B.08.02 Revised Final LEAD 370 Building Assessment Report.pdf

HAZARDOUS MATERIAL BUILDING ASSESSMENT

Building 370 Missile Maintenance Facility

Letterkenny Army Depot Chambersburg, Pennsylvania

Revised Final

Contract No. W912DR-18-D-0003

Delivery Order No. W912DR21F0354 Leidos CRN 339835

Prepared for:

U.S. Army Corps of Engineers

Baltimore District 2 Hopkins Plaza

Baltimore, Maryland 21201

Prepared by:

Leidos 1750 Presidents Street Reston, Virginia 20190

May 2022

THIS PAGE WAS INTENTIONALLY LEFT BLANK

CERTIFICATION 4

CONTRACTOR STATEMENT OF INDEPENDENT TECHNICAL REVIEW

Leidos has completed the Revised Final Hazardous Material Building Assessment Report for Building 370 at the Letterkenny Army Depot in Chambersburg, Pennsylvania. Notice is hereby given that an independent technical review has been conducted that is appropriate to the level of risk and complexity inherent in the project as defined in the Leidos Quality Assurance Plan. During the independent technical review, compliance with established policy principles and procedures, using justified and valid assumptions, was verified. This included review of assumptions, methods, procedures, and materials used in analyses; the appropriateness of data used and the level of data obtained; and reasonableness of the results, including whether the product meets the customer’s needs consistent with the law and existing Corps policy.

May 18, 2022 Lisa Jones-Bateman, PMP, REM Project Manager

Date

Joseph E. Peters QA/QC Officer

Fernando Padilla Independent Technical Review Team Leader

Significant concerns and explanation of the resolutions are documented within the project file.

As noted above, all concerns resulting from independent technical review of the project have been considered.

John R. Carter, III, P.G., PMP Leidos Senior Program Manager

LEAD Hazardous Material Building Assessment v Building 370 Assessment Report May 2022

TABLE OF CONTENTS

EXECUTIVE SUMMARY .................................................................................................................. ES-1

1. INTRODUCTION AND FACILITY DESCRIPTION ............................................................... 1-1

1.1 INTRODUCTION ................................................................................................................. 1-1

1.2 FACILITY BACKGROUND ................................................................................................ 1-1

1.3 BUILDING DESCRIPTION AND INFORMATION ........................................................... 1-1

1.4 HAZARDOUS MATERIALS SURVEY .............................................................................. 1-1

2. HAZARDOUS MATERIAL SURVEY METHODOLOGY ...................................................... 2-1

2.1 ASBESTOS ............................................................................................................................ 2-1

2.2 LEAD-BASED PAINT .......................................................................................................... 2-1

2.3 PCBs....................................................................................................................................... 2-2

2.4 MERCURY SURVEY ........................................................................................................... 2-2

2.5 MOLD VISUAL INSPECTION AND SAMPLING ............................................................. 2-2

2.6 INACCESSIBLE AND LIMITED-ACCESS AREAS .......................................................... 2-2

3. AREA A SURVEY RESULTS ...................................................................................................... 3-1

3.1 AREA A ASBESTOS ............................................................................................................ 3-1

3.1.1 ACM Samples ........................................................................................................... 3-1

3.1.2 ACM Summary ......................................................................................................... 3-3

3.2 AREA A LEAD-BASED PAINT .......................................................................................... 3-4

3.2.1 LBP Samples ............................................................................................................. 3-4

3.2.2 LBP Summary ........................................................................................................... 3-5

3.3 AREA A PCBs ....................................................................................................................... 3-5

3.4 AREA A MERCURY ............................................................................................................ 3-5

3.5 AREA A MOLD VISUAL INSPECTION AND SAMPLING RESULTS ........................... 3-6

3.5.1 Visual Inspection ....................................................................................................... 3-6

3.5.2 Tape Lift Samples ..................................................................................................... 3-6

3.5.3 Mold Summary .......................................................................................................... 3-7

4. AREA B SURVEY RESULTS ...................................................................................................... 4-1

4.1 AREA B ASBESTOS ............................................................................................................ 4-1

4.1.1 ACM Samples ........................................................................................................... 4-1

4.1.2 ACM Summary ......................................................................................................... 4-2

4.2 AREA B LEAD-BASED PAINT .......................................................................................... 4-3

4.2.1 LBP Samples ............................................................................................................. 4-3

4.2.2 LBP Summary ........................................................................................................... 4-6

4.3 AREA B PCBs ....................................................................................................................... 4-7

4.4 AREA B MERCURY ............................................................................................................ 4-7

4.5 AREA B MOLD VISUAL INSPECTION AND SAMPLING RESULTS ........................... 4-7

4.5.1 Visual Inspection ....................................................................................................... 4-7

4.5.2 Tape Lift Samples ..................................................................................................... 4-8

4.5.3 Mold Summary .......................................................................................................... 4-9

5. AREA C SURVEY RESULTS ...................................................................................................... 5-1

5.1 AREA C ASBESTOS ............................................................................................................ 5-1

5.1.1 ACM Samples ........................................................................................................... 5-1

5.1.2 ACM Summary ......................................................................................................... 5-2

5.2 AREA C LEAD-BASED PAINT .......................................................................................... 5-2

5.2.1 LBP Samples ............................................................................................................. 5-2

5.2.2 LBP Summary ........................................................................................................... 5-4

5.3 AREA C PCBs ....................................................................................................................... 5-4

LEAD Hazardous Material Building Assessment vi

TABLE OF CONTENTS (Continued)

5.4 AREA C MERCURY ............................................................................................................ 5-4

5.5 AREA C MOLD VISUAL INSPECTION AND SAMPLING RESULTS ........................... 5-5

5.5.1 Visual Inspection ....................................................................................................... 5-5

5.5.2 Tape Lift Samples ..................................................................................................... 5-6

5.5.3 Mold Summary .......................................................................................................... 5-6

6. AREA D SURVEY RESULTS ...................................................................................................... 6-1

6.1 AREA D ASBESTOS ............................................................................................................ 6-1

6.1.1 ACM Samples ........................................................................................................... 6-1

6.1.2 ACM Summary ......................................................................................................... 6-2

6.2 AREA D LEAD-BASED PAINT .......................................................................................... 6-2

6.2.1 LBP Samples ............................................................................................................. 6-2

6.2.2 LBP Summary ........................................................................................................... 6-3

6.3 AREA D PCBs ....................................................................................................................... 6-3

6.4 AREA D MERCURY ............................................................................................................ 6-3

6.5 AREA D MOLD VISUAL INSPECTION AND SAMPLING RESULTS ........................... 6-4

6.5.1 Visual Inspection ....................................................................................................... 6-4

6.5.2 Tape Lift Samples ..................................................................................................... 6-4

6.5.3 Mold Summary .......................................................................................................... 6-5

7. WASTE STREAM CHARACTERIZATION ............................................................................. 7-1

8. LIMITATIONS .............................................................................................................................. 8-1

9. REFERENCES ............................................................................................................................... 9-1

LEAD Hazardous Material Building Assessment vii

LIST OF APPENDICES

APPENDIX A. Licenses APPENDIX B. Survey Checklists B.1 Floor Plans and Hazardous Material Locations B.2 Asbestos Survey Checklist B.3 Lead-Based Paint Survey Checklist B.4 PCBs and Mercury Survey Checklist B.5 Mold Survey Checklist APPENDIX C. Analytical Data C.1 Eurofins Laboratory Asbestos Data C.2 XRF Lead-Based Paint Data C.3 Eurofins TCLP Data C.4 Eurofins Laboratory Mold Data APPENDIX D. Remediation Area Drawings

LEAD Hazardous Material Building Assessment viii

LIST OF FIGURES

Figure 1-1. Building 370 Location ....................................................................................................... 1-3

LIST OF TABLES

Table 1-1. Survey Team Staff ............................................................................................................. 1-2 Table 3-1a. Summary of ACM Detections in Area A .......................................................................... 3-2 Table 3-1b. Estimated ACM Quantities on or above Ceiling in Room A125 ...................................... 3-3 Table 3-2. Summary of ACM Management Corrective Actions in Area A ....................................... 3-3 Table 3-3. Summary of LBP Detections in Area A ............................................................................ 3-4 Table 3-4. Summary of Mercury Survey in Area A ........................................................................... 3-6 Table 3-5. Area A Tape Lift Sample Results ...................................................................................... 3-7 Table 4-1. Summary of ACM Detections in Area B ........................................................................... 4-2 Table 4-2. Summary of ACM Management Corrective Actions in Area B ........................................ 4-3 Table 4-3. Summary of LBP Detections in Area B ............................................................................ 4-4 Table 4-4. Summary of Mercury Survey in Area B ............................................................................ 4-7 Table 4-5. Area B Tape Lift Sample Results ...................................................................................... 4-9 Table 5-1. Summary of ACM Detections in Area C ........................................................................... 5-1 Table 5-2. Summary of ACM Management Corrective Actions in Area C ........................................ 5-2 Table 5-3. Summary of LBP Detections in Area C ............................................................................ 5-3 Table 5-4. Summary of Mercury Survey in Area C ............................................................................ 5-5 Table 5-5. Area C Tape Lift Sample Results ...................................................................................... 5-6 Table 6-1. Summary of ACM Detections in Area D .......................................................................... 6-1 Table 6-2. Summary of ACM Management Corrective Actions in Area D ....................................... 6-2 Table 6-3. Summary of LBP Detections in Area D ............................................................................ 6-2 Table 6-4. Summary of Mercury Survey in Area D ........................................................................... 6-3 Table 6-5. Area D Tape Lift Sample Results ...................................................................................... 6-4

LEAD Hazardous Material Building Assessment ix

LIST OF ACRONYMS AND ABBREVIATIONS

ACM Asbestos-Containing Material AHERA Asbestos Hazard Emergency Response Act AHU Air Handling Unit DPW Department of Public Works ECEI Eurofins Carolina Environmental, Inc.

ELLE Eurofins Laboratories Lancaster Environmental FLB Fluorescent Light Ballast HVAC Heating, Ventilation, and Air Conditioning LBP Lead-Based Paint LEAD Letterkenny Army Depot LED Light-Emitting Diode LF Linear Feet O&M Operation and Maintenance P.E. Professional Engineer PCB Polychlorinated Biphenyl P.G. Professional Geologist PLM Polarized Light Microscopy PMP Project Management Professional QA Quality Assurance QC Quality Control REM Registered Environmental Manager RH Relative Humidity TCLP Toxicity Characteristic Leaching Procedure UL Underwriters Laboratory USACE U.S. Army Corps of Engineers USEPA U.S. Environmental Protection Agency WWII World War II XRF X-Ray Fluorescence

LEAD Hazardous Material Building Assessment ES-1

EXECUTIVE SUMMARY

Leidos has been contracted by the

U.S. Army Corps of Engineers (USACE), Baltimore District to perform a hazardous material survey and facility evaluation for Building 370 at the Letterkenny Army Depot (LEAD) located in Chambersburg, Pennsylvania.

This work is being performed in accordance with USACE, Baltimore District Contract Number W912DR-18-D-0003, Delivery Order Number W912DR21F0354. The hazardous material survey identified locations and quantities of asbestos-containing material (ACM), lead-based paint (LBP), mercury-containing devices, polychlorinated biphenyls (PCBs) in light ballasts, and the presence of mold in Building 370.

Building 370 is the approximately 350,000-ft2 Missile Maintenance Facility. The building consists of four areas that were constructed between 1955 and the mid-1980s.

Contaminants identified at Building 370 were ACM, mold, LBP, mercury-containing devices, and suspect PCB ballasts. The recommendations and approximate hazardous material quantities identified during the survey and data evaluation are as follows:

• ACM was identified in thermal system insulation; various floor tiles and/or associated mastic;

window glazing compound; mastic on heating, ventilation, and air conditioning (HVAC) duct insulation; and cementitious wallboard. The fire doors throughout the building are assumed to be ACM; however, further inspection of the fire doors by the abatement contractor prior to demolition and disposal activities is required to determine if they contain asbestos. The locations and approximate quantities of ACM for removal and disposal are summarized by area in Tables 3-1a and 3-1b, 4-1, 5-1, and 6-1.

• LBP was detected throughout Building 370 on structural components (i.e., I-beam columns, crossmembers, bracing, brackets, trusses, purlins, girts), one window, floor grates, fixed ladders and catwalks, cranes and crane tracks, door frames, curbing, bollards, floor markings, pallet stands, railings, bumpers, and the battery charging station and trolley. The locations and approximate quantities of LBP are summarized by area in Tables 3-3, 4-3, 5-3, and 6-3. The Army indicated that most of these building components with LBP will remain in the building, and abatement is proposed for building components with LBP in poor condition.

• Twenty suspect PCB-containing fluorescent light ballasts (FLBs) were identified in Building 370 in Areas A and D. These ballasts could not be inspected because they were inaccessible. The FLBs should be removed and disposed of in accordance with all applicable Federal, state, and local regulations prior to renovation activities.

• The mercury survey identified 4 thermostats, 7 mercury vapor lamps, and approximately 4,950 fluorescent lamps as mercury-containing devices, as summarized in Tables 3-4, 4-4, 5-4, Building 370 Missile Maintenance Facility

CONTAMINANTS IDENTIFIED

Asbestos Mold Lead-Based

Paint

Mercury PCBs

LEAD Hazardous Material Building Assessment ES-2 and 6-4. These devices should be removed and recycled or disposed of in accordance with all applicable Federal, state, and local regulations prior to renovation activities.

• The mold growth and water damage observed in Building 370 was limited and would not require special handling during planned renovation activities beyond standard practices for renovation work. At the time of the survey in 2021, the roof was in the process of being replaced in Areas A, B, and C, and once it is confirmed that leaks have been repaired, the approximately 3,300 ft2 of water staining on concrete walls and floors, or condensation marks on the ceiling, should be cleaned and sanitized. The Army indicated that air diffusers, return grilles, and ductwork would be replaced with the installation of new HVAC systems and that the water-stained ceiling tiles and water-damaged insulation should be replaced.

LEAD Hazardous Material Building Assessment 1-1

1. INTRODUCTION AND FACILITY DESCRIPTION

1.1 INTRODUCTION

Leidos has been contracted by the U.S. Army Corps of Engineers (USACE), Baltimore District to perform a hazardous material building assessment to characterize and quantify contaminants for Building 370 at the Letterkenny Army Depot (LEAD) in Chambersburg, Pennsylvania. This work is being performed in accordance with the USACE, Baltimore District Contract Number W912DR-18-D-0003, Delivery Order Number W912DR21F0354. The delivery order was awarded on September 2, 2021.

This Hazardous Materials Assessment Report documents the results of the survey for Building 370.

The following work plans governed the hazardous material building assessments: the Final Project Management Plan/Quality Control Plan for the Hazardous Material Building Assessment, Building 370 Missile Maintenance Facility, Letterkenny Army Depot (Leidos 2021a) and the Final Accident Prevention Plan for the Hazardous Material Building Assessment, Building 370 Missile Maintenance Facility, Letterkenny Army Depot (Leidos 2021b).

1.2 FACILITY BACKGROUND

Established in 1941 at the onset of World War II (WWII), Letterkenny was 1 of 12 ordnance depots assigned with the mission of stockpiling war material. Letterkenny was selected based on proximity to rail lines, the industrial centers in the Great Lakes states, and the ports of the Eastern Seaboard. The depot was rapidly constructed, and Letterkenny soon became one of the largest depots in the United States with 798 underground igloos; 12 aboveground magazines; 17 warehouses; and 21,000 acres for the housing and shipment of ammunition, trucks, and combat equipment (LEAD 2021).

After WWII, the flow of supplies reversed, and Letterkenny Ordnance Depot had the task of storing millions of tons of supplies, both from the operating production centers and from returning forces. Storing thousands of active shells and other munitions, some of which were serviceable, was high on the list of priorities. All equipment stockpiled needed to be inspected, secured, and safe-tied, and what was not useful tagged for disassembly and in some cases destroyed (LEAD 2021).

Letterkenny was not confirmed as a permanent military installation until 1954 and was renamed Letterkenny Army Depot in August 1962. From the 1950s onward, LEAD evolved to keep up with current events and technological advancements. Its mission expanded to include maintenance, supply, and ammunition; missile maintenance and air defense; and overhaul of artillery, tactical vehicles, and tanks.

During the 1980s, the depot was the largest repair center for the Hawk system, as well as the Center for Technical Excellence. LEAD currently is the Army’s Center of Industrial and Technical Excellence for Air Defense and Tactical Missile Ground Support Equipment, Mobile Electric Power Generation Equipment, and Patriot Missile Recertification (LEAD 2021).

1.3 BUILDING DESCRIPTION AND INFORMATION

Building 370 is the Missile Maintenance Facility and occupies approximately 350,000 ft2. Figure 1-1 shows the Building 370 location. The original part of the building, Area A, was constructed in 1955. Areas B, C, and D were subsequently added to Building 370, with all additions completed by the mid-1980s.

Building 370 is built on concrete slabs with structural steel supports and a flat roof. At the time of the survey in 2021, the Building 370 roof in Areas A, B, and C was being replaced and included removing the existing roof to the decking and installing all new materials. Areas A, B, and C have high bay areas with overhead rollup doors. Portions of Areas B and C have a second floor.

1.4 HAZARDOUS MATERIALS SURVEY

The objective of the building assessment is to characterize and quantify hazardous material that would interfere with the progress and schedule of any planned renovation activities and/or represent life safety

LEAD Hazardous Material Building Assessment 1-2 concerns. In addition, a Specifications Package to address the handling, removal, and disposal of the hazardous materials identified was prepared and submitted under separate cover. The following hazardous material items were assessed: asbestos-containing material (ACM), lead-based paint (LBP), polychlorinated biphenyls (PCBs) in fluorescent light ballasts, mercury-containing devices, and the presence of mold. In addition, in accordance with the scope of work, samples of building materials with LBP, as determined based on the results of the X-ray fluorescence (XRF) survey, were collected for toxicity characteristic leaching procedure (TCLP) lead analysis.

Prior to the assessments, Leidos performed a facility records review and met with LEAD points of contact to discuss concerns with building systems. Relevant information from the records review and onsite interviews during the surveys is included in Sections 3 through 6, where applicable to the survey conditions and results.

The Building 370 assessment was conducted between November 1 and 18, 2021, and revisits occurred on December 7, 2021, to gather additional data about a subset of LBP sampling locations and on May 4 and 5, 2022, to collect additional asbestos data. Table 1-1 lists the Leidos Team staff who conducted the surveys. The survey methodology is described in Section 2. The surveys and findings are described in Sections 3 through 6, and the results of the TCLP sampling are included in Section 7. Applicable staff licenses are presented in Appendix A.

Table 1-1. Survey Team Staff Name Role Relevant Licenses and Training

Dana Winslow Survey Team Lead Lead Inspector Technician, Mold Inspection and Assessment Training

John Whelpley Survey Technician and Site Safety and Health Officer

P.E., Asbestos Inspector License (PA), Lead Inspector Technician (PA), Mold Inspection and Assessment Training

Lindsey Moyer Survey Technician Mold Inspection and Assessment Training Gabrielle Gromofsky Survey Technician Lead Inspector Training Tom Adams Survey Technician USEPA LBP Risk Assessor James McCully Survey Technician Asbestos Inspector License (PA)

LEAD Hazardous Material Building Assessment 1-3

Building 370

DATE: 11/29/2021FIGURE: 1-1

PROJECT: \GIS_DATA\GIS_DATA\Building HAZMAT Surveys\Letterkenny\ Figure 1-1 Base Map.mxd

BUILDING 370 LOCATION

LETTERKENNY ARMY DEPOT

CHAMBERSBURG, PENNSYLVANIA

Service Layer Credits: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan, Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC,

(c) OpenStreetMap contributors, and the GIS User Community

0 500 1,000 1,500 2,000250 Feet

³

LEAD Hazardous Material Building Assessment 2-1

2. HAZARDOUS MATERIAL SURVEY METHODOLOGY

Hazardous material surveys of the interior of Building 370 were conducted to identify the following hazards: ACM, LBP, PCBs, mercury-containing devices, and the presence of mold. The scope of the survey did not include the building exterior envelope or the roof. Based on consultation with and feedback from USACE and LEAD, assessments of paint booths, blast booths, the Kardex Remstar vertical storage modules, dip tanks, and the equipment/parts racks in Area D were not included in the surveys. Although the project scope included surveys of outbuildings and sheds within 10 feet of the building, no such structures were present to survey. The building was occupied during the survey, and samples were collected only in areas where sampling activities did not pose a hazard to LEAD personnel working in the building.

Floor plans showing locations of hazardous materials identified during the survey are included in Appendix B. For purposes of the surveys and this report, Leidos amended the floor plans to assign unique room identifiers for each Building 370 space. These room identifiers are included in Appendix B.

2.1 ASBESTOS

A survey of Building 370 was conducted for asbestos and included physical assessments and sampling of suspect ACM from accessible areas. Building 370 was inspected for materials or products that were suspected to contain asbestos. This information was used to document the existence of and to quantify ACM in the building. The survey data were used to assess the condition, location, and other characteristics of the potential ACM identified during the inspection and quantify the ACM that needs to be removed before renovation.

Potential ACM was evaluated by the collection and analysis of samples of suspect ACM. All suspect ACM was physically touched to determine if it was friable (i.e., material which, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure). Bulk samples were selected from each type of suspect construction material from locations throughout the functional space.

Eurofins Carolina Environmental, Inc. (ECEI) evaluated bulk samples with polarized light microscopy (PLM) to determine the presence of regulated asbestos materials. A homogeneous area was determined to contain ACM based on a finding that laboratory analysis of at least one sample collected from that area showed that asbestos was present in an amount greater than 1 percent.

The laboratory separated the building materials into individual component layers for analysis. For example, sample AB-A123-01-03 (consisting of white floor tile with attached yellow mastic) was separated into tile and mastic layers prior to laboratory analysis.

2.2 LEAD-BASED PAINT

The Federal Government banned consumer uses of lead-containing paint in 1978 due to health concerns. The LBP survey locations were selected in Building 370 based on the testing combinations observed, consisting of the room equivalents (e.g., offices, corridors, stairways), room components (e.g., floors, walls, doors, windows), and substrates (e.g., brick, concrete, wood, drywall). Some components were grouped together as needed (e.g., parts of a window frame). The goal of the LBP survey was to evaluate all homogeneous areas.

A Thermo Scientific Niton XLp 300 XRF analyzer was used to provide immediate analytical results for onsite analyses of the presence of LBP. Lead measurements were taken to determine if lead was present in the paint in excess of 1.0 mg/cm2. In addition, the condition of the LBP surfaces were assessed generally following the Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing

(HUD 2012).

LEAD Hazardous Material Building Assessment 2-2

2.3 PCBs

Surveys/inspections of fluorescent light ballasts (FLBs) in each type of accessible light fixtures were conducted to determine if the light fixtures contain PCBs. Sampling was not conducted as part of the PCB evaluation. The following criteria recommended by the U.S. Environmental Protection Agency (USEPA) for identifying the PCB-containing FLBs in school buildings (USEPA 2018) were used during the visual inspection to determine if the FLBs contain PCBs:

• Only T12 magnetic FLBs, not T8 or T5 electronic FLBs, may contain PCBs. The “T” designates tubular-shaped lamps, and the number after the “T” represents the diameter in eighths of an inch.

• FLBs manufactured before July 1, 1979, may contain PCBs.

• FLBs manufactured between July 1, 1979 and July 1, 1998, that do not contain PCBs must be labeled “No PCBs.”

• If an FLB is not labeled “No PCBs,” it will be assumed it contains PCBs unless it is known to be manufactured after 1979.

• FLBs manufactured after 1998 are not required to be labeled and do not contain PCBs.

Fluorescent fixtures containing T12 and T8 lamps were surveyed/inspected using a ballast discriminator to determine if the ballasts were electronic or magnetic. Although T8 fixtures do not use PCB-containing ballasts, T8 lamps fit in T12 fixtures; therefore, T8 fixtures were surveyed in the event that T8 lamps were present in T12 fixtures. Ballast discriminators examine the light frequency being emitted from the targeted light. Ballasts that are electronic will emit a frequency of 15 kHz or greater, which is read by the discriminator as a signal of 30 kHz or greater (as light is not polarized, the frequency is doubled) and indicated by the discriminator with a green light-emitting diode (LED) light. Ballasts that are magnetic will emit a frequency significantly lower and be indicated by the ballast discriminator with an orange/red LED light. If the ballast was electronic, it does not contain PCBs. If the ballast was magnetic, which may or may not contain PCBs, a visual inspection was conducted.

2.4 MERCURY SURVEY

As part of the building assessment survey, building devices that may contain mercury were observed and recorded. Sampling was not conducted as part of the mercury assessment. The survey was limited to noting the presence of fluorescent lighting, liquid thermometers (e.g., thermostats containing mercury), gauges, exit signs with fluorescent lighting, and other equipment that may contain mercury. If the presence of mercury in a building device could not be confirmed, the item was noted as potentially containing mercury, and no further evaluation was conducted. If mercury was present, the approximate quantity of items (e.g., number of fluorescent lamps) was recorded.

2.5 MOLD VISUAL INSPECTION AND SAMPLING

An inspection of the interior of Building 370 was conducted during the survey to identify suspect mold, water leaks, or other conditions that would contribute to or indicate mold growth and proliferation.

Accessible interior areas of the building where signs of water damage were observed and mold may be present were visually inspected. Tape lift samples were collected from areas of suspect mold growth or where visual inspection identified moisture intrusion, water damage, musty odors, and/or other conditions conducive to mold. Tape lift samples are used to confirm the presence of mold on suspect mold areas and to identify the genera of mold present on the surface.

2.6 INACCESSIBLE AND LIMITED-ACCESS AREAS

Only building materials that were accessible during the survey could be inspected and sampled. Areas that were inaccessible included the following:

LEAD Hazardous Material Building Assessment 2-3

• Inside walls and above fixed ceilings. This includes above the fixed gypsum drywall ceiling in Room A125. The area above the ceiling in this 22,500-ft2 room was only accessible from Mechanical Room A213 with only a limited view of the ceiling space from this room.

• Enclosed pipe and duct chases.

• Inside mechanical and electrical equipment.

• Foundation.

• Rooms A113 and A119 in Area A and the food storage area in Area B were locked and surveyed from the wire-caged door or door window, which allowed for a visual inspection. The ACM team was able to access Room A113 on a later day of the survey.

• The crawl space located under Restrooms A104 and A105 was visually inspected from the access hatch in Mechanical Room A101.

• Approximately 123 fire doors from eight different manufacturers were identified during the survey of Building 370, as shown in Appendix B. This included 19 fire doors in Area A, 40 in Area B, 61 in Area C, and 3 in Area D. Door hardware was removed from representative doors, but the interior of the doors could not be accessed for inspection without damaging the doors. In addition, the Underwriters Laboratory (UL) label on the door hinges did not provide a date of construction. The fire doors were not sampled to avoid causing irreparable damage to these functional building components. It is assumed that the 123 fire doors are ACM. Further inspection of the fire doors by the abatement contractor prior to demolition and disposal activities is required to determine if they contain asbestos.

Surveys of the inaccessible areas should be performed prior to any proposed renovations or maintenance involving these building components.

LEAD Hazardous Material Building Assessment 3-1

3. AREA A SURVEY RESULTS

Hazardous material surveys of the interior of Area A were conducted to identify the following hazards: ACM, LBP, PCBs, mercury-containing devices, and the presence of mold. The penthouse mechanical room located on the roof above Area A was included in the survey. Floor plans showing locations of hazardous materials identified during the survey are included in Appendix B. For purposes of the surveys and this report, Leidos amended the floor plans to assign unique room identifiers for each Building 370 space. These room identifiers are included in Appendix B.

3.1 AREA A ASBESTOS

Prior to the survey, USACE provided Leidos with asbestos sampling results from surveys completed by others in December 1993 (Dames & Moore 1993) and April 2021 (Boggs 2021). These reports were reviewed and potential ACM was resampled based on the survey team’s professional judgment.

3.1.1 ACM Samples

During the asbestos survey, 96 building material samples of suspect ACM were collected from Area A. These 96 building material samples included all accessible suspect ACM building material types at Area A, including:

• Thermal system insulation (pipe insulation and elbows)

• Thermal system insulation end cap mastic

• Heating, ventilation, and air conditioning (HVAC) duct mastic

• Wall insulation

• Seam sealant

• Pipe sealant

• Wall and floor penetration sealant

• Ceiling tile

• Vibration collar

• Cove base mastic

• Door insulation

• Floor tile and flooring with associated mastic

• Fiberboard

• Drywall and joint compound

• Caulk

• Window glazing compound

• Expansion joint material.

Descriptions of the 96 building material samples are provided in Appendix B. The Damage Assessment and Exposure Assessment for each building material using the protocols in the Army ACM Checklist is also included in Appendix B. The laboratory analytical results for the building material component layers are provided in Appendix C. The drawing showing areas requiring remediation is included in Appendix D.

Building materials found to be ACM based on sampling or suspect asbestos materials determined to be the same as the sampled materials are summarized in Table 3-1a. The analytical results indicate that all samples that were positive contained chrysotile asbestos, which is the most commonly encountered form of asbestos that was used in buildings in the United States. Several samples also contained amosite asbestos, as summarized below. The friability of these building material samples is summarized in Table 3-1a.

LEAD Hazardous Material Building Assessment 3-2

Table 3-1a. Summary of ACM Detections in Area A Building

Material Type Location Estimated Quantity

Associated Sample Numbers

ACM

Concentration Friability

Insulation on 3-inch-diameter cold water pipes

A109, A115, A125, A213, and High Bay

350 LF of 3-inch-diameter pipes

AB-AHB-03

AB-A125-02

AB-A115-01

65% chrysotile Friable

Insulation on 4-inch-diameter steam pipes

Radioactive Material Room and A108

10 LF of 4-inch-diameter pipes

AB-RAD-01

AB-A108-02

AB-A108-06

15-33% chrysotile 2% amosite

Friable

Insulation on 5-inch-diameter pipes

A104, A107, and A109

80 LF of 5-inch-diameter pipes

AB-A107-01

AB-A109-02

AB-A104-03

15% chrysotile 20% amosite

Friable

Insulation on 6-inch-diameter pipes

A109 and A125 180 LF of 6-inch-diameter pipes

AB-A125-03

AB-A125-06

AB-A109-01

5-20% chrysotile 5-30% amosite

Friable

Insulation on 6-inch-diameter fittings

A109 Three 6-inch-diameter elbows

AB-A109-03

AB-A109-04

AB-A109-05

10-65% chrysotile 2% amosite

Friable

Insulation on 8-inch-diameter pipes

High Bay, A213, and above ceiling in A125

250 LF of 8-inch-diameter pipes;

see Table 3-1b

AB-A213-01

AB-A125-08

AB-A125-09

5% chrysotile 10-30% amosite

Friable

Window glazing compound

One window in shared wall between A115 and A116

12 LF in one 2- by 3-foot window

AB-A116-01

AB-A116-02

2% chrysotile Non-Friable

Green 9- by 9-inch and gray 9- by 9-inch floor tile

Vault, A113, A122, and under wall framing in A121

420 ft2 AB-Vault-01 AB-Vault-02

AB-A113-01

AB-A113-02

3-10% chrysotile (tile)

Non-Friable

Black mastic on 24- by 18-inch HVAC duct insulation

Above the ceiling in A125

Unable to estimate due to limited accessibility; see Table 3-1b

AB-A125-05

AB-A125-07

3% chrysotile Non-Friable

Fire doors Throughout Area A

12 single and 7 double 5- by

7-foot fire doors

Unable to inspect the interior of the doors without damaging their integrity

Assumed ACM --

Joint compound Ceilings in A106, A112, A114C, A115, A117, A120, A123, and A124

850 ft2 AB-A106-20

AB-A114C-20

2% chrysotile Friable

Room A125 occupies approximately 22,500 ft2 and has a drywall ceiling approximately 15 feet above the floor. The joint compound was identified as ACM during the limited ACM survey in Area A conducted by Boggs Environmental Consultants in April 2021. Leidos estimated 22,500 ft2 of joint compound on the ceiling of Room A125, as shown in Table 3-1b.

Leidos was able to access the area above the Room A125 ceiling via Mechanical Room A213 and observed thermal system insulation and black HVAC duct mastic as ACM but was unable to estimate the quantities of these materials due to limited accessibility. The 1993 and April 2021 surveys also noted the present of this ACM and limited accessibility. The 1993 report provided estimated quantities, which are summarized in Table 3-1b.

LEAD Hazardous Material Building Assessment 3-3

Table 3-1b. Estimated ACM Quantities on or above Ceiling in Room A125 Building

Material Type Location Estimated Quantity Source Joint compound A125 ceiling 22,500 ft2 Sampled by Boggs 2021, estimate based on floor plans Insulation on 2- to 4-inch-diameter pipes Above A125 ceiling 620 LF Dames & Moore 1993

Insulation on 6- to 8-inch-diameter pipes Above A125 ceiling

620 LF Dames & Moore 1993

Insulation on 6- to 8-inch-diameter fittings Above A125 ceiling

50 elbows Dames & Moore 1993

Black mastic on HVAC duct insulation Above A125 ceiling

1,600 LF of 24- by 18-inch fiberglass insulation*

Dames & Moore 1993

*Dames & Moore 1993 states “there is approximately 1,600 LF of material.” Leidos assumes this measurement refers to the actual ductwork.

3.1.2 ACM Summary

ACM was identified in Area A in thermal system insulation, window glazing compound, 9- by 9-inch floor tiles, joint compound on ceilings, and HVAC duct mastic. The fire doors are assumed to be ACM.

The thermal system insulation and joint compound on ceilings is friable, and the other identified ACM located during the survey is non-friable. The identified ACM is intact and in fair to good condition. As of the time of the survey, ACM does not present an immediate hazard to the building occupants.

Each inspected ACM building material received a Damage Assessment and Exposure Assessment using the Army ACM Checklist, as shown in Appendix B. These numbers were used to determine the Army Recommended Management Corrective Action using the Army Risk Assessment Matrix, as shown in Table 3-2. None of the ACM identified had an Army Assessment Index of A (Immediate Action) or B (Action as Soon as Possible).

Table 3-2. Summary of ACM Management Corrective Actions in Area A

Building Material Type Location

Damage Assessment

Exposure Assessment

Army Recommended Management Corrective

Actions Insulation on 3-inch-diameter cold water pipes

A109, A115, A125, A213, and High Bay

9 9 C Initiate an O&M program.

Removal should be scheduled as part of the normal repair and maintenance cycle of the facility.

Insulation on 4-inch-diameter steam pipes

Radioactive Material Room and A108

7 9 C Initiate an O&M program.

Removal should be scheduled as part of the normal repair and maintenance cycle of the facility.

Insulation on 5-inch-diameter pipes

A104, A107, and A109 7 9 C Initiate an O&M program.

Removal should be scheduled as part of the normal repair and maintenance cycle of the facility.

LEAD Hazardous Material Building Assessment 3-4

Table 3-2. Summary of ACM Management Corrective Actions in Area A (Continued) Building

Material Type Location Damage

Assessment Exposure

Assessment Army Recommended

Management Corrective Actions Insulation on 6-inch-diameter pipes

A109 and A125 7 9 C Initiate an O&M program. Removal should be scheduled as part of the normal repair and maintenance cycle of the facility.

Insulation on 6-inch-diameter fittings

A109 9 9 C Initiate an O&M program. Removal should be scheduled as part of the normal repair and maintenance cycle of the facility.

Insulation on 8-inch-diameter pipes

High Bay, A213, and above ceiling in A125

10 7 C Initiate an O&M program. Removal should be scheduled as part of the normal repair and maintenance cycle of the facility.

Window glazing compound

One window in shared wall between A115 and A116

2 11 C Initiate an O&M program. Removal should be scheduled as part of the normal repair and maintenance cycle of the facility.

Green 9- by 9-inch and gray 9- by 9-inch floor tile

Vault, A113, A122, and under wall framing in A121

4 11 C Initiate an O&M program. Removal should be scheduled as part of the normal repair and maintenance cycle of the facility.

Black mastic on HVAC duct insulation

Above the ceiling in A125

3 6 D Schedule removal when practical and cost-effective.

Joint compound Ceilings in A106, A112, A114C, A115, A117, A120, A123, and A124

2 12 C Initiate an O&M program. Removal should be scheduled as part of the normal repair and maintenance cycle of the facility.

3.2 AREA A LEAD-BASED PAINT

3.2.1 LBP Samples

A total of 148 XRF readings were taken in Area A of Building 370, as shown in Appendix B.

Eight samples tested positive for the presence of LBP, as shown in Appendix C. These building components, their condition, and their estimated quantities are summarized in Table 3-3.

Table 3-3. Summary of LBP Detections in Area A Painted

Component Description Paint Color Condition Location

Associated Sample

Numbers

Highest XRF Reading (mg/cm2)

Estimated Quantity

Window, including frame and casing (wood)

White Intact One window in shared wall between A115 and A116

XRF-A116-01

2.0 One 33- by

46-inch window

LEAD Hazardous Material Building Assessment 3-5

Table 3-3. Summary of LBP Detections in Area A (Continued) Painted

Component Description

Paint Color Condition Location

Associated Sample

Numbers

Highest XRF Reading (mg/cm2)

Estimated Quantity

Pallet stands (metal)

Yellow Fair Room A125, grid coordinate E5.5

XRF-A125-02 1.6 Four stands with 4.5- by 5-foot platform, 30-inch height

Stair treads (metal)

Black and yellow

Poor Area A High Bay western loading dock stairs

XRF-AHB-13

XRF-AHB-14

5.4 Six stair treads

3 inches by 3 feet each

Curbing (metal) Red and gray

Fair Area A High Bay, between each of the six overhead doors

XRF-AHB-20 1.0 40 LF of 6-inch curbing

Railing (metal) Yellow

Poor Area A High Bay loading dock

XRF-AHB-24 2.6 26 LF of 3-inch-diameter railing Bumper (wood) Blue

(yellow under blue)

Fair Area A High Bay loading dock

XRF-AHB-25 7.9 42 ft2

Bollards (metal) Yellow Intact 12 bollards on the exterior of Area A High Bay

XRF-Exterior-01 5.0 61 LF of 6-inch-diameter bollard

3.2.2 LBP Summary

LBP was detected in Area A on one wood window, metal pallet stands, metal stair treads, metal curbing, metal railing, one wood bumper, and metal bollards. The stair treads and railing in the Area A High Bay loading dock are in poor condition and require remediation if they are not being removed as part of building renovation activities. The drawing showing areas requiring remediation is included in Appendix D.

3.3 AREA A PCBs

A representative of each type of light fixture containing T12 and T8 lamps encountered within Area A was inspected with the ballast discriminator to determine if it, and each of the fixtures identical to it, contained PCBs. Survey results are included in Appendix B. As a result of the survey/inspection, 12 magnetic ballasts were identified in Room A118; however, the ballasts had “no PCB” labels and do not contain PCBs. Sixteen inactive fluorescent fixtures are located in the plenum above Room A118. These fixtures were not connected to electricity, and they were inaccessible and could not be inspected.

Presumably, these fixtures were not removed during lighting upgrades. Further inspection of these 16 fixtures is required to determine if they contain PCBs. If the ballasts contain PCBs, they should be removed and disposed of in accordance with all applicable Federal, state, and local regulations prior to renovation activities. The drawing showing areas requiring remediation is included in Appendix D.

3.4 AREA A MERCURY

The presence of building devices potentially containing mercury was based solely on visual observations. If the presence of mercury in a building device could not be confirmed, the item was noted as potentially containing mercury, and no further evaluation was conducted. If mercury was present, the approximate quantity of items (e.g., number of fluorescent lamps) was recorded.

Approximately 1,370 fluorescent lamps containing mercury are in Area A, as shown in Appendix B and summarized in Table 3-4. No mercury-containing thermostats or other devices were found during the

LEAD Hazardous Material Building Assessment 3-6 survey. These materials should be removed and recycled or disposed of in accordance with all applicable Federal, state, and local regulations prior to renovation activities. The drawing showing areas requiring remediation is included in Appendix D.

Table 3-4. Summary of Mercury Survey in Area A Location Number of Devices Mercury-Containing Devices Area A 1,370 Fluorescent lamps

3.5 AREA A MOLD VISUAL INSPECTION AND SAMPLING RESULTS

3.5.1 Visual Inspection

The observations from the Area A visual inspection are discussed below. The mold survey checklist, with additional details and floor plans showing the location of identified mold and water staining, are provided in Appendix B.

Limited areas of water damage and suspect mold growth were observed in Area A. The more significant water damage was observed under windows on exterior walls. The windows in Room A108 and the Radioactive Material Area were replaced 2 years ago and the occupant stated they no longer leak, but water staining was observed under the windows. Water-stained ceiling tiles were observed in a few rooms, but all tiles were dry at the time of the survey. Room A110 had the most water-stained ceiling tiles, and these ceiling tiles were primarily along the walls of the room where Area A is connected to Areas B and C.

Ductwork and piping were above the drop ceiling in Room A110, but no active leaks were observed.

The insulation in Room HIPAR2 was intact but bowing, which appeared to be from a roof leak. Water staining also was observed above the rollup door on the southwestern wall of Room HIPAR2. A building occupant in Room HIPAR1 stated the roof was replaced over Room HIPAR1 in the spring of 2021 but not over Room HIPAR2. The occupant noted that before the roof was replaced, the ceiling in Room HIPAR1 was wet and a musty or moldy smell was noticeable throughout the room. The occupant stated the roof insulation was removed and contained mold. Hallway A100, outside Room HIPAR1, had water staining marks on the floor, but no obvious signs of mold and no water staining down the northern metal wall were observed. Room A101/P36A had rusted trusses and joists throughout the entire room, but no water staining was observed on the floor. Room A101/P36A is a mechanical area with high humidity and temperature fluctuations. Suspect mold growth was observed in a large basin sink in Room A101/P36A, but a sample could not be collected because the faucet was dripping and the area was wet.

Dust and dirt accumulation and suspect mold growth were observed in…