Base_Seattle_Asbestos_Lead_Report_120513_Reference_Document.pdf

Asbestos and Lead Based Paint Survey Report

Restrooms and South Entrance

USCG-Base Seattle, Building 1

1519 Alaskan Way South

Seattle, King County, Washington December 5, 2013

Terracon Project No. 81137095

Prepared for:

United States Coast Guard

CEU Oakland

Prepared by:

Terracon Consultants, Inc.

Mountlake Terrace, Washington As a Subcontractor to EnviroApplications, Inc.

San Diego, California

KMLee1 Text Box

REFERENCE DOCUMENT

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Project Objective

2.0 BUILDING DESCRIPTION

3.0 ASBESTOS FIELD ACTIVITIES

3.1 Visual Assessment

3.2 Physical Assessment

3.3 Sample Collection

3.4 Sample Analysis

4.0 ASBESTOS REGULATORY OVERVIEW

5.0 LEAD BASED PAINT FIELD ACTIVIES

6.0 LEAD BASED PAINT REGULATORY OVERVIEW

7.0 FINDINGS AND RECOMMENDATIONS

8.0 GENERAL COMMENTS

APPENDICES

APPENDIX A – ASBESTOS SURVEY SAMPLE SUMMARY

APPENDIX B – LEAD BASED PAINT SAMPLE SUMMARY

APPENDIX C – CHAIN OF CUSTODY AND LABORATORY ANALYTICAL REPORTS

APPENDIX D – SAMPLE LOCATION PLAN:

FIGURE 1 – RESTROOMS & SOUTH ENTRANCE SAMPLE LOCATIONS

APPENDIX E – TRAINING CERTIFICATES

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ASBESTOS AND LEAD BASED PAINT SURVEY REPORT

Restrooms and South Entrance USCG-Base Seattle, Building 1

1519 Alaskan Way South Seattle, King County, Washington

Terracon Project No. 81137095

December 5, 2013

1.0 INTRODUCTION

Terracon conducted an asbestos and lead-based paint survey of the restrooms and south entrance of the United States Coast Guard (USCG) - Base Seattle, Building 1, located at 1519 Alaskan Way South in Seattle, King County, Washington. The survey was conducted November 19, 2013 by an Asbestos Hazard Emergency Response Act (AHERA)-accredited asbestos inspector in general accordance with the Master Subcontract Agreement (MSA) dated August 9, 2013, and the Subcontractor Letter of Authorization dated November 19, 2013, between Terracon and EnviroApplications, Inc. (EAI) authorizing Terracon to perform this service. Interior and exterior building components were surveyed and homogeneous areas of suspect asbestos-containing materials (ACM) and suspect lead-based paints (LBP) were visually identified and documented.

Although reasonable effort was made to survey inaccessible suspect materials, additional suspect but unsampled ACM and LBP could be located in walls, in voids or in other concealed areas.

Suspect ACM samples were collected in general accordance with the sampling protocols outlined in United States Environmental Protection Agency (EPA) 40 Code of Federal Regulations (CFR)

763.86. Samples were delivered to accredited laboratories for analysis by polarized light microscopy (PLM) for asbestos samples and flame atomic absorption spectrometry (FAAS) for paint chip samples.

1.1 Project Objective

We understand this asbestos and lead-based paint survey was requested due to the planned renovation of the restrooms and south entrance of the building.

EPA regulation 40 CFR 61, Subpart M, National Emission Standards for Hazardous Air Pollutants (NESHAP), prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities. The asbestos NESHAP requires that potentially regulated asbestos-

Asbestos and Lead Based Paint Survey Report USCG-Base Seattle, Bldg. 1 ■ Seattle, Washington December 5, 2013 ■ Terracon Project No. 81137095

Responsive ■ Resourceful ■ Reliable 2 containing building materials be identified, classified and quantified prior to planned disturbances or demolition activities. The NESHAP authority for King County is the Puget Sound Clean Air Agency (PSCAA).

The Department of Labor and Industries (L&I) enforces the Washington Industrial Safety and Health (WISHA) Standard for Lead in Construction, Washington Administrative Code (WAC) 296- 155-176, which defines the lead exposure limits for all construction workers performing demolition and/or renovation activities. Should lead be detected at any concentration, WAC 296-155-176 provides the appropriate methods of compliance to ensure worker safety from potential lead exposure.

The State of Washington Hazardous Waste and Toxics Reduction (HWTR) Program affects persons who generate, transport, transfer, recycle, treat, store, or dispose of regulated dangerous wastes, as defined in the Dangerous Waste Regulations (173-303 WAC). Solid wastes, including demolition/renovation debris, must be evaluated to determine if the waste designates as lead-containing dangerous waste prior to disposal.

2.0 BUILDING DESCRIPTION

The site is developed with a 5-story structure (not including the basement) comprised of cast-in-place concrete exterior and central core (stairwell/elevator shaft) walls. Interior corridor and partition walls are primarily gypsum block with wood-framed partition walls in some areas.

Vertical finishes observed in the restrooms and at the south entrance (ground level) consisted primarily of ceramic wall tile, plaster and gypsum wall board. Horizontal finishes consisted of primarily of ceramic tile, terrazzo flooring (hallways), sheet vinyl flooring, carpet (hallways), suspended ceiling tiles, gypsum board and plaster.

3.0 ASBESTOS FIELD ACTIVITIES

The survey was conducted by AHERA-accredited asbestos inspector Adam Stauffer. A copy of Mr. Stauffer’s asbestos inspector training certificate is attached as Appendix E. The survey was conducted in general accordance with the sample collection protocols established in EPA regulation 40 CFR 763, the Asbestos Hazard Emergency Response Act (AHERA). A summary of survey activities is provided below.

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3.1 Visual Assessment

Survey activities began with visual observation of the interior and exterior of the areas that will potentially be disturbed during renovation activities in order to locate and identify homogeneous areas of suspect ACM. A homogeneous area (HA) consists of building materials that appear similar throughout in terms of color and texture. The assessment was conducted throughout visually accessible areas of the restroom and south entrance building components.

Building materials identified as concrete, glass, wood, masonry, metal or rubber were not considered suspect ACM.

3.2 Physical Assessment

A physical assessment of each homogeneous area of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the EPA as a material which can be crumbled, pulverized or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

3.3 Sample Collection

Based on results of the visual observation, bulk samples of suspect ACM were collected in general accordance with AHERA sampling protocols. Random samples of suspect materials were collected in each homogeneous area. Sample team members collected bulk samples using wet methods, as applicable, to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.

Terracon collected 48 bulk samples from 15 homogeneous areas of suspect ACM. A summary of all samples collected is included as Appendix A.

3.4 Sample Analysis

Bulk ACM samples were submitted under chain of custody to Seattle Asbestos Test (SAT) of Lynnwood, Washington for analysis by polarized light microscopy (PLM) with dispersion staining techniques per EPA methodology (600/R-93/116). The percentage of asbestos, where applicable, was determined by microscopic visual estimation.

SAT is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP Accreditation No. 200768-0).

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4.0 ASBESTOS REGULATORY OVERVIEW

The NESHAP regulation for asbestos regulates asbestos fiber emissions and asbestos waste disposal practices. It requires the identification of existing asbestos-containing materials (ACM) according to friability prior to demolition or renovation activity. Friable ACM is a material containing more than 1% asbestos that, when dry, may be crumbled, pulverized or reduced to powder by hand pressure.

The NESHAP regulation classifies ACM as either regulated asbestos-containing material (RACM), Category I non-friable ACM or Category II non-friable ACM. RACM includes all friable ACM, along with Category I non-friable ACM that has become friable or will be or has been subjected to sanding, grinding, cutting or abrading, and Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity. Category I non-friable ACMs are exclusively asbestos-containing packings, gaskets, resilient floor coverings, floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II non-friable ACM are all other non-friable materials other than Category I non-friable ACM that contain more than 1% asbestos. RACM must be removed prior to renovation or demolition activities.

Washington Administrative Code (WAC) 173 400 075 adopts the federal NESHAP rule by reference. In the State of Washington, authority to administer NESHAP requirements is delegated to the regional air pollution authorities (e.g., the local Clean Air Agency or the Washington State Department of Ecology). In King County, the NESHAP requirements are administered by the Puget Sound Clean Air Authority (PSCAA). PSCAA must be notified at least 10 working days prior to the demolition of any structure with a projected roof area greater than 120 square feet, regardless of whether any asbestos was identified. Notification is not required for renovation projects, unless the project involves the disturbance of friable asbestos containing materials. The owner or operator must also provide the Washington State Department of Labor and Industry (L&I) with written notification at least 10 working days prior to the commencement of asbestos removal projects involving at least 10 linear feet or 48 square feet of RACM. Removal of RACM must be conducted by a State of Washington-certified asbestos abatement contractor.

In the State of Washington, worker exposures to asbestos are governed by L&I’s Division of Occupational Safety and Health (DOSH). The administrative rule WAC 296-62-07705 requires that employee exposure to airborne asbestos fibers be maintained below 0.1 asbestos fibers per cubic centimeter of air (0.1 f/cc) as an eight hour time weighted average. State of Washington Occupational Safety and Health rules also classify construction and maintenance activities which could disturb ACM, and specify work practices and precautions which employers must follow when their employees engage in each class of regulated work.

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5.0 LEAD BASED PAINT FIELD ACTIVITIES

In conjunction with the asbestos survey, Terracon personnel visually assessed the interior and exterior of the site building slated for renovation, and performed limited LBP sampling that consisted of collecting six (6) paint chip samples from various painted components. All lead samples were submitted under chain of custody to NVL Laboratories, Inc. (NVL), of Seattle, Washington. The LBP samples were analyzed by flame atomic absorption spectrometry per EPA Method 7000B. NVL is accredited under the Environmental Lead Laboratory Accreditation Program (ELLAP No. 101861).

6.0 LEAD BASED PAINT REGULATORY OVERVIEW

Lead is regulated by the EPA, the Washington State Department of Ecology (Ecology), the United States Occupation Safety and Health Administration (OSHA) and WISHA (enforced by L&I). The EPA regulates lead use, while both the EPA and Ecology regulate removal, and disposal. OSHA and WISHA both regulate lead exposure to workers. The EPA defines LBP as paint, varnish, stain, or other applied coating that contains lead equal to or greater than 1.0 mg/cm2, 5,000 mg/kg, or 0.5% by dry weight as determined by laboratory analysis. For the purpose of the OSHA lead standard, lead includes metallic lead, all inorganic lead compounds, and organic lead soaps. A synopsis of the OSHA regulations (29 CFR 1926.62) and the applicability are as follows:

The OSHA Interim Lead Standard for Construction (29 CFR 1926.62) applies to all construction work where an employee may be occupationally exposed to lead. All work related to construction, alteration, or repair (including painting and decorating) is included. The lead-in-construction standard applies to any detectable concentration of lead in paint, as even small concentrations of lead can result in unacceptable employee exposures depending upon on the method of removal and other workplace conditions.

Similar to the OSHA standard, the WISHA Standard for Lead in Construction, states that if lead is present in the workplace in any quantity WISHA requires that demolition activities be conducted in accordance with WAC 296-155-176, lead Safety Standards for Construction

Work.

In accordance with Ecology’s Dangerous Waste Regulations, solid wastes must be designated to see if they are dangerous wastes before disposal unless they are exempted or removed from the dangerous waste regulations. If any of the samples are reported with leachable lead

Responsive ■ Resourceful ■ Reliable 6 concentration of 5.0 mg/L or more, then the waste must be classified and disposed of as dangerous waste.

7.0 FINDINGS AND RECOMMENDATIONS

Asbestos

Laboratory analysis identified asbestos, in seven (7) of the 48 samples submitted, at levels greater than one percent (>1%) in the following materials:

Thinset and fibrous vapor barrier associated with ceramic floor tile Paper backing associated with sheet vinyl flooring Pipe insulation lagging Hard-mudded pipe insulation elbows

Appendix A identifies the homogeneous areas sampled, sample identification numbers, material descriptions, and analytical results. Laboratory analytical reports and chains of custody are included in Appendix C. In addition Appendix D contains the sample location plan: Figure 1 – Restrooms & South Entrance Sample Locations.

As previously indicated, the disposal of asbestos-containing waste materials and the removal of ACM during renovation activity are regulated by EPA NESHAP regulations. The above-listed materials, with the exception of the thinset associated with the ceramic floor tiles, are considered RACM and their removal is required prior to renovation related impacts. The thinset associated with the ceramic floor tile is a NESHAP Category II non-friable ACM, however, given the likelihood the material will be crushed or pulverized during renovation activities removal is recommended prior to any renovation related impacts.

In the event that unsampled suspect ACM is discovered during renovation/demolition activities, Terracon recommends that the renovation contractor contact EAI and Terracon immediately upon discovery, so that samples of the suspect ACM can be collected and analyzed in order to classify, and/or quantify the material.

Lead

Based on a review of the analytical results, one (1) of the six (6) sampled components were found to contain lead that exceeded 5,000 mg/kg (equivalent to 5,000 parts-per-million or 0.5%

Responsive ■ Resourceful ■ Reliable 7 by weight), which is the maximum concentration to be considered non-LBP as defined by the

EPA.

Historical white paint on bathroom walls (assumed under current paint schemes)

Three (3) additional components, of the six (6) sampled, were found to be lead-containing, however, concentrations were below 5,000 mg/kg, the maximum concentration to be considered non-LBP as defined by the EPA.

Appendix B identifies the color sampled, substrate, building component, sample identification numbers, location, condition, and analytical results. Laboratory analytical reports and chains of custody are included in Appendix C. In addition Appendix D contains the sample location plan:

Figure 1 – Restrooms & South Entrance Sample Locations.

This LBP survey was limited to readily observable and accessible surfaces. Terracon cannot guarantee all other building components (besides the one noted above) to be LBP free as the possibility exists that LBP coated surfaces may be hidden from sight or in inaccessible locations, or the homogeneous construction areas identified may not be truly homogeneous.

This limited LBP survey was not performed to the United States Department of Housing and Urban Development’s (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint

Hazards in Housing standards. It should be understood that this LBP survey is not considered to be comprehensive in nature, and the results are not intended to be used to determine lead hazards, develop abatement plans, or prepare detailed cost estimates for abatement.

According to the L&I, abatement of LBP is not required prior to demolition. However, Terracon recommends that the results of this sampling be provided to your renovation contractor, who should subsequently be responsible for determining lead hazards.

In accordance with Ecology’s Dangerous Waste Regulations, solid wastes must be designated to see if they are dangerous wastes before disposal unless they are exempted or removed from the dangerous waste regulations. Therefore Terracon recommends that representative samples of the building renovation/demolition waste stream be tested through laboratory analyses in order to determine if the waste is hazardous. Specifically, toxicity characteristics leaching procedure (TCLP) sampling should be performed and samples analyzed for leachable lead. If the samples are reported with a leachable lead concentration of 5.0 mg/L or more, then the waste must be classified and disposed of as hazardous waste.

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8.0 GENERAL COMMENTS

This asbestos and lead-based paint survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our survey of the building. The information contained in this report is relevant to the date on which this survey was performed, and should not be relied upon to represent conditions at a later date. This report has been prepared on behalf of and exclusively for use by the United States Coast Guard and EAI for specific application to their project as discussed. This report is not a bidding document.

Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories or other third parties supplying information which may have been used in the preparation of this report. No warranty, express or implied is made.

APPENDIX A

ASBESTOS SURVEY SAMPLE SUMMARY

RESTROOMS AND SOUTH ENTRANCE

USCG-BASE SEATTLE, BUILDING 1

1519 ALASKAN WAY SOUTH

SEATTLE, KING COUNTY, WASHINGTON

HOMOGENEOUS

AREA

SAMPLE NO. DESCRIPTION SAMPLE LOCATION

1-1

4”x4” beige ceramic wall tile with brown adhesive Restrooms Ground – 4th floor 1-2

1-3

2-4

White plaster skim coat and grey scratch coat on walls

Restrooms Ground – 4th floor

2-5 2-6 2-7 2-8 2-9

3-10 2”x2” beige with white freckles ceramic floor tile

(ND)

light grey thinset (2% Chrysotile)

Fibrous vapor barrier (49-50% Chrysotile)

Restrooms Ground – 4th floor

(approx. 800 SF) 3-11

3-121

4-13

Newer white plaster skim coat on

HA-2

Women’s restroom Ground floor 4-14

4-15

5-16

2’x4’ white suspended ceiling tiles with small pin- and worm-holes Restrooms Ground – 4th floor 5-17

5-18

6-19

Light grey gypsum block walls Throughout bathroom/corridor walls 6-20 6-21

7-221

Grey-white pipe insulation lagging

(15% Chrysotile)

Men’s & women’s restrooms 3rd floor, Men’s restroom 4th floor (approx. 40 LF observed – it is assumed that all piping concealed within wall and ceiling cavities has asbestos-containing lagging, total quantity is

7-23

7-242

SAMPLE NO. DESCRIPTION SAMPLE LOCATION

unknown)

8-25

Hard mudded pipe insulation elbows

(10% Chrysotile)

Men’s & women’s restrooms 3rd floor, Men’s restroom 4th floor (approx. 5 EA observed – it is assumed that all piping concealed within wall and ceiling cavities has asbestos-containing elbows, total quantity is unknown )

8-262

8-272

9-28 Light brown gypsum wall board, seam tape and white joint compound

Men’s & Women’s restrooms partition walls 4th and 5th floor

9-29 9-30

10-31 White with light grey terrazzo sheet vinyl flooring

(ND)

with paper backing (47-49% Chrysotile)

Hallway to women’s restrooms 4th floor

(approx. 50 SF) 10-32

10-33

11-34 Brown adhesive on 3” brown vinyl cove base Hallway to women’s restroom

4th floor 11-35 11-36

12-37 White with grey and black freckles sheet vinyl flooring with paper backing

Men’s & women’s restrooms 5th floor 12-38

12-39

13-40

Brown/cream adhesive on 4” grey-tan vinyl cove base

Men’s & women’s restrooms 5th floor 13-41

13-42

14-43

Exterior insulation finishing system (EIFS) over HA-15

Exterior at south entrance Ground floor 14-44

14-45

15-46

Light brown exterior plaster Exterior at south entrance

Ground floor 15-47 15-48

Bold sample text denotes asbestos containing material (ACM) ND – non detect SF – square feet LF – linear feet EA – each HA – homogenous area 1Non detect for all layers in this sample but included as at least one other sample within HA contains asbestos

SAMPLE NO. DESCRIPTION SAMPLE LOCATION

2Not analyzed following positive result in previously analyzed sample within HA

APPENDIX B

LEAD-BASED PAINT SAMPLE SUMMARY

RESTROOMS AND SOUTH ENTRANCE

USCG-BASE SEATTLE, BUILDING 1

1519 ALASKAN WAY SOUTH

SEATTLE, KING COUNTY, WASHINGTON

Sample ID Color Substrate Component Sample Location

Lab Result (% by weight)

Condition (Intact, Fair, or Poor)

Pb-01

White (under current schemes)

Plaster Walls

Ground floor men’s restroom / throughout restrooms

0.65 Intact

Pb-02 Off white Plaster

Walls Ground floor men’s restroom / throughout restrooms

<0.010 Intact Gypsum

Pb-031

Beige-tan over mint green under Pb-02

Plaster Walls Ground – 4th floor restrooms

0.17 Intact

Pb-041 Yellowish cream Gypsum

Walls 4th floor restrooms 0.37 Intact Plaster

Pb-051 Tan over Pb-03 Plaster Walls 5th floor restrooms 0.24 Intact

Pb-06 Tan

EIFS

Walls South entrance exterior <0.010 Intact

Plaster Bold sample text denotes lead-based paint 1Lead containing paint

APPENDIX C

CHAIN OF CUSTODY AND LABORATORY ANALYTICAL REPORTS

Client Sample Description ConcentrationLab ID Analyzed Lead

Collected

EMSL Analytical, Inc.

200 Route 130 North, Cinnaminson, NJ 08077 Phone/Fax: (856) 303-2500 / (856) 786-5974 http://www.EMSL.com cinnaminsonleadlab@emsl.com

Attn: Chad Kean, CHMM, CPSWQ Terracon Consultants, Inc.

21905 64th Ave. W.

Suite 100 Mountlake Terrace, WA 98043

Received: 11/22/13 11:19 AM

81137095-USCG Seattle

Fax: (425) 771-3549 Phone: (425) 771-3304

Project:

11/19/2013Collected:

Test Report: Lead in Paint Chips by Flame AAS (SW 846 3050B*/7000B)

201312382 CustomerID: TCWA25 CustomerPO:

ProjectID:

EMSL Order:

Site: All 0001Pb-01 0.65 % wt11/26/201311/19/2013

Site: All 0002Pb-02 <0.010 % wt11/26/201311/19/2013

Site: All 0003Pb-03 0.17 % wt11/26/201311/19/2013

Site: 4th Floor 0004Pb-04 0.37 % wt11/26/201311/19/2013

Site: 5th Floor Above Hard Lid 0005Pb-05 0.24 % wt11/26/201311/19/2013

Site: Exterior Stucco 0006Pb-06 <0.010 % wt11/26/201311/19/2013

Julie Smith - Laboratory Director NJ-NELAP Accredited:03036 or other approved signatory

Test Report ChmSnglePrm/nQC-7.21.0 Printed: 11/26/2013 5:03:30 PM

Reporting limit is 0.010 % wt based on the minimum sample weight per our SOP. The QC data associated with these results included in this report meet the method QC requirements, unless specifically indicated otherwise. Unless noted, results in this report are not blank corrected. EMSL bears no responsibility for sample collection activities. Samples received in good condition unless otherwise noted. * slight modifications to methods applied. "<" (less than) result signifies that the analyte was not detected at or above the reporting limit. Measurement of uncertainty is available upon request.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NELAP Certifications: NJ 03036, NY 10872, PA 68-00367, AIHA-LAP, LLC ELLAP 100194, A2LA 2845.01

Initial report from 11/26/2013 17:03:30 http://www.EMSL.com mailto:cinnaminsonleadlab@emsl.com

APPENDIX D

SAMPLE LOCATION PLAN

Samples 7-24, 8-26 and 8-27 collected from closet/pipe chase in central stair on 4th Floor

4-15

4-13

4-14, 6-19

2-5, 5-16

3-10

1-1, 2-4, Pb-01

Pb-02

9-30

2-9, 6-21, Pb-05

12-38

12-37, 13-40, 13-41, 13-42

12-39

10-33

10-32

2-8, Pb-04

3-12

1-3, 9-28

7-23

10-31, 11-34, 11-35, 11-36

9-29

2-7

7-22, 8-25

5-18

6-20

1-2

2-6

Pb-03

3-11

5-17

Work area layouts provided by USCG Civil Engineering Unit Oakland, CA

14-43, 14-44, 14-45, Pb-06

15-46-, 15-47, 15-48

Project Mngr:

Approved By:

Checked By:

Drawn By:

Project No.

Scale:

Date:

File No. Consulting Engineers and Scientists

FIG. No.

21905 64th Avenue W, Ste 100 Mountlake Terrace, WA 98043 FAX. (425) 771-3549PH. (425) 771-3304 EnviroApplications, Inc.

Seattle, King County, Washington USCG-Base Seattle, Bldg. 1 - 1519 Alaskan Way South

Restrooms & South Entrance Sample Locations

December 2013

*.dwg

Not to scale

81137095

CDK

CDK

AAS

CDK

APPENDIX E

TRAINING CERTIFICATES