Atch 18 - HAZMAT Report_MUHJ 23-4038 Convert Old Steam Plant Facility 655.pdf
PDF 7 MB Posted
- Solicitation number
- FA480025B0002
View the file
Other files
Show all 25
On GovTribe
Work with this file
- Download the original file
- Contacts named in this file
- Similar government files
- Ask GovTribe AI about this file
Text version
Prepared for:
Dills Architects PC
1432 N Great Neck Road, Ste 204
Virginia Beach, Virginia 23454
Hazardous Materials Inspection Report
Facility 665 – Former Steam Plant
Langley Air Force Base
Hampton, Virginia
November 10, 2023 | Terracon Project No. K3237153
5465 Greenwich Road
Virginia Beach, VA 23462
P (757) 518-1703
F (757) 518-1704
Terracon.com
Facilities | Environmental | Geotechnical | Materials
November 14, 2023
Dills Architects PC
1432 N Great Neck Road, Ste 204
Virginia Beach, Virginia 23454
Attn: Ms. Anna Campbell
O: (757) 496-4926
M: (757) 636-8625
E: acampbell@dillsarchitects.com
Re: Hazardous Materials Inspection Report
Facility 665 – Former Steam Plant
Langley Air Force Base
Hampton, Virginia
Terracon Project No. PK3237153
Dear Ms. Campbell:
Terracon Consultants, Inc. (Terracon) is pleased to present the results of the hazardous materials inspection performed for the approximately 4,522 square foot
Former Steam Plant (Facility 665) located in the northeast portion of the Langley Air
Force Base in Hampton, Virginia. Our services were performed in general accordance with Terracon Proposal No. PK3237153, dated August 16, 2023.
Asbestos-containing materials (ACM) were identified in samples of suspect materials collected during the inspection. Lead was identified in the paint samples collected during this inspection above the laboratory’s method detection limit. Cadmium, Chromium, and Lead were identified in TCLP samples collected during this inspection above the laboratory’s detection limits. Polychlorinated biphenyls (PCBs) were not detected at concentrations above the laboratory’s method detection limit in the submitted samples from the building. Please refer to the report for further details.
Terracon appreciates the opportunity to provide environmental consulting services to you on this project. If you should have any questions regarding this report, please contact the undersigned at (864) 292-2901.
Sincerely, Terracon Consultants, Inc.
T. Christopher Hahn, REM For Alicia Coley, CIH
Environmental Department Manager Authorized Project Reviewer
Hazardous Materials Inspection Report Facility 665, Langley Air Force Base │ Hampton, Virginia November 14, 2023 │ Terracon Project No. K3237153
Facilities | Environmental | Geotechnical | Materials i
Table of Contents
EXECUTIVE SUMMARY ............................................................................ ii
1. Introduction
2. Building Description
3. Field Activities
4. Regulatory Overview
5. Findings and Recommendations
6. General Comments
Appendix A Sample Summary Tables
Table 1 – Asbestos Inspection Sample Summary
Table 1A – ACM Estimated Quantities
Table 2 – Metals in Paint Summary
Table 3 – PCB Sample Summary
Table 4 – TCLP Sample Summary
Appendix B Analytical Laboratory Reports
Appendix C Inspector’s Credential
Appendix D Sample Location Drawings
Appendix E Photographs
Facilities | Environmental | Geotechnical | Materials ii
EXECUTIVE SUMMARY
Terracon Consultants, Inc. (Terracon) conducted a hazardous materials inspection on the approximately 4,522 square foot Former Steam Plant (Facility 665) located in the northeast portion of the Langley Air Force Base in Hampton, Virginia. Our inspection was conducted on October 25, 2023, in support of the planned proposed improvements/repair of the following: Renovation of the building and creation of an office area for ACC CE staff (to include a minimum of 10 offices), a small mezzanine over partial office area, a conference room, break room a two-story storage area with lift and a new roll-up door, restrooms and a locker area, a new roofing system, the raising of the floor level, the demolition of steel steam stacks, the repair of all brick, windows and other exterior elements, the repair of any structural issues and full replacement of all electrical, mechanical and plumbing systems. This executive summary is intended as an overview for the convenience of the reader. The complete report must be reviewed in its entirety prior to making decisions regarding this site.
The asbestos-containing material (ACM) inspection was conducted by Mr. Chris Hahn, a Virginia licensed asbestos inspector. The inspection was conducted in general accordance with the sampling protocols outlined in the Environmental Protection
Agency’s (EPA) National Emissions Standard for Hazardous Air Pollutants (NESHAP), Asbestos Hazard Emergency Response Act (AHERA), and Commonwealth of Virginia regulations. Note: Some destructive sampling was performed within the building to access pipe chases; and above suspended ceiling systems and wall cavities.
Asbestos
A total of sixty-six (66) bulk samples were collected from the structure. Many of the bulk samples contained several layers bringing the total number of sample layers analyzed to one-hundred thirty-six (136). Sample descriptions, locations, analytical results, and classifications are summarized in Table 1 in Appendix A. Estimated quantities of ACM detected are provided in Table 1A in Appendix A. Copies of the asbestos laboratory analytical reports are included in Appendix B.
Asbestos was detected (greater than 1%) in the following materials:
◼ Vinyl Floor Tile 2, 3, 4, 5, Ceramic Floor Tile 1, and Mastics 2, 3, 5, and 6 (3-
10% Chrysotile ) associated with the southwest interior office space floors.
Facilities | Environmental | Geotechnical | Materials iii
Floor Tile samples collected from these areas were comprised of six layers of floor tile (5 VFT, 1 CFT), each with a corresponding mastic.
Asbestos was detected (lesser than 1%) in the following materials:
◼ Mastic 4 associated with Vinyl Floor Tile 4 in the southwest interior office space.
◼ Joint Compound associated with the Dry Wall in the south interior Mezzanine
Bathroom.
◼ Pipe Wrap associated with the Fuel Oil Supply Pipes in the below slab interior trench located on the southeast interior floor.
Lead in Paint
A total of nineteen (19) paint chip samples were collected from the interior and exterior of the subject structure and submitted to the contract laboratory for analysis for the presence and concentrations of lead via EPA Method SW-846-3050. The results are summarized in Table 2 in Appendix A. All of the eighteen (18) samples submitted for analysis contained detectable lead concentrations. Nine (9) of the samples contained lead concentrations that exceed the US EPA’s definition of Lead-
Based Paint of 0.5% by weight:
◼ L-1; Red paint on the south exterior brick façade; 2.20% weight
◼ L-3; Green paint over silver on the northeast metal overhead door; 0.92% weight
◼ L-4; Silver paint over black then orange on metal beams under south interior mezzanine; 1.60% weight
◼ L-5; Yellow paint over white, black, then orange on metal beams under south interior mezzanine; 9.80% weight
◼ L-7; Blue/Green paint over black then orange on the brick wall in the south mezzanine bathroom; 1.30% weight
◼ L-8; Green paint on metal electrical pump control panel in the western interior;
0.79% weight
◼ L-10; Yellow paint on metal railings of the south mezzanine staircase; 17% weight
Facilities | Environmental | Geotechnical | Materials iv
◼ L-12; White paint over Green then Silver on metal steam piping in the north interior; 0.5% weight
◼ L-15; Black/Gray paint on metal staircase steps leading to the south interior mezzanine; 0.58% weight
Two building materials composite samples were created from the interior and exterior of the subject structure and submitted to the contract laboratory for analysis for the presence of concentrations of Toxicity Characteristic Leaching Procedure
(TCLP) RCRA-8 metals. TCLP-1 was composited from building materials from the SW portion of the subject building, while TCLP-2 was composited from building materials from the NE portion of the subject building. Both of the composite samples produced detectable levels of lead and chromium, and TCLP-2 contained detectable levels of cadmium as well. None of the analytical results from sample TCLP-1 or TCLP-2 identified cadmium, chromium, or lead at concentrations that exceed the Toxicity
Characteristic threshold value for hazardous waste.
PCBs
A total of two (2) samples of caulk/sealant associated with the structure were collected and submitted to the contract laboratory for analysis for the presence and concentrations of polychlorinated biphenyls (PCBs) via EPA Method 8082A. Neither of the submitted samples, PCB-1 and PCB-6, were reported to contain PCBs above the laboratory’s method detection limit. Please refer to the report for further details.
The results are summarized in Table 3 in Appendix A.
Building 163, Norfolk Naval Shipyard │ Portsmouth, Virginia November 14, 2023 │ Terracon Project No. K3237044
Facilities | Environmental | Geotechnical | Materials 1
1.0 Introduction
Terracon Consultants, Inc. (Terracon) conducted a hazardous materials inspection on the interior and exterior of the approximately 4,522 square foot Former Steam Plant (Facility
665) located in the northeast portion of the Langley Air Force Base in Hampton, Virginia.
Our inspection was conducted on October 25, 2023, in support of the planned upgrade and renovation to the building, and in accordance with our Proposal No. PK3237153, dated August 16, 2023, to the Client.
1.1 Project Objective
We understand this hazardous materials inspection was requested to identify and sample, where applicable, the following suspect hazardous materials:
◼ Asbestos-containing materials (ACM)
◼ Lead containing paint
◼ PCB-containing caulks/sealants
In addition, a visual inspection of potentially PCB containing and mercury containing equipment/components was conducted.
Terracon’s scope of services included providing information regarding the identity, location, condition, and approximate quantities of the above-mentioned hazardous materials in interior and exterior building components (including the roof) prior to renovation of the building.
EPA regulation 40 CFR 61, Subpart M, National Emission Standards for Hazardous Air
Pollutants (NESHAP), prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities. The asbestos NESHAP requires that potentially regulated ACM be identified, classified, and quantified prior to planned disturbances or demolition activities. The Occupational Health and Safety Administration (OSHA) has promulgated worker protection standard for the disturbance of materials containing asbestos during demolition and renovation projects.
The Occupational Health and Safety Administration (OSHA) has promulgated a worker protection standard for the disturbance of lead-containing paints during demolition projects. The limited lead paint sampling was performed to meet informational needs to comply with the OSHA Lead in Construction Standard (29 CRF 1926.62). Currently, proposed renovations or demolition activities which may impact lead paint is subject to
OSHA regulation 29 CFR 1926.62 – Lead Exposure in Construction. Proposed renovations or demolition activities which may impact cadmium and chromium containing paint are subject to OSHA regulations 29 CFR 1926.1127 and 29 CFR 1926.1126, respectively.
Facilities | Environmental | Geotechnical | Materials 2
1.2 General Conditions and Limitations
The hazardous materials inspection encompassed the interior and exterior of the building. At the direction of the Client, the roof system and associated materials were included in the scope of the inspection. The level of effort and associated tasks performed for this service was limited to the scope of services outlined in Terracon’s proposal.
1.3 Reliance
This report is prepared for the exclusive use and reliance of the Dills Architects PC (The
Client). Use or reliance by any other party is prohibited without the written authorization of the Client and Terracon.
Reliance on the report by the Client and all authorized parties will be subject to the terms, conditions, and limitations stated in Terracon’s proposal and the Agreement for
Services. The limitation of liability defined in the Agreement for Services is the aggregate limit of Terracon’s liability to the Client and all relying parties.
2.0 Building Description
The subject building is an approximate 4,522 square foot former steam plant building that was originally constructed in 1941 within the northeastern portion of the Langley Air
Force Base. The structure was originally developed with multiple steam boilers, three exhaust roof stacks, and an underground storage tank (UST) reportedly containing
60,000 gallons of fuel oil. The boilers were previously removed, presumably alongside the UST as indicated by the concrete cutouts in the ground to the southeast of the structure, and the facility is currently vacant and used as furniture storage space.
The building consists of structural steel framing with concrete masonry unit (CMU) exterior perimeter walls with a brick façade system. The flat portion of the roof is an asphaltic rolled roof system over rigid insulation. The pitched main roof consists of what appears to be lightweight concrete panels over steel roof framing and covered with asphaltic shingles. Interior finishes consist of painted brick and concrete block walls and concrete floors, painted drywall walls, vinyl floor tile, and acoustical ceiling tiles in office areas suspended on a metal grid system.
Facilities | Environmental | Geotechnical | Materials 3
3. 0 Field Activities
3.1 Asbestos
The asbestos inspection was conducted by Mr. Chris Hahn, a Virginia Licensed Asbestos
Building Inspector (License No. 3303001983). A copy of Mr. Hahn’s’ license is provided in Appendix C. The inspection was conducted on October 25, 2023, in general accordance with the Environmental Protection Agency’s (EPA) National Emissions
Standard for Hazardous Air Pollutants (NESHAP), Asbestos Hazard Emergency Response
Act (AHERA), and Commonwealth of Virginia Regulations.
Visual Assessment
Our inspection activities began with visual observation of the interior and exterior of the building, including the roof, to identify apparent homogeneous areas of suspect ACM. A homogeneous area consists of building materials, which appear similar throughout in terms of color, texture and date of application. Building materials which were not identified as concrete, glass, wood, masonry, metal or rubber were considered suspect
ACM.
Physical Assessment
A physical assessment of each homogeneous area of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the
EPA as a material, which can be crumbled, pulverized or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.
Sample Collection
Based on the results of the visual sampling, bulk samples of suspect ACM were collected in general accordance with AHERA sampling protocols. Random samples of suspect materials were collected in each homogeneous area. Bulk samples were collected using wet methods as applicable to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.
A total of sixty-six (66) bulk samples were collected from the structure. Many of the bulk samples contained several layers bringing the total number of sample layers analyzed to one-hundred thirty-six (136). A summary of the suspect ACM samples collected during the inspection is presented in Table 1 in Appendix A.
Facilities | Environmental | Geotechnical | Materials 4
Sample Analysis
Bulk samples were submitted using chain-of-custody procedures to EMSL Analytical, Inc.
(EMSL) in Morrisville, North Carolina. EMSL is accredited by the National Voluntary
Laboratory Accreditation Program (NVLAP Accreditation No. 102104-0) and Virginia (Lab
Accreditation No. 3333-000228) to analyze suspect asbestos-containing bulk materials.
The samples were analyzed using Polarized Light Microscopy (PLM) following EPA Method
600/R-93/116. The percentage of asbestos, where applicable, was determined by microscopical visual estimation.
3.2 Lead in Paint
The lead in paint sampling was conducted by Chris Hahn of Terracon. Paint chip samples were collected from homogenous painted surfaces identified to determine its lead content, measured in milligrams/Kilogram dry weight. Suspect lead paint samples were collected in general accordance with the EPA’s work practice standards for conducting lead paint activities (40 CFR 745.227). Currently, proposed renovation and demolition activities that could potentially disturb lead paint are subject to the OSHA regulations
(29 CFR 1926.62).
The paint sampling began with the Terracon representative walking the structure, observing painted surfaces, and selecting sample locations. After the sampling strategy was determined, Terracon collected 19 paint chip samples from homogeneous surfaces.
Paint chip samples were submitted under a chain of custody to EMSL Analytical (EMSL) in Cinnaminson, New Jersey. Paint chip samples were analyzed by Flame Atomic
Absorption (FAA) according to EPA Method SW-846-3050. EMSL is an American
Industrial Hygiene Association (AIHA) Environmental Lead Laboratory Accreditation
(ELLAP) accredited laboratory (ELLAP Lab Code 100194), to perform Flame Atomic
Absorption Spectrophotometry analysis. A summary of the paint chip samples collected during the sampling is presented in Table 2 in Appendix A. The lead paint laboratory analytical report is provided in Appendix B.
Further, TCLP sampling was conducted by Chris Hahn of Terracon. The two TCLP composite samples were collected from building materials representative of the potential future waste stream to determine their toxicity by the concentrations of hazardous contaminants by dry weight as specified in 40 CFR 261.24. The Resource Conservation and Recovery Act (RCRA) gave the USEPA authority to regulate the waste status of demolition or renovation debris, including lead-containing materials. Specific notification and testing requirements must be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead and Chromium-containing wastes are considered hazardous waste under RCRA if Toxicity Characteristic Leaching Procedure (TCLP) results exceed 5 milligrams per liter (mg/L), and Cadmium-containing wastes are considered
Facilities | Environmental | Geotechnical | Materials 5 hazardous waste under RCRA if Toxicity Characteristic Leaching Procedure (TCLP) results exceed 1 milligrams per liter (mg/L). EPA exempts from most RCRA requirements those generators whose combined hazardous waste generation is less than
100 kilograms (kg) per month
The TCLP sampling began with the Terracon representative walking the structure, observing homogenous planned construction locations, and selecting sampling locations.
After the sampling strategy was determined, Terracon collected 2 composite TCLP samples from homogeneous surfaces.
TCLP samples were submitted under a chain of custody to Enthalpy Analytical in
Richmond, Virginia. TCLP samples were analyzed by SW-846 Test Method 1311: Toxicity
Characteristic Leaching Procedure. Enthalpy Analytical is an accredited laboratory for solid waste analysis by the Commonwealth of Virginia (VELAP Certificate No. 12157). A summary of the TCLP samples collected during the sampling is presented in Table 4 in
Appendix A. The laboratory analytical report is provided in Appendix B.
3.3 Polychlorinated Biphenyls (PCBS) in Caulk/Sealants
The PCBs in caulk/sealant sampling was conducted by Terracon representative, Chris
Hahn. Two samples of caulk/sealant associated with interior and exterior components of the structure were collected by removing the caulk/sealant with decontaminated hand tools by the inspector. Sample locations were selected at the discretion of Terracon’s representative. The samples were placed into non-preserved laboratory certified clean glass jars and packed on ice.
Two samples were submitted under chain of custody to EMSL Analytical (EMSL) in
Cinnaminson, New Jersey for analysis. Suspect caulk/sealant samples were analyzed by
Method EPA 8082A for PCB concentrations. EMSL is an accredited laboratory for solid waste analysis by the Commonwealth of Virginia (VELAP Certificate No. 12613).
3.4 Limited Visual Assessment for Hazardous Materials
Terracon conducted a limited visual inspection for hazardous materials consisting of
PCBs in light ballasts/electrical transformers, mercury bulbs/light tubes, and mercury-containing devices. Materials were sampled as part of this service. A summary of findings regarding this service is included in Section 5.5.
Facilities | Environmental | Geotechnical | Materials 6
4.0 Regulatory Overview
4.1 Asbestos
The following sections provide a general overview to the applicable asbestos regulations.
Please refer to the complete current regulation in order to verify compliance before any actions are initiated on an ACM.
NESHAP
The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. It also requires the identification and classification of existing building materials prior to demolition or renovation activities.
Under NESHAP, asbestos-containing building materials are classified as either friable, Category I non-friable or Category II non-friable ACM. Friable materials are those that, when dry, may be crumbled, pulverized or reduced to powder by hand pressure.
Category I non-friable ACM includes packings, gaskets, resilient floor coverings and asphalt roofing products containing more than 1% asbestos. Category II non-friable
ACM are any materials other than Category I materials that contain more than 1% asbestos.
Friable ACM, Category I and Category II non-friable ACM which is in poor condition and has become friable or which will be subjected to drilling, sanding, grinding, cutting or abrading and which could be crushed or pulverized during anticipated renovation or demolition activities are considered regulated ACM (RACM).
Commonwealth of Virginia Regulations
In the State of Virginia, asbestos activities are regulated by the Virginia Department of
Labor and Industry (DOLI). DOLI regulates asbestos through enforcement of the Virginia
Occupational Safety and Health (VOSH) regulations, enforcement of the U.S. EPA
Asbestos NESHAP, and enforcement of the Asbestos Notification regulations found in the labor laws of Virginia. DOLI requires written notification by licensed asbestos abatement contractors for any asbestos abatement project at least 10 linear feet or 10 square feet.
A notification is not required for nonfriable asbestos containing roofing, flooring, or siding materials that will not become friable during removal. Notifications must be submitted 20 calendar days prior to starting the asbestos project. The EPA must also be notified for any asbestos projects that are at least 150 square feet, or 250 linear feet and essentially all demolition projects. The EPA notification period is 10 working days prior to starting the asbestos project. The VA DOLI asbestos regulations can be found at http://www.doli.virginia.gov.
http://www.doli.virginia.gov/
Facilities | Environmental | Geotechnical | Materials 7
Asbestos abatement must be conducted under the direct supervision of a Virginia accredited supervisor, except that permitted removals of roofing products may be conducted under the direct supervision of a Virginia accredited roofing supervisor. An asbestos abatement design must be prepared by a Virginia accredited abatement designer for each individually permitted removal of more than 3000 square feet (281 square meters), 1500 linear feet (462 meters) or 656 cubic feet (18 cubic meters), of regulated asbestos containing materials conducted in public areas. Third-party air monitoring must be conducted during the abatement activities in accordance with AHMP requirements.
OSHA
OSHA’s general industry asbestos standard (29 CFR 1910.1001) requires employers to exercise due diligence in complying with the requirements to inform their employees and affected contractors working in the facility about the presence and location of both ACM and materials assumed to contain asbestos.
The OSHA Asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos during construction and maintenance activities. The standard classifies construction and maintenance activities which could disturb ACM, and specifies work practices and precautions which employers must follow when engaging in each class of regulated work. States which administer their own federally-approved state
OSHA programs may require additional precautions.
A full copy of the OSHA asbestos standard for general and construction industry may be found at OSHA’s website (www.osha.gov) and should be referenced for specific information.
4.2 Lead in Paint
The metals in paint sampling activities were conducted in general accordance with the
EPA’s work practice standards for conducting lead paint activities (40 CFR 745, and State and local regulations) to meet informational needs to comply with the OSHA Lead in
Construction Standard. Lead is regulated by the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA).
The Resource Conservation and Recovery Act (RCRA) gave the USEPA authority to regulate the waste status of demolition or renovation debris, including lead-containing materials. Specific notification and testing requirements must be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead and Chromium-containing wastes are considered hazardous waste under RCRA if Toxicity Characteristic
Leaching Procedure (TCLP) results exceed 5 milligrams per liter (mg/L), and Cadmium-containing wastes are considered hazardous waste under RCRA if Toxicity Characteristic http://www.osha.gov/
Facilities | Environmental | Geotechnical | Materials 8
Leaching Procedure (TCLP) results exceed 1 milligrams per liter (mg/L). EPA exempts from most RCRA requirements those generators whose combined hazardous waste generation is less than 100 kilograms (kg) per month.
Detectable lead quantities may constitute a dust hazard during renovation and demolition activities. Personnel performing renovation and demolition activities that may disturb painted components with concentrations of lead, chromium, and cadmium above the designated analytical detection limit should comply with all current OSHA regulations in order to minimize employee exposure. OSHA defines lead-containing paint as a paint, which contains lead, regardless of the concentration. Currently, any proposed renovation and demolition is subject to the OSHA regulations 29 CFR 1926.62
(Lead). The OSHA regulation defines specific training requirements, engineering controls, and working practices for construction personnel subject to this standard.
Occupational exposure to lead occurring in the course of construction work, including maintenance activities, painting, alteration and repairs is subject to the OSHA Lead
Exposure in Construction standard.
Construction work covered by 29 CFR 1926.62 includes any repair or renovation activities or other activities that disturb in-place lead-containing materials, but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than 50 micrograms per cubic meter (g/m3) averaged over an eight-hour period without adequate protection.
The OSHA Standard also establishes an action level of 30 g/m3 which if exceeded triggers the requirement for medical monitoring.
The above overview is not intended to be inclusive of all potentially pertinent regulatory information. The relevant EPA and OSHA standards should be consulted prior to undertaking activities involving the demolition, renovation, or maintenance of surfaces coated with lead-based paints.
4.3 PCBs
Current PCB regulations can be found in the Code of Federal Regulations (CFR) at 40
CRF 761, the Toxic Substances Control Act (TSCA). Commonwealth of Virginia regulations pertaining to PCB wastes can be found in the Virginia Administrative Code
(VAC) 9VAC20-81-630. Under TSCA, PCB-containing caulk is considered PCB bulk product waste if the concentration of PCBs in the caulk is greater than or equal to (≥) 50 mg/Kg (40 CFR 761.3). Caulk with PCB concentrations ≥ 50 mg/Kg must be disposed of as PCB bulk product waste according to 40 CFR 761.62.
PCB bulk product waste includes waste derived from manufactured products containing
PCBs in a non-liquid state where the concentration at the time of designation for
Facilities | Environmental | Geotechnical | Materials 9 disposal is ≥ 50 ppm PCBs (see 40 CFR 761.3 and 761.62). Caulk with PCB concentrations ≥ 50 ppm is not authorized for use and must be disposed of as PCB bulk product waste according to 40 CFR 761.62. Additionally, the definition of PCB bulk product waste includes building materials that have been coated or serviced with PCBs.
That is masonry, wood, metals, and other building materials that are purposely coated with PCB-containing caulk are regulated as PCB bulk product waste if the caulk coating the building materials contains PCBs at concentrations ≥ 50 ppm.
4.4 Hazardous Materials
Materials such as heavy metals (e.g., mercury and lead), PCBs, and various other chemicals/hazardous substances may be found at commercial and industrial facilities.
These materials may be located in containers or be contained in various building materials, fixtures, or equipment. These materials, if improperly managed, may be considered environmental hazards and, therefore, require special handling and disposal considerations prior to, or in conjunction with, renovation or demolition efforts to prevent their entry into the environment. Hazardous materials are regulated under different federal and state statutes including the Toxic Substances Control Act (TSCA) and RCRA.
5.0 Findings and Recommendations
5.1 Asbestos
Asbestos was detected in concentrations greater than 1% in the following materials:
◼ Vinyl Floor Tile 2, 3, 4, 5, Ceramic Floor Tile 1, and Mastics 2, 3, 5, and 6 (3-10%
Chrysotile) associated with the southwest interior office spaces. Sample comprised of six layers of floor tile (5 VFT, 1 CFT), each with a corresponding mastic.
Materials containing greater than 1% asbestos are subject to permitting and disposal by the Commonwealth of Virginia. These materials must be removed by a Virginia Licensed
Asbestos Abatement Contractor prior to disturbance. Virginia and NESHAP require notification of abatement. Due to the quantities of RACM present, an asbestos removal plan must be developed by a Virginia-accredited Project Designer. Additionally, asbestos air monitoring must be performed prior to, during, and at the conclusion of RACM abatement.
In addition to the NESHAP-defined ACM, the following materials were identified as containing less than (<) 1% asbestos. Although these materials are not regulated by
NESHAP, these materials are subject to Occupational Safety and Health Administration
(OSHA) requirements if they are disturbed (see 29 CFR 1926.1101). If the results are
Facilities | Environmental | Geotechnical | Materials 10 not further analyzed by the point count method, they must be assumed to contain asbestos >1% and treated as so.
Asbestos was detected in concentrations lesser than 1% in the following materials:
◼ Mastic 4 associated with Vinyl Floor Tile 4 in the southwest interior office space.
◼ Joint Compound associated with the Dry Wall in the south interior Mezzanine
Bathroom.
◼ Pipe Wrap associated with the Oil Supply Pipes in the interior trench located on the southeast interior floor.
Sample descriptions, locations, analytical results, and classification are summarized in
Table 1 in Appendix A. Estimated quantities of detected ACM are provided in Table 1A of
Appendix A. Copies of the asbestos laboratory analytical reports are included in
Appendix B.
Additionally, suspect ACM, including the following materials (if encountered during demolition) should be considered asbestos containing until sampling determines otherwise: fire door insulation, vermiculite insulation within cinderblock walls, pipe flanges and gaskets, and vapor barrier behind the façade. Evaluation of the structure for the presence of these materials will require further exploratory demolition and/or additional sampling by a Commonwealth of Virginia licensed asbestos inspector prior to renovation or demolition. Federal, state, and local regulations should be consulted before initiating any action on an ACM.
5.2 Lead, Chromium, and Cadmium-Containing Paint
Lead was detected above the laboratory reporting limits in all of the paint samples collected and submitted for analysis, and nine (9) of the samples contained lead concentrations that exceed the US EPA’s definition of Lead-Based Paint of 0.5% by weight:
◼ L-1; Red paint on the south exterior brick façade; 2.20% weight
◼ L-3; Green paint over silver on the northeast metal overhead door; 0.92% weight
◼ L-4; Silver paint over black then orange on metal beams under south interior mezzanine; 1.60% weight
Facilities | Environmental | Geotechnical | Materials 11
◼ L-5; Yellow paint over white, black, then orange on metal beams under south interior mezzanine; 9.80% weight
◼ L-7; Blue/Green paint over black then orange on the brick wall in the south mezzanine bathroom; 1.30% weight
◼ L-8; Green paint on metal electrical pump control panel in the western interior;
0.79% weight
◼ L-10; Yellow paint on metal railings of the south mezzanine staircase; 17% weight
◼ L-12; White paint over Green then Silver on metal steam piping in the north interior; 0.5% weight
◼ L-15; Black/Gray paint on metal staircase steps leading to the south interior mezzanine; 0.58% weight
Contractors should be made aware of the presence of the identified lead coatings, so that they may maintain compliance with worker protection regulations, employ lead-safe work practices, and/or conduct a negative exposure assessment per OSHA regulations
29 CFR 1926.62 (Lead in Construction).
OSHA does not consider methods that rely solely on the analysis of bulk materials or surface content of lead (or other toxic material) to be acceptable for safely predicting employee exposure to airborne contaminants. Without air monitoring results or without the benefit of historical or objective data (including air sampling which clearly demonstrates that the employee cannot be exposed above the action level during any process, operation, or activity) the analysis of bulk or surface samples cannot be used to determine employee airborne exposure.
Two building materials composite samples were created from the interior and exterior of the subject structure and submitted to the contract laboratory for analysis for the presence of concentrations of Toxicity Characteristic Leaching Procedure (TCLP) RCRA-8 metals. TCLP-1 was composited from building materials from the SW portion of the subject building, while TCLP-2 was composited from building materials from the NE portion of the subject building. Both composite samples produced detectable levels of lead and chromium, and TCLP-2 contained detectable levels of cadmium as well. None of the analytical results from sample TCLP-1 or TCLP-2 identified cadmium, chromium, or lead at concentrations that exceed the Toxicity Characteristic threshold value for hazardous waste.
Terracon recommends a project specification be written to address work practices, clean-up, and specific disposal requirements to satisfy EPA, Virginia, and OSHA
Facilities | Environmental | Geotechnical | Materials 12 regulations; this document can be prepared by Terracon for inclusion in the bidding specifications. It is not required to fully abate the lead paint from the substrate for disposal or recycling efforts; however, the deteriorated paint and disturbance of paint must be addressed in accordance with 29 CFR 1926.62 and disposed of properly, as discussed above.
5.3 PCBs
Neither of the two submitted samples were reported to contain PCB congeners above the laboratory’s method detection limit. The results are further summarized in Table 3 in
Appendix A.
5.4 Limited Visual Inspection for Mercury & PCB-Containing
Equipment/Components
PCBs in Light Ballasts
Light ballasts are the electrical components attached to fluorescent light fixtures usually found under a metal over-plate. Prior to 1978, ballasts were commonly manufactured with polychlorinated biphenyls (PCBs). PCBs were used in fluorescent light ballasts because of their good electrical insulating capabilities. Ballasts made after 1978 are usually marked "Non-PCB." Certain sealants have been found to contain PCBs.
Terracon observed a representative number of fluorescent light ballasts throughout the building. The observed fluorescent light ballasts were predominantly not labeled as non-
PCBs containing. Terracon estimates that the building contains approximately 30 fluorescent light ballasts that may contain PCBs.
Terracon recommends that any fluorescent light ballasts that may be found within the building that do not contain the “Non-PCB” label be assumed to contain PCBs. Ballasts with a clearly marked “Non-PCB” label are not regulated and can be disposed of with general construction and demolition debris. Should fluorescent light ballasts without the
“Non-PCB” label be encountered, they should be removed, disposed of, and/or recycled according to Federal and Commonwealth of Virginia waste disposal guidelines by an appropriately licensed contractor.
Facilities | Environmental | Geotechnical | Materials 13
Mercury
Mercury is used in several building components including fluorescent lamps, thermostats, and thermometers. Terracon conducted a visual inspection to identify mercury-containing components throughout the building.
Terracon did not observe fluorescent lamps suspected to contain mercury within the building at the time of our inspection. Terracon did not observe potential mercury-containing thermostats or thermometers suspected to contain mercury.
Terracon recommends that all fluorescent bulbs within the building be presumed to be mercury-containing. Any mercury-containing building components that are to be impacted as part of renovation and demolition activities should be removed, disposed of, and/or recycled according to Federal and Commonwealth of Virginia hazardous waste disposal guidelines by an appropriately licensed contractor.
Potential for Total Petroleum Hydrocarbon Contamination in Soils
A review of historic floor plans for the facility, as provided by the client, revealed the historic presence of a 60,000-gallon fuel oil underground storage tank located adjacent to the southeast of the building. During site reconnaissance, patched area(s) were observed in the paved area where the site diagrams depict the UST. It is presumed that the tank has been removed from the ground, in association with the interior boilers and other steam plant equipment, when the facility was decommissioned. However, the supply lines used for the transfer of the fuel oil were observed within trenches beneath the concrete floor of the building. A distinct petroleum odor was noted by the on-site inspector upon removal of the steel plate that covers the line trench.
Based upon these observations, there is the potential for petroleum impacted soils and groundwater to be present on-site. Further assessment is required to determine the condition of site media as it relates to petroleum impacts.
Facilities | Environmental | Geotechnical | Materials 14
6.0 General Comments
This hazardous materials inspection was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our survey of the building. The information contained in this report is relevant to the date on which this survey was performed and should not be relied upon to represent conditions at a later date.
This report has been prepared on behalf of and exclusively for use by Dills Architects PC for specific application to their project, as discussed herein. Terracon does not warrant the work of regulatory agencies, laboratories or other third parties supplying information, which may have been used in the preparation of this report. No warranty, express or implied is made.
This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary.
APPENDIX A
TABLES
Sample
Number Analytical Results Sample Location Sample Description
Homogeneous
Area Classification
Friable /
Non-Friable
Current
Condition
IB-1A NAD
IB-1B NAD
IB-1C 3% Chrysotile
IB-1D 3% Chrysotile
IB-1E 5% Chrysotile
IB-1F 10% Chrysotile
IB-1G 10% Chrysotile
IB-1H <1% Chrysotile
IB-1I 8% Chrysotile
IB-1J 3% Chrysotile
IB-1K 5% Chrysotile
IB-1L 5% Chrysotile
IB-2A NAD
IB-2B NAD
IB-2C 3% Chrysotile
IB-2D 3% Chrysotile
IB-2E 5% Chrysotile
IB-2F 10% Chrysotile
IB-2G 10% Chrysotile
IB-2H <1% Chrysotile
IB-2I 8% Chrysotile
IB-2J 3% Chrysotile
IB-2K 5% Chrysotile
IB-2L 5% Chrysotile
TABLE 1
ASBESTOS RESULTS SAMPLE SUMMARY
FACILITY 665 - LANGLEY AIR FORCE BASE
HAMPTON, VIRGINIA
TERRACON PROJECT NO. K3237153
SW Interior Office Space
Floor
12" Yellow VFT (A)
Brown Mastic (B)
8" Dark Brown VFT (C)
Brown Mastic (D)
8" Black VFT (E)
Black Mastic (F)
8" White VFT (G)
Black Mastic (H)
8" Gray VFT (I)
Black Mastic (J)
4" Gray CFT (K)
Black Mastic (L)
Type I Non-
Friable Non-Friable Good
Analytical Results Sample Location Sample Description
Homogeneous
Area Classification
Friable /
Non-Friable
Current
Condition
TABLE 1
ASBESTOS RESULTS SAMPLE SUMMARY
FACILITY 665 - LANGLEY AIR FORCE BASE
HAMPTON, VIRGINIA
TERRACON PROJECT NO. K3237153
SW Interior Office Space
Floor
12" Yellow VFT (A)
Brown Mastic (B)
8" Dark Brown VFT (C)
Brown Mastic (D)
8" Black VFT (E)
Black Mastic (F)
8" White VFT (G)
Black Mastic (H)
8" Gray VFT (I)
Black Mastic (J)
4" Gray CFT (K)
Black Mastic (L)
Type I Non-
Friable Non-Friable Good
IB-3A NAD
IB-3B NAD
IB-3C 2% Chrysotile
IB-3D LNP
IB-3E 5% Chrysotile
IB-3F 5% Chrysotile
IB-3G 8% Chrysotile
IB-3H <1% Chrysotile
IB-3I 3% Chrysotile
IB-3J 5% Chrysotile
IB-3K 3% Chrysotile
IB-3L 5% Chrysotile
IB-4 NAD
IB-5 NAD
IB-6 NAD
IB-7A NAD
IB-7B NAD
IB-7C NAD
IB-7D NAD
IB-8A NAD
IB-8B NAD
IB-8C NAD
IB-8D NAD
IB-9A NAD
IB-9B NAD
IB-9C NAD
IB-9D NAD
SW Office Space Ceiling
Textured Drywall Ceiling w/
Insulation Wrap:
White/Brown Drywall (A)
White Texture (B)
Ceiling Insulation (C)
Wrap (D)
3 Miscellaneous Non-Friable Good
SW Office Space Ceiling Gray 2" X 4" ACT 2 Miscellaneous Friable Damaged
SW Interior Office Space
Floor
12" Yellow VFT (A)
Brown Mastic (B)
8" Dark Brown VFT (C)
Brown Mastic (D)
8" Black VFT (E)
Black Mastic (F)
8" White VFT (G)
Black Mastic (H)
8" Gray VFT (I)
Black Mastic (J)
4" Gray CFT (K)
Black Mastic (L)
Type I Non-
Friable Non-Friable Good
Analytical Results Sample Location Sample Description
Homogeneous
Area Classification
Friable /
Non-Friable
Current
Condition
TABLE 1
ASBESTOS RESULTS SAMPLE SUMMARY
FACILITY 665 - LANGLEY AIR FORCE BASE
HAMPTON, VIRGINIA
TERRACON PROJECT NO. K3237153
SW Interior Office Space
Floor
12" Yellow VFT (A)
Brown Mastic (B)
8" Dark Brown VFT (C)
Brown Mastic (D)
8" Black VFT (E)
Black Mastic (F)
8" White VFT (G)
Black Mastic (H)
8" Gray VFT (I)
Black Mastic (J)
4" Gray CFT (K)
Black Mastic (L)
Type I Non-
Friable Non-Friable Good
IB-10A NAD
IB-10B LNP
IB-11A NAD
IB-11B LNP
IB-12A NAD
IB-12B LNP
IB-13A NAD
IB-13B NAD
IB-14A NAD
IB-14B NAD
IB-15A NAD
IB-15B NAD
IB-16 NAD
IB-17 NAD
IB-18 NAD
IB-19A NAD
IB-19B NAD
IB-20A NAD
IB-20B NAD
IB-21A NAD
IB-21B LNP
SW Interior Office Space Gray Drywall (A)
White Joint Compound (B) 4 Miscellaneous Non-Friable Good
Non-Friable Good
Cementitious Ceiling Tile 6 Miscellaneous Non-Friable Good
MiscellaneousSW Interior Office Space
S Interior Mezzanine Stairs
Brown/Gray Base (A)
Brown/Tan Mastic (B)
Main Building Ceiling Under
Roof
Black No-Slip Textured Pad:
Layer 1 (A)
Layer 2 (B)
7 Miscellaneous Non-Friable Good
Analytical Results Sample Location Sample Description
Homogeneous
Area Classification
Friable /
Non-Friable
Current
Condition
TABLE 1
ASBESTOS RESULTS SAMPLE SUMMARY
FACILITY 665 - LANGLEY AIR FORCE BASE
HAMPTON, VIRGINIA
TERRACON PROJECT NO. K3237153
SW Interior Office Space
Floor
12" Yellow VFT (A)
Brown Mastic (B)
8" Dark Brown VFT (C)
Brown Mastic (D)
8" Black VFT (E)
Black Mastic (F)
8" White VFT (G)
Black Mastic (H)
8" Gray VFT (I)
Black Mastic (J)
4" Gray CFT (K)
Black Mastic (L)
Type I Non-
Friable Non-Friable Good
IB-22A NAD
IB-22B NAD
IB-23A NAD
IB-23B NAD
IB-24A NAD
IB-24B NAD
IB-25A NAD
IB-25B NAD
IB-26A NAD
IB-26B NAD
IB-27A NAD
IB-27B <1% Chrysotile
IB-28A NAD
IB-28B LNP
IB-29A NAD
IB-29B NAD
IB-30A NAD
IB-30B LNP
IB-31 <1% Chrysotile
IB-32 NAD
IB-33 NAD
S Interior Floor in Pipe
Trench Pipe Wrap 11
Good
Non-Friable
12" Beige VFT (A)
Tan Mastic (B) 8 Miscellaneous Non-Friable
S Interior Mezzanine
Bathroom
Good
N Interior Office Space
Good
S Interior Mezzanine
Bathroom
Gray Drywall (A)
White Joint Compound (B) 9 Miscellaneous
White/Blue Drywall (A)
White Joint Compound (B) 10 Miscellaneous Non-Friable
Miscellaneous Friable Good
Analytical Results Sample Location Sample Description
Homogeneous
Area Classification
Friable /
Non-Friable
Current
Condition
TABLE 1
ASBESTOS RESULTS SAMPLE SUMMARY
FACILITY 665 - LANGLEY AIR FORCE BASE
HAMPTON, VIRGINIA
TERRACON PROJECT NO. K3237153
SW Interior Office Space
Floor
12" Yellow VFT (A)
Brown Mastic (B)
8" Dark Brown VFT (C)
Brown Mastic (D)
8" Black VFT (E)
Black Mastic (F)
8" White VFT (G)
Black Mastic (H)
8" Gray VFT (I)
Black Mastic (J)
4" Gray CFT (K)
Black Mastic (L)
Type I Non-
Friable Non-Friable Good
IB-34A NAD
IB-34B NAD
IB-35A NAD
IB-35B NAD
IB-36A NAD
IB-36B NAD
B-1A NAD
B-1B NAD
B-1C NAD
B-1D NAD
B-2A NAD
B-2B NAD
B-2C NAD
B-2D NAD
B-3A NAD
B-3B LNP
B-3C NAD
B-3D LNP
NE Flat Roof
NW Flat Roof
SE Flat Roof
Roofing:
Black Tar 1 (A)
Black Tar 2 (B)
Brown Insulation 1 (C)
Brown Insulation 2 (D)
13 Miscellaneous Non-Friable Good
Steam Piping at S Miscellaneous Non-Friable Good
Mezzanine Stairs
Mudded Elbow:
Mud (A)
Wrap (B)
Analytical Results Sample Location Sample Description
Homogeneous
Area Classification
Friable /
Non-Friable
Current
Condition
TABLE 1
ASBESTOS RESULTS SAMPLE SUMMARY
FACILITY 665 - LANGLEY AIR FORCE BASE
HAMPTON, VIRGINIA
TERRACON PROJECT NO. K3237153
SW Interior Office Space
Floor
12" Yellow VFT (A)
Brown Mastic (B)
8" Dark Brown VFT (C)
Brown Mastic (D)
8" Black VFT (E)
Black Mastic (F)
8" White VFT (G)
Black Mastic (H)
8" Gray VFT (I)
Black Mastic (J)
4" Gray CFT (K)
Black Mastic (L)
Type I Non-
Friable Non-Friable Good
B-4A NAD
B-4B NAD
B-5A NAD
B-5B NAD
B-6A LNP
B-6B NAD
B-7 NAD
B-8 NAD
B-9 NAD
B-10 NAD
B-11 NAD
B-12 NAD
B-13A NAD
B-13B NAD
B-14A NAD
B-14B NAD
B-15A NAD
B-15B NAD
B-16 NAD
B-17 NAD
B-18 NAD
Gray Mortar 16 Miscellaneous Non-Friable Good
Black Asphalt Shingle (A)
Gray/Black Roof Felt (B) 17 Miscellaneous Non-Friable Good
Brown/Gray Sealant 18 Miscellaneous Non-Friable Good
14 Miscellaneous Non-Friable Good
Non-Friable Good
Exterior Brick Façade
Pitched Roof
Exterior Thru-Wall A/C
Parapet Wall at Flat Roof
Black Parapet Flashing
Sealant (A)
Asphalt Roll (B)
Parapet Wall at Flat Roof Gray Coping Sealant 15 Miscellaneous
Analytical Results Sample Location Sample Description
Homogeneous
Area Classification
Friable /
Non-Friable
Current
Condition
TABLE 1
ASBESTOS RESULTS SAMPLE SUMMARY
FACILITY 665 - LANGLEY AIR FORCE BASE
HAMPTON, VIRGINIA
TERRACON PROJECT NO. K3237153
SW Interior Office Space
Floor
12" Yellow VFT (A)
Brown Mastic (B)
8" Dark Brown VFT (C)
Brown Mastic (D)
8" Black VFT (E)
Black Mastic (F)
8" White VFT (G)
Black Mastic (H)
8" Gray VFT (I)
Black Mastic (J)
4" Gray CFT (K)
Black Mastic (L)
Type I Non-
Friable Non-Friable Good
B-19 NAD
B-20 NAD
B-21 NAD
B-22A NAD
B-22B NAD
B-23A NAD
B-23B NAD
B-24A NAD
B-24B NAD
B-25 NAD
B-26 NAD
B-27 NAD
B-28 NAD
B-29 NAD
B-30 NAD
Notes:
NW Exterior Steam Pipe
Gray Window Sealant
Pipe Insulation:
Brown Wrap (A)
Brown Insulation (B)
Black Paper around 6"
Steam Piping
Brown Elbow Insulaiton 22 Miscellaneous Friable Good
N Exterior 6" Steam Pipe
6" Steam Pipe Below
Aluminum Wrap
21 Miscellaneous
Miscellaneous
Miscellaneous Non-Friable
Non-Friable
Non-Friable Good
Good
GoodN Exterior Wall Window
NAD - No Asbestos Detected
LNP - Layer Not Present
Identified asbestos-containing materials are highlighted and bolded.
Sample Location Sample Description Approximate
Quantity Classification
Current
Condition
Southwestern Interior Office
Space Floors
VFT and CFT and Associated
Mastics within Six Layers :
12" Yellow VFT (A)
Brown Mastic (B)
8" Dark Brown VFT (C)
Brown Mastic (D)
8" Black VFT (E)
Black Mastic (F)
8" White VFT (G)
Black Mastic (H)
8" Gray VFT (I)
Black Mastic (J)
4" Gray CFT (K)
Black Mastic (L)
500 SF
Category I Non-
Friable Good
TABLE 1A
IDENTIFIED ASBESTOS-CONTAINING MATERIALS
Notes:
LF = Linear Feet
SF= Square Feet
FACILITY 665 - LANGLEY AIR FORCE BASE
HAMPTON, VIRGINIA
TERRACON PROJECT NO. K3237153
ID No.
Area Substrate Component Color
Lead
Concentration (% weight)
L-1 S Exterior Façade Brick Exterior Red 2.20
L-2 E Interior Wall Brick Wall White over Green 0.34
L-3 NE Overhead Cargo Door Metal Garage Door Green over Silver 0.92
L-4 S Interior Under Mezzanine Metal Steel Beam Silver over Black then Orange 1.60
L-5 S Interior Under Mazzanine Metal Steel Beam Yellow over White, Black, then Orange 9.80
L-6 SE Interior Wall Brick Wall White over Green then
White 0.47
L-7 S Mezzanine Bathroom Brick Wall Blue/Green over
White then Yellow 1.30
L-8 W Interior Electrical Pump
Control Panel Metal
Electrical
Equipment Green 0.79
L-9 SW Metal Column in Interior Wall Metal Wall Green over White then
Black 0.33
L-10 S Mezzanine Railing Metal Railing Yellow 17.00
L-11 Central Interior Floor Concrete Floor Gray 0.018
L-12 N Interior Steel Piping Metal Steam Pipe White over Green then Silver 0.50
L-13 N Interior Room Wall Drywall Wall Green/Blue 0.16
L-14 N Interior Room Wall Drywall Wall White BDL
L-15 S Mezanine Staircase Step Metal Staircase Black/Gray 0.58
L-16 SW Office Door Wood Door Brown over Green then White 0.25
L-17 Exterior Aboveground Storage
Tank Metal AST Red over Silver 0.021
L-18 Exterior Exhaust Stack at Roof…
This is the start of the file's text. The full file is on GovTribe.
File details come from the government source that posted it. Updated .