Amendment 3 attachment C8417 Lead Asbestos and Radon Assessment Report.pdf

LEAD, ASBESTOS, AND RADON ASSESSMENT

REPORT #41

Prepared for

United States Coast Guard Facilities Design and Construction Center, Atlantic 5505 Robin Hood Road, Suite K Norfolk, Virginia 23513-2431

October 1998

F I N A L

Contract Number: DTCG47-96-D-3EFK09/TOK09-0033

U.S. COAST GUARD

VIRGINIA HOUSING - CAPE HENRY LIGHTHOUSE,

PORTSMOUTH FLAG QUARTERS, RTC

YORKTOWN SENIOR OFFICERS QUARTERS, AND

STATION MILFORD HAVEN HOUSING & UPH

Woodward-Clyde Federal Services a subsidiary of URS Corporation 200 Orchard Ridge Drive, Suite 101 Gaithersburg, Maryland 20878 301-258-9780

Prepared by

TABLE OF CONTENTSTABLE OF CONTENTS

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Executive Summary.....................................................................................................................................ES-1

Section 1 ONE Introduction ..........................................................................................................................1-1

1.1 Scope of Services ..................................................................................1-1

1.2 Applicable Regulations ..........................................................................1-2

1.2.1 Radon ........................................................................................1-2

1.2.2 Lead-Based Paint .......................................................................1-2

1.2.3 Lead In Water ............................................................................1-3

1.2.4 Asbestos ....................................................................................1-3

1.2.5 Criteria for Lead ........................................................................1-3

1.2.6 State Regulations .......................................................................1-3

1.3 USCG Major Finding Conditions ...........................................................1-4

1.4 Summary of Criteria for Contaminants Assessed ....................................1-5

1.5 Recommended Actions ..........................................................................1-5

1.5.1 Radon ........................................................................................1-5

1.5.2 Lead ..........................................................................................1-6

1.5.3 Asbestos ....................................................................................1-7

1.6 Housing Data / Responsible Authorities .................................................1-9

1.7 Housing Unit Data...............................................................................1-10

1.8 Basis of Cost Estimates .......................................................................1-10

1.9 Limitations ..........................................................................................1-11

Section 2 TWO Radon ....................................................................................................................................2-1

2.1 Radon Results .......................................................................................2-1

2.2 Recommendations .................................................................................2-1

Section 3 THREE Lead .......................................................................................................................................3-1

3.1 Lead-Based Paint...................................................................................3-1

3.1.1 Results .......................................................................................3-1

3.1.2 Recommendations......................................................................3-1

3.2 Lead In Dust..........................................................................................3-2

3.2.1 Results .......................................................................................3-2

3.2.2 Recommendations......................................................................3-2

3.3 Lead In Soil...........................................................................................3-3

3.3.1 Results .......................................................................................3-3

3.3.2 Recommendations......................................................................3-3

3.4 Lead In Drinking Water .........................................................................3-4

3.4.1 Results .......................................................................................3-4

3.4.2 Recommendations......................................................................3-5

Section 4 FOUR Asbestos...............................................................................................................................4-1

4.1 Asbestos Results....................................................................................4-1

4.2 Recommendations .................................................................................4-2

TABLE OF CONTENTSTABLE OF CONTENTS

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Section 5 FIVE Playgrounds .........................................................................................................................5-1

5.1 Playground Sample Results....................................................................5-1

5.2 Recommendations .................................................................................5-1

Section 6 SIX Definitions and Acronyms..................................................................................................6-1

List of Figures, Tables and Appendices

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Figures

Figure 1 Site Location Map - Cape Henry Lighthouse, Virginia Beach, VA

Figure 2 Site Location Map - Portsmouth Flag Quarters

Figure 3 Site Location Map - RTC Yorktown and Housing for Station Milford Haven

Tables

Table 1-1 Housing Unit Data

Table 2-1 Radon Sample Results

Table 3-1 Positive RMD XRF Sample Results

Table 3-2 Lead in Paint Action Cost Results

Table 3-3 Lead in Dust Sample Results

Table 3-4 Lead in Dust Action Cost Results

Table 3-5 Lead in Soil Sample Results

Table 3-6 Lead in Soil Action Cost Results

Table 3-7 Lead in Water Sample Results

Table 4-1 Positive Asbestos Sample Results

Table 4-2 Asbestos Action Cost Results

Table 5-1 Playground - Lead in Soil Sample Results

Appendices

Appendix A Personnel and Laboratory Certifications

Appendix B Major Finding Correspondence

Appendix C HUD Standard Reevaluation Schedule

Appendix D Site Drawings and Floor Plans

Appendix E Photographs

Appendix F Laboratory Report - Radon

Appendix G Field Data - Lead

Appendix H Laboratory Analysis - Lead

Appendix I Drinking Water Survey Data

Appendix J Field Data - Asbestos

Appendix K Laboratory Analysis - Asbestos

Executive Summary

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Woodward-Clyde Federal Services (WCFS) was retained by United States Coast Guard (USCG) Facilities Design and Construction Center, Atlantic (FDCC-LANT) under contract DTCG47-96-D- 3EFK09 Task Order Number TOK09-0033 to perform Lead, Asbestos, and Radon Assessment Services in North Carolina and Virginia. This report addresses sites assessed in Virginia. The assessment was conducted from March 19 through March 25, 1998. A separate report was issued to address sites assessed in North Carolina.

The purpose of this task order was to locate and quantify radon, lead-based paint (LBP), lead in dust, soil, and drinking water, and asbestos-containing materials (ACM) in USCG family housing, unaccompanied personnel housing (UPH) and child development centers (CDCs), and associated playgrounds. Housing units in the following areas were assessed in Virginia:

• Cape Henry Lighthouse

• Portsmouth Flag Quarters

• RTC Yorktown Senior Officers Quarters

• Station Milford Haven (including housing units in Cobbs Creek, Dutton, Hudgins, and Gloucester)

One playground was identified and assessed at Cape Henry Lighthouse. No CDCs were identified.

Survey Results and Recommendations

Radon

• Radon levels detected at all units surveyed were below the Environmental Protection Agency (EPA) action level (AL) of 4.0 picoCuries per liter (pCi/L).

Lead

• Painted surfaces at some family housing units exceeded the United States Department of Housing and Urban Development (HUD), Commonwealth of Virginia, and USCG ALs for lead in paint of 1.0 mg/cm2 as measured by Radiation Monitoring Device (RMD) X-ray fluorescence (XRF). Surface conditions ranged from intact to poor. It is recommended that painted components in intact condition be included in a Lead Hazard Management Plan. The Management Plan should address the maintenance of intact painted surfaces and substrate and should remain in place until abatement of lead from components or removal of painted components from the building. Surfaces in fair condition should be stabilized and included in the Lead Hazard Management Plan. Surfaces in poor condition should be abated by removing the lead-containing paint and the surface should be repainted with lead-free paint.

• Lead in dust exceeded the HUD, Virginia, and USCG AL for window troughs (800 µg/ft2) at Quarters 1, Guest Quarters, Building 64, RTC Yorktown (8100 µg/ft2). It is recommended that the affected areas be cleaned using a phosphate-based detergent and all surfaces in the units should be cleaned using a HEPA filtered vacuum. Lead in paint is the most likely source of the lead in dust. All other units had lead in dust levels below the HUD, Virginia, and USCG ALs, however, four other units had high lead in dust levels and although the HUD, Executive Summary

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Virginia, and USCG ALs were not exceeded, consideration should be given to cleaning the affected areas.

• Lead in soil levels were below recommended the HUD and Virginia ALs of 400 µg/g for play areas and 2,000 µg/g for building perimeters and yards, and USCG AL (2,000 µg/g) in all areas surveyed with the exception of Quarters C1/C2, Cape henry Lighthouse (3100 µg/g) and Quarters A, Building A, RTC Yorktown (600 µg/g).

• Lead in drinking water in first draw and flush samples was below the HUD and Virginia AL of 15 µg/L, and USCG AL of 50 µg/L at all locations surveyed.

Asbestos

• Asphalt roofing shingles, transite siding, floor tile, linoleum, resilient floor surface (RFS), cove base, and mastics were not sampled and are assumed to be ACM for purposes of this report.

• Sample results indicate ACM are present in some housing units. Materials found to contain asbestos include kitchen sink undercoating and interior caulking. Materials were in good condition. It is recommended that intact materials be included in an Asbestos Management Plan.

Playgrounds

• One playground at Cape Henry Lighthouse was assessed. Lead in paint was not assessed because the playground consisted of plastic and wooden equipment with no painted surfaces.

Lead in soil was also below the HUD and Commonwealth of Virginia AL of 400 µg/g and the USCG AL of 2000 µg/g. No asbestos in soil samples were collected because sand boxes were not present.

Recommended Action Cost Estimate Summary

Cost estimates were developed for recommended actions based on RS Means Building Construction Cost Data, 1998 and ECHOS Environmental Remediation Cost Data, 1998.

Cost estimates for recommended actions are presented on tables for each sample matrix (radon, lead in paint, lead in dust, lead in soil, lead in water, and asbestos), where applicable. The total cost for each sample matrix is presented on the following table:

Matrix Cape Henry Lighthouse

Portsmouth Flag Quarters

RTC

Yorktown

Station Milford Haven

Radon $0 $0 $0 $0

Lead in Paint $1,925 $427 $2,609 $3,456

Lead in Dust $0 $0 $2,275 $0

Lead in Soil $529 $0 $529 $0

Lead in Water $0 $0 $0 $0

Asbestos $2,560 $599 $1,268 $4,126

SECTIONSECTIONONE Introduction

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1. Section 1 ONE Introduction

1.1 SCOPE OF SERVICES

Woodward-Clyde Federal Services (WCFS) was retained by United States Coast Guard (USCG) Facilities Design and Construction Center, Atlantic (FDCC-LANT) under contract DTCG47-96-D- 3EFK09 Task Order Number TOK09-0033 to perform Lead, Asbestos, and Radon Assessment Services in North Carolina and Virginia. This report addresses sites assessed in Virginia. The assessment was conducted from March 19 through March 25, 1998. A separate report was issued to address sites assessed in North Carolina.

The purpose of this task order was to locate and quantify lead-based paint (LBP); lead in dust, soil and drinking water; asbestos-containing materials (ACM); and radon in USCG family housing, unaccompanied personnel housing (UPH) and child development centers (CDCs), and associated playgrounds. Housing units in the following areas were assessed in Virginia (see Figures 1, 2, and 3):

• Cape Henry Lighthouse

• Portsmouth Flag Quarters

• RTC Yorktown Senior Officers Quarters

• Station Milford Haven (including housing units in Cobbs Creek, Dutton, Hudgins, and Gloucester)

One playground was identified and assessed at Cape Henry Lighthouse. No CDCs were identified.

The following activities were performed:

• A regulatory review was completed to determine applicable State requirements for conducting radon, lead and asbestos surveys. (See Section 1.2).

• Radon gas surveys were conducted through the installation of commercially available charcoal radon monitoring kits.

• A LBP survey was conducted using a Radiation Monitoring Device (RMD) X-ray fluorescence (XRF) analyzer and selective paint chip sampling.

• Lead in dust was evaluated through the collection of wipe samples from bare floors, carpeted floors, window sills, and window troughs.

• Lead in drinking water was evaluated through the collection of first draw and flush water samples.

• Drinking water was also assessed by performing an evaluation of the local water supply plant’s compliance to the Safe Drinking Water Act.

• Lead in soil was evaluated through the collection of perimeter soil samples near building driplines, bare soil in playgrounds, and background locations.

• Suspected ACMs were evaluated through surveying the interior and exterior of structures and collecting bulk samples for analysis.

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Included in this report are recommendations and planning cost estimates for the abatement, remediation, and/or management of the materials found.

Dates of Assessment

Facilities were assessed on the following dates:

Cape Henry Lighthouse

• March 19, 1998

Portsmouth Flag Quarters

• March 20, 1998

RTC Yorktown Senior Officers Quarters

• March 23, 1998

Station Milford Haven

• March 24 and 25, 1998

1.2 APPLICABLE REGULATIONS

1.2.1 Radon

The Environmental Protection Agency (EPA) established a residential action level (AL) of 4 picoCuries per Liter (pCi/L) for radon. The Indoor Radon Abatement Act (IRAA) of 1988 (Title III of Toxic Substances Control Act or TSCA) required EPA to establish regional radon mitigation centers that train and certify private contractors in residential radon measurement and mitigation. While the EPA provides a listing service for certified contractors they neither require certification nor endorse those listed. The Commonwealth of Virginia requires personnel performing the placement of radon canisters to have passed the EPA Radon Proficiency Exam for Measurements and be listed by the EPA. Personnel who have passed the EPA Radon Proficiency Exam for Measurements placed the radon canisters for this project. Certification forms are located in Appendix A.

1.2.2 Lead-Based Paint

Federal standards for lead hazards are defined in the Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing published by the United States Department of Housing and Urban Development (HUD) in June 1995. The EPA has established training requirements for various lead-related activities. Personnel conducting this survey were trained as lead inspectors/risk assessors, as required by 40 Code of Federal Regulation (CFR) 745, Subpart L (August 1996). In addition, personnel using XRF instrumentation must have received training addressing the proper use of the instrument and topics in Radiation Safety in accordance with Nuclear Regulatory Commission (NRC). Personnel trained in the operation of RMD’s LPA-1 Lead Paint Inspection System operated the RMD XRF analyzer during this lead assessment. The Commonwealth of Virginia requires the successful completion of an EPA/Virginia Certified course. In addition, personnel must pass the Virginia licensing exam. Personnel possessing a

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Virginia Lead-based Paint License were used for this project. Certification forms are located in Appendix A.

1.2.3 Lead in Water

In 40 CFR, Parts 141 and 142 (June 1991), the EPA established an AL of 15 micrograms per liter (µg/L) lead (effective December 1992) for public water supply utilities. The AL is exceeded if the level of lead in more than 10 percent of the targeted tap samples is greater than 15 µg/L. The public water supply utility must implement corrosion control measures for the portion of the system under its control if the AL is exceeded. If the source of lead contamination is within a building, installation of a treatment device or replacement of the piping system may be necessary.

The Commonwealth of Virginia lead in water AL is 15 µg/L.

1.2.4 Asbestos

The EPA defines asbestos-containing building material (ACBM) as any material which contains one percent or greater asbestos by volume. EPA has also established regulations for conducting asbestos inspections in schools in the Asbestos Hazard Emergency Response Act (AHERA), 40 CFR 763. This regulation was used for conducting the current survey. In accordance with Public Law 101-637, Asbestos School Hazard Abatement Re-authorization Act (ASHARA), the housing unit assessments were conducted by EPA AHERA accredited asbestos inspectors and followed the AHERA assessment protocol. The Commonwealth of Virginia requires Asbestos Risk Assessors to obtain state accreditation. Commonwealth of Virginia-accredited Asbestos Risk Assessors were used for this project. Certification forms are located in Appendix A.

1.2.5 Criteria for Lead

The criteria established by HUD and the Commonwealth of Virginia for lead in paint are: 1 milligram per square centimeter (mg/cm2) when measured by XRF, or 0.5% by weight when analyzed by a laboratory. The EPA and Commonwealth of Virginia criteria for lead in dust are:

100 micrograms per square foot (µg/ft2) for floor surfaces; 500 µg/ft2 for window sills; and 800 µg/ft2 for window troughs. The HUD and Commonwealth of Virginia lead in soil criteria are 400 milligrams per kilogram (mg/kg) for play areas and high-contact areas for children, and 2,000 mg/kg for building perimeters and yards.

1.2.6 State Regulations

The scope of work for this survey was written to comply with federal regulations. The Commonwealth of Virginia regulatory requirements generally follow the federal requirements for asbestos. Asbestos risk assessors are required to obtain state accreditation. Field personnel included a Virginia Accredited Asbestos Inspector and a Virginia Licensed Lead Inspector. The Commonwealth of Virginia requires personnel performing the placement of radon survey canisters to have passed the EPA Radon Proficiency Exam for Measurements and be listed by the EPA.

Canisters were placed by personnel who have passed the Radon Proficiency Exam for Measurements, however, the formality of paying a fee and being listed by the EPA was not completed prior to the field assignment.

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1.3 USCG MAJOR FINDING CONDITIONS

As specified in the Scope of Work, the USCG has established major finding levels for each of the contaminants assessed during this survey. Should these levels (as listed below) be exceeded, immediate abatement and/or removal of residents from a housing unit may be warranted. The following criteria were used to identify major finding conditions:

• Radon levels greater than or equal to 20 pCi/L in short term tests (using a 72 hour charcoal canister as specified by the USCG in the scope of work).

• Paints containing greater than or equal to 1.0 mg/cm2 of lead as measured by XRF or greater than or equal to 0.5% by weight as measured by a laboratory; and, surfaces in the housing unit are peeling and easily accessible to children under seven years old; or, the substrate is severely damaged and easily accessible to children under seven years old.

• Dust with lead levels greater than or equal to the following limits: 100 µg/ft2 for floors, 500 µg/ft2 for window sills, and 800 µg/ft2 for window troughs.

• Soil which is bare and in a residential area with lead concentrations greater than 2000 µg/g.

• Lead in first draw water samples greater than or equal to 50 ppb (50 µg/L).

• The ACMs which are easily accessible to occupants and meets the criteria of significantly damaged as defined by AHERA.

In cases where the major finding criteria were met, a letter was sent to the Commanding Officer, USCG FDCC-LANT, indicating the situation and location of any problem areas. A letter is included in Appendix B. The following major finding letters were written for locations assessed in this report:

• Major Finding Letter #85, dated April 12, 1998, was issued listing major findings for lead in paint found in housing units at Cape Henry Lighthouse.

• Major Finding Letter #86, dated April 27, 1998, was issued listing major findings for lead in paint found in housing units at Station Milford Haven housing in Hudgins, Virginia.

• Major Finding Letter #87, dated April 27, 1998, was issued listing major findings for lead in dust found in housing at RTC Yorktown.

• Major Finding Letter #88, dated April 27, 1998, was issued listing major findings for lead in soil found at Cape Henry Lighthouse.

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1.4 SUMMARY OF CRITERIA FOR CONTAMINANTS ASSESSED

The following table summarizes the criteria used during this survey for the various contaminants assessed.

FEDERAL

(EPA, HUD)

STATE

(VA)

USCG

(MAJOR FINDING)

RADON 4.0 pCi/L 4.0 pCi/L 20.0 pCi/L

LEAD (PAINT)

XRF 1.0 mg/cm2 1.0 mg/cm2 1.0 mg/cm2

Bulk 0.5% by wt. 0.5% by wt. 0.5% by wt.

LEAD (DUST)

Floor Surface 100 µg/ft2 100 µg/ft2 100 µg/ft2

Window Sill 500 µg/ft2 500 µg/ft2 500 µg/ft2

Window Trough

800 µg/ft2 800 µg/ft2 800 µg/ft2

LEAD (SOIL) - in play areas and high contact areas for children

400 ppm (400 µg/g) 400 ppm (400 µg/g) 2000 ppm (2000 µg/g)

LEAD (SOIL) -

building perimeters and yards

2000 ppm (2000 µg/g) 2000 ppm (2000 µg/g) 2000 ppm (2000 µg/g)

LEAD (WATER) 15 ppb (15 µg/L) 15 ppb (15 µg/L) 50 ppb (50 µg/L) ASBESTOS >1% >1% >1% - damaged or significantly damaged

1.5 RECOMMENDED ACTIONS

1.5.1 Radon

Recommendations were made for additional testing or corrective action if individual sample results exceeded the EPA and Commonwealth of Virginia AL of 4 pCi/L.

Long-term monitoring was recommended if the short-term monitoring showed results above the EPA and Commonwealth of Virginia AL. If long-term monitoring shows results above the AL, the need for mitigation should be considered. If the results of monitoring are above the USCG major finding level of 20 pCi/L, mitigation was recommended.

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1.5.2 Lead

Lead-based paint, lead in dust, and lead in soil

Lead hazards and potential hazards were identified by comparison of test results to the criteria summarized in Section 1.4. The hazard assessment also included an evaluation of the paint condition and the degree of deterioration was considered in the recommended action.

The recommendations to eliminate or reduce lead hazards fall into two categories: interim controls and abatement measures. Abatement means any set of measures designed to permanently eliminate LBP hazards. Permanent, as defined in the HUD guidelines, means having an expected life of at least 20 years. Abatement measures for LBP include enclosure of surface, encapsulation of surface, removal of painted component and removal of paint. Paint removal should always be avoided, if possible, due to the dust hazard that may be created during abatement activities. For soil, a permanent cover, such as asphalt or concrete classifies as abatement. Another abatement option is the removal of contaminated soil.

Interim controls are measures designed to reduce temporarily human exposure or likely exposure to LBP hazards. Interim controls for LBP include dust removal, paint film stabilization, and treatment of friction and impact surfaces. Interim control for lead-containing soil include the introduction of a surface cover, land use controls (fencing, warning signs, planting dense bushes) and measures to reduce off-site transport of the contaminated soil (doormats). Interim controls are appropriate for implementation on a broad scale and may prove cost-effective in many cases.

When interim controls are utilized, the affected areas should be included in a Lead Hazard Management Plan. Intact LBP does not present a hazard, but these surfaces should also be included in the Management Plan. The elements of a Lead Hazard Management Plan include:

• on-going monitoring

• employee training

• medical surveillance

• respiratory protection program

• occupant education/notification

• Operations and Maintenance (O&M) Program

On-going monitoring should be conducted in accordance with the HUD Standard Re-evaluation Schedules (SRS). Visual surveys should be conducted at least annually and when a dwelling is vacated. Trained maintenance personnel can conduct these surveys. Re-evaluations must be conducted by an EPA and Commonwealth of Virginia accredited risk assessor.

The O&M procedures should be developed for each type of repair or clean-up operation anticipated. These written procedures will include work practices and the use of proper equipment, including personal protective equipment.

The actions recommended in this report are made in accordance with HUD guidelines. In some instances, a more conservative action may be recommended if it is more cost-effective than long-term management in place.

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Assignment of Reevaluation Schedule

HUD has established Standard Reevaluation Schedules (SRS) that describe how frequently a certified risk assessor should reevaluate a housing unit, based on the results of the initial evaluation. The results of this survey were categorized and assigned schedule numbers as summarized in the table below. The schedule numbers are included in the lead in paint, lead in dust, and lead in soil action cost results tables (where applicable) for units that were assessed. A copy of the SRS in their entirety is included in Appendix C.

Schedule Evaluation Results

1 No leaded dust, leaded soil or LBP identified

2 No LBP hazards identified during risk assessment conducted before hazard control or at clearance (hazards include dust and soil)

3 Average of leaded dust levels on all floors, interior window sills, or window troughs sampled exceeded the applicable standard by less than a factor of 10

4 Average of leaded dust levels on all floors, interior window sills, or window troughs sampled exceeded the applicable standard by a factor of 10 or more

5 No leaded dust or leaded soil hazards identified, but LBP or LBP hazards were found

6 Bare leaded soil exceeded standard, but less than 5,000 micrograms per gram

7 Bare leaded soil greater than or equal to 5,000 micrograms per gram

Lead in Water

Recommendations were made for corrective action if individual sample results exceeded the EPA and Commonwealth of Virginia AL of 15 ppb (15 µg/L).

If the first draw sample, but not the flush sample, exceeds the AL, occupants should be educated to run water for a period of five minutes before using it for cooking or drinking purposes. If both the first draw and the flush sample, or just the flush sample, exceed the AL, remediation, such as the installation of a treatment device or replacement of piping, may be in order, particularly if the level exceeds the USCG major finding level of 50 ppb (50 µg/L).

1.5.3 Asbestos

A hazard ranking was assigned to each material identified by laboratory analysis to contain greater than 1% asbestos or assumed to contain asbestos, based on the condition of the material and the potential for disturbance. The EPA and Commonwealth of Virginia Certified assessor rated the condition of the material as good, damaged, or significantly damaged. Factors considered included the quality of installation, adhesion of the material to the outer covering, delamination, contact damage, and material disintegration.

The disturbance potential ranking takes into account the accessibility of the material (contact damage), noise and/or mechanical vibration, and air flow across a surface.

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Rankings were assigned based on the following key:

Hazard Rank Material Condition Disturbance Potential

1 Good Low

2 Good Potential for Damage

3 Good Potential for Significant Damage

4 Damaged Low

5 Damaged Potential for Damage

6 Damaged Potential for Significant Damage

7 Significantly Damaged Any

Hazard rankings were assigned based on the condition of ACMs (good, damaged, significantly damaged) and the potential for damage (accessibility, air movement, vibration) determined by the inspector at the time of the survey. Recommendations for response actions were based on these hazard rankings. Response actions include removal, encapsulation, enclosure, repair, and O&M.

All ACM and suspected ACM should be included in an O&M Program until they are removed from the building or the building is demolished.

Materials were categorized into four priority levels based on the above information. These levels are defined as follows:

Priority I – Material significantly damaged; abatement (removal) recommended

Priority II – Material damaged; abatement (removal, encapsulation, enclosure) recommended

Priority III – Material has minor damage; repair and O&M recommended

Priority IV – Material in good condition; O&M recommended

Priority levels are included on the asbestos action cost results tables. On occasion, when a small amount of material was present in multiple locations, removal was recommended, not because of the hazard involved, but because this approach was more cost-effective.

Materials which are not removed should be included in an Asbestos Management Plan (AMP).

The AMP should remain in place until all ACBM is removed or the building is demolished.

Elements of an AMP are:

• Identification/location of ACBM

• Assignment of roles/responsibilities

• Personnel training

• Medical surveillance

• Respiratory protection program

• Visual surveys and re-inspections

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• Work permit program

• O&M Program

The O&M Program should include established work practices for the various types of activities that are expected to be performed during building maintenance. Written procedures should provide detailed information on the equipment to be used, including personal protective equipment, the method of containment and air monitoring requirements.

1.6 HOUSING DATA / RESPONSIBLE AUTHORITIES

The following table provides information on responsible housing authorities.

Cape Henry Lighthouse

Portsmouth Flag Quarters

RTC Yorktown Station Milford Haven

OPFAC Number 05-36235 32-47100 75-63100 05-30287

Responsible Unit Group Hampton Roads

Group Hampton Roads

RTC Yorktown Facility Engineering

Group Hampton Roads

Responsible Unit Phone Number

(757) 483-8515 (757) 686-4044 (757) 898-2249 (757) 483-8515

Construction Date 1940, 1938 1955 1936-1941 1967-1981

Number of Housing Units

3 1 2 plus guest house 8

Number of UPHs (units/rooms)

1 (Qtrs C)/4 rooms

NA NA 1/9 rooms

Number of Playgrounds

1 None None None

Area Housing Authority

ISC Portsmouth ISC Portsmouth RTC Yorktown ISC Portsmouth

Area Housing Authority Phone Number

(757) 686-4044 (757) 686-4044 (757) 898-2177 (757) 686-4044

Local Housing Authority

Group Hampton Roads

ISC Portsmouth RTC Yorktown Administration

Group Hampton Roads

Civil Engineering Unit

Cleveland Cleveland FDCC-LANT Cleveland

Civil Engineering Unit OPFAC Number

(216) 522-3934 (216) 522-3934 32-73001 (216) 522-3934

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1.7 HOUSING UNIT DATA

Housing unit data are presented on Table 1-1. Information regarding gross area, net living area, construction date, number of stories, bathrooms and bedrooms, type of unit, exterior, foundation, and roof is provided. Appendix D contains floor plans and sample locations for each unit assessed. Photographs are presented in Appendix E.

1.8 BASIS OF COST ESTIMATES

Cost estimates were developed for recommended actions based on RS Means Building Construction Cost Data, 1998 and ECHOS Environmental Remediation Cost Data, 1998. The following list indicates assumptions developed for each sample constituent:

• The LBP recommended action costs for annual O&M include maintenance personnel visits to each unit once a year to perform visual inspection and painting surfaces as necessary. The cost also includes record keeping of all units and annual blood sampling for children living in each unit. For cost estimation purposes, it was assumed that two children were living in each unit. The cost for developing a Lead Hazard Management Plan (O&M Plan) is not included.

• The LBP recommended action costs for abatement include worker mobilization to the site, bulk paint removal, and disposal of removed material as hazardous waste for each individual material (the cost would likely be reduced if abatement of multiple materials were performed at the same time). Replacement costs include workers mobilization to the site, preparation, and painting of surfaces after abatement for each individual material (the cost would likely be reduced if abatement of multiple materials were performed at the same time).

• Lead in dust recommended action costs include cleaning the affected area with phosphate-based detergent and cleaning all vertical and horizontal surfaces in the unit with a HEPA filtered vacuum. Annual blood sampling for children living in each unit is also included. For cost estimation purposes, it was assumed that two children were living in each unit.

• Lead in soil recommended action costs include the cost of discrete soil sampling to determine the extent of lead in soil contamination. In addition, the cost of encapsulating the area is included on the action cost table. Final recommended actions should be based on the results of discrete soil samples. These actions may include encapsulation or removal of soil.

• Asbestos recommended action costs for O&M include maintenance personnel visits to each unit once every 6 months to perform visual inspection and record keeping. The cost to develop an AMP is not included. Asbestos abatement cost includes mobilization to the site, notification fee, abatement air monitoring, bulk asbestos abatement, abatement inspection, and asbestos materials disposal for each individual material (the cost would likely be reduced if abatement of multiple materials were performed at the same time). Replacement cost includes mobilization to the site and installation of new items for each individual material (the cost would likely be reduced if abatement of multiple materials were performed at the same time).

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1.9 LIMITATIONS

The conclusions presented in this report are the professional opinions of Woodward-Clyde based on the indicated data obtained during this assessment and described in this report. They are intended only for the purpose and the location of this specific project.

The purpose of this survey was to identify and assess ACM, lead (paint, dust, soil, and water) and radon in specified buildings and areas.

The on-site survey was limited to visual observations of the accessible interior and exterior spaces of the buildings.

The survey was “non-destructive”, and a limited number of samples were collected under the terms of the contract. It is possible that some ACM or lead may not have been identified. For example, material within walls was not sampled. It is also possible that asbestos or lead may not have been detected in some sampled materials due to variations in material composition or limitations inherent in analytical techniques. Finally, it is possible that some material which was assumed to be ACM but not sampled does not contain asbestos.

No warranty or guarantee, either expressed or implied, concerning the findings or conclusions of this survey is offered or intended. Rather, it is represented that the scope and performance of the professional services rendered are in accordance with the current state of practice as conducted by similarly qualified practitioners.

Changes in applicable standards may occur as a result of legislation or the broadening of knowledge. Accordingly, the findings of this report may be invalidated, wholly or in part, by changes beyond our control. Opinions and judgments expressed herein, which are based on our understanding and interpretation of current regulatory standards, should not be construed as legal opinions.

SECTIONSECTIONTWO Radon

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2. 2. Section 2 TWO Radon

Each housing unit assessed was tested for radon gas using a commercially available carbon canister device of the type specified by the USCG in the Scope of Work. The canisters used were the type supplied by Key Technology Inc., having an approximate exposure time of 72 hours and a lower limit of detection of 0.2 pCi/L, as specified in the Scope of Work. Canisters were placed in basements, if present, or in a room on the lowest level of the unit. Canisters were left in place for approximately 72 hours and then removed. Each canister was submitted to Key Technology Inc., Jonestown, Pennsylvania, for analysis; results are presented on Table 2-1. Laboratory results are provided in Appendix F.

2.1 RADON RESULTS

Results of radon samples collected at housing units were below the EPA and Commonwealth of Virginia recommended guidance level of 4 pCi/L. Sample results are presented on Table 2-1.

2.2 RECOMMENDATIONS

No results exceeded recommended guidance levels, therefore, no recommendations are offered at this time.

SECTIONSECTIONTHREE Lead

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3. 3. Section 3 THREE Lead

3.1 LEAD-BASED PAINT

Housing units were surveyed for LBP using an RMD XRF analyzer as specified in the Scope of Work. This direct readout device has an error of ±0.2 mg/cm2. Positive and inconclusive results are presented on Table 3-1. It was not necessary to collect paint chip samples during this assessment because no paint surfaces had inconclusive results as measured by the RMD XRF.

Recommended action cost estimates are presented on Table 3-2. Positive sample locations are indicated on figures presented in Appendix D. Laboratory results and field data sheets are provided in Appendices G and H.

3.1.1 Results

Cape Henry Lighthouse

No components surveyed at Quarters A or Quarters C2 exceeded the HUD, Commonwealth of Virginia, or USCG AL. Multiple components surveyed at Quarters B and Quarters C1 exceeded the HUD, Commonwealth of Virginia, and USCG AL. Painted surfaces were in good to poor condition at the time of the assessment. Results are presented in Table 3-1.

Portsmouth Flag Quarters

Multiple components surveyed at 301 Sycamore Street exceeded the HUD, Commonwealth of Virginia, and USCG AL. Painted surfaces were in good to fair condition at the time of the assessment. Results are presented in Table 3-1.

RTC Senior Officers Quarters

Multiple components surveyed at Quarters 1-Building 44, Quarters 1-Building 64 (Guest Quarters), and Quarters A-Building A exceeded the HUD, Commonwealth of Virginia, and USCG AL. Painted surfaces were in good to fair condition at the time of the assessment. Results are presented in Table 3-1.

Station Milford Haven

No components surveyed at Lot 5 Cobbs Creek, Lot 12 Dutton, Lot 13 Dutton, Lot 14 Dutton, or Lot 24 Gloucester exceeded the HUD, Commonwealth of Virginia, or USCG AL. Multiple components surveyed at Lot 18 Cobbs Creek, Quarters 1 Hudgins, Quarters 2 Hudgins, exceeded the HUD, Commonwealth of Virginia, and USCG AL. Painted surfaces were in good to poor condition at the time of the assessment. Results are presented in Table 3-1.

3.1.2 Recommendations

Action cost estimates are presented on Table 3-2. Children living in housing units testing positive for LBP should undergo blood lead testing. The recommended action for intact areas is inclusion in a Lead Hazard Management Plan and O&M which includes maintaining intact surfaces and substrates. Components in fair condition should be stabilized and included in a Lead Hazard Management Plan. Components in poor condition should be abated through removal and replacement of surface paint.

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3.2 LEAD IN DUST

Dust samples were collected from bare floor areas, carpeted floor areas, window sills, and window troughs (where applicable). Samples were submitted to Gascoyne Laboratories, Inc., Baltimore, Maryland, and analyzed for lead content using flame atomic absorption. Results are presented on Table 3-3. Laboratory results and field data sheets are provided in Appendices G and H, respectively.

3.2.1 Results

Cape Henry Lighthouse

No samples collected exceeded the HUD, Commonwealth of Virginia, or USCG ALs. The window sills at Quarters A and Quarters C1 had relatively high lead in dust levels, 84 µg/ft2 and 210 µg/ft2, respectively, although the ALs were not exceeded. Results are presented on Table 3- 3.

Portsmouth Flag Quarters

No samples collected exceeded ALs. Results are presented on Table 3-3.

RTC Yorktown Senior Officers Quarters

No samples collected exceeded ALs with the exception of the window troughs (8100 µg/ft2) at Quarters 1 Building 64 (Guest Quarters). Results are presented on Table 3-3.

Station Milford Haven

No samples collected exceeded ALs. The window troughs at Lot 5 Cobbs Creek and Quarters 1 Hudgins had relatively high lead in dust levels, 84 µg/ft2 and 540 µg/ft2, respectively, although the ALs were not exceeded. Results are presented on Table 3-3.

3.2.2 Recommendations

Cape Henry Lighthouse

No lead in dust samples exceeded ALs, therefore no recommendations are offered at this time.

Consideration should be given to thoroughly cleaning Quarters A and Quarters C1, although the ALs were not exceeded.

Portsmouth Flag Quarters

No lead in dust samples exceeded ALs, therefore no recommendations are offered at this time.

RTC Yorktown Senior Officers Quarters

Window troughs at Quarters 1 Building 64 (Guest Quarters) exceeded the HUD, Commonwealth of Virginia, and USCG AL. The affected area should be washed using a phosphate-based detergent and all surfaces in the unit should be cleaned using a HEPA filtered vacuum. Care should be taken to prevent future build-up of dust in these areas. It is assumed that the source of the lead is LBP. Children living in housing units testing positive for lead should undergo blood lead testing. An action cost estimate is presented on Table 3-4.

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Station Milford Haven

No lead in dust samples exceeded ALs, therefore no recommendations are offered at this time.

Consideration should be given to thoroughly cleaning Lot 5 Cobbs Creek and Quarters 1 Hudgins, although the ALs were not exceeded.

3.3 LEAD IN SOIL

Soil samples were collected under driplines at all of the housing units. One background soil sample was collected from each housing area sampled. The soil samples were submitted to Gascoyne Laboratories, Inc., Baltimore, Maryland, for analysis by flame atomic absorption.

Results are presented on Table 3-5. Laboratory results and field data sheets are provided in Appendices G and H.

3.3.1 Results

Cape Henry Lighthouse

Soil lead levels were below the HUD, Commonwealth of Virginia, and USCG ALs with the exception of Quarters C1/C2 (3100 mg/kg). Quarters C1 and C2 are in the same building. The first floor unit is designated as C1 and the second floor unit is designated as C2. Results are presented on Table 3-5.

Portsmouth Flag Quarters

Soil lead levels were below the HUD, Commonwealth of Virginia, and USCG ALs. Results are presented on Table 3-5.

RTC Yorktown Senior Officers Quarters

Soil lead levels were below the HUD, Commonwealth of Virginia, and USCG ALs with the exception of Quarters A Building A (600 mg/kg). Results are presented on Table 3-5.

Station Milford Haven

Soil lead levels were below the HUD, Commonwealth of Virginia, and USCG ALs. Results are presented on Table 3-5.

3.3.2 Recommendations

Cape Henry Lighthouse

Lead in soil results exceed the HUD, Commonwealth of Virginia, and USCG ALs at Quarters C1/C2. Access to the area should be limited. Access can be limited using resident notification, posting signs, or through the installation of fencing or vegetation. Discrete soil samples should be collected in the area of the dripline at Quarters C1/C2 to determine the extent of lead in soil contamination. These additional results should be used to determine what action should be taken.

Future actions may include soil encapsulation or remediation. Lead in exterior paint on Quarters C1/C2 is likely the source of lead in the soil. Recommendations regarding lead in paint should be followed to limit future lead in soil contamination. Action cost results are presented on Table 3-6.

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Portsmouth Flag Quarters

Lead in soil was not detected above the HUD, Commonwealth of Virginia, or USCG ALs in this area, therefore, no recommendations are offered at this time.

RTC Yorktown Senior Officers Quarters

Lead in soil results exceed the HUD, Commonwealth of Virginia, and USCG ALs at Quarters A, Building A. Access to the area should be limited. Access can be limited using resident notification, posting signs, or through the installation of fencing or vegetation. Discrete soil samples should be collected in the area of the dripline at Quarters A, Building A to determine the extent of lead in soil contamination. These additional results should be used to determine what action should be taken. Future actions may include soil encapsulation or remediation. Lead in exterior paint on Quarters A, Building A is likely the source of lead in the soil. Recommendations regarding lead in paint should be followed to limit future lead in soil contamination. Action cost results are presented on Table 3-6.

Station Milford Haven

Lead in soil was not detected above the HUD, Commonwealth of Virginia, or USCG ALs in this area, therefore, no recommendations are offered at this time.

3.4 LEAD IN DRINKING WATER

First draw and flush water samples were collected in laboratory supplied 1000 milliliter (ml) bottles. Water samples were then transferred to 250 ml bottles for shipment to the laboratory to decrease shipping volume and weight. Samples were collected from kitchen faucets, where applicable, at all housing units. The first draw samples were collected after no reported water usage during the eight hours prior to sample collection. After the first draw samples were collected, flush samples were collected after running the tap water for a period of five minutes.

Samples were submitted to Gascoyne Laboratories, Inc., Baltimore, Maryland, and analyzed using EPA Method 200.9, Atomic Absorption, furnace technique. The detection limit was 2 ppb (2 µg/L). Water sample results are presented on Table 3-7. Laboratory results and field data sheets are provided in Appendices G and H, respectively. In addition to water sample collection, public water supply departments for each housing area were contacted to obtain the most recent copy of water sample results collected to maintain compliance with the Safe Drinking Water Act.

Information obtained regarding public water supply departments is discussed below. These results are included in Appendix I.

3.4.1 Results

Cape Henry Lighthouse

All first draw sample and flush water sample results were below the EPA National Primary Drinking Water Standard for lead, the Commonwealth of Virginia AL, and the USCG major finding criteria. Results are presented on Table 3-7.

Copies of the most recent water sample results were obtained from the City of Norfolk, Department of Utilities, Division of Water Production and Division of Water Quality. Lead

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content in water at the Moores Bridges Water Treatment Plant and the 37th Street Water Treatment Plant was below detection limits on the most recent sampling event for the first quarter of 1998.

Information obtained from the City of Norfolk, Department of Utilities, Division of Water Production and Division of Water Quality is included in Appendix I.

Portsmouth Flag Quarters

All first draw sample and flush water sample results were below the EPA National Primary Drinking Water Standard for lead, the Commonwealth of Virginia AL, and the USCG major finding criteria. Results are presented on Table 3-7.

Copies of the most recent water sample results were obtained from the City of Portsmouth, Department of Public Utilities, Water Quality Division. According the 1998 Water Quality Report, which summarizes all of the water quality results for 1997, lead content in water was below detection limits.

Information obtained from the City of Portsmouth, Department of Public Utilities, Water Quality Division is included in Appendix I.

RTC Yorktown Senior Officers Quarters

All first draw sample and flush water sample results were below the EPA National Primary Drinking Water Standard for lead, the Commonwealth of Virginia AL, and the USCG major finding criteria. Results are presented on Table 3-7.

Copies of the most recent water sample results were obtained from the City of Newport News Waterworks. Lead content in water at the Lee Hall Water Treatment Plant was below detection limits on the most recent…