Asbestos Survey Report HST Elevators - Construction 2020 12 08.pdf

INSPECTION REPORT

NON-FRIABLE ACM, LEAD-BASED PAINT

AND PCB-CONTAINING LIGHT BALLASTS

DEPARTMENT OF STATE BUILDING

WASHINGTON, D.C.

Draft Revision 2: October 21, 1998

ECC Project No. 98-3623

Prepared For: Ms. Francesca Blythe Blythe and Associates 7801 Norfolk Avenue Bethesda, Maryland 20814

Robert Cienki Industrial Hygienist Signature

Thomas M. Hardy Project Manager Signature

Non-Friable ACM, Lead-Based Paint, Department of State Building PCB Ballast Inspection Report: Revision 2 October 21, 1998

TABLE OF CONTENTS

1.0 Executive Summary

2.0 Authorization and Scope of Investigation

3.0 Records Search

4.0 Lead-Based Paint Investigation

4.1 History of Lead in Paint

4.2 Sampling and Analysis

4.3 Methodology of the Spectrum Analyzer

4.3.1 Description

4.3.2 Operational Concepts

4.3.3 Testing Procedures

4.3.4 Precision and Accuracy

4.3.5 License Requirements for XRF Operation

4.3.6 Substrate Correction

4.4 Testing Results

4.4.1 Phase I Renovation Section 1A (Department of War)

4.4.2 Phase I Renovation Section 1B

4.4.3 Phase I Renovation Section 1C

4.4.4 Southern Half of the Main State building (Phase 2)

4.5 Abatement Options/Costing

5.0 Non-Friable Asbestos-Containing Materials

5.1 Sampling and Analysis

5.2 Testing Results

5.2.1 Section 1A (Department of War)

5.2.2 Sections 1B and 1C

5.2.3 Southern Half of Main State building (Phase 2)

5.3 Estimated Removal Costs

6.0 PCBs in Light Fixture Ballasts

6.1 Background

6.2 Testing Results

6.2.1 Section 1A

6.2.2 Section 1B

6.2.3 Section 1C

6.3 Estimated Disposal Costs

7.0 Limitations

LIST OF TABLES

Table 1 - Laboratory Analytical Results of Paint Chip Samples Table 2 - XRF Sampling Results for Section 1A Table 3 - XRF Sampling Results for Section 1B Table 4 - XRF Sampling Results for Section 1C Table 5 - XRF Sampling Results for Section 2 Table 6 - Asbestos-Containing Material Quantities By Phase Table 7 - List of Asbestos-Containing Materials - Section 1A Table 8 - List of Asbestos-Containing Materials - Section 1B Table 9 - List of Asbestos-Containing Materials - Section 1C Table 10 - Light Fixture Inventory Table 11 - Summary of Light Fixture Ballast Inventory by Ballast Type Table 12 - Results of PCBs in Light Fixture Ballasts - Section 1A Table 13 - Results of PCBs in Light Fixture Ballasts - Section 1B Table 14 - Results of PCBs in Light Fixture Ballasts - Section 1C Table 15 - Results of PCBs in Light Fixture Ballasts - All Sections

LIST OF APPENDICES

Appendix A - Listing of Suites Inspected Appendix B - XRF Field Data, Divided by Section Appendix C - Laboratory Analytical Results of Paint Chip Samples Appendix D - Asbestos Laboratory Licenses and Accreditations

Appendix E - Laboratory Analytical Results of Asbestos Bulk Samples Appendix F - Asbestos-Containing Materials, Divided by Section Appendix G - Light Fixture Ballast Field Data Listing, Divided by Section Appendix H - Photographs of Light Fixture Types Appendix I - Representative Photographs of ACMs at the Main State building

1.0 Executive Summary

Environmental Consultants and Contractors (ECC), Incorporated, was authorized by Ms.

Francesca Blythe of Blythe and Associates to perform a limited inspection for non-friable asbestos-containing materials (ACMs) and lead-based paint in the southern half of the Department of State building, located in Washington, District of Columbia. The intent of this limited inspection was to determine if the types and extents of non-friable ACM and building components covered with lead-based paint are consistent with the results of a previous inspection for non-friable asbestos-containing materials and lead-based paint in the northern half of the building, delineated as Phase 1A, 1B, and 1C and documented in a report prepared by ECC and dated July 1, 1996. The results of the previous inspection are incorporated into this document.

ECC performed this inspection between September 16, and October 2, 1998.

ECC identified vinyl asbestos floor tile and asbestos-containing mastic in most office suites in the building. The tile and mastic cover 262,984 square feet in Section 1A, 117,400 square feet in Section 1B, 171,035 square feet in Section 1C, and nearly all of the office suites in the southern half of the building, estimated to be approximately 700,000 square feet.

Other non-friable ACM identified include mastic on acoustical wall and ceiling tile, pipe and duct mastic, asbestos-impregnated paper on fiberglass duct insulation, and various other mastics.

ECC performed an inspection for lead-based paint using spectrum analyzer (XRF) methodology.

A total of 1,100 assays (XRF readings), including calibrations, were obtained in the study area.

Results of the inspection revealed lead-based paint to be present stair components and stairwell door frames. The previous inspection had identified lead-based paint on plaster walls and ceilings, radiators, millwork (baseboards, chair rails, etc., excluding doors and door casings) throughout Section 1A, stair components and stair walls in Sections 1B, and on stair components in Section 1C.

four XRF tests on walls (1 of 536) and door jambs (3 of 141) were positive for lead-based paint. ECC recommends confirming the XRF result via paint chip sampling.

Architectural components such as baseboards and radiators are classified as Category II abatement waste under RCRA. Abatement of lead-based paint applied to these components may be accomplished by removing and replacing them. If removed, these components should be stored in a secured area while appropriate TCLP analyses are performed to determine if the waste is classified as hazardous or non-hazardous; typically, architectural components are found to be non-hazardous and may be disposed of in a permitted solid waste landfill.

The total area of all plaster walls and ceilings in Section 1A was not determined as part of this investigation, however, the magnitude of this area is considered sufficiently great such that removal of lead-based paint as an abatement option is infeasible. Removal of LBP from small areas of wall and ceiling plaster may be performed by High Efficiency Particulate Air (HEPA) vacuum blasting HEPA sanding, or wet scraping (if effective).

ECC inspected the ballasts in representative, accessible light fixtures to determine the presence or absence of PCBs ballasts. The information gathered by cataloguing the light fixture and ballast types was used to correlate PCB-containing ballasts within light fixtures. ECC's survey documented a total of 10,034 light fixtures in Sections 1A, 1B, and 1C, encompassing 30 types of light fixtures and 42 types of ballasts. ECC inspected 756 light fixtures; the percentage of unlabeled (i.e. assumed PCB-containing) ballasts for each type of fixture was extrapolated in an effort to estimate the total number of ballasts known or assumed to contain PCBs. Based on our observations, 2,313 ballasts (-23%) are considered PCB-containing.

2.0 Authorization and Scope of Investigation

Environmental Consultants and Contractors (ECC), Incorporated, was authorized by the Ms.

Francesca Blythe of Blythe and Associates to perform a limited building inspection for non-friable asbestos-containing materials and lead-based paint in the southern half of the Department of State building, located in Washington, District of Columbia. The intent of this limited inspection was to determine if the types and extents of non-friable ACMs and building components coated with lead-based paint are consistent with the results of a previous inspection for non-friable asbestos-containing materials and lead-based paint in the northern half of the building, delineated as Phase 1A, 1B, and 1C and documented in a report prepared by ECC and dated July 1, 1996.

The State Department Building is located at 2401 C Street, N.W., Washington, D.C.; it is bounded to the north by D Street, to the east by 21st Street, to the northeast by Virginia Avenue, to the south by C Street, and to the west by 23rd Street. The site structure is an eight-story office building with a subgrade garage. The building was constructed in two distinct phases; the War Department building, occupying the northeast corner of the structure, was constructed c. 1941, and the New State Department building, which abuts the southern and western sides of the 1941 building, was constructed c. 1960. The previous inspection included the Phase I Renovation area; the War Department building and the northern portion of the New State Department building. This inspection included the remainder of the New State Department building.

The scope of services for this inspection consisted of the following:

? Testing of as many surfaces in the survey area as possible, with a minimum of 200 tests per day, during a three day period for lead-based paint using XRF methodology;

? Visual examination of as many areas in the survey area as possible during a two day period to determine the order of magnitude of previously identified non-friable asbestos-containing materials.

? Photographing various asbestos-containing materials selected by Mr. David Needham.

The scope of services for the previous inspection consisted of the following:

" Research and review of available information regarding asbestos and lead-based paint abatement performed in the structure through a records search of GSA's Technical Resources Library and available Department of State files;

" Visual examination of the Phase I Renovation area for suspect non-friable asbestos-containing materials, collection and analysis of asbestos bulk samples, and determination of material condition and extent of each identified non-friable asbestos-containing material;

" Visual examination of the Phase I Renovation area for suspect friable asbestos-containing materials which were not sampled during a previous survey, and collection and analysis of asbestos bulk samples;

" Sampling of painted surfaces in the Phase I Renovation area using a portable X-Ray Fluorescence (XRF) analyzer to determine the presence or absence of lead-based paint;

" Collection and laboratory analysis of paint chip samples to determine the presence or absence of lead-based paint;

" Assessment of the conditions of surfaces painted with lead-based paint;

" Visual examination of representative light fixture ballasts to assess the potential for polychlorinated biphenyls (PCB's) in the dielectric fluids;

" Cost estimates for removal of non-friable asbestos-containing materials, lead-based paint, and PCB-containing light ballasts.

A previous asbestos survey had identified the presence of asbestos cement board ("Transite") panels above ceilings in office suites throughout the study area. The locations of these cement board panels have been documented and their quantities delineated in the previous report, and ECC did not sample or delineate this material in our survey.

ECC personnel were escorted through the Department of State building by personnel from the Office of Real Property Management. The escorts documented the dates on which each room or suite was accessed; a copy of the list produced during ECCs 1996 inspection is included in Appendix A. ECC was provided access to the majority of office suites, common areas, and mechanical spaces in Sections 1A, 1B, and 1C of the Phase I Renovation area. Inaccessible areas included: Basement Disintegrator/Incinerator rooms, Basement Transformer Vault, Rooms B447A, B451, B456, B458, B460, B646, B726, B841, B844C, B921A, 1829A (Escalator room), 2442A, 2654, 3437, and 7433, and suites 5433 and 8440.

Information supplied by the Office of Real Property Management indicated that the Disintegrator/Incinerator suite had been recently gutted and remodeled, and would be frozen (i.e.

not impacted) by the proposed renovation project.

3.0 Records Search

As part of our previous investigation, ECC reviewed relevant documents at the GSA's Technical Resources Library to obtain information regarding abatement of asbestos-containing materials and lead-based paint in the Phase I Renovation area of the Department of State building. Mr.

George Dee and Ms. Mary Hitchcock provided assistance in finding pertinent documentation.

Information reviewed consisted primarily of original construction data from the 1930s and 1940s, design and specification data for various building modifications, and scattered information regarding removal of asbestos-containing materials.

According to a site plan prepared by Caballerd Architects, dated December 16, 1988, a modular partition renovation (project number RDC 68219) was performed in office suites 2446, 2484, 2495, and in a portion of suite 2733. These suites are located in Section 1A of the Phase I Renovation area. The renovation included the removal and/or replacement of drywall partitions, metal panel partitions, wood doors and frames, light fixtures, carpet, vinyl or wood base, metal chair rail, and asbestos-containing ceiling plaster. No plaster walls were removed or replaced. Suspect asbestos-containing ceiling plaster was not observed in these spaces. Light fixture ballasts inspected within these suites were labeled NO PCB.

Information documenting asbestos removal projects in the basement and in the seventh floor mechanical rooms were reviewed during the records search. According to a site plan (project number RDC 88069) prepared by GNM Associates, Inc., dated June 28, 1989, asbestos-containing plaster ceilings were removed from portions of basement corridors 6, 7 and 8 in Phase I Renovation Section 1A. Asbestos removal was performed in areas of the sub-basement Mechanical Room B-647 and included removal of piping above metal pan and acoustical ceiling tile, piping eight inches or less in diameter in mechanical room and exposed in corridors, piping larger than eight inches in the mechanical room, insulation on chiller water pump valves and strainers, chillers, air handling units and a condensate tank, insulation on exposed ductwork near the loading dock, ceiling plaster and pipe insulation in the corridor, and ceiling plaster in the elevator lobby.

A site plan prepared by SAIC (project number RDC 68240), dated July 1, 1988, provided information concerning the complete removal of ACM and asbestos-contaminated materials from the western half of the seventh floor mechanical space. This work included decontamination of interior ductwork and equipment, and the removal and replacement of acoustical lining and ductwork in these areas.

4.0 Lead-Based Paint Investigation

4.1 History of Lead in Paint

Lead was a primary ingredient in many types of paint produced in the 1930's and 1940's. The use of lead in paint was lessened in the 1950's, although lead was still utilized in some pigments and as a drying agent. The Consumer Product Safety Commission established a maximum lead content in newly applied paint of 0.5% by dry weight in 1973. The maximum lead content in newly applied paint was lowered to 0.06% by dry weight in 1978.

Information provided by GSA indicated that the Department of War building (Phase I Renovation Section 1A) was constructed in 1941; The New State Department building (including Phase I Renovation Sections 1B and 1C) was constructed in 1960. Based on the construction dates of these buildings, the potential for the presence of lead-based paints is high.

The 1973 amendments to the Lead Based Paint Poisoning Prevention Act (LBPPPA) designated the Department of Housing and Urban Development (HUD) as the main agency in the Federal effort to eliminate the hazard of lead based paint (LBP) in housing. The HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, dated June, 1995, are the current standard for developing sampling and assessment strategies in public and Indian housing. These guidelines were referenced during the course of this investigation; however, ECC's survey for lead-based paint did not adhere to protocols dictating the number of sample areas to be tested as described in this document.

The action level for LBP established in the LBPPPA amendments in the 1987 Housing Act is 0.5% by dry weight when using laboratory testing methodology, such as atomic absorption spectrometry (AAS) or inductively coupled plasma atomic emission spectrometry (ICP-AES).

The action level for LBP established in the LBPPPA amendments in the 1987 Housing Act is a lead content of 1.0 milligrams per square centimeter (mg/cm2) of painted surface as measured by an X-ray fluorescence (XRF) analyzer.

Laboratory testing is considered to be more accurate, although more expensive, than the more common XRF on-site testing devices. The HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing recommends back-up laboratory testing to confirm XRF analysis. A combination of both XRF and laboratory methodologies was utilized in order to maximize efficiency and to confirm accuracy and precision.

4.2 Sampling and Analysis

A spectrum analyzer XRF sampler (versus a direct reading XRF sampler) was employed during the survey to eliminate the need to determine substrate equivalent lead by removing paint to test unpainted areas. Paint samples were collected as needed from component surfaces which tested inconclusive for lead-in-paint as determined by XRF screen and test modes. In screen mode, spectrum analyzer readings between 0.7 mg/cm2 and 1.3 mg/cm2, inclusive, are classified as inconclusive. XRF readings above 1.3 mg/cm2 are considered positive readings, and XRF readings below 0.7 mg/cm2 are considered negative readings.

Paint samples submitted for laboratory analysis were collected in accordance with the procedures outlined in the Industrial Lead Paint Removal Handbook. These procedures state that the total thickness of the paint film should be removed cleanly down to the substrate. The Handbook recommends cutting a square approximately 1 inch on a side through the coating to the substrate while a sampling bag is held or taped beneath it. The entire chip of paint can then be detached from the substrate, taking care to avoid including portions of the substrate itself.

The paint chip samples were submitted to R.J. Lee Group, Incorporated, in Monroeville, Pennsylvania, for analysis by atomic spectroscopic (Flame AA) techniques.

The condition of each painted area sampled was evaluated on a four point scale. Divisions of the scale include good, satisfactory, poor, and unsatisfactory. The surface of paint in good condition is completely intact. Paint in satisfactory condition shows some evidence of wear (e.g. some cracking noticeable) but the paint is adhered to the substrate. Paint in poor condition is characterized by some peeling or chalking. Paint in unsatisfactory condition is characterized by peeling, chipping, cracking, and scaling.

ECC personnel performed the initial lead-based paint screening between January 31 and March 20, 1996. The limited inspection of the remainder of the New State building was performed on September 16, 17, and 29, 1998. Results of the XRF sampling are discussed in Section 4.4. A complete listing of XRF field data collected in each section of the Phase I renovation is included in Appendix B. Copies of the laboratory analytical results of paint chip samples are presented in Appendix C.

4.3 Methodology of the Spectrum Analyzer

4.3.1 Description

During this investigation a portable Metals Analysis Probe (MAP-4) X-Ray Fluorescence (XRF) Spectrum Analyzer, manufactured by Scitec Corporation, was used to test for lead in paint. This device consists of a probe, containing a sealed radioactive source and x-ray scanner detector, and a battery-powered console containing a multi-channel spectrum analyzer with a microprocessor and a digital LCD display.

4.3.2 Operational Concepts

The MAP probe uses a low-level radioactive isotope of Cobalt (Co57) to excite atoms in front of the probe. Excited atoms absorb the radiation energy, causing their electrons to jump to unstable, higher energy shells. Electrons in these unstable, higher energy shells shed their excess energy as x-rays in order to return to more stable lower energy shells. These x-rays have unique characteristics which allow the probe's spectrum analyzer to determine the element from which the x-rays emanate. K-shell and L-shell x-rays are used to determine lead concentrations. The L-shell x-rays are detected from the outer few surface layers of paint, while the K-shell x-rays are detected from all layers of paint down to the substrate. The X-rays are measured in electron volt units which are divided into 256 energy classes, or channels, defined by an upper and lower limit. When the x-rays are analyzed by the multi-channel spectrum analyzer, it produces a spectrum comparing the proportional energy of each channel number. The concentration of lead is determined from the proportion of x-rays within the "channels" characteristic of lead vs. other elements. The spectrum data generated by each test is automatically recorded and stored in the console memory.

As the MAP XRF instrument measures x-ray intensity, the internal software automatically analyzes the spectrum and displays the lead concentration in milligrams per square centimeter (mg/cm2). The microprocessor automatically compensates for substrate and matrix effects. An XRF detector is the only instrument that can be used in-situ to non-destructively measure the concentration of lead in paint. It allows simple, fast screening for detecting lead in paint at or above a user selected action limit, in this case 1.0 mg/cm2.

4.3.3 Testing Procedures

To operate the XRF, the analyzing mode (screen, test, confirm, or unlimited) is selected, the probe is placed against a painted surface, the shutter is opened by turning a key, and measurement begins by squeezing a trigger. Screen, test, and confirm modes each provide a specific precision by testing for a predetermined period. Longer testing periods provide greater precision. Unlimited mode uses a flexible period, testing only until the lead concentration can be determined with sufficient precision to be classified as either above or below the user selected action level, in this case 1.0 mg/cm2.

Unlimited mode was used for all paint tests. Test mode was used to validate the spectrum analyzer calibration.

4.3.4 Precision and Accuracy

The precision and accuracy of the XRF, both element-specific and spectrum analyzer, have been studied by the National Institute of Standards and Technology (NIST). In reports published by NIST (Methods for Measuring Lead Concentrations in Paint Films and Measuring Lead Concentrations in Paint Using a Portable Spectrum Analyzer X-Ray Fluorescence Device) it was concluded that:

1. spot tests when carried out by an experienced analytical chemistry technician can detect the presence of lead in paint films having concentrations in excess of 1 mg/cm2 in approximately 90 percent of test samples;

2. the estimate of the precision of a field measurement procedure using lead-specific portable XRF analyzers for lead concentrations near 1 mg/cm2 is 0.6 mg/cm2 and the estimated systematic error of the procedure is 0.2 mg/cm2; this results in a 95 percent confidence interval of 1.4 mg/cm2;

3. based upon preliminary measurements using the latest version of the spectrum analyzer portable XRF, the 95 percent confidence interval for field measurements is estimated to be

0.5 mg/cm2.

The previously referenced study tested several direct-reading XRF detectors; however, the device used in this study is specifically the Metals Analysis Probe (MAP-4) X-Ray Fluorescence (XRF) Spectrum Analyzer manufactured by the Scitec Corporation. According to published information about the MAP-4 XRF, measurements within 0.075 mg/cm2 are achievable. NIST and HUD Guidelines have established the average precision of the Spectrum Analyzer to be 0.3 mg/cm2.

The MAP XRF is calibrated at the factory using a wide variety of reference standards and substrates. It does not need to be re-calibrated daily; however, the device is initialized daily.

Initialization sets the instrument to take measurements using reference conditions previously programmed into the instrument. The instrument calibration is validated before and after testing, and every four hours, whichever is most frequent.

4.3.5 License Requirements for XRF Operation

Because of the sealed radioactive source in the XRF detector, operators are subject to a general license requirements and the regulations of the U.S. Nuclear Regulatory Commission (USNRC).

During this investigation, the XRF detector was operated only by ECC personnel who have completed an NRC-approved radiation safety training program.

4.3.6 Substrate Correction

Substrate correction is the removal of paint from several areas of each substrate encountered at each project and testing the unpainted substrate to determine the substrate influence on XRF results. XRF analyzers are divided into two classes, spectrum analyzer or direct reading.

Substrate correction is required for all direct reading XRFs and for some spectrum analyzer XRFs, under certain technical conditions.

The EPA has conducted extensive testing of every model of XRF to determine the operational parameters, including determining when substrate correction is required. This information is included in a Performance Characteristic Sheet (PCS) published for every model of XRF.

The instrument used during this inspection, a Scitec Map-4, is classified as a spectrum analyzer.

Based upon the PCS for the Scitec Map-4 (edition 2, effective June 26, 1996), substrate correction is not required when testing is performed in unlimited mode.

4.4 Testing Results

The PCS for the Scitec Map-4 published by the EPA establishes inconclusive ranges for XRF results based upon the operational mode selected (screen, test, confirm, or unlimited). Unlimited mode was used for all testing at the Department of State. The PCS defines the inconclusive range of the Map-4 in unlimited mode to range from 0.91 - 1.19 mg/cm2.

Additionally, the HUD Guidelines divide inconclusive results into high and low ranges, based upon the inconclusive range of the XRF instrument used during the inspection. The Guidelines define a high inconclusive reading to be an XRF reading at or above the midpoint of the inconclusive range; for a Scitec Map-4 operated in unlimited mode a high inconclusive reading would range from 1.05 - 1.19 mg/cm2. ECC expands the high inconclusive range to include all readings greater than or equal to 1.0 mg/cm2, the HUD action level.

4.4.1 Phase I Renovation Section 1A (Department of War)

In Section 1A of the Phase I Renovation area, 1,155 assays (XRF readings) were obtained.

Based on the HUD Guidelines, 12 of the 20 components tested are painted with LBP. These include:

" upper and lower plaster walls in office suites, " radiator covers, " chair rails, " baseboards, " ceilings, " concrete floors, " stairway baseboards, risers, and walls, " plaster walls in corridors, " plaster columns.

The conditions of these painted surfaces varied from satisfactory to good, with the majority of the surfaces in good condition.

The remaining seven components tested resulted in negative XRF readings and are considered free of lead-based paint. These components include:

" door jamb/casings, " interior and exterior door faces, " walls of drywall construction, " ductwork and equipment in the mechanical spaces, " lower corridor walls in the basement, " elevators.

Table 2 provides a detailed summary of the XRF sampling results obtained in the Phase I Renovation Section 1A.

4.4.2 Phase I Renovation Section 1B

A total of 489 assays were collected in the Phase I Renovation Section 1B. Four components are painted with LBP including:

" stairway risers, " stairway baseboards, " stairway walls, " columns.

Paint on these surfaces was in good condition.

The remaining 16 components tested negatively. These include:

" door jamb/casings, " interior and exterior door faces, " upper and lower plaster walls, " walls of drywall construction, " corridor walls, " chair rails, " baseboards, " ceilings, " floors, " mechanical equipment and ductwork in the mechanical spaces, " radiator covers, " elevators.

A detailed summary of the XRF sampling results for Phase I Renovation Section 1B are presented in Table 3.

4.4.3 Phase I Renovation Section 1C

A total of 383 assays were collected in Section 1C of the study area. Two components are considered to be painted with lead-based paint. These include:

" stairway risers, " stairway baseboards.

Paint on these surfaces was in good condition.

The remaining 17 components tested negative for lead-based paint. These components include:

" door jamb/casings, " interior and exterior door faces, " upper and lower plaster walls, " walls of drywall construction, " stairway walls, " corridor walls, " chair rails, " baseboards, " ceilings, " floors, " mechanical equipment and ductwork in the mechanical spaces, " radiator covers, " columns, " elevators.

A detailed summary of the XRF sampling results for the Phase I Renovation Section 1C are presented in Table 4.

4.4.4 Southern Half of the Main State building (Phase 2)

A total of 1100 assays (including 73 calibrations) were collected in the southern half of the Main State building. XRF testing determined that five components, all associated with the stairwells, are covered with lead-based paint including;

" stairwell door frames

" stair baseboards

" stair balusters

" stair rails

" stair stringers

The HUD Guidelines recommend collecting paint chip samples from all components with positive or high inconclusive XRF results if the percentage of positive XRF readings per testing combination is below fifteen percent. These testing combinations and the percentages include;

" door jambs - 3 positive (2.13%), 3 high inconclusive of 141 assays

" walls - 1 positive (0.19%) of 536 assays

A detailed listing of the XRF test results presented by testing combination are presented in Table 5.

4.5 Abatement Options/Costing

In Section 1A, plaster walls and ceilings were found to be coated with lead-based paint; drywall partitions were free of lead-based paint. Walls in stairwells in Section 1B, along with stair risers and baseboards, were also found to be coated with lead-based paint. ECC was not provided with details regarding the scope of the Phase I renovation; the total area of all plaster walls and ceilings in Section 1A and stairwells in Section 1B was not determined as part of this investigation, however, the magnitude of this area is considered sufficiently great such that removal of lead-based paint as an abatement option is considered infeasible.

ECC recommends that the potential for impact to surfaces coated with lead-based paint caused by renovation activities (e.g. removal of wall plaster) be evaluated. Destructive removal of wall and ceiling plaster should be undertaken only after proper removal of lead-based paint;

alternatives to removal of the plaster include enclosure with drywall or encapsulation. If planned renovation activities do not include wide-scale removal of plaster, the LBP may be left in place and included in an Operations and Maintenance program. Removal of small areas of plaster coated with LBP should only be performed after the paint has been removed using High Efficiency Particulate Air (HEPA) vacuum blasting, HEPA sanding, or wet scraping techniques.

These activities should only be performed by trained, licensed personnel, and should be monitored to ensure that airborne lead concentrations do not exceed regulatory limits. The work area should be thoroughly cleaned after completion of the abatement using wet methods and HEPA vacuums.

Architectural components such as baseboards and radiators are classified as Category II abatement waste under the Resource Conservation and Recovery Act (RCRA). Abatement of lead-based paint on these components may be accomplished by removing and replacing them. If removed, these components should be stored in a secured area while they are evaluated via a

Toxicity Characteristic Leaching Procedure (TCLP) analysis, a laboratory analytical procedure used to determine the amount of lead which might leach from the component. Laboratory results for TCLP analyses at or above 5.0 parts per million (ppm) require the component to be classified as hazardous waste; however, TCLP analyses performed on architectural components typically result in lead concentrations below 5.0 ppm, and the components are considered non-hazardous waste and may be disposed of in a permitted solid waste landfill.

Lead-based paint on stair risers and baseboards in stairwells in Sections 1B, 1C, and 2 can be removed using heat gun or chemical techniques (exclusive of paint removal products containing methylene chloride). Note that walls in the stairwell in Section 1B are coated with lead-based paint. The estimated time to complete LBP removal the in each of the New State building stairwells is ten days; the estimated cost to complete LBP removal in each of the New State building stairwells, including preparation, labor, and waste disposal, is $14,000.00.

5.0 Non-Friable Asbestos-Containing Materials

ECC had performed an asbestos inspection for non-friable asbestos-containing materials (including drywall systems) in Sections 1A, 1B, and 1C of the Phase I Renovation area.

Additionally, ECC had inspected the referenced areas for suspect friable materials not identified in a previous inspection. The locations and extents of non-friable asbestos-containing cement board ("Transite") panels installed above ceilings had been documented in a previous survey (not by ECC) and was not repeated.

ECC performed a visual inspection to ascertain the presence of previously identified non-friable ACMs in the southern half of the Main State building. Additionally, ECC collected bulk samples of suspect non-friable ACMs present in large quantities but not previously characterized regarding asbestos content.

5.1 Sampling and Analysis

This survey was performed following protocols outlined in GSA's Environmental Management Technical Guide for Asbestos Inspection and Assessment (E102.03965). These protocols are based on inspection and sampling guidelines established by the United States Environmental Protection Agency (EPA) Asbestos Hazard Emergency Response Act (AHERA) developed to address asbestos hazards in schools. The guidelines include the following:

" Collection of three samples from each type of suspect thermal system insulation in a building including boiler insulation, pipe insulation, tank insulation, and breeching insulation;

" Collection of three samples from suspect surfacing materials such as spray-applied fireproofing, or acoustical treatment of a quantity less than 1,000 square feet, five samples if the quantity is greater than 1,000 square feet but less than 5,000 square feet, and seven samples if the quantity is greater than 5,000 square feet;

" Collection of at least one sample from suspect miscellaneous materials such as vinyl floor tile, acoustical ceiling tile, and drywall system (Note - GSA's Environmental Management Technical Guide for Asbestos Inspection and Assessment requires collection of three samples from suspect miscellaneous materials).

Information provided to ECC indicates that the building was constructed in two sections.

Section 1A (Department of War) was constructed in 1941; the remainder of the building was constructed in 1960. Therefore, for the purposes of this study, Section 1A was considered an independent functional area. Sections 1B and 1C were considered a single functional area, although ECC attempted to sample each of these areas independently. The remainder of the New State building is considered homogeneous with Sections 1B and 1C; sampling in the remainder of the building was limited to confirmatory samples.

ECC representative Robert Cienki (Virginia Asbestos Inspector License #3303-001952, expires 5/31/96) and Thomas Hardy (Virginia Asbestos Inspector License #3303-000475, expires 12/31/96) conducted the previous asbestos inspection in 1996. ECC representative Robert Cienki (Virginia Asbestos Inspector License #3303-001952, expires 5/31/99) conducted this inspection in Sept.-Oct., 1998. During the inspection of all suites, ECC was escorted by State Department employees from the Office of Operations of Real Property Management. Non-friable asbestos containing materials throughout the study area were observed to be in uniformly good condition.

Samples were collected following professional protocols intended to minimize any potential for fiber release. Areas immediately surrounding sample collection points were wet wiped and/or vacuumed upon completion of sampling. Sampled materials susceptible to air erosion, vibration damage, or with exposed friable surfaces due to sampling were sealed with appropriate materials, including but not limited to: duct tape, spray glue, or encapsulant. Since the focus of this investigation was to identify non-friable ACM, most sample locations were not sealed as described above. Sampling equipment was decontaminated following sample collection to minimize the potential for cross-contamination of samples. In all areas it was attempted to sample in inconspicuous areas.

ECC collected a total of 292 bulk samples (287 during the previous inspection). Bulk samples were submitted to R.J. Lee Group, Incorporated, located in Manassas, Virginia, a Virginia-licensed and accredited asbestos laboratory, for analysis by Polarized Light Microscopy with Dispersion Staining, (PLM), Improved Interim Method (Appendix A to Subpart F, 40 CFR 763). Copies of the laboratory licenses and accreditations are included in Appendix D. Copies of the laboratory reports are included in Appendix E.

5.2 Testing Results

All non-friable ACMs identified in the entire Main State building, confirmed ACM by laboratory analysis, are listed below:

Flooring materials:

" 12" x 12" light gray vinyl floor tile (VFT)

" 12" x 12" tan VFT

" 12" x 12" tan VFT w/ brown streaks

" 12" x 12" tan VFT w/ black flecks

" 12" x 12" off-white VFT w/ brown flecks

" 12" x 12" white VFT w/ black flecks

" 12" x 12" white VFT w/ tan flecks

" 12" x 12" blue VFT w/white streaks

" 9" x 9" olive brown VFT w/white streaks

" 9" x 9" gray VFT w/white streaks

" 9" x 9" gray VFT w/black flecks

" 9" x 9" white VFT

" 9" x 9" light brown VFT

" 9" x 9" light green VFT

" 9" x 9" green VFT

" 9" x 9" tan VFT w/white streaks

" floor tile mastic

HVAC System materials:

" tan mastic on seams, black mastic, and red mastic associated with mixing units

" paper wrapping impregnated with black mastic on 12" OD supply ducts

" paper wrapping impregnated with black mastic on 2' x 1' supply ducts

" black mastic on supply ducts

" black mastic on ductwork

Miscellaneous materials:

" mastic on raised Computer Room flooring supports (isolated areas)

" Plastic baseboard mastic

" Acoustical ceiling tile mastic

" Acoustical wall tile mastic

" mastic on cork insulation on chilled water piping

A summary of the material type and quantity of each asbestos-containing material identified is presented in Table 6. A listing of the asbestos-containing materials identified in each section of the Phase I Renovation is presented in Appendix F.

5.2.1 Section 1A (Department of War)

In general, floors in the majority of the office suites in Section 1A are carpeted over asbestos-containing vinyl floor tile (primarily 9" x 9" gray tile with white streaks, although lesser quantities of other varieties of vinyl floor tile were identified) adhered to the floor with asbestos-containing black mastic. Floor coverings in hallways and common areas (cafeteria, restrooms, etc.) were generally found not to contain asbestos. The floors of historic suites are hardwood only; no floor tile or mastic were identified. Vinyl asbestos floor tile and mastic cover approximately 262,984 square feet in Section 1A.

Other non-friable ACM identified included:

" mastic on acoustical ceiling tile/wall tile - tile covers approximately 13,310 square feet;

" vertical band mastic - approximately 200 linear feet;

" mastic on cork insulation - approximately 500 linear feet;

" mastic on vinyl cove baseboard - approximately 12,990 linear feet;

" mastic on raised floors - approximately 3,900 square feet;

A listing of the ACM identified in Section 1A is presented in Table 7. The table is arranged to include room or suite number, room identification, material quantity and material type.

5.2.2 Sections 1B and 1C

The floors in office suites in Sections 1B and 1C are carpeted over asbestos containing olive-brown 9" x 9" vinyl floor tiles adhered with asbestos-containing black mastic. Floor coverings in hallways and common areas (cafeteria, restrooms, etc.) were generally found not to contain asbestos. Vinyl asbestos floor tile and mastic cover approximately 117,400 square feet in Section 1B and approximately 171,035 square feet in Section 1C.

Other non-friable ACM identified included:

" mastic on acoustical ceiling tile/wall tile - tile covers approximately 3,650 square feet in Section 1B; approximately 3,340 square feet in Section 1C;

" mastic on fiberglass ductwork - approximately 5,680 linear feet in Section 1B; approximately 5,985 linear feet in Section 1C;

" mastic on vinyl cove baseboard - approximately 11,170 linear feet in Section 1B; approximately 7,795 linear feet in Section 1C;

" mastic on raised floors - approximately 4,000 square feet in Section 1B;

approximately 775 square feet in Section 1C;

" various other mastics - small quantities in both Section 1B and 1C.

Two ducted air supplies are located above suspended ceilings in corridors in Sections 1B and 1C. These ducts are insulated with fiberglass with a paper wrapping; this paper is impregnated with asbestos-containing black mastic. Feeder lines lead from the supply ducts to mixing boxes located above ceilings in the office areas, and the connections of these feed lines to the mixing boxes are coated with black or red asbestos-containing mastic. Ductwork connecting mixing units to diffusers is generally free of suspect materials, however, in isolated areas, the connection at the mixing unit is sealed with tan asbestos-containing mastic.

A listing of the ACM identified in Section 1B is presented in Table 8; a comparable listing for Section 1C is presented in Table 9.

5.2.3 Southern Half of Main State building (Phase 2)

ECC observed olive-brown 9" vinyl floor tiles adhered with mastic in nearly every office suite inspected in the southern half of the Main State building. This material is visually homogeneous with the olive-brown vinyl floor tile identified as an ACM in Sections 1B and 1C. A bulk sample of this materials collected in Suite 3425 contained 6% chrysotile asbestos in the tile and 3% chrysotile asbestos in the mastic; this sample confirms these materials as asbestos-containing.

ECC observed gray 9" vinyl floor tiles adhered with mastic in Suite 5424. A sample of the gray floor tile contained 6% chrysotile asbestos.

ECC observed mastic-impregnated wrapping paper on supply air ducts above drop ceilings in each corridor of every floor in the southern half of the Main State building. This material is identical to mastic-impregnated wrapping paper observed in Sections 1B and 1C.

ECC observed black and red mastics on supply air mixing units above drop ceilings throughout the southern half of the Main State building. This material is identical to similarly located black and red mastic observed in Sections 1B and 1C.

5.3 Estimated Removal Costs

According to the National Emission Standards for Hazardous Air Pollutants (NESHAPS) regulations, all identified ACMs in the study area are considered Category I non-friable ACM.

As such, these materials must be removed prior to demolition or renovation only if they are in poor condition or if the renovation/demolition activities will cause the material to become friable.

All materials were observed to be in good condition (i.e. non-friable).

The scope of the proposed renovation was not provided to ECC, although it is assumed that all asbestos-containing materials will be removed during the project, and that the asbestos removal activities will be performed over significant areas rather than room by room. Additionally, estimated removal costs for friable ACM and those for non-friable ACM are not additive if both categories of materials are present in an area, since containment costs would not be duplicated and may be lower (e.g. in the case of asbestos floor tile located in an area where friable pipe insulation is present).

ECC estimates the unit cost for removal of vinyl asbestos floor tile and mastic (inclusive of mastic applied to vinyl cove baseboards) to be $2.00 - $2.50 per square foot. Note that unit costs for removal of asbestos floor tile and mastic could vary from approximately $1.00/square foot to $3.00/square foot based on the scope of the removal project. Total estimated removal costs for asbestos floor tile and mastic (including vinyl baseboard) are shown below:

" Section 1A - 262,984 sq. ft. @ $2.50/sq. ft. = $657,460.00

" Section 1B - 117,400 sq. ft. @ $2.50/sq. ft. = $293,500.00

" Section 1C - 171,035 sq. ft. @ $2.50/sq. ft. = $427,588.00

" Section 2 - -700,000 sq. ft. @ 2.50/sq. ft. = $1,750,000.00

Total $3,128,548.00

Estimated unit costs for other non-friable ACM identified and the total estimated removal costs for each section of the Phase I Renovation area are presented below:

Mastic on acoustical wall and ceiling tile - unit cost estimated at $0.75/sq. ft.

" Section 1A - 13,310 sq. ft. @ $0.75/sq. ft. = $9,983.00

" Section 1B - 3,650 sq. ft. @ $0.75/sq. ft. = $2,738.00

" Section 1C - 3,340 sq. ft. @ $0.75/sq. ft. = $2,505.00

Total $15,226.00

Mastic on fiberglass ductwork - unit cost estimated at $1.50/sq. ft.

" Section 1A - none identified = $0.00

" Section 1B - 5,680 lin. ft. @ $1.50/lin. ft. = $8,520.00

" Section 1C - 5,985 lin. ft. @ $1.50/lin. ft. = $8,978.00

" Section 2 - 15,000 lin. ft. @ $1.50/lin. ft.= $22,500.00

Total $39,998.00

Mastic on fiberglass or cork pipe insulation - unit cost estimated at $2.00/sq. ft.

" Section 1A - 700 lin. ft. @ $2.00/lin. ft. = $1,400.00

" Section 1B - none identified = $ 0.00

" Section 1C - none identified = $ 0.00

Total $1,400.00

Mastic on raised flooring

" Section 1A - 3,900 sq. ft. @ $2.50/sq. ft. = $9,750.00

" Section 1B - 4,000 sq. ft. @ $2.50/sq. ft. = $10,000.00

" Section 1C - 775 sq. ft. @ $2.50/sq. ft. = $1,978.00

Total $21,728.00

6.0 PCBs in Light Fixture Ballasts

6.1 Background

Fluorescent light fixture ballasts manufactured prior to 1979 commonly contained polychlorinated biphenyls (PCBs). PCBs range in form from oily liquids to white crystalline solids to hard non-crystalline resins. They were primarily used as coolants and lubricants in transformers, capacitors, and other electrical equipment. In fluorescent fixtures, PCBs are usually found in capacitors within the ballast.

In 1976, The Toxic Substances Control Act (TSCA) banned the production of PCBs in the United States because of mounting evidence that they accumulate in the environment and are a human health hazard. Generally, all ballasts manufactured before 1979 are likely to contain PCBs; the year of manufacture is sometimes found on the ballast or its mounting bracket. For this investigation, any ballast which is not labeled NO PCBs is assumed to contain PCBs.

ECC conducted a survey of fluorescent light fixtures throughout the study area of the Department of State building. ECC examined the ballasts in accessible, representative light fixtures in an attempt to determine the presence or absence of PCBs in the ballast. The information gathered by cataloguing the light fixture and ballast type was used to estimate the number of PCB-containing ballasts in the study area. Tables 10 and 11 summarize the types of light fixtures and ballasts. A complete listing of the PCB field data, including the office suite identification, fixture type, number of fixtures, number of fixtures inspected, ballast labeling, and ballast identification, is presented in Appendix G. Photographs documenting each type of light fixture are presented in Appendix H.

ECC's survey documented a total of 10,034 light fixtures in Sections 1A, 1B, and 1C, encompassing 30 types of light fixtures and 42 types of ballasts. ECC visually inspected 756 light fixtures; the percentage of unlabeled (i.e. assumed PCB-containing) ballasts for each type of fixture was extrapolated in an effort to estimate the total number of ballasts known or assumed to contain PCBs. Based on our observations, 2,313 ballasts (-23%) are considered PCB-containing.

TABLE 10

LIGHT FIXTURE INVENTORY

I.D.

DESCRIPTION

LOCATION

Surface Mounted

1 foot X 4 feet

2 tubes

1 ballast

Old War

2 feet X 4 feet

4 tubes

2 ballasts

Suspended with grill

Flush Mounted

1 foot X 8 feet 2 panels corridors of 1B and

1C

4A

1 panel

1 panel

Bathrooms, Corridors, Offices

Ceiling/Wall Mounted

4 inches X 16 feet

Bathrooms

Wall Mounted

4 inches X 3 feet

1 tube

Stairways, Over Mirrors in Bathrooms

Recessed

3.5 feet X 3.5 feet

Elevator Alcoves

7A

3.5 feet X 3.5 feet

6 tubes

3 ballasts

Offices

Elevator Alcoves

4 feet X 4 feet

D Street entrance

450 fixtures

Offices, Corridors

2 feet X 2 feet

2 curved tubes

21st Street entrance

Flush Mounted with grill

3 feet X 3 feet

8 tubes

4 ballasts

Cafeteria

Suspended with grill

1 foot X 3 feet

Basement Service Elevator Alcove

5-inch diameter two 3" curved tubes

Garage Lobby

Flush Mounted with grill

3 tubes

Suspended

Basement Offices

1.5 feet X 4 feet wood frame

2.5 feet X 4 feet

Surface Mounted (some with wood grill)

Basement

I.D.

DESCRIPTION

LOCATION

Surface Mounted (wooden frame)

1 foot X 0.5 foot

Inaccessible similar to type 10

16 tubes

1 ballast per tube

21st Street entrance

6 tubes

1 ballast/tube

6 inches X 3 feet

Suspended w/ metal grill

6 inches X 1.5 feet

7th Floor Mech.

Recessed with grill

1.5 feet X 3 feet

3 tubes

1st Floor Offices

6.2 Testing Results

6.2.1 Section 1A

A total of 3,967 light fixtures are located in the corridors and office suites in Section 1A; 380 of these fixtures were inspected by ECC personnel. In Section 1A, 1,554 ballasts (-39%) are considered PCB-containing. A summary of the light fixture ballast inventory for Section 1A is presented in Table 12.

Ten different types of light fixtures were observed…