5-CXY Hangar 501 Report of Building Findings.pdf
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- Dauphin County, Harveys Lake Borough, Pennsylvania
About this file
This is a Report of Findings from an environmental inspection and limited sampling assessment conducted by Skelly and Loy, Inc. for the Susquehanna Area Regional Airport Authority (SARAA) on Building 501 (Hempt Hangar) at Capital City Executive Airport in New Cumberland, Pennsylvania. The inspection, performed on August 19, 2020, included visual assessment for environmental concerns and limited asbestos-containing material (ACM) and lead-based paint (LBP) sampling. The work scope encompassed preparation of a scaled floor plan, collection and analysis of 38 bulk samples representing suspect ACMs, analysis of 12 paint chip samples for lead content, inventory of hazardous and environmentally regulated containers and equipment, exploration of site features including subsurface sewage holding tanks and floor drains, and photodocumentation of identified concerns. Two EPA-trained and Pennsylvania Department of Labor and Industry-certified Asbestos Building Inspectors and one certified Lead-Based Paint Inspector conducted the assessment. The analytical work was performed by International Asbestos Testing Laboratory (IATL) in Mt. Laurel, New Jersey, using EPA-approved methodologies.
The inspection identified three ACM-containing materials: black coating beneath a sink (Series 8) at 3.7% chrysotile asbestos, silver corrugated metal roof coating (Series 16) at 2.3% chrysotile asbestos, and 9"x9" grey vinyl floor tile (Series 19) at 4.9% chrysotile asbestos. One paint sample containing lead at concentrations greater than 0.5% was identified on metal walls and structural steel in Rooms 3 and 4, along with eight additional paint samples containing lead below the 0.5% threshold. The report documented numerous containers of hazardous and environmentally regulated materials, including paints, pesticides, cleaning agents, petroleum products, fluorescent lighting ballasts, mercury thermostats, and refrigeration equipment. Additional environmental concerns included un-piped floor drains and frost-proof water supply stickups allowing potential subsurface contamination, evidence of water damage in two areas, indicators of bird inhabitation with associated droppings and nesting materials, and an unconfirmed subsurface holding tank serving a bathroom and kitchen. The report recommends asbestos abatement prior to demolition or renovation, compliance with OSHA Lead in Construction standards for LBP disturbance, proper disposal of hazardous materials by licensed contractors with waste documentation, subsurface soil boring and sampling to assess potential contamination, a Phase I Environmental Site Assessment, and careful removal of water-damaged materials and bird waste by trained contractors.
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August 28, 2020
Ms. Jessica Silcox Environmental Program Manager, Engineering Susquehanna Area Regional Airport Authority One Terminal Drive, Suite 300 Middletown, Pennsylvania 17057
Re: Report of Findings Visual Inspection for Environmental Concerns and Limited ACM and LBP Sampling Hempt Hangar Building, Capital City Airport, 210 Airport Road New Cumberland, Pennsylvania
Dear Ms. Silcox:
Skelly and Loy, Inc. is pleased to present this Report of Findings resulting from the visual inspection for environmental concerns and limited asbestos-containing material (ACM) and lead-based paint (LBP) sampling of the building at the Capital City Airport (CXY) known as the Hempt Hanger. This hangar is also referred to as Building No. 501 and is located close to and accessed via Gate 13 off of Old Depot Road.
The site inspection and limited ACM and LBP sampling occurred on August 19, 2020, and was performed by three environmental professionals from Skelly and Loy. The inspection and sampling were performed in general accordance with the work scope presented in our proposal dated and submitted to you on August 17, 2020, and accepted by the Susquehanna Regional Area Airport Authority on August 18, 2020. Main work items performed by the inspection team consisted of the following.
1. Preparation of a scaled floor plan of the building (A copy of the field sketch of the floor plan identifying assigned room numbers and descriptions as well as main environmental items of concern is enclosed.)
2. Collection and analysis of bulk samples representing readily accessible suspect ACMs
3. Collection and analysis of paint chip samples of readily accessible surface coatings suspected of containing lead
Skelly and Loy, Inc., A Terracon Company 449 Eisenhower Boulevard, Suite 300 Harrisburg, PA 17111-2302 P (717) 232 0593 F (717) 232-1799 skellyloy.com terracon.com
4. Exploration/investigation of site features in, on, and immediately sur-rounding the building, indicating potential environmental concern, including a subsurface sewage holding tank, floor drains, water damage, bird droppings and nesting materials, and ground surface/subsurface indicators of possible buried objects and systems
5. Inventorying and cataloging of containers and equipment that have contents and components that are either hazardous or environmentally regulated
6. Photodocumentation of identified environmental concerns and sampled suspect ACMs and suspect LBP
The ensuing report provides information pertaining to our investigative techniques and findings, inspector and laboratory credentials, sample analysis and results, and conclusions and recommendations.
INVESTIGATIVE APPROACH AND TECHNIQUES
Limited ACM Inspection
Two United States Environmental Protection Agency (U.S. EPA)-trained and Pennsyl-vania Department of Labor and Industry (PaDOLI)-certified Asbestos Building Inspectors collected samples of all readily accessible suspect ACMs as well as roofing materials which were accessed via the use of an extension ladder. A total of 38 samples representing 20 different suspect ACMs were collected, documented on a Chain of Custody (COC) form, and shipped to International Asbestos Testing Laboratory (IATL) of Mt Laurel, New Jersey. The samples were subsequently analyzed by U.S. EPA Method 600 R-93/116, 1993 with some samples reanalyzed by Point Counting method. Copies of the COC form and the analytical report are enclosed. IATL is accredited by the American Industrial Hygiene Association. A copy of IATL’s accreditation is included along with copies of PaDOLI certifications for both Asbestos Building Inspectors. The different suspect ACMs sampled and their known locations can be seen on Table 1, Summary of Summary of Suspected Asbestos-Containing Materials. For materials identified to contain asbestos at a concentration greater than 1%, the material’s estimated quantity, condition, friability, and asbestos category are also listed in Table 1. The definition of ACM is any material containing greater than 1 % asbestos. It should be noted that samples of suspect ACMs were discreetly collected and that a destructive or intrusive investigation for suspect ACMs did not occur. This is another way of stating that walls, floors, ceilings, heating and other equipment, etc. were not opened up or explored.
Limited Lead-Based Paint Inspection
One U.S. EPA-trained and PaDOLI-certified Lead-Based Paint Inspector collected a single representative paint chip sample of each of 12 different coatings identified. Again, only readily accessible paint coatings were sampled. The samples were documented on a COC form, submitted to IATL of Mt Laurel, New Jersey, and analyzed for lead content by Method D3335- 85a, 2009. A copy of the inspector’s certification is enclosed, as is IATL’s accreditation for performing lead analysis. Copies of the COC form and the analytical report for the paint chip samples are enclosed. Analytical results are presented Table 2 along with the paint descriptions and their general locations(s) and conditions.
Containers and Equipment with Hazardous or Environmentally Regulated Contents and Components
While on the site, the inspectors inventoried and cataloged containers ranging in size from only a few ounces up to 55 gallons in capacity. These containers were believed to contain chemicals that were either hazardous or environmentally regulated such as paints, pesticides, cleaning agents, glues/mastics/adhesives, and petroleum products. Additionally, the inspectors cataloged equipment and other objects found in or on the building that had components that may be hazardous or environmentally regulated in nature. These included things such as fluorescent lighting and associated ballasts, high-pressure sodium or mercury vapor lighting, motorized equip-ment using liquid lubricants, mercury thermostats, electrical transformers, and refrigeration/ cooling equipment containing compressor oils and chlorofluorocarbons. No sort of sampling of the chemicals or component contents was performed; instead, the contents were presumed to be hazardous and/or environmentally regulated was based on labeling information and inspector experience and knowledge. The listing of all such containers, equipment, and components are presented in Table 3.
Other Environmental and Health Concerns
While on the site, the inspection team also made note of any floor drains and exterior subsurface features and looked for indicators of underground storage tanks (USTs). Additionally, the team made note of any water damage and indicators of bird inhabitation due to potential health concerns associated with mold and avian pathogens. All such concerns, whether verified as existing or not, are listed in Table 4 along with their locations.
INVESTIGATIVE RESULTS
Limited ACM Inspection
Of the 20 different accessible suspect ACMs encountered, 38 samples were collected and submitted for analysis. The laboratory identified one additional sample, bringing the total number of samples analyzed to 39. Of these materials, the coating, black, beneath the sink (Series 8);
corrugated metal roof coating, silver (Series 16); and 9"x9" vinyl floor tile, grey (Series 19) were identified to contain asbestos greater than 1%. The laboratory identified a silver coating (Series 18A[L2]) that was also found to contain asbestos. However, this material was previously identified by the inspectors as Series 16. Although the exterior caulking, grey outer layer (Series 11) does contain measurable amounts of asbestos, it is not by definition ACM. The silver roof coating (Series 16) and the 9"x9" vinyl floor tile, grey (Series 19) are presently defined as Category I Nonfriable (NF) ACMs. The coating, black beneath the sink in Room 6 (Series 8) is presently defined as Category II NF ACM.
Limited Lead-Based Paint Inspection
Of the 12 different accessible paints suspected of containing lead that were sampled and analyzed, only one (Pb5) was identified to be lead-based. This paint was white, located on the metal half of the walls in Room 4 and on the walls and structural steel in Room 3. Eight of the paint chip samples were identified as containing lead; however, the concentrations were below 1%, making these paint chip samples lead-containing paint as opposed to LBP. Two paint chip samples were found to not contain any lead above the laboratory detection limit, and one sample (Pb10) was unable to be analyzed by the laboratory due to insufficient material being submitted.
This sample (Pb10) was beneath Pb9. A summary of the analytical results is included in Table 2.
Containers and Equipment with Hazardous or Environmentally Regulated Contents and Components
A wide array of numerous containers containing different types of chemicals and products used during property, building, and aircraft maintenance were present in various portions of the building. Some are considered hazardous (based on being either toxic, reactive, ignitable, or corrosive), and all should be considered environmentally regulated to some degree. To reiterate, none of these materials were actually sampled or analyzed; their designation as either hazardous or environmentally regulated is based on inspector experience and/or product labeling. Table 3 includes a listing of all such containers and components.
Other Environmental and Health Concerns
Sanitary wastewater from Room 1 of the hangar building flows into a subsurface concrete tank approximately 32 feet west of Room 1. A worker at the adjacent hangar reported that this tank was a holding tank and that 100% of the wastewater entering into the tank was held until it was full, at which time the tank was pumped out. The worker reported that the tank was not a typical septic tank where clear (solids-free) water flowed through and into a leach field. He also stated that the hangar was not hooked up to public sewer. It could not be confirmed, however, where wastewater from Room 6 (kitchen/office) flowed.
Each hangar room (three total) in the building had a single floor drain toward the center.
These drains were opened up, and crushed limestone gravel was seen in the bottom, leading the investigators to believe that the floor drains simply served as an opening in the floor to allow water to enter and then dissipate into the gravel and simply drain into the ground beneath each hangar room floor. When water was poured into one of the drains, the water readily disappeared into the gravel, but no water was seen to flow into either of the two remaining drains, supporting the notion that these drains were NOT connected, at least not with piping. In addition, staining was observed on the concrete floors of the hangars; this could indicate spills, leaks, or uncontrolled releases of chemicals that could have entered these floor drains.
Frost-proof water supply stickups were noted in each of the three hangars. Immediately below each supply stickup was what appeared to be a hole through the concrete floor that was filled with gravel. Only two of the stickups were operational but when both were allowed to operate with water flowing into the gravel for a period of time, all water readily entered into the gravel and disappeared. Although the gravel was not dug up or removed, it is believed that (like the three floor drains) the three gravel-filled holes simply served as a means for excess water to pass through the floor and into the subsurface below the floor.
Obvious indicators of fuel USTs were not noted, meaning fuel fill or vent pipes, tank product level records, fuel delivery records, heating oil burning equipment, etc. were not seen.
However, a long, wooden stick with measurement gradations that is typically used for “sticking” (i.e., dipping) into a tank to measure the depth of petroleum product in the tank was observed.
Signs of water damage were noted near the steps leading up to the loft (Room 7) above Room 1. It appeared that the fiberboard panels used as wall finishing material was warped and water-stained, but no indicators of active or past mold growth were seen on the exposed surfaces.
Similar indicators of water intrusion were noted along the western wall of the kitchen/office (Room 6) associated with the window. Wood paneling in this area was warped and delaminating.
Indicators of birds inhabiting the hangar building were seen in hangar Room 3 and consisted of bird droppings on the floor and some equipment as well as nesting materials on the floor that were assumed to be brought into the hanger by birds through openings in the building envelope.
CONCLUSIONS AND RECOMMENDATIONS
Limited ACM Inspection
• The following materials were identified to contain asbestos:
‒ Series 8: coating, black, beneath the sink;
‒ Series 16: corrugated metal roof coating, silver; and
‒ Series 19: 9"x9" vinyl floor tile, grey
• Asbestos abatement activities (if elected) must be performed under proper ten-day notification and must be performed by a certified asbestos abatement contractor.
• Category II NF ACM can potentially become friable, and thus regulated, if left in place during demolition or renovation actives that will disturb them. Therefore, they must be abated prior to demolition or renovation disturbance as well.
• The Category I NF ACMs can be left in place during demolition or renovation disturbance as long as they do not become friable and are kept wet during demolition or renovation, visible emissions do not occur, and the resulting waste streams (including the substrates [masonry, block, brick, concrete, gravel, etc.] to which the floor tiles, silver roof coating, and sink coating tar are attached) are disposed of as construction/demolition debris in a properly permitted landfill. However, the Pennsylvania Department of Environmental Protection does encourage abatement of all ACMs from buildings prior to their demolition.
• Although the exterior caulking, grey outer layer (Series 11) is not ACM by definition, it does contain trace amounts of asbestos that, when improperly disturbed/demolished, can result in an airborne asbestos fiber concertation exceeding the Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit. Care should be taken during demolition/disturbance and loading of this material to keep it adequately wet and prevent visible emissions from occurring.
• If renovation or demolition activities disturbing these ACMs do not occur, it is recom-mended that these ACMs be managed in place under an Asbestos Management Plan generated by a PaDOLI-certified Asbestos Management Planner. Additionally, any contractors hired to perform work near these ACMs should be made aware of the presence of the ACMs and cautioned to not disturb the ACMs.
Limited Lead-Based Paint Inspection
• One paint coating sampled contained lead at a concentration greater than 0.5% by weight and is thus defined as LBP. Other paints were also identified as containing lead at varying concentrations less than 0.5%. Pb10 (located beneath Pb9, which was identified to as containing lead at varying concentrations less than 0.5%) was not analyzed. Disturbance of the paint coatings containing any concentrations of lead could cause a health hazard to workers and/or cause a degradation of the surrounding environment unless such disturbance is done properly using appropriate work practices, engineering controls, personal protective equipment, and disposal practices. Furthermore, the contractor performing construction (i.e., renovation, demolition, or disposal) of building components coated with paints containing lead must comply with all regulations governing waste disposal.
• Contractors must adhere to OSHA Lead in Construction Standard 29 CFR 1926.62 and other applicable OSHA standards if/when disturbing the paint coating by using appropriate work practices, engineering controls, personal protective equipment, and disposal practices.
Containers and Equipment with Hazardous or Environmentally Regulated Contents and Components
If any of these chemicals or components can still be used, they are not considered wastes.
However, if for any reason they are not or cannot be used, they should be considered wastes and disposed of properly. The lease with the soon-to-be former tenant should be consulted to determine which party is responsible for the disposal of unused/unneeded chemicals and equipment containing components with regulated substances. Any such products, chemicals, and components that are considered wastes should be properly field-characterized and disposed of by an experienced and licensed/permitted disposal company with waste disposal documenta-tion being generated and provided to the responsible party (i.e., to the Generator). As the current tenant is a business and not a private household, municipal programs for disposal of such waste from residential origin may not be available as a disposal option.
It is Skelly and Loy’s understanding that the current tenant is moving to a different (smaller) hangar on the CXY property and will still maintain aircraft in the new location. Therefore, the tenant may be able and willing to transfer many of the chemicals and products for use at the new location. Other tenants on the CXY property may be able and willing to use products that the subject tenant does not wish to keep but still have a useful life. If, however, disposal ends up being the fate of any of the chemicals, consideration should be given to “bulking” numerous small containers of like-chemicals into a single, larger container for disposal cost savings. Below are additional protocols that are recommended for disposing of certain hazardous or environmentally regulated materials:
• It is recommended that the identified suspect hazardous/environmentally regulated waste materials be properly field-characterized, containerized, prepared for shipment, manifested, and disposed of or recycled at a permitted facility prior to the demolition of the building.
• The universal wastes (including fluorescent lamps and ballasts) should be removed and disposed of in accordance with Pennsylvania Code Title 25, Chapter 266b “Universal Waste Program” and U.S. EPA Title 40, Part 273 Standards for Universal Waste Management.
• E-waste should be disposed of or recycled at a permitted facility that accepts such wastes.
• Waste mercury-containing thermostats should be disposed of in accordance with Pennsylvania Act. No. 97, “Mercury-Free thermostat Act.”
• Before disposal, the window air conditioning units and mini refrigerator must have their refrigerant gases and compressor oils reclaimed by a certified heating, ventilation, and air conditioning (HVAC) technician with a certificate of recycling being issued in accordance with Section 608 of the Clean Air Act.
Other Environmental and Health Concerns
The presence of three floor drains (that are believed to be un-piped) inside the three different hangars within the building are a concern due to the possibility of waste liquids generated in the past simply being poured down the drains and allowed to soak into the gravel and soil beneath the hangar floor. Consideration should be given to performing concrete coring and sub-slab soil boring, sampling, and testing. Ideally, such boring and sampling program should delineate both the lateral and vertical extent of any subsurface contamination existing as a result of wastewater disposal via the un-piped floor drains. The soil samples should, at a minimum, be tested for chemical constituents common to petroleum and cleaning products as well as metals.
The same recommendations are offered in association with the subsurface immediately surround-ing the gravel “drains” associated with the three frost-free spigots since past liquid waste disposal could have occurred via these “drains” as well.
Whereas the sanitary wastewater originating from the bathroom and sink in Room 1 was confirmed to go into a holding tank on the western side of the building, the fate of wastewater generated in the kitchen/office room (Room 6) was not ascertained. If for no other reason than future plumbing and excavation, it is recommended that it be ascertained how and where the wastewater from Room 6 flows. Construction diagrams and engineering drawings that the airport authority may have should be consulted to hopefully shed light on this, including confirming if the holding tank is in fact a holding tank. The current tenant could also be asked for pump out records and receipts; this may also help confirm the method of wastewater disposal.
Although no sort of mold sampling (air, wipe, or bulk) was performed, it is recommended that all water-damaged building material be carefully removed in a controlled manner and replaced, but replacement of the building material should only occur after the source of the moisture has been corrected. The two main areas include the southern wall immediately adjacent to the steps leading up to the loft above Room 1 and the western wall in Room 6 surrounding the window. It is recommended that a firm experienced and trained in mold remediation perform the removal of the mold-damaged building materials. Other trades are recommended for correction of the water source problems (roofers, plumbers, siding/window contractors).
Although no sort of avian pathogen screening sampling and analysis was performed, the bird droppings and nesting materials located in various portions of the hangar building should be considered a potential source for such pathogens that, if not removed, could infect occupants.
Therefore, it is recommended that these waste materials also be carefully contained and removed and the resultant surfaces cleaned and disinfected. Many mold remediation contractors are also experienced in the removal of bird waste, etc. and use much of the same equipment and techniques in addressing avian wastes as when performing mold remediation. However, it is imperative that any and all openings through which birds have entered the building in the past be sealed up to prevent future habitation.
Although there were no indicators of the presence of an UST other than the presence of a measuring stick typically used for gauging product depth in the hangar, the possible presence of an UST should not be dismissed. It is recommended that the tenant be asked about the purpose of the gauging stick in the hangar.
Lastly, due to the lack of historical use information, it is recommended that a Phase I Environmental Site Assessment (ESA) be performed on the property in order to develop a baseline environmental condition at the cessation of the current tenant’s lease but before the commencing a lease with a new tenant. The performance of a Phase I ESA may answer some of the questions identified above and would also provide information on the history of the building as it relates to when it was constructed, ownership, and past occupancy. Significant dates regarding development of the property can be cross-referenced to when certain environmental and waste disposal laws were enacted. If a Phase I ESA is not elected to be performed, it is still recommended that subsurface soil sampling be conducted to determine if disposal of wastewater or an uncontrolled release of chemicals to the floor drains/spigot drains have occurred, subse-quently impacting the subsurface. In addition, signage or cones should be placed over the floor drains until such time it can be determined where the drains are piped and discharge. No waste or wash water should be disposed of in these floor drains.
DISCLAIMER
We did not perform a Phase I ESA. As such, the following efforts were not performed:
• background research or records review;
• interviews with knowledgeable persons;
• database searches;
• compliance audit;
• environmental lien search;
• wetland identification or archaeological review;
• radon or vapor intrusion testing;
• soil or water testing;
• geophysical investigation of the site’s subsurface;
• aerial photograph review;
• historical Sanborn Fire Insurance Mapping review; and
• physical setting sources review (soils, geology, and topographical mapping).
The ACM and LBP inspections were limited to only accessible portions of the building and to only accessible suspect ACM and LBPs. Additional suspect ACMs and LBPs may exist within inaccessible portions of the building.
Skelly and Loy, Inc. thanks you and the Susquehanna Area Regional Airport Authority for this opportunity to be of service. Should you have any questions or require additional information regarding the findings, conclusions, or recommendations contained herein, please to not hesitate to contact me.
Sincerely yours, SKELLY and LOY, Inc.
Robert D. Rowley, CIH, CSP, Director of Industrial Hygiene Services
Enclosures cc: Gerry Longenecker Lauren Tilley Matt Nowlin R20-0372.000 File: CXY Hempt Hangar, Report of Findings.docx
Lab No.: 7051613 Client No.: R200372.000-1A
Analyst Observation: Brown Cove Base Client Description: Kick Plate, Brown
Location:
Facility:
Percent Asbestos:
None Detected
Percent Non-Asbestos Fibrous Material:
Percent Non-Fibrous Material:
Lab No.: 7051614 Client No.: R200372.000-1B
Analyst Observation: Brown Cove Base Client Description: Kick Plate, Brown
Lab No.: 7051615 Client No.: R200372.000-2A
Analyst Observation: Yellow Mastic Client Description: Kick Plate Mastic, Tan
Lab No.: 7051616 Client No.: R200372.000-2B
Analyst Observation: Yellow Mastic Client Description: Kick Plate Mastic, Tan
Lab No.: 7051617 Client No.: R200372.000-3A
Analyst Observation: Off-White Floor Tile Client Description: 12"x12" VFT Tan With White Blotches
Lab No.: 7051618 Client No.: R200372.000-3B
Analyst Observation: Off-White Floor Tile Client Description: 12"x12" VFT Tan With White Blotches
Laboratory Director
Approved By:
Date Analyzed:
8/20/2020Date Received:
Analyst:
Please refer to the Appendix of this report for further information regarding your analysis.
Signature:
Ellen Smith
08/21/2020 Frank E. Ehrenfeld, III
9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054
Telephone: 856-231-9449 Email: customerservice@iatl.com
CERTIFICATE OF ANALYSIS
Client: Skelly And Loy, Inc.
449 Eisenhower Blvd.
Harrisburg PA 17111
8/21/2020Report Date:
Report No.: 618345 - PLM Project: SARAA Hermot Hangar Project No.:
PLM BULK SAMPLE ANALYSIS SUMMARY
Client: SKE490
Dated : 8/24/2020 2:44:43 Page 1 of 10
Lab No.: 7051619 Client No.: R200372.000-4A
Analyst Observation: Black Mastic Client Description: Mastic, Black
2 Cellulose
Lab No.: 7051620 Client No.: R200372.000-4B
2 Cellulose
Lab No.: 7051621 Client No.: R200372.000-5A
Analyst Observation: White Floor Tile Client Description: 12"x12" VFT White With Printed Blotches
Lab No.: 7051622 Client No.: R200372.000-5B
Analyst Observation: White Floor Tile Client Description: 12"x12" VFT White With Printed Blotches
Lab No.: 7051623 Client No.: R200372.000-6A
Analyst Observation: Black/Tan Mastic
1 Cellulose
Lab No.: 7051624 Client No.: R200372.000-6B
Analyst Observation: Black/Tan Mastic
Laboratory Director
Approved By:
Date Analyzed:
8/20/2020Date Received:
Analyst:
Please refer to the Appendix of this report for further information regarding your analysis.
Signature:
Ellen Smith
08/21/2020 Frank E. Ehrenfeld, III
9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054
Telephone: 856-231-9449 Email: customerservice@iatl.com
CERTIFICATE OF ANALYSIS
Client: Skelly And Loy, Inc.
449 Eisenhower Blvd.
Harrisburg PA 17111
8/21/2020Report Date:
Report No.: 618345 - PLM Project: SARAA Hermot Hangar Project No.:
PLM BULK SAMPLE ANALYSIS SUMMARY
Dated : 8/24/2020 2:44:43 Page 2 of 10
Lab No.: 7051625 Client No.: R200372.000-7A
Analyst Observation: Tan Ceiling Tile Client Description: 2"x2" ACT White Pocked Marks
35 Cellulose 15 Fibrous Glass
Lab No.: 7051626 Client No.: R200372.000-7B
Analyst Observation: Tan Ceiling Tile Client Description: 2"x2" ACT White Pocked Marks
35 Cellulose 15 Fibrous Glass
Lab No.: 7051627 Client No.: R200372.000-8
Analyst Observation: Black Sink Undercoating Client Description: Sink Undercoat, Black
PC 3.7 Chrysotile
96.3
Lab No.: 7051628 Client No.: R200372.000-9
Analyst Observation: Grey Sink Undercoating Client Description: Sink Undercoat, White
Lab No.: 7051629 Client No.: R200372.000-10A
Analyst Observation: Black Expansion Joint Client Description: Concrete Expansion Joint, Black
4 Cellulose
Lab No.: 7051630 Client No.: R200372.000-10B
Analyst Observation: Black Expansion Joint Client Description: Concrete Expansion Joint, Black
3 Cellulose
Laboratory Director
Approved By:
Date Analyzed:
8/20/2020Date Received:
Analyst:
Please refer to the Appendix of this report for further information regarding your analysis.
Signature:
Ellen Smith
08/21/2020 Frank E. Ehrenfeld, III
9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054
Telephone: 856-231-9449 Email: customerservice@iatl.com
CERTIFICATE OF ANALYSIS
Client: Skelly And Loy, Inc.
449 Eisenhower Blvd.
Harrisburg PA 17111
8/21/2020Report Date:
Report No.: 618345 - PLM Project: SARAA Hermot Hangar Project No.:
PLM BULK SAMPLE ANALYSIS SUMMARY
Dated : 8/24/2020 2:44:43 Page 3 of 10
Lab No.: 7051631 Client No.: R200372.000-11A
Analyst Observation: Clear Caulk Client Description: Ext Caulking, Grey Outer Layer
Lab No.: 7051632 Client No.: R200372.000-11B
Analyst Observation: Lt Tan Caulk Client Description: Ext Caulking, Grey Outer Layer
PC 0.25 Chrysotile
99.75
Lab No.: 7051633 Client No.: R200372.000-12A
Analyst Observation: White Caulk Client Description: Ext. Caulking, White Inside Layer
Lab No.: 7051634 Client No.: R200372.000-12B
Client Description: Ext. Caulking, White Inside Layer
Lab No.: 7051635 Client No.: R200372.000-13A
Client Description: Door Caulking, White
Lab No.: 7051636 Client No.: R200372.000-13B
Client Description: Door Caulking, White
Laboratory Director
Approved By:
Date Analyzed:
8/20/2020Date Received:
Analyst:
Please refer to the Appendix of this report for further information regarding your analysis.
Signature:
Ellen Smith
08/21/2020 Frank E. Ehrenfeld, III
9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054
Telephone: 856-231-9449 Email: customerservice@iatl.com
CERTIFICATE OF ANALYSIS
Client: Skelly And Loy, Inc.
449 Eisenhower Blvd.
Harrisburg PA 17111
8/21/2020Report Date:
Report No.: 618345 - PLM Project: SARAA Hermot Hangar Project No.:
PLM BULK SAMPLE ANALYSIS SUMMARY
Dated : 8/24/2020 2:44:43 Page 4 of 10
Lab No.: 7051637 Client No.: R200372.000-14A
Analyst Observation: Off-White Glazing Client Description: Window Glazing, White
Lab No.: 7051638 Client No.: R200372.000-14B
Analyst Observation: Off-White Glazing Client Description: Window Glazing, White
Lab No.: 7051639 Client No.: R200372.000-15A
Analyst Observation: White Joint Compound Client Description: Joint Compound, White
Lab No.: 7051640 Client No.: R200372.000-15B
Analyst Observation: White Joint Compound Client Description: Joint Compound, White
Lab No.: 7051641 Client No.: R200372.000-16A
Analyst Observation: Silver Coating Client Description: Corrugated Roof Coating, Silver
PC 2.3 Chrysotile
97.7
Lab No.: 7051642 Client No.: R200372.000-16B
Analyst Observation: Sample Not Analyzed Client Description: Corrugated Roof Coating, Silver
Sample Not Analyzed
Laboratory Director
Approved By:
Date Analyzed:
8/20/2020Date Received:
Analyst:
Please refer to the Appendix of this report for further information regarding your analysis.
Signature:
Ellen Smith
08/21/2020 Frank E. Ehrenfeld, III
9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054
Telephone: 856-231-9449 Email: customerservice@iatl.com
CERTIFICATE OF ANALYSIS
Client: Skelly And Loy, Inc.
449 Eisenhower Blvd.
Harrisburg PA 17111
8/21/2020Report Date:
Report No.: 618345 - PLM Project: SARAA Hermot Hangar Project No.:
PLM BULK SAMPLE ANALYSIS SUMMARY
Dated : 8/24/2020 2:44:43 Page 5 of 10
Lab No.: 7051643 Client No.: R200372.000-17A
Analyst Observation: Silver/Black Caulk Client Description: Roof Caulking, Black
Lab No.: 7051644 Client No.: R200372.000-17B
Analyst Observation: Silver/Black Caulk Client Description: Roof Caulking, Black
Lab No.: 7051645 Client No.: R200372.000-18A
Analyst Observation: Black Non-Fibrous Client Description: Roof Peak Corrugated Gap Spacer, Black
Lab No.: 7051645(L2) Client No.: R200372.000-18A
Analyst Observation: Silver Coating
PC 1.2 Chrysotile
98.8
Lab No.: 7051646 Client No.: R200372.000-18B
Analyst Observation: Black Non-Fibrous
Lab No.: 7051647 Client No.: R200372.000-19A
Analyst Observation: Grey Floor Tile Client Description: 9"x9" VFT, Grey
PC 4.9 Chrysotile
95.1
Laboratory Director
Approved By:
Date Analyzed:
8/20/2020Date Received:
Analyst:
Please refer to the Appendix of this report for further information regarding your analysis.
Signature:
Ellen Smith
08/21/2020 Frank E. Ehrenfeld, III
9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054
Telephone: 856-231-9449 Email: customerservice@iatl.com
CERTIFICATE OF ANALYSIS
Client: Skelly And Loy, Inc.
449 Eisenhower Blvd.
Harrisburg PA 17111
8/21/2020Report Date:
Report No.: 618345 - PLM Project: SARAA Hermot Hangar Project No.:
PLM BULK SAMPLE ANALYSIS SUMMARY
Dated : 8/24/2020 2:44:43 Page 6 of 10
Lab No.: 7051648 Client No.: R200372.000-19B
Analyst Observation: Sample Not Analyzed Client Description: 9"x9" VFT, Grey
Lab No.: 7051649 Client No.: R200372.000-20A
Lab No.: 7051650 Client No.: R200372.000-20B
Laboratory Director
Approved By:
Date Analyzed:
8/20/2020Date Received:
Analyst:
Please refer to the Appendix of this report for further information regarding your analysis.
Signature:
Ellen Smith
08/21/2020 Frank E. Ehrenfeld, III
9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054
Telephone: 856-231-9449 Email: customerservice@iatl.com
CERTIFICATE OF ANALYSIS
Client: Skelly And Loy, Inc.
449 Eisenhower Blvd.
Harrisburg PA 17111
8/21/2020Report Date:
Report No.: 618345 - PLM Project: SARAA Hermot Hangar Project No.:
PLM BULK SAMPLE ANALYSIS SUMMARY
Dated : 8/24/2020 2:44:43 Page 7 of 10
Appendix to Analytical Report Customer Contact: Rob Rowley Method:40 CFR Appendix E to Subpart E of Part 763, interim method for the Determination of Asbestos in Bulk Insulation Samples, and USEPA 600, R93-116 as needed.
This appendix seeks to promote greater understanding of any observations, exceptions, special instructions, or circumstances that the laboratory needs to communicate to the client concerning the above samples. The information below is used to help promote your ability to make the most informed decisions for you and your customers.
Please note the following points of contact for any questions you may have.
iATL Customer Service: customerservice@iatl.com iATL Office Manager:wchampion@iatl.com iATL Account Representative: Kelly Klippel Sample Login Notes: See Batch Sheet Attached Sample Matrix: Bulk Building Materials Exceptions Noted: See Following Pages
General Terms, Warrants, Limits, Qualifiers:
General information about iATL capabilities and client/laboratory relationships and responsibilities are spelled out in iATL policies that are listed at www.iATL.com and in our Quality Assurance Manual per ISO 17025 standard requirements. The information therein is a representation of iATL definitions and policies for turnaround times, sample submittal, collection media, blank definitions, quantification issues and limit of detection, analytical methods and procedures, sub-contracting policies, results reporting options, fees, terms, and discounts, confidentiality, sample archival and disposal, and data interpretation.
iATL warrants the test results to be of a precision normal for the type and methodology employed for each sample submitted. iATL disclaims any other warrants, expressed or implied, including warranty of fitness for a particular purpose and warranty of merchantability. iATL accepts no legal responsibility for the purpose for which the client uses test results. Any analytical work performed must be governed by our Standard Terms and Conditions. Prices, methods and detection limits may be changed without notification. Please contact your Customer Service Representative for the most current information.
This confidential report relates only to those item(s) tested and does not represent an endorsement by NIST-NVLAP, AIHA LAP LLC, or any agency of local, state or province governments nor of any agency of the U.S. government.
This report shall not be reproduced except in full, without written approval of the laboratory.
Information Pertinent to this Report:
Analysis by US EPA 600 93-116: Determination of Asbestos in Bulk Building Materials by Polarized Light Microscopy (PLM).
Certifications:
NIST-NVLAP No. 101165-0• NYSDOH-ELAP No. 11021• AIHA-LAP, LLC No. 100188•
Quantification at <0.25% by volume is possible with this method. (PC) Indicates Stratified Point Count Method performed. (PC-Trace) means that asbestos was detected but is not quantifiable under the Point Counting regimen. PC Trace represents a <0.25% amount. Analysis includes all distinct separable layers in accordance with EPA 600 Method. If not reported or otherwise noted, layer is either not present or the client has specifically requested that it not be analyzed (ex. analyze until positive instructions). Small asbestos fibers may be missed by PLM due to resolution limitations of the optical microscope. Therefore, PLM is not consistently reliable in detecting asbestos in non-friable organically bound (NOB) materials. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing.
Analytical Methodology Alternatives: Your initial request for analysis may not have accounted for recent advances in regulatory requirements or advances in technology that are routinely used in similar situations for other qualified projects. You may have the option to explore additional analysis for further information. Below are a few options, listed as the matrix followed by the appropriate methodology. Also included are links to more information on our website.
Bulk Building Materials that are Non-Friable Organically Bound (NOB) by Gravimetric Reduction techniques employing PLM and TEM: ELAP 198.6 (PLM-NOB), ELAP 198.4 (TEM-NOB)
9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054
Telephone: 856-231-9449 Email: customerservice@iatl.com
CERTIFICATE OF ANALYSIS
Client: Skelly And Loy, Inc.
449 Eisenhower Blvd.
Harrisburg PA 17111
8/21/2020Report Date:
Report No.: 618345 - PLM Project: SARAA Hermot Hangar Project No.:
Page 8 of 10Dated : 8/24/2020 2:44:44
Loose Fill Vermiculite Insulation, Attic Insulation, Zonolite (copyright), etc.: US EPA 600 R-4/004 (multi-tiered analytical process) Sprayed On Insulation/Fireproofing with Vermiculite (SOF-V): ELAP 198.8 (PLM-SOF-V)
Soil, sludge, sediment, aggregate, and like materials analyzed for asbestos or other elongated mineral particles (ex. erionite, etc.): ASTM D7521, CARB 435, and other options available
Asbestos in Surface Dust according to one of ASTM's Methods (very dependent on sampling collection technique – by TEM): ASTM D 5755, D5756, or D6480
Various other asbestos matrices (air, water, etc.) and analytical methods are available.
Disclaimers / Qualifiers:
There may be some samples in this project that have a "NOTE:" associated with a sample result. We use added disclaimers or qualifiers to inform the client about something that requires further explanation. Here is a list with highlighted disclaimers that may be pertinent to this project. For a full explanation of these and other disclaimers, please inquire at customerservice@iatl.com.
1) Note: No mastic provided for analysis.
2) Note: Insufficient mastic provided for analysis.
3) Note: Insufficient material provided for analysis.
4) Note: Insufficient sample provided for QC reanalysis.
5) Note: Different material than indicated on Sample Log / Description.
6) Note: Sample not submitted.
7) Note: Attached to asbestos containing material.
8) Note: Received wet.
9) Note: Possible surface contamination.
10) Note: Not building material. 1% threshold may not apply.
11) Note: Recommend TEM-NOB analysis as per EPA recommendations.
12) Note: Asbestos detected but not quantifiable.
13) Note: Multiple identical samples submitted, only one analyzed.
14) Note: Analyzed by EPA 600/R-93/116. Point Counting detection limit at 0.080%.
15) Note: Analyzed by EPA 600/R-93/116. Point Counting detection limit at 0.125%.
16) Note: This sample contains >10% vermiculite mineral. See Appendix for Recommendations for Vermiculite Analysis.
Recommendations for Vermiculite Analysis:
Several analytical protocols exist for the analysis of asbestos in vermiculite. These analytical approaches vary depending upon the nature of the vermiculite mineral being tested (e.g. un-processed gange, homogeneous exfoliated books of mica, or mixed mineral composites).Please contact your client representative for pricing and turnaround time options available.
iATL recommends initial testing using the EPA 600/R-93/116 method. This method is specifically designed for the analysis of asbestos in bulk building materials. It provides an acceptable starting point for primary screening of vermiculite for possible asbestos.
Results from this testing may be inconclusive. EPA suggests proceeding to a multi-tiered analysis involving wet separation techniques in conjunction with PLM and TEM gravimetric analysis (EPA 600/R-04/004).
For New York State customers, NYSDOH requires disclaimers and qualifiers for various vermiculite containing samples that direct analysis via ELAP198.6 and ELAP198.8 for samples that contain >10% vermiculite mineral where ELAP198.6 may be used to evaluate the asbestos content of the material. However, any test result using ELAP198.6 will be reported with the following disclaimer: “ELAP198.6 method does not remove vermiculite and may underestimate the level of asbestos present in a sample containing >10% vermiculite.”
Further information on this method and other vermiculite and asbestos issues can be found at the following: Agency for Toxic Substances and Disease Registry (ATSDR) www.atsdr.cdc.gov, United States Geological Survey (USGS) www.minerals.usgs.gov/minerals/, US EPA www.epa.gov/asbestos. The USEPA also has an informative brochure "Current Best Practices for Vermiculite Attic Insulation" EPA 747F03001 May 2003, that may assist the health and remediation professional. NYS customers please follow current NYSDOH ELAP requirements per policy on subject of surfacing and vermiculite, May 6, 2016, Testing Requirements for Surfacing Material Containing Vermiculite (https://www.wadsworth.org/sites/default/files/WebDoc/I198_8_02_2.pdf)
The following is a summary of the analytical process outlines in the EPA 600/R-04/004 Method:
1)Analytical Step/Method: Initial Screening by PLM, EPA 600R-93/116 Requirements/Comments: Minimum of 0.1 g of sample. ~0.25% for most samples.
Telephone: 856-231-9449 Email: customerservice@iatl.com
CERTIFICATE OF ANALYSIS
Client: Skelly And Loy, Inc.
449 Eisenhower Blvd.
Harrisburg PA 17111
8/21/2020Report Date:
Report No.: 618345 - PLM Project: SARAA Hermot Hangar Project No.:
Page 9 of 10Dated : 8/24/2020 2:44:44
2)Analytical Step/Method:Wet Separation by PLM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Sinks" only.
3)Analytical Step/Method:Wet Separation by PLM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Floats" only.
4)Analytical Step/Method:Wet Separation by TEM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Sinks" only.
5)Analytical Step/Method:Wet Separation by TEM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Suspension" only.
*With advance notice and confirmation by the laboratory.
**Approximately 1 Liter of sample in double-bagged container (~9x6 inch bag of sample).
9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054
Telephone: 856-231-9449 Email: customerservice@iatl.com
CERTIFICATE OF ANALYSIS
Client: Skelly And Loy, Inc.
449 Eisenhower Blvd.
Harrisburg PA 17111
8/21/2020Report Date:
Report No.: 618345 - PLM Project: SARAA Hermot Hangar Project No.:
Page 10 of 10Dated : 8/24/2020 2:44:44
AIHA Laboratory Accreditation Programs, LLC 3141 Fairview Park Drive, Suite 777, Falls Church, VA 22042 USA main +1 703-846-0736 fax +1 703-207-8558
Twitter: @AIHA_LAP_LLC R4 01/24/2018
September 30, 2019
Laboratory ID: 100188
Frank Ehrenfeld
International Asbestos Testing Laboratories (IATL)
9000 Commerce Parkway, Suite B.
Mt. Laurel, NJ 08054
Dear Mr. Ehrenfeld:
Congratulations! The AIHA Laboratory Accreditation Programs (AIHA-LAP), LLC’s Analytical Accreditation
Board (AAB) has approved International Asbestos Testing Laboratories (IATL) as an accredited Industrial Hygiene, Environmental Lead, and Environmental Microbiology laboratory.
Accreditation documentation includes the IHLAP, ELLAP, and EMLAP accreditation certificate, scope of accreditation document and a copy of the current AIHA-LAP, LLC license agreement (if your completed agreement is not on file at AIHA-LAP, LLC). The accreditation symbol has been designed for use by all AIHA-LAP, LLC accredited laboratories. If your laboratory chooses to use the symbol in its advertising the laboratory’s accreditation, you must complete and return the AIHA-LAP, LLC license agreement to a Laboratory Accreditation Specialist.
Once submitted, an electronic copy of the accreditation symbol will be sent to you.
Laboratory accreditation shall be maintained by continued compliance with IHLAP, ELLAP, and EMLAP requirements (see Policy Modules 2B, 2C, 2D, and 6), which includes proficient participation in AIHA-LAP, LLC approved proficiency testing, demonstration of competency, or round robin program as indicated on the AIHA-LAP
“Approved PT and Round Robin” webpage, its associated Scope/PT table, and as required in Policy Module 6, for all Fields of Testing (FoTs) for which the laboratory is accredited. An accredited laboratory that wishes to expand into a new FoT must submit an updated accreditation application to AIHA-LAP, LLC for review by the AAB.
Any changes in ownership, laboratory location, personnel, FoTs/Methods, or significant procedural changes shall be reported to AIHA-LAP, LLC in writing within twenty (20) business days of the change.
The accreditation certificate is the property of AIHA-LAP, LLC and must be returned to us should your laboratory withdraw or be removed from the IHLAP, ELLAP, and EMLAP.
Again, congratulations. If you have any questions, please contact Drake McGregor, Laboratory Accreditation
Specialist, at (703) 846-0739.
Sincerely, Cheryl O. Morton
Managing Director acknowledges that
International Asbestos Testing Laboratories (IATL) 9000 Commerce Parkway, Suite B, Mt. Laurel, NJ 08054
Laboratory ID: 100188 along with all premises from which key activities are performed, as listed above, has fulfilled the requirements of the AIHA Laboratory Accreditation
Programs (AIHA-LAP), LLC accreditation to the ISO/IEC 17025:2017 international standard, General Requirements for the Competence of Testing and
Calibration Laboratories in the following:
LABORATORY ACCREDITATION PROGRAMS
✓ INDUSTRIAL HYGIENE Accreditation Expires: September 01, 2021
✓ ENVIRONMENTAL LEAD Accreditation Expires: September 01, 2021
✓ ENVIRONMENTAL MICROBIOLOGY Accreditation Expires: September 01, 2021
FOOD Accreditation Expires:
UNIQUE SCOPES Accreditation Expires:
Specific Field(s) of Testing (FoT)/Method(s) within each Accreditation Program for which the above named laboratory maintains accreditation is outlined on the attached Scope of Accreditation. Continued accreditation is contingent upon successful on-going compliance with ISO/IEC 17025:
2017 and AIHA-LAP, LLC requirements. This certificate is not valid without the attached Scope of Accreditation. Please review the AIHA-LAP, LLC website (www.aihaaccreditedlabs.org) for the most current Scope.
Elizabeth Bair
Chairperson, Analytical Accreditation Board
Cheryl O. Morton
Managing Director, AIHA Laboratory Accreditation Programs, LLC
Revision 17 – 09/11/2018 Date Issued: 09/30/2019 http://www.aihaaccreditedlabs.org/
Effective: 04/10/2015
100188_Scope_IHLAP_2019_09_30
AIHA Laboratory Accreditation Programs, LLC
SCOPE OF ACCREDITATION
International Asbestos Testing Laboratories (IATL) Laboratory ID: 100188 9000 Commerce Parkway, Suite B, Mt. Laurel, NJ 08054 Issue Date: 09/30/2019
The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients are urged to verify the laboratory’s current accreditation status for the particular field(s) of testing/Methods, since these can change due to proficiency status, suspension and/or withdrawal of accreditation.
Industrial Hygiene Laboratory Accreditation Program (IHLAP)
Initial Accreditation Date: 03/01/1991
A complete listing of currently accredited Industrial Hygiene laboratories is available on the AIHA-LAP, LLC website at:
http://www.aihaaccreditedlabs.org
IHLAP Scope
Category
Field of Testing (FoT)
(FoTs cover all relevant IH matrices)
Technology sub-type/
Detector
Published Reference
Method/Title of In-house Method
Method Description or Analyte (for internal methods only)
Spectrometry Core Atomic Absorption FAA NIOSH 7082
X-ray Diffraction (XRD) NIOSH 7500
Asbestos/Fiber
Microscopy Core
Polarized Light
Microscopy (PLM)
EPA 600/R-93/116
Phase Contrast
Microscopy (PCM)
NIOSH 7400
Transmission Electron
Microscopy (TEM)
NIOSH 7402
Effective: 10/14/2016
Scope_ELLAP_R7
AIHA Laboratory Accreditation Programs, LLC
SCOPE OF ACCREDITATION
International Asbestos Testing Laboratories (IATL) Laboratory ID: 100188 9000 Commerce Parkway, Suite B, Mt. Laurel, NJ 08054 Issue Date: 09/30/2019
The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients are urged to verify the laboratory’s current accreditation status for the particular field(s) of testing/Methods, since these can change due to proficiency status, suspension and/or withdrawal of accreditation.
The EPA recognizes the AIHA-LAP, LLC ELLAP program as meeting the requirements of the National Lead Laboratory
Accreditation Program (NLLAP) established under Title X of the Residential Lead-Based Paint Hazard Reduction Act of 1992 and includes paint, soil and dust wipe analysis.
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