Attachment 3 HazMat Report.pdf

HAZARDOUS BUILDING MATERIALS SURVEY

Renovation

Contract No. W912DW21D1007, Design PKG No. CE0879

Architect-Engineer (A-E) Design, Repair of the Interior, Exterior, and Mechanical, Electrical, Plumbing, and Construct Cover, BLDG. 3757

Joint Base Lewis-McChord, Washington

Prepared for

WJA Design Collaborative

617 Western Avenue

Seattle, Washington 98104

Prepared by

Med-Tox Northwest

Post Office Box 1446 98071-1446

Auburn, Washington

MTNW Project 9096.1

Anthony Fullerton

AHERA BI #190507 Exp. 08/22/2024

November 2023

Hazardous Building Materials Survey

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Contents

Acronyms ...................................................................................................................................... iii

Survey Summary

Building Information

General and Structural

Heating/Mechanical/Plumbing System

Asbestos Summary

Surfacing Materials

Thermal System Insulation

Miscellaneous Materials

Paint Containing Metals Summary

Waste Designation Survey

Other Hazardous Building Materials

PCB Light Ballasts and Fluorescent Light Tubes

Mercury-Containing Thermostats

Laboratory Analytical Methods

Asbestos-Containing Materials

Paint Containing Metals

Comments and Recommendations

Asbestos-Containing Materials

Limitations

Appendix A AHERA Building Inspector and WDOC Lead-Based Paint Certificates ......... A

Appendix B Building and Asbestos Materials Photographic Documentation ..................... B

Appendix C Summary of Materials Sampled for Asbestos .................................................... C

Appendix D Sample and Material Location Drawings ............................................................ D

Appendix E National Voluntary Laboratory Accreditation Program Certificate .................. E

Appendix F Analytical Report- Asbestos .................................................................................. F

Appendix G Analytical Report- Lead ......................................................................................... G

Appendix H EMSL Certification .................................................................................................. H

Appendix I Analytical Report – PCB ........................................................................................... I

Appendix J On-Site Analytical Accreditation ............................................................................. J

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Tables

Table 1. Summary of Asbestos-Containing Materials

Table 2. Summary of Suspect Materials Determined Non-asbestos

Table 3. Summary of Bulk Paint Chip Sample Results

Table 4. Summary of Light Fixtures, Smoke Detectors and Exit Signs

Table 5. Summary of PCB Results

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Acronyms

A-E Architect-Engineer ACM asbestos-containing materials ACT acoustical ceiling tile AHU air handling unit AHERA Asbestos Hazard Emergency Response Act ASHARA Asbestos Schools Hazard Abatement Reauthorization Act ASTM American Society of Testing and Materials CMU cement masonry unit CFR Code of Federal Regulation DEHP Di (2-ethylhexyl) phthalate EA each ECD electron capture detectors EMSL EMSL Analytical, Inc.

EPA U.S. Environmental Protection Agency GC gas chromatography GWB gypsum wallboard JBLM Joint Base Lewis-McChord HBM hazardous building materials HM homogeneous material ICP inductively coupled plasma LBP lead-based paint LCP lead containing paint LF linear feet mg/cm2 milligrams per square centimeter mg/kg milligrams per kilogram mg/L milligrams per Liter MTNW Med-Tox Northwest NIST National Institute of Standards and Technology ND none detected NVLAP National Voluntary Laboratory Accreditation Program OSHA Occupational Safety and Health Administration PCB polychlorinated biphenyl PLM polarized light microscopy ppm parts per million

PSCAA Puget Sound Clean Air Agency PVC polyvinyl chlorinated RCRA Resource Conservation and Recovery Act TCLP toxicity characteristic leaching procedure TSI thermal system insulation WAC Washington Administration Code WDOC Washington Department of Commerce XRF x-ray fluorescence

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Survey Summary

On September 27 and October 12, 2023, Anthony Fullerton of Med-Tox Northwest (MTNW) conducted a hazardous building material (HBM) survey of Building 3757 located at Joint Base Lewis McChord (JBLM). The A-E Design, Repair of the Interior, Exterior, and Mechanical, Electrical, Plumbing, and Construct Cover, Bldg. 3757 was completed under subcontract to WJA Design Collaborative. The project shall address all necessary upgrades and repairs to the existing building to include, but not be limited to:

• Building envelope

• Roofing systems

• Structural elements

• Interior layout (non-structural elements)

• Interior and exterior architectural finishes

• Electrical repairs and upgrades

• Plumbing repairs and upgrades

• Mechanical repairs and upgrades

• Existing Hazardous Material abatement.

The MTNW survey was conducted for renovation and/or demolition purposes and included asbestos, lead containing paint (LCP), and other potential HBM such as, polychlorinated biphenyl (PCB) solids sampling that will be impacted by the upcoming project. Limited destructive investigation was performed during this survey; due to building occupancy however, renovation or demolition activities may uncover additional suspect asbestos materials. The Comments and Recommendations section of this report details additional destructive investigation required before and/or during demolition activities. As required the building inspector certified under the Asbestos Hazard Emergency Response Act (AHERA) and employed by MTNW conducted the asbestos portion of the survey.

This survey consisted of a visual inspection, touching of suspect materials, and sample collection with analysis. As-built drawings were available and reviewed as part of this survey report. Copies of the AHERA building inspector certificates and State of Washington Department of Commerce (WDOC) lead-based paint accreditation are included in Appendix A.

Building Information

General and Structural

Building 3757

This dining facility building was constructed in 1977 and consists of brick masonry walls, a concrete slab floor (with partial crawlspace), metal truss roof supports finished with extruded steel pan decking (corrugated metal roof sheets). The roof consists of built-up tar and paper over insulation. There are pitched roofs over the

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November 2023 2 WJA Design Collaborative entryways that are finished with corrugated metal panels. Interior spaces inside the building include a food prep area, food storage rooms, coolers, serving areas, dining areas, dish washing area, janitor closets and restrooms.

Heating/Mechanical/Plumbing System

Primary heating and cooling for the building is provided by multiple air handling units located on the roof (total of 6). Water for the heating system is heated by a large gas-fired boiler and stored in an insulated storage tank. There are several different diameters of pipes running throughout the building. There were several fitting insulation types observed. These included polyvinyl Chloride (PVC) fittings over fiberglass and mudded fitting insulation (pipes with mudded fittings were observed above the suspended ceiling in the dining areas).

There is also an insulated 10-inch pipe with valve located near the hot water storage tank in the mechanical room that has cementitious sealant on the top and bottom and an insulated 14-inch diameter hanging tank with cementitious sealant. The cementitious sealant was determined to be asbestos containing.

The 6-inch roof drain downspout piping observed (mechanical room roof drain) was insulated with foil wrapped fiberglass and the fittings are insulated with hand trowelled mud and cheesecloth. Samples collected from the roof drainpipe fitting insulation was determined to be negative for asbestos.

Ceilings

Ceilings throughout the building consist primarily of acoustical ceiling tiles (ACT) suspended in a metal t-grid system. The dining areas have a combination of suspended ceilings and hard lid finished with orange peel textured gypsum wallboard (GWB) system. The ceilings in the kitchen area are smooth finished plaster and the restroom ceilings are GWB system. The entry ways located on both sides of the building have rough textured plaster on the ceilings.

Walls

Most of the walls throughout the building consist of painted cement masonry unit (CMU) and concrete. Built-out interior walls are finished with orange peel textured GWB system. Other wall finishes include wall laminate, sheet metal protective coverings and ceramic wall tiles.

Floor Systems

The flooring found in the building included a combination of carpeting, ceramic floor tile and vinyl floor tile systems over concrete. According to the design team, the floor is not expected to be impacted by the planned renovation activities.

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Photographic documentation of the building and its major systems described herein are provided in Appendix B.

Asbestos Summary

The AHERA regulation, 40 Code of Federal Regulations (CFR) 763, is the primary governing regulation when performing asbestos surveys. This regulation was originally enacted for school buildings but has since been applied to public and commercial buildings by the Asbestos School Hazard Abatement Reauthorization Act (ASHARA) in 1994 and by the Occupational Safety and Health Administration’s (OSHA) worker protection regulations in 1995, specifically 29 CFR 1926.1101(k).

Puget Sound Clean Air Agency (PSCAA) also requires compliance with AHERA’s survey and sampling requirements. This applies to any renovation or demolition activities where suspect asbestos-containing material (ACM) may be disturbed. PSCAA is a local agency that receives statutory authority from the Environmental Protection Agency (EPA) to enforce environmental regulations.

AHERA divides suspect ACM into three categories; “surfacing materials” (i.e., sprayed fireproofing, popcorn ceiling texture, etc.), “thermal system insulation” (TSI) (i.e., pipe or building insulation, etc.), and “miscellaneous materials” (i.e., flooring material, roofing, construction mastics, etc.). The building was surveyed for these materials as they relate to the upcoming renovation project and sampled as required (total of 105 samples). For a complete listing of suspect materials sampled, see Appendix C.

Sampling locations are indicated on the drawing in Appendix D. Table 1 below lists asbestos-containing materials identified in the building that will be impacted by this renovation or require communication of hazards to construction workers during the project.

Table 1. Summary of Asbestos-Containing Materials.

Material Location Friable Quantity

Building 3757

White sealant on metal duct (HM- 27)

Roof No 36 LF

10-inch pipe at valve to hot water tank- cementitious sealant on ends (HM-40)

Mechanical room Yes 1 EA

14-inch hanging tank-cementitious sealant on ends

(HM-41)

Mechanical room Yes 1 EA

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Note: This table is not to be used without the complete survey document including appendices for additional information.

Surfacing Materials

There were four surfacing materials identified in Building 3757 as defined by 40 CFR 763.

▪ Orange peel textured GWB system (HM-05). This material was observed on the interior of the building in the restrooms, breezeway, and dining rooms. Six samples were collected of this material; all samples were determined to be negative asbestos.

▪ CMU coating and mortar (HM-06). The interior CMU is painted. Five samples were collected of this paint coating and mortar; all samples were determined to be negative for asbestos.

▪ Rough textured plaster ceiling/soffit (HM-07). This finish material was observed in the entryways and on the perimeter soffit. Five samples were collected of the rough textured plaster; all samples were determined to be negative for asbestos.

▪ Smooth finish plaster ceiling (HM-38). The ceiling in the kitchen area is finished with smoothly finished plaster. Five samples were collected of this material; all samples were determined to be negative asbestos.

Thermal System Insulation

There were twelve TSI materials as defined by 40 CFR 763 identified in Building 3757.

▪ White foil pipe wrap with white sealant over fiberglass- 6-inch pipes above drop ceiling (HM-01). There were various diameter pipes with insulation observed in the building. There are runs that are insulated with white foil wrap over fiberglass lagging and PVC fittings over fiberglass. Three samples were collected of the white foil wrap with mastic and sealant; all samples were determined to be negative for asbestos. The fiberglass lagging was visually determined to be non-asbestos containing.

▪ 4-inch mudded pipe fitting (HM-02). This pipe system was observed above the suspended ceiling in the dining areas. The pipes are insulated with foil wrapped fiberglass lagging and the associated fittings are insulated with hand troweled mud covered with cheese cloth. Three samples were collected of this material; all samples were determined to be negative for asbestos.

▪ Foil duct wrap and mastic over fiberglass (HM-03). The metal ducts located above the suspended ceiling were observed to be insulated with this material.

Three samples were collected of this material; all samples were determined to be negative for asbestos.

▪ Foil backed wall panel insulation boards (HM-04). The perimeter walls located above the suspended ceilings in the dining areas are insulated with

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November 2023 5 WJA Design Collaborative insulation boards. Three samples were collected of this material; all samples were determined to be negative for asbestos.

▪ Silver paint coating and tar- roof (HM-25). The built-up roofing is painted with silver coat heat reflecting paint. Three samples were collected of this material; all samples of this material were determined to be negative for asbestos.

▪ 6-inch mudded pipe fitting- roof drain downspout (HM-31). The roof drain downspout located in the mechanical room was observed to be insulated with fiberglass pipe lagging and hand trowelled mudded fittings. Three samples were collected from the mudded fittings; all samples were determined to be negative for asbestos.

▪ Foil wrap with mastic over fiberglass insulation- water storage tank (HM-32).

The large water storage tank in the mechanical room is covered with foil wrap over fiberglass insulation. Three samples were collected of this material; all samples were determined to be negative for asbestos.

▪ White foil pipe wrap with white sealant over fiberglass- 6-inch pipes (HM-33).

These pipes with insulation were observed in the mechanical rooms. Four samples were collected of this material: all samples were determined to be negative for asbestos.

▪ 10-inch pipe at valve to hot water tank- cementitious sealant on ends (HM-40). This pipe and valve were observed next to the large hot water storage tank in the mechanical room. The pipe is insulated with fiberglass lagging with cheesecloth and cementitious sealant on the ends. Seven samples were collected of this material: this material was determined to contain 4%-5% Chrysotile asbestos.

▪ 14-inch hanging tank- cementitious sealant on ends (HM-41). This hanging tank was observed in the mechanical room. The tank is insulated with fiberglass lagging with cheesecloth and cementitious sealant on the ends. Three samples were collected of this material: this material was determined to contain 7% Chrysotile asbestos.

▪ White foil pipe wrap with white sealant over fiberglass- 8-inch pipes (HM-42).

These pipes with insulation were observed in the mechanical rooms. Three samples were collected of this material: all samples were determined to be negative for asbestos.

▪ Fiberglass insulation. This material is located on mechanical systems throughout the building. Fiberglass insulation was visually determined non-asbestos containing.

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Miscellaneous Materials

▪ Un-textured GWB system (HM-08). This material was observed in the kitchen area janitor closets and storage closets. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ 2- x 4-foot ACT pin and crater pattern (HM-09). The drop ceiling throughout most of the building was observed to have this type of ceiling tile in place.

Three samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ 6-inch brown cove base and mastic (HM-10). This material was observed in the dining areas. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Gray wood grain pattern flooring (HM-11). This material was observed in the dining and breezeways. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ 4-inch ceramic wall tile grout/ thin set (HM-12). This material was observed on the walls in multiple places inside the building. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ White restroom fixture caulk (HM-13). This material was observed around the fixtures in the restrooms. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ White wall laminate caulk (HM-14). This material was observed on the walls in the janitor closet. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Brown interior window frame sealant (HM-15). This material was observed on the interior portion of the metal window frames. Three samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Brown interior door frame sealant (HM-16). This material was observed on the inside of the enter/exit doors on the north and sides of the building. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Brown exterior door frame sealant (HM-17). This material was observed on the outside of the enter/exit doors on the north and sides of the building. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Exterior wall expansion joint-concrete to brick (HM-18). This material is located on the exterior of the building at the interface between the brick exterior wall and concrete sidewalk. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

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▪ Brown exterior window frame sealant (HM-19). This material was observed around the exterior metal window frames. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Windowpane to frame sealant (HM-20). This material was observed sealing the glass windowpanes to the inside of the frame. Three samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Brick mortar (HM-21). The building is constructed with brick and mortar.

Three samples were collected of the brick mortar and analyzed for asbestos content; this material is negative for asbestos.

▪ Metal fascia to brick flashing caulk (HM-22). This material was observed on the metal fascia flashing. Three samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Gray door frame caulk- exterior (HM-23). This material was observed around the metal door frame of the double door to the mechanical room. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Rolled composition roofing and tar- parapet (HM-24). The parapet of the roof consists of rolled composition roofing with black tar sealant. Three samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Black tar on vents (HM-26). There are multiple vents located on the roof;

many were observed to have black tar on them. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ White sealant on metal duct (HM-27). There is metal ducting associated with air handling unit (AHU) #6 located on the roof. Two samples were collected and analyzed for asbestos content; this material was determined to contain 2% Chrysotile asbestos. Subsequent re-analysis of one sample by PLM 400 point count determined the asbestos content was 1.25-2 % asbestos content.

▪ Gray sealant on metal duct (HM-28). There is metal ducting associated with AHU #6 located on the roof. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Plaster on windbreak wall (HM-29). There is a metal-framed windbreak wall finished with plaster in-fill located on the roof. Three samples were collected of the plaster and analyzed for asbestos content; this material is negative for asbestos.

▪ Black tar sealant on windbreak wall metal post base (HM-30). There is a metal-framed windbreak wall finished with plaster in-fill located on the roof.

The base of the wall consists of metal posts with black tar sealant. Two

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November 2023 8 WJA Design Collaborative samples were collected of the black tar sealant and analyzed for asbestos content; this material is negative for asbestos.

▪ Tan mastic on foam insulation board (HM-34). This material was observed in the crawlspace. Two samples were collected of this material; all samples were determined to be negative for asbestos.

▪ White fibrous boiler door gasket (HM-35). The boiler located in the mechanical room was fully operational at the time of the survey. There were white fibrous gaskets observed around the door that were accessible. Two samples were collected of the gasket material and analyzed for asbestos content; this material is negative for asbestos.

▪ Wall laminate mastic (HM-36). The walls in the mechanical room were observed to have white wall laminate over the un-textured GWB system. Two samples were collected of the wall laminate mastic and analyzed for asbestos content; this material is negative for asbestos.

▪ Un-textured GWB system (HM-37). The walls in the mechanical room were observed to have white wall laminate over the un-textured GWB system. Two samples were collected of the un-textured GWB system and analyzed for asbestos content; this material is negative for asbestos.

▪ Built-up roofing core with silver paint (HM-25 and HM-39). The roof of the building consists of silver paint and built-up tar and paper over insulation and fiberboard. The roof is affixed to the metal pan decking. One core sample was collected and analyzed for asbestos content; this material is negative for asbestos.

▪ Red sealant (HM-43). This sealant was observed on the chimney of the small package boiler located in the mechanical room. Two samples were collected and analyzed for asbestos content; this material is negative for asbestos.

Table 2 below lists all suspect materials that have been determined non-asbestos.

Table 2. Summary of Suspect Materials Determined Non-asbestos.

Material Material

White foil pipe wrap with white sealant over fiberglass (HM-01)

4-inch mudded pipe fitting (HM-02)

Foil duct wrap and mastic over fiberglass

(HM-03)

Foil backed wall panel insulation boards

(HM-04)

Orange peel textured GWB system (HM- 05)

CMU coating and mortar (HM-06)

Rough textured plaster ceiling/soffit (HM- 07)

Un-textured GWB system (two HM’s 08 and 37)

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Material Material

2-x-4-foot ACT pin and crater pattern (HM- 09)

6-inch brown cove base and mastic (HM-10)

Gray wood grain pattern flooring (HM-11) 4-inch ceramic wall tile grout/ thin set (HM- 12)

White restroom fixture caulk (HM-13) White wall laminate caulk (HM-14)

Brown interior window frame caulk (HM- 15)

Brown interior door frame caulk (HM-16)

Brown exterior door frame caulk (HM-17) Exterior wall expansion joint- concrete to brick (HM-18)

Brown exterior window frame caulk (HM- 19)

Windowpane to frame sealant (HM-20)

Brick mortar (HM-21) Metal fascia to brick flashing caulk (HM-22)

Gray door fame caulk- exterior (HM-23) Rolled composition roofing and tar- parapet

(HM-24)

Silver paint coating and tar (HM-25) Black tar on vents (HM-26)

Gray sealant on metal ducts (HM-28)

Plaster on windbreak wall (HM-29) Black tar sealant on windbreak wall metal post base (HM-30)

6-inch mudded pipe fittings (HM-31) Foil wrap with mastic over fiberglass insulation (HM-32)

White foil pipe wrap with sealant over fiberglass- 6-inch pipes (HM-33)

Tan mastic on foam insulation board (HM- 34)

White fibrous boiler door gasket (HM-35) Wall laminate mastic (HM-36)

Smooth finish plaster ceiling (HM-38) Built-up roofing core with silver coat paint (HM-39 and HM-25)

White foil wrap and sealant over fiberglass- 8-inch (HM-42)

Red sealant (HM-43)

Note: This table is not to be used without the complete survey document including appendices for additional information.

Paint Containing Metals Summary

Lead was commonly used in most paint products until 1978, when it was banned from residential paints at concentrations greater than 600 parts per million (ppm); however, commercial applications with lead were still utilized and are still available. Lead is poisonous to the human body and presents a potential health hazard during any kind of disturbance (such as maintenance, including grinding, welding, and cutting) and if improperly disposed, where lead can enter drinking water supplies. Industrial paints routinely contain other heavy metals such as arsenic, barium, cadmium and chromium which can also cause adverse health effects if not managed for worker exposure.

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EPA defines lead-based paint (LBP) as a concentration of 1.0 milligram per centimeter squared (mg/cm2) or greater by X-Ray fluorescence (XRF) or 0.5 percent by weight or greater by total lead analysis (equivalent to 5,000 milligrams per kilogram [mg/kg]). This EPA action level triggers requirements for protection of the environment, maintenance workers, and building occupants. It also triggers training and certification requirements for inspectors, project designers, contractors, supervisors, and workers for child occupied facilities.

OSHA worker protection regulations has not defined a minimum concentration for regulating lead (or any other heavy metal) and has clarified that lead at any detectable concentration shall be considered regulated (29 CFR 1926.62).

OSHA also regulates metals in the construction industry with four substance specific regulations for arsenic, cadmium, hexavalent chromium and lead. The other metals are regulated through the hazard communication standard and 1926.55 gases, vapors, fumes, dusts and mists standard.

The Resource Conservation and Recovery Act (RCRA) of 1976 is a federal law that gives the EPA authority to regulate waste materials as defined in CFR 40 CFR Part 261.

The act, which regulates land-based disposal of waste (and focuses on hazardous waste), has the goal of reducing waste and encouraging recycling. It regulates eight metals based on toxicity to characterize certain wastes as either hazardous or non-hazardous.

Metals in Painted Surfaces

Interior and exterior painted surfaces were tested for the RCRA eight heavy metals using bulk sample collection and chemical analysis; analytical results are provided in Table 3.

Table 3. Summary of Bulk Paint Chip Sample Results.

Sample Number Location Component Substrate Color Result

(ppm)

9096.1-3757-01Pb Kitchen Ceiling Plaster White As

Ba

Cd

Cr

Pb

Se

Ag

Hg

ND

ND

ND

ND

ND

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Sample Number Location Component Substrate Color Result

(ppm)

9096.1-3757-02Pb Entry ways and soffit

Ceiling Plaster Off-white

As

Ba

Cd

Cr

Pb

Se

Ag

Hg

ND

1,600

0.83

3.4

ND

0.45

7.3

9096.1-3757-03Pb Dining areas Walls CMU Off-white

As

Ba

Cd

Cr

Pb

Se

Ag

Hg

ND

3,300

ND

4.5

4.5

ND

ND

9096.1-3757-04Pb Dining/ serving area

Walls GWB Off-white

As

Ba

Cd

Cr

Pb

Se

Ag

Hg

ND

ND

3.5

5.3

ND

ND

9096.1-3757-05Pb Roof Windbreak wall

Plaster Gray Pb <80

9096.1-3757-06Pb Janitor closet Ceiling GWB Off-white Pb <80

As=Arsenic, Ba=Barium, Cd=Cadmium, Cr=Chromium, Pb=Lead, Se=Selenium, Ag=Silver, Hg=mercury, ND = none detected. Bolded values – bulk paint chip samples with metals detected above the laboratory reporting limit have been bolded. OSHA worker protection regulations have stated that lead at any detectable concentration shall be considered regulated per 29 CFR 1926.62.

Waste Designation Survey

Waste designation sampling has not been performed due to the destructive nature of the sampling technique and building occupancy however, bulk paint chip sampling

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November 2023 12 WJA Design Collaborative results indicate that paint chips may fail waste designation if removed as a single waste stream. The contractor should collect a Toxicity Characteristic Leaching Procedure (TCLP) sample once the waste stream has been established. WAC 173-303 Dangerous Waste Regulations defines hazardous waste as it relates to lead by toxicity as 5.0 milligrams per liter (mg/L) TCLP.

Other Hazardous Building Materials

PCB Light Ballasts and Fluorescent Light Tubes

Older fluorescent light ballasts have small capacitors that may contain high concentrations of PCBs. Nearly all ballasts manufactured before 1979 contain PCBs.

All ballasts manufactured after July 1, 1978 that do not contain PCBs are required to be clearly marked "No PCBs". Unmarked ballasts or ballasts without a date code should be assumed to be PCB ballasts. PCBs are toxic chemicals according to the EPA.

While there is only a small amount, about one ounce of PCBs in each light ballast capacitor, there are a large number of ballasts in the United States. About half of the one billion ballasts, estimated as currently installed, were manufactured before 1979 and usually contain PCBs. Ballasts manufactured after 1978 may contain a PCB replacement called Di (2-ethylhexyl) phthalate (DEHP), a probable human carcinogen.

In any case, ballasts should not be disassembled for disposal but collected and sent to a certified recycling/disposal facility.

All fluorescent light fixtures should be assumed to contain PCB ballasts and mercury containing light tubes. The following is a summary of fixtures observed in the building:

Table 4. Summary of Light Fixtures, Smoke Detectors and Exit Signs.

Location 4-foot, 2-bulb

4-foot, 1-bulb

Emergency Lights

Smoke Exit

Throughout site 165 6 9 13 11

Total 165 6 9 13 11

Typically, there is one ballast for every two light tubes in a fluorescent light fixture;

accordingly, there are approximately 171 ballasts in the light fixtures requiring recycling or PCB hazardous waste disposal. There are also 336 light tubes that will need to be recycled during demolition.

PCBs in Building Materials

PCBs were used in paint and caulk formulations as drying oils (resins) and plasticizers or softening agents (liquids). Concrete surfaces and equipment, as well as marine or waterproofing applications, used at Federal installations and in the manufacturing and industrial sectors may have painted surfaces containing PCBs.

PCBs were tested in representative materials from the interior and exterior of the building. Table 5 below provides a summary of PCB sample results.

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Table 5. Summary of PCB Results

Sample Number Location Material Result

(mg/kg)

9096.1-3757-01PCB Exterior soffits and entry/exit ceilings

Off-white paint on textured plaster ND

9096.1-3757-02PCB Concrete sidewalk to brick wall

Black expansion joint ND

9096.1-3757-03PCB Exterior Brown window frame caulk ND

9096.1-3757-04PCB Exterior Brown door frame caulk ND

9096.1-3757-05PCB Dining area Off-white paint on CMU wall ND

9096.1-3757-06PCB Kitchen Off-white on GWB ND Note: This table is not to be used without the complete survey document including appendices for additional information.

Mercury-Containing Thermostats

Heating system thermostats were investigated for mercury containing systems.

Dismantled thermostats did not reveal any suspect mercury-containing materials.

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Laboratory Analytical Methods

Asbestos-Containing Materials

Bulk samples were analyzed by Polarized Light Microscopy (PLM) dispersion staining EPA Method 600/R-93/116 by Seattle Asbestos Test, LLC. Sample (9096.6-3757-073) was also analyzed using PLM EPA method 600/R-93/600 400 point count. Seattle Asbestos Test, LLC is accredited through the National Voluntary Laboratory Accreditation Program (NVLAP) administered by the National Institute of Standards and Technology (NIST), a division of the U. S. Department of Commerce. This accreditation does not constitute endorsement, but rather a finding of laboratory competence. Seattle Asbestos Test, LLC participant number is 200768-0 (certifications in Appendix E). A copy of the laboratory analytical report is provided in Appendix F.

Paint Containing Metals

Bulk samples were submitted to EMSL Laboratories, Inc. (EMSL) for analysis. RCRA 8 samples were analyzed by inductively coupled plasma (ICP) due to the multiple metals present. Procedures for analyzing metals are found in the American Society of Testing and Materials (ASTM) D-3335-78 and EPA Method Manual SW-846, Method 6010.

(EMSL used SW 846 3050B/6010D). Mercury by CVAA, SW- 846-7471B.

Analytical results for bulk paint chip sampling are provided in Appendix G, laboratory certification for EMSL Analytical Inc. is attached in Appendix H.

PCBs

Bulk PCB samples were submitted to On-Site Environmental, Inc., for analysis using gas chromatography (GC) equipped with electron capture detectors (ECD). A total of six (6) samples were analyzed using EPA Method SW-846 8081/8082. Analytical results are provided in Appendix I. On-Site Environmental, Inc. laboratory certification is attached in Appendix J.

Sample and material locations drawings are in Appendix D.

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November 2023 15 WJA Design Collaborative

Comments and Recommendations

Asbestos-Containing Materials

Med-Tox Northwest recommends, and state/federal law requires, that all asbestos materials identified in Table 1 be removed prior to or managed during demolition.

We recommend that this survey report be placed on-site during renovation and/or selective demolition and copies provided to the contractor(s) bidding and performing work. OSHA requires that the report be on-site and available for review during the entire project duration.

Additional destructive investigation and sampling will be required prior to and during renovation activities including, but not limited to the following:

1. If during the course of the project, pipe and/or fitting insulations not identified in this report are observed, they must be treated as ACM until sampling proves otherwise.

2. Doors were not destructively investigated due to building occupancy and potential fire rating. During demolition, inspect every door and door jamb for suspect asbestos insulation material or remove and dispose as ACM.

3. Due to occupancy electrical systems were not tested. Testing and verification by an AHERA building inspector will be required for any electrical components scheduled for modification or demolition.

If the building is not renovated or demolished and abatement of identified ACM is not performed, periodic surveillance should be performed by an AHERA accredited building inspector at least once every three years. In addition, bi-annual surveillance should be performed by maintenance personnel trained by an AHERA building inspector.

29 CFR 1926.1101 requires ACM be removed by trained and licensed contractors using certified asbestos abatement workers and supervisors (except for deregulated roofing sealants, mastics, and coatings).

MTNW recommends third party oversight of asbestos abatement and renovation activities by an AHERA accredited building inspector to ensure regulatory compliance and completion of the additional destructive methods recommended herein.

Paint Containing Metals

The testing performed during this survey identified lead in high to low concentration in most of the samples collected. For lead, any percentage of lead in the material should be an assumed risk to human health. All metal painted or primed surfaces (structural framing, mechanical equipment, metals/frames, etc.) should be assumed to contain at

Repair of the Interior, Exterior, and Mechanical, Electrical, Plumbing, and Construct Cover, Bldg. 3757

November 2023 16 WJA Design Collaborative least trace levels of lead in paint, therefore requiring compliance with 29 CFR 1926.62 during demolition activities or any other disturbance of painted surfaces. There are substance specific OSHA regulations for arsenic, cadmium and chromium that will require compliance components during any upcoming renovation projects that will affect these areas. The other metals with PELs will require exposure monitoring during disturbance.

PCB

There were no PCB’s detected in the bulk samples collected. However, during demolition, the asbestos abatement contractor should be tasked with dismantling light fixtures, collecting all lighting ballasts for proper disposal, and recycling the light tubes.

Ballasts without “No-PCB” labels are considered PCB-containing and must be disposed of as hazardous waste. “No-PCB” ballasts may designate as Washington Dangerous Waste and should be sent to an EPA licensed facility for proper disposal. Light tubes can be recycled as a universal waste for minimal cost or must be disposed of as a hazardous waste.

Other Hazardous Building Materials

Fluorescent light tubes contain mercury and can be recycled as a universal waste for minimal cost. Additionally, exit signs and emergency lights may be regulated as universal or hazardous waste and will require dismantling and special handling.

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Limitations

A good faith effort has been made to identify ACM and LCP in preparation to the Repair of the Interior, Exterior, and Mechanical, Electrical, Plumbing, and Construct Cover, Bldg. 3757 Project. This survey was performed in preparation to a planned project but due to occupancy, destructive investigation could not be performed.

Sampling was performed consistent with the level of care and skill ordinarily exercised by professionals currently practicing under similar conditions in the area. No other warranty, expressed or implied, is made.

This report has been prepared for the exclusive use of WJA, Design Collaborative and its’ designates. The analyses, conclusions, and recommendations presented in this report are based on conditions encountered at the time of our survey and our experience and judgment. MTNW cannot be held responsible for interpretation by others of the data contained in this report; any use of this report shall include the entire document. This survey is not intended for use as abatement plans and/or specifications which MTNW recommends for regulatory compliance.

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November 2023 A WJA Design Collaborative

Appendix A AHERA Building Inspector and WDOC Lead-

Based Paint Certificates

STATE OF WASHINGTON

Department of Commerce

Lead-Based Paint Abatement Program

Has fulfilled the certification requirements of

WAC 365-230

and has been certified to conduct lead-based paint activities as a

Risk Assessor

Certification # Issuance Date Expiration Date 0242 08/13/2020 04/03/2023

Anthony L Fullerton

Anthony L. Fullerton

AHERA Building Inspector

This is to certify that

4 hours of online refresher training as an

186102 Certificate Number

Instructor:

Aug 25, 2022 Date(s) of Training

Expires in 1 year.

to comply with the training requirements of has satisfactorily completed

TSCA Title II, 40 CFR 763 (AHERA)

EPA Provider # 1085

N/AExam Score:

(if applicable)

David Welch

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November 2023 B WJA Design Collaborative

Appendix B Building and Asbestos Materials

Photographic Documentation

Repair Interior, Exterior, Mechanical, Electrical, Plumbing and Construct Cover Bldg. 3757

Photo 1: Building 3757 facing southwest.

Photo 2: Exterior of the building facing east. The mechanical rooms and loading dock are pictured.

Photo 3: Roof of the building facing east.

Photo 4: ACM white sealant on the metal ducting associate with AHU #6.

Photo 5: Parapet and windbreak wall on the roof.

Photo 6: Large hot water storage tank in the main mechanical room.

Photo 7: Main mechanical room pipes, valves and tanks.

Photo 8: Detached boiler room facing north.

Photo 9: Typical finishes observed in the dining areas.

Photo 10: Pipes located above the suspended ceiling in the dining areas.

Photo 11: Breezeway located between the two dining areas.

Photo 12: Typical finishes observed in the serving area.

Photo 13: Typical finishes observed in the kitchen area.

Photo 14: Crawlspace under the kitchen area.

Photo 15: 14-inch hanging tank with ACM cementitious sealant located in the main mechanical room.

Photo 16: 10-inch pipe at valve to hot water tank with ACM cementitious sealant on the ends.

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November 2023 C WJA Design Collaborative

Appendix C Summary of Materials Sampled for Asbestos

Hazardous Building Materials Survey—

November 2023 C-1 WJA Design Collaborative

Table C-1. Summary of Materials Sampled for Asbestos

Sample Material Location AHERA Type HM Result

9096.1-3757-001 White foil pipe wrap with white sealant over fiberglass

6-inch pipes above drop ceiling

TSI 01 ND

9096.1-3757-002 White foil pipe wrap with white sealant over fiberglass

6-inch pipes above drop ceiling

TSI 01 ND

9096.1-3757-003 White foil pipe wrap with white sealant over fiberglass

6-inch pipes above drop ceiling

TSI 01 ND

9096.1-3757-004 4-inch mudded pipe fitting

Pipes above drop ceiling in dining areas

TSI 02 ND

9096.1-3757-005 4-inch mudded pipe fitting

Pipes above drop ceiling in dining areas

TSI 02 ND

9096.1-3757-006 4-inch mudded pipe fitting

Pipes above drop ceiling in dining areas

TSI 02 ND

9096.1-3757-007 Foil duct wrap and mastic over fiberglass

Metal ducting above ceiling

TSI 03 ND

9096.1-3757-008 Foil duct wrap and mastic over fiberglass

Metal ducting above ceiling

TSI 03 ND

9096.1-3757-009 Foil duct wrap and mastic over fiberglass

Metal ducting above ceiling

TSI 03 ND

9096.1-3757-010 Foil backed wall panel insulation boards

Perimeter wall above drop ceiling

TSI 04 ND

9096.1-3757-011 Foil backed wall panel insulation boards

Perimeter wall above drop ceiling

TSI 04 ND

9096.1-3757-012 Foil backed wall panel insulation boards

Perimeter wall above drop ceiling

TSI 04 ND

9096.1-3757-013 Orange peel textured GWB system

North Restrooms Surfacing 05 ND

9096.1-3757-014 Orange peel textured GWB system

North Restrooms Surfacing 05 ND

November 2023 C-2 WJA Design Collaborative

9096.1-3757-015 Orange peel textured GWB system

South Restrooms Surfacing 05 ND

9096.1-3757-016 Orange peel textured GWB system

South Restrooms Surfacing 05 ND

9096.1-3757-017 Orange peel textured GWB system

North dining ceiling Surfacing 05 ND

9096.1-3757-018 Orange peel textured GWB system

North dining Surfacing 05 ND

9096.1-3757-019 CMU coating and mortar

Interior Surfacing 06 ND

9096.1-3757-020 CMU coating and mortar

Interior Surfacing 06 ND

9096.1-3757-021 CMU coating and mortar

Interior Surfacing 06 ND

9096.1-3757-022 CMU coating and mortar

Interior Surfacing 06 ND

9096.1-3757-023 CMU coating and mortar

Interior Surfacing 06 ND

9096.1-3757-024 Roungh textured plaster ceiling/soffit

South entryway Surfacing 07 ND

9096.1-3757-025 Roungh textured plaster ceiling/soffit

North entryway Surfacing 07 ND

9096.1-3757-026 Roungh textured plaster ceiling/soffit

North perimeter soffit

Surfacing 07 ND

9096.1-3757-027 Roungh textured plaster ceiling/soffit

South perimeter soffit

Surfacing 07 ND

9096.1-3757-028 Roungh textured plaster ceiling/soffit

South perimeter soffit

Surfacing 07 ND

9096.1-3757-029 Un-textured GWB Kitchen area janitor closets

Misc. 08 ND

9096.1-3757-030 Un-textured GWB Kitchen area closets

Misc. 08 ND

9096.1-3757-031 2-x-4-foot ACT pin and crater pattern

South seating area Misc. 09 ND

9096.1-3757-032 2-x-4-foot ACT pin and crater pattern

North seating area Misc. 09 ND

9096.1-3757-033 2-x-4-foot ACT pin and crater pattern

Serving area Misc. 09 ND

November 2023 C-3 WJA Design Collaborative

9096.1-3757-034 6-inch brown cove base and mastic

North seating area Misc. 10 ND

9096.1-3757-035 6-inch brown cove base and mastic

North seating area Misc. 10 ND

9096.1-3757-036 Gray wood grain pattern flooring

North seating area Misc. 11 ND

9096.1-3757-037 Gray wood grain pattern flooring

North seating area Misc. 11 ND

9096.1-3757-038 4-inch ceramic wall tile grout/thin set

North restrooms Misc. 12 ND

9096.1-3757-039 4-inch ceramic wall tile grout/thin set

South restrooms Misc. 12 ND

9096.1-3757-040 White restroom fixture caulk

North restrooms Misc. 13 ND

9096.1-3757-041 White restroom fixture caulk

South restrooms Misc. 13 ND

9096.1-3757-042 White wall laminate caulk

Janitorial closet Misc. 14 ND

9096.1-3757-043 White wall laminate caulk

Janitorial closet Misc. 14 ND

9096.1-3757-044 Brown interior window frame caulk

East windows, south dining area

Misc. 15 ND

9096.1-3757-045 Brown interior window frame caulk

North windows, north dining area

Misc. 15 ND

9096.1-3757-046 Brown interior window frame caulk

South windows, south dining area

Misc. 15 ND

9096.1-3757-047 Brown interior door frame caulk

North entry/exit doors

Misc. 16 ND

9096.1-3757-048 Brown interior door frame caulk

South entry/exit doors

Misc. 16 ND

9096.1-3757-049 Brown exterior door frame caulk

North entry/exit Misc. 17 ND

9096.1-3757-050 Brown exterior door frame caulk

South entry/exit Misc. 17 ND

9096.1-3757-051 Exterior wall expansion joint-concrete to brick

North exterior Misc. 18 ND

9096.1-3757-052 Exterior wall expansion joint-concrete to brick

North exterior Misc. 18 ND

9096.1-3757-053 Brown exterior window frame caulk

South side, east exterior windows

Misc. 19 ND

November 2023 C-4 WJA Design Collaborative

9096.1-3757-054 Brown exterior window frame caulk

North side, east exterior windows

Misc. 19 ND

9096.1-3757-055 Windowpane to frame sealant

Exterior North side exterior windows

Misc. 20 ND

9096.1-3757-056 Windowpane to frame sealant

Exterior South side exterior windows

Misc. 20 ND

9096.1-3757-057 Windowpane to frame sealant

Exterior South dining area, East side windows

Misc. 20 ND

9096.1-3757-058 Brick mortar Exterior south Misc. 21 ND

9096.1-3757-059 Brick mortar Exterior north Misc. 21 ND

9096.1-3757-060 Brick mortar Exterior east-center

Misc. 21 ND

9096.1-3757-061 Metal fascia to brick flashing caulk

Exterior, north Misc. 22 ND

9096.1-3757-062 Metal fascia to brick flashing caulk

Exterior, south Misc. 22 ND

9096.1-3757-063 Gray door frame caulk- exterior

Mechanical room Misc. 23 ND

9096.1-3757-064 Gray door frame caulk- exterior

Mechanical room Misc. 23 ND

9096.1-3757-065 Rolled composition roofing and tar-parapet

Roof Misc. 24 ND

9096.1-3757-066 Rolled composition roofing and tar-parapet

Roof Misc. 24 ND

9096.1-3757-067 Rolled composition roofing and tar-parapet

Roof Misc. 24 ND

9096.1-3757-068 Silver paint coating and tar

Roof TSI 25 ND

9096.1-3757-069 Silver paint coating and tar

Roof TSI 25 ND

9096.1-3757-070 Silver paint coating and tar

Roof TSI 25 ND

9096.1-3757-071 Black tar on vents Roof Misc. 26 ND

9096.1-3757-072 Black tar on vents Roof Misc. 26 ND

9096.1-3757-073 White sealant on metal duct

AHU #6 east side of roof

Misc. 27 2% CHR

Re-analyzed by 400

Point Count to contain 1.25% CHR

November 2023 C-5 WJA Design Collaborative

9096.1-3757-074 White sealant on metal duct

AHU #6 east side of roof

Misc. 27 2% CHR

9096.1-3757-075 Gray sealant on metal duct

AHU #6 east side of roof

Misc. 28 ND

9096.1-3757-076 Gray sealant on metal duct

AHU #6 east side of roof

Misc. 28 ND

9096.1-3757-077 Plaster on windbreak wall

Roof Misc. 29 ND

9096.1-3757-078 Plaster on windbreak wall

Roof Misc. 29 ND

9096.1-3757-079 Plaster on windbreak wall

Roof Misc. 29 ND

9096.1-3757-080 Black tar sealant on windbreak wall metal post base

Roof Misc. 30 ND

9096.1-3757-081 Black tar sealant on windbreak wall metal post base

Roof Misc. 30 ND

9096.1-3757-082 Metal fascia to brick flashing caulk

North side above entry doors

Misc. 22 ND

9096.1-3757-083 6-inch mudded pipe fittings

Mechan…