MXRD_11-0077_-_Attach.3_-_CARDNO_Testing_Rpt.pdf
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- Multiple Award Construction Contract Indefinite Delivery Indefinite Quantity (MACC IDIQ) Request for Proposal (RFP) Federal contract opportunity
- Solicitation number
- FA2835-19-R-A041
About this file
This document summarizes the results of a hazardous building materials survey conducted at Building 1103 located at Hanscom Air Force Base in Bedford, Massachusetts. The survey identified various asbestos-containing materials throughout the building that will require abatement prior to demolition, including floor tile, floor tile mastic, and exterior paint. It also found lead paint on representative interior and exterior surfaces.
The survey further identified various hazardous materials requiring proper disposal, such as approximately 595 fluorescent light ballasts (all labeled as non-PCB), 1,520 fluorescent light bulbs containing mercury, one 80-gallon hydraulic elevator system reservoir that may contain PCBs, and approximately 11 refrigerant-containing pieces of equipment. It provides recommendations for developing abatement and disposal specifications, overseeing abatement work, and handling excluded PCB products. Limitations of the survey and materials sampling are also outlined.
FA2835-19-R-A041 Section J Attachment #11 MACC IDIQ B1103 Demolition Task Order Statement of Work Attachment #3
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HAZARDOUS BUILDING MATERIALS INSPECTION REPORT
HANSCOM AIR FORCE BASE
BUILDING # 1103
BEDFORD, MASSACHUSETTS
PREPARED FOR:
DEWBERRY
280 SUMMER STREET, 10TH FLOOR
BOSTON, MASSACHUSETTS 02210
PREPARED BY:
CARDNO ATC
600 WEST CUMMINGS PARK, SUITE 5450
WOBURN, MASSACHUSETTS 01801
CARDNO ATC PROJECT 060.75143.0015
MARCH 8, 2013
TABLE OF CONTENTS
1.0 EXECUTIVE SUMMARY ...................................................................................................................... I
1.1 ASBESTOS .................................................................................................................................................. I
1.2 LEAD DETERMINATION.............................................................................................................................. II
1.3 PCB, MERCURY AND OTHER HAZARDOUS MATERIALS SURVEY (OHM) ..................................................... II
2.0 ASBESTOS CONTAINING MATERIALS SURVEY
2.1 SAMPLING METHODOLOGY
Table 1: Summary of Identified Asbestos-Containing Materials
Table 3: Summary of Non-ACM
2.5 RECOMMENDATIONS
3.0 LEAD PAINT DETERMINATION
3.1 TESTING PROCEDURES - RMD LPA-1 XRF ANALYZER
3.2 SUMMARY OF FINDINGS
Table 4: Lead Paint Testing Results by XRF
3.3 REGULATORY IMPLICATIONS AND REGULATIONS
3.4 COST ESTIMATES
4.0 PCB, MERCURY AND OTHER HAZARDOUS MATERIALS (OHM) SURVEY
4.1 OBJECTIVE
4.2 SCOPE OF WORK
4.3 RESULTS
4.3.1 Light Ballasts
4.3.2 Fluorescent and High Intensity Discharge (HID) Light Bulbs
4.3.3 Other Potential PCB-Containing Equipment
4.3.4 Mercury-Containing Equipment
4.3.5 Aboveground Storage Tanks
4.3.6 Electronic Devices and White Goods
4.3.7 Other Hazardous Materials
4.4 ACCESS LIMITATIONS
4.5 CONCLUSIONS
4.6 LIMITATIONS
APPENDIX A: ASBESTOS BULK SAMPLE ANALYSIS RESULTS BY PLM
APPENDIX B: LIMITED PCB SEALANT SURVEY LETTER REPORT
Dewberry, Inc. Hazardous Building Materials Inspection Hanscom Air Force Base – Building # 1103 March 8, 2013
Cardno ATC Project No. 060.75143.0015 III
Limitations
Our professional services have been performed, our findings obtained and our recommendations prepared in accordance with customary principles and practices in the field of environmental science and engineering. This statement is in lieu of other statements either expressed or implied. This report does not warrant against future operations or conditions, nor does it warrant against operations or conditions present of a type or at a location not investigated.
Environmental evaluations are limited in the sense that conclusions and recommendations are developed and information obtained from limited research and secondary sources. Except as set forth in this report, Cardno ATC has made no independent investigations as to the accuracy or completeness of the information derived from the secondary sources and personal interviews and has presumed that such information was accurate and complete.
This report is intended for the sole use of Dewberry, Inc. The scope of services performed in execution of this evaluation may not be appropriate to satisfy the needs of other users, and use or re-use of this document or the findings, conclusions, or recommendations, is at risk of said user.
CERIFICATION OF RESULTS
This report has been prepared for the exclusive use of Dewberry, Inc. Photocopying of this document by parties other than those designated by the Client, or use of this document for purposes other than it is intended, is prohibited.
Respectfully submitted this 8th day of March, 2013.
Cardno ATC
Bryan Thompson Project Manager
David Mitchell Senior Project Manager
Dewberry, Inc. Hazardous Building Materials Survey
Cardno ATC Project No. 060.75143.0015 1
2.0 ASBESTOS CONTAINING MATERIALS SURVEY
2.1 Sampling Methodology
The survey was performed by an EPA-accredited and Commonwealth of Massachusetts DLS certified Asbestos Inspector between November 5, 2012 – February 28, 2013. Bulk samples, representing individual homogenous areas of suspect materials, were collected in a randomly distributed manner, in accordance with the methods outlined below.
Building materials exist in the form of thermal systems insulation (TSI), surfacing materials, and miscellaneous materials.
The following generally illustrates the sampling strategy employed by Cardno ATC where feasible:
(a) Surfacing materials - In a randomly distributed manner, collect bulk samples of surfacing materials, representative of each homogeneous area, and not assumed to be ACM.
(1) Collect at least three bulk samples from each homogeneous area that is less than or equal to 1,000 ft2.
(2) Collect at least five bulk samples from each homogeneous area that is greater than 1,000 ft2, but less than or equal to 5,000 ft2.
(3) Collect at least seven bulk samples from each homogeneous area that is greater than 5,000 ft2.
(b) Thermal systems insulation.
(1) In a randomly distributed manner, collect at a minimum, three (3) bulk samples of thermal systems insulation material, representative of each homogeneous area, and not assumed to be ACM.
(2) Collect, at a minimum, one (1) bulk sample of patched thermal systems insulation, representative of each homogenous area, and not assumed to be ACM, providing the section of patch was less than 6 linear or square feet.
(3) Collect, at a minimum, three (3) representative bulk samples of each insulated mechanical system not assumed to be ACM, including, but not limited to cementitious material used on pipe fittings such as tees, elbows, or valves.
Representative sampling was conducted in a manner sufficient as to identify whether each homogenous area is either asbestos or non-asbestos containing.
(4) Bulk samples are not required to be collected from any homogeneous area where the accredited asbestos inspector has determined that the thermal systems insulation is a non-suspect material (i.e., fiberglass, foam glass, rubber, or any other non-ACM).
(c) Miscellaneous materials - Collect, at a minimum, two (2) representative bulk sample of each miscellaneous material not assumed to be ACM, including, but not limited to ceiling tiles, floor tiles, associated floor tile mastic, roofing materials, waterproofing, etc.
Representative sampling was conducted in a manner sufficient as to identify whether each homogenous area is either asbestos or non-asbestos containing.
Cardno ATC Project No. 060.75143.0015 6
2.3 Analytical Method
Bulk samples of suspect materials were analyzed by ProScience Analytical Services, Inc., of Woburn, Massachusetts (ProScience) using the EPA approved method (EPA/600R-93/116) for polarized light microscopy with dispersion staining (PLM/DS), using the visual estimation technique for asbestos quantification. By using the PLM/DS method, a trained microscopist is able to identify and distinguish between asbestos group minerals and other fibrous materials such as cellulose (paper), mineral (rock), wood or glass fiber. The quantity of each of these substances is estimated on a weight basis and recorded as a percent. Only the asbestos content, if any, is recorded in the bulk sample ‘Report of Analysis’ (Appendix A). If a material contains 1% asbestos or greater, it is considered to be asbestos-containing material. Upon client request, or at the recommendation of the analyst, the ‘Point Counting Method’ may be used to verify the presence/absence of asbestos when a sample contains less than 10% asbestos by visual estimate.
ProScience is certified by the Massachusetts DLS (certification #AA 000156) to perform all types of asbestos analysis. ProScience, is also accredited by the EPA National Voluntary Laboratory Accreditation Program (NVLAP). The PLM/DS analytical method is modeled after 40 CFR Part 763, Subpart F, Appendix A: "Interim Method for the Determination of Asbestos in Bulk Insulation Samples."
2.4 Consideration for Hidden Materials
Cardno ATC conducted the asbestos survey in representative interior, exterior and roofing areas throughout Building # 1103, located at Hanscom Air Force Base, in Bedford, Massachusetts. Cardno ATC performed limited exploratory demolition in various locations throughout the building to the degree feasible to identify the presence of hidden ACM. Appropriate efforts were made in representative areas of the building, to identify multiple layers of flooring systems, as well as any suspect materials located within wall cavities, chases, plenums, and above suspended ceiling systems. The various roof areas were also sampled as a part of the inspection. Note that Cardno ATC did not disassemble mechanical equipment or electrical gear that may have suspect ACM internal components.
Cardno ATC recommends that if a suspect material has not been positively identified, but is similar in mode of occurrence or physical properties as other identified ACM, it should be considered asbestos containing. Only through further sampling and analysis should a suspect material be identified as non-asbestos.
2.5 Recommendations
Cardno ATC understands that demolition activities are planned for the building. All identified ACM that will be impacted by the planned demolition project should be properly removed and disposed by a Commonwealth of Massachusetts licensed Asbestos Contractor prior to disturbance.
In consideration that exterior paint in other areas throughout the facility has been identified to contain asbestos, Cardno ATC recommends that more extensive sampling of exterior paint be performed prior to demolition.
Cardno ATC recommends that precautions be taken to prevent unauthorized disturbance of identified ACM in this report.
Cardno ATC Project No. 060.75143.0015 7
Cardno ATC also recommends the following as part of the abatement process:
• Although the asbestos contractor is required to follow the requirements outlined in Federal, Massachusetts State, and local regulations regarding asbestos during any abatement project, Cardno ATC recommends the development of a project specification and the use of project oversight to ensure compliance with all applicable regulations as well as protect the interest of the client for all abatement work performed at the Site. The project specification shall reference the regulations pertinent to each project, including those work procedures that shall be followed by asbestos abatement personnel.
• As part of each abatement contractor bidding process, a unit price schedule for the abatement of asbestos-containing materials should be established. The unit price schedule should include costs for those materials identified within this report, as well as those materials that may potentially be uncovered during renovation/demolition activities.
Included should be unit prices for the removal of asbestos-containing materials (e.g., floor tile, floor tile mastic, gray duct sealant), as well as those non-asbestos-containing materials, which may be asbestos contaminated (i.e. carpeting, plywood, etc.).
• Project oversight will provide Dewberry, Inc with on-site technical expertise during all phases of the abatement work. Project oversight provides a constant management of the abatement project to ensure that all identified asbestos-containing materials are removed in accordance with all applicable regulations and to prevent an asbestos fiber release.
Tasks performed during project oversight should include periodic work inspections to ensure that all procedures employed by the abatement contractor are acceptable, and air monitoring around each work area to detect elevated asbestos fiber levels.
Cardno ATC Project No. 060.75143.0015 8
3.0 LEAD PAINT DETERMINATION
Cardno ATC performed a limited lead-containing paint (LCP) determination on representative interior and exterior painted surfaces that are to be impacted by demolition. The lead determination was performed by Cardno ATC’s Massachusetts licensed Lead Paint Inspector / Risk Assessor, Mr. Harold Springer (Lic. No.3041). The lead paint testing was performed via X-Ray Fluorescence (XRF) Analysis, using an RMD Lead Paint Analyzer.
3.1 Testing Procedures - RMD LPA-1 XRF Analyzer
The RMD Lead Paint Analyzer is a complete lead paint analysis system, which quickly, accurately and non-destructively measures the concentration of Lead Paint on surfaces. The RMD relies on the measurement of the L-shell and K-shell X-rays to determine the amount of lead present in the painted surface. K-shell X-rays can penetrate many layers of paint and allow a good measurement of the lead content of paint to be made without being significantly affected by the thickness or number of layers of paint on the surface of the sample. L-shell X-rays have less penetration and provide a measurement of the surface level lead content of paint.
The RMD has the ability to analyze and compute corrections for the differences in the energy spectrums relating to different substrates. This analysis of the energy spectrum means that the lead paint reading displayed on the instrument already accounts for any substrate effects and no correction is required by the operator.
Upon arrival at the job site, a “validation test” was performed to assure that the instrument was operating properly. A series of three test measurements using the nominal time which was used during the inspection were taken on the NIST Paint Film Standard (SRM No. 2579) as required by the instrument’s Performance Characteristic Sheet (PCS). The individual readings and an average of the three readings were recorded and compared to the standards. In all cases the instrument was functioning within the standard deviation as defined by the manufacturer and the PCS. All validation readings were recorded in the field data of each unit where validation tests were performed. If for any reason the XRF does not pass the quality control procedures, it is Cardno ATC’s policy to replace that instrument with an XRF that passes the above criteria for calibration.
3.2 Summary of Findings
The following XRF readings are in milligrams per square centimeter (mg/cm2). Readings above 0.0 have been highlighted.
Cardno ATC Project No. 060.75143.0015 13
4.0 PCB, MERCURY AND OTHER HAZARDOUS MATERIALS (OHM) SURVEY
A hazardous materials survey was conducted on November 8, 2012, by Mr. Amorelli. The survey consisted of a visual inspection of accessible interior and exterior areas of the Site building, which is currently vacant and scheduled for demolition.
4.1 Objective
The objective of the hazardous materials survey was to evaluate for the presence of PCB-containing ballasts and electrical equipment, mercury-containing electrical components, refrigerant-containing equipment, equipment that could contain chemicals, and other potential hazardous materials including chemicals or unlabeled containers that may require disposal as part of the demolition of the Site building.
Sealants (i.e., caulk and glazing) suspected to contain PCBs were sampled and submitted for laboratory PCB analysis. The results of the limited PCB sealant survey are discussed in a separate report.
4.2 Scope of Work
The survey was an evaluation of the above-ground portions of the Site building based on visual assessment of the building. During the survey, each accessible area was visually inspected for the presence of hazardous materials that will require proper disposal prior to demolition activities. Cardno ATC inspected interior and exterior building locations that could be accessed from the ground and the roof for potentially hazardous materials. Potential hazardous materials observed during the survey were visually inspected and the item, condition, quantity, and location were noted. The results of the survey are noted in the following section. The scope of work for this project did not include inspection of the Site for the presence of underground tanks or other underground structures that may contain hazardous materials.
The limited PCB sealant survey is discussed in a separate report.
4.3 Results
A list of potentially hazardous materials or items suspected to contain hazardous materials, as observed during the survey, is included in Section 4.5.
Certain electrical components such as resistors, small dry-type transformers, and computer circuit boards do not contain large quantities of hazardous materials but their recycling is encouraged by government agencies. Larger white goods and electrical components should be recycled per applicable local, state, and federal regulations.
A summary of several main categories of items containing or suspected to contain hazardous materials is included in the following subsections.
4.3.1 Light Ballasts
Light fixture ballasts manufactured prior to 1979 may contain small quantities of PCBs. Light ballasts manufactured after 1979 do not contain PCBs and those manufactured between 1978 and 1998 were required to have “No PCBs” labels. Light ballasts that do not have “No PCBs” labels, unless known to be manufactured since 1998, should be treated as PCB-containing and handled/disposed of accordingly.
Alternatively, for light ballasts that do not have “No PCBs” labels, the manufacturer may sometimes be contacted to ascertain the presence of PCBs.
Cardno ATC Project No. 060.75143.0015 14
Cardno ATC estimates the total number of ballasts at the Site to be approximately 595. Cardno ATC inspected various fluorescent light ballasts during the survey. Based on the results of the inspection, Cardno ATC estimates that all ballasts are labeled as “No PCBs”. Ballasts that are not labeled are presumed to contain PCBs and require special management. The possibility exists that ballasts which are PCB-containing exist in areas which Cardno ATC did not inspect or did not have access to due to the location of the ballasts or the condition of the light fixture covers.
4.3.2 Fluorescent and High Intensity Discharge (HID) Light Bulbs
Fluorescent and HID light bulbs may contain small amounts of heavy metals such as mercury, lead, cadmium, and nickel, and therefore must be handled/disposed of properly. An inventory of fluorescent and HID light bulbs in the surveyed areas was conducted. A total of approximately 1,520 fluorescent light bulbs were observed.
4.3.3 Other Potential PCB-Containing Equipment
In some cases, “wet-type” electrical transformers contain transformer oil (also known as dielectric fluid) that may contain PCBs and therefore must be handled and disposed of properly. “Dry-type” electrical transformers, on the other hand, contain no transformer oil. Cardno ATC did not observe dry-type or “wet-type” transformers at the Site.
Hydraulic systems contain hydraulic fluid (typically petroleum-based) that may contain PCBs and must be handled/disposed of properly. Cardno ATC observed one (1) hydraulic elevator system with an approximately 80-gallon reservoir. Based on the age of Site building (pre-1978), it is possible that the hydraulic oil within the system contains PCBs.
Note that electrical cabinets containing electrical switches, breakers, and other electrical equipment were located in several of the inspected areas. Due to safety and logistical reasons, the cabinets were not opened during the hazardous material survey. However, there are typically no hazardous materials or components containing hazardous materials located within these types of common small electrical cabinets.
4.3.4 Mercury-Containing Equipment
Thermostats, thermometers, and pressure gauges sometimes contain mercury. In addition, mercury-containing switches were sometimes used on heating boilers and other building equipment. Cardno ATC observed approximately two (2) potential mercury-containing thermostats/switches/gauges at the Site building. No other potential mercury-containing equipment was observed.
4.3.5 Aboveground Storage Tanks
Cardno ATC did not observe evidence of aboveground storage tanks (AST) at the Site.
The scope of work for this project did not include inspection of the Site for the presence of underground tanks or other underground structures that may contain hazardous materials.
Hot water heaters and air compressor tanks in the Site building should be recycled or properly disposed.
Cardno ATC Project No. 060.75143.0015 15
4.3.6 Electronic Devices and White Goods
Larger electronic devices and white goods, such as computers, printers, and microwaves, contain hazardous components that should be recycled or properly disposed. Cardno ATC did not observe evidence of these items at the Site.
4.3.7 Other Hazardous Materials
Multiple motors and pumps associated with heating, ventilation and cooling (HVAC) equipment and other equipment were observed at the Site. Larger motors and pumps often contain lubricating oil that should be recycled or properly disposed. Cardno ATC estimates the total number of motors and pumps at the Site to be approximately 17.
All air conditioners and refrigerators observed during the survey are presumed to contain refrigerants such as freon that need to be recycled or properly disposed unless otherwise noted. Cardno ATC estimates the total number of refrigerant-containing pieces of equipment at the Site to be approximately 11.
4.4 Access Limitations
Cardno ATC performed a representative visual hazardous materials survey at the Site building, which is scheduled for demolition. All Site areas were accessible during the survey.
The survey did not include hazardous materials behind finished walls/ceilings/floors of the surveyed areas. Cardno ATC cannot attest to conditions and/or components/fixtures located within these inaccessible areas. It is the recommendation of Cardno ATC that prior to demolition activities, all areas that were not accessed at the time of the survey be inspected to determine the presence of containers or building materials containing hazardous materials.
The scope of work for this project did not include inspection of the Site for the presence of underground tanks or other underground structures that may contain hazardous materials.
4.5 Conclusions
Various light ballasts, light bulbs, motors/pumps, refrigerant-containing equipment, thermostats and switches, and hydraulic system were observed by Cardno ATC within the surveyed areas. Care should be taken when handling the inventoried materials and the materials should be disposed according to applicable local, state, and federal regulations. The following table is a summary of items observed during the hazardous materials survey.
APPENDIX A
ASBESTOS BULK SAMPLE ANALYSIS RESULTS BY PLM,
Cardno ATC
600 West Cummings Park Suite 5450 Woburn, MA 01801
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January 25, 2012
Mr. David Rice, AIA, NCARB, LEED AP Via email: drice@dewberrry.com Project Manager – Hanscom AFB IDIQ Contact Dewberry 280 Summer Street, 10th Floor Boston, Massachusetts 02210
Subject: Limited PCB Sealant Survey Building 1103 Hanscom Air Force Base Bedford, Massachusetts Cardno ATC Project No. 060.75143.0015
Dear Mr. Rice:
Cardno ATC has been retained by Dewberry to perform a limited survey of polychlorinated biphenyls (PCBs) in suspect sealant materials at Building 1103 located at the Hanscom Air Force Base in Bedford, Massachusetts (the “Site”). The survey was conducted in association with the proposed demolition of the building. The survey was performed on November 8, 2012, by Mr.
Chris Amorelli, Cardno ATC Environmental Scientist.
The survey objective was to evaluate for the presence of PCB-containing sealants (i.e. various caulking and glazing compound materials) that would require special management as part of the proposed demolition. This survey only evaluated sealants that were observed on the date of the survey. The survey did not include testing of other surrounding building materials (i.e. masonry surrounds, frames, sills, etc.) adjacent to the sealants.
Following is a summary of the survey field activities, analytical data, and conclusions.
Field Activities
Cardno ATC collected bulk samples of a total of eight (8) suspect sealant materials throughout the building. Duplicate samples of select homogenous materials were collected but at slightly different locations.
Samples were collected via hand tools (i.e. screwdriver, hammer, pliers, chisel, etc.) and the hand tools were decontaminated with hexane between samples. The samples were then transported under chain-of-custody to Con-Test Analytical Laboratory, Inc. (Con-Test) of East Longmeadow, Massachusetts, for PCB analysis. Samples were analyzed following United States Environmental Protection Agency (USEPA) Method 3540C for Soxhlet extraction and Method 8082 for PCB analysis.
Australia • Belgium • Canada • Columbia • Ecuador • Germany • Indonesia • Italy • Kenya • New Zealand • Papua New Guinea • Peru • Tanzania • United Arab Emirates • United Kingdom • United States • Operations in 85 countries
Limited PCB Sealant Survey, Hanscom AFB, Building 1103 January 25, 2012
Laboratory Analysis Results
Cardno ATC summarizes the samples submitted for laboratory analysis in the following Table 1:
Table 1: PCB Survey Summary - Building 1103 Sample
ID Sample Material Sample Location Materials Between
PCB
Concentration
Estimated Quantity* ACM**
1103-1A Door frame caulk Exterior loading dock door Metal/brick ND (0.71) - No 1103-2A Door frame caulk Exterior side doors Metal/CMU 1.2 60 LF No 1103-3A Expansion joint caulk Exterior façade joints Brick/concrete
1.2 200 LF No
1103-3B ND (0.72)
1103-4A Window frame caulk Exterior windows throughout Metal/concrete 1.5
2,000 LF No 1103-4B 0.79
1103-5A Window glazing compound
Exterior windows throughout Glass/metal ND (0.67) - No
1103-6A Door frame caulk Exterior front door Metal/metal ND (0.68) - No 1103-7A Window frame caulk Exterior front door windows Metal/concrete 1.0 30 LF No 1103-8A Window frame caulk Exterior front door windows Metal/brick ND (0.68) - No
PCB concentrations shown in parts per million (ppm) ND = Not detected above the indicated laboratory detection limit Bold = PCBs detected in sample LF = Linear feet *Estimated quantities only provided for material which were determined to contain PCBs and/or asbestos **Asbestos was not detected in any of the materials analyzed for PCBs
PCBs were detected in four (4) of the eight (8) materials sampled. Two (2) duplicate samples were subsequently submitted to confirm the PCB concentrations of the original samples. Although PCBs were not detected in one of the duplicate samples, based on the detection of PCBs in the original sample the material is considered to contain PCBs. Total PCB concentrations ranged from 0.79 to 1.5 parts per million (ppm). PCBs were not detected in the remaining four (4) materials. Aroclor 1248 was the only Aroclor observed in most of the samples, while Aroclor 1254 was observed in one sample. As reported in the laboratory analytical report case narrative summary, all reported results were within laboratory quality control objectives. The laboratory analytical data is further presented in Table 2 and the associated laboratory analytical report is attached.
Conclusions and Recommendations
Based on the findings of the limited survey, PCB concentrations ranging from 0.79 to 1.5 ppm were observed in four (4) separate sealant materials. The low PCB concentrations indicate that adjacent materials (e.g. metal frames, glass, concrete, etc.) are unlikely to be adversely impacted.
The management of PCB-containing materials is regulated by the Toxic Substances Control Act (TSCA) and associated 40 CFR 761 Regulations, as administered by the United States Environmental Protection Agency
(EPA).
The PCB-containing sealants at the Site are classified under TSCA as Excluded PCB Products, which are materials with concentrations between 1 ppm and 50 ppm and which meet the following additional conditions:
The products or source of the products containing less than 50 ppm concentration PCBs were legally manufactured, processed, distributed in commerce, or used before October 1, 1984;
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The products or source of the products containing less than 50 ppm concentrations PCBs were legally manufactured, processed, distributed in commerce, or used, i.e., pursuant to authority granted by EPA regulation, by exemption petition, by settlement agreement, or pursuant to other Agency-approved programs; and
The resulting PCB concentration (i.e. below 50 ppm) is not a result of dilution, or leaks and spills of PCBs in concentrations greater than 50 ppm.
Excluded PCB Products may be managed by any permitted waste management or recycling facility as long as the facility is made aware of the fact that material being sent to them contains PCBs and their permit allows them to accept these types of materials. Many solid waste and recycling facilities cannot accept materials that contain PCBs at 2 ppm or greater. Workers handling Excluded PCB Products must also be made aware that these materials are present.
Materials which were determined to not contain PCBs are not regulated by the Toxic Substances Control Act (TSCA) or state regulations and, if confirmed not to contain asbestos, may be managed as demolition debris.
It should be noted that no sampled sealant materials contained asbestos. Cardno ATC performed a separate evaluation for the presence of asbestos, provided under separate cover.
Cardno ATC recommends incorporating Excluded PCB Product handling and disposal requirements into project Technical Specifications.
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Limitations
Our professional services have been performed and our findings obtained and prepared in accordance with customary principles and practices in the field of environmental science and engineering. This statement is in lieu of other statements either expressed or implied. This report does not warrant against future operations or conditions, nor does it warrant against operations or conditions present of a type or at a location not investigated.
Environmental evaluations are limited in the sense that conclusions are developed and information obtained from limited research and secondary sources. Except as set forth in this report, Cardno ATC has not made independent investigations as to the accuracy or completeness of the information derived from the secondary sources and personal interviews and has presumed that such information was accurate and complete. This report is intended for the sole use of Dewberry. The scope of services performed in execution of this evaluation may not be appropriate to satisfy the needs of other users, and use or re-use of this document or the findings or conclusions is at risk of said user.
Sincerely, Chris Amorelli Environmental Scientist for Cardno ATC Direct Line +1 781-404-1442 Email: chris.amorelli@cardno.com
Daniel P. White, PG Senior Project Manager for Cardno ATC Direct Line +1 781-404-1432 Email: daniel.white@cardno.com
Attachments: Table 2 – PCB Analytical Data Summary PCB Analytical Laboratory Report cc: Michael Gitten, Cardno ATC David Mitchell, Cardno ATC
File: Limited PCB Sampling Report-Hanscom AFB-Building 1103
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File details come from the government source that posted it. Updated .