Atch 5 - Basis of Design_HERT 23-4439_Renovate East Wing of Building 401.pdf

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Pa ge

REPORT

Asbestos Hazard Abatement Plan Fort Eustis Building 401 East Wing

Submitted to:

PACE Collaborative Attn: Tim Hahn P.E 1277 Perimeter Pkwy, Virginia Beach, VA, 23454

Submitted by:

WSP USA Inc.

1100 Boulders Parkway, Suite 500, Richmond, Virginia, 23225 +1 (804)-521-1774

31800238.002

31800238.002 i

Distribution List

Electronic Copy- PACE Collaborative ii

Table of Contents

1.0 SCOPE

2.0 PURPOSE

3.0 NOTIFICATION, SUBMITTALS AND WARNING SIGNS

4.0 ABATEMENT PROCEDURES – GENERAL

4.1 Preparation Activities

4.2 Non-Friable ACM Removal

4.2.1 Non-Friable Indoor-Floor Tiles and Mastic

4.2.2 Non-Friable Transite Panelling

4.2.3 Non Friable HVAC Mastic

4.2.4 Non-Friable Fire Doors

5.0 OTHER TRADES

6.0 DECONTAMINATION GENERAL REQUIREMENTS

6.1 Decontamination of Tools and Equipment

6.2 Decontamination of Personnel

7.0 ASBESTOS PERMISSIBLE EXPOSURE LIMITS

8.0 EXPOSURE ASSESSMENT/AIR MONITORING PLAN

8.1 Background Sampling Prior to Asbestos Work

8.2 Area Sampling Prior to Asbestos Work

8.3 Personal Sampling During Asbestos Work

8.4 Final Clearance Procedures and Sampling

9.0 RESPIRATORY PROTECTION

10.0 TRAINING

11.0 MEDICAL SURVEILLANCE

12.0 FIRE AND EMERGENCY MEDICAL RESPONSE

13.0 WASTE STORAGE AND DISPOSAL

TABLES

Table 1: Identified Asbestos Containing Materials at the Site

Table 2: General Project Requirements iii

APPENDICES

APPENDIX A

Selected CIH Credentials

APPENDIX B

Figures 1-4

APPENDIX C

Hazardous Materials Survey

1.0 SCOPE

This Asbestos Hazard Abatement Plan (AHAP) describes the work practices and procedures to be used for the removal of non friable asbestos containing material (ACM) from Building 401 East Wing (site), located at 401 Victory Blvd, Newport News, VA 23604. The asbestos abatement work includes the removal of 9” x 9” floor tile and associated mastic, Heating, Venting and Air Conditioning (HVAC) mastic, Transite panels and fire insulated doors.

The prime contractor conducting all work related to this abatement should a licensed asbestos abatement contracting company by the Virginia Department of Professional and Occupational Regulation (DPOR) whose employees are certified and/or trained in asbestos removal practices and procedures.

Based on the HAZMAT report attached at the end of this abatement plan, the following materials and areas have been identified for abatement work at the site.

Table 1: Identified Asbestos Containing Materials at the Site

WORK

AREA NO.

SAMPLE NUMBER HSG # ASBESTOS CONTAINING

MATERIAL DESCRIPTION

OSHA WORK

OPERATION

1 103123-01-04 A/B/C 4 Black 9” x 9” floor tile and mastic observed under carpet, floor 2- room 205

Class II

2 103123-01-06 A/B/C 6 Tan 9” x 9” floor tile and mastic observed under carpet, floor 2- room 215

Class II

3 103123-01-08 A/B 8 White/Yellow mastic on HVAC junctions, throughout site

Class II

4 103123-01-11 A/B/C/D 11 Tan 9” x 9” floor tile and mastic observed under carpet, floor 1- hallway and rooms 103, 109A, 109B, 110, 113, 114 and 116

Class II

5 Presumed ACM 13 Transite panels observed throughout the hallways and several offices

Class II

6 Presumed ACM 14 Fire door insulation, at stairwell

Class II

The Work Areas are subject to change based on progress of the abatement. For more information on the above noted materials, refer to Table 1- Asbestos Homogenous Sample Group Information from the Hazardous Materials Survey attached at the end of this plan.

2.0 PURPOSE

To provide for the safe handling and disposal of ACM, an AHAP is submitted to establish relevant practices and procedures which will ensure worker and public safety. This plan establishes asbestos abatement management procedures, work practices, air monitoring requirements and general industrial hygiene concepts specifically designed to comply with all applicable federal and local regulations.

The following regulations/compliance guidelines are incorporated by reference:

VIRGINIA DEPARTMENT OF LABOR & INDUSTRTY (DOLI)

Regulations to control the handling of asbestos through the enforcement of the Virginia Occupational Safety and Health Regulations (VOSH), Environmental Protection Agency (EPA) Asbestos National Emission Standards for Hazardous Air Pollutants (Asbestos NESHAP), and Asbestos Notification regulations in the Virginia Labor laws.

Virginia Permit application and notification for asbestos removal and Demolition

U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA)

EPA 340/1 90 018 (1990) Asbestos/NESHAP Regulated Asbestos Containing Materials Guidance

Code of Virginia Title 36 § 36-99

NATIONAL EMISSION STANDARDS FOR HAZARDOUS POLLUTANTS (NESHAP)

NESHAP 40.1 Virginia Asbestos NESHAP Act

NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH (NIOSH)

NIOSH 94 113 (1994; 4th Ed) NIOSH Manual of Analytical Methods

AMERICAN NATIONAL STANDARDS INSTITUTE (ANSI)

ANSI Z88.2 (1992) Respiratory Protection

ANSI Z9.2 (2001) Fundamentals Governing the Design and Operation of Local Exhaust Ventilation Systems

U.S. ARMY CORPS OF ENGINEERS (USACE)

EM 385 1 1 (2008) Safety and Health Requirements

EP 1110 1 11 (1992; R 1997) Asbestos Abatement Guideline Detail Sheets

U.S NAVAL FACILITIES ENGINEERING COMMAND (NAVFAC)

ND OPNAVINST 5100.23 (Rev G) Navy Occupational Safety and Health (NAVOSH) Program Manual

U.S. NATIONAL ARCHIVES AND RECORDS ADMINISTRATION (NARA)

29 CFR 1910.51 Sanitation

29 CFR 1910.59 Hazard Communication

29 CFR 1926.103 Respiratory Protection

29 CFR 1926.200 Accident Prevention Signs and Tags

29 CFR 1926.1101 Asbestos

40 CFR 61 National Emission Standards for Hazardous Air Pollutants

40 CFR 763 Asbestos

42 CFR 84 Approval of Respiratory Protective Devices

3.0 NOTIFICATION, SUBMITTALS AND WARNING SIGNS

The contractor will provide a courtesy notification to the Virginia DOLI their intended activities at least twenty

(20) calendar days prior to the start of work as required for non friable asbestos. The Virginia DOLI permit application and notification for asbestos removal and demolition form combines the requirements of the NESHAP 40 CFR subpart M, and the Virginia DOLI regulation concerning licensed asbestos contractor notification, asbestos project permits and permit fees (16VAC25-20).

Additionally, a selected designated competent person, supervisor/worker training certifications; medical examinations; respirator fit tests, and manufacturer’s catalogue data for abatement equipment will be included in the submittal package accompanying this plan.

During work, the contractor shall have the following documents available on site:

A copy of this AHAP;

Respiratory Protection Program;

Air monitoring and inspection reports;

Activity Hazard Analysis (AHA) for abatement related task;

Emergency phone numbers (posted);

Contract specs for asbestos abatement;

Entry/Exit Logs

Inventory of regulated materials and their locations; and

Disposal certificates (if available)

The regulated areas will be isolated from other occupied areas of the work site not included in the removal effort.

This will be accomplished by erecting barriers, barrier tape, or installing other barricades that limit access to the regulated area. Respirators will be worn during all ACM removal. A competent person whose responsibilities are described in the next section will supervise any work conducted in the regulated area.

Asbestos danger signs will be posted at all entrances to regulated areas in accordance with 29 CFR 1910.145 (d)(4), and 29 CFR 1926.1101. Signs will be posted at least 10 feet before entry to the regulated area.

The danger signs will bear the following information:

Waste containers and/or bags will be labelled with the following information:

No other trades will be allowed in the regulated area during the removal. No one will be permitted in the regulated area unless having received required training previously and have been medically cleared to wear suitable PPE.

4.0 ABATEMENT PROCEDURES – GENERAL

The removal of ACM will be performed in accordance with project specifications, 29 CFR 1926.1101 and EP 1110 1 11, USACE Asbestos Abatement Guideline Detail Sheets.

No unacceptable practices such as high speed abrasive disk saws, use of compressed air to remove asbestos, dry sweeping/cleaning, or employee rotationwill be permitted. Asbestos abatement procedures will be performed using wet methods, as needed. Critical barriers will be used to isolate the asbestos work regulated area.

The Contractor will always have a Competent Person (CP) whom is licensed by Virginia DPOR as Asbestos Supervisor on site to supervise the abatement work. Their duties will include supervision of abatement workers performing Class II work. The CP is responsible for designating the regulated area, setting up entry and exit procedures (maintaining an entry/exit log), ensuring regulated area integrity, supervising the use of personal protective equipment and decontamination procedures, and inspecting the regulated area on a basis sufficient to determine if conditions have changed. The site must have passed an appropriate visual inspection and clean air certification before release to other trades.

Additionally, the CP will arrange to have respirators assigned to individual workers for their exclusive use.

Respirators will conform to 29 CFR 1926.1101. Respirators will be collected, cleaned, and disinfected daily after use and will be stored in a convenient, clean, and sanitary location. A written respiratory protection program, along with up-to-date respirator fit test certificates for all workers using respiratory protection on the job (according to 29 CFR 1910.134, ANSI Z88.2, .29 CFR 1926.62, 29 CFR 1926.1101) will be present at the work site.

The CP is responsible for providing for instruction to each employee regarding the potential hazards of asbestos, safety and health precautions, and the use of respirators.

4.1 Preparation Activities

Electrical circuits in the regulated area will be locked out/tagged out by the Contractor in accordance with 29 CFR 1910.147 prior to start of work. Any temporary power required for lighting, local exhaust equipment, vacuums, portable hand tools, and air monitoring equipment will be equipped with ground fault circuit interrupters (GFCIs).

For interior works, the HVAC system supplying the work area shall be locked out/tagged out and isolated to prevent entrainment of asbestos dust throughout the building. All openings including windows, doors, HVAC registers/vents, and electrical outlets inside the work area shall be covered and sealed with two layers of 6 mil polyethylene and duct tape (if the opening is small enough, it can be covered by two layers of duct tape). The first layer shall be left in place until the area has passed the final visual inspection and clearance air monitoring.

All movable objects shall be vacuumed with a HEPA vacuum, cleaned with amended water and removed from the work area. Any movable objects which cannot be adequately cleaned prior to removal shall be disposed of as asbestos containing waste. Immovable (stationary) objects in the work area shall be cleaned and covered with 2 layers of 6 mil polyethylene sheeting and sealed with duct tape.

Table 2: General Project Requirements

ITEM REQUIREMENT

RESPIRATORY PROTECTION ½ MASK, NEGATIVE PRESSURE, DUAL HEPA CARTRIDGE

PROTECTIVE CLOTHING DISPOSABLE, SPUN-BONDED POLYETHYLENE SUIT

CONTAINMENT BARRIERS ENTRY “Z-FLAP”, LAY DOWN PLASTIC AT REMOVAL SITE

WASTE PACKAGING CLEAR LABELLED 6-MIL BAGS AND/OR CUSTOM “BURRITO” WRAPPING

DECONTAMINATION UNIT CHANGE OUT AREA

NEGATIVE PRESSURE AIR YES

4.2 Non-Friable ACM Removal

All non friable ACM will be removed as OSHA Class II asbestos work operations and the following.

4.2.1 Non-Friable Indoor-Floor Tiles and Mastic

The work area shall first be secured through use of barrier tape and signs placed at the entrance to the work areas. Critical barriers shall be placed over all openings to the regulated area to ensure that airborne asbestos does not migrate from the regulated area.

A change area or single chamber decontamination unit at the entrance/exit to the work area will be established for donning/doffing protective clothing and equipment. Workers will don/doff personal protective equipment in a one-stage change unit.

Workers within the regulated area shall always wear PPE , including the following:

Full body disposal coveralls;

Steel toe rubber boots;

Half face piece air purifying respirator w/ HEPA filter cartridges;

Safety goggles;

Rubber work gloves (cloth work gloves may be worn inside); and

Hard hats.

All floor tile and associated mastic ACM will be wet with amended water solution and removed intact as feasible.

Mastic will be manually scraped and chemically stripped to the extent feasible. Flooring or its backing shall not be sanded. Mechanical chipping is prohibited unless performed in a negative pressure enclosure. All scraping of residual adhesive and/or backing shall be performed using wet methods. Vacuums equipped with HEPA filter, disposable dust bag, and metal floor tool (no brush) shall be used to clean floors.

ACM, including any loose or broken pieces, will be immediately placed in a 6-mil labelled bag. Waste will be temporarily stored on site in a designated storage area. The storage area will be posted as a regulated area and kept locked at the end of each work shift.

All windows and exterior entry doors will be sealed with polyethylene sheathing critical barriers. Floor near the work area will be misted with amended water to prevent entrainment of dust that might compromise air sampling.

A plastic drop is placed beneath the job. Mastic remover may be applied to any areas with residual adhesive or mastic.

Upon exiting the work area, workers shall vacuum off clothing and respirator face-piece in the change area, remove coverall in a peel down fashion and remove respirators. Respirators will be cleaned and stored in accordance with the respiratory protection program. Drop cloths (polyethylene sheeting), disposable coveralls, cloth inner gloves, wet wipes and used respirator filters shall be disposed of as asbestos waste.

4.2.2 Non-Friable Transite Paneling

Transite panels work area will be prepared using the same prep work area presented in Section 4.2.1.

All Transite panels will be removed from the walls in an intact state. A later of 6-mil poly shall be placed on the floor where the panel is going to be removed as a precautionary measure in case of breakage it can be wrapped immediately. Amended water shall be available close to the removal area to mist the panel in case of rupture.

cutting, machinal breaking or destruction of the transite is permitted. Upon removal, the transite will be double wrapped in polyethylene sheathing, labelled as asbestos containing materials, and placed into the temporary storage on site in the designated area. The storage area will be posted as a regulated area and kept locked at the end of each work shift. All windows and exterior entry doors will be sealed with polyethylene sheathing “critical barriers”. A plastic drop is placed beneath the job.

Upon exiting the work area, workers shall vacuum off clothing and respirator face-piece in the change area, remove coverall in a peel down fashion and remove respirators. Respirators will be cleaned and stored in accordance with the respiratory protection program. Drop cloths (polyethylene sheeting), disposable coveralls, cloth inner gloves, wet wipes and used respirator filters shall be disposed of as asbestos waste.

4.2.3 Non Friable HVAC Mastic

HVAC mastic work area will be prepared using the same prep work area presented in Section 4.2.1 and 4.2.2.

All HVAC mastic will be removed in an intact state. The mastic will be removed by cutting with a utility knife around the ACM directly into the aluminium jacketing of the HVAC lining. Direct cutting and grinding on the asbestos containing mastic is not permitted. All cutting of the jacketing shall be performed using wet methods.

Vacuums equipped with HEPA filter, disposable dust bag, and metal floor tool (no brush) shall be used to clean work areas. All windows and exterior entry doors will be sealed with polyethylene sheathing “critical barriers”. A plastic drop is placed beneath the job.

Upon removal all ACM will be placed into polyethene bags, labelled as asbestos containing materials and placed into the temporary storage on site in the designated area. The storage area will be posted as a regulated area and kept locked at the end of each work shift.

Upon exiting the work area, workers shall vacuum off clothing and respirator face-piece in the change area, remove coverall in a peel down fashion and remove respirators. Respirators will be cleaned and stored in accordance with the respiratory protection program. Drop cloths (polyethylene sheeting), disposable coveralls, cloth inner gloves, wet wipes and used respirator filters shall be disposed of as asbestos waste.

4.2.4 Non-Friable Fire Doors

The fire doors work area will be prepared using the same prep work area presented in Section 4.2.1, 4.2.2 and 4.2.3.

All Fire doors will be removed from the door frames in an intact state. No cutting, machinal breaking or destruction of the fire doors are permitted. Upon removal, the doors will be double wrapped in polyethylene sheathing, labelled as asbestos containing materials, and placed into the temporary storage on site in the designated area.

The storage area will be posted as a regulated area and kept locked at the end of each work shift.

Upon exiting the work area, workers shall vacuum off clothing and respirator face-piece in the change area, remove coverall in a peel down fashion and remove respirators. Respirators will be cleaned and stored in accordance with the respiratory protection program. Drop cloths (polyethylene sheeting), disposable coveralls, cloth inner gloves, wet wipes and used respirator filters shall be disposed of as asbestos waste.

5.0 OTHER TRADES

Other trades shall be notified of the type of work and hazards involved and advised that the area is closed to them until notified by the Asbestos Project Designer or Project Monitor representatives that the area is safe for entry.

Only trained qualified personnel shall be permitted entry to the area. Site will be released to other trades only after visual inspections and certification of clearance air sampling by the project designer or CIH designated representative.

6.0 DECONTAMINATION GENERAL REQUIREMENTS

Work practices and procedures such as wet methods and local exhaust with HEPA filtration may help to minimize the contamination of tools, equipment and personnel and maintain surfaces of the asbestos controlled areas free of particulates. However, before leaving the regulated area, all tools, equipment and personnel will undergo decontamination as follows.

6.1 Decontamination of Tools and Equipment

Tools and equipment shall be decontaminated using a HEPA filtered vacuum or and wet wiping with amended water and disposable rags. Rags will be disposed of as asbestos-contaminated waste.

Rubber boots and other reusable protective equipment such as gloves shall be rinsed, dried and placed in impermeable bags prior to leaving the work area. All items shall be inspected by the project designer or CIH designated representative before being transported out of the regulated area.

6.2 Decontamination of Personnel

On exiting a regulated area where non friable asbestos is being removed (Class II Asbestos Work), workers shall vacuum off clothing and respirator face piece while standing on a drop cloth in the changing area or single chamber decontamination unit.

Upon exiting the work area, workers shall vacuum off clothing and respirator face piece in the change area, remove coverall in a peel down fashion and remove respirators. Respirators will be cleaned and stored in accordance with the respiratory protection program. Drop cloths (polyethylene sheeting), disposable coveralls, cloth inner gloves, wet wipes and used respirator filters shall be disposed of as asbestos waste.

7.0 ASBESTOS PERMISSIBLE EXPOSURE LIMITS

The OSHA Permissible Exposure Limit (PEL) is established as airborne concentration of asbestos more than

0.1 fibre per cubic centimetre (f/cc) of air as an eight (8) hour time weighted average. Work will stop immediately if concentrations equal or exceed 0.1 f/cc outside of a regulated area.

In addition, OSHA has established an Excursion Limit which is airborne concentration of asbestos more than

1.0 fibre per cubic centimetre (f/cc) of air as averaged over a sampling period of thirty (30) minutes.

8.0 EXPOSURE ASSESSMENT/AIR MONITORING PLAN

The project designer or project monitor shall oversee air monitoring procedures with daily air monitoring performed by the air sampling competent technician under the direction of the project designer or project monitor. All sampling will be in accordance with procedures outlined in 29CFR 1926.1101, NIOSH method 7400, and project specifications.

Sampling results will be submitted to the client or affected employees within 10 working days, signed by the testing laboratory employee performing air sampling, the employee that analysed the sample, and the project designer or project monitor.

8.1 Background Sampling Prior to Asbestos Work

Before demolition operations begin, an area air sample will be collected to establish a baseline or “background” of the work areas. This is commonly conducted one day prior to the masking and sealing operations for each removal site.

8.2 Area Sampling Prior to Asbestos Work

Area samples will be used to determine if work methods are adequate for preventing significant airborne fibre releases and for determining ambient fibre concentrations in the regulated area.

Area (environmental) samples will be conducted at a minimum in each regulated area for each day of removal (running from the start to the end of work shift) and final cleaning activities as follows:

For Class II Indoor Work Operations per work area:

One at entrance to the work area (or single chamber deacon if used)

One inside the regulated area

If sampling outside the regulated area shows airborne fibre levels exceeding background concentrations or

0.01 f/cc, whichever is greater, the project designer or project monitor will stop work immediately and notify the client.

8.3 Personal Sampling During Asbestos Work

Daily personal samples will be collected to establish objective data for the assessment of worker exposure during representative work operations. For each abatement area, at least 10% of the work force will be monitored per day of demolition activities. The samples will be running each day of actual removal work or final cleaning from start to finish of workday.

The worker having the greatest potential exposure to airborne asbestos fibres will be selected for personal sampling. The Contractor's workers will not be exposed to an airborne fibre concentration more than 1.0 fibre per cubic centimetre, as averaged over a sampling period of 30 minutes.

Should a personal excursion concentration of 1.0 fibre per cubic centimetre expressed as a 30 minute sample occur inside a regulated work area, the Contractor shall stop work immediately, notify the client, and implement additional engineering controls and work practice controls to reduce airborne fibre levels below prescribed limits in the work area. Work shall not restart until authorized by the client.

8.4 Final Clearance Procedures and Sampling

After final clean-up and the asbestos control area is dry but prior to clearance sampling, the project designer or CIH designated representative will perform a visual inspection to ensure that the asbestos control and work area is free of any accumulations of dirt, dust, or debris. A written report signed and dated by a Virginia accredited asbestos project monitor will be prepared to document that the asbestos control area is free of dust, dirt, and debris and all waste has been removed.

At least five final clearance air samples will be collected per work area, upon completion. The asbestos fibre counts from these sample shall be less than 0.01 fibres per cubic centimetre or be not greater than the background, whichever is greater. The inside area samples collected daily during abatement may be used as clearance provided concentrations were maintained at less than < 0.01 throughout the abatement.

Should any of the final samples indicate a higher value, the Contractor shall take appropriate actions to re clean the area and shall repeat the sampling and lab analysis at the Contractor's expense.

8.5 Testing Laboratory

All samples collected on site will be analysed by Eurofins Analytical LLC (Eurofins), located at 10329 Stony Run Lane, Ashland, Virginia 23005. Eurofins is an AIHA accredited laboratory, laboratory ID LAP-100531.

The phone number is (804)-365-3000.

9.0 RESPIRATORY PROTECTION

The contractor shall have available on site a written respiratory protection program, current respirator fit test certificates, and medical clearance records for respirator use for all workers in accordance with 29CFR 1910.134 and 29CFR 1926.1101.

All workers will don the appropriate respirators and personal protective equipment (PPE) as detailed in previous section prior to entering regulated areas and during all abatement activities. Half mask respirators equipped with HEPA (P100) filters are adequate protection for Class II (non friable) work. Respiratory protection may be upgraded/downgraded based on the results of the exposure assessment in accordance with 29 CFR 1926.1101 and a determination by the designated CP. Respirators will be selected from among those approved as being acceptable for protection by the National Institute for Occupational Safety and Health (NIOSH) under the provisions of 42 CFR Part 84.

10.0 TRAINING

The abatement supervisor shall be trained in accordance with United States Environmental Protection Agency (USEPA) Asbestos Hazard Emergency Response Act (AHERA) training criteria and have passed the Contractor/Supervisor course as specified in 40CFR Part 763, Subpart E, and shall be licensed by the Virginia

DPOR.

At a minimum, workers shall be trained in accordance with United States Environmental Protection Agency (USEPA) Asbestos Hazard Emergency Response Act (AHERA) training criteria and have passed the Worker course as specified in 40CFR Part 763, Subpart E and shall be licensed by the Virginia DPOR

11.0 MEDICAL SURVEILLANCE

All employees involved i n asbestos abatement activities will be provided with medical examinations by a licensed physician in accordance with 29CFR 1926.1101(m). All workers have medical clearance from a licensed physician to wear respirators for this type of work. Medical exam are required on an annual basis.

Exposure records will be maintained for the length of employment plus 30 years.

12.0 FIRE AND EMERGENCY MEDICAL RESPONSE

The contractor will be responsible for implementation of this accident prevention plan and all on-site personnel will be accountable for reading, understanding, and following the guidelines contained herein.

The inventory list of hazardous materials and their locations will also be posted at the jobsite in accordance with the Hazard Communication Program. The CP or their designate will be responsible for maintaining a clean job site, free from hazards and providing safe access and egress from the regulated area. Emergency telephone numbers will be posted for the fire department, ambulance service, and the nearest emergency medical clinic/hospital.

The fastest route/location map to the clinic/hospital, along with the emergency telephone numbers will be prominently posted in the regulated area. Site personnel will be trained in emergency procedures and the availability of emergency assistance during the personnel training session. The CP or their designate will be the lead person in all medical emergencies.

A safety meeting will be conducted before the Monday morning shift to discuss pertinent site safety topics. A daily huddle for all personnel will be conducted daily. If personnel have illnesses or injuries such as upper respiratory infections that would limit their ability to wear their PPE properly, they must notify the Superintendent at the beginning of this meeting.

The CP or their designate and the Project Manager will ensure compliance with the provisions of the Accident Prevention Program. Personnel will report injuries no matter how minor in any area of contamination to the Superintendent as soon as possible. Should an accident occur, the Project Manager or designate will immediately notify the CP, complete an accident report, and investigate the cause. Any recommended hazard control measures must be discussed with the Supervisor and meet their approval, before implementation. Any chemical exposures or occupational injuries and illnesses will also be reported to the CP. The contractor will maintain records of all site accidents and first aid treatments. Additionally, documentation of recordable workplace injuries and illnesses are routinely maintained at the Contractor’s office for at least five years as required by OSHA. The contractor shall have at least one 10 lb. type ABC fire extinguishers available in each regulated area. At least two employees on each work shift shall have a current First Aid and CPR certificate.

A fully stocked first aid kit shall be available during work.

13.0 WASTE STORAGE AND DISPOSAL

At the end of each shift, workers will collect asbestos waste, debris, bags, containers, equipment, and asbestos-contaminated clothing, and secure it in sealed, leak-tight, 6-mil labeled, polyethylene plastic bags or custom-size wrapping as needed, while still wet. Proper labeling includes the waste generator name, site address, and manifest document number at a minimum.

Asbestos waste will be stored in a locked and secured space until mobilized for transportation and disposal.

The waste will be held by the selected contractor until it is transported by a registered hazardous waste transporter and disposed of in an asbestos-accepted landfill.

The selected contractor will assume responsibility to document, transport, and dispose of all asbestos-containing waste. Proper disposal documentation shall be returned by the contractor to the facility owner at the conclusion of the Project.

Signature Page

WSP USA Inc.

Adelmarie Bones, MSPH, CIH, CSP Senior Industrial Hygienist, Asbestos Viginia Asbestos Project Designer 3305001429

Bryan Fitt Environmental Engineer, Asbestos Inspector

APPENDIX A

Credentials

12/18/23, 9:15 AM License Lookup: License Search Results https://dporweb.dpor.virginia.gov/LicenseLookup/LicenseDetail 1/1

DPOR License Lookup License Number 3305001429

License Details Name BONES, ADELMARIE

License Number 3305001429 License Description Asbestos Project Designer License

Rank Asbestos Project Designer Address TAMPA, FL 33607

Initial Certification Date 2023-11-06 Expiration Date 2024-11-30

The data located on this website are not the public records of the Department of Professional and Occupational Regulation (DPOR). All public records are physically located at DPOR's Public Records Section: 9960 Mayland Drive, Suite 400, Richmond, VA 23233. While DPOR works to ensure the accuracy of the data provided online, the data available on these pages are updated routinely but may not be up to date at all times (due to document processing delays, technical maintenance, etc.).

DPOR assumes no liability for any errors, omissions, or inaccuracies in the information provided or for any reliance on data provided online. While DPOR has attempted to ensure that the data contained herein are accurate and reflect the status of its regulants, DPOR makes no warranties, expressed or implied, concerning the accuracy, completeness, reliability, or suitability of this data. If discrepancies or errors are discovered, please inform DPOR so that appropriate action may be taken.

DPOR License Lookup build 1,467 (built 2023-02-27 11:28:50).

202 31800238.002

APPENDIX B

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APPENDIX C

Hazardous Materials Survey

REPORT

HAZARDOUS MATERIALS SURVEY

Fort Eustis Building 401 East Wing

Submitted to:

PACE Collaborative Attn: Tim Hahn P.E 1277 Perimeter Pkwy, Virginia Beach, VA, 23454

Submitted by:

WSP USA Inc.

1100 Boulders Parkway, Suite 503

Richmond, VA

+1 804-521-1774

31800238.002

November 2023

November 2023 31800238.002 ii

Table of Contents

1.0 INTRODUCTION

1.1 Facility Description

1.2 Scope of Services

1.3 Applicable Federal, State and Local Regulations and Notices

2.0 HAZMAT SURVEY METHODOLOGY

2.1 Asbestos Survey Sample Collection and Methodology

2.1.1 Asbestos NESHAP Regulations and Guidelines

2.2 Paint Sampling Methodology

2.3 Mold Sampling Methodology

3.0 RESULTS SUMMARY AND RECOMMENDATIONS

3.1 Asbestos Results and Discussion

3.2 Lead Paint Sampling Results and Discussion

3.3 Mold Sampling Results and Discussion

4.0 RECOMMENDATIONS

4.1 Asbestos

4.2 Lead

4.3 Mold

5.0 LIMITATIONS OF REPORT

APPENDICES

APPENDIX A

Table 1 - Asbestos Homogeneous Sample Group Information

APPENDIX B

Table 2 - Lead Paint Sampling Information

APPENDIX C

Table 3 - Mold Sampling Information

APPENDIX D

Figures 1 - 7

APPENDIX E

Laboratory Data and Qualification Certificates iii

Note Page:

1.0 INTRODUCTION

WSP Inc. USA was retained by Pace Collaborative (Pace) to conduct a Hazardous Materials Survey (HAZMAT) for the east wing of building located at 401 Victory Blvd, Newport News, VA 23604. This report summarizes the information obtained during a site visit from October 31st to November 2nd, 2023, and is intended to provide a factual account of the project findings, as well as reference information for future abatement, decommissioning, and demolition contractors, as needed. Therefore, the presentation of the data has been formatted accordingly.

The purpose of the hazardous material survey was to identify the presence of accessible asbestos containing materials (ACMs), lead containing materials (LBPs), and mold in accordance with the requirements stipulated in United States Air Force Manual 32-7002 Environmental Compliance and Pollution. This survey was conducted in accordance with a pre-demolition and renovation asbestos survey requirements as set by the United States Environmental Protection Agency (USEPA) National Emissions Standards for Hazardous Air Pollutants (NESHAP) requirements. Bryan Fitt of WSP conducted the field portion of the survey. Mr. Fitt is trained in accordance with USEPA asbestos regulations and is an accredited Virginia Asbestos Inspector (No. 3303004571); a copy of his license is provided in Appendix E.

1.1 Facility Description

The 401 building (site) is located on Victory Boulevard at the Fort Eustis Army base in Newport News, Virginia. The site is comprised of a North, West and East wing, which is occupied with offices, conference rooms, and other related uses. The effort of this HAZMAT survey was exclusive to the first and second floor interior of the East wing.

Building 401 was constructed in the 1960’s and has undergone multiple interior renovations, including in the past 15 years.

1.2 Scope of Services

The objective of the HAZMAT survey was to identify and generally categorize regulated materials currently present within the office building. This work included conducting a visual survey of the building followed by sampling and analysis, as necessary, to determine preliminary waste classifications and/or verify chemical content of specific materials identified during the work. This information can be used for the following purposes:

In the event of future demolition activities, as a record of materials that must be removed and/or properly managed in accordance with local, state, and/or federal regulations;

To determine where follow-up sampling and analysis may be necessary to confirm regulated materials and/or future waste disposal classifications.

1.3 Applicable Federal, State and Local Regulations and Notices In the event that the building will be demolished, or disturbances/maintenance of certain materials are necessary, then the typical federal and state regulations governing management and disposal of waste materials may apply, such as:

Applicable federal and state Occupational Safety and Health regulations

Title 40, Code of Federal Regulations, Part 261 - Identification and Listing of Hazardous Waste

Title 40, Code of Federal Regulations, Part 262 - Standards Applicable to Generators of Hazardous Waste

Title 40, Code of Federal Regulations, Part 264 - Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities

Title 40, Code of Federal Regulations, Part 265 - Interim Status Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities

Title 49, Code of Federal Regulations, Parts 100-199 - Transportation of Hazardous Materials

Title 40, Code of Federal Regulations, Part 268 - Land Disposal Restrictions

Code of Virginia title 54.1- Chapter 5 Asbestos, Lead, and Home Inspection Contractors and Workers

National Emissions Standards for Hazardous Air Pollutants (NESHAP)

United States Air Force Instruction 32-1023 Designing and Constructing Military Construction Projects

United States Air Force Manual 32-7002 Environmental Compliance and Pollution Prevention

40 CFR Part 61 (NESHAP), Subpart M - National Emission Standards for Asbestos, Section 61.145 – Standard for Demolition and Renovation (40 CFR Part 61, Subpart M)

, paint, solvent, etc.)

2.0 HAZMAT SURVEY METHODOLOGY

WSP performed the field work of the survey from October 31st through November 2nd, 2023. Initially, a visual survey was performed for inventory and quantification purposes. Based on the results of the visual survey and professional experience, WSP executed a sampling and analysis program designed to determine if certain materials may require special handling and management during future decommissioning or demolition work. A summary of the findings of the HAZMAT survey are presented in the following sections.

2.1 Asbestos Survey Sample Collection and Methodology

The purpose of the assessment was to provide a visual inspection and to collect representative samples of materials suspected to contain asbestos. The samples will help identify the presence of visible and accessible asbestos-containing materials (ACM), including Category I (NF-I) and Category II (NF-II) non-friable ACMs, to satisfy the requirements of 40 CFR Part 61 (NESHAP), Subpart M - National Emission Standards for Asbestos, Section 61.145

– Standard for Demolition and Renovation (40 CFR Part 61, Subpart M).

The scope of the survey included:

Visually identify the presence of suspected ACMs within the building(s) on site;

Perform representative sampling of suspected ACMs to meet NESHAP requirements in accordance with the defined sampling requirements outlined in 40 CFR Part 763, Subpart E – Asbestos-Containing Materials in Schools (40 CFR Part 763, Subpart E [Asbestos Hazard Emergency Response Act, AHERA]);

Third-party analysis of bulk samples for asbestos type/percentage content by an independently accredited asbestos laboratory; and

Prepare a factual report detailing the findings with recommendations for removal of identified Regulated Asbestos-Containing Materials (RACMs), if required, under 40 CFR Part 61, Subpart M.

The survey was generally non-intrusive in nature with limited destructive openings and tests performed to determine, where practical, the extent of suspected ACMs present. Reasonable efforts were made to look behind walls, below existing floor surfacing and roofing materials, and other access-challenged areas.

Sampling was completed of homogeneous materials that were uniform in color, texture, and installation or construction date. A minimum of two samples and a maximum of four samples per homogeneous material were collected and submitted for analysis, depending on the nature of the material being sampled. Samples of suspected ACMs were collected using a coring device or other method, as appropriate, to collect a small volume cross section of the suspect material. Each individual sample was placed into a clean, unused sealable plastic bag and individually labelled with a unique sample identification number.

Representative samples were submitted, under chain of custody procedures, to Eurofins CEI Labs, Inc. (Eurofins) in located in Cary, NC for asbestos content analysis to determine asbestos type and percentage. Eurofins holds a valid Asbestos Analytical Laboratory License and is accredited under the United States National Voluntary Laboratory Accreditation Program (NVLAP), Laboratory Code 101768-0, for asbestos bulk sample analysis and adheres to a written quality assurance/quality control (QA/QC) program which governs their analysis process. All bulk materials were analyzed using Polarized Light Microscopy (PLM) in accordance with USEPA Test Method EPA/600/R-93/116: Method for the Determination of Asbestos in Bulk Building Materials (analytical results are provided in Appendix B).

The USEPA identifies an asbestos-containing material as any material that contains more than 1.0 percent (%) asbestos by dry weight. Any materials reported by Hayes as “<1%” or “None Detected” contain less than 1.0% asbestos and are therefore not considered asbestos-containing under the USEPA definition.

2.1.1 Asbestos NESHAP Regulations and Guidelines

The purpose of the NESHAP asbestos regulation is to protect human health and the environment by minimizing the release of asbestos fibers when facilities that contain ACMs are renovated or demolished. The USEPA defines an ACM as a material that contains greater than one-percent asbestos by dry weight. 40 CFR Part 61, Subpart M requires that the owner or operator of a demolition or renovation activity must thoroughly inspect the facility for the presence of asbestos, including Category I and Category II non-friable ACMs, prior to the commencement of demolition or renovation.

Category I non-friable ACM means asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products containing more than 1 percent asbestos.

Category II non-friable ACM means any material, excluding Category I non-friable ACMs, containing more than 1 percent asbestos that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Friable ACM means any material containing more than 1 percent asbestos that when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

2.2 Paint Sampling Methodology

A focused paint sampling program was performed to confirm the presence of lead in paint throughout the site for future decommissioning and demolition planning. The presence of lead in paint at elevated concentrations should be disclosed to future contractors involved with demolition activities to facilitate implementation of appropriate worker safety protocols and waste management steps.

Painted surfaces within the site were identified and grouped together by component type, substrate, visible color and accessibility. A random representative area of each unique combination was sampled and tested. For each of these designated paints, an accessible area was chosen which represents the paint on that building’s component.

The painted surface of the structural substrate to be sampled was wetted prior to and during the sample collection, and an area of the paint/coating was scraped out from the surface, down to the substrate. The samples were placed into separate leak-tight bags, and a unique sample identification number was assigned to each sample. Samples were submitted by chain of custody procedures to Eurofins CEI Labs, Inc. (Eurofins) in located in Cary, NC., an American Industrial Hygiene Association (AHIA) accredited facility with an Environmental Laboratory Accreditation Program (ELAP) accredited laboratory for analysis in accordance with USEPA SW-846 Test Method 6010D: Inductively Coupled Plasma-Optical Emission Spectrometry (ICP-OES). Copies of the laboratory analysis are included in Appendix E.

2.3 Mold Sampling Methodology

There are no specific regulations in most countries addressing exposure to mold contamination for indoor environments. However, according to current recognized mold assessment and remediation guidelines, building materials and HVAC equipment supporting mold growth should be remediated as rapidly as possible to ensure a healthy environment.1 2 Remediation of mold growth is based on an approximation of the extent of visible mold growth including the estimated extent of any hidden mold growth, the type of building materials involved, and the sensitivity of building occupants to mold exposures. Repair of the defects that led to water accumulation or excessive building dampness should be conducted in conjunction with or prior to any mold remediation.

Currently, no numerical standards exist for the interpretation of mold analysis. Samples taken for the direct evaluation of mold growth using optical microscopy provide a qualitative assessment of mold contamination and amplification. The most important aspect of this procedure is to determine whether molds are colonizing, growing, and amplifying, regardless of what species of mold are present. Contamination is defined as the types and/or quantity of mold (and other fungal matter) that are not normally there and should not be there.

Thus, microscopic analysis and results interpretation of mold samples are subjective, and the presence of certain types of indicator mold species and/or the presence of mycelia or hyphal fragments in the samples may be more appropriate in determining whether there is evidence of mold contamination. Indicator molds may include those types of fungi which are typically associated with water damaged building materials, and can vary from region to region, but often include Aspergillus/Penicillium, Stachybotrys, and Chaetomium mold species.

As areas were observed to present suspect mold growth, a swab surface sample was collected in the affected area.

All samples were collected via swab and submitted to Eurofins, an American Industrial Hygiene Association (AHIA) accredited lab. The laboratory reported results utilizing a Mold Growth Rating (MGR) for quantification comparisons.

MGRs were described as follows:

1 American Industrial Hygiene Association Position Statement on Mold and Dampness in the Built Environment, March 26, 2013 2 ANSI/IICRC Standard and Reference Guide for Professional Mold Remediation S520 (Latest Edition)

Mold Growth Rating (MGR) Rating

0 No Fungal matter was detected; debris present is not consistent with fungal matter

1 Trace amount of fungal matter detected; a few random appearances of fungal matter indicated. Does not indicated active growth

2 Up to 25% of the sample surface is covered with fungal matter; probably indicates active growth at some point in time

3 36% - 50% of the sample surface is covered with fungal matter; Indicates active growth at some point and time

4 51% - 75% of the sample surface is covered with fungal matter; Indicates active growth at some point and time

5 Greater than 75% of the sample surface is covered with fungal matter; Indicates active growth at some point and time

3.0 RESULTS SUMMARY AND RECOMMENDATIONS

Results and discussions on findings have been formatted accordingly.

3.1 Asbestos Results and Discussion

A total of 14 homogeneous sample groups (HSGs) were visually identified with a total of 31 individual samples collected and submitted for analysis to comply with the requirements of 40 CFR Part 763, Subpart E. Additionally, three (3) HSGs were observed and not sampled as they were either unsafe to sample, inaccessible at the time of the survey or would jeopardize the use integrity of the feature. These HSGs are presumed to be asbestos-containing (PACMs) or may contain ACMs. Sample location, descriptions and the laboratory analytical results of suspected asbestos-containing materials are provided within a summary table containing photos and information for each HSG as Table 1 - Asbestos Homogenous Sample Group Information, provided in Appendix A.

As indicated on Table 1, 4 HSGs that were sampled were determined to be ACMs via laboratory analysis, with an additional 3 PACMs identified. Confirmed and presumed ACM’s throughout the site include:

Tile under carpet (HSGs 4 and 11)

Mastic associated with tile under carpet (HSG 6)

Mastic on HVAC equipment (HSG 8)

Transite walls (HSG 13)

Fire Doors (HSG 14)

Onsite…