Asbestos Re-Inspection Report DSCR Building No. 32.pdf

ASBESTOS RE-INSPECTION REPORT FOR BUILDING NO. 32

AT

DEFENSE LOGISTICS AGENCY

DEFENSE SUPPLY CENTER RICHMOND

RICHMOND, VIRGINIA

May 22, 2018

Revision 1

Prepared by

U.S. ARMY CORPS OF ENGINEERS, BALTIMORE DISTRICT

Environmental and Munitions Design Center Environmental and Explosive Safety Section

2 Hopkins Plaza Baltimore, Maryland 21201

Asbestos Re-inspection Report Building No. 32 May 22, 2018

This report describes specific activities and findings related to the asbestos re-inspection for the interior and exterior of Building 32. This report was prepared and reviewed by the following individuals:

Stephen B. Epps

Project Lead Industrial Hygienist Asbestos Inspector/ Management Planner VA Asbestos Inspector No. 3303004379 Management Planner No. 3304001667 Environmental and Munitions Design Center Environmental Safety Office United States Army Corps of Engineers-Baltimore District

Genet A. Tulu

Industrial Hygienist Asbestos Inspector VA Asbestos Inspector No. 3303004380 Environmental and Munitions Design Center Environmental Safety Office United States Army Corps of Engineers-Baltimore District

TABLE OF CONTENTS

EXECUTIVE SUMMARY

1.0 INTRODUCTION

1.1 Scope of Work

1.2 Purpose

2.0 PROCESS

2.1 Sample Collection Procedures

2.2 Analytical Standards and Result Evaluation

Table 1. ACM Hazard Ranking

3.0 BUILDING DESCRIPTION

4.0 SUMMARY OF FINDINGS

5.0 RECOMMENDATION

Table 2. Non Asbestos Homogenous Areas (2006-2018)

Figure 1. ACM and PACM Locations

APPENDIX A. PHOTGRAPHS OF ACM

APPENDIX B. INSPECTOR LICENSES

EXECUTIVE SUMMARY

The United States Army Corps of Engineers (USACE), Baltimore District personnel have been tasked with conducting an installation wide, comprehensive Asbestos re-inspection for non-school and non-childcare facilities located at the Defense Supply Center Richmond (DSCR).

This installation is located at 8000 Jefferson Davis Highway in Richmond, Virginia and supports the Defense Logistics Agency (DLA).

This re-inspection is a requirement under the approved installation Asbestos Management Plan that covers all federal buildings on the installation (Zia, 2013) and will provide the necessary surveillance information to identify and assess the condition of known Asbestos Containing Building Materials (ACBM), also referred in this report as Asbestos Containing Materials (ACM). The report also serves to identify ACM that may have been missed on previous surveys due to limited access. This report will serve the DSCR, DF-Free Environmental Management Division in ensuring that their operation and maintenance (O&M) program minimizes or eliminates the exposure to asbestos fibers during routine operations in or around ACBM.

Additionally, this report will provide the preliminary information necessary in the planning process during projects that may involve renovation or demolition of ACBM in compliance with provisions of the Clean Air Act.

Ms. Genet Tulu (VA Asbestos Inspector No. 3303004380) conducted the re-inspection of Building No. 32 on April 18, 2018. The survey was conducted in accordance with State and Federal regulations. During the survey building materials known to be ACBM were verified and additional homogenous areas suspected to be Asbestos Containing Materials (ACM) were visually identified, their quantity measured, and sampled for analysis, where necessary in accordance with EPA regulation 40 CFR 763 and the Asbestos Hazard Emergency Response Act.

During this survey all ACM materials that were identified during the previous survey in 2013 were visually inspected and quantities verified. Materials identified to contain asbestos in the previous survey and confirmed during this re-inspection were hinged and sliding fire doors. No additional homogenous areas or ACM were identified during this survey.

1.0 INTRODUCTION

1.1 Scope of Work

An asbestos re-inspection survey was completed for Building No. 32 located at the Defense Supply Center Richmond in Richmond, Virginia. The re-inspection was conducted by personnel from the U.S. Army Corps of Engineers (USACE), Baltimore District, Environmental and Explosives Safety Section (EESS) at the request of USACE Norfolk District on behalf of Defense Logistics Agency Installation Support at Richmond. This re-inspection was conducted on April 18, 2018 by Virginia licensed asbestos inspectors and in accordance with all applicable state and federal regulations.

1.2 Purpose

This survey identifies and evaluates ACM, PACM, or suspect materials that were not previously identified, if any. The re-inspection incorporates findings from a previous survey that was conducted on June 12, 2013 by Zia Engineering & Environmental Consultants, LLC (Zia). The goal of this re-inspection is to assess the condition of previously identified ACM, PACM, and to conduct visual and physical assessments on any previously un-sampled suspect homogenous areas. If ACM or PACM is found, the report identifies the areas and materials that contain ACM or PACM, the quantity of the material, current condition, hazard assessment, and updated diagrams that show the materials location.

2.0 PROCESS

The asbestos re-inspection was performed in accordance with 40 CFR Part 763, Asbestos Hazard Emergency Response Act (AHERA) and EPA 40 CFR Part 61 National Emissions Standard for Hazardous Air Pollutants (NESHAP). The re-inspection included visual identification of existing and accessible suspect homogenous building materials. In addition, an assessment of condition, friability, and estimate of material quantity was made. Field information was organized as per the AHERA concept of homogenous area. A homogenous area is defined as a suspect material of similar age, appearance, function and texture. Homogenous areas were grouped building-wide to determine if additional or new samples need to be collected.

A thorough attempt was made to access all areas for visual and physical verification of suspect ACM. However, due to the partial destructive nature of collecting building samples for asbestos analysis and some areas may be inaccessible or conditions may present a challenge to safe entry or access to the materials, EESS personnel do not guarantee that all ACM or PACM in the building were located and identified. Additionally, this report details suspect ACM or PACM as identified at the time of inspection only. Quantities of suspect ACM listed in this report are rough field measurements only and if removal is necessary they must be verified by contractors prior to commencement of work.

Initially the 2013 Asbestos report from the inspection from Zia was reviewed by EESS inspectors. If the materials found to be ACM or PACM were re-located and quantity verified, their condition will be assessed and reported. It is possible that some ACM or PACM materials identified on previous survey were not re-located or were ruled out through further sampling and analysis during this survey.

2.1 Sample Collection Procedures

If additional suspect homogenous areas that were not sampled or considered during the previous survey were located during this re-inspection, their size will be quantified and the material may be sampled for verification. Bulk confirmatory samples of suspect ACM will then be collected in the following manner;

1) Materials will be divided into homogenous areas.

2) Representative samples of each of the following homogeneous area categories may be collected or material may be assumed to contain asbestos.

• Thermal System Insulation (TSI) is insulation material applied to boilers, pipes, fittings, tanks, ducts, or on other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes. For suspect TSI a minimum of three bulk samples are required to be collected for verification.

• Surfacing material means material that is sprayed-on, troweled-on, or otherwise applied to surfaces, such as acoustical plaster on ceiling and fireproofing materials on structural members or other materials on surfaces for acoustical, fireproofing, or other purposes. For suspect surfacing material a minimum of three bulk samples are required to be collected for homogenous area less than 1,000 square feet, a minimum of 5 bulk samples are required for a homogenous area greater than 1,000 square feet and less than 5,000 square feet, and a minimum of 7 bulk samples are required for a homogenous area greater than 5,000 square feet.

• Miscellaneous material means interior building material on structural components, structural members or fixtures, such as floor and ceiling tiles, and does not include surfacing material or thermal system insulation. For suspect miscellaneous material a minimum of two bulk samples are required to be collected for verification.

3) After collection, each sample will be packaged in a sealed plastic bag, labeled, and a sample Chain of Custody will be prepared. Additionally a field sampling log with the sample number, sampled material type, location where the sample was collected, and quantity of the material will be maintained.

2.2 Analytical Standards and Result Evaluation

Bulk samples of suspect ACM collected will be analyzed by the accepted method of polarized light microscopy (PLM) using the Environmental Protection Agency’s method, EPA-600 visual estimate. Some samples may be prepared using gravity tracked matrix reduction method (ELAP 198.6) since the binding material may be obstructing the view of asbestos fibers. Additionally, for non-friable or organically bound bulk samples, when trace amount asbestos is identified during the PLM analysis the inspector may choose to submit these samples for Transmission Electron Microscopy (TEM) with the NY ELAP198.4 method for a definitive assessment. The bulk samples were analyzed by Aerosol Monitoring and Analytical Services, Inc. (AMA Inc.).

This laboratory is accredited by the National Voluntary Laboratory Accredited Program (NVLAP Accreditation No. 101143-0) an accreditation sponsored by the National Institute of Standards and Technology (NIST)).

Samples analyzed having no identified asbestos are reported as “NAD” (No Asbestos Detected).

Those containing less than 1% asbestos are reported as “TR” (Trace). Those containing asbestos were reported with the type and percentage of asbestos. In compliance with the AHERA regulations, material is considered an ACM when it contains greater than one percent asbestos.

The one percent cut off is consistent with EPA's definition under the asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP). However, the Occupational Safety and Health Act (OSHA) has a standard with a definition for both "asbestos" and "asbestos-containing materials." This definition of asbestos does not have a one percent cut off, therefore, asbestos that is present in percentages less than one percent continues to be covered by the OSHA standard. Work operations conducted in areas where the asbestos or asbestos product is below one percent is considered an "unclassified" operation and would need to adhere to some of the requirements under OSHA, therefore results that have trace asbestos will be considered ACM for worker protection purposes.

Materials found to contain asbestos will then be assessed utilizing the following hazard ranking table (Table 1).

Table 1. ACM Hazard Ranking Assessment Category ACM Condition ACM Disturbance Potential

7 Significantly Damaged* Any 6 Damaged Significant Damage 5 Damaged Damage 4 Damaged Low 3 Good Significant Damage 2 Good Damage 1 Good Low

* The difference between damage and significantly damaged is that significantly damaged means damage evenly distributed across 10% or more of the functional space or localized over 25% of the functional space

3.0 BUILDING DESCRIPTION

Building No. 32 was constructed approximately in 1942 and in the previous survey it was noted that the building was remodeled sometime after 2006. The building is approximately 272,000 square feet in size. The building is an old warehouse building that has been converted into office space. The exterior material consists of mainly of brick construction on a concrete foundation with a metal gable roof. Interior finishes include unfinished concrete floors, carpet, ceramic and vinyl tile; lay-in suspended ceiling tile, drywall and concrete block interior walls. The boiler rooms and mechanical rooms throughout this building have been fitted with fiberglass insulation, boiler rooms with fiberglass gasket rope and pipe insulation, pipe elbow fittings with plastic elbows and joints.

4.0 SUMMARY OF FINDINGS

Ms. Genet Tulu (VA Asbestos Inspector No. 3303004380) conducted the re-inspection of this building on April 18, 2018. Upon reviewing the 2013 inspection report prepared by Zia and conducting the building walkthrough, the following ACM were verified;

• Fire Doors (Hinged and Sliding)

During the re-inspection no additional homogenous areas were discovered. Additional information on the location of ACM verified can be found in Figure 1. A consolidated list of materials that were ruled out as ACM to date can be found in Table 2, these materials were ruled out either through the experience and knowledge of an accredited inspector or by means of laboratory analysis of samples from previous surveys. Further investigation and sampling should not be required for these areas as long as design specifications for the building can be reviewed to determine that “Asbestos Free” materials were utilized in the final construction and renovation materials.

5.0 RECOMMENDATION

Fire Doors

During the current and previous inspections sixty fire doors were identified and considered PACM. These doors were found intact and good condition. As long as the doors are maintained in good condition and drilling, cutting, or damaging of any fire doors is avoided this material can be left in place and would poses relatively little risk of asbestos exposure to occupants under normal conditions. There is an elevated risk of exposure to individuals conducting maintenance activities on these doors, such as hardware installation or during the course of a fire or any damage to the doors, asbestos fibers can be released in to the air. Even if fire doors appear to be newly installed, appearance or age is not a good indicator on the likelihood the core may be comprised of asbestos containing materials. If activities that could disturb the core of a fire door are scheduled then the door manufacturer should be contacted to determine if asbestos is included in the materials of construction or the door core material can be sampled by an accredited asbestos inspector. The downfall of coring a fire door for analysis is that it will damage and compromise the fire rating of the doors and if ACM is present it may result in the release of asbestos fibers into the air. Refer to the AMP for further guidance on the removal, maintenance, and disposal of asbestos containing materials.

Table 2. Non Asbestos Homogenous Areas (2006-2018) Homogenous Areas Non Suspect Not ACM

2x2 fissure/pinhole ceiling tile x sheetrock and joint compound x 4" tan cove base and mastic x

4" grey cove base with mastic x 4" red cove base with mastic x

4" black cove base and mastic x 4" green cove base and mastic x

4" mint green cove base and mastic x 16x16 strawberry floor tiles/ mastic x

12x12 off-white w/ black floor tiles/ mastic x 12x12 grey w/ red spots floor tiles/ mastic x

12x12 grey smear floor tiles/ mastic x 12x12 grey w/ black white floor tiles/ mastic x

12x12 grey stone floor tiles/ mastic x 12x12 green floor tiles/ mastic x

12x12 dark green floor tiles/ mastic x 12x12 orange floor tiles/ mastic x

4" wall grout x floor expansion joint caulk black x window glazing x sink mastic x 2" wall grout x

6" dark grey cove base and mastic x 2x2 recessed fissures/ pinhole ceiling tile x

2x2 recessed waffled face ceiling tile x 2x2 textured ceiling tile/ pinhole x

2x2 textured ceiling tile x 2x2 grooved ceiling tile x fiberglass paper wrap x batt insulation x white mastic on fiberglass pipe insulation x

12x 12 grey blue tile with mastic x tan marble wall paper over joint compound and drywall x

2x 2 fissure pinhole random ceiling tile x 2x 2 pinhole large ceiling tile x

Smooth texture, joint compound and drywall x 12x 12 dark green tile with yellow mastic x green vertical stripe wallpaper, joint compound and drywall x green arrowhead wallpaper, joint compound and drywall x pink arrowhead wallpaper, joint compound and drywall x green crinkle wallpaper, joint compound and drywall x blue crinkle wallpaper, joint compound and sheetrock x grey crinkle wall paper, joint compound and sheetrock x

Figure 1. ACM and PACM Locations

APPENDIX A. PHOTGRAPHS OF ACM

PHOTO 1

Fire Doors (Sliding and Hinged)

APPENDIX B. INSPECTOR LICENSES

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