I.B.08.2_21R0034 USDA-ARS Kerrville 4D1 - Hazardous Materials Inspection.pdf

ENVIRONMENTAL SCIENCE, ENGINEERING & INDUSTRIAL HYGIENE SERVICES

Middletown, MD ~ Morgantown, WV Corporate Office: 200 W Main Street, Middletown, MD 21769 Tel: (301) 694-5687 ~ Fax: (301) 694-9799

TRANSMITTAL

DATE: June 3, 2019

BEC PROJECT NUMBER: TX18002

PROJECT NAME: United States Department of Agriculture (USDA)

Agriculture Research Service (ARS), Plains Area (PA) Knipling-Bushland U.S. Livestock Insects Research Laboratory (KBUSLIRL) 2700 Fredericksburg Road Kerrville, Texas 7808-9184

FORWARDED TO: MERRICK & COMPANY

5970 Greenwood Plaza Boulevard Greenwood Village, Colorado 80111

Merrick Project #64019927-00

ATTENTION: Mr. Jon C. DeLay, P.E.

Sr. Project Manager

SUBJECT ITEM(S): 17 May 2019-USDA Kerrville Hazardous Materials Inspection–Final Technical Report

COMMENTS: For Your Use & Distribution

USDA ARS KBUSLIRL HAZARDOUS MATERIALS/WASTES & PETROLEUM PRODUCT SURVEY

KERRVILLE, TEXAS FINAL TECHNICAL REPORT

PCBs, MERCURY, PETROLEUM, HAZARDOUS MATERIALS INSPECTION

Conducted at:

UNITED STATES DEPARTMENT of AGRICULTURE

AGRICULTURAL RESEARCH SERVICE

KNIPLING-BUSHLAND

U.S. LIVESTOCK INSECTS RESEARCH LABORATORY

2700 FREDERICKSBURG ROAD

KERRVILLE, TEXAS 7808-9184

Prepared for:

BEC Project #TX18002

Fieldwork Conducted:

March 24, 2019 – April 3, 2019

Report Date: May 17, 2019

Middletown, MD ~ Morgantown, WV Corporate Office: 200 W Main Street, Middletown, MD 21769 Tel: (301) 694‐5687 ~ Fax: (301) 694‐9799

PCBs, MERCURY, PETROLEUM, HAZARDOUS MATERIALS INSPECTION

Conducted at:

Knipling-Bushland U.S. Livestock Insects Research Laboratory

TABLE OF CONTENTS

SECTION 1.0 SITE DESCRIPTION & SCOPE OF WORK 1

SECTION 2.0 HAZARDOUS MATERIALS INSPECTION 1

Section 2.1 Polychlorinated-Biphenyl Containing Materials 1

Section 2.2 Mercury Containing Materials 2

Section 2.3 O Zone Depleting Substances 2

Section 2.4 Petroleum & Other Chemical Containing Substances 2

Section 2.5 Hazardous Waste 2

Section 2.6 Hazardous Materials Inspection Limitations 2

SECTION 3.0 CONCLUSIONS & RECOMMENDATIONS 3

Section 3.1 Conclusions 3

Section 3.2 Recommendations 3

APPENDICES

APPENDIX A: PCB Containing Material

APPENDIX B: Mercury Containing Materials

APPENDIX C: O Zone Depleting Substances

APPENDIX D: Petroleum & Other Chemical Products

APPENDIX E: Observed Hazardous Waste

APPENDIX F: Hazardous Waste Manifest

APPENDIX G: BEC Photo Sheet

BOGGS ENVIRONMENTAL CONSULTANTS, INC.

On-site Fieldwork & Final Technical Report By: Technical Report Reviewed By;

Andrew Hanson Mark A. Boggs

Project Manager President/CEO http://boggsenvironmental.com/

SECTION 1.0 SUBJECT SITE DESCRIPTION & SCOPE OF WORK

Project Site: United States Department of Agriculture (USDA)

Agriculture Research Service (ARS), Plains Area (PA)

Knipling-Bushland U.S. Livestock Insects Research Laboratory (KBUSLIRL)

2700 Fredericksburg Road

Requester Name:

Requestor Address: Jon C. DeLay, P.E.

Sr. Project Manager

Subject Site Description & Scope of Work:

The subject site, Knipling-Bushland U.S. Livestock Insects Research Laboratory (KBUSLIRL), provides important tick and blood-feeding fly research capabilities supporting long-standing cooperative efforts among the USDA ARS Animal

Plant Health Inspection Service (APHIS), USDA ARS Veterinary Service (VS), and the U.S. cattle industry.

The scope of work was to survey all improvements present at the KBUSLIRL grounds for hazardous materials/wastes and petroleum products, in support of a major modernization project scheduled to commence at KBUSLIRL in the near future. These hazardous materials/wastes and/or petroleum products are required to undergo proper removal and disposal

(or transfer from planned work zones to other areas of operation for reuse, as applicable) prior to commencement of the modernization project, It is our understanding nearly all existing structures are slated for demolition to accommodate the modernization project. The structures to undergo demolition include, but may not necessarily be limited to, the following: two barns; three research labs; two insect rearing facilities; three insect research labs; storage garage; ten isolation pens; feed shed and related pens; and two animal shelters

BEC conducted the hazardous materials survey under contract to Merrick & Company (Merrick) of Denver, Colorado.

Merrick is a prime contractor to the USDA ARS providing architectural/engineering (A/E) building design and construction period services. BEC understands USDA ARS requested the survey to determine applicability (and impact) of (i) United States (US) Environmental Protection Agency (EPA) / (ii) Texas Department of State Health Services

(TDSHS) environmental pollution/public health protective regulations and (iii) US Occupational Safety and Health

Administration (US OSHA) worker protection regulations to the planned construction work activities associated with the laboratory modernization project.

SECTION 2.0 HAZARDOUS MATERIALS INSPECTION

2.1 Background

BOGGS ENVIRONMENTAL CONSULTANTS, INC. conducted the hazardous materials survey at the subject site, located at 2700 Fredericksburg road, Kerrville, Texas, between March 24, 2019 and April 3, 2019.

BEC conducted interviews with the Owners to become familiar with the building history, conceptual modernization scope of work, limits of the inspection, and reviewed historic Hazardous Waste shipping manifests, prior to proceeding with the field inspection.

BEC notes the survey did not involve exploratory demolition to access hidden (enclosed) construction conditions nor inventory of laboratory supply/storage cabinets; only readily-accessible building areas, of which were deemed subject to disturbance during the planned renovation/demolition work, underwent visual inspection during the course of the survey.

http://boggsenvironmental.com/

Visual observations were made for materials and substances, including but not necessarily limited to, those listed hereunder:

hazardous materials, hazardous waste, petroleum products, chemical substances:

polychlorinated-biphenyl (PCB) compounds -containing dielectric fluids within electrical lighting fixture ballasts and electric transformers, mercury containing fluorescent light tubes, electrical switches, thermometers, thermostats, ozone depleting substances, and, chemical-containing substances

2.1 Polychlorinated-Biphenyl Containing Materials

Electrical lighting fixture ballasts missing labels or not labeled as “Non-PCB” were presumed to contain PCBs, and were inventoried, as such. BEC provides the descriptions of identified PCB containing light ballasts located at the subject site hereunder in Appendix A: PCB Containing Materials

2.2 Mercury Containing Materials

Multiple materials labeled by their manufacturer as containing low-pressure mercury and/or phosphorus vapors were present at the subject site. Fluorescent light tubes without green end caps are presumed to contain mercury vapors.

BEC provides the descriptions of identified mercury-containing light tubes located at the subject site in Appendix B:

Mercury Containing Materials

2.3 Ozone Depleting Substances

BEC identified the following equipment that contains or potentially contains ozone depleting substances (ODS) such as compressed refrigerant gases, during this site investigation. BEC provides the descriptions of identified ODS-containing storage vessels located at the subject site in Appendix C: Ozone Depleting Substances

2.4 Petroleum & Other Chemical Containing Products

BEC advises, during the course of the investigation, potential hazardous chemicals were observed at subject site. BEC provides the descriptions of identified petroleum products and other chemical substances located at the subject site in

Appendix D: Other Chemicals & Petroleum Products

2.5 Hazardous Waste

BEC advises, during the course of the investigation, containers labeled as hazardous were observed at the subject site.

Satellite hazardous waste accumulation facilities were observed at the subject site. The contents of the satellite hazardous waste facilities, laboratory fume hoods, and/or hazardous material/waste storage cabinets are required to undergo proper packaging, collection/transport, and appropriate disposal prior to commencement of the renovation/demolition work. BEC provides the descriptions of the hazardous waste identified at the subject site hereunder in Appendix E: Observed Hazardous Waste.

It is relevant to note, review of historical KBUSLIRL hazardous waste generation reports, provided in Appendix F:

Hazardous Waste Manifest, revealed the subject site generates less than one hundred kilograms (<100 Kg) of hazardous waste on a monthly basis. This level of hazardous waste generation is classified by the US EPA Resource

Conservation and Recovery Act, as a Very Small Quantity Generator (RCRA-VSQG).

2.6 Limitations

The above inspection was characterized by making observations for materials present at readily-accessible building areas. All readily-accessible areas were inspected, in accordance with generally accepted engineering work practices.

BEC advises the materials listed in the appendices were present during the course of the survey, however, specialized management programs require routine collection, transport, and disposal (or recycle/reuse) of these materials in accordance with federal and state regulations. Accordingly, the inventory of materials observed during the survey is subject to change. Therefore, BEC makes no warranty, expressed or implied, the materials inventory will remain, as observed during the course of the survey.

SECTION 3.0 CONCLUSIONS & RECOMMENDATIONS

3.1 Conclusions

1. BEC concludes, based upon onsite visual inspection, multiple electrical lighting fixture ballasts are present at the subject site. Some of these ballasts are subject to the requirements of the US EPA Toxic Substance

Control Act (TSCA) of 1976, including the Frank R. Lautenberg Chemical Safety for the 21st Century Act of

2016. Specifically, “Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in

Commerce, And Use Prohibitions” (40 CFR Part 761) regulations apply to disposal and/or recycling of PCB containing ballast.

2. BEC concludes, based upon the onsite visual inspection, fluorescent light tubes, containing elemental inorganic metallic mercury, are present at the subject site. These light tubes are subject to the requirements of the US EPA Resource Conservation and Recovery Act (RCRA) of 1976, including the Federal Hazardous and Solid Waste Amendments of 1984. Specifically, “Standards for Universal Waste Management” (40 CFR

Part 273) and “Identification & Listing of Hazardous Waste” (40 CFR Part 261) regulations apply to handling and management (removal and disposal) of fluorescent light tubes containing mercury and/or phosphorus.

3. BEC concludes, based upon the onsite visual inspection, equipment that contains or potentially contains ozone depleting substances (ODS) are present at the subject site. These ODS are subject to the requirements of the

US EPA Clean Air Act of 1970 (40 CFR Part 62), including the “Title VI- Ozone Layer Protection” amendments of 1990.

4. BEC concludes, based upon onsite visual inspection, hazardous waste is present at the subject site. This waste is subject to the requirements of the US EPA Toxic Substance Control Act (TSCA) of 1976, including the

Frank R. Lautenberg Chemical Safety for the 21st Century Act of 2016. In general, “Solid Wastes” (40 CFR

Part 260- 262) and specifically, “Identification & Listing of Hazardous Waste” (40 CFR Part 260) regulations apply to identification, segregation, packaging, shipping, and disposal of this waste.

5. BEC concludes, based upon onsite visual inspection, petroleum products are present at the subject site. The petroleum product is subject to the requirements of the US EPA Toxic Substance Control Act (TSCA) of

1976, including the Frank R. Lautenberg Chemical Safety for the 21st Century Act of 2016. Specifically, “Standards for the Management of Used Oil” (40 CFR Part 279) regulations apply to identification, segregation, packaging, shipping, and disposal of this waste.

6. BEC concludes, based upon the onsite visual inspection, various chemicals and paints used in the maintenance and upkeep of the buildings are present at the subject site and will need to be properly disposed of in accordance with Federal, State and local regulations.

SECTION 3.0 CONCLUSIONS & RECOMMENDATIONS

3.2 Recommendations

1. BEC recommends visual inspection of each electrical lighting fixture for PCBs, prior to renovation/demolition work activities disturbing and/or damaging the ballast. The completed survey involved visual inspection of a number of fixtures representative of the entire lot of fixtures; not every fixture was dismantled to accommodate visual inspection. PCB ballast should undergo disposal in accordance with local, state, and Federal regulations.

Non-leaking PCB ballast should be disposed in accordance with 40 CFR 761.50 (b)(2)(i) and 40 CFR 761.60

(b)(2)(i).

Any PCB ballast found to be leaking should be stored in accordance with 40 CFR 761.65 (c)(1) for up to 30 days and/or 40 CFR 761.65 (b) for longer than 60 days. Leaking PCB ballast should be disposed in accordance with 40

CFR 761.50 (b)(2) and 40 CFR 761.62 (a) or (c).

2. BEC recommends visual inspection of each fluorescent light tube for the manufacturer’s labels indicating the presence of mercury, prior to renovation/demolition work activities disturbing and/or damaging the light tubes.

The completed survey involved visual inspection of a number of light tubes representative of the entire lot of light tubes; not every light tube was removed from the lighting fixture to accommodate visual inspection. Precaution should be taken during removal, storage, and disposal of fluorescent light tubes to avoid breakage. BEC recommends, in accordance with recognized industry practices, recycling of all mercury-containing fluorescent lamp tubes, pursuant to their removal.

3. BEC recommends, in accordance with recognized industry practice, all paints, chemicals, and petroleum products shall be removed- in accordance with local, state, and federal regulations- prior to renovation/demolition work activities disturbing and/or damaging these materials. Transfer all materials for proper reuse and/or recycling or disposal.

4. BEC recommends all compressed refrigerant gases (ODS) undergo proper recovery and reclamation by a licensed

ODS technician, prior to renovation/demolition work activities disturbing and/or damaging the ODS-containing vessels.

5. BEC recommends compliance with existing site hazardous waste management program requirements for transfer, packaging, and shipping/disposal of all hazardous materials and/or wastes, prior to renovation/demolition work activities disturbing and/or damaging vessels containing hazardous waste.

6. Observe recognized industry standards in securing and safekeeping all transportation bills of lading, shipping manifests, disposal receipts, and/or certificates of destruction or recycling in accordance with appropriate recordkeeping practices.

APPENDIX A

PCB CONTAINING MATERIAL

PCB CONTAINING MATERIALS

Description Location/Building PCB Quantity

Light Tube Ballasts 1, 2, 4, 5, 7, 11, 13, 14, 15, 19, 21, 22, 27, 28, 32, 35, 36, 38, 39 Non-PCB 276 Each

PCB Containing Light Ballasts 37 PCB 30 Each

Horseshoe Light Tube Ballasts 1 Non-PCB 4 Each

Integrated Ballast for 4' Mini Light Tubes 1, 2, 3, 5, 6, 8, 9, 29, 30, 37, 38, 39, 40 Presumed PCB 611 Each

Pole Mounted Transformers Throughout PCB 25 Each

ENVIRONMENTAL SCIENCE, ENGINEERING AND INDUSTRIAL HYGIENE SERVICES

APPENDIX B

MERCURY CONTAINING MATERIALS

Description Location/Building Mercury Quantity

4' Light Tube 4, 11, 14, 15, 19, 21, 22, 27, 28, 30, 32, 35, 36, 37, 38, 39 Yes ~695 Each

Horseshoe Light Tube 1 Yes ~8 Each

2' Light Tube 1, 2, 5, 38 Yes ~13 Each

12" Light Tube 7, 13, 36 Yes ~60 Each

4' Mini Light Tube 1, 2, 3, 5, 6, 8, 9, 29, 30, 37, 38, 39, 40 Yes ~614 Each

Description Location/Building Mercury Quantity

Bi Metal Thermostat Building #13 No 1 Each

Honeywell Thermostat Building #32 Yes 1 Each

Thermostat (Electric Heat) Building #37 Yes 1 Each

MERCURY CONTAINING LIGHT TUBES

MERCURY CONTAINING THERMOSTATS

APPENDIX C

OZONE DEPLETING SUBSTANCES

OZONE DEPLETING SUBSTANCES

Description Location Quantity

Refrigerant (Likely R-22) for 2 AC Units Building #1 West Exterior Unavailable

R410A Refrigerant for Trane Exterior AC Compressor Building #2 Unavailable

R-22 Refrigerant for Avis AC Unit Building #2 150-300 psi

R-22 Refrigerant for 2 Localized Ruud AC Units Building #3 East Exterior 150-300 psi

Refrigerant (Likely R-22 or R-12) for 8 Window AC Units Building #4 < 3 lb

R-22 Refrigerant for Avis AC Unit Building #4 150-300 psi

R-22 Refrigerant for Avis AC Unit Building #5 150-300 psi

R-22 Refrigerant for Avis AC Unit Building #6 150-300 psi

R-22 Refrigerant for Avis AC Unit Building #8 150-300 psi

Refrigerant (Likely R-22 or R-12) for Window AC Unit Building #9 < 3 lb

Refrigerant (Likely R-22) for Daya AC Compressor Building #9 Unavailable

Refrigerant (Likely R-22 or R-12) for 2 Window AC Units Building #11 < 3 lb

R410A Refrigerant for Compressor Building #11 13 lb

Refrigerant (Likely R-22 or R-12) for 2 Window AC Units Building #15 < 3 lb

Refrigerant (Likely R-22) for AC Unit Building #21 < 3 lb

Refrigerant (Likely R-22 or R-12) for 6 Window AC Units Building #22 < 3 lb

Refrigerant (Likely R-22 or R-12) for 3 Window AC Units Building #28 < 3 lb

R410R Refrigerant for Coleman AC Compressor Building #29 3 lb 7 oz

R-22 Refrigerant for Avis AC Unit Building #35 150-300 psi

Refrigerant (Likely R-22) for AC Unit Building #36 Unavailable

Refrigerant (Likely R-22) for AC Unit Building #37 East Exterior Unavailable

Refrigerant (Likely R-22) for AC Unit Building #37 West Exterior Unavailable

Refrigerant (Likely R-22 or R-12) for Ruud AC Unit Building #37A Unavailable

R410A Refrigerant for Tappan AC Compressor Building #38 6.63 kg

R-22 Refrigerant for Avis AC Compressor Building #38 150-300 psi

R410A Refrigerant for Tappan AC Compressor Building #39 6.63 kg

R-22 Refrigerant for Avis AC Compressor Building #39 150-300 psi

R-22 Refrigerant for Avis AC Compressor Building #40 150-300 psi

Refrigerant (Likely R-22 or R-12) for Window AC Unit Building #40B < 3 lb

APPENDIX D

PETROLEUM & OTHER CHEMICAL PRODUCTS

PETROLEUM AND OTHER CHEMICAL PRODUCTS

Substance Location Quantity

Nuclaic Acid Building #38 8 Litres

Hazardous Material Building #39 18 Gallons

Acetone Building #10 40 Gallons

Silver Nitrate Building #5 5 Gallons

Acetone Building #5 4 Gallons

Ethyl Alcohol Building #5 1 Gallon

Methanol Building #5 4 Gallons

Chlorinated Waste Solvent Building #9 1 Gallon

Acetone Building #9 1 Gallon

TCE Building #9 2 Litres

Acetone Building #9 1 Gallon

Paint Building #17 3 Gallons

Spray Paint Cannister Building #17 4 Each

Hydraulic Oil Building #17 1 Gallon

Gasoline Building #17 5 Gallons

Lubricants Building #13 1 Can

Aerosol Paints Building #13 12 Cans

Gasoline Building #31 10 Gallons

Diesel Fuel Building #31 20 Gallons

Used Oil Building #31 220 Gallons

Live Bacteria Additive Building #31 55 Gallons

Motor Oil Building #31 15 Gallons

Latex Paint Building #31 30 Gallons

Isopropyl Alcohol Building #31 5 Gallons

Enamel Building #31 6 Gallons

Hydraulic Oil Building #31 2 Gallons

Various Alcohols Building #37 Flamable Cabinet 10 Gallons

Spray Paint Cannister Building #7 50 Each

Paint Building #7 10 Gallons

Dichloroethane Building #7 1-2 Litres

Isopropyl Alcohol Building #7 5 Litres

A33 Disinfectant Building #40B 5 Gallons

Diesel Fuel Generator South of Building #30 150 Gallons

Diesel Fuel Generator South of Building # 150 Gallons

APPENDIX E

OBSERVED HAZARDOUS WASTE

OBSERVED HAZARDOUS WASTE

Substance Location Quantity

Membrane Stain Building #38 1 Pint

Proprente Stain Gel Building #38 1 Pint

Chloroform Building #38 1 Pint

Phenols Building #38 1 Pint

Methanol Building #38 1 Pint

Imidazole Building #38 1 Pint

Hydrochloric Acid Building #39 1 Pint

Isopropyl Alcohol Building #39 1 Pint

Methanol Building #39 1 Gallon

Ethanol Building #39 1 Gallon

Buffer Building #23 1 Gallon

Sodium Phosphate Building #23 1 Gallon

Acetic Acid Building #23 1 Gallon

Isopropyl Alcohol Building #23 4 Litres

Phenol Alcohol Building #23 2 Litres

Phenol Chlorination Building #23 3 Litres

Phenol Chloroform Ethanol Building #37 1 Gallon

Phenaly Chloroform Ethanol Building #37 1 Cup

Chloroform/Isopropyl Alcohol Building #37 1 Pint

Isopropyl Alcohol/Ethanol Building #37 1 Pint

Hydrochloric Acid Building #37 1 Pint

Binding Buffer Building #37 1 Pint

Acidic Buffer Building #37 1 Pint

Acetone Building #37 1 Pint

Hydroacetic Acid Building #37 1 Pint

Biological Waste Building #37A 1 Bag

APPENDIX F

HAZARDOUS WASTE MANIFEST

APPENDIX G

BEC PHOTO SHEET

Knipling – Bushlands U.S. Livestock Insects Research Laboratory

PCB Containing Light Ballast

Mercury Containing 4’ Light Tube

Mercury Containing Horseshoe Light Tube

Mercury Containing 2’ Light Tube

Mercury Containing Mini Light Tube

Mercury Containing Thermostat

Pole Mounted Transformer

Petroleum & Other Chemical Products