mercury-containing equipment, and lamps. Additionally, lamp ballasts suspected of containing PCBs and lead-containing equipment were documented if observed.

No sampling or other characterization was performed as part of this scope of service. Additionally, ECS did not access any energized electrical equipment or other equipment/devices that were in use or that may pose a hazard to ECS personnel or building occupants.

November 20, 2025

4.0 RESULTS

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

4.1 Asbestos Sampling and Verification

In total, 10 bulk samples from five (5) homogeneous areas were submitted to the laboratory, of which 16 layers were analyzed.

An ACM is defined as any material containing more than one percent (>1%) asbestos as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM. The U.S. EPA categorizes ACM as follows:

• Friable ACMs are defined as any ACM that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable ACMs are defined as any ACM that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

• Category I non-friable ACM includes packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than one percent (>1%) asbestos.

• Category II non-friable ACM includes any material, excluding Category I non-friable ACM, containing more than one percent (>1%) asbestos.

Regulated Asbestos Containing Materials (RACM) are friable ACM or non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or has crumbled, been pulverized, or reduced to powder in the course of renovation and/or demolition operations.

SAI submitted a signed final laboratory report to ECS on November 20, 2025. In summary, none of the bulk samples submitted for analysis were reported to contain asbestos in detectable concentrations. A complete list of the sampled materials submitted for analysis and sample locations is appended to this report. Photographs of representative building materials are appended to this report.

In addition to bulk sampling, ECS performed an asbestos verification walk-through of various areas within the proposed Phase 2 asbestos abatement plan. Based on the client provided asbestos abatement plans, the following asbestos-containing materials were observed:

1. Asbestos-Containing Floor Tile and Mastic - Various areas throughout Wing 3 of the 5th floor, Wing 3 of 2nd Floor and Wing 0 on the Ground Floor.

2. Asbestos-Containing Floor Tile and Non Asbestos-Containing Mastic - Various areas throughout Wings 0 and 3 on the 7th Floor, Wing 3 on the 5th Floor, Wing Three on the 1st Floor, Wings 3 and 0 on the Ground Floor, Wing 0 within the Basement and the Basement of the Library.

3. Asbestos-Contaminated Carpet and Asbestos-Containing Carpet Mastic - Various areas throughout Wing 3 and the Library on the 1st Floor.

November 20, 2025

4. Asbestos-Contaminated Carpet and Asbestos-Containing Carpet Mastic with Asbestos-Contaminated Floor-Tile and Mastic Underneath - Various areas throughout Wing 3 on the 1st Floor, Wing 3 on the 4th Floor, and Wings 0 and 3 on the Ground Floor.

5. Asbestos-Contaminated Carpet and Asbestos-Containing Carpet Mastic with Asbestos-Containing or Contaminated Flooring Underneath - Various areas throughout Wing 3 on the 7th Floor, Wing 3 on the 4th Floor, Wing 0 on the 2nd Floor, the Library on the 1st Floor, and Wing 3 on the Ground Floor.

6. Asbestos-Containing Floor Tile and Mastic Underneath Non Asbestos-Containing Floor Tile and Mastic - Various areas throughout Wing 0 in the Basement.

7. Residual Asbestos-Containing Mastic - Various areas throughout Wing 0 in the Basement.

8. Asbestos-Containing Pipe Insulation and Fitting Insulation - Custodial Closets in Wing 0 on the 6th and 2nd Floor.

9. Duct Insulation with Asbestos-Containing Canvas Wrap on Cork, Asbestos-Contaminated Cork, and Asbestos-Containing Black Mastic - Library (Mid and Upper Levels).

Asbestos verification performed by ECS throughout this survey was not comprehensive of all identified asbestos-containing materials within previous survey reports and asbestos abatement plans. Please note that the above-referenced ACMs, other identified ACMs, and/or assumed ACMs should be assumed present in other areas of the building not surveyed by ECS.

4.2 Suspect or Assumed Asbestos-Containing Materials

During the survey, some portions of the study area were locked and not able to be accessed by ECS.

These areas were deemed inaccessible and were not assessed. The locked areas included:

• Fifth floor Wing 0/3, corner office suite in the northwest corner

• Third floor Wing 0, north side of corridor, offices between Column Line 13 and 21

• Basement Wing 3, west side of corridor, offices between Column Line B and H

Based on the substantial agreement between the existing survey documents, the project drawings, and the conditions observed on site, ECS would not anticipate that these previously surveyed areas would have conditions that differ significantly from the existing Modernization project documents.

Due to the inaccessibility or the destructive means that asbestos sampling requires, additional suspect ACMs may remain within the building, hidden within 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.

Based upon our 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:

November 20, 2025

• Asbestos Cement or Insulators in electrical panels and systems

• Elevator Components in elevators (Panels, Brake Shoes, Roping, etc.)

• Fire Door and associated Casing Insulation in locations requiring a rated fire door and door casing

• Light Shield Insulation in light shields

• Thermal System Insulation (TSI) on pipes within chases behind walls and above ceilings not previously abated

• Waterproofing Membrane/Mastics/vapor barriers within exterior wall cavities, behind interior finishes, exterior veneer and/or subgrade walls

• Materials not included in the study scope of work

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

4.3 Lead in Paint and Surface Coatings

Effective July of 2013, the District of Columbia defines lead-based paint as any paint or other surface coatings that contain lead greater than or equal to 0.7 mg/cm2 or 0.5% by weight. These standards are enforceable in the District of Columbia pursuant to D.C official code § 8-231.01 (20).

However, the Lead-Based Paint Survey Report prepared by High Sierra, dated July 31, 2023, lists a threshold for the definition of lead-based paint in the District of Columbia at 1.0 mg/cm2. ECS reviewed the Lead-Based Paint Survey Report prepared by High Sierra and compared results to the updated District of Columbia definition of lead-based paint. The previous LBP survey of the ground floor did not identify LBP, with the exception of three (3) window sashes located in rooms 1026, 1028, and 1030. Therefore, based on EPA and DC regulations, any window sashes included in the proposed renovations should be considered LBP and handled accordingly.

4.4 Universal Waste and Liquid Suspect PCB-Containing Equipment

The disposal of fixtures and equipment in buildings that contain various substances such as mercury or lead is regulated by local, state, and federal regulations. Collectively, most mercury-containing materials and batteries, which may contain lead, along with stored pesticides, are classified as "Universal Waste". The disposal of lamp ballasts and electrical transformers that contain suspect PCB-containing oils is also regulated at the state and federal levels.

4.4.1 Suspect Polychlorinated Biphenyl (PCB) Containing Ballasts and Equipment

Polychlorinated biphenyls (PCBs) are toxic coolants or lubricating oils used in some electrical transformers and capacitors, hydraulically operated equipment, light ballasts, and other similar equipment.

As part of our survey, ECS attempted to identify potential liquid PCB-containing materials and equipment. At the time of the survey, ECS visually observed fluorescent light ballasts in accessible areas of the structure in an attempt to identify labeling indicating the presence/absence of

November 20, 2025

PCB-containing fluids. Fluorescent light fixture locations observed were substantially similar to those provided in the PCB abatement plan drawings, with the exception of some renovations observed on the 7th floor. Labeling was not observed on the ballasts that were accessible to be surveyed.

As indicated on the Phase II Modernization project drawings, it is recommended that all ballasts be assumed to be PCB-containing during renovation and disposal.

4.4.2 Mercury-Containing Components

The EPA classifies mercury as both hazardous and toxic. The survey included observations for equipment that could contain mercury, such as thermostats, transformers, fluorescent lamps, and switch-containing devices.

As previously discussed, fluorescent lamps were observed. The fluorescent lamps may contain small quantities of mercury. As indicated on the project drawings, all fluorescent lamps should be handled and disposed as mercury-containing.

4.4.3 Lead-Acid Batteries

Lead-acid batteries located in emergency lamps, exit signs, alarm panels, and associated with electrical components, etc., were observed or are assumed to be present. No evidence of leaking or damage was observed at the time of the survey.

5.0 RECOMMENDATIONS AND REGULATORY REQUIREMENTS

Based on our understanding of the purpose of the survey, the results of laboratory analysis, and our findings and observations, ECS presents the following recommendations.

5.1 Asbestos-Containing Materials

ECS recommends that, where a material type has been identified as asbestos-containing,, other materials with similar color, texture, age, and size throughout the building’s interior and exterior be assumed to contain asbestos. Please refer to Section 1.0 and 4.1 for a complete list of building materials previously reported positive for asbestos and Section 4.2 for materials assumed to contain asbestos. Identified ACMs must be removed, encapsulated, or enclosed before disturbance of the materials.

ECS observed that the remaining asbestos-containing materials were substantially similar to those identified in the 2006 project drawings reviewed during the survey. Based on the similarity of the findings, ECS does not recommend revised drawings be prepared. However, the GSA specification templates for handling and disposal of asbestos-containing materials have been significantly modified since 2006. Based on these revisions, ECS recommends that an updated project specification be prepared to delineate known and suspect asbestos-containing materials in the building and to outline proper procedures for the abatement. This will help protect the government's liability by better defining the scope of work and contractors’ roles and responsibilities in the abatement process and holding the contractor accountable for the performance of the project.

The specification typically defines the Contractor’s scope of work and outlines requirements and procedures that must be followed for the project. The intent of the specification is to give

November 20, 2025 performance requirements for the Contractor so that the project can be completed safely and in compliance with applicable federal and state regulations and guidelines, as well as additional project-specific requirements.

In accordance with regulations and GSA specification requirements, removal or disturbance of asbestos-containing materials should be performed by a District of Columbia licensed asbestos abatement contractor. In addition, an asbestos project monitor/industrial hygienist shall perform observations of the asbestos abatement project for general compliance with applicable asbestos regulations, document completion of work, and perform air monitoring/final clearance air testing as needed. ECS can provide this service on behalf of the government if requested.

A notification will be required by the District of Columbia Department of Energy and Environment (DOEE) and the US EPA prior to beginning the abatement project. The District of Columbia and the EPA require 10 working days notice prior to abatement of regulated asbestos-containing materials (RACMs). This is the responsibility of the abatement firm retained for this project. Building owners or designated representatives must also inform occupants no less than 30 days prior to the commencement of asbestos abatement. Requests for a waiver from this requirement must be submitted in writing to DOEE. Except in emergency situations, notices of asbestos abatement work must be posted at least three (3) days before work commences (3-day Asbestos Project Notice).

Notices must be posted immediately outside all entrances and exits from the work site of asbestos abatement.

Suspect ACMs not observed due to inaccessibility or not sampled due to the destructive means that sampling would require may also be encountered during construction activities. At the time of the survey, only limited destructive means were used to locate or sample suspect ACMs; therefore, additional suspect ACMs may remain within inaccessible areas that include, but are not limited to, sub-grade walls, structural members, topping slabs, exterior areas, sub-grade sealants, flooring located below underlayments, vapor barriers, pipe trenches, and other subsurface utilities, etc.. If additional suspect ACMs are uncovered that were not accessible during this survey, in accordance with 29 CFR 1926.1101, it is recommended that these materials either 1) be assumed to contain asbestos; or 2) be sampled before disturbance upon discovery for asbestos content by an asbestos inspector.

Should any identified ACM remain in place, ECS recommends the development and implementation of a site-specific Asbestos Operations and Maintenance Plan detailing routine maintenance and repair operations, contractor notification procedures, and all other requirements under OSHA – reference 29 CFR 1926.1101.

5.2 Lead in Paint and Surface Coatings

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

ECS understands that a portion of the building within the scope of this project will be used as a daycare and will be defined as a child-occupied facility. Based on District of Columbia regulations, the project may be defined as a Lead Project. The District of Columbia includes construction projects located within 100 feet of a child-occupied facility as potentially subject to a lead activity permit. The

November 20, 2025

DC Department of Energy and Environment (DOEE) encourages property owners and/or construction contractors to complete and submit a voluntary lead activity notification form prior to renovation, repair, or demolition projects in structures constructed prior to 1978 to determine if a lead renovation or lead abatement permit will be required.

Per U.S. EPA Regulations (40 CFR 745) under the Renovation, Repair, and Painting (RRP) Rule, all work that will involve window replacement, the demolition of painted surfaces, or disturbance of lead paint in excess of six (6) square feet per interior room or 20 square feet of exterior space must follow the RRP Rule. This rule applies to target housing and child-occupied facilities. Should this scenario be relevant now or in the future, a work plan is recommended to be prepared prior to the start of work to outline general requirements under RRP regulations and to specify contractor requirements, including certification by the U.S. EPA under the RRP Rule.

The presence of lead is a concern primarily when conditions exist where it may be 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 meter (µg/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 that may generate a lead hazard (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 µg/m3 as an 8-hour 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.

Lead-containing materials may be classified as hazardous waste if the lead content exceeds disposal criteria. ECS recommends that the contractor collect representative samples of the demolition/ renovation waste stream and have them analyzed using the EPA Toxicity Characteristic Leaching Procedure (TCLP) analysis before debris is disposed of from the site. The purpose of the laboratory testing is to verify and document that the waste stream contains lead concentrations of less than five parts per million (ppm) and is, therefore, not regulated hazardous waste.

5.3 Universal Waste and Liquid PCBs in Equipment

Fluorescent lamp ballasts manufactured prior to 1979 may contain small quantities of PCBs.

Additionally, regardless of “PCB" labeling, ballasts produced between 1980 and 1991 may contain di-ethyl hexyl phthalate (DEHP), which is classified as a potential carcinogen by the EPA. Additionally, DEHP contamination on Superfund sites is common and responsible parties are subject to liability under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) should cleanup of DEHP be necessary. ECS recommends that all ballasts suspected to contain PCBs be properly recycled or disposed of in accordance with US EPA and regulations. In practice many

November 20, 2025

ECS Project # 47:22408 https://octo.quickbase.com/db/bpyvr9wmv?a=nwr&ifv=1 ballasts lacking the "No-PCBs" label have been removed from buildings as part of routine maintenance; however, inspection of each ballast by the contractor performing removal is still recommended to ensure proper disposal into the proper waste stream.

ECS recommends that fluorescent lamp tubes/bulbs suspected to contain mercury be properly recycled or disposed of in accordance with EPA and District of Columbia regulations. Recycling is the most environmental friendly means of disposal for these materials. Fluorescent lamps may be disposed as universal waste if they remain unbroken during removal. If bulbs are crushed or broken prior to disposal, they are classified as hazardous waste by the EPA.

The disposal of universal waste and lamp ballasts must be performed in a manner by which the individual wastes are segregated and disposed of properly as required by federal regulations. If any of these materials are observed to be leaking or otherwise damaged prior to disposal they must be disposed of as hazardous waste in accordance with EPA regulations. Handling, packaging, labeling, and disposal of hazardous materials should be performed in accordance with EPA and Department of Transportation regulations.

Generators of universal and hazardous waste must obtain an EPA Generator ID number in order to dispose of these materials.

5.4 Radon

ECS reviewed a Ninety Day Radon Sampling Report by Aerosol Monitoring and Analysis, Inc. (AMA) dated June 4, 1994. The radon measurement concentrations during these measurement events ranged between 0.3 to 1.8 pCi/L. The ANSI/AARST guidelines state that if the initial measurement result is above the action level of 4.0 pCi/L, follow-up testing and/or remediation is recommended.

Radon testing should also be conducted when any of the following circumstances occur:

• A new addition is constructed, or alterations for building reconfiguration or rehabilitation occur;

• A ground contact unit not previously tested is occupied, or a building is newly occupied;

• Heating or cooling systems are significantly altered, resulting in changes to air pressures or pressure relationships;

• Ventilation is significantly altered by extensive weatherization, changes to mechanical systems, or comparable procedures;

• Significant openings in soil occur due to groundwater or slab surface water control systems that are altered or added or natural settlement, causing major cracks to develop;

• Earthquakes or construction blasting, fracking, or formation of sinkholes nearby; or,

• A mitigation system is altered, modified, or repaired.

The US EPA also recommends that if future renovation work alters the buildings, additional re-testing should be considered for re-occupancy, especially if this alters airflow patterns in the building(s).

November 20, 2025

5.5 Gap Analysis

As part of this Feasibility Study, ECS reviewed historical documentation, including the previous Hazardous Material Survey for the Phase I and II Modernization, an Operations and Maintenance Inspection Report by Global, a Lead-Based Paint Survey Report prepared by High Sierra, and a Ninety-Day Radon Sampling Report by Aerosol Monitoring and Analysis. Additionally, client-provided hazardous material abatement and demolition drawings from 2010 for the initially scheduled Phase II Modernization Project were reviewed prior to and during ECS' site visit.

Based on observations and findings from the site visit conducted on November 17, 2025, ECS determined that the identified existing asbestos-containing materials, lead-based paint, mercury-containing articles, and suspect PCB-containing lighting ballasts were substantially similar to those documented in the previous reports and asbestos and PCB abatement plan drawings reviewed.

ECS noted that portions of Wing 3 and portions of Wing 0 on the seventh floor were renovated since the 2006 project documents were created. Overall, the few renovations that have occurred between the 2006 project documents would be expected to very slightly reduce the actual amount of mercury-containing lamps and PCB-containing ballasts to be segregated and disposed; however, the asbestos-containing material quantities would not expect to be reduced in a noticable amount given the scale of the project.

Since the time of the 2010 project documents, the GSA specification templates for handling and disposal of asbestos-containing materials, lead-based paint, mercury-containing articles, and PCB-containing ballasts have been significantly modified. Based on these revisions, ECS recommends that updated project specification sections be prepared to outline proper procedures for handling and disposal of these materials.

Since the time of the 2010 project documents, the DC lead laws have been revised, and the project may be required to seek a DC Lead Activity Permit. This would require lead surface wipe sampling within and adjacent to the project area following completion of the demolition. The DC and US EPA lead surface wipe clearance standards have been significantly reduced. This may require additional cleaning efforts by the contractor to meet the revised clearance criteria. The new levels are frequently causing repeated rounds of cleaning and re-testing. The burden of meeting lead wipe clearance criteria should be placed on the contractor to protect the government, the architect, and other government-contracted parties from potential cost implications.

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.

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

November 20, 2025 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.

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.

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.

November 20, 2025

Appendix I: Site Photographs

1 - View of Previously Identified Asbestos-Containing Flooring Materials - Basement

2 - View of Non Asbestos-Containing 12"x12" Black with White Streaks Vinyl Floor Tile (ECS Sample #'s 9 & 10)

ECS Project No. 47:22408

3 - View of Non Asbestos-Containing White with Gold Speck and Gray with Green Speck Floor Tile and associated White Mastic and Leveling Compound (ECS Sample #'s 3 through 8)

4 - View of Previously Identified Asbestos-Containing Flooring Materials - Library Basement

5 - View of Previously Identified Asbestos-Containing Flooring Materials - Ground Floor

6 - View of Previously Identified Asbestos-Containing Flooring Materials - 1st Floor

7 - View of Asbestos-Containing Canvas Duct Insulation Wrap - Library (Upper and Mid Level)

8 - View of Previously Identified Asbestos-Containing Flooring Materials - 2nd Floor

9 - View of Previously Identified Asbestos-Containing Flooring Materials - 4th Floor

10 - View of Previously Identified Asbestos-Containing Pipe Insulation and Pipe Fittings - 6th Floor Custodial Closet

11 - View of Previously Identified Asbestos-Containing Flooring Materials - 7th Floor

Appendix II: Asbestos Bulk Sample Results

GSA HQ Modernization Phase 2 Feasibility Study - ACM Bulk Table ACM Bulk Sample Results ECS Project No.47:22408

Site Visit: November 17, 2025

Sample # Sampling Location Material/Description Layer Analyzed/Lab Notes Analytical Results

1 Mechanical Room Across Room 1310 Green HVAC Duct Pin Mastic None Detected

2 Mechanical Room Across Room 1310 Green HVAC Duct Pin Mastic None Detected

3 - A Library Emergency Stairwell Gray and Green Speck Floor Tile with associated White Mastic Tile None Detected

3 - B Library Emergency Stairwell Gray and Green Speck Floor Tile with associated White Mastic Mastic None Detected

4 - A Library Emergency Stairwell Gray and Green Speck Floor Tile with associated White Mastic Tile None Detected

4 - B Library Emergency Stairwell Gray and Green Speck Floor Tile with associated White Mastic Mastic None Detected

5 - A Library Emergency Stairwell White and Gold Speck Floor Tile with associated White Mastic Tile None Detected

5 - B Library Emergency Stairwell White and Gold Speck Floor Tile with associated White Mastic Mastic None Detected

6 - A Library Emergency Stairwell White and Gold Speck Floor Tile with associated White Mastic Tile None Detected

6 - B Library Emergency Stairwell White and Gold Speck Floor Tile with associated White Mastic Mastic None Detected

7 Library Emergency Stairwell Gray Leveling Compound None Detected

8 Library Emergency Stairwell Gray Leveling Compound None Detected

9 - A Hallway Outside Room B-212A 12"x12" Black with White Streak Vinyl Floor Tile and associated Back Mastic Tile None Detected

9 - B Hallway Outside Room B-212A 12"x12" Black with White Streak Vinyl Floor Tile and associated Back Mastic Mastic None Detected

10 - A Hallway Outside Room B-212A 12"x12" Black with White Streak Vinyl Floor Tile and associated Back Mastic Tile None Detected

10 - B Hallway Outside Room B-212A 12"x12" Black with White Streak Vinyl Floor Tile and associated Back Mastic Mastic None Detected

SUSPECT ASBESTOS-CONTAINING MATERIALS BULK SAMPLING RESULTS

Table Notes:

Bold = Asbestos-Containing Materials N/A = Not Analyzed None Detected = No Asbestos Detected

Appendix III: Laboratory Report(s)

Bulk Asbestos Analysis By Polarized Light Microscopy EPA Method: 600/R-93/116 and

40 CFR, Part 763, Subpart E, App.E

Lab Order ID:Attn: 10096871Customer: ECS Mid-Atlantic, LLC 14026 Thunderbolt Place Chantilly, VA 20151

Analysis:

Date Received:

Bobby Rhett

PLM

11/18/2025

Project: 47:22408 GSA HQ Modernization Hazmat 1800 F St NW, Washington, DC 202710

Date Reported: 11/20/2025

Sample ID

Lab Sample ID

Description

Lab Notes Asbestos

Fibrous Components

Non-Fibrous Components Treatment

Attributes

10096871_0001

Green HVAC Duct Pin Mastic

None Detected 100% Other

Non-Fibrous

Dissolved

Green

Homogeneous

10096871_0002

Green HVAC Duct Pin Mastic

None Detected 100% Other

Non-Fibrous

Dissolved

Green

Homogeneous

3 - A

10096871_0003

Gray and Green Speck Floor Tile with associated White

Mastic None Detected 100% Other

Non-Fibrous

Dissolved

Gray, Green

Homogeneous tile

3 - B

10096871_0011

Gray and Green Speck Floor Tile with associated White

Mastic None Detected 100% Other

Non-Fibrous

Dissolved

White

Homogeneous mastic

4 - A

10096871_0004

Gray and Green Speck Floor Tile with associated White

Mastic None Detected 100% Other

Non-Fibrous

Dissolved

Gray, Green

Homogeneous tile

4 - B

10096871_0012

Gray and Green Speck Floor Tile with associated White

Mastic None Detected 100% Other

Non-Fibrous

Dissolved

White

Homogeneous mastic

5 - A

10096871_0005

White and Gold Speck Floor Tile with associated White

Mastic None Detected 100% Other

Non-Fibrous

Dissolved

White, Gold

Homogeneous tile

5 - B

10096871_0013

White and Gold Speck Floor Tile with associated White

Mastic None Detected 100% Other

Non-Fibrous

Dissolved

White

Homogeneous mastic

Disclaimer: Due to the nature of the EPA 600 method, asbestos may not be detected in samples containing low levels of asbestos. We strongly recommend that analysis of floor tiles, vermiculite, and/or heterogenous soil samples be conducted by TEM for confirmation of "None Detected" by PLM. This report relates only to the samples tested and may not be reproduced, except in full, without the written approval of SAI. This report may not be used by the client to claim product endorsement by NVLAP or any other agency of the U.S. government. Analytical uncertainty available upon request. Scientific Analytical Institute participates in the NVLAP Proficiency Testing program.

Unless otherwise noted blank sample correction was not performed. Estimated MDL is 0.1%.

Heather Boykin (16)

Analyst Approved Signatory

Page 1 of 2P-F-002 r15 1/15/2028 Scientific Analytical Institute, Inc. 4604 Dundas Dr. Greensboro, NC 27407 (336) 292-3888

Bulk Asbestos Analysis By Polarized Light Microscopy EPA Method: 600/R-93/116 and

40 CFR, Part 763, Subpart E, App.E

Lab Order ID:Attn: 10096871Customer: ECS Mid-Atlantic, LLC 14026 Thunderbolt Place Chantilly, VA 20151

Analysis:

Date Received:

Bobby Rhett

PLM

11/18/2025

Project: 47:22408 GSA HQ Modernization Hazmat 1800 F St NW, Washington, DC 202710

Date Reported: 11/20/2025

Sample ID

Lab Sample ID

Description

Lab Notes Asbestos

Fibrous Components

Non-Fibrous Components Treatment

Attributes

6 - A

10096871_0006

White and Gold Speck Floor Tile with associated White

Mastic None Detected 100% Other

Non-Fibrous

Dissolved

White, Gold

Homogeneous tile

6 - B

10096871_0014

White and Gold Speck Floor Tile with associated White

Mastic None Detected 100% Other

Non-Fibrous

Dissolved

White

Homogeneous mastic

10096871_0007

Gray Leveling Compound

None Detected 100% Other

Non-Fibrous

Crushed

Gray

Homogeneous

10096871_0008

Gray Leveling Compound

None Detected 100% Other

Non-Fibrous

Crushed

Gray

Homogeneous

9 - A

10096871_0009

12"x12" Black with White Streak Vinyl Floor Tile and associated Back Mastic None Detected 100% Other

Non-Fibrous

Dissolved

White, Black

Homogeneous tile

9 - B

10096871_0015

12"x12" Black with White Streak Vinyl Floor Tile and associated Back Mastic None Detected 100% Other

Non-Fibrous

Dissolved

Black

Homogeneous mastic

10 - A

10096871_0010

12"x12" Black with White Streak Vinyl Floor Tile and associated Back Mastic None Detected 100% Other

Non-Fibrous

Dissolved

White, Black

Homogeneous tile

10 - B

10096871_0016

12"x12" Black with White Streak Vinyl Floor Tile and associated Back Mastic None Detected 100% Other

Non-Fibrous

Dissolved

Black

Homogeneous mastic

Disclaimer: Due to the nature of the EPA 600 method, asbestos may not be detected in samples containing low levels of asbestos. We strongly recommend that analysis of floor tiles, vermiculite, and/or heterogenous soil samples be conducted by TEM for confirmation of "None Detected" by PLM. This report relates only to the samples tested and may not be reproduced, except in full, without the written approval of SAI. This report may not be used by the client to claim product endorsement by NVLAP or any other agency of the U.S. government. Analytical uncertainty available upon request. Scientific Analytical Institute participates in the NVLAP Proficiency Testing program.

Unless otherwise noted blank sample correction was not performed. Estimated MDL is 0.1%.

Heather Boykin (16)

Analyst Approved Signatory

Page 2 of 2P-F-002 r15 1/15/2028 Scientific Analytical Institute, Inc. 4604 Dundas Dr. Greensboro, NC 27407 (336) 292-3888

Relinquished By

ECS Mid-Atlantic, LLC Bobby Rhett ·te 14026 Thundert>olt Place, su, (703)-471-8400 nHolo@ecSlimtted.com

47:22408 GSA I-IQ Modernization

I-IAZMAT

1800 F St NW, Washington, DC 202710

47:22408:84(RLR2)

11/1712025 17:30

PLM EPA 600/R-93/118

2-Da TAT

I

Green HVAC Duct Pin Mastic Mechanical Room Across Room 1310 Green HVAC Duct Pin Mastic Mechanical Room Across Room 1310

Gray and Green Speck Floor Tile with associated White Library Emergency Stairwell Mastic

Gray and Green Speck Floor Tile with associated White Library Emergency Stairwell Mastic

White and Gold Speck Floor Tile with associated White Library Emergency Stairwell Mastic

White and Gold Speck Floor Tile with associated White Library Emergency Stairwell Mastic

Gray Leveling Compound library Emergency Stairwell Gray Leveling Compound Library Emergency Stairwell

12"x12" Black with White Streak Vinyl Floor Tile Hallway Outside Room B-212A and associated Back Mastic

12"x12" Black with White Streak Vinyl Floor Tile Hallway Outside Room B-212A and associated Back Mastic

Accepted

Rejected of D

I

Appendix IV: Previous Reports

HAZARDOUS MATERIAL

PRE-CONSTRUCTION SURVEY

For

1800 F Street Modernization Project

General Services Administration Central Office Building

1800 F Street Washington, DC 20405

SBA PROJECT # 13-001

CAPE PROJECT # 40504.000

Prepared for:

Prepared by:

SHALOM BARANES ASSOCIATES

May 2005

TABLE OF CONTENTS

Section...................................................................................................................................Page #

1.0 INTRODUCTION

1.1 OVERVIEW

1.2 TECHNICAL APPROACH

1.2.1 Lead-Containing Paint Survey

1.2.2 Asbestos-Containing Material Survey

1.2.3 Polychlorinated Biphenyl (PCB) Light Ballast Survey

1.2.4 Mercury-Containing Light Tube Survey

2.0 SURVEY RESULTS AND RECOMMENDATIONS

2.1 Lead-Containing Paint

Lead-Containing Paint was identified on the following components:

2.2 Asbestos-Containing Materials

2.3 Polychlorinated Biphenyl Light Ballast

2.4 Mercury-Containing Light Tubes

Appendices

Appendix A-1 Suspect ACM Bulk Sample Log Appendix A-2 Survey Drawings: Bulk Sample Locations and Extent of Materials Appendix A-3 Laboratory Reports: Asbestos Bulk Sample Analysis Results Appendix L-1 Aggregate Summary of Paint Chip Sample Analysis Results Appendix L-2 Survey Drawings: Paint Chip Sample Locations Appendix L-3 Laboratory Reports: Paint Chip Sample Analysis Results Appendix P-1 Survey Drawings: PCB and Hg Extent of Materials

Hazardous Material Pre-Construction Survey Report for 1800 F Street Modernization

CAPE 1 1.0 Introduction

1.0 INTRODUCTION

This introductory section brie fly describes the project, outlines the format of the survey report, presents technical approach to the project, and to the sample analysis methodology. The survey results and recommendations are provided in Section 2.0. All information is provided as a guide and shall not be solely used for the abatement of these materials. Contractor shall refer to abatement drawings and specifications Section 01546, “Safety and Health,” 02020 “Demolition,” Section 02085 “Asbestos Abatement Procedures”, Section 02089 “Removal of PCB Containing Light Ballast and Mercury Containing Fluorescent Light Tubes”, and to Section 02090 “Lead Paint Abatement Procedures”.

1.1 OVERVIEW

Shalom Baranes Associates (SBA) retained CAPE to conduct an asbestos-containing material (ACM), lead-containing paint (LCP), polychlorinated biphenyl (PCB) containing light ballast, and mercury-containing light tube surveys of the General Services Administration (GSA) Central Office Building located at 1800 F Street, Washington, DC.

The survey was conducted June 29th through July 19th, 2004 by CAPE’s survey team.

1.2 TECHNICAL APPROACH

The survey consisted of investigating all accessible interior and exterior areas of the building.

Data from EA Engineering’s report titled “Pre-Renovation Hazardous Materials Report for GSA Central Office Building” dated May 1, 2003 (EA Report) was utilized for the asbestos and lead surveys . The asbestos field investigation criteria established for this project consisted of inspecting interior and exterior areas for suspect asbestos containing building materials (ACBM) and collecting bulk samples in accordance with the criteria outlined in 40 CFR Part 763, Asbestos Hazard Emergency Response Act (AHERA). The survey did not include destructive investigation. The lead containing paint (LCP) survey criteria established for this project consisted of paint chip sampling on the major component types present in each representative area.