Hampton - Asbestos and Lead Survey Report - Rev 2.pdf

Froehling & Robertson, Inc. 3015 Dumbarton Road Richmond, Virginia 23228 T 804.264.2701 www.fandr.com

A Minority-Owned Business

Update 2021 - winter

LIMITED ASBESTOS AND LEAD-BASED PAINT SURVEY REPORT

REVISION 2

Hampton VA Medical Center

Building 52

100 Emancipation Drive

Hampton, Virginia 23667

Prepared For:

Charlotte Engineers, LLP

5838 Monroe Road

Charlotte, NC 28212

Phone: 704.531.3000

Attention: Mr. Douglas Ehlers, PE

Email: dehlers@charlotteengineers.com

Re-Issue Date: June 8, 2021

F&R Project Number: 59Z-0149-REV 2

Prepared By:

E. Glenn Hargrove, CIH

Director of Industrial Hygiene

Reviewed By:

Jesse D. Phillips, CIH

Practice Leader, Industrial Hygiene Services dehlers Typewritten Text Appendix D

Charlotte Engineers, LLP Hampton, Virginia VAMC Building 52

F&R Project Number 59Z-0149-REV 2 i June 8, 2021

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1. PURPOSE

1.2. SITE DESCRIPTION

2.0 SCOPE OF SERVICES

3.0 LIMITED ASBESTOS-CONTAINING MATERIALS SURVEY

3.1. ASBESTOS-CONTAINING MATERIALS (ACM) METHODOLOGY

3.2. ASBESTOS-CONTAINING MATERIALS FINDINGS

3.3. ASBESTOS-CONTAINING MATERIALS INVENTORY

3.3.1. Trace Asbestos

3.3.2. Presumed Asbestos-Containing Materials

3.4. ASBESTOS-CONTAINING MATERIALS RECOMMENDATIONS

3.5. APPLICABLE REGULATIONS

3.5.1. EPA/NESHAP Regulations for Asbestos-Containing Materials

3.5.2. Virginia Asbestos Regulations

3.5.3. OSHA Asbestos Regulations

4.0 LIMITED LEAD-BASED PAINT SURVEY

4.1. LEAD-BASED PAINT SURVEY METHODOLOGY

4.1.1. XRF Testing

4.2. LEAD-BASED PAINT SURVEY FINDINGS

4.2.1. XRF Survey Results

4.2.1.1. Locations of Detected Lead-Based Paint

4.2.1.2. Inaccessible or Presumed Lead-Based Paint

4.3. LEAD-BASED PAINT CONCLUSIONS & RECOMMENDATIONS

4.4. APPLICABLE REGULATIONS

4.4.1. OSHA Regulations for Lead-Based Paint

4.4.2. EPA Regulations for Lead-Based Paint

4.4.2.1. Disposal

4.4.3. Virginia Lead Regulations

5.0 LIMITATIONS

F&R Project Number 59Z-0149-REV 2 ii June 8, 2021

APPENDICES

Appendix A

F&R Personnel and Laboratory Accreditations

Appendix B

Figures

Asbestos Sample Location Figures

Asbestos-containing Mastic Figures

Fire Door Figures

Appendix C

Laboratory Certificates of Analysis

Bulk Sample Chain of Custody Forms

Photographic Documentation

Section 1

Asbestos-Containing Materials

Section 2

Lead-Based Paint

Appendix E

Explanation of XRF Data Table

XRF Data Table

XRF Performance Characteristic Sheet

F&R Project Number 59Z-0149-REV 2 1 June 8, 2021

1.0 INTRODUCTION

Froehling & Robertson, Inc. (F&R) conducted limited asbestos inspection and lead-based paint

(LBP) screening services during the period from April 13-16, 2021 at the Hampton Virginia

Veterans Affairs Medical Center (VAMC) Building 52 addressed 100 Emancipation Drive in

Hampton, Virginia. F&R returned to the site on May 20, 2021 to conduct additional supplemental testing to characterize the sub-floor at which time additional flooring was detected beneath the upper sub-floor. It is F&R’s understanding that the structure is the subject of planned demolition which will impact building materials. The following sections document the survey procedures and results. Refer to Appendix A for Personnel Accreditation documentation of F&R personnel associated with this survey.

1.1. Purpose

The purpose of the limited asbestos inspection and LBP screening is to identify asbestos-containing materials (ACMs) and LBP coatings that may require appropriate removal, handling, and disposal procedures prior to scheduled demolition activities at the subject property. This survey is to aid in the determination of health and safety requirements during the conduct of work which may impact identified materials.

1.2. Site Description

Building 52 is a 19,335 square foot (SF) two story brick and joist structure with a basement and adjoining crawlspace, and an attic. The building consists of a combination of masonry and wood-frame construction. Perimeter walls, situated on concrete spread footers, comprise red brick exterior façades and both white glazed and painted brick interior finishes. The sloped roof comprises wood trusses and plywood decking finished with asphalt shingles with felt vapor barrier beneath. Two canopy roofs along the front and back portions of the building are formed of a membrane which overlays a gypsum roof layer. During the follow up May 20, 2021 testing, concealed floor finishes and historical subflooring were identified beneath subflooring present beneath the visible floor finishes at the facility which had been installed on top of older materials.

The wooden subfloors are supported by wooden open-web joists. Interior renovations have resulted in gypsum wallboard system finishes concealing historic masonry finish materials.

Interior finishes also include vinyl floor tile, vinyl cove base, vinyl stair tread, original interior brick walls behind gypsum board, ceiling tiles within a lay-in-ceiling system below an older pressed metal ceiling, and plaster, among others.

It should be noted that material and color descriptions are subjective and that, due to the nature of the environment, identical materials and colors may have been labeled as different depending on the lighting, other colors in the area, and other factors. Additionally, acoustic ceiling panels were described subjectively and differentiated as possible based on aesthetic details such as texture variations.

F&R Project Number 59Z-0149-REV 2 2 June 8, 2021

2.0 SCOPE OF SERVICES

As outlined in F&R proposal number 2059-00846 Rev. 2, the survey included the following services with respect to the proposed demolition activities:

Identification and sampling, as necessary, of suspect ACMs for analysis.

Determination of the presence, location, and estimated quantity of identified ACMs.

Testing, as necessary, of surface coatings for the presence of Lead.

F&R was also requested to prepare abatement project design specifications for materials within the structure which may require abatement and/or special handling and disposal considerations.

The abatement project design specifications will be provided under a separate cover to be incorporated as part of a larger project manual for bidding purposes.

Note that the proposed services had anticipated the need for evaluation of select areas within

Building 110 at the VAMC campus with respect to ACM and LBP; however, evaluation of this building was deemed unnecessary due to the existence of sufficient survey data from earlier efforts. Consequently, asbestos and lead evaluation for Building 110 was not conducted and is not reported herein. Additionally, the proposal accounted for evaluation of mold within Building

110. This was conducted but is reported under separate cover.

3.0 LIMITED ASBESTOS-CONTAINING MATERIALS SURVEY

F&R’s Virginia Licensed Asbestos Building Inspector, E. Glenn Hargrove (Virginia Asbestos License

#3303001281), conducted the Asbestos Survey of the Building 52 located at 100 Emancipation

Drive in Hampton, Virginia on April 13-16, 2021. Other structures onsite were not included. Mr.

Hargrove was further assisted by F&R industrial hygienist Mr. James Wallace.

Federal Regulations (40 CFR Part 61, Subpart M – National Emission Standards for Hazardous Air

Pollutants (NESHAP), as well as Virginia Department of Labor and Industry regulations require a thorough asbestos inspection of the structure to be conducted prior to the commencement of demolition activities. An ACM is defined by the Occupational Safety & Health Administration

(OSHA) and the Environmental Protection Agency (EPA) as material containing greater than one percent (1%) asbestos.

3.1. Asbestos-Containing Materials (ACM) Methodology

This survey was conducted in general accordance with the Federal NESHAP and applicable State regulations for the presence of ACMs. The survey was characterized by a visual inspection and sampling of suspect building components at the subject property to be impacted by the proposed demolition activities.

F&R Project Number 59Z-0149-REV 2 3 June 8, 2021

Guidelines utilized in the asbestos survey were established by the EPA, ASTM International

(ASTM), and The Environmental Information Association, Inc. (EIA). Utilized guidelines included:

the Asbestos Hazard Emergency Response Act (40 CFR Part 763, Subpart E – Asbestos-Containing

Materials in Schools (cited as AHERA)), ASTM Standard E2356-14 Standard Practice for

Comprehensive Building Asbestos Surveys, and the EIA publication Managing Asbestos in

Buildings: A Guide for Owners and Managers – A Revision to the United States Environmental

Protection Agency’s 1985 document Guidance for Controlling Asbestos-Containing Materials in

Buildings (EPA 560/5-85-024) Known as the Purple Book.

During the initial site visit F&R’s aforementioned industrial hygienist collected and submitted suspect asbestos-containing bulk samples to the laboratory, of which, a total of eighty one (81) suspect asbestos-containing bulk samples with discernable layers were analyzed. Due to multiple layers, a total of one hundred and twenty five (125) layers were analyzed. During the May 2021 site visit the industrial hygienist collected and submitted two (2) additional suspect asbestos-containing bulk samples with discernable layer for analysis. Due to multiple layers, a total of four

(4) samples were analyzed. For this report, a total of eighty three (83) samples were submitted for analysis for which a total of one hundred and twenty nine (129) layers were analyzed.

Samples of suspect ACMs were organized as per the AHERA concept of Homogeneous Area (HA), collected, and transported to the Environmental Hazards Services, L.L.C. (EHS) testing laboratory.

EHS is a National Institute for Standards and Technology (NIST) National Voluntary Laboratory

Accreditation Program (NVLAP) accredited laboratory (NVLAP Lab Code: 101882-0) and Virginia licensed asbestos laboratory, in Richmond, Virginia, for analysis by Polarized Light Microscopy

(PLM) following EPA Method 600/R-93/116 and 600/M4-82-020. Refer to Appendix A for

Laboratory Certificates of Accreditations. Refer to Appendix C for Laboratory Certificates of

Analysis and Bulk Sample Chain of Custody Forms for further description of sampled materials/analytical results. Photographs of certain sampled building materials are included in

Appendix D.

F&R collected bulk samples of roofing materials during this survey. Sampling activities were not coordinated with a professional roofing contractor for repair purposes; no contact information was provided or indicated as preferred by the Client. The sample locations were not repaired;

however, the space is unoccupied and slated for demolition. If concern related to water intrusion exists, repairs should be made.

Building materials considered not suspect for asbestos were excluded from the sampling approach at the discretion of our inspector(s). In particular, masonry materials such as structural concrete, ceramic tile, grout, brick, mortar, and concrete masonry unit (CMU) block were excluded as was obvious fiberglass insulation; these have been confirmed as non-asbestos containing on many other projects based on F&R’s experience. Masonry materials which constitute a surfacing or troweled on finish such as plaster, stucco, or parging were included, where observed. Additionally, jacketing associated with obvious fiberglass Thermal Systems

F&R Project Number 59Z-0149-REV 2 4 June 8, 2021

Insulation (TSI) was included even when the fiberglass was excluded. If masonry or other materials were observed which were clearly associated with a construction application where asbestos was historically utilized, such as cementitious material at a fireplace thimble or in a TSI application, these materials were collected for analysis if accessible. Investigation of possible steam tunnels associated with the heating system for the building was also not conducted.

3.2. Asbestos-Containing Materials Findings

The following material types were identified, sampled, and accordingly homogenized based upon similar construction discovered during bulk sampling:

Vinyl composite floor tile and associated mastic to include leveling compound;

Vinyl covebase and associated mastic;

Stair tread and associated mastic;

Concrete sub-floor backing;

Black and white caulking on HVAC components;

Gypsum board with joint compound;

Ceiling tiles;

Red firestop caulking;

Ceiling plaster;

Roofing asphalt shingles and associated felt;

Exterior caulks;

HVAC vibration dampers.

The following table presents a summary of survey results from sampling events performed on April

13-16, and May 20, 2021. Refer to Appendix B for illustration of the approximate locations of collected bulk samples. Positive asbestos samples (samples containing >1% asbestos) as well as materials containing detectable concentrations that are <1% (trace) are in BOLD type.

SUSPECT ASBESTOS-CONTAINING MATERIALS SAMPLE INFORMATION

HA

Sample

Situation1 Sample Location(s)

Material

Description/Function Laboratory Description

Percent

Asbestos

1A

1 Hallway at Room 107

12 x 12” White Vinyl

Floor Tile

Off White Vinyl;

Homogeneous

NAD

Yellow Mastic Yellow Adhesive;

Homogeneous

NAD

1A-

Lower

Lower Layer Leveling

Compound

Gray Granular;

Homogeneous

NAD

Lower Layer Black

Mastic

Black Tar-Like;

Homogeneous 4% Chrysotile

1 1B 1 Hallway at Room 107 12 x 12” White Vinyl

Floor Tile

Off White Vinyl;

Homogeneous

NAD

F&R Project Number 59Z-0149-REV 2 5 June 8, 2021

HA

Sample

Situation1 Sample Location(s)

Material

Description/Function Laboratory Description

Percent

Asbestos

Yellow Mastic Yellow Adhesive;

Homogeneous

NAD

1B-

Lower

Lower Layer Leveling

Compound

Gray Granular;

Homogeneous

NAD

Lower Layer Black

Mastic

Black Tar-Like;

Homogeneous 4% Chrysotile

1 1C 2 Room 209

12 x 12” White Vinyl

Floor Tile

Off White Vinyl;

Homogeneous

NAD

Black Mastic Black Tar-Like;

Homogeneous 4% Chrysotile

1 1D 2 Room 220

12 x 12” Inch White

Vinyl Floor Tile

Off White Vinyl;

Homogeneous

NAD

Black Mastic Black Tar-Like;

Homogeneous 4% Chrysotile

1 1E 2 Room 201

12 x 12” Floor Tile Tan, White Vinyl;

Homogeneous

NAD

Yellow Mastic Yellow Adhesive;

Homogeneous

NAD

Leveling Compound Gray Granular;

Homogeneous

NAD

Black Mastic Black/Brown Tar-Like

Adhesive; Inhomogeneous 5% Chrysotile

1 1F 2 Room 207

Yellow Mastic Yellow Adhesive; Gray

Granular; Inhomogeneous

NAD

Black Mastic Black Tar-Like;

Homogeneous 4% Chrysotile

2 2A 2 Room 201

12 x 12” White Vinyl

Floor Tile

White Vinyl;

Homogeneous

NAD

Yellow Mastic Pale Yellow Adhesive;

Homogeneous

NAD

2 2B 1 Room 110

12 x 12” White Vinyl

Floor Tile

White Vinyl;

Homogeneous

NAD

Yellow Mastic Pale Yellow Adhesive;

Homogeneous

NAD

Leveling Compound Gray Granular;

Homogeneous

NAD

2 2C 1 Room 111

12 x 12” White Vinyl

Floor Tile

White Vinyl;

Homogeneous

NAD

Yellow Mastic Pale Yellow Adhesive;

Homogeneous

NAD

Leveling Compound Gray Granular;

Homogeneous

NAD

3 3A 1 Room 115

12 x 12” White Vinyl

Floor Tile

White Vinyl;

Homogeneous

NAD

Yellow Mastic Yellow Adhesive;

F&R Project Number 59Z-0149-REV 2 6 June 8, 2021

HA

Sample

Situation1 Sample Location(s)

Material

Description/Function Laboratory Description

Percent

Asbestos

Leveling Compound Gray Granular;

Homogeneous

NAD

3 3B 1 Room 115

12 x 12” White vinyl

Floor Tile

White Vinyl;

Homogeneous

NAD

Yellow Mastic Yellow Adhesive;

Homogeneous

NAD

3 3C 2 Room 203 12 X 12” White vinyl

Floor Tile

White/Pink Vinyl;

Homogeneous

NAD

4 4A 2 Room 203

12 x 12” Beige Vinyl

Floor Tile Beige Vinyl; Homogeneous NAD

Amber Mastic Amber Adhesive;

Homogeneous

NAD

5 5A 2 Room 203

12 x 12” Vinyl Floor

Tile Tan Vinyl; Homogeneous NAD

Yellow Mastic Yellow Adhesive;

Homogeneous

NAD

Leveling Compound Gray Granular;

Homogeneous

NAD

6 6A 1 Hallway at Room 118

12 x 12” Brown Vinyl

Floor Tile

Tan/Light Brown Vinyl;

Homogeneous

NAD

Yellow Mastic Yellow Adhesive;

Homogeneous

NAD

6 6B 1 Room 123

12 x 12” Brown Vinyl

Floor Tile

Tan/Light Brown Vinyl;

Homogeneous

NAD

Black Mastic Black Tar-Like;

Homogeneous 4% Chrysotile

7 7A 2 Room 207

12 x 12” Vinyl Floor

Tile

White Vinyl;

Homogeneous

NAD

Yellow Mastic Yellow Adhesive;

Homogeneous

NAD

Black Mastic and

Leveling Compound

Black Tar-Like; Gray

Granular; Inhomogeneous

Trace <1%

Chrysotile

Lab Note: Unable to separate layers of black mastic and leveling compound.

7 7B 2 Room 210

12 x 12” White Vinyl

Floor Tile

White Vinyl;

Homogeneous

NAD

Yellow Mastic Yellow Adhesive;

Homogeneous

NAD

Black Mastic and

Leveling Compound

Black Tar-Like; Gray

Granular; Inhomogeneous 3% Chrysotile

Lab Note: Unable to separate layers of black mastic and leveling compound.

7 7C 2 Room 220

12 x 12” White Vinyl

Floor Tile

White Vinyl;

Homogeneous

NAD

Black Mastic Black Tar-Like;

4% Chrysotile

F&R Project Number 59Z-0149-REV 2 7 June 8, 2021

HA

Sample

Situation1 Sample Location(s)

Material

Description/Function Laboratory Description

Percent

Asbestos

8 8A 2 Hallway at Room 216

12 x 12” Vinyl Floor

Tile

White Vinyl;

Homogeneous

NAD

Black Mastic Black Tar-Like;

Homogeneous 4% Chrysotile

8 8B 2 Stairwell Foyer

12 x 12” Vinyl Floor

Tile Tan Vinyl; Homogeneous NAD

Mastic Yellow Adhesive;

Homogeneous

NAD

Leveling Comp.

Gray Granular;

Homogeneous

NAD

8 8C 2 Hallway at Room 207

12 x 12” Vinyl Floor

Tile White vinyl; Homogeneous NAD

Mastic Black/Amber Tar-like

Adhesive; Inhomogeneous 6% Chrysotile

9 9A 1 Room 102 12 x 12” Green Vinyl

Floor Tile

Light Green Vinyl;

Homogeneous

NAD

9 9B 1 Room 102 12 x 12” Green Vinyl

Floor Tile

Light Green Vinyl;

Homogeneous

NAD

10 10A 1 119

Yellow Mastic Green/Yellow Adhesive

Inhomogeneous

NAD

12 x 12” Inch Vinyl

Floor Tile (under carpet)

White Vinyl;

Homogeneous

NAD

Black Mastic Black Tar-Like;

Homogeneous 6% Chrysotile

11 11A 1 Room 110

Black Vinyl Cove Base Black Vinyl; Homogeneous NAD

Yellow Mastic Yellow Adhesive;

Homogeneous

NAD

11 11B 1 Room 201

Black Vinyl Cove Base Brown Vinyl;

Homogeneous

NAD

Tan Mastic Tan Adhesive;

Homogeneous

NAD

12 12A 1 Room 102

Green Vinyl Cove Base Green Vinyl;

Homogeneous

NAD

Tan Mastic Tan Adhesive;

Homogeneous

NAD

12 12B 1 Room 102

Green Vinyl Cove Base Green Vinyl;

Homogeneous

NAD

Tan Mastic Tan Adhesive;

Homogeneous

NAD

13 13A 1 Room 115

Gray Vinyl Cove Base Gray Vinyl; Homogeneous NAD

Yellow Mastic Yellow Adhesive;

F&R Project Number 59Z-0149-REV 2 8 June 8, 2021

HA

Sample

Situation1 Sample Location(s)

Material

Description/Function Laboratory Description

Percent

Asbestos

13 13B 1 Room 115

Gray Vinyl Cove Base Gray Vinyl; Homogeneous NAD

Yellow Mastic Yellow Adhesive;

Homogeneous

NAD

14 14A 2 Middle of Stairwell

Stair Tread Beige Vinyl; Homogeneous NAD

Tan Mastic Tan Adhesive;

Homogeneous

NAD

Brown Mastic Dark Brown Adhesive;

Homogeneous

NAD

Gray Caulking Gray Pliable;

Homogeneous

NAD

14 14B 2 North Stairwell at

Top

Stair Tread Green Vinyl;

Homogeneous 2% Chrysotile

Yellow Mastic Pale Yellow Adhesive;

Homogeneous

NAD

14 14C 2 South Stairwell at

Middle

Stair Tread Green Vinyl;

Homogeneous 2% Chrysotile

Brown Mastic Brown Brittle Adhesive;

Homogeneous

NAD

15 15A B Middle of Basement Paper backing to subfloor

Black Tar-Like; Brown

Fibrous; Inhomogeneous

NAD

15 15B B Middle of Basement Paper backing to subfloor

Black Tar-Like; Brown

Fibrous; Inhomogeneous

NAD

16 16A 1

First Floor Men’s

Restroom on HVAC

Duct

Black Caulking Dark Brown Pliable;

Homogeneous 3% Chrysotile

16 16B 1

First Floor Women’s

Restroom on HVAC

Duct

Black Caulking Dark Brown Pliable;

Homogeneous 3% Chrysotile

16 16C 2

Second Floor Men’s

Restroom on HVAC

Duct

Black Caulking Dark Brown Pliable;

Homogeneous 3% Chrysotile

17 17A 1

First Floor Men’s

Restroom on HVAC

Duct

White Caulking White Pliable;

Homogeneous

NAD

17 17B 1

First Floor Women’s

Restroom on HVAC

Duct

White Caulking White Pliable;

Homogeneous

NAD

17 17C 2

Second Floor Men’s

Restroom on HVAC

Duct

White Caulking White Pliable;

Homogeneous

NAD

17 17D 4 Attic-North AHU White Caulking White Pliable;

Homogeneous

NAD

17 17E 4 Attic-South AHU White Caulking White Pliable;

F&R Project Number 59Z-0149-REV 2 9 June 8, 2021

HA

Sample

Situation1 Sample Location(s)

Material

Description/Function Laboratory Description

Percent

Asbestos

18 18A 1 Room 110 on HVAC

Duct White Caulking

White Pliable;

Homogeneous

NAD

18 18B 1 Room 125 on HVAC

Duct White Caulking

White Pliable;

Homogeneous

NAD

18 18C 2 Hallway at Room 210 on HVAC Duct White Caulking

White Pliable;

Homogeneous

NAD

19 19A 1 Room 110 Gypsum Board

White Powdery; Granular;

Brown Fibrous;

Inhomogeneous

NAD

19 19B 1 Room 125 Gypsum Board

White Powdery; Granular;

Brown Fibrous;

Inhomogeneous

NAD

19 19C 1 Hallway at Room 116 Gypsum Board

White Powdery; Granular;

Brown Fibrous;

Inhomogeneous

NAD

19 19D 2 Room 203 Gypsum Board

White Powdery; Granular;

Brown Fibrous;

Inhomogeneous

NAD

19 19E 2 Room 208 Gypsum Board

White Powdery; Granular;

Brown Fibrous;

Inhomogeneous

NAD

19 19F 2 Room 215 Gypsum Board

White Powdery; Granular;

Brown Fibrous;

Inhomogeneous

NAD

19 19G 4 Attic-North AHU Wall Gypsum Board White Powdery; Granular;

Inhomogeneous

NAD

20 20A 1 Room 110 Ceiling Tile with Pits and Pinholes

White Paint; Gray Fibrous;

Inhomogeneous

NAD

20 20B 1 Room 125 Ceiling Tile with Pits and Pinholes

White Paint; Gray Fibrous;

Inhomogeneous

NAD

20 20C 2 Room 210 Ceiling Tile with Pits and Pinholes

White Paint; Gray Fibrous;

Inhomogeneous

NAD

20 20D 2 Hallway at Room 221 Ceiling Tile with Pits and Pinholes

White Paint; Gray Fibrous;

Inhomogeneous

NAD

21 21A 1 Room 123 Red Firestop Caulking Red Pliable; Homogeneous NAD

21 21B 1 Room 110 Red Firestop Caulking Red Pliable; Homogeneous NAD

22 22A 1 Women’s Restroom Plaster White/Brown Granular;

Inhomogeneous

NAD

22 22B 1 Women’s Restroom Plaster White/Brown Granular;

Inhomogeneous

NAD

22 22C 1 Women’s Restroom Plaster White/Brown Granular;

Inhomogeneous

NAD

23 23A R Porch Canopy-Rear Roofing

White Powdery; Dark

Green Adhesive;

Inhomogeneous

F&R Project Number 59Z-0149-REV 2 10 June 8, 2021

HA

Sample

Situation1 Sample Location(s)

Material

Description/Function Laboratory Description

Percent

Asbestos

23 23B R Porch Canopy-Front Roofing

White Powdery; Dark

Green Adhesive;

Inhomogeneous

NAD

24 24A R Porch Canopy on Wall Black Caulking Black Tar-Like;

Homogeneous 7% Chrysotile

25 25A R Roof Asphalt Shingle Black Aggregate; Tar-Like

Fibrous; Inhomogeneous

NAD

25 25B R Roof Asphalt Shingle Black Aggregate; Tar-Like

Fibrous; Inhomogeneous

NAD

26 26A 3 Attic-North Air

Handler Unit White Caulking

White Pliable;

Homogeneous

NAD

26 26B 3 Attic-North Air

Handler Unit White Caulking

White Pliable;

Homogeneous

NAD

26 26C 3 Attic-South Air

Handler Unit White Caulking

White Pliable;

Homogeneous

NAD

26 26D 3 Attic-South Air

Handler Unit White Caulking

White Pliable;

Homogeneous

NAD

27 27A 3 Attic-South Air

Handler Unit Vibration Damper

Black Pliable; Fibrous;

Homogeneous

NAD

28 28A E

Exterior Window

Casing on Canopy at

Fitness Room

White Caulking White Pliable;

Homogeneous

NAD

28 28B E Front Window of

Room 101 White Caulking

White Pliable;

Homogeneous

NAD

29 29A E Canopy at Base of

Brick Wall at Flashing Gray Caulking

Gray Pliable;

Homogeneous

NAD

30 30A E Residual Caulking on

Front Columns Tan Caulking Tan Brittle; Homogeneous 3% Chrysotile

30 30B E Residual Caulking on

Front Columns Tan Caulking Tan Brittle; Homogeneous 3% Chrysotile

31 31A E Exterior Wall at Room

Residual Red Caulking

Brown Brittle;

Homogeneous 8% Chrysotile

32 32A 2 Kitchen, in Room 217

Under sub-flooring

Off-white Vinyl Floor

Tile

Beige Vinyl;

Homogeneous 3% Chrysotile

Black Mastic Black Adhesive;

Homogeneous 8% Chrysotile

33 33A 2 Room 201

Under sub-flooring

Green Vinyl Floor Tile

Green Vinyl;

Homogeneous 2% Chrysotile

Black Mastic Black Adhesive;

Homogeneous 4% Chrysotile

1Situation: 1 –First Floor; 2 – Second Floor; 3-Attic; B – Basement; R - Roof; E – Exterior

Bold: Asbestos Containing Material or Trace (<1%) Asbestos Present

F&R Project Number 59Z-0149-REV 2 11 June 8, 2021

3.3. Asbestos-Containing Materials Inventory

While reasonable effort is made by the asbestos inspector to conduct a thorough inspection of the interior and exterior of the facility, some areas remained inaccessible due to certain site conditions. F&R conducted a survey of the reasonably and safely accessible portions of the building to be impacted by the planned demolition. Rooms 105, 213, and 222 were not accessed during the assessment. Potentially concealed building materials detected beneath the upper sub-floor were not exhaustively characterized. Suspect ACM in these spaces which were not represented during this survey should be presumed positive unless the material can be positively identified as a material that has been tested. Two fireplaces located within Room 101 have been covered by newer construction and were inaccessible during the survey. These areas should be observed prior to demolition of the structure to determine if materials suspect to contain asbestos are present.

The following table presents identified materials containing greater than 1% asbestos.

Photographic documentation of ACMs for reference is provided as Appendix D.

ASBESTOS-CONTAINING MATERIALS INVENTORY

HA #

Material

Description Material Location(s)

Result

(Percent

ACM)

NESHAP Category1 Estimated

Quantity2

1,6,7, Black Mastic

Most flooring on the

1st and 2nd floors and stairwells

4-6%

Chrysotile Category II Non-Friable 14,250 SF

32 &

Vinyl Floor Tile and Black

Mastic

Presumed present under upper wood sub-floor on both 1st and 2nd floors and stairwells

3-8%

Chrysotile Category I/II Non-Friable 18,000 SF

Green Vinyl

Stair Tread

North and south stairwells

2%

Chrysotile Category I Non-Friable 150 SF

16 Black Caulking HVAC Metal Ducting 3%

Chrysotile Category II Non-Friable 200 LF 3

24 Black Caulking Exterior Walls 7%

Chrysotile Category II Non-Friable 2 SF 4

30 Tan Caulking Residual Caulking on

Columns

3%

Chrysotile Category II Non-Friable 2 SF 5

Black Mastic and Leveling

Compound3

Various Areas

<1%(trace)-

3%

Chrysotile

Category II Non-Friable NA

1EPA/NESHAP Category: See Section 3.5.1 for details.

2Estimated Quantity: Note: All quantities are estimates based on visible and inferred site conditions; actual quantities may vary.

SF = Square Feet | LF = Linear Feet | NA = Not Applicable | TBD = To Be Determined

F&R Project Number 59Z-0149-REV 2 12 June 8, 2021

3 The estimated linear footage applies to the estimate of HVAC metal duct that will require removal to effect the abatement of the caulk.

4 The caulking is distributed in small amounts over a broad area on the columns and exterior walls; however, the total amount of caulk would be considered small. See photographs in Section 1 of Appendix D for visual representation.

5 Lab unable to separate layers of black mastic and leveling compound. It is likely that the black mastic is positive and the leveling compound is negative, as indicated by other individual sample results of the materials. See Section

3.3.1, below, for additional detail. Abatement of the mastic from the leveling compound may be impractical due to the inability to effectively separate the two materials.

F&R presumes that, where materials have been documented to be ACMs and where those materials are similar to other materials which have not been found to be positive, those similar materials will be considered to be ACMs (i.e. where one material was analyzed and found to be positive, it is prudent to consider other similar materials positive, despite potential analytical data to the contrary).

3.3.1. Trace Asbestos

Asbestos (Trace <1%) was detected in one (1) representative sample of the HA #7 black mastic and leveling compound located in room 207 of Building 52. However, the lab was unable to separate the layer of black mastic from the layer of leveling compound. It is likely that the black mastic is positive and the leveling compound is negative as indicated by individual samples of the materials.

3.3.2. Presumed Asbestos-Containing Materials

During the conduct of this survey, sampling was limited to those materials which were within the areas designated by the client, which were safely accessible, and which were able to be sampled without damaging systems or structures. As such, some materials should be presumed to be positive, unless sampling is conducted and shown to be negative. Such presumed asbestos containing materials (PACMs) include, but are not limited to:

Fire door interiors, Gaskets and packing materials in plumbing or hydraulic systems, where present, Electrical panel backing/arc deflectors/spark arresters, Specialized equipment within chemical handling structures, Roofing materials not already tested, Wiring insulation or other live electrical system components, Chimneys and flues or other cementitious pipes or panels, Fire suppression curtains or blankets, HVAC duct vibration cloth of an appearance not already tested, F&R Project Number 59Z-0149-REV 2 13 June 8, 2021

Thermal system insulations in steam tunnels;

Materials in Rooms 105, 213, and 222 which were not represented during this survey

Materials associated with two fireplaces located within Room 101;

Et cetera.

As noted above, select non-suspect building materials were excluded from the sampling and analysis; however, without confirmation sampling, F&R cannot definitively affirm that detectable concentrations of asbestos in such materials are absent.

Note that asbestos was used in over 3,000 known products and was used extensively in construction materials including in insulation and finish materials such as gypsum board-based systems, acoustical tiles, caulks and mastics, vinyl-based materials, and specialty products.

Asbestos also continues to be used in new construction because, as stated by the EPA, "the manufacture, importation, processing, and distribution in commerce of [various] products […] are not banned.”

3.4. Asbestos-Containing Materials Recommendations

As detailed above, several materials were identified as asbestos-containing, utilized in various instances throughout the structure.

Prior to impacting the identified or presumed ACMs via demolition, F&R recommends that the

ACMs be appropriately removed, handled, and disposed of by an appropriately licensed/accredited Abatement Contractor utilizing appropriately licensed/accredited personnel.

Best practices dictate that an asbestos abatement specification document be prepared which details project-specific work plans and requirements. This abatement specification document should incorporate delineation of identified or presumed ACMs and should be furnished by the client or building owner to contractors for bidding purposes. Appropriately licensed or accredited personnel must prepare and/or review such specification documents. This survey report should not be used for bidding purposes.

F&R notes that the Contractor may leave select Category I and II non-friable materials in the building during demolition with the following constraints:

a. The landfill receiving these materials (Category I and/II non-friable) must be notified in writing and must be willing to receive these materials.

b. The Contractor cannot make these materials friable during demolition by demolition methods including, but not limited to, compaction of the debris. The Contractor cannot salvage the mixed debris following demolition.

c. During demolition, no visible emissions of dust are allowed. The Contractor must use dust control measures (i.e., water) during demolition.

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d. The demolition is considered a Class II asbestos abatement activity and the demolition contractor must be in compliance with all appropriate OSHA requirements.

F&R further recommends that a third party Asbestos Professional be retained to provide on-site surveillance and guidance of the Asbestos Abatement Contractor to confirm complete and proper removal/disposal of ACMs in accordance with applicable federal, state, and local regulations. This recommendation is made as a best practice to reduce potential exposure to workers and limit liability.

The Client should note that F&R has encountered instances in which materials were analyzed by

Polarized Light Microscopy (PLM) (following EPA Method 600/R-93/116) for the presence of asbestos with a result of “None Detected”, but when analyzed by Transmission Electron

Microscopy (TEM) for Non-friable Organically Bound (NOB) bulk material, analytical results have indicated that asbestos is present in quantities greater than 1%. The client should be aware that

F&R has samples analyzed by the PLM method for a number of reasons (including financial and time considerations) and that this method is considered acceptable in the State of Virginia;

however, some firms employ the more stringent TEM method which is required in some states.

Therefore, it is possible that some materials identified as containing no asbestos within this report may, if subjected to a more stringent analytical method, reveal the presence of asbestos at concentrations of 1% or greater.

In addition, it should be noted that through NESHAP Applicability Determinations, asbestos bulk samples analyzed via PLM which indicate a result of asbestos content to be less than ten (10) percent, including trace amounts (<1%), the material in question shall either be assumed to be an ACM or further analyzed via PLM Point Count or TEM to verify asbestos content. Results obtained via PLM Point Count or TEM analysis shall supersede previous results obtained by standard PLM analysis. Samples with analytical results via PLM which indicate that no asbestos was detected are not required to be further analyzed via PLM Point Count or TEM.

As noted in Section 3.3, Rooms 105, 213, and 222 were not accessed during the assessment.

Suspect ACM in these spaces which were not represented during this survey should be presumed positive unless the material can be positively identified as a material that has been tested. Two fireplaces located within Room 101 have been covered by newer construction and were inaccessible during the survey. These areas should be observed prior to demolition of the structure to determine if materials suspect to contain asbestos are present.

Should additional suspect ACMs be discovered during renovation and/or demolition activities that have not been sampled and will be disturbed, F&R recommends the work be temporarily halted. Samples of suspect materials should be collected, analyzed, and handled accordingly prior to the resumption of renovation and/or demolition activities.

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3.5. Applicable Regulations

3.5.1. EPA/NESHAP Regulations for Asbestos-Containing Materials

The U.S. Environmental Protection Agency promulgated the National Emission Standards for

Hazardous Air Pollutants (NESHAP) [40 CFR Part 61], which addresses the application, removal, and disposal of asbestos-containing materials (ACM). Under NESHAP the following categories are defined for asbestos-containing materials:

Friable - When dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Non-friable - When dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Category I Non-friable ACM - Packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1% asbestos.

Category II Non-friable ACM – Material, excluding Category I Non-friable ACM, which contains more than 1% asbestos.

Regulated Asbestos Containing Material (RACM) – One of the following:

1. Friable ACM

2. Category I Non-friable ACM that has become friable.

3. Category I Non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading.

4. Category II Non-friable ACM that has a high probability of becoming, or has become, friable by the forces expected to act on the material in the course of demolition or renovation operations.

Under NESHAP, the following actions are required:

1. Prior to the commencement of demolition or renovation activities, the building owner must inspect the affected facility or part of the facility where the demolition or renovation activities will occur for the presence of asbestos.

2. Remove RACM from the facility before activities begin that would break up, dislodge, or similarly disturb the material or preclude access for subsequent removal.

3. ACM need not be removed before demolition if:

a) It is Category I non-friable ACM that is not in poor condition.

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b) It is on a facility component that is encased in concrete or other similar material and is adequately wet whenever exposed.

c) It was not accessible for testing and was therefore not discovered until after demolition began and because of the demolition the material cannot be safely removed.

d) It is Category II non-friable ACM and the probability is low that the material will become crumbled, pulverized, or reduced to powder during demolition.

3.5.2. Virginia Asbestos Regulations

The Virginia Department of Labor and Industry (DOLI) regulates asbestos through enforcement of the Virginia Occupational Safety and Health (VOSH) regulations, enforcement of the

Environmental Protection Agency's National Emission Standards for Hazardous Air Pollutants

(NESHAP), and enforcement of the Asbestos Notification regulations found in the Labor Laws of

Virginia (§40.1-51.20). Agency locations and regulations can be found on the agency Web site http://www.doli.virginia.gov.

The Virginia Department of Professional and Occupational Regulation (DPOR) is responsible for company and individual licensure in Virginia. Licensure and regulatory information can be found on DPOR's Web site http://www.dpor.virginia.gov/

The Virginia Department of Environmental Quality (DEQ) is responsible for the regulation of landfills in Virginia. Information on the disposal of asbestos in Virginia landfills can be obtained from the DEQ Web site http://www.deq.state.va.us/.

3.5.3. OSHA Asbestos Regulations

The Occupational Safety and Health Administration (OSHA) regulates employee exposure to asbestos under 29 CFR 1926.1101 and 29 CFR 1910.1001. Work associated with known or suspect ACMs must be conducted according to these regulations in addition to the noted EPA regulations.

4.0 LIMITED LEAD-BASED PAINT SURVEY

F&R’s Virginia Licensed Lead-Based Paint Inspector/Risk Assessor, E. Glenn Hargrove (License

#3356001115), performed the testing of surface coatings for lead on April 14 and 16, 2021. Refer to Appendix A for F&R Personnel Accreditation Documentation.

F&R Project Number 59Z-0149-REV 2 17 June 8, 2021

4.1. Lead-Based Paint Survey Methodology

The survey was conducted in general accordance with EPA’s work practice standards for conducting LBP activities (40 CFR 745.227), and the HUD Guidelines for the Evaluation and

Control of Lead-Based Paint Hazards in Housing (Second Edition, July 2012); however, this was not a comprehensive surface-by-surface investigation for LBP, but rather a screening survey of major coated surfaces where the presence of LBP is suspected.

Several components, particularly 2nd story window components were not safely accessible for testing or required invasive sampling techniques during the survey. Therefore, F&R has employed professional judgment in making determinations about the homogeneity of components determined to be “positive.”

4.1.1. XRF Testing

Testing of surface coatings was conducted utilizing a Heuresis Pb200i X-Ray Fluorescence (XRF)

Lead Paint Analyzer (Serial Number 1504). Only accessible painted, coated, and/or varnished surfaces were tested using the XRF.

The XRF contains a small radioisotopic source and operates on the principle of x-ray fluorescence, whereby lead atoms in a surface coating are stimulated to emit characteristic x-rays, which are then detected by the instrument. Levels of lead are reported in units of milligrams per square centimeter (mg/cm2). The XRF can measure surface or non-surface concentrations of lead with

95% accuracy at the HUD action level of 1.0 mg/cm2. The XRF is able to accurately detect a concentration as low as 0.1 mg/cm2 of lead. The XRF classifies coated surfaces as “positive”, “negative”, or “null” for lead content based on the action level (1.0 mg/cm2) and the performance characteristics of the XRF. The XRF was checked for calibration before and after the survey. The calibration was checked against a standard reference material (1.04 mg/cm2 NIST Standard) supplied by the XRF manufacturer. A copy of the XRF Performance Characteristic sheet is included as an attachment to this report.

Positive: Lead is present at or above the action level of 1.0 mg/cm2 on one or more of the components tested.

Negative: Lead is not present at or above the action level of 1.0 mg/cm2 on any of the components tested.

Null: Insufficient data was collected by the XRF during the sample time to determine if the surface is positive or negative (i.e. – premature removal or instrument slippage, terminating the test).

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4.2. Lead-Based Paint Survey Findings

4.2.1. XRF Survey Results

A total of two hundred and thirty four (234) XRF readings, including calibration, were collected from the interior and exterior of the building. Twenty two (22) of the readings collected at the

Project site were positive for LBP when compared to the action level of 1.0 mg/cm². Refer to

Appendix E, XRF Data Table for a listing of the readings and respective information as well as an explanation of the data table and the Performance Characteristic Sheet. The following table presents the positive readings collected.

XRF READINGS FOR LEAD-BASED PAINT

Reading Number Component Substrate Color Room Floor

5 Roof Sash-lower Wood White Exterior Upper Trim

7 Roof Sash-lower Wood White Exterior Upper Trim

13 Sash cover-lower Vinyl White Exterior Upper Trim

24 Ceiling panel-original Metal White Room 201 Second

25 Ceiling panel-original Metal White Room 201 Second

66 Original Ceiling Panel Metal White Room 110 Second

67 Original Ceiling Panel Metal White Room 110 First

84 Beam Metal Orange Crawlspace Crawlspace

85 Beam Metal Orange Crawlspace Crawlspace

91 Beam Metal Orange Basement Basement

92 Beam Metal Orange Basement Basement

114 North Hand Railing Metal Black Front Porch Exterior

115 North Hand Railing Metal Black Front Porch Exterior

116 North Hand Railing Metal Black Front Porch Exterior

177 Wall Ceramic Gray 210 Bathroom Second

178 Wall Ceramic Gray 210 Bathroom Second

179 Wall Ceramic Gray 210 Bathroom Second

220 Railing Metal Black Rear Entrance Exterior

228 Upper Window Trim Vinyl White Front Porch Exterior

229 Upper Window Trim Vinyl White Front Porch Exterior

230 Upper Window Trim Vinyl White Front Porch Exterior

231 Ceiling Vinyl White Front Porch Exterior 1 The condition of the underlying paint was not visible for assessment-the condition refers to that of the vinyl.

4.2.1.1. Locations of Detected Lead-Based Paint

Based on the detection of LBP on specific component types and our observation of an apparent homogenous painting history, the following building components should be considered to be coated with LBP:

F&R Project Number 59Z-0149-REV 2 19 June 8, 2021

LEAD-BASED PAINT MATERIALS INVENTORY

Material Description Color Substrate Material Location(s)

Interior

Original Pressed Metal

Ceiling Panels White Metal 1st and 2nd Floors

Beam Orange Metal Crawlspace and

Basement

Wall – Ceramic Tiles Gray Ceramic Bathroom 210

Exterior

Porch Hand Rails Black Metal Front Porch

Railing Black Metal Rear Entrance

Upper Window Trim White Vinyl Front Porch

Ceiling White Vinyl Front Porch

Lower Roof Sash White Wood Front Exterior & Canopy at Room 201

Lower Sash Cover White Vinyl Front Exterior & Canopy at Room 201

The above table details only those building materials with painted and/or coated surfaces with a reported lead concentration greater than or equal to 1.0 mg/cm2. However, readings of several painted or coated surfaces indicated a lead content between 0.1 mg/cm2 and 0.9 mg/cm2.

F&R presumes that, where materials have been documented to be LBP and where those materials are similar to other materials which have not been found to be positive, those similar materials will be considered to be LBP (i.e. where one material was analyzed and found to be positive, it is prudent to consider other similar materials positive, despite potential data to the contrary unless heterogeneity can be reasonably inferred).

Note that some positive readings were collected on metal or vinyl overwrap, presumably over original wooden painted components. The positive results were likely yielded as a result of the

XRF reading through the overwrap material to the apparently lead-based paint coated surface below.

4.2.1.2. Inaccessible or Presumed Lead-Based Paint

During the conduct of this survey, testing was limited to those materials which were safely accessible and readily visible. As such, some materials should be presumed to be positive, unless sampling is conducted and shown to be negative. Such presumed LBP coated components include, but are not limited to:

F&R Project Number 59Z-0149-REV 2 20 June 8, 2021

Roof components (e.g. cupola), which were not safely accessible;

Materials in Rooms 105, 213, and 222 which were not represented during this survey

Materials associated with two fireplaces located within Room 101;

Painted surfaces in locked spaces.

4.3. Lead-Based Paint Conclusions & Recommendations

This survey concludes that building components located on both the exterior and interior of the structure contain lead-based paint/coatings. Photographic documentation of select lead-containing paint/coatings on building materials is presented in Appendix D: Section 2.

F&R recommends that activities which may disturb such coatings be conducted following appropriate Federal and State regulations. Federal regulations with regard to worker safety and disposal requirements are summarized in the following Section – Applicable Regulations; this is not an exhaustive list.

Should additional suspect LBP coated components be discovered during renovation and/or demolition activities that have not been evaluated but will be disturbed, F&R recommends work be temporarily halted. Samples of suspect materials should be evaluated and handled accordingly prior to the resumption of demolition activities.

In the interim while the building remains partially occupied, F&R recommends that routine maintenance of the building be conducted to prevent or reduce risk associated with extant lead based paint. These measures should correspond to Chapter 6 of the HUD Guidelines for the

Evaluation and Control of Lead-Based Paint Hazards in Housing (Second Edition, July 2012) which notes the following components of ongoing lead-safe maintenance:

Stabilization of deteriorated paint

Proper cleanup of dust and debris

Periodic Visual Assessments

Correction of problems found in the visual assessments

Using lead-safe work practices

Further, F&R recommends proper hygiene including hand washing after using front handrails.

4.4. Applicable Regulations

4.4.1. OSHA Regulations for Lead-Based Paint

While the majority of materials tested at the site were negative for lead based paint and/or surface coatings, other painted and/or coated surfaces or materials containing lead may contain sufficient concentrations of lead, which when disturbed, may generate lead dust greater than the

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“Action Level” concentration of 30 micrograms per cubic meter (µg/m3) or greater than the

“Permissible Exposure Limit” of 50 micrograms per cubic meter established by the OSHA “Lead

Exposure in Construction Rule” (29 CFR 1926.62). The OSHA standard does not define acceptable levels of lead in paint at which no exposure to airborne lead (above the action level) would be expected; however, guidance is available for work practices which present the highest risk for lead exposure to workers. Rather, OSHA defines airborne concentrations and references specific types of work practices and operations from which a lead hazard may be generated (reference

29 CFR 1926.62, section d). Environmental and personnel monitoring should be conducted during removal or demolition processes (as applicable) to determine actual personal exposure.

This monitoring information can be used to determine the levels of personnel protection and environmental controls required for work involving specific removal/demolition processes on specific structures. Under OSHA requirements, the Contractor performing the work will be required to conduct this monitoring. It is important to note that environmental controls will vary dependent upon the content of lead in paint, the process used to remove it, duration of the work, and the amount of paint to be removed.

F&R recommends that workers disturbing painted (or coated) surfaces as part of this project receive OSHA Lead in Construction Awareness training and that engineering controls and hygiene practices described in 29 CFR 1926.62 be followed during the disturbance of painted (or coated) surfaces.

4.4.2. EPA Regulations for Lead-Based Paint.

4.4.2.1. Disposal

For disposal of demolition debris, particularly material coated with LBP, testing may be required as specified by the Environmental Protection Agency (EPA) for lead content to determine proper disposal. EPA regulations require that a generator of waste determine if that waste is hazardous by performing testing in accordance with the requirements of 40 CFR 261.11 or for wastes that may be RCRA hazardous (such as items with high lead content), the generator may assume that the waste is hazardous and comply with the hazardous waste regulation. The need for determination of disposal may be additionally subject to the disposal and/or recycling facility utilized.

Characterization of the waste stream for lead is typically performed by the collection of a sample for analysis by the toxicity characteristic leaching procedure, referred to as a TCLP. The sample should be representative of the various components of the waste stream and of a sufficient quantity to meet the testing laboratory’s requirement to provide reliable data, approximately 5 parts per million lead.

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4.4.3. Virginia Lead Regulations

The Virginia Department of Labor and Industry (DOLI) regulates lead through enforcement of the

Virginia Occupational Safety and Health (VOSH) regulations. Agency locations and regulations can be found on the agency Web site http://www.doli.virginia.gov.

The Virginia Department of Professional and Occupational Regulation (DPOR) is responsible for company and individual licensure in Virginia. Licensure and regulatory information can be found on DPOR's Web site http://www.dpor.virginia.gov/.

The Virginia Department of Environmental Quality (DEQ) is responsible for the regulation of landfills in Virginia. Information on the disposal of hazardous waste in Virginia landfills can be obtained from the DEQ Web site http://www.deq.state.va.us/.

5.0 LIMITATIONS

This report has been…