Attachment D - Final ACM and LBP Survey_ Base San Juan.pdf

Base San Juan Hurricane Rebuild West and Central Locations

Project No. 10878158 USCG Base San Juan, PR

Attachment D Limited Lead-Based Paint & Asbestos-Containing

Material Buildings 100, 101, 103, 125 & 126

AECOM

Final Report

LIMITED LEAD-BASED PAINT

AND ASBESTOS-CONTAINING MATERIAL

SURVEY FOR BUILDINGS 100, 101, 103,

125 AND 126.

ARCHITECTURAL/ENGINEERING SERVICES

FOR

DD1391 PLANNING PROPOSAL/PROJECT PROPOSAL

REPORT FOR HURRICANE EXECUTION PLAN-SHORE

AT U.S. COAST GUARD SECTOR SAN JUAN

SAN JUAN, PR

CG SFRL P/N 07-11062507

UNITED STATES COAST GUARD

SECTOR SAN JUAN

SAN JUAN, PR

April 12, 2019 i

TABLE OF CONTENTS

EXECUTIVE SUMMARY

DISCLAIMER

1.0 INTRODUCTION

1.1 REGULATORY BACKGROUND

1.1.1 Asbestos-Containing Materials

1.1.2 Lead Based Paint

1.2 DISPOSAL OF LEAD BASED PAINT AND ASBESTOS CONTAINING

MATERIALS

1.2.1 Lead Based Paint Disposal Requirements

1.2.2 Asbestos Disposal Requirements

2.0 SURVEY AND SAMPLING PROCEDURES

2.1 SURVEYED SITES

2.1.1 Sampling for Asbestos Content Determination

2.1.2 Sampling for Lead-Based Paint

2.1.3 Analytical Laboratory

3.0 RESULTS

3.1 Lead-Based Paint Sampling Results

3.2 Asbestos Containing Materials Sampling Results

4.0 CONCLUSIONS AND RECOMMENDATIONS

4.1 Conclusions

4.2 Recommendations

5.0 LIMITATIONS

TABLES

TABLE 1-A LEAD ANALYSIS RESULTS (BLD. 100)

TABLE 1-B LEAD ANALYSIS RESULTS (BLD. 101)

TABLE 1-C LEAD ANALYSIS RESULTS (BLD. 103)

TABLE 1-D LEAD ANALYSIS RESULTS (BLD. 125)

TABLE 1-E LEAD ANALYSIS RESULTS (BLD. 126)

TABLE 1-F LEAD ANALYSIS RESULTS (POSITIVE RESULTS)

TABLE 2-A ASBESTOS ANALYSIS RESULTS (BLD. 100)

TABLE 2-B ASBESTOS ANALYSIS RESULTS (BLD. 101)

TABLE 2-C ASBESTOS ANALYSIS RESULTS (BLD. 103)

TABLE 2-D ASBESTOS ANALYSIS RESULTS (BLD. 125)

TABLE 2-E ASBESTOS ANALYSIS RESULTS (BLD. 126)

Results Report

Limited Lead-Based Paint & Asbestos-Containing Material Survey ii

APPENDIXES

APPENDIX A FIGURES

APPENDIX B PHOTOGRAPHIC LOG (LBP & ACM Surveyed Structures)

APPENDIX C LABORATORY RESULTS

APPENDIX D LABORATORY ACCREDITATIONS

APPENDIX E AECOM PERSONNEL ACCREDITATION

US Coast Guard—Sector San Juan

April 12, 2019

EXECUTIVE SUMMARY

AECOM Caribe, LLP (AECOM) was retained by the United States Coast Guard (USCG) to perform a Limited Asbestos and Lead-Based Paint (LBP) Survey at five buildings scheduled for demolition/remodeling as part of the response to the impacts caused by the Hurricane Maria. The mentioned buildings are located in the USCG facility identify as Sector San Juan in the municipality of San Juan, Puerto Rico. The surveyed structures are being evaluated for remodeling or demolition to provide space for the construction of new facilities at the referenced coast guard site.

The purpose of this survey is to identify the presence or not of ACM and LBP in the buildings scheduled for remodeling or demolition. This survey report includes a brief description of the structures, field sampling protocols, analytical methods and limitations, summary of findings, and recommendations.

Sampling activities were conducted during November 28 - 30, 2018. The sampling points were determined based on field observation of suspect materials, painted areas and in accordance with the scope of work and the protocols recommended for investigation and sampling inspections.

The structures were evaluated to identify the presence of Suspect Asbestos Containing Materials

(SACM) and Lead-Based Paint (LBP) materials. After performing the evaluation, and based upon professional judgment and experience, forty-four (44) bulk ACM samples were taken due to the presence of Suspect Asbestos-Containing Material (SACM), and fifty (50) LBP samples were taken due to the presence of Suspect Lead-Based Paint in the referenced structures. The surveyed structures were identified as Bld. 100, Bld. 101, Bld. 103, Bld. 125 and Bld. 126.

The collected samples and prepared chain of custody sheets were delivered to AES International, Inc. which is a local accredited laboratory for the analysis of ACM and LBP samples. Samples for asbestos content were analyzed by PLM, (EPA Method 600/R-93/116). Paint chip samples were analyzed for detection of lead in paint chips using EPA SW-846 Method 7420 by Flame

Atomic Absorption Spectroscopy (AAS). Based on the survey results obtained the following is concluded:

o Lead-Based Paint (LBP) was detected in three of the surveyed structures: in one paint sample collected from Bld. 100, in one paint sample collected from Bld. 125 and in one paint sample collected from Bld. 126. No LBP was detected in the samples collected from Bld. 101 and Bld. 103.

o According to the preliminary survey findings, LBP Abatement activities are required for the removal of the lead-based paint prior to the start of renovation or demolition activities in the areas where LBP was found. After abatement activities are completed, the debris

April 12, 2019 from the demolition can be disposed as non-hazardous, in an authorized industrial landfill. Prior to final disposal, a Toxicity Characteristic Leaching Procedure (TCLP) composite paint sample shall be collected in order to determine if the material is hazardous or not.

o None of the bulk samples collected in the surveyed structures was detected with asbestos fibers. Construction materials samples are defined to be asbestos containing if the total asbestos fibers content determined from PLM analysis method is greater than 1% f/cc.

o According to the preliminary survey findings, no ACM abatement activities are recommended at the evaluated buildings prior to the start of any remodeling or demolition activity in the site.

DISCLAIMER

This report is prepared by AECOM for the express use and benefit of USCG, its agents and employees. The information in this report or portions thereof may be required to be included in notifications to employees, contractors or other visitors to the Site. This report is not intended to be used as a specification or work plan for any of the work suggested or recommended in this report.

This report is based upon conditions and practices observed at the property the date of site visit and information made available to the surveyor. This report does not intend to identify all hazards or unsafe practices, or to indicate that other hazards or unsafe practices do not exist at the premises.

April 12, 2019

1.0 INTRODUCTION

AECOM Caribe, LLP (AECOM) was retained by the United States Coast Guard (USCG) to perform a Limited Asbestos and Lead-Based Paint (LBP) Survey at five buildings scheduled for remodeling or demolition as part of the response to the impacts caused by the Hurricane Maria.

The mentioned buildings are located in the USCG facility identify as Sector San Juan in the municipality of San Juan, Puerto Rico. The surveyed structures are being evaluated for remodeling or demolition to provide space for the construction of new facilities at the referenced coast guard site.

The purpose of this survey is to identify the presence or not of ACM and LBP in the buildings scheduled for remodeling or demolition (see Figures 1 and 2 in Appendix A for Topographic

Map and surveyed building location).

Sampling activities of this survey were conducted during November 28 - 30, 2018. The sampling points were determined based on field observation of suspect materials, painted areas and in accordance with the protocols recommended for sampling inspections. The structures were evaluated to identify the presence of Suspect Asbestos Containing Materials (SACM) and Lead-

Based Paint (LBP) materials.

The survey is a working document designed to effectively manage waste disposal and minimize asbestos and lead based paint-related health risks during removal or demolition activities to personnel working on the subject site located in the municipality of San Juan, Puerto Rico. This report presents a description of the scope, methods and protocols, results of chemical analyses, conclusions and recommendations.

1.1 REGULATORY BACKGROUND

1.1.1 Asbestos Containing Building Materials

The term asbestos describes six naturally occurring fibrous minerals found in certain types of rock formations. Among that group, the minerals chrysotile, amosite, and crocidolite have been most commonly used in building products such as floor tile, pipe insulation, boiler insulation, and plasters. The minerals anthophyllite, actinolite and tremolite are not frequently found in ACBM. Asbestos can be found in numerous building materials. If maintained intact and undisturbed ACBM do not pose a health risk. They may, however, become a health hazard if they are damaged, disturbed, or deteriorate over time and release fibers into the air.

Asbestos materials can be classified as friable and non-friable. A friable Asbestos-

Containing Building Material (ACM) is defined as any material that contains more than 1% asbestos, and that it is friable by hand pressure in its dry state. A Non-Friable

April 12, 2019

ACM is any material that contains more than 1% asbestos and that in its dry state it is not friable by hand pressure. EPA has further divided Non Friable ACM as

Categories I and II.

There are two EPA regulations governing asbestos, the Asbestos Hazard Emergency

Response Act (AHERA) and the National Emission Standards for Hazardous Air

Pollutants (NESHAP). AHERA (Title 40 CFR Part 763) was enacted by the Congress in 1986, which mandated a regulatory program to address the asbestos hazards in schools. Subsequently, on November 28, 1990 the Congress enacted the Asbestos

School Hazard Abatement Reauthorization Act (ASHARA) which expanded the requirements of AHERA to persons who work with asbestos in public and commercial buildings, as well as schools.

As per requirements of the Clean Air Act (CAA) of 1970, EPA promulgated

NESHAP (Title 40 CFR Part 61) on April 1973. NESHAP is intended to minimize the release of asbestos fibers during certain activities (i.e., installations, renovations, and demolitions). The NESHAP regulation also requires owners and operators to notify delegated State and local agencies and/or the regional EPA offices before demolition or renovation activities begin. In addition, NESHAP requires the removal of all friable ACBM prior to demolition.

The Occupational Safety and Health Administration (OSHA), and delegated States are responsible for regulating environmental exposure and protecting workers from asbestos exposure. OSHA requires owners of pre-1981 buildings to assume that all suspects ACBM is asbestos-containing until a survey is performed.

1.1.2 Lead-Based Paint

Lead-Based Paint (LBP) is defined as any paint or other surface coatings with a concentration equal or greater than 1.0 milligram per square centimeter of lead, when the analysis is conducted on site with an X-Ray Fluorescence Detector, or 0.5 percent by weight when the analysis is conducted using Atomic Absorption (AA) by an external laboratory. Equivalent units are 5,000 ug/g, 5,000 mg/kg or 5,000 ppm by weight. Surface coatings include paint, shellac, varnish, or any other coating, including wallpaper which covers painted surfaces.

The USEPA has proposed that LBP is a hazard when:

There are more than 2 square feet of damaged paint at interior surfaces

(walls, roofs, floors and doors);

More than 10 square feet of the same at exterior surfaces; and, April 12, 2019

More than 10% of the surface total of all components with small surface areas such as window sills, window wells, trim, baseboards, etc.

1.2 DISPOSAL OF LEAD-BASED PAINT AND ASBESTOS-CONTAINING

MATERIAL

1.2.1 Lead Based Paint Disposal Requirements

The Puerto Rico Environmental Quality Board allows the disposal of lead based paint abated from structures in authorized, Non-Hazardous waste industrial landfills.

Likewise, lead-based paint containing debris can be disposed as non-hazardous waste, provided the waste has been tested for non-hazardous characteristics by a certified analytical laboratory.

1.2.2 Asbestos Disposal Requirements

Asbestos waste or debris must be promptly disposed of at an approved disposal site.

Disposal of asbestos must follow EPA's National Emissions Standards for Hazardous

Air Pollutants (NESHAP) 40 CFR part 61, subpart M. The EPA's Asbestos Waste

Management Guidance offers useful information disposal. The rule requires:

Methods to contain asbestos waste (wet, double-bagged).

Procedures for hauling waste. Asbestos must not leak from the containers used to haul it.

Disposal of asbestos containing material in an authorized landfill.

Landfilling is the environmentally preferred method of asbestos disposal because asbestos fibers are immobilized by soil. Asbestos cannot be safely incinerated or chemically treated for disposal.

Formal record keeping of asbestos waste disposal.

Puerto Rico’s Industrial Landfill Facilities are permitted by the Puerto Rico

Environmental Quality Board to receive and dispose Asbestos-Containing Materials, as long as these are not mixed with, or contain hazardous constituents as defined by

RCRA.

April 12, 2019

2.0 SURVEY AND SAMPLING PROCEDURES

2.1 SURVEYED SITES

Suspect ACM and LBP samples were collected from all the buildings scheduled for remodeling or demolition located within the study area. A brief description of the surveyed structures is presented below.

a- Building 100: This structure is also identified as the Operations Building and consists of a two-story building of approximately 10,970 square feet in the first floor and 8,770 in the second level. The first floor is currently occupied by personnel of Mariner Licensing and Prevention. The second floor is partially occupied by personnel of Response and Command Center Planning. Due to the impacts of Hurricane Maria, part of second floor is unoccupied.

b- Building 101: This structure is identify as Vessel Support Building and consists of a two-story building of approximately 8,260 square feet per story. The first floor of this building is being used by personnel of the Maintenance

Augmentation Team of the Coast Guard.

c- Building 103: This structure consists of a one-story building of approximately

7,800 square feet. It’s being used for offices and other relative uses.

d- Building 125: This structure consists of a one-story building of approximately

3,500 square feet. It’s being used as a Health Services Center for the coast guard personnel.

e- Building 126: This structure consists of a two-story building of approximately

3,900 square feet per story. The first floor is being used as Servicing Personnel

Office (SPO), Work-Life Family Advocacy, Command Security Office, Education Service Office and Transportation Office. The second floor is being used as Commanding Officer of Military Personnel, Administrative Officer, Personnel Officer, Legal Office and Chaplain Office.

Based on the observations made during the site reconnaissance, all the structures were evaluated and sampled as follows:

Painted components of the evaluated structures were sampled and analyzed to determine the presence or not of lead in paint chips.

April 12, 2019

The suspect material observed in the structures scheduled for remodeling or demolition was sampled to determine the presence or not of asbestos fibers in them.

Photographic logs of surveyed structures to identify the presence or not of LBP and ACM is included in Appendix B.

2.1.1 Sampling for Asbestos Content Determination

Sampling for ACM was conducted following EPA-recommended applicable guidelines. The procedure used for sampling suspect materials was designed to minimize possible fiber release. Samples of representative suspect materials were collected in accordance with the EPA guidelines and procedures presented in “Guide for Controlling Asbestos Containing Material in Buildings”. Once the suspect material was identified, it was sprayed with water.

Then a representative sample of the material was collected and placed in an airtight bag. The bagged sample was properly labeled and stored. If any debris was generated during sampling it was properly cleaned.

A chain of custody form was completed for the bulk samples collected; samples were delivered to the analytical laboratory for analysis using Polarized Light Microscopy

(PLM). Chains of Custody and analytical results are included in Appendix C.

2.1.2 Sampling for Lead-Based Paint

A standard method for collecting paint chip samples was followed. Several Standards have been provided:

ASTM E 1729, Standard Practice for Field Collection of Dried Paint

Samples for Lead Determination by Atomic Spectrometry Techniques.

The paint chip collection protocol in Appendix 13.2 of the 1995 HUD

Guidelines.

ASTM E 1645, Standard Practice for the Preparation of Dried Paint

Samples for Subsequent Lead Analysis by Atomic Spectrometry, is a related standard that may also be consulted regarding the preparation of paint chip samples for laboratory analysis. Paint samples should be selected and collected by a PREQB-Certified Lead Inspector. All layers of paint in the area selected shall be collected, with enough samples to run the anticipated test method.

April 12, 2019

The results may be reported in either, percent by weight, milligrams of lead per square centimeter or in micrograms of lead per gram, or both.

If results are to be reported in milligrams per square centimeter, sample must be taken within a demarcated area of 100 cm , and all the paint within that area must be removed for testing.

Results in milligrams per square centimeter are usually not affected by including any material underneath the paint.

To obtain each paint-chip sample, a minimum area of approximately one square inch was scored using a knife. The collected samples were placed in Zip-Lock Type re-sellable plastic bags, labeled and delivered to the laboratory for analysis. All samples were properly documented using the chain of custody form with the corresponding sample number. Chains of Custody and analytical results are included in Appendix

C. Samples were analyzed using EPA Method 7420/6010.

2.1.3 Analytical Laboratory

AES International, Inc. was retained by AECOM to conduct the asbestos and Lead-

Based Paint analyses. EMSL Accreditation documents are included in Appendix D.

3.0 RESULTS

3.1 LEAD BASED PAINT SAMPLING RESULTS

In each of the five structures, at least ten samples of paint were collected. Results indicate that Lead-Based Paint was found in three of the sampled structures. Laboratory results are presented in Appendix C. The location of the subject structures is illustrated in

Figure 2, Appendix A.

1- Building 100 – Only one of ten (10) samples collected from this structure was found with LBP. Sample USCG-B100-LBP-06, light yellow paint located at room

121 in the first floor was found with 3.90 % weight of lead.

2- Building 101 – None of ten (10) samples collected from this structure was found with LBP.

3- Building 103 – None of ten (10) samples collected from this structure was found with LBP.

April 12, 2019

4- Building 125 – Only one of ten (10) samples collected from this structure was found with LBP. Sample USCG-B125-LBP-09, concrete yellow paint located at the north exterior wall was found with 4.71 % weight of lead.

5- Building 126 – Only one of ten (10) samples collected from this structure was found with LBP. Sample USCG-B126-LBP-04, concrete white paint located at the wall of the porch in the second floor was found with 4.71 % weight of lead.

Tables 1-A to 1-E shows a summary of the lead-based paint results for each building.

TABLE 1-A

LEAD-BASED PAINT ANALYSIS RESULTS

BUILDING 100

US COAST GUARD- SECTOR SAN JUAN

# SAMPLE ID SAMPLE DESCRIPTION/ LOCATION LEAD RESULTS

(% wt) 1 USCG-B100-LBP-01 Bone white Paint – Exterior Wall <0.010

2 USCG-B100-LBP-02 Textured Paint - Exterior Wall <0.010

3 USCG-B100-LBP-03 Interior Wall Paint – 1 st floor - Corridor <0.010

4 USCG-B100-LBP-04 Red Paint -Steel beam- Room 103 0.035

5 USCG-B100-LBP-05 Green Paint – Interior Wall – Room 119 0.132

6 USCG-B100-LBP-06 Light Yellow Paint- Interior Wall – Room 121 3.90

7 USCG-B100-LBP-07 Light Blue Paint - Interior Wall – Room 213 0.116

8 USCG-B100-LBP-08 Interior Wall Paint – Room 231 <0.010

9 USCG-B100-LBP-09 Metal door Paint – Entrance Room 203 <0.010

10 USCG-B100-LBP-10 Bone white Paint – Interior Wall – 1 st floor -

Corridor

<0.010

Note: Results in red indicates presence of lead-based paint.

TABLE 1-B

BUILDING 101

(% wt)

1 USCG-B101-LBP-01 Metal Door Paint – Room 110 <0.010

2 USCG-B101-LBP-02 Concrete Floor Paint – 1 st floor- Room 109 <0.010

3 USCG-B101-LBP-03 Concrete Wall Paint – 1 st floor – Near entrance <0.010

4 USCG-B101-LBP-04 Dark Gray Paint – Concrete Wall paint – Room

109-112

<0.010

5 USCG-B101-LBP-05 Traffic Yellow Paint – 1 st floor- Stairs and pipes <0.010

6 USCG-B101-LBP-06 Concrete Wall Paint – 2 nd floor – Entrance <0.010

April 12, 2019

US COAST GUARD- SECTOR SAN JUAN

# SAMPLE ID SAMPLE DESCRIPTION/ LOCATION LEAD RESULTS

(% wt)

7 USCG-B101-LBP-07 Concrete Wall Paint – 2 nd floor – Corridor Room

<0.010

8 USCG-B101-LBP-08 Stairs Paint – Near Room 216 <0.010

9 USCG-B101-LBP-09 Concrete Wall Paint – 2 nd floor –East Exterior

Wall

<0.010

10 USCG-B101-LBP-10 Bone white Paint - Concrete West Exterior Wall <0.010

TABLE 1-C

BUILDING 103

(% wt)

1 USCG-B103-LBP-01 Light Gray Paint – Concrete Wall – Corridor 113 <0.010

2 USCG-B103-LBP-02 Dark Gray Paint – Metal Door Frame - Room 111 <0.010

3 USCG-B103-LBP-03 Metal Door Paint – Corridor Room 101 <0.010

4 USCG-B103-LBP-04 White Paint – Gypsum board Wall- Room 108 <0.010

5 USCG-B103-LBP-05 Dark Gray Floor Paint – Room 119 <0.010

6 USCG-B103-LBP-06 Light Gray Floor Paint – Room 130 <0.010

7 USCG-B103-LBP-07 White Paint – Concrete Wall – Room 129 <0.010

8 USCG-B103-LBP-08 Frame/ Metal Door Paint – Room 129 <0.010

9 USCG-B103-LBP-09 Concrete Wall Paint – East Exterior Wall <0.010

10 USCG-B103-LBP-10 Concrete Wall Paint – South Exterior Wall <0.010

TABLE 1-D

BUILDING 125

(% wt)

1 USCG-B125-LBP-01 Gypsum board Wall Paint – Corridor 117 <0.010

2 USCG-B125-LBP-02 Metal Door Paint – Corridor 117 <0.010

3 USCG-B125-LBP-03 Metal Frame /Door Paint – Corridor 117 <0.010

4 USCG-B125-LBP-04 Wall Paint – Room 122 <0.010

5 USCG-B125-LBP-05 White Wall Paint – Room 126 <0.010

6 USCG-B125-LBP-06 Bone white Wall Paint – Waiting Area Room 101 <0.010

7 USCG-B125-LBP-07 Concrete Wall Paint – Exterior Balcony <0.010

8 USCG-B125-LBP-08 Ceiling Plaster Paint - Exterior Balcony <0.010

April 12, 2019

US COAST GUARD- SECTOR SAN JUAN

# SAMPLE ID SAMPLE DESCRIPTION/ LOCATION LEAD RESULTS

(% wt)

9 USCG-B125-LBP-09 Concrete Wall Paint – North Exterior Wall 4.71

10 USCG-B125-LBP-10 Concrete Wall Paint – West Exterior Wall 0.015

TABLE 1-E

BUILDING 126

(% wt)

USCG-B126-LBP-01

Concrete Wall Paint- 1 st floor – South Exterior

Wall 0.120

2 USCG-B126-LBP-02 Concrete Wall Paint – 1 st floor – Storage Room 0.287

3 USCG-B126-LBP-03 Interior Wall Paint- 1 st floor – Arvelo Office <0.010

4 USCG-B126-LBP-04 Concrete Wall Paint- 2 nd floor - Porch 1.58

5 USCG-B126-LBP-05 Stairs and Floor Paint- 2 nd floor - Porch <0.010

6 USCG-B126-LBP-06 Interior Wall Paint- 2 nd

- floor - Office 0.011

7 USCG-B126-LBP-07 Beige Wall Paint – 2 nd floor - Corridor <0.010

8 USCG-B126-LBP-08 Stairs Paint – 2 nd floor - Exterior 0.012

9 USCG-B126-LBP-09 Stairs Paint – East Exterior Wall 0.017

10 USCG-B126-LBP-10 Concrete Wall Paint – North Exterior Wall 0.288

TABLE 1-F

LEAD ANALYSIS RESULTS (POSITIVES)

US COAST GUARD - SAN JUAN SECTOR

# SAMPLE ID SAMPLE DESCRIPTION/ LOCATION APPROXIMATE

AREA (FT2)

Building 100

1 USCG-B100-LBP-06 Light Yellow Paint/ Interior Wall-Mechanical Room-R-121 150

Building 125

1 USCG-B125-LBP-09 Concrete Wall Paint/North Exterior Wall 250

Building 126

1 USCG-B126-LBP-04 Concrete Wall Paint/ 2 floor - Porch 300

3.2 ASBESTOS CONTAINING MATERIALS SAMPLING RESULTS

The limited survey laboratory results indicate that no asbestos containing materials were found in the sampled structures. Laboratory results are presented in Appendix C. The location of the subject structures is illustrated in Figure 2, Appendix A.

Tables 2-A to 2-E shows a summary of the ACM results for each building.

TABLE 2-A

ASBESTOS ANALYSIS RESULTS

BUILDING 100

US COAST GUARD- SECTOR SAN JUAN

# SAMPLE ID SAMPLE DESCRIPTION/ LOCATION ACM RESULTS

(% ASBESTOS)

USCG-B100-ACM-01

Roofing Material-Black / Part of roof under reparation/replacement

ND

2 USCG-B100-ACM-02 Wall textured Material / Building Ext. walls ND

3 USCG-B100-ACM-03 12”X12” VFT, Gray with dots / R-100 & 101 ND

4 USCG-B100-ACM-04 AC Ducts insulation Material / R-103/1st Floor ND

5 USCG-B100-ACM-05 2’x2’ Acoustic panel / R-113 / 1st Floor ND

6 USCG-B100-ACM-06 2” Diam. Water pipe insulation-white / R-121/

1st Floor

ND

7 USCG-B100-ACM-07 12”X16” Ceramic floor tile-dark brown / R-103/

1st Floor

ND

8 USCG-B100-ACM-08 12”X16” Ceramic floor tile-ivory / R-227 & 231/

2nd Floor

ND

9 USCG-B100-ACM-09 AC Ducts insulation material / 2 nd

Floor, R-231 ND

10 USCG-B100-ACM-10 12”X12” VFT-gray / 2

Floor / R-231 ND

TABLE 2-B

BUILDING 101

# SAMPLE ID SAMPLE DESCRIPTION/ LOCATION ACM RESULTS

(% ASBESTOS)

1 USCG-B101-ACM-01 2’x2’ Ceiling Acoustic Panel with dots/ R-102 ND

2 USCG-B101-ACM-02 2’x2’ Ceiling Acoustic Panel-white / R-102 ND

3 USCG-B101-ACM-03 4”x4” Ceramic Wall tiles / R-104 ND

4 USCG-B101-ACM-04 2’x2’ Ceiling Acoustic Panel with dots/ R-104 ND

5 USCG-B101-ACM-05 AC Ducts insulation Material / Mezzanine ND

6 USCG-B101-ACM-06 Pipe insulation Material / Mezzanine ND

April 12, 2019

US COAST GUARD- SECTOR SAN JUAN

# SAMPLE ID SAMPLE DESCRIPTION/ LOCATION ACM RESULTS

(% ASBESTOS)

7 USCG-B101-ACM-07 12”x12” VFT- gray / R-112 ND

8 USCG-B101-ACM-08 Wall baseboard & mastic / R-112 ND

9 USCG-B101-ACM-09 12”x12” VFT- gray / R-203 / 2nd Floor ND

10 USCG-B101-ACM-10 12”x12” VFT- gray / R-200 /2nd Floor ND

TABLE 2-C

BUILDING 103

(% ASBESTOS)

1 USCG-B103-ACM-01 12” x 12” Vinyl Floor Tile Mastic / Room 110 ND

2 USCG-B103-ACM-02 2’ x 2’ Acoustic Panel / Room 114 ND

3 USCG-B103-ACM-03 Ceiling Panels / Corridor -near Room 114 ND

4 USCG-B103-ACM-04 Wall Baseboard / Room 104 ND

5 USCG-B103-ACM-05 Gypsum board- drywall panel / Room 111 ND

6 USCG-B103-ACM-06 2’ x 2’ Acoustic Panel / Room 122 ND

TABLE 2-D

BUILDING 125

(% ASBESTOS)

1 USCG-B125-ACM-01 Vinyl Flooring and Mastic / Corridor 117 ND

2 USCG-B125-ACM-02 Gypsum board- Drywall panel / Room 119 ND

3 USCG-B125-ACM-03 2’ x 2’ Acoustic Panel / white / Room 119 ND

4 USCG-B125-ACM-04 2’ x 2’ Acoustic Panel / Room 122 & 124 ND

5 USCG-B125-ACM-05 12” x 12” VFT and Mastic / Room 122 & 124 ND

6 USCG-B125-ACM-06 Wall Baseboard / Room 126 ND

7 USCG-B125-ACM-07 8” x 8” Ceramic Floor Tile-yellow / Room 104 ND

8 USCG-B125-ACM-08 Ceiling Spray Plaster –white / Balcony ND

9 USCG-B125-ACM-09 Wall Plaster- white / Garden Wall ND

10 USCG-B125-ACM-10 8” x 8” Ceramic Floor Tile / Room 123 (Electrical

Room)

ND

TABLE 2-E

BUILDING 126

(% ASBESTOS)

1 USCG-B126-ACM-01 8” x 8” Ceramic Floor Tile / 1 st floor- Porch ND

2 USCG-B126-ACM-02 Wall Baseboard and Mastic / 1 st floor – Storage

Room

ND

3 USCG-B126-ACM-03 8” x 8” Ceramic Floor Tile-under carpet - various colors / Storage Room (Break area)-1st Floor

ND

4 USCG-B126-ACM-04 8”x8” Ceramic Floor Tiles-yellow / 1 st floor – IT

Server Room

ND

5 USCG-B126-ACM-05 8” x 8” Ceramic Floor Tile-Green / 2 nd floor -

Porch

ND

6 USCG-B126-ACM-06 4” x4” Ceramic wall Tile / 2 nd floor - Bathroom ND

7 USCG-B126-ACM-07 2’ x 4’ Acoustic Panel / 2 nd floor - Bathroom ND

8 USCG-B126-ACM-08 Wall Baseboard – 2 nd floor / Corridor ND

Notes:

ND indicates that no asbestos fibers were detected in the analyzed samples. An Asbestos Containing Material (ACM) is one that contains 1% asbestos fibers or more.

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4.0 CONCLUSIONS AND RECOMMENDATIONS

4.1 CONCLUSIONS

Based on the results of the sampling program the following conclusions are made:

The survey revealed the presence of lead in paint above the regulatory threshold standard of 0.5 % by weight in three of the surveyed buildings (BLD. 100, Bld. 125 and Bld. 126).

The survey revealed that no Asbestos Containing Materials were detected in the surveyed buildings.

This was a limited survey, if doubts or questions arise regarding asbestos or lead content in or on areas that were not tested, then additional testing should be performed on those specific areas.

4.2 RECOMMENDATIONS

Based in the results of the screening survey, no ACM Abatement activities are required during remodeling or demolition activities in the surveyed structures.

LBP Abatement activities are recommended for the removal of the lead-based paint prior to the start of renovation or demolition activities in the areas where LBP was found. After abatement activities are completed, the debris from the demolition can be disposed as non-hazardous, in an authorized industrial landfill. Prior to final disposal, a Toxicity

Characteristic Leaching Procedure (TCLP) composite paint sample shall be collected in order to determine if the material is hazardous or not.

A notification shall be submitted to the PR Environmental Quality Board and the PR

Office of General Permits (OGPe) in order to apply and obtain a Demolition Permit prior to beginning demolition of referenced structures.

A copy of this Survey Report must be maintained on site during demolition activities.

APPENDIXES

APPENDIX A

Figures

APPENDIX B

Photographic Log

APPENDIX C

Laboratory Results

APPENDIX D

Laboratory Accreditations

APPENDIX E

AECOM Personnel Accreditation