16-Asbestos_and_Lead_Assessment,_4.14.16.pdf

GSA ▪ Asbestos/Lead Assessment

(MATSSC – HVAC Improvement Project)

Provided to:

Greenman-Pedersen, Inc.

Engineering and Construction Services

Provided by:

Cocciardi and Associates, Inc.

1337 Veterans Memorial Drive

Jessup, Pennsylvania 18434

Cocciardi and Associates, Inc. Project No150829 April 14, 2016

4 Kacey Court • Mechanicsburg, PA 17055-5596 • (717) 766-4500 • FAX (717) 766-3999 1337 Veterans Memorial Drive • Jessup, PA 18434 • (570) 291-0030 • FAX (570) 291-0035 www.cocciardi.com http://www.cocciardi.com/

Greenman Pedersen, Inc. -i- GSA ▪ Asbestos/Lead Assessment (MATSSC – HVAC Improvement Project)

TABLE OF CONTENTS

Section 1 Introduction

1.1 Project Summary 1

1.2 Purpose and Scope 1

1.3 Site/Project Background 1

1.4 Limitations 2

Section 2 Asbestos Building Inspection

2.1 Inspection Personnel and Methods 2

2.2 Results 3

2.3 Conclusions 5

2.4 Recommendations 5

Section 3 Lead Paint Screening

3.1 Inspection Personnel and Methods 6

3.2 Results 7

3.3 Conclusions 7

3.4 Recommendations 7

Section 4 Certification

Appendix List Appendix A: Scope Of Work

Appendix B: US Public Health Service Asbestos Reinspection Report

Appendix C: PA DOLI Asbestos Inspector License and City of Philadelphia Asbestos Investigator

Appendix D: Laboratory Analytical Report And Associated COC (Asbestos - EMSL)

Appendix E: Laboratory Analytical Report And Associated COC (Lead - Galson)

Appendix F: SSA Lead Sampling Form / Summary Report

Greenman Pedersen, Inc. -1-

Section 1: Introduction

1.1: Project Summary

The following report is provided to document the activities, findings, and subsequent recommendations relative to the Asbestos Containing Material (ACM) Pre-Alteration Assessment and limited Lead Paint Survey for the following General Service Administration (GSA) project/site:

Site: Mid-Atlantic Social Security Center (MATSSC) Location: Philadelphia, PA

Project: HVAC Improvement Project

1.2: Purpose and Scope

Cocciardi and Associates, Inc. (Cocciardi) was contracted by Greenman-Pedersen, Inc. (GPI) to perform an ACM Assessment and Limited Lead Paint Survey to facilitate the HVAC Improvement Project at the above-referenced site. The assessment was requested to meet requirements of the U.S. General Service Administration (GSA) policy in addition to U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), City of Philadelphia Department of Public Health (DOPH), and U.S. Environmental Protection Agency (EPA) regulations, where applicable and as outlined below:

Asbestos: OSHA Asbestos in General Industry and Construction Standards (29 CFR

1910.1001 and 1926.1101, respectively); EPA Asbestos Hazard Emergency Response Act (40 CFR 763); City of Philadelphia DOPH Asbestos Control Regulation (July 20, 2009); and, GSA Public Buildings Service Asbestos Policy (September 2007).

Lead Paint: OSHA Lead in Construction (29 CFR 1926.62); SSA Lead Compliance Program (022114).

The scope of the project was limited to the surfaces, materials, and components that are to be potentially impacted by the proposed project. These locations were designated based on the provided Scope of Work dated September 29, 2015 and information provided by GPI representatives during an onsite review of the building.

1.3: Site/Project Background

MATSSC: The MATSSC, located at 300 Spring Garden Street in Philadelphia, Pennsylvania was built in 1974. The MATSSC is a seven (7) story, 570,000 square foot office building. It consists of a brick and glass exterior, with one level below grade, and a mechanical penthouse. The proposed MATSSC HVAC Improvement Project involves the following:

1. Replacement of eight (8) downdraft Computer Room Air Conditioners (CRACs) and associated equipment located in the Computer Room (ROCC).

2. Replacement of certain fiberglass pipe insulation components.

Greenman Pedersen, Inc. -2-

3. Replacement of approximately 600 Fan Coil Units (FCUs) and associated insulation and piping connections.

4. Replacement of internal parts (e.g. valves, motors, coils, filter racks, etc.) to Air Handler Units (AHUs).

The scope of work provided to Cocciardi by GPI is found in Appendix A.

Cocciardi was provided with an Asbestos Reinspection Report generated by The United States Public Health Service on September 19, 2013. Information from this report was reviewed and accounted for during this assessment as deemed appropriate by Cocciardi. The full inspection report can be viewed in Appendix B.

1.4: Limitations

The assessments were limited to those areas identified by GPI as being potentially impacted by the scope of the above project. Asbestos sample collection was limited to accessible areas. Invasive measures were performed as applicable and permitted by building representatives.

Section 2: Asbestos Building Inspection

2.1: Inspection Personnel and Methods

The inspection was completed on March 28 and 29, 2016 by Cody Youshock, a Pennsylvania Department of Labor and Industry (PA DOLI)-accredited Asbestos Building Inspector and AMS-certified Asbestos Investigator in the City of Philadelphia. Refer to Appendix C for a copy of PA DOLI and Philadelphia licenses.

The Asbestos Building Inspection included a visual and tactile review of the designated areas included in the scope (listed above), sampling and quantification of suspect ACM, and evaluation of their current condition (friable or non-friable). These activities were conducted in accordance with the above-referenced OSHA and EPA regulations and guidance documents.

Where adequate material was available, an appropriate number of samples were collected from each homogenous material identified as a suspect material. Level C (including P-100 filter equipped, full face, negative pressure respirator) protection was donned during sample collection of friable materials. Latex or nitrile gloves were changed and tools were adequately decontaminated between sample collection to prevent cross-contamination.

In addition to the onsite inspection, Cocciardi reviewed existing asbestos survey documentation provided to GPI by GSA.

All samples collected under the scope of this project were submitted to EMSL Analytical, Inc.

(EMSL) in Cinnaminson, New Jersey, and analyzed by Polarized Light Microscopy (PLM) via EPA Method 600/R-93-116. EMSL is a National Voluntary Laboratory Accreditation Program participating laboratory.

Greenman Pedersen, Inc. -3-

An assessment of the suspect asbestos containing building materials was conducted during the inspection, which included classification of material by the following criteria: Friability (friable or non-friable); and, EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) Category.

Friability:

1. Friable: Friable material in a building means that the material, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure, and includes previously non-friable material after such material becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure.

2. Non-Friable: Non-Friable means material in a building which, when dry, may not be crumbled, pulverized, or reduced to powder by hand pressure.

EPA NESHAP Categories:

1. Category I Non-Friable ACM (CAT I): Asbestos containing packing, gaskets, floor covering and asphalt roofing products containing more than one percent (1%) asbestos.

2. Category II Non-Friable ACM (CAT II): Any material, excluding Category I non-friable asbestos containing material, containing more than one percent (1%) asbestos. Material, that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

3. Regulated Asbestos Containing Material (RACM): Friable asbestos material, Category I non-friable asbestos containing material that has become friable, and Category I non-friable asbestos material that will be or has been subject to sanding, grinding, cutting, or abrading. This includes Category II non-friable asbestos containing material that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition.

2.2: Results of the ACM Assessment

A total of nine (9) suspect materials were identified as potentially impacted by the proposed renovations. Where existing documentation on laboratory analysis was not available or discernable, Cocciardi collected bulk samples of these suspect materials. In addition to the sampled materials, Cocciardi identified both non-suspect materials and suspect materials that are outside of the proposed scope, as summarized below.

Suspect Materials:

o Sampled – Brown Duct Putty; Transite Panels; White Vent Caulk; Gray Block Mortar;

White Putty on Fiberglass Insulation; Coil Vent Cloth o Previously identified as non-asbestos – Spray-on Fireproofing; Valve Insulation on Piping; Vibration Sleeves/Cloth o Previously identified as asbestos – Transite Ceiling/Floor Panels

Non-Suspect Materials: Fiberglass Insulation (throughout); Concrete/Brick Structural Components; Metal Interior Components; Floor Boards in ROCC; Armaflex (Black) Pipe Insulation

Greenman Pedersen, Inc. -4-

Suspect Materials Outside of Project Scope: Exterior Components, such as Window

Glazing/Caulking; Roofing Components (Flashing, Roof Core); Fire Door Interior; Slop Sink Caulk (Gray); Floor Leveling Compound; Boiler Components; Ceiling Tiles; Floor Tiles/Mastics;

Cove Base Moldings/Mastics; Joint Compound; Plaster Components; Drywall Ceilings;

Sheetrock Walls

Analytical results of bulk PLM samples were compared to the EPA/OSHA definition of ACM, identified as greater than 1% asbestos. A summary of suspect materials, locations, condition, quantities, and sample information (identification numbers, analytical results) is provided in Table I. Copies of laboratory analytical reports and associated chain of custody forms are provided in Appendix D.

Assessment information, including NESHAP category, friability and condition, for confirmed ACM are provided in C-1.

Table I Asbestos Building Inspection: Suspect Materials and Analytical Results

Greenman-Pedersen, Inc.: General Services Administration MATSSC: HVAC Improvement Project

March 28 and 29, 2016 Material Description Location Material ID Result

Spray-on Fireproofing

Fireproofing Overspray located throughout the entire facility on beams, ceilings, walls, etc.

Throughout (See Appendix B) 150829-1 None Detected (1)

Brown Duct Putty Duct Putty located on various duct components

Penthouse Corners, All Shafts

150829-2A

None Detected 150829-2B

150829-2C

Transite Panels Transite Floor Panels underneath pipe components

Penthouse Corners, Ground Level Shafts

150829-3A

10% Chrysotile 150829-3B

150829-3C

White Vent Caulk White Vent Caulk located on air handler units

Penthouse NE Corner, Penthouse

NW Corner, Penthouse SE

Corner, Penthouse SW Corner

150829-4A

None Detected 150829-4B

150829-4C

Gray Block Mortar Gray Mortar located between cinder block components

All Shafts

150829-5A

None Detected 150829-5B

150829-5C

White Insulation Putty White Putty on Insulation All Shafts

150829-6A None Detected 150829-6B

150829-6C

Greenman Pedersen, Inc. -5-

Table I (CONTINUED) Asbestos Building Inspection: Suspect Materials and Analytical Results

Greenman-Pedersen, Inc.: General Services Administration MATSSC: HVAC Improvement Project

March 28 and 29, 2016 Material Description Location Material ID Result

Coil Vent Cloth Material

Gray/Black coil vent cloth found on coil units

Coil Units in Office Areas (Throughout)

150829-7A None Detected 150829-7B

150829-7C Piping Valve

Insulation Piping Valve Insulation See Appendix B 150829-8 None Detected (1)

Vibration Sleeves/Cloth

Vibration Sleeves/Cloth located on duct and vent units

Throughout Mechanical and Electrical Rooms

150829-9 None Detected (1)

Note 1: These results were included in the Asbestos Reinspection Report Update generated by The United States Public Health Service on September 19, 2013. This report is attached as Appendix B.

2.3: Conclusions

C-1: The Asbestos Building Inspection performed within areas potentially affected by the HVAC

Improvement Project identified the following materials as ACM (greater than 1% asbestos):

Table II Confirmed Asbestos Containing Materials

Material Description Locations Quantity

Transite Panels Friability: Non-Friable OSHA: Class II EPA NESHAP: Category I

Penthouse Corners, Ground Level Shafts (Located on Floor)

176 SF

Table II Notes:

SF: Square Feet

Analytical/laboratory testing identified the remaining suspect materials (including Spray-on Fireproofing, Duct Putty, Vent Caulk, Gray Mortar, Insulation Putty, Vent Coil Cloth, Valve Insulation, and Vibration Cloth.) as non-ACM.

2.4: Recommendations

R-1: Asbestos abatement activities are recommended prior to any repair, renovation, or demolition activities which would disturb the matrix of confirmed ACM (identified in C-1).

It is recommended that any asbestos activity be performed in accordance with applicable EPA, OSHA, PA DEP, and City of Philadelphia regulatory requirements. In order to comply with these requirements the following is recommended:

Greenman Pedersen, Inc. -6-

1. Written EPA notification of demolition/renovation ten (10) working days prior to asbestos related activities, as required by the National Emission Standards for Hazardous Airborne Pollutants (NESHAP) of the Clean Air Act.

2. Development of a written Asbestos Abatement Project Design Specification, dictating abatement work practices and control measures to reduce airborne fiber concentrations, waste disposal requirements, and air sample collection and analysis requirements including the final clearance, (re-occupancy) criteria.

3. Selection of a licensed asbestos contractor for the performance of asbestos response activities.

4. Air sample collection and analysis subsequent to asbestos abatement activities in compliance with project design requirements for the re-occupancy by non-protected individuals.

R-2: In the event that the project is modified and will expand to other locations not included in this survey, or will impact suspect materials originally outside of the project scope, additional testing of suspect materials may be required.

Section 3: Lead Paint Screening

3.1: Inspection Personnel and Methods

The Lead Paint Assessment was completed on March 28 and 29, 2016 by Cocciardi representative Mr. Cody Youshock. The assessment identified three (3) representative surfaces that may be impacted by the proposed renovation activities. In accordance with standard industry sampling requirements, Cocciardi collected a bulk grab or composite sample from each representative area. Samples were collected in accordance with the following industry-standard protocols:

Cocciardi donned new nitrile gloves prior to each sample.

Plastic sheeting was placed beneath each sampled area.

Coatings were physically removed via a scraper and utility knife. All sample collection tools were cleaned prior to, and after sample collection. Precautions were taken to preclude inclusion of substrates in the sample collection. Heat guns with a maximum temperature below 1100°F were used to assist in sample collection for some areas.

Each sample was placed in a new, labeled, plastic centrifuge tube.

After collection, plastic sheeting was removed and the area was either wiped with a wet cloth or HEPA vacuumed.

Samples were subsequently submitted via Federal Express to Galson Laboratories, Inc. for analysis by Induced Coupled Plasma (ICP, EPA Method SW846-6010C). Galson is an American Industrial Hygiene Association (AIHA) National Lead Laboratory Accreditation Program (NLLAP) accredited laboratory for the referenced method.

Greenman Pedersen, Inc. -7-

3.2: Results

Results from this analysis are outlined in Table III, below. A copy of the laboratory analytical report and associated chain of custody are found in Appendix E.

Table III Summary of Analytical Results: Lead Paint via ICP (EPA SW846-6010C)

Greenman-Pedersen, Inc.: General Services Administration MATSSC: HVAC Improvement Project

March 28 and 29, 2016

Sample ID Representative Area Description Results Surface Substrate Color

150829-Pb1 NW Corner of Penthouse Wall Concrete Block White 0.0097%

150829-Pb2 NE Corner of Penthouse Floor Concrete Slab

Yellow/ Gray <0.0023%

150829-Pb3 SE Corner of Penthouse Floor Concrete Gray <0.0023%

Table III Notes:

%: Percent lead by weight

3.3: Conclusions

C-2: Analytical results of samples collected from surfaces potentially impacted by renovations have confirmed the presence of lead within surface coatings on white concrete block walls throughout the penthouse corner areas.

Results of remaining tested samples were not identified above the laboratory detection limit. However, these results alone are not sufficient in eliminating the need for compliance with the requirements outlined by the OSHA Lead in Construction Standard.

3.4: Recommendations

R-3: Due to the presence of lead paint on various surface coatings that may be impacted by renovations, all contractors performing lead-related activities, as defined by the OSHA Lead in Construction Standard in 29 CFR 1926.62 (including demolition, removing, salvaging, enclosing, encapsulating, etc.), are required to conform to all applicable regulations designated by the above standard. Applicable elements for compliance identified by the OSHA Lead in Construction Standard include, but are not limited to:

• Employee exposure assessments

• Personal and respiratory protective equipment

• Implementation of a lead compliance program

• Work practice and engineering controls

• Lead hygiene training

• Medical monitoring

Greenman Pedersen, Inc. -8-

Section 4: Certification

The information contained in this report is believed to be accurate and true to the best knowledge of the inspector(s). Findings and recommendations for this investigation are based on the observations of the conditions, as they existed at that time. The inspector(s) and Cocciardi and Associates, Inc. assumes no liability for financial or health consequences due to actions or lack of actions taken by the client as a result of this inspection.

Sincerely, Michael Baltrusaitis, CHMM, CSP Senior Professional Cocciardi and Associates, Inc.

Cody Youshock Safety, Health and Environmental Technologist Cocciardi and Associates, Inc.

cc: File Attachments

Appendix A

Scope Of Work

Provided To:

Greenman Pedersen, Inc.

GSA ▪ Asbestos/Lead Assessment

Appendix B

Public Health Service Asbestos Reinspection Report

Provided To:

Greenman Pedersen, Inc.

GSA ▪ Asbestos/Lead Assessment

Appendix C

PA DOLI Asbestos Inspector License and City of Philadelphia Asbestos Investigator

Provided To:

Greenman Pedersen, Inc.

GSA ▪ Asbestos/Lead Assessment

Appendix D

Laboratory Analytical Report And Associated COC (Asbestos - EMSL)

Provided To:

Greenman Pedersen, Inc.

GSA ▪ Asbestos/Lead Assessment

Appendix E

Laboratory Analytical Report And Associated COC (Lead - Galson)

Provided To:

Greenman Pedersen, Inc.

GSA ▪ Asbestos/Lead Assessment

Appendix F

SSA Lead Sampling Form Summary Report

Provided To:

Greenman Pedersen, Inc.

GSA ▪ Asbestos/Lead Assessment

SSA Lead Sampling Form Date: 3/29/16

Facility Name: MATSSC

Samples collected by: Cody Youshock (Cocciardi & Associates, Inc.)

Sample ID Sample Type Location/Rm# Room Type* Surface Surface Material Color Results # Comments §

(X) or (B) Sampled† Description‡ Sampled¥

150829-Pb1 B NW Corner Penthouse

Mechanical Room Wall Concrete Block Paint White 0.0097% Small Amount of

Lead Present

150829-Pb2 B NE Corner Penthouse

Mechanical Room Floor Concrete Slab Paint Yellow/

Gray <0.0023%

Below Laboratory

Detection Limit

150829-Pb3 B SE Corner Penthouse

Mechanical Room Floor Concrete Paint Gray <0.0023%

Below Laboratory

Detection Limit

* Mechanical room; office, corridor, etc

† Floor, wall, ceiling, pipe, etc ‡ duct, door, door frame, etc ¥ Paint, tile, other?

§ include detailed sample location within space and photo id (X) – XRF (B) - bulk paint chip # - mg/cm2 for XRF or % for bulk chip sample

SSA Lead Sampling Report

This cover report provides a summary of documentation of an activity impacting potential lead-containing material at Social Security Administration.

Date 3/29/16

Activity (paint chip sampling; XRF surface sampling; personal exposure monitoring; other – be specific)

Paint Chip Sampling

Location (Building / Room ID) MATSSC

Description of Activity

Paint Chip Sampling to facilitate HVAC Improvement Project

Detailed Description of Surface Impacted (Type; location in room; color; condition of material)

Concrete Block (White); Concrete Slab (Yellow/Gray); Concrete (Gray); All in good condition; Located throughout Penthouse areas

If Exposure Assessment (detailed description of equipment used, work practices, PPE employed) n/a

Atypical conditions that may have impacted results n/a

Summary of Analytical Results White Concrete Block yielded a result of 0.0097% lead by weight; All other components tested were below detection limits.

Conclusions Lead present within concrete block surfaces.

Applicable Recommendations

See final report.

SSA Lead Sampling Form attached? Yes

Chain of Custody attached? Yes

Lab Analyses & Certifications attached? Yes

Photos attached? No

Drawings attached? No

Field Notes attached? No

Name/Affiliation of report preparer Cody Youshock; Cocciardi and Associates, Inc.