TMFJB Apex 4-1-19 HazMat Inspection.pdf

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Administrative Office of the U. S. Courts (AOUSC) Space Realignments Task 2 and 4, Thurgood Marshall Federal Judiciary Building (TMFJB)
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Apex Companies, LLC 15850 Crabbs Branch Way, Suite 200Rockville, MD20855 T 800.733.2739 F 301.975.0169 apexcos.com

HAZARDOUS BUILDING MATERIALS INSPECTION REPORT

For:

Thurgood Marshall Federal Judiciary Building (TMFJB) Security Program Upgrades

Washington, DC

Apex Job No.: QUINN-023

April 1, 2019

Prepaid for:

Ms. Katie Irwin, AIA, IIDA, LEED AP BD+C Quinn Evans Architects

2121 Ward Place NW, 4th Floor Washington, DC 20036

Prepared by:

Daniel Admasu Project Manager/Project Designer

Maryland Division

Hazardous Building Materials Inspection Report TMFJB Security Program Updates, Washington, DC

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................................................................................. iii LIST OF ACRONYMS .................................................................................................................................. v

1.0 ASBESTOS INSPECTION

1.1 Sampling Protocol

2.0 LEAD BASED PAINT INSPECTION

3.0 OTHER HAZARDOUS BUILDING MATERIALS

4.0 RECOMMENDATIONS

5.0 LIMITATIONS

6.0 REPORT RELIANCE AND USE

TABLES

Table 1 Confirmed Asbestos Containing Materials (ACM)

Table 2 Homogeneous Materials

Table 3 Lead XRF Results

Table 4 PCB Bulk Sampling Results

APPENDICES

Appendix A Personnel Certifications

Appendix B Asbestos Bulk Sampling Laboratory Results/Chain-of-Custody

Appendix C Bulk PCB Samples Laboratory Results

Appendix D Photo Log

Appendix E Site Drawings

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EXECUTIVE SUMMARY

As part of the Architect of the Capitol (AOC) Statement of Work for Thurgood Marshall Federal

Judiciary Building (TMFJB) Security Program Upgraded, Apex Companies, LLC (Apex) conducted a building inspection for asbestos-containing materials (ACM), lead-based paint (LBP), polychlorinated biphenyl (PCB) suspect sealants and other hazardous materials. Inspection services were performed in

February 2019. The building inspection was limited to interior and exterior Security Program Upgraded areas (project areas) only.

Asbestos Inspection

Accessible interior and exterior project areas of the subject property were inspected for ACM. Apex conducted the asbestos inspection using guidelines set forth by the Occupational Safety and Health

Administration (OSHA) and the U.S. Environmental Protection Agency (EPA). ACM is defined by federal and the District of Columbia regulations as a material that contains greater than one (1) percent asbestos by laboratory analysis.

Mr. Daniel Admasu and Mr. Peter Braun conducted the on-site inspection and are EPA-accredited asbestos inspectors. A copy of Mr. Daniel Admasu’s and Mr. Peter Braun’s certifications can be found in

Appendix A. Laboratory analytical results confirmed the following materials to be ACM:

Based on laboratory analysis results, none identified to be ACM.

The following material was assumed to be ACM that was not readily encountered or accessible for sampling during our site visit:

Fire rated doors in Daycare, Fire Command office, Stairwells, and perimeter walls.

Lead Inspection

Accessible interior and exterior project areas were inspected for LBP. Apex conducted the lead inspection by using a portable x-ray fluorescence (XRF) analyzer. The current definition of LBP established by the District of Columbia is greater than or equal to 1.0 milligrams of lead per square centimeter of surface area (≥ 1.0 mg/cm2) by XRF sampling.

Apex’s on-site XRF lead-based paint inspection revealed none to be above the District of

Columbia’s definition for LBP.

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Apex notes that detectable levels of lead below the District of Columbia’s definition of LBP were reported in paint on multiple building components. Work practices involving the disturbance of such lead-containing paints or other materials are regulated under the OSHA’s Lead in Construction Standard in Title

29 of the CFR Part 1926.62. As a result, all construction and demolition activities involving lead-containing materials (regardless of the lead content) must comply with the OSHA standard, which prescribes requirements for contractor/worker exposure assessment, worker protection, and engineering controls.

Other Hazardous Building Materials

As part of Apex’s scope of work, Apex inspected for other potential hazardous building materials, such as mercury-containing lighting tubes, thermostats and gauges, polychlorinated biphenyl (PCB) light ballasts and transformers, etc. A summary of Apex’s findings is presented below.

Mercury Hazards

No mercury containing comments will be impacted within the project area. Any concealed building materials discovered during renovation/demolition activities, which are suspected to contain mercury should be investigated or tested to confirm the absence or presence of mercury.

PCBs (Polychlorinated Biphenyls)

Polychlorinated biphenyls (PCBs) suspect materials such as caulking, sealant and expansion joints were assessed in the project areas during the site visit. Results of the laboratory analysis confirmed none for the presence of PCB’s in all samples analyzed.

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LIST OF ACRONYMS

ACM Asbestos-Containing Material

AHERA Asbestos Hazard Emergency Response Act (40 CFR Part 763)

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

EPA United States Environmental Protection Agency

HAZCOM Hazard Communication

HEPA High Efficiency Particulate Air Filter

HVAC Heating, Ventilation, and Air Conditioning

LBP Lead-based Paint

NESHAP National Emission Standards for Hazardous Air Pollutants

NIST National Institute of Standards and Technology

NOB Non-friable Organically Bound

NVLAP National Voluntary Laboratory Accreditation Program

OSHA Occupational Safety and Health Administration

PACM Presumed Asbestos Containing Material

PCM Phase Contrast Microscopy

PEL Permissible Exposure Limit

PLM Polarized Light Microscopy

TEM Transmission Electron Microscopy

TSCA Toxic Substances Control Act

TSI Thermal System Insulation

UL Underwriters Laboratory

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1.0 ASBESTOS INSPECTION

Apex conducted the asbestos inspection of the building using guidelines set forth by the

Occupational Safety and Health Administration (OSHA) and the U.S. Environmental Protection Agency

(EPA).

Materials that were considered suspect were identified and the number of samples to be collected of these suspect materials was determined by the inspector using the Asbestos Hazard Emergency

Response Act (Title 40 CFR Part 763) (AHERA) protocols. As defined by AHERA policy, suspect materials include the following building material types:

1. Surfacing Materials – including spray-applied or troweled-on wall/ceiling coatings;

2. Thermal System Insulation (TSI) – including pipe insulation, and mudded pipe elbows, and;

3. Miscellaneous Materials –including ceiling tile, floor tiles and mastics, gaskets (if accessible), fire doors, wallboard and spackling.

Suspect materials that are homogeneous in nature (i.e., uniform in color and texture) were identified, touched to determine friability, and sampled by removing a small piece that was then placed in a labeled container. For a given homogeneous area, one (1) or more samples were collected in a randomly distributed manner in accordance with AHERA provisions as referenced in the OSHA Asbestos in

Construction standard (Title 29 CFR 1926.1101). Materials not considered by the AHERA standard as suspect ACM were not addressed by Apex during this inspection, unless specifically referenced.

Table 1 contains a list of the confirmed ACM. The information provided in this table includes detailed ACM descriptions, friability (ability to be reduced to powder by hand pressure), locations, and approximate quantities. Table 2 contains a list of homogeneous materials sampled; which provides a complete list of all identified suspect ACM. Each suspect material is grouped according to class (i.e., surfacing, TSI, or miscellaneous material). This table provides descriptions of each suspect ACM, general location, friability, samples collected, and ACM determination.

All bulk samples were sent to EMSL Analytical, Inc., of Cinnaminson, NJ, a National Voluntary

Laboratory Accreditation Program (NVLAP) accredited laboratory and analyzed using polarized light microscopy in conjunction with dispersion staining (PLM/DS) to determine asbestos content. Appendix B contains the laboratory results/chain-of-custody for all bulk samples collected by Apex during the asbestos inspection.

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1.1 Sampling Protocol

Suspect building materials to be sampled were classified as friable or non-friable (as defined by the EPA). The materials were sampled to determine whether they are asbestos-containing [i.e., contain greater than one (1) percent asbestos]. Samples were analyzed for asbestos content using PLM/DS by a NVLAP accredited laboratory.

Suspect materials were sampled in general accordance with EPA's AHERA, as referenced in the most recent (September 1996) revision of the OSHA's Asbestos in Construction regulations

[Title 29 of the Code of Federal Regulations (29 CFR) 1926.1101], as follows:

MODIFIED AHERA SAMPLING PROTOCOL

Type of Material Estimated Quantity Required Samples

Sprayed or Troweled-on Surfacing Material

Greater than 5,000 ft2 7

Between 1,000 ft2 and 5,000 ft2 5

Less than 1,000 ft2 3

Thermal System Insulation All Quantities 3

Miscellaneous Materials All Quantities

Per AHERA, these materials must be sampled "in a manner sufficient to determine whether or not they contain asbestos." Apex generally collects 1 to 3 samples of such material based upon the inspector's judgment.

Note: These sampling protocol quantities are per functional area and/or homogeneous area.

A number of suspect ACM identified at the building warranted special scrutiny or otherwise required special consideration. These materials are:

• Floor tiles, resilient flooring, and mastics: All floor tiles, resilient flooring, and underlying mastics were considered suspect ACM. Each flooring material and its associated mastic were sampled and analyzed separately. If either component was found to contain greater than one (1) percent asbestos, then only that material was considered ACM. If carpeting was affixed to the floor, Apex’s procedure consisted only of pulling corners up to one (1) foot to view the material beneath. Based on this observation, the characterization of the homogeneous material underneath (i.e., tile or mastic), if any, was extrapolated to the entire floor surface of that area. Note: When only the mastic tests positive as ACM, the floor tile should also be considered as ACM due to residual mastic that remains on floor tile during removal.

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TABLE 1

Confirmed ACM

Thurgood Marshall Federal Judiciary Building (TMFJB) Washington, DC

Description of Material Friable (Yes/No)

Location ACMa

(Yes/No) Approx.

Quantity

Material Condition Response Action

Fire rated doors No Fire command center, Daycare, exterior perimeter wall, and stairwells Yes 36 each Good

May be impacted during renovation.

Remove project impacted doors prior to renovation/demolition a ACM: A homogenous material is considered asbestos containing if any one sample is found to contain greater than one percent asbestos.

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TABLE 2

Homogeneous Materials List

Thurgood Marshall Federal Judiciary Building (TMFJB) Washington, DC

Description of Material Type Friable (Yes/No) Location Sample

Numbers ACMa

(Yes/No) Approx.

Quantity

Thermal Systems Insulation

White Seam Sealant over Silver Foil Fiberglass Pipe Wrap (HA6) No Loading Dock Above Ceiling B25, B26, B27 No --

Surfacing Materials

Grey Textured Ceiling Plaster (HA3) Loading Dock B17, B18, B19 No --

Grey Texture Wall Plaster (HA4) No Loading Dock B20, B21, B22 No --

Miscellaneous Materials

White Drywall (HA1) No

Loading Dock-Storage Level 6-S Elv. Lob.

Level 6-N Elv. Lob.

Level 7 S Elv. Lob.

Level 7-N Elv. Lob.

Daycare

B01, B02, B03, B04, B05, B06, B07, B08

No --

White Joint Compound (HA2) No

Loading Dock-Storage Level 6-S Elv. Lob.

Level 6-N Elv. Lob.

Level 7 S Elv. Lob.

Level 7-N Elv. Lob.

Daycare

B09, B10, B11, B12, B13, B14, B15, B16

No --

Grey Exterior Stone Wall Sealant (HA5) No Exterior Loading Dock B23, B24 No --

Grey Exterior Stone Wall and Sidewalk Sealant (HA7) No

Atrium Exterior Sidewalk, Atrium Interior Wall, Ground level N Elv. Lob.

South entrance

B28, B29, B30, B31, B32 No --

Grey Marble Floor Grout (HA8) No Atrium B33, B34 No --

Yellow Carpet Mastic (HA9) No North and south garage elevator lobbies B35, B36, B37 No --

White Fire Stop on Metal Electric Conduit (HA10) No North and south garage elevator lobbies B38, B39 No --

Red Fire Stop on Metal Electric Conduit (HA11) No North and south garage elevator lobbies B40, B41 No --

Yellow Carpet Tile Mastic (HA12) No North and south garage Elv Lobbies Daycare

B42, B43, B44, B45, B46 No --

White, Grey, Green, Purple 12”x12” Vinyl Floor Tile (HA13) No Concourse Level- Hallway Adjacent to S

Elevator Lobby B47, B48, B49, B50 No --

Tan Glue Dots associated with Wood Baseboard (HA14) No Level 6-Hallway Adjacent to S Elevator

Lobby B51, B52 No --

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Description of Material Type Friable (Yes/No) Location Sample

Numbers ACMa

(Yes/No) Approx.

Quantity

White Mastic associated with Wood Baseboard (HA15) No Concourse Level-Hallway Adjacent to

North Elevator Lobby B53, B54 No --

Green Seam Sealant on Metal Duct (HA16) No Ground level N Elevator Lobby above

Drywall Ceiling access from Hatch B55, B56 No --

White Seam Sealant on Silver Foil Fiberglass Duct (HA17) No

Level 7- North and South Hallway adjacent to Elevator Lobby above Ceiling Tile

B57, B58 No --

White 2x2 Ceiling Tile with Rough Texture and Silver Backing (HA18)

No Throughput North and South elevator lobbies

B59, B60, B61, B62 No --

White Fire Stop Sealant (HA19) No Level 6 and 7-Hallway Adjacent to Elevator Lobby above Drop Ceiling Tiles B63, B64 No --

Blueish Grey 12”x12” Vinyl Floor Tile and associated Black Mastic

(HA20)

No Fire Command Center B65, B66 No --

Blue 12”x12” Vinyl Floor Tile with Black Specks and associated Yellow Mastic (HA22)

No Concourse Level-Maintenance-Control Room CV26 B67, B68 No --

Grey Exterior Door and Window Caulking (HA23) No South entrance on exterior B69, B70 No --

Fire rated doors (HA21) No Fire Command Center, Daycare, Exterior Perimeter Walls, and Stairwells

Assumed positive Yes 36 each a ACM: A homogenous material is considered asbestos containing if any one sample is found to contain greater than one percent asbestos.

SF = square feet; LF = linear feet

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2.0 LEAD BASED PAINT INSPECTION

Apex performed an x-ray fluorescence (XRF) lead-based paint (LBP) inspection of the project areas. The purpose of the inspection was to determine if LBP is present on the building components located within the interior project areas, which may be directly affected during the course of renovation activities.

The XRF LBP inspection was performed utilizing XRF spectrum analyzer to determine the presence of suspect lead-painted components. XRF technology is well known for accuracy in detecting lead within individual layers of paint. By emitting radiation through each paint layer, Apex was able to determine the presence of lead within tested components. Building components typically known for posing potential lead exposure were tested during the inspection. All XRF test results are found in Table 3.

Certain rooms/areas of the building, similar in design and construction history, were included within the representative LBP inspection. The current definition of LBP established by the District of Columbia is greater than 1.0 milligrams of lead per square centimeter of surface area (>1.0 mg/cm2) using a portable

XRF analyzer.

Apex’s on-site XRF lead-based paint inspection revealed none to be above the District of

Columbia’s definition for LBP.

The lead paint testing is intended to provide testing data to employers, as required by OSHA, so that measures may be taken to prevent lead exposures to workers during renovation and/or demolition activities. This inspection does not include risk assessment of lead hazard. It is important to note that even low concentrations of lead in paint (i.e., less than 1.0 mg/cm2) that do not meet the District of Columbia’s definition for LBP, have the potential to result in some lead exposure to building occupants and/or workers, particularly construction workers involved with activities such as torch cutting and welding metal structures, abrasive blasting, or sanding painted surfaces. Work practices involving the disturbance of such lead-containing paints or other materials are regulated under the U.S. Occupational Safety and Health

Administration’s (OSHA’s) Lead in Construction Standard in Title 29 of the CFR Part 1926.62. As a result, all construction and demolition activities involving lead-containing materials (regardless of the lead content) must comply with the OSHA standard, which prescribes requirements for contractor/worker exposure assessment, worker protection, and engineering controls.

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TABLE 3

XRF Results

Thurgood Marshall Federal Judiciary Building (TMFJB) Washington, DC

Reading No. Component Substrate Color Floor Room Results

Lead Cons.

mg/cm2

1 Calibrate Positive 1.12 2 Wall CMU Grey Concourse Loading dock Negative 0 3 Wall Concrete Grey Concourse Loading dock Negative 0 4 Wall CMU Grey Concourse Loading dock Negative 0 5 Column Concrete Grey Concourse Loading dock Negative 0

6 Column corner guard Metal Grey Concourse Loading dock Negative 0

7 Vertical pipe Metal Grey Concourse Loading dock Negative 0 8 Lift curb Concrete Yellow Concourse Loading dock Negative 0 9 Lift post Metal White Concourse Loading dock Negative 0 10 Lift floor Metal Blue Concourse Loading dock Negative 0.03 11 Lift threshold Metal Yellow Concourse Loading dock Negative 0 12 Ballard Metal Grey Concourse Loading dock Negative 0.02

13 Curb Concrete Yellow Concourse Loading dock Negative 0 14 Wall Plaster Grey Concourse Loading dock Negative 0

15 Caution floor marking Concrete Yellow Concourse Loading dock Negative 0

16 Wall Drywall Grey Concourse Loading dock Negative 0 17 Door Metal Grey Concourse Loading dock Negative 0 18 Door frame Metal Grey Concourse Loading dock Negative 0

19 Vertical supply pipe Metal Brown Concourse Loading dock Negative 0

20 Ballard Metal Yellow Concourse Loading dock Negative 0 21 Floor Stone Yellow Ground Atrium Negative 0 22 Wall Stone Yellow Ground Atrium Negative 0 23 Wall Stone Grey stone Ground North Elv. Lob. Negative 0 24 Wall Drywall White/Grey Ground North Elv. Lob. Negative 0

25 Floor Stone White/Grey Ground North Elv. Lob. Negative 0.01 26 Floor Marble Green Ground North Lobby Negative 0 27 Floor Stone Grey Ground North Lobby Negative 0 28 Wall Drywall White/Grey Ground North Lobby Negative 0 29 Wall Stone Grey Ground North Lobby Negative 0 30 Wall CMU White Upper Garage North Elv. Lob. Negative 0 31 Wall CMU Green Upper Garage North Elv.Lob. Negative 0 32 Ceiling Concrete White Upper Garage North Elv.Lob. Negative 0 33 Conduit Metal White Upper Garage North Elv.Lob. Negative 0

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Reading No. Component Substrate Color Floor Room Results

Lead Cons.

mg/cm2

34 Conduit Metal White Lower Garage North Elv.Lob. Negative 0 35 Ceiling Concrete White Lower Garage North Elv.Lob. Negative 0 36 Wall CMU White Lower Garage North Elv.Lob. Negative 0 37 Wall CMU Blue Lower Garage North Elv.Lob. Negative 0

38 Wall CMU Red Lower Garage South Elv.Lob. Negative 0 39 Wall CMU White Lower Garage South Elv.Lob. Negative 0 40 Ceiling CMU White Lower Garage South Elv.Lob. Negative 0 41 Door CMU Beige Lower Garage South Elv.Lob. Negative 0 42 Door frame CMU Beige Lower Garage South Elv.Lob. Negative 0 43 Wall CMU Beige Lower Garage South Elv.Lob. Negative 0 44 Wall CMU White Upper level South Elv.Lob. Negative 0 45 Wall CMU Yellow Upper level South Elv.Lob. Negative 0 46 Yellow CMU White Upper level South Elv.Lob. Negative 0.01 47 Wall Metal White/Grey Upper level South Elv.Lob. Negative 0 48 Wall column Wood Grey 7th floor South Elv. Lob. Negative 0

49 Wall Wood Clear varnish 7th floor South Elv. Lob. Negative 0

50 Baseboard Polished granite Green 7th floor South Elv. Lob. Negative 0

51 Baseboard Wood Grey 7th floor South Elv. Lob. Negative 0 52 Wall Drywall White 7th floor South Elv. Lob. Negative 0 53 Wall Drywall White 7th floor South Elv. Lob. Negative 0 54 Wall column Wood Grey 7th floor South Elv. Lob. Negative 0 55 Baseboard Wood Grey 7th floor South Elv. Lob. Negative 0 56 Ceiling Wood Grey 7th floor South Elv. Lob. Negative 0 57 Calibrate Positive 1.15 58 Calibrate Negative 0.6 59 Calibrate Positive 1.3

60 Wall Drywall Grey Mezzanine level Fire command center Negative 0

61 Wall Drywall Grey Mezzanine level Fire command center Negative 0

62 Door Metal Grey Mezzanine level Fire command center Negative 0

63 Door frame Metal Grey Mezzanine level Fire command center Negative 0.01

64 Door frame CMU Grey Mezzanine level Fire command center Negative 0

65 Framing Metal Brown Mezzanine level Fire command center Negative 0

66 Partition wall Wood Black Mezzanine level Fire command center Negative 0.03

67 Wall Drywall White Mezzanine level Daycare Negative 0 68 Wall Drywall White Mezzanine level Daycare Negative 0 69 Window frame Metal Beige Mezzanine level Daycare Negative 0

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Reading No. Component Substrate Color Floor Room Results

Lead Cons.

mg/cm2

70 Door frame Metal Beige Mezzanine level Daycare Negative 0

71 Floor Concrete Grey Concourse Level Adj room to CV26 Negative 0

72 Door Metal Grey Concourse Level CV26 Negative 0 73 Door frame Metal Grey Concourse Level CV26 Negative 0 74 Wall Drywall White Concourse Level CV26 Negative 0 75 Calibrate Positive 1.2 76 Calibrate Positive 3.5 77 Calibrate Negative 0

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3.0 OTHER HAZARDOUS BUILDING MATERIALS

Apex inspected for other potential hazardous building materials within the project areas. The purpose of the inspection was to determine if other hazardous building materials such as mercury-containing lighting tubes, thermostats and gauges, PCB light ballasts and transformers, etc. are present, which may be directly affected by the course of renovation/demolition activities. A summary of Apex’s findings is presented below.

Mercury Hazards

No mercury containing comments will be impacted within the project area. Any concealed building materials discovered during renovation/demolition activities, which are suspected to contain mercury should be investigated or tested to confirm the absence or presence of mercury.

PCBs (Polychlorinated Biphenyls)

Apex collected two (2) exterior sealant/caulk bulk samples from the west and south entrance areas to determine if PCBs were present at levels or above 50 parts per million (ppm). The samples were sent to

EMSL Analytical Laboratory of Cinnaminson, NJ for analysis by gas chromatography in accordance with

U.S Environmental Protection Agency (EPA) Test Methods (SW-846) for evaluating PCB. The samples were analyzed for Aroclors1016, 1221, 1232, 1242, 1248, 1254, 1260, 1262, and 1268 (Aroclors are multi-component mixtures of PCBs). Results of the laboratory analysis confirmed none for the presence of PCB’s in the samples.

The sampling results are summarized in Table 4. Laboratory results and chain of custody are included to this report in Appendix C. Site Photographs and Drawing are included in Appendix D and

Appendix E, respectively.

TABLE 4

PCB Bulk Sampling Results

Sample # Description Location Total PCBs

Concentration, parts per million (ppm)

Aroclors® Detected

022819-TMJ-

DA-PCB01

Gray exterior stone wall sealant West entrance ND --

022819-TMJ-

DA-PCB02 Gray door caulk South entrance ND --

Note: Regulated levels of PCBs refers to PCBs in concentrations greater than or equal to (≥) 50 parts per million (ppm).

ND = none detected

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4.0 RECOMMENDATIONS

The following is a series of recommendations that Apex proposes based on laboratory analysis and conditions of the building at the time of the inspection.

Asbestos

Materials suspected of potentially containing asbestos were identified during the inspection and sampled for asbestos content. Since ACM is present in the building, actions should be taken to prevent fiber release and to minimize exposure of subcontractors to asbestos fibers. Appendix D contains a photo log of observed ACM. The following are Apex’s recommendations for management of these ACM.

• The fire doors found in the Daycare, stairwells, fire command office and perimeter areas may be impacted during construction work. Remove projected impacted doors or present a workplan addressing proper handling of asbestos containing fire doors during components removals and replacement.

• The renovation/demolition contractor and other subcontractors working within the building should be made aware of the locations of the ACM and the possibility of concealed suspect ACM that could be found during renovation activities. They should be advised to not disturb the identified ACM or suspect ACM.

• Any concealed building materials discovered during renovation/demolition activities, which are suspected to contain asbestos, should be sampled by a licensed asbestos inspector and analyzed by NVLAP-accredited laboratory to confirm the absence or presence of asbestos prior to disturbing such materials. If the materials are found to contain asbestos, applicable local, state and federal regulations will apply.

The following recommendations should be followed for demolition/renovation projects including contracting the services of an environmental consultant to monitor/document that the abatement contractor activities comply with abatement specifications, applicable local, state and federal requirements.

Using this report as a guide:

• The prospective abatement contractor(s) should independently verify quantities of ACM present and unique site conditions in order to prepare a cost estimate and for notification purposes.

Notification to the proper agency should be submitted prior to commencing any abatement activities.

• A licensed asbestos abatement contractor must remove any regulated ACM (RACM) within the District of Columbia. Abatement activities must be performed in compliance with the abatement specification, applicable local, state, and federal requirements.

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• A ten (10)-day working day notification to the Department of Energy & Environment (DOEE) and a thirty (30) day occupant notice is required (If occupied) on NESHAP sized (greater than or equal to 160 square feet, 260 linear feet, or 35 cubic feet) asbestos abatement projects. Additionally, three

(3) days prior to the beginning of any abatement activities, post warning signs on the entrances/exits of the building.

Lead-based Paint

• No lead abatement is required prior to demolition. It is important to note that even low concentrations of lead in paint (i.e. less than 1.0 mg/cm2) that fall below the criteria for LBP, have the potential to result in some lead exposure to workers, particularly construction workers involved with activities such as torch cutting and welding metal structures, abrasive blasting, or sanding painted surfaces. Work practices involving the disturbance of such lead-containing paints or other materials are regulated under the OSHA’s Lead in Construction Standard in Title 29 of the CFR Part 1926.62. As a result, all construction and demolition activities involving lead-containing materials (regardless of the lead content) must comply with the OSHA standard, which prescribes requirements for contractor/worker exposure assessment, worker protection, and engineering controls.

Other Hazardous Building Materials

• No quantifiable other hazardous building material identified within the project areas. Any concealed building materials discovered during renovation/demolition activities, which are suspected to contain hazardous materials should be investigated or tested to confirm the absence or presence of hazardous materials.

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5.0 LIMITATIONS

Every reasonable attempt was made to locate ACM, LBP, and other hazardous building materials within the project areas. However, areas that are inaccessible can only be addressed through extrapolation of conditions in accessible building space and review of building plans, specifications, or other building documents provided to Apex.

Although every attempt was made to identify suspect ACM, LBP, and other hazardous building materials in the inspected areas, it should be noted that it is possible for additional not identified or tested

ACM, LBP, PCB ballasts, and other hazardous building materials could be found within concealed areas of the locations included in this report. Future construction activities could expose additional suspect building components. If suspect, ACM, LBP, and other hazardous building materials are identified, Apex recommends additional assessment and analysis be performed.

Changes in the condition of the site may occur with time due to either natural processes or human activities. The findings presented in this report are based on site conditions existing at the time of the inspection. Apex cannot be responsible for any errors or omissions in this assessment resulting from incomplete or inaccurate disclosures.

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6.0 REPORT RELIANCE AND USE

This report documents the findings of the services performed by Apex in accordance with our contractual agreement with QUINN EVANS Architects. The findings, opinions, and conclusions of this report are for the exclusive use of QUINN EVANS Architects. This report shall not be provided to any other person, entity, or public or governmental agency (unless otherwise mandated by law) without QUINN

EVANS Architects’s written consent. Reliance on this report for any use or by parties other than specifically stated herein is prohibited without the expressed written consent of both Apex, and QUINN EVANS

Architects. This document is not intended for any purposes other than those expressly set forth herein or as described in Apex’s proposal or for use by parties other than for whom it has been prepared.

Apex Companies, LLC 15850 Crabbs Branch Way, Suite 200Rockville, MD20855 T 800.733.2739 F 301.975.0169 apexcos.com

EXECUTIVE SUMMARY ............................................................................................................................. iii LIST OF ACRONYMS .................................................................................................................................. v

1.0 ASBESTOS INSPECTION

1.1 Sampling Protocol

2.0 LEAD BASED PAINT INSPECTION

3.0 OTHER HAZARDOUS BUILDING MATERIALS

4.0 RECOMMENDATIONS

5.0 LIMITATIONS

6.0 REPORT RELIANCE AND USE

Table 1 Confirmed Asbestos Containing Materials (ACM)

Table 2 Homogeneous Materials

Table 3 Lead XRF Results

Table 4 PCB Bulk Sampling Results

Appendix C Bulk PCB Samples Laboratory Results building inspection for asbestos-containing materials (ACM), lead-based paint (LBP), polychlorinated biphenyl (PCB) suspect sealants and other hazardous materials. Inspection services were performed in

February 2019. The building inspection was limited to interior and exterior Security Program Upgraded

Administration (OSHA) and the U.S. Environmental Protection Agency (EPA). ACM is defined by federal and the District of Columbia regulations as a material that contains greater than one (1) percent asbestos asbestos inspectors. A copy of Mr. Daniel Admasu’s and Mr. Peter Braun’s certifications can be found in inspection by using a portable x-ray fluorescence (XRF) analyzer. The current definition of LBP established by the District of Columbia is greater than or equal to 1.0 milligrams of lead per square centimeter of surface

Apex notes that detectable levels of lead below the District of Columbia’s definition of LBP were reported in paint on multiple building components. Work practices involving the disturbance of such lead-containing paints or other materials are regulated under the OSHA’s Lead in Construction Standard in Title

29 of the CFR Part 1926.62. As a result, all construction and demolition activities involving lead-containing such as mercury-containing lighting tubes, thermostats and gauges, polychlorinated biphenyl (PCB) light materials discovered during renovation/demolition activities, which are suspected to contain mercury were assessed in the project areas during the site visit. Results of the laboratory analysis confirmed none

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

EPA United States Environmental Protection Agency

HAZCOM Hazard Communication

HEPA High Efficiency Particulate Air Filter

HVAC Heating, Ventilation, and Air Conditioning

LBP Lead-based Paint

NESHAP National Emission Standards for Hazardous Air Pollutants

NIST National Institute of Standards and Technology

NOB Non-friable Organically Bound

NVLAP National Voluntary Laboratory Accreditation Program

OSHA Occupational Safety and Health Administration

PACM Presumed Asbestos Containing Material

PCM Phase Contrast Microscopy

PEL Permissible Exposure Limit

PLM Polarized Light Microscopy

TEM Transmission Electron Microscopy

TSCA Toxic Substances Control Act

1.0 ASBESTOS INSPECTION

Apex conducted the asbestos inspection of the building using guidelines set forth by the

Occupational Safety and Health Administration (OSHA) and the U.S. Environmental Protection Agency

(EPA).

Materials that were considered suspect were identified and the number of samples to be collected of these suspect materials was determined by the inspector using the Asbestos Hazard Emergency

Response Act (Title 40 CFR Part 763) (AHERA) protocols. As defined by AHERA policy, suspect materials include the following building material types:

1. Surfacing Materials – including spray-applied or troweled-on wall/ceiling coatings;

2. Thermal System Insulation (TSI) – including pipe insulation, and mudded pipe elbows, and;

3. Miscellaneous Materials –including ceiling tile, floor tiles and mastics, gaskets (if accessible), fire doors, wallboard and spackling.

Suspect materials that are homogeneous in nature (i.e., uniform in color and texture) were identified, touched to determine friability, and sampled by removing a small piece that was then placed in a labeled container. For a given homogeneous area, one (1) or more samples were collected in a randomly distributed manner in accordance with AHERA provisions as referenced in the OSHA Asbestos in

Construction standard (Title 29 CFR 1926.1101). Materials not considered by the AHERA standard as suspect ACM were not addressed by Apex during this inspection, unless specifically referenced.

Table 1 contains a list of the confirmed ACM. The information provided in this table includes detailed ACM descriptions, friability (ability to be reduced to powder by hand pressure), locations, and approximate quantities. Table 2 contains a list of homogeneous materials sampled; which provides a complete list of all identified suspect ACM. Each suspect material is grouped according to class (i.e., surfacing, TSI, or miscellaneous material). This table provides descriptions of each suspect ACM, general location, friability, samples collected, and ACM determination.

All bulk samples were sent to EMSL Analytical, Inc., of Cinnaminson, NJ, a National Voluntary

Laboratory Accreditation Program (NVLAP) accredited laboratory and analyzed using polarized light microscopy in conjunction with dispersion staining (PLM/DS) to determine asbestos content. Appendix B contains the laboratory results/chain-of-custody for all bulk samples collected by Apex during the asbestos

1.1 Sampling Protocol

Suspect building materials to be sampled were classified as friable or non-friable (as defined by the EPA). The materials were sampled to determine whether they are asbestos-containing [i.e., contain greater than one (1) percent asbestos]. Samples were analyzed for asbestos content using PLM/DS by a NVLAP accredited laboratory.

Suspect materials were sampled in general accordance with EPA's AHERA, as referenced in the most recent (September 1996) revision of the OSHA's Asbestos in Construction regulations

[Title 29 of the Code of Federal Regulations (29 CFR) 1926.1101], as follows:

MODIFIED AHERA SAMPLING PROTOCOL

Type of Material Estimated Quantity Required Samples

Sprayed or Troweled-on Surfacing Material

Greater than 5,000 ft2 7

Between 1,000 ft2 and 5,000 ft2 5

Less than 1,000 ft2 3

Thermal System Insulation All Quantities 3

Miscellaneous Materials All Quantities

Per AHERA, these materials must be sampled "in a manner sufficient to determine whether or not they contain asbestos." Apex generally collects 1 to 3 samples of such material based upon the inspector's judgment.

Note: These sampling protocol quantities are per functional area and/or homogeneous area.

A number of suspect ACM identified at the building warranted special scrutiny or otherwise required special consideration. These materials are:

• Floor tiles, resilient flooring, and mastics: All floor tiles, resilient flooring, and underlying mastics were considered suspect ACM. Each flooring material and its associated mastic were sampled and analyzed separately. If either component was found to contain greater than one (1) percent asbestos, then only that material was considered ACM. If carpeting was affixed to the floor, Apex’s procedure consisted only of pulling corners up to one (1) foot to view the material beneath. Based on this observation, the characterization of the homogeneous material underneath (i.e., tile or mastic), if any, was extrapolated to the entire floor surface of that area. Note: When only the mastic tests positive as ACM, the

TABLE 1

Confirmed ACM

Thurgood Marshall Federal Judiciary Building (TMFJB) Washington, DC

Description of Material Friable (Yes/No)

Location ACMa

(Yes/No) Approx.

Quantity

Material Condition Response Action

Fire rated doors No Fire command center, Daycare, exterior perimeter wall, and stairwells Yes 36 each Good

May be impacted during renovation.

Remove project impacted doors prior a ACM: A homogenous material is considered asbestos containing if any one sample is found to contain greater than one percent asbestos.

TABLE 2

Homogeneous Materials List

Thurgood Marshall Federal Judiciary Building (TMFJB) Washington, DC

Description of Material Type Friable (Yes/No) Location Sample

Numbers ACMa

(Yes/No) Approx.

Quantity

Thermal Systems Insulation

White Seam Sealant over Silver Foil Fiberglass Pipe Wrap (HA6) No Loading Dock Above Ceiling B25, B26, B27 No --

Surfacing Materials

Grey Textured Ceiling Plaster (HA3) Loading Dock B17, B18, B19 No --

Grey Texture Wall Plaster (HA4) No Loading Dock B20, B21, B22 No --

Miscellaneous Materials

White Drywall (HA1) No

Loading Dock-Storage Level 6-S Elv. Lob.

Level 6-N Elv. Lob.

Level 7 S Elv. Lob.

Level 7-N Elv. Lob.

Daycare

B01, B02, B03, B04, B05, B06, B07, B08

No --

White Joint Compound (HA2) No

Loading Dock-Storage Level 6-S Elv. Lob.

Level 6-N Elv. Lob.

Level 7 S Elv. Lob.

Level 7-N Elv. Lob.

Daycare

B09, B10, B11, B12, B13, B14, B15, B16

No --

Grey Exterior Stone Wall Sealant (HA5) No Exterior Loading Dock B23, B24 No --

Grey Exterior Stone Wall and Sidewalk Sealant (HA7) No

Atrium Exterior Sidewalk, Atrium Interior Wall, Ground level N Elv. Lob.

South entrance

B28, B29, B30, B31, B32 No --

Grey Marble Floor Grout (HA8) No Atrium B33, B34 No --

Yellow Carpet Mastic (HA9) No North and south garage elevator lobbies B35, B36, B37 No --

White Fire Stop on Metal Electric Conduit (HA10) No North and south garage elevator lobbies B38, B39 No --

Red Fire Stop on Metal Electric Conduit (HA11) No North and south garage elevator lobbies B40, B41 No --

Yellow Carpet Tile Mastic (HA12) No North and south garage Elv Lobbies Daycare

B42, B43, B44, B45, B46 No --

White, Grey, Green, Purple 12”x12” Vinyl Floor Tile (HA13) No Concourse Level- Hallway Adjacent to S

Elevator Lobby B47, B48, B49, B50 No --

Tan Glue Dots associated with

Description of Material Type Friable (Yes/No) Location Sample

Numbers ACMa

(Yes/No) Approx.

Quantity

White Mastic associated with Wood Baseboard (HA15) No Concourse Level-Hallway Adjacent to

North Elevator Lobby B53, B54 No --

Green Seam Sealant on Metal Duct (HA16) No Ground level N Elevator Lobby above

Drywall Ceiling access from Hatch B55, B56 No --

White Seam Sealant on Silver Foil Fiberglass Duct (HA17) No

Level 7- North and South Hallway adjacent to Elevator Lobby above Ceiling Tile

B57, B58 No --

White 2x2 Ceiling Tile with Rough Texture and Silver Backing (HA18)

No Throughput North and South elevator lobbies

B59, B60, B61, B62 No --

White Fire Stop Sealant (HA19) No Level 6 and 7-Hallway Adjacent to Elevator Lobby above Drop Ceiling Tiles B63, B64 No --

Blueish Grey 12”x12” Vinyl Floor Tile and associated Black Mastic

(HA20)

No Fire Command Center B65, B66 No --

Blue 12”x12” Vinyl Floor Tile with Black Specks and associated Yellow Mastic (HA22)

No Concourse Level-Maintenance-Control Room CV26 B67, B68 No --

Grey Exterior Door and Window Caulking (HA23) No South entrance on exterior B69, B70 No --

Fire rated doors (HA21) No Fire Command Center, Daycare, Exterior Perimeter Walls, and Stairwells

Assumed positive Yes 36 each a ACM: A homogenous material is considered asbestos containing if any one sample is found to contain greater than one percent

2.0 LEAD BASED PAINT INSPECTION

Apex performed an x-ray fluorescence (XRF) lead-based paint (LBP) inspection of the project areas. The purpose of the inspection was to determine if LBP is present on the building components located within the interior project areas, which may be directly affected during the course of renovation activities.

The XRF LBP inspection was performed utilizing XRF spectrum analyzer to determine the presence of suspect lead-painted components. XRF technology is well known for accuracy in detecting lead within individual layers of paint. By emitting radiation through each paint layer, Apex was able to determine the presence of lead within tested components. Building components typically known for posing potential lead exposure were tested during the inspection. All XRF test results are found in Table 3.

Certain rooms/areas of the building, similar in design and construction history, were included within the representative LBP inspection. The current definition of LBP established by the District of Columbia is greater than 1.0 milligrams of lead per square centimeter of surface area (>1.0 mg/cm2) using a portable

XRF analyzer.

Apex’s on-site XRF lead-based paint inspection revealed none to be above the District of

Columbia’s definition for LBP.

The lead paint testing is intended to provide testing data to employers, as required by OSHA, so that measures may be taken to prevent lead exposures to workers during renovation and/or demolition activities. This inspection does not include risk assessment of lead hazard. It is important to note that even low concentrations of lead in paint (i.e., less than 1.0 mg/cm2) that do not meet the District of Columbia’s definition for LBP, have the potential to result in some lead exposure to building occupants and/or workers, particularly construction workers involved with activities such as torch cutting and welding metal structures, abrasive blasting, or sanding painted surfaces. Work practices involving the disturbance of such lead-containing paints or other materials are regulated under the U.S. Occupational Safety and Health

Administration’s (OSHA’s) Lead in Construction Standard in Title 29 of the CFR Part 1926.62. As a result, all construction and demolition activities involving lead-containing materials (regardless of the lead content)

TABLE 3

XRF Results

Thurgood Marshall Federal Judiciary Building (TMFJB) Washington, DC

Reading No. Component Substrate Color Floor Room Results

Lead Cons.

mg/cm2

1 Calibrate Positive 1.12 2 Wall CMU Grey Concourse Loading dock Negative 0 3 Wall Concrete Grey Concourse Loading dock Negative 0 4 Wall CMU Grey Concourse Loading dock Negative 0 5 Column Concrete Grey Concourse Loading dock Negative 0

6 Column corner guard Metal Grey Concourse Loading dock Negative 0

7 Vertical pipe Metal Grey Concourse Loading dock Negative 0 8 Lift curb Concrete Yellow Concourse Loading dock Negative 0 9 Lift post Metal White Concourse Loading dock Negative 0 10 Lift floor Metal Blue Concourse Loading dock Negative 0.03 11 Lift threshold Metal Yellow Concourse Loading dock Negative 0 12 Ballard Metal Grey Concourse Loading dock Negative 0.02

13 Curb Concrete Yellow Concourse Loading dock Negative 0 14 Wall Plaster Grey Concourse Loading dock Negative 0

15 Caution floor marking Concrete Yellow Concourse Loading dock Negative 0

16 Wall Drywall Grey Concourse Loading dock Negative 0 17 Door Metal Grey Concourse Loading dock Negative 0 18 Door frame Metal Grey Concourse Loading dock Negative 0

19 Vertical supply pipe Metal Brown Concourse Loading dock Negative 0

20 Ballard Metal Yellow Concourse Loading dock Negative 0 21 Floor Stone Yellow Ground Atrium Negative 0 22 Wall Stone Yellow Ground Atrium Negative 0 23 Wall Stone Grey stone Ground North Elv. Lob. Negative 0 24 Wall Drywall White/Grey Ground North Elv. Lob. Negative 0

25 Floor Stone White/Grey Ground North Elv. Lob. Negative 0.01 26 Floor Marble Green Ground North Lobby Negative 0 27 Floor Stone Grey Ground North Lobby Negative 0 28 Wall Drywall White/Grey Ground North Lobby Negative 0 29 Wall Stone Grey Ground North Lobby Negative 0 30 Wall CMU White Upper Garage North Elv. Lob. Negative 0 31 Wall CMU Green Upper Garage North Elv.Lob. Negative 0 32 Ceiling Concrete White Upper Garage North Elv.Lob. Negative 0 33 Conduit Metal White Upper Garage North Elv.Lob. Negative 0

QuinnEvans-TMFJB-HazMatInsp_rpt;(QUINN-023);dta/ttn 8

Reading No. Component Substrate Color Floor Room Results

Lead Cons.

mg/cm2

34 Conduit Metal White Lower Garage North Elv.Lob. Negative 0 35 Ceiling Concrete White Lower Garage North Elv.Lob. Negative 0 36 Wall CMU White Lower Garage North Elv.Lob. Negative 0 37 Wall CMU Blue Lower Garage North Elv.Lob. Negative 0

38 Wall CMU Red Lower Garage South Elv.Lob. Negative 0 39 Wall CMU White Lower Garage South Elv.Lob. Negative 0 40 Ceiling CMU White Lower Garage South Elv.Lob. Negative 0 41 Door CMU Beige Lower Garage South Elv.Lob. Negative 0 42 Door frame CMU Beige Lower Garage South Elv.Lob. Negative 0 43 Wall CMU Beige Lower Garage South Elv.Lob. Negative 0 44 Wall CMU White Upper level South Elv.Lob. Negative 0 45 Wall CMU Yellow Upper level South Elv.Lob. Negative 0 46 Yellow CMU White Upper level South Elv.Lob. Negative 0.01 47 Wall Metal White/Grey Upper level South Elv.Lob. Negative 0 48 Wall column Wood Grey 7th floor South Elv. Lob. Negative 0

49 Wall Wood Clear varnish 7th floor South Elv. Lob. Negative 0

50 Baseboard Polished granite Green 7th floor South Elv. Lob. Negative 0

51 Baseboard Wood Grey 7th floor South Elv. Lob. Negative 0 52 Wall Drywall White 7th floor South Elv. Lob. Negative 0 53 Wall Drywall White 7th floor South Elv. Lob. Negative 0 54 Wall column Wood Grey 7th floor South Elv. Lob. Negative 0 55 Baseboard Wood Grey 7th floor South Elv. Lob. Negative 0 56 Ceiling Wood Grey 7th floor South Elv. Lob. Negative 0 57 Calibrate Positive 1.15 58 Calibrate Negative 0.6 59 Calibrate Positive 1.3

60 Wall Drywall Grey Mezzanine level Fire command center Negative 0

61 Wall Drywall Grey Mezzanine level Fire command center Negative 0

62 Door Metal Grey Mezzanine level Fire command center Negative 0

63 Door frame Metal Grey Mezzanine level Fire command center Negative 0.01

64 Door frame CMU Grey Mezzanine level Fire command center Negative 0

65 Framing Metal Brown Mezzanine level Fire command center Negative 0

66 Partition wall Wood Black Mezzanine level Fire command center Negative 0.03

67 Wall Drywall White Mezzanine level Daycare Negative 0 68 Wall Drywall White Mezzanine level Daycare Negative 0 69 Window frame Metal Beige Mezzanine level Daycare Negative 0

QuinnEvans-TMFJB-HazMatInsp_rpt;(QUINN-023);dta/ttn 9

Reading No. Component Substrate Color Floor Room Results

Lead Cons.

mg/cm2

70 Door frame Metal Beige Mezzanine level Daycare Negative 0

71 Floor Concrete Grey Concourse Level Adj room to CV26 Negative 0

72 Door Metal Grey Concourse Level CV26 Negative 0 73 Door frame Metal Grey Concourse Level CV26 Negative 0 74 Wall Drywall White Concourse Level CV26 Negative 0 75 Calibrate Positive 1.2 76 Calibrate Positive 3.5 77 Calibrate Negative 0

QuinnEvans-TMFJB-HazMatInsp_rpt;(QUINN-023);dta/ttn 12

• A ten (10)-day working day notification to the Department of Energy & Environment (DOEE) and a thirty (30) day occupant notice is required (If occupied) on NESHAP sized (greater than or equal to 160 square feet, 260 linear feet, or 35 cubic feet) asbestos abatement projects. Additionally, three

(3) days prior to the beginning of any abatement activities, post warning signs on the entrances/exits of the building.

Lead-based Paint

• No lead abatement is required prior to demolition. It is important to note that even low concentrations of lead in paint (i.e. less than 1.0 mg/cm2) that fall below the criteria for LBP, have the potential to result in some lead exposure to workers, particularly construction workers involved with activities such as torch cutting and welding metal structures, abrasive blasting, or sanding painted surfaces. Work practices involving the disturbance of such lead-containing paints or other materials are regulated under the OSHA’s Lead in Construction Standard in Title 29 of the CFR Part 1926.62.

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