9 507441_FAA_ORF_HazMat Assessment.pdf
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- HVAC Replacement Norfolk International Airport
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About this file
This document is a Limited Hazardous Building Materials Survey Report for the Norfolk International Airport (ORF) prepared by TRC Environmental Corporation for the Federal Aviation Administration (FAA). The survey, conducted on September 1, 2022, focused on identifying potential asbestos-containing materials and lead-based paints in preparation for a roof replacement project involving the ATCT, Base Building, and Base Building Addition.
Laboratory analysis revealed no asbestos-containing materials above 1% in any of the sampled roof materials, including black roofing asphalt, gray and white caulking, and white asphalt sealant. However, lead testing detected significant lead content in two paint samples: an HVAC fan cover paint with 260,000 ppm lead (classified as lead-based paint) and a roof safety railing paint with 840 ppm lead (classified as lead-containing paint). The report recommends following OSHA requirements for lead in construction when disturbing these painted surfaces during the roof replacement project, with a total estimated affected area of approximately 30 square feet.
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LIMITED HAZARDOUS BUILDING
MATERIALS SURVEY REPORT
ATCT, Base Building, and Base Building Addition Roof Replacement Project Norfolk International Airport (ORF)
Virginia Beach, Virginia
Prepared for:
Federal Aviation Administration 800 Independence Ave, SW
Washington, DC
Report Date: September 20, 2022
Prepared By:
4747 N 7th Street, Suite 422, Phoenix, AZ 85014
TRC Project: 507441.0000.0000
TABLE OF CONTENTS
EXECUTIVE SUMMARY ............................................................................................................. i
INTRODUCTION
BACKGROUND
Asbestos-Containing Materials Asbestos Bulk Sampling Procedures Paint Chip Sampling Laboratory Analysis
FINDINGS
Asbestos Containing Materials >1% Negative Materials (No Asbestos Detected)
RECOMMENDATIONS
Asbestos-Containing Materials Lead-Containing Paints
DISCLAIMER
Appendices
Appendix A – Sample Location Diagrams
Appendix B – Representative Photographs
Appendix C – Laboratory Results and Chain of Custody
Appendix D – Certifications
Limited Hazardous Building Materials Survey Report September 20, 2022 Roof Replacement Project Norfolk International Airport (ORF) TRC Project: 507441
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EXECUTIVE SUMMARY
The Federal Aviation Administration (FAA) contracted TRC Environmental Corporation (TRC) to conduct a limited scope hazardous building materials survey at the Norfolk International Airport Site located in Virginia Beach, Virginia. The survey activities were initiated on September 1, 2022, by Mr. Antonio Conde, a Commonwealth of Virginia Licensed Asbestos Inspector (License #3303004685).
Asbestos-Containing Materials Sampling Results
Results of the bulk sampling indicated that the samples analyzed by the laboratory were negative for asbestos based on PLM and TEM methodologies. Any materials uncovered during demolition activities that are not addressed in this report must be sampled by an accredited asbestos inspector prior to any disturbance, or they must be treated as asbestos-containing material (ACM).
Lead-Containing Paint Sampling Results
Results of the laboratory analysis indicate that lead was detected above the reporting limits in two
(2) of the four (4) paint chip samples that were analyzed. Lead-based paint (LBP) is defined as equal to 5,000 parts per million (ppm). For any paint in which lead was detected, TRC recommends that any demolition or renovation activities that may disturb painted surfaces be conducted according to the OSHA requirements regarding lead in construction (29 CFR 1926.62).
Limited Hazardous Building Materials Survey Report September 20, 2022 Roof Replacement Project Norfolk International Airport (ORF) TRC Project: 507441
- 1 -
INTRODUCTION
The Federal Aviation Administration (FAA) contracted TRC Environmental Corporation (TRC) to conduct a limited scope hazardous building materials survey at the Norfolk International Airport Site located in Virginia Beach, Virginia. The survey activities were initiated on September 1, 2022, by Mr. Antonio Conde, a Commonwealth of Virginia Licensed Asbestos Inspector (License #3303004685).
BACKGROUND
Asbestos-Containing Materials
The Occupational Safety and Health Administration (OSHA) defines asbestos-containing material (ACM), as any material containing more than one percent asbestos.
The Environmental Protection Agency (EPA) defines ACM as follows:
1. Friable asbestos-containing material (ACM), is defined by the Asbestos NESHAP, as any material containing more than one percent (1%) asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy (PLM), that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure.
2. Nonfriable ACM is any material containing more than one percent (1%) asbestos as determined using the PLM method that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. The EPA further defines two categories of nonfriable ACM:
a. Category I (Cat I) - Category I nonfriable ACM is any asbestos-containing packing, gasket, resilient floor covering or asphalt roofing product which contains more than one percent (1%) asbestos as determined using PLM according to the method specified in Appendix A, Subpart F, 40 CFR Part 763, and
b. Category II (Cat II) - Category II nonfriable ACM is any material, excluding Category I nonfriable ACM, containing more than one percent (1%) asbestos as determined using PLM according to the methods specified in Appendix A, Subpart F, 40 CFR Part 763 that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.
3. Regulated Asbestos-Containing Material (RACM) is (a) friable asbestos material, (b) Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting or abrading, or (d) Category II nonfriable 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 in the course of demolition or renovation operations.
Asbestos Bulk Sampling Procedures
The survey was conducted in accordance with the sample collection protocols established in 40 CFR 763 (AHERA), 40 CFR 61 Subpart M (NESHAP). A summary of survey activities is provided below.
Limited Hazardous Building Materials Survey Report September 20, 2022 Roof Replacement Project Norfolk International Airport (ORF) TRC Project: 507441
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Survey activities began with visual observation of the project area to identify homogeneous areas of suspect ACM. A homogeneous area consists of building materials that appear similar throughout in terms of color and texture that does not extend to other buildings. Visual assessments were conducted in accessible areas of the building. Building materials identified as glass, wood or metal were not considered suspect ACM.
A physical assessment of each homogeneous area of suspect ACM was conducted to assess the friability and condition of the materials. Friability was assessed by physically touching suspect materials.
Based on results of the visual observation, bulk samples of suspect ACM were collected in accordance with AHERA protocols. Samples of suspect materials were collected in each homogeneous area. Bulk samples were collected 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.
Field information was organized as per the AHERA concept of homogenous area (HA). That is, suspect ACM with similar age, appearance, and texture was grouped together, sampled, and assessed for condition.
Bulk samples of suspect ACM were initially analyzed by Polarized Light Microscopy. Samples which yielded a negative PLM result, and which are classified as a "non-friable" organically bound material were then reanalyzed utilizing Transmission Electron Microscopy (TEM) methodology to verify PLM results.
Bulk samples were submitted under proper COC documentation to the laboratory. Samples were analyzed per N.J.A.C. 8:60 and 12:120 via EPA 600/R-93/116 .
Paint Chip Sampling
TRC conducted a limited lead coating survey to identify lead-based paint (LBP) and/or lead-containing paint (LCP). The lead paint survey was performed to identify representative testing combinations of suspect LBP/LCP on painted surfaces that made up the majority of the coatings in each area assessed that would present a hazard during roof replacement activities.
The general purpose of this investigation was to confirm the presence, and determine the location of LBP and/or LCP coatings and components that may be disturbed in association with the roof replacement activities at the Site. TRC has documented the general condition of such painted building surfaces, characterized the composition of painted surfaces with regard to lead content, and quantified areas/components to define the magnitude to which deteriorated LBP and/or LCP is present, where encountered. Information derived from this survey may be used in communicating potential lead exposure hazards to workers performing abatement and/or demolition. The scope of work associated with this investigation included the following elements:
Visual assessment of painted surfaces and components;
Testing of select painted surfaces and components using paint chip analysis; and Assess condition and approximate quantities of LBP/LCP/LCM for reporting purposes.
Lead-based paint (LBP) is defined by the United States Department of House and Urban Development (HUD) as any paint, varnish, stain, or other applied coating that has one (1.0) mg/cm2 or more of lead or 0.5% by weight (5,000 micrograms per gram [ug/g] or 5,000 parts of
Limited Hazardous Building Materials Survey Report September 20, 2022 Roof Replacement Project Norfolk International Airport (ORF) TRC Project: 507441
- 3 -lead per million [ppm]). According to the OSHA Program Directive, Lead: Exposure in Construction, "For all occupational exposure to lead occurring in the course of construction work, the standard (1926.62) does not specify a minimum amount or concentration of lead that triggers a determination that lead is present and the potential for occupational exposure exists." Therefore any paint containing less than 0.5% by weight, but greater than the laboratory detection limit is considered to be a LCP.
Paint chip samples were collected from painted surfaces to determine total lead content and assist in determining Occupational Safety and Health Administration (OSHA) requirements with respect to construction activities which may disturb lead-containing paints.
Paint chip samples were submitted under proper COC documentation to the laboratory. Samples were analyzed by Flame AAS utilizing the Environmental Protection Agency's (EPA) Test Method for Evaluating Solid Waste, Physical / Chemical Methods, EPA SW-846 Method 3050B/7000B.
Laboratory Analysis
Laboratory services were provided by EMSL Analytical, Inc., an accredited National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory located in Cinnaminson, NJ and/or their location in Morrisville, NC.
FINDINGS
Asbestos Containing Materials >1%
Laboratory analytical results indicated asbestos was not detected in any of the materials sampled in concentrations greater than 1%.
Negative Materials (No Asbestos Detected)
Results of the bulk sampling indicated the following sampled materials did not contain detectable levels of asbestos:
Norfolk International Airport Site Virginia Beach, Virginia Negative Materials
Samples Material Description Material Location(s) FAA-VA-1, 2, 3, 4 Black Roofing Asphalt Based
Built-Up Base Building Roof
FAA-VA-5, 6, 7, 15 Gray Caulking Base Building Roof, Tower Roof FAA-VA-8, 9, 10 White Asphalt Sealant Base Building Roof
FAA-VA-11, 12, 13,
14 White Caulking Tower Roof
FAA-VA-16 White Roofing, Multi-Layer Tower Roof
Limited Hazardous Building Materials Survey Report September 20, 2022 Roof Replacement Project Norfolk International Airport (ORF) TRC Project: 507441
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Paint Chip Sample Results
Norfolk International Airport Site Virginia Beach, Virginia Lead-Containing Paints / Lead-Based Paints
Sample Number Location Description
Parts Per Million Lead (ppm)
Lead- Containing
Paint Lead-Based
Paint
FAA-VA-LCP-
1 Safety Rail Paint Yellow Paint <190 ppm NO NO
FAA-VA-LCP-
2 Safety Rail Paint Yellow Paint <80 ppm NO NO
FAA-VA-LCP-
HVAC Fan Cover Paint
Light Gray Paint
260,000 ppm YES YES
FAA-VA-LCP-
Roof Safety Railing Paint
Grayish/Taupe Paint 840 ppm YES NO
FAA-VA-LCP-
Roof Middle Housing Wall Paint
Insufficient Sample for Analysis
Not Analyzed Not Analyzed
Results of laboratory analysis indicate that lead was detected above the reporting limit in two (2) of the four (4) paint chip samples that were analyzed. Sample 5 was not analyzed due to an insufficient amount of sample material submitted. This shouldn’t impact the project because sample 4 is the same paint as 5 and was later disclosed to us by the client as falling outside of the scope of work as outlined in provided drawings.
RECOMMENDATIONS
Asbestos-Containing Materials
Results of the bulk sampling indicated all asbestos samples analyzed by the laboratory were negative for asbestos based on PLM and TEM methodologies. Any materials uncovered during demolition activities that are not addressed in this report must be sampled by an accredited asbestos inspector prior to any disturbance, or they must be treated as asbestos-containing material ACM.
Lead-Containing Paints
Results of laboratory analysis confirmed that lead was detected in two (2) of the four (4) paint chip samples collected. TRC recommends that demolition activities which may disturb painted surfaces be conducted according to the OSHA requirements regarding lead in construction (29
CFR 1926.62).
DISCLAIMER
The content presented in this report is based on data collected during the survey, review of pertinent regulations, requirements, guidelines and commonly followed industry standards, and information provided by Client, their clients, agents, and representatives.
The work has been conducted in an objective and unbiased manner and in accordance with generally accepted professional practice for this type of work. TRC believes the data and analysis
Limited Hazardous Building Materials Survey Report September 20, 2022 Roof Replacement Project Norfolk International Airport (ORF) TRC Project: 507441
- 5 -to be accurate and relevant, but cannot accept responsibility for the accuracy or completeness of available documentation or possible withholding of information of other parties.
This limited hazardous materials survey report is designed to aid the property owner, architect, construction manager, general contractor, and asbestos abatement contractor in locating asbestos-containing materials and lead-containing paints.
Sincerely, TRC Environmental Corporation
Adam Carity Bart Ashley, CIH, CSP Office Practice Leader Principal Scientist asbestos-containing ma
Sincerely, TRC Environmental Co
Adam Carity Office Practice Leader
Appendix A – Sample Location Diagram(s)
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D ig ita lly si gn ed b y Ja so n
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11 13
A sb es to s S am pl e Lo ca tio ns S am pl e Lo ca tio n M ap K ey Le ad P ai nt
S am pl e
Lo ca tio ns
LC
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-1
LC
P
-2
LC
P
-3
LC
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-4
LC
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-5
Appendix B – Representative Photographs
FAA ROOF SURVEY NORFOLK INTERNATIONAL AIRPORT – SUSPECT
ASBESTOS CONTAINING MATERIALS PHOTOGRAPHIC LOG
Sample Numbers: FAA-VA-1, FAA-VA-2, FAA-VA-3, FAA-
VA-4
Material Description: Roofing Asphalt Based Built-Up Material Color: Black Accessible Material: Accessible Asbestos Detected: None Asbestos Type: No Asbestos Detected Homogeneous Area: Base Building Roof Total Approximate Quantity: 16750 SF Condition: Good Material Type: Misc.
Notes: Multi-layer; asphalt, tar, fiberglass and composite material, Flashing is asphalt and tar on metals
Sample Numbers: FAA-VA-15, FAA-VA-5, FAA-VA-6, FAA-
VA-7
Material Description: Caulking Material Color: Gray Accessible Material: Accessible Asbestos Detected: None Asbestos Type: No Asbestos Detected Homogeneous Area: Base Building Roof, Tower Roof Total Approximate Quantity: 65 LF Condition: Good Material Type: Misc.
Notes: None
Sample Numbers: FAA-VA-10, FAA-VA-8, FAA-VA-9 Material Description: Asphalt Sealant Material Color: White Accessible Material: Accessible Asbestos Detected: None Asbestos Type: No Asbestos Detected Homogeneous Area: Base Building Roof Total Approximate Quantity: 10-15 LF Condition: Good Material Type: Misc.
Notes: None
Sample Numbers: FAA-VA-11, FAA-VA-14 Material Description: Caulking Material Color: White Accessible Material: Accessible Asbestos Detected: None Asbestos Type: No Asbestos Detected Homogeneous Area: Tower Roof Total Approximate Quantity: 5-10 SF Condition: Good Material Type: Misc.
Notes: Hatch door caulk seal, duct line caulk seal
Sample Numbers: FAA-VA-12, FAA-VA-13 Material Description: Caulking Material Color: White Accessible Material: Accessible Asbestos Detected: None Asbestos Type: No Asbestos Detected Homogeneous Area: Tower Roof Total Approximate Quantity: 10-15 LF Condition: Good Material Type: Misc.
Notes: None
Sample Numbers: FAA-VA-16 Material Description: Roofing Multi-Layer Material Color: White Accessible Material: Accessible Asbestos Detected: None Asbestos Type: No Asbestos Detected Homogeneous Area: Tower Roof Total Approximate Quantity: 250 SF Condition: Good Material Type: Misc.
Notes: Rubber membrane with composite/mineral wool layer on top of metal (non-suspicious); sampled to confirm
FAA ROOF SURVEY NORFOLK INTERNATIONAL AIRPORT – LEAD
CONTAINING PAINT PHOTOGRAPHIC LOG
Sample Numbers: FAA-VA-LCP-1 Sample Location:
Description: Safety Rail Paint Laboratory Result (%): <0.019 % wt Substrate: Metal Paint Locations: Base Building Roof Quantity of Deteriorated Paint (SF): N/A – Outside scope according to provided drawings
Sample Numbers: FAA-VA-LCP-2 Sample Location:
Description: Safety Rail Paint Laboratory Result (%): <0.0080 % wt Substrate: Metal Paint Locations: Base Building Roof Quantity of Deteriorated Paint (SF): N/A – Outside scope according to provided drawings
Sample Numbers: FAA-VA-LCP-3 Sample Location:
Description: HVAC Fan Cover Paint Laboratory Result (%): 26 % wt Substrate: Metal Paint Locations: Base Building Roof Quantity of Deteriorated Paint (SF): 30 SF
FAA ROOF SURVEY NORFOLK INTERNATIONAL AIRPORT – LEAD
CONTAINING PAINT PHOTOGRAPHIC LOG
Sample Numbers: FAA-VA-LCP-4 Sample Location:
Description: Roof Safety Railing Paint Laboratory Result (%): 0.084 % wt Substrate: Metal Paint Locations: Tower Roof Quantity of Deteriorated Paint (SF): N/A – Outside scope according to provided drawings
Appendix C – Laboratory Results and Chain of Custody
OrderID: 042222090
OrderID: 042222090
ConcentrationAnalyzed Weight RDL LeadClient SampleDescription Collected
Test Report: Lead in Paint Chips by Flame AAS (SW 846 3050B/7000B)*
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: J Lewis TRC Environmental Corp. - West Region 4747 N 7th Street, Suite 422 Phoenix, AZ 85014
Received: 09/02/22 11:00 AM
FAA ROOF SURVEY NORFOLK INTERNATIONAL AIRPORT
Fax:
Phone: (602) 266-8288
Project:
9/1/2022Collected:
202207711 CustomerID: ENVC52 CustomerPO:
ProjectID:
EMSL Order:
Site: SAFETY RAIL PAINT <190 ppm9/6/2022 0.1068 g
202207711-0001 1909/1/2022FAA-VA-LCP-1 ppm
Site: SAFETY RAIL PAINT <80 ppm9/6/2022 0.2607 g
202207711-0002 809/1/2022FAA-VA-LCP-2 ppm
Site: HVAC FAN COVER PAINT 260000 ppm9/6/2022 0.2731 g
202207711-0003 80009/1/2022FAA-VA-LCP-3 ppm
Site: ROOF SAFETY RAILING PAINT 840 ppm9/6/2022 0.0716 g
202207711-0004 2809/1/2022FAA-VA-LCP-4 ppm
Page 1 of 1Test Report PB w/RDL-2.0.0.0 Printed: 9/19/2022 1:31:34 PM
Owen Mckenna, Lead Laboratory Director or other approved signatory
EMSL maintains liability limited to cost of analysis. Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. The report reflects the samples as received.
Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted.
* Analysis following Lead in Paint by EMSL SOP/Determination of Environmental Lead by FLAA. Reporting limit is 0.008% wt based on the minimum sample weight per our SOP. "<" (less than) result signifies the analyte was not detected at or above the reporting limit. Measurement of uncertainty is available upon request. Definitions of modifications are 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
Report Amended: 09/19/2022 13:31:34 Replaces the Inital Report 09/09/2022 19:00:37. Reason Code: Client-Change to Appearance
OrderID: 202207711
Appendix D – Certification(s)
File details come from the government source that posted it. Updated .