Asbestos n Lead TCLP Site #1- EA VAUGHN.pdf

Asbestos and Lead TCLP Environmental Building Assessment

Of

Demolished Barn Type Structure Site #1

Taylor Landing Road Girdletree, MD 21829

NCE Project # 230718-2

Prepared For

Maryland Department of Natural Resources 580 Taylor Avenue

Annapolis, Maryland 21401

Date of Report

August 13, 2023 i

Table of Contents

1.0 Summary

1.1 Summary of Findings

2.0 Introduction and Site Description

2.1 Purpose and General Scope of Services

2.2 Limitations

3.0 Inspection Methods and Rationale

3.1 Asbestos

3.2 Lead TCLP

4.0 Results and Recommendations

4.1 Asbestos

4.2 Lead TCLP

5.0 Certification

List of Appendices

Appendix A Asbestos Bulk Data Sheets Appendix B Asbestos Laboratory Analytical Data Appendix C Lead TCLP Laboratory Analytical Data

Asbestos and Lead TCLP Environmental Building Assessment Demolished Barn Structure – Taylor Landing Road, Girdletree, MD: NCE Project No. 230718-2

1.0 Summary

Norman Creek Environmental (NCE) was retained by the Maryland Department of Natural Resources to conduct an Environmental Building Assessment of the demolished barn type structure on the property at Site #1, Taylor Landing Rd. (the Site) in Girdletree, Maryland.

The purpose of this Environmental Building Assessment was to identify specific building materials and building contents that must be addressed prior to or during demolition of the structures at the Site to ensure environmental compliance with local, state, and Federal regulations.

The scope of services included inspection, assessment, and sampling/analysis of suspect asbestos-containing materials (ACMs) and collection of samples for lead Toxicity Characteristic Leaching Procedure (TCLP) analysis. NCE conducted the inspections and sampling on July 28, 2023.

1.1 Summary of Findings

A summary of findings for the assessed hazardous materials that may require removal, recycling/disposal, and/or remediation is presented below. Details regarding the identified hazardous materials and the associated recommendations can be found in the corresponding section of the report.

Item Potential Hazard Section Hazardous Material Identified?

ACM > 1% Asbestos 4.1 Yes

Lead TCLP Lead > 5 mg/L 4.2 No

Based on the visual assessment, It appears that the structure has been demolished, with all debris remaining on-site. The sampling consisted of collecting samples of suspect asbestos containing materials within the debris pile as visually identified. TCLP sampling for lead was also conducted by collecting painted and non-painted materials within the debris pile.

2.0 Introduction and Site Description

One demolished structure is located on the property. No information relating to the date of construction or actual street address was provided by the Owner. It is the intent of the Owner to remove and dispose of the demolish materials noted to be on site within the debris pile.

The structure on the property has undergone demolition activities in what appears to have been several years ago. The purpose of this Environmental Building Assessment was to identify specific building materials and contents that must be addressed prior to disposal of the demolished structure to ensure environmental compliance with local, state, and Federal regulations. This Environmental Building Assessment was conducted on July 28, 2023.

A summary of the scope of work for this Environmental Building Assessment included the following:

• Conduct comprehensive asbestos inspections of the structure debris pile and

• Conduct lead-specific pre-demolition composite TCLP sampling of the structure.

2.1 Limitations

The limitations that were encountered during this Environmental Building Assessment include limited visual access to materials within the debris pile. Not all materials could be visually assessed at the time of the inspection.

3.0 Inspection Methods and Rationale

3.1 Asbestos

The purpose of this asbestos inspection was to identify whether building materials at the Site are ACMs that may be subject to National Emission Standards for Hazardous Air Pollutants (NESHAP)/Maryland requirements during the planned disposal activities. An ACM is a building material that contains greater than 1% asbestos. According to NESHAP and Maryland regulations, regulated ACM (RACM) must be removed by a Maryland-licensed Asbestos Contractor in accordance with COMAR 26.11.21, if the RACM will be impacted by renovation or demolition activities. As defined in Title 40 of the Code of Federal Regulations (CFR) Part 61, RACM includes (a) friable asbestos materials; (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; and (d) Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder during demolition or renovation activities.

NCE adheres to sampling requirements outlined in the Asbestos Hazard Emergency Response Act (AHERA) and Occupational Safety and Health Act (OSHA). NCE’s Maryland-licensed Asbestos Inspector (William Montley, License # 230003591) conducted the asbestos inspection and sampling. A total of 6 building material samples were collected and shipped to an accredited laboratory (SanAir Technologies Laboratory, Inc. in Powhatan, Virginia) for analysis using polarized light microscopy (PLM) by U.S. Environmental Protection Agency (EPA) Method 600. Samples that represent two or more distinct layers of building materials are considered to be heterogeneous, and each layer or distinct material is analyzed and reported separately.

As a result, 8 PLM analyses were required. All ACMs were quantified and are provided in this report in Section 4.1.

3.2 Lead TCLP

The purpose of the lead TCLP assessment was to evaluate the disposal requirements for the building materials and contents in association with the planned demolition of the buildings and in accordance with local, state, and Federal regulations.

The lead-specific TCLP test simulates landfill-leaching conditions; specifically, how much lead will leach out of the waste when exposed to typical landfill conditions. If the leachable amount of lead is equal to or greater than 5.0 milligrams per liter (mg/L), the waste is classified as hazardous waste. If the leachable amount of lead is less than 5.0 mg/L, the waste is classified as non-hazardous waste. The State of Maryland and EPA require that: (1) samples be truly "representative" of the building waste intended for disposal; (2) samples must contain a minimum of 100 grams of material; and (3) laboratories conducting the TCLP test must comply with EPA guidance SW-846.

To ensure that composite samples are "representative" of the entire quantity of debris removed, NCE collects one composite sample per structure or one per 2,500 square feet of floor space, whichever results in the greater number of samples. NCE collected one composite TCLP sample from the Site. The sample was shipped to an accredited laboratory (SanAir Technologies Laboratory, Inc. in Powhatan, Virginia) for lead TCLP analysis by EPA Methods 1311 and 6010C.

4.0 Results and Recommendations

4.1 Asbestos

This section provides the results of the asbestos inspection (sampling and analyses) for the structure at the Site. It is important to note that not all building material types were sampled. The inspection was limited to building materials that were accessible and suspected to contain asbestos at the time of the inspection. The asbestos bulk data sheets and laboratory analytical results are provided in Appendix A and Appendix B, respectively.

A total of 6 building material samples were collected at the site. A total of 8 PLM analyses were completed based on material layering. The table below provides a list of RACM identified at the site. RACM must be removed by a Maryland-licensed Asbestos Contractor in accordance with COMAR 26.11.21, if the RACM will be impacted by renovation or demolition activities. Category I non friable asbestos may remain in the structure providing the structure is not demolished by intentional burning and materials are not made friable during the demolition process. Refer to “A Guide to Normal Demolition Practices Under the Asbestos NESHAP” for demolition guidance and disposal requirements. The document can be reviewed at the following web link:

https://www.epa.gov/sites/default/files/2014-09/documents/epa-340-1-92-013- 199209.pdf. The guide requires all Category II Non-friable asbestos materials be removed prior to demolition. In this case, the Category II non-friable asbestos materials are located throughout the debris pile. Category I non-friable materials are also located throughout the debris pipe. NCE recommends that all materials within the debris pile be disposed of as Category II nonfriable asbestos, in a landfill permitted to accept Category I and II non-friable asbestos containing materials.

Regulated ACM Estimated Quantity

Asbestos Type Location(s)

Asbestos Cement Board Roofing Panels 2500 SF Category 1I

Nonfriable Debris Pile

Vinyl Asbestos Floor Tile 2500 SF Category 1 Nonfriable Debris Pile

Asbestos Cement Board Wall Panels

2500 SF

Category 1I Nonfriable Debris Pile

4.2 Lead TCLP

This section provides the results of the lead-specific pre-demolition composite TCLP sampling and analyses for the structure at the Site. NCE collected one composite sample from the Site. Analytical results are provided in Appendix C.

Sample Location Lead TCLP Concentration (mg/L)

Demolished Barn-type Structure <0.5

The results of the lead-specific TCLP testing indicate that the leachable lead concentration for the debris associated with the structure was less than 5.0 mg/L. As a result, any construction waste/debris associated with the Site would be considered non-hazardous for lead.

5.0 Certification

This Environmental Building Assessment was conducted in accordance with accepted environmental practices, standards, regulations, and procedures.

Prepared By:

William Montley, CHMM

Principal

Appendices

Project No. 230718-2

Appendix A Asbestos Bulk Data Sheets

Date: July 28, 2023 page: 1

Bulk Asbestos Sampling Data Inspector: William Montley Accred: 230003591

Sample Area Suspect ACM Friable (y/n)

1 Debris Pile Asbestos Cement Board Roof Panels N

2 Debris Pile Asbestos Cement Board Roof Panels N

3 Debris Pile 9x9 VCT and Mastic Debris N

4 Debris Pile 9x9 VCT and Mastic Debris N

5 Debris Pile Asbetsos Cement Board Flat Panels N

6 Debris Pile Asbetsos Cement Board Flat Panels N

ASBESTOS BULK DATA Project Name:

Site #1, Taylor Landing Road, Girdletree, MD

Project # 230718-2

Date: 7/28/2023

No. Suspect Homogeneous

ACM

Friabl e (Y/N)

“+” Approx.

Quantity Location(s) Sample

ID(s)

Curved Asbestos Cement Board

Roof Panels

N

Debris Pile

01/02

9x9 Vinyl Floor Tile Debris

03a/4a

9x9 Vinyl Floor Tile Mastic Debris

03b/04b

Flat Asbestos Cement Board Wall Panels

05/06

“X” = Building Materials Containing > 1% Asbestos by PLM Analysis

ACRONYMS: NOTES:

ACM - asbestos-containing material LF - linear feet PLM - polarized light microscopy SF - square feet

Page_1_ of _1_

X

Appendix B Asbestos Laboratory

Analytical Data

SanAir ID#: 23041763

Project Name: Site #1, Taylor Landing Road Report Date: 8/11/2023

Analysis Report prepared for Norman Creek Environmental LLC

Dear William Montley, We at SanAir would like to thank you for the work you recently submitted. The 6 sample(s) were received on Tuesday, August 01, 2023 via UPS. The final report(s) is enclosed for the following sample(s): 01, 02, 03, 04, 05, 06.

These results only pertain to this job and should not be used in the interpretation of any other job. This report is only complete in its entirety. Refer to the listing below of the pages included in a complete final report.

Sincerely, Sandra Sobrino Asbestos & Materials Laboratory Manager SanAir Technologies Laboratory

Final Report Includes:

- Cover Letter

- Analysis Pages

- Disclaimers and Additional Information

Sample conditions:

- 6 samples in Good condition.

10501 Trade Ct., N. Chesterfield, VA 23236 | 804.897.1177 | Fax: 804.897.0070 | www.SanAir.com | IAQ@SanAir.com

Project Number:

P.O. Number:

Project Name: Site #1, Taylor Landing Road

7/28/2023Collected Date:

8/1/2023 10:30:00 AMReceived Date:

8/11/2023 3:02:54 PM

23041763 SanAir ID Number

FINAL REPORT

Norman Creek Environmental LLCName:

Address: 416 Katherine Avenue

Essex, MD 21221

443-690-8659Phone:

Analyst: Moore, Brandi

Asbestos Bulk PLM EPA 600/R-93/116 Stereoscopic Components

SanAir ID / Description Appearance % Fibrous % Non-fibrous Asbestos Fibers 01 / 23041763-001 Roof Panels (Transite)

Grey Non-Fibrous

Homogeneous

88% Other 12% Chrysotile

02 / 23041763-002 Roof Panels (Transite)

Grey Non-Fibrous

Homogeneous

88% Other 12% Chrysotile

03 / 23041763-003 9x9 VAT & Mastic, Floor Tile

Black Non-Fibrous

Homogeneous

95% Other 5% Chrysotile

03 / 23041763-003 9x9 VAT & Mastic, Mastic

Black Non-Fibrous

Homogeneous

100% Other None Detected

04 / 23041763-004 9x9 VAT & Mastic, Floor Tile

Black Non-Fibrous

Homogeneous

95% Other 5% Chrysotile

04 / 23041763-004 9x9 VAT & Mastic, Mastic

Black Non-Fibrous

Homogeneous

100% Other None Detected

05 / 23041763-005 Transite Flat Panels

Grey Non-Fibrous

Homogeneous

88% Other 12% Chrysotile

06 / 23041763-006 Transite Flat Panels

Grey Non-Fibrous

Homogeneous

88% Other 12% Chrysotile

Analyst:

Analysis Date: 8/11/2023 Date: 8/11/2023

Approved Signatory:

Project Number:

P.O. Number:

Project Name: Site #1, Taylor Landing Road

7/28/2023Collected Date:

8/1/2023 10:30:00 AMReceived Date:

8/11/2023 3:02:54 PM

23041763 SanAir ID Number

FINAL REPORT

Norman Creek Environmental LLCName:

Address: 416 Katherine Avenue

Essex, MD 21221

Disclaimer

This report is the sole property of the client named on the SanAir Technologies Laboratory chain-of-custody (COC). Results in the report are confidential information intended only for the use by the customer listed on the COC. Neither results nor reports will be discussed with or released to any third party without our client's written permission. The final report shall not be reproduced except in full without written approval of the laboratory to assure that parts of the report are not taken out of context. This report and any information contained within shall not be edited, altered, or modified in any way by any persons or agencies receiving, viewing, distributing, or otherwise possessing a copy of this final report. The laboratory reserves the right to perform amendments to any finalized report, of which shall supersede and make obsolete any previous editions. Such changes, modifications, additions, or deletions shall be effective immediately upon notice thereof, which may be given by means including but not limited to posting on the SanAir client portal website, electronic or conventional mail, or by any other means. The information provided in this report applies only to the samples submitted and is relevant only for the date, time, and location of sampling. The accuracy of the results is dependent upon the client’s sampling procedure and information provided to the laboratory by the client on the COC. SanAir assumes no responsibility for the sampling procedure and will provide evaluation reports based solely on the sample(s) in the condition in which they arrived at the laboratory and information provided by the client on the COC, such as: project number, project name, collection dates, po number, special instructions, samples collected by, sample numbers, sample identifications, sample type, selected analysis type, flow rate, total volume or area, and start stop times that may affect the validity of the results in this report. Samples were received in good condition unless otherwise noted on the report.

SanAir assumes no responsibility or liability for the manner in which the results are used or interpreted. This report does not constitute nor shall not be used by the client to claim product, process, system, or person certification, approval, or endorsement by NVLAP, NIST, NELAC, AIHA LAP, LLC or any other U.S. governmental agencies and may not be accredited by every local, state, and federal regulatory agencies. Samples are held for a period of 60 days. Fibers smaller than 5 microns cannot be seen with this method due to scope limitations. For NY state samples, method EPA 600/M4-82-020 is performed.

NYELAP Disclaimer:

Polarized- light microscopy is not consistently reliable in detecting asbestos in floor covering and similar non-friable organically bound materials. Quantitative transmission electron microscopy is currently the only method that can be used to determine if this material can be considered or treated as non-asbestos containing.

Asbestos Accreditations National Voluntary Laboratory Accreditation Program (NVLAP) Lab Code 200870-0 City of Philadelphia Department of Public Health Air Management Services, Certification#ALL-460 Commonwealth of Pennsylvania Department of Environmental Protection Number 68-05397 California State Environmental Laboratory Accreditation Program Certificate Number 2915 Colorado Department of Public Health and Environment Registration Number AL-23143 Connecticut Department of Public Health Environmental Laboratory Registration Number PH-0105 Massachusetts Department of Labor Standards Asbestos Analytical Services License Number:

AA000222

State of Maine Department of Environmental Protection License Number: LB-0075, LA-0084 New York State Department of Health Laboratory ID: 11983 State of Rhode Island Department of Health Certification No.: PCM00126, PLM00126, TEM00126 Texas Department of State Health Services License Number: 300440 Commonwealth of Virginia Department of Professional and Occupational Regulation Number:

3333000323 State of Washington Department of Ecology Laboratory ID: C989 State of West Virginia Bureau for Public Health Analytical Laboratory Number: LT000616 Vermont Department of Health License Number: Asb-Co-An-000006 Louisiana Department of Environmental Quality AI Number 212253, Certificate #05088

Revision Date: 4/18/2023 Page 4 of 5

Appendix C Lead TCLP

Laboratory Analytical Data

SanAir ID#: 23041576

Project Name: Site #1, Taylor Landing Rd Report Date: 8/8/2023

Analysis Report prepared for Norman Creek Environmental LLC

Dear William Montley, We at SanAir would like to thank you for the work you recently submitted. The 1 sample(s) were received on Tuesday, August 01, 2023 via UPS. The final report(s) is enclosed for the following sample(s): 01.

These results only pertain to this job and should not be used in the interpretation of any other job. This report is only complete in its entirety. Refer to the listing below of the pages included in a complete final report.

Sincerely, Abisola Kasali Metals Laboratory Director SanAir Technologies Laboratory

Final Report Includes:

- Cover Letter

- Analysis on Test Family T

- Disclaimers and Additional Information

Sample conditions:

- 1 samples in Good condition.

10501 Trade Ct., N. Chesterfield, VA 23236 | 804.897.1177 | Fax: 804.897.0070 | www.SanAir.com | IAQ@SanAir.com

Project Number:

P.O. Number:

Project Name: Site #1, Taylor Landing Rd

7/28/2023Collected Date:

8/1/2023 10:30:00 AMReceived Date:

8/8/2023 10:12:54 AM

23041576 SanAir ID Number

FINAL REPORT

Norman Creek Environmental LLCName:

Address: 416 Katherine Avenue

Essex, MD 21221

Analyst: Baird, Marti

Test Method: EPA 1311/6010C

TCLP Analysis Results in

Sample Description Analyte mg/L MRL (mg/L)

23041576 - 1 01 / TCLP-01 Lead Lead (Pb) < 0.5 < 0.5

Signature:

Date: 8/4/2023 Date: 8/4/2023

Reviewed:

Project Number:

P.O. Number:

Project Name: Site #1, Taylor Landing Rd

7/28/2023Collected Date:

8/1/2023 10:30:00 AMReceived Date:

8/8/2023 10:12:54 AM

23041576 SanAir ID Number

FINAL REPORT

Norman Creek Environmental LLCName:

Address: 416 Katherine Avenue

Essex, MD 21221

Disclaimer

Refer to our accreditation certificate and scope on our website at www.sanair.com for an up to date list of the Fields of Testing for which we are accredited. SanAir participates in the State of New York’s DOH-ELAP (Lab Id 11983), and has met the EPA's NLLAP program standards. This report does not constitute nor shall be used by the client to claim product, process, system, or person certification, approval, or endorsement by AIHA LAP, LLC, NELAC, NIST, and/or any other U.S. governmental agencies; and test results in this report may not be accredited by every local, state or federal regulatory agency.

This report is the sole property of the client named on the SanAir Technologies Laboratory chain-of-custody (COC). Neither results nor reports will be discussed with or released to any third party without our client’s written permission. Final reports cannot be reproduced, except in full, without written authorization from SanAir Technologies Laboratory, Inc. This report and any information contained within shall not be edited, altered, or modified in any way by any persons or agencies receiving, viewing, distributing, or otherwise possessing a copy of this final report. The laboratory reserves the right to perform amendments to any finalized report, of which shall supersede and make obsolete any previous editions. Such changes, modifications, additions, or deletions shall be effective immediately upon notice thereof, which may be given by means including but not limited to posting on the SanAir client portal website, electronic or conventional mail, or by any other means. The information provided in this report applies only to the samples submitted and is relevant only for the date, time, and location of sampling. The accuracy of the results of the analysis is dependent upon the method of sample procurement and information provided by the client on the COC, neither of which SanAir assumes responsibility for, such as project number, project name, collection dates, po number, special instructions, samples collected by, sample numbers, sample identifications, sample type, selected analysis type, flow rate, total volume or area, and start stop times that may affect the validity of the results in this report. SanAir Technologies Laboratory, Inc only assures the precision and accuracy of the data it generates and assumes no responsibility for errors or biasing that occur during collection prior to SanAir’s receipt of the sample(s). Evaluation reports are based solely on the sample(s) in the condition in which they arrived at the laboratory and on the information provided by the client on the COC. Sample(s) were received in good condition unless otherwise noted on the report. SanAir assumes no responsibility or liability for the manner in which the results are used or interpreted. SanAir’s Method Detection Limits (MDL) and Reporting Limits (RL) have been derived using various materials meeting each accrediting agencies’ standards. All quality control results are acceptable unless otherwise noted. SanAir does not make contamination corrections to reports based upon analysis of laboratory and/or field blanks. All samples are disposed of after 90 days unless otherwise requested by the client.

TCLP EPA Limits

5.0 mg/L Silver (Ag) 100 mg/L Barium (Ba) 5.0 mg/L Chromium (Cr) 5.0 mg/L Lead (Pb)

5.0 mg/L Arsenic (As) 1.0 mg/L Cadmium (Cd) 0.2 mg/L Mercury (Hg) 1.0 mg/L Selenium (Se)

LELAP Lab ID#05088 Commonwealth of VA Department of General Services DCLS, VELAP Laboratory ID#460251 New York State Department of Health Laboratory ID No: 11983 California State Environmental Laboratory Accreditation Program Certificate No: 2915 State of Connecticut Department of Public Health Environmental Laboratory Registration Number: PH-0105

Revision Date 2/16/2023