826CM3009 BID SET Hazmat Report.pdf
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About this file
This document is an Asbestos & Lead Paint Sampling Report for the Alexandria National Cemetery's Rostrum and Historical Wall Renovation Project (NCA Project #826CM3009), conducted on June 27, 2024. The inspection was performed by Brett Brumbaugh of Castle Hill Associates, who collected 10 bulk samples from various locations including ground pavers, marble walls, stone columns, and retaining walls. Using polarized light microscopy and X-Ray Fluorescence testing, the investigation found no asbestos-containing materials, but identified lead-based paint on multiple components of the flagpole upper railing, including the metal railing top, spindles, bottom, supports, and poured lead anchors.
The report includes detailed laboratory analysis from Eurofins Laboratory in Chantilly, VA, which confirmed no asbestos presence in the samples. For lead-based paint components, the report recommends that if these painted components are to be removed, disturbed, or repainted during renovations, personal air monitoring must be conducted to comply with OSHA lead exposure requirements. The inspector, Brett Brumbaugh, is certified as a Virginia licensed asbestos inspector and EPA Licensed Lead Risk Assessor, with credentials valid through December 31, 2024, and the laboratory holds NVLAP accreditation for asbestos fiber analysis.
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ASBESTOS & LEAD PAINT SAMPLING REPORT
for
ALEXANDRIA NATIONAL CEMETERY
1450 WILKES ST.
ALEXANDRIA, VA 22314
PROJECT:
ROSTRUM AND HISTORICAL WALL RENOVATION
NCA PROJECT #826CM3009
INSPECTION DATE:
JUNE 27, 2024
ENVIRONMENTAL CONSULTANT:
CASTLE HILL ASSOCIATES, LLC
1197 FARNSWORTH RD., UNIT E
WATERVILLE, OH 43566
567-952-0212 www.CASTLEHILLASSOCIATES.com http://www.castlehillassociates.com/ kroggenkamp Placed Image
ASBESTOS & LEAD PAINT SURVEY
ALEXANDRIA NATIONAL CEMETERY – ALEXANDRIA, VA
ROSTRUM & HISTORICAL WALL RENOVATION PROJECT
JUNE 2024
TABLE OF CONTENTS
• ASBESTOS & LEAD SAMPLING SUMMARY
• ASBESTOS BULK SAMPLING DESCRIPTIONS AND LAB RESULTS
• ASBESTOS MATERIAL PHOTOS
• ASBESTOS – HOMOGENEOUS SAMPLING AREAS (HSA) MATERIAL PHOTOS
• LEAD PAINT SAMPLING RESULTS
• LEAD-BASED PAINT COMPONENT PHOTOS
• LEAD PAINT TESTED MATERIAL PHOTOS
• ASBESTOS LABORATORY REPORT
• ASBESTOS LABORATORY CERTIFICATIONS
• INSPECTOR CERTIFICATIONS
ASBESTOS & LEAD PAINT INSPECTION SUMMARY
On June 27, 2024, Brett Brumbaugh of Castle Hill Associates performed a limited asbestos survey and lead paint XRF (X-Ray Fluorescence) testing prior to the planned renovations planned for the Rostrum and Historical Wall renovations at the Alexandria National Cemetery in Alexandria, VA.
Bulk samples were collected of suspect asbestos containing materials that will be impacted by the planned renovations at the site. There were 10 bulk samples taken as part of this survey with the materials tested and the lab analytical results included in this report.
The asbestos bulk sampling conducted as part of this project was based upon the appearance, texture, and location of the suspect materials. All bulk samples were analyzed utilizing current US EPA (United States Environmental Protection Agency) methods for PLM (Polarized Light Microscopy) by Eurofins Laboratory in Chantilly, VA. Eurofins is accredited by the NIST (National Institute of Standards and Technology), NVLAP program (National Voluntary Laboratory Accreditation Program) and an AIHA (American Industrial Hygiene Association) accredited laboratory. The laboratory and inspector certifications are presented later in this document.
Lead paint and building component testing was conducted on all painted surfaces or suspect lead containing building materials in the renovation areas which will be disturbed as part of this project.
The testing was conducted utilizing a Viken Detection Pb200i direct read XRF analyzer. Painted components or building materials that were tested in the areas are considered to be “lead-based” paint or lead-containing building components as defined by the US EPA (greater than 1.0 milligram per centimeter squared or mg/cm2). The XRF analyzer used in this survey undergoes yearly leak testing to verify no radiation leakage from the unit.
The asbestos and lead testing were conducted by Brett Brumbaugh who is a Virginia licensed asbestos inspector and is also an EPA Licensed Lead Risk Assessor. Mr. Brumbaugh has been conducting asbestos surveys and lead sampling since 1987 and is licensed in 34 states.
ASBESTOS MATERIALS FINDINGS
As a result of the bulk sampling conducted during this inspection, there were no asbestos containing materials identified on the structures which will be impacted by the planned renovations at the site.
LEAD-BASED PAINT FINDINGS
As a result of the XRF testing for lead-based paint on building materials conducted during this inspection, there was lead identified as follows:
Lead Painted Building Materials/Components
Locations Paint Color
Metal railing top Flagpole upper railing Black
Railing spindle Flagpole upper railing Black
Railing bottom Flagpole upper railing Black
Poured lead anchors Flagpole upper railing Gray
Railing support Flagpole upper railing Black
CONLUSIONS/RECOMMENDATIONS
ASBESTOS: There were no asbestos containing materials that will be impacted by the planned renovations. If any of the windows or roofing will be removed during the renovations, they should be tested prior to disturbance to verify the presence of asbestos materials.
LEAD-BASED PAINT: The identified lead painted components can remain in-place indefinitely and do not require abatement if they remain in-place. If the components are to be removed, disturbed, or repainted during the renovations, then personal air monitoring for the workers must be conducted to comply with OSHA requirements for lead exposure in construction to establish a negative exposure assessment.
Inspector Signature, Brett L. Brumbaugh, REPA, CESCO Asbestos Inspector - Commonwealth of Virginia License # 3303004018 EPA Licensed Lead Paint Risk Assessor LBP-R-I216003-2
ASBESTOS SAMPLING PROTOCOL
The bulk samples were collected from locations that were selected to be representative of the building materials. Sampling was accomplished using the simplified sampling scheme referred in the AHERA regulations and found in the “Pink Book”. Locations of individual samples are referred on this report.
The samples were either collected with a coring tool designed for asbestos sampling or placed into a plastic bag for laboratory analysis. The samples were analyzed via polarized light microscopy with dispersion staining, using the “Interim method for the Determination of Asbestos in Bulk Insulation Samples” found in Appendix A to Subpart F in 40 CFR Part 763.
The regulations require specific numbers of samples be obtained per homogeneous area. For example, when sampling for joint compound or asbestos in hard plaster (sprayed-on or troweled-on surfacing materials) samples are to be taken based on the following increments: 0 to 1000 square feet of material, 3 samples are necessary. From 1001 to 5000 square feet, 5 samples are necessary, over 5000 square feet 7 samples are required. If during analysis any samples are found to contain asbestos, the entire homogeneous area is delineated as asbestos containing material. In the case of pipe insulation or other types of manufactured materials, the regulations require only enough samples to ascertain whether asbestos is present. In this case, the minimum number of samples to collect and analyze is usually three.
The sampling performed in this inspection followed these sampling guidelines.
ASBESTOS GLOSSARY OF TERMS
Friable asbestos material: means any material containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763 section 1, Polarized Light Microscopy, that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.
Category I Non-friable Asbestos Containing Material (ACM) means asbestos containing packings, gaskets, resilient floor coverings, and asphalt roofing products containing more that 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763, Section 1, Polarized Light Microscopy.
Category II Non-friable ACM means any material, excluding Category I non-friable ACM, containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763, section 1, Polarized Light Microscopy that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.
Regulated Asbestos Containing Material (RACM): means (a) Friable asbestos material, (b) Category I non-friable ACM that has become friable, (c) category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material expected in the course of demolition or renovation operations regulated by this subpart.
ASBESTOS BULK SAMPLE DESCRIPTIONS & RESULTS
Site: Alexandria National Cemetery Location: 1450 Wilkes St., Alexandria, VA 22314 Project Name: Rostrum & Historical Wall Renovations Sampling Date: 6/27/2024
Sampler: Brett Brumbaugh
Certification: VA Licensed Asbestos Inspector # 3303004018 Analysis Date: 7/5/2024 Laboratory: Eurofins - Chantilly, VA
SAMPLE
HA # MATERIAL AREA/LOCATION LABORATORY RESULT
1 A Mortar on ground pavers Pavers at flagpole No Asbestos Detected
2 A Mortar on ground pavers Pavers at Rostrum No Asbestos Detected
3 B Mortar on marble wall cap Retaining wall cap by flagpole No Asbestos Detected
4 B Mortar on marble wall cap Retaining wall cap by flagpole No Asbestos Detected
5 C Mortar on stone wall supports Stone column S. of flagpole No Asbestos Detected
6 C Mortar on stone wall supports Stone column N. of flagpole No Asbestos Detected
7 D Mortar on Rostrum marble Rostrum No Asbestos Detected
8 D Mortar on Rostrum marble Rostrum No Asbestos Detected
9 E Mortar on east retaining wall Retaining wall by front gates No Asbestos Detected
10 E Mortar on west retaining wall Retaining wall on W. side of site No Asbestos Detected
LEAD PAINT TESTING DATA
Project: Alexandria National Cemetery Location: 1450 Wilkes St., Alexandria, VA 22314
Area: Rostrum & Historical Wall Renovations
Inspector: Brett Brumbaugh
Date: 6/27/2024
XRF Mfg.: Viken Detection
Model: Pb200i
Type: XRF Lead Paint Analyzer
Serial # 2757
Reading # Room/Area Component Paint Color Pb Conc.
mg/cm2
Result
1 Flagpole railing Metal railing top Black 5.3 POSITIVE
2 Flagpole railing Railing spindle Black 4.8 POSITIVE
3 Flagpole railing Railing bottom Black 2.3 POSITIVE
4 Flagpole railing Poured lead anchors Gray 33.2 POSITIVE
5 Flagpole railing Railing support Black 5.1 POSITIVE
6 Railing at lower stairs Metal railing top Black 0.2 Negative
7 Railing at lower stairs Railing spindle Black 0.4 Negative
8 Railing at lower stairs Railing bottom Black 0.5 Negative
9 Front entry gate Side support column Black 0.1 Negative
10 Front entry gate Swinging gate Black 0.2 Negative
11 Front entry gate Swinging gate spindle Black 0.3 Negative
12 Front entry gate Stone column Black 0.4 Negative
13 Front entry gate Stone column Black 0.3 Negative
NOTE: Any XRF reading equal to or greater than 1.0 mg/cm2 is considered to be lead-based paint (HUD/EPA)
NOTE: Any XRF reading greater than 0.0 mg/cm2 is considered to be lead-containing paint (OSHA)
PHOTOGRAPHS OF LEAD-BASED PAINT COMPONENTS
Photo LC-1 Flagpole railing Metal railing top, spindles, and supports
Photo LC-2
Flagpole railing Metal railing top, spindles, and supports
Photo LC-3
Flagpole railing poured lead anchors
ASBESTOS LABORATORY REPORT
Approved by:
Approved Signatory Alexis Starrett
Report for:
Mr. Brett Brumbaugh, REPA Castle Hill Associates PO Box 283 Waterville, OH 43566
Regarding:
Eurofins EPK Built Environment Testing, LLC Project: Alexandria Nat. Cemetery; Alexandria, VA
EML ID: 3694329
All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. The results relate only to the samples as received and tested. The results include an inherent uncertainty of measurement associated with estimating percentages by polarized light microscopy. Measurement uncertainty data for sample results with >1% asbestos concentration can be provided when requested.
Eurofins EPK Built Environment Testing, LLC ("the Company"), a member of the Eurofins Built Environment Testing group of companies, shall have no liability to the client or the client's customer with respect to decisions or recommendations made, actions taken or courses of conduct implemented by either the client or the client's customer as a result of or based upon the Test Results. In no event shall the Company be liable to the client with respect to the Test Results except for the Company's own willful misconduct or gross negligence nor shall the Company be liable for incidental or consequential damages or lost profits or revenues to the fullest extent such liability may be disclaimed by law, even if the Company has been advised of the possibility of such damages, lost profits or lost revenues. In no event shall the Company's liability with respect to the Test Results exceed the amount paid to the Company by the client therefor.
Dates of Analysis:
Asbestos PLM: 07-05-2024
Service SOPs: Asbestos PLM (EPA 40CFR App E to Sub E of Part 763 & EPA METHOD 600/R-93-116, SOP EM-AS-S-1267) NVLAP Lab Code 600331-0
EMLab ID: 3694329, Page 1 of 4Eurofins EPK Built Environment Testing, LLC
Eurofins EPK Built Environment Testing, LLC 4460 Brookfield Corporate Drive, Suite A, Chantilly, VA 20151
(866) 871-1984 www.eurofinsus.com/Built Client: Castle Hill Associates C/O: Mr. Brett Brumbaugh, REPA Re: Alexandria Nat. Cemetery; Alexandria, VA
Date of Sampling: 06-27-2024 Date of Receipt: 07-01-2024 Date of Report: 07-05-2024
ASBESTOS PLM REPORT
Total Samples Submitted: 10 Total Samples Analyzed: 10
Total Samples with Layer Asbestos Content > 1%: 0
Location: 1, Mortar- Ground Pavers Lab ID-Version‡: 18121585-1
Sample Layers Asbestos Content Gray Mortar ND
Sample Composite Homogeneity: Good
Location: 2, Mortar- Ground Pavers Lab ID-Version‡: 18145356-1
Sample Layers Asbestos Content Gray Mortar ND
Sample Composite Homogeneity: Good
Location: 3, Mortar- Marble Wall Lab ID-Version‡: 18121586-1
Sample Layers Asbestos Content Gray Mortar ND
Sample Composite Homogeneity: Good
Location: 4, Mortar- Marble Wall Lab ID-Version‡: 18145357-1
Sample Layers Asbestos Content Gray Mortar ND
Sample Composite Homogeneity: Good
EMLab ID: 3694329, Page 2 of 4Eurofins EPK Built Environment Testing, LLC
The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the federal government. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.
Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.
‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is reflected by the value of "x".
(866) 871-1984 www.eurofinsus.com/Built Client: Castle Hill Associates C/O: Mr. Brett Brumbaugh, REPA Re: Alexandria Nat. Cemetery; Alexandria, VA
Date of Sampling: 06-27-2024 Date of Receipt: 07-01-2024 Date of Report: 07-05-2024
ASBESTOS PLM REPORT
Location: 5, Mortar-Wall stairs Lab ID-Version‡: 18121587-1
Sample Layers Asbestos Content Light Gray Mortar ND
Sample Composite Homogeneity: Good
Location: 6, Mortar-Wall stairs Lab ID-Version‡: 18145358-1
Sample Layers Asbestos Content Light Gray Mortar ND
Sample Composite Homogeneity: Good
Location: 7, Mortar- Marble Memorial Lab ID-Version‡: 18121588-1
Sample Layers Asbestos Content White Mortar ND
Sample Composite Homogeneity: Good
Location: 8, Mortar- Marble Memorial Lab ID-Version‡: 18145359-1
Sample Layers Asbestos Content White Mortar ND
Sample Composite Homogeneity: Good
EMLab ID: 3694329, Page 3 of 4Eurofins EPK Built Environment Testing, LLC
The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the federal government. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.
Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.
‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is
(866) 871-1984 www.eurofinsus.com/Built Client: Castle Hill Associates C/O: Mr. Brett Brumbaugh, REPA Re: Alexandria Nat. Cemetery; Alexandria, VA
Date of Sampling: 06-27-2024 Date of Receipt: 07-01-2024 Date of Report: 07-05-2024
ASBESTOS PLM REPORT
Location: 9, Mortar- Entry Retain Wall Lab ID-Version‡: 18121589-1
Sample Layers Asbestos Content Gray Mortar ND
Sample Composite Homogeneity: Good
Location: 10, Mortar- Entry Retain Wall Lab ID-Version‡: 18145360-1
Sample Layers Asbestos Content Gray Mortar ND
Sample Composite Homogeneity: Good
EMLab ID: 3694329, Page 4 of 4Eurofins EPK Built Environment Testing, LLC
The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the federal government. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.
Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.
‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is
LABORATORY CERTIFICATIONS
INSPECTOR CERTIFICATIONS
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