2012_HAZMAT_Report.pdf

HAZARDOUS MATERIALS SURVEY REPORT

RENOVATE AND PROVIDE SECOND FLOOR BUILDING 74

NAVAL RESEARCH LABRATORY

WASHINGTON, DC

PREPARED FOR:

MARSHALL CRAFT ASSOCIATES, INC.

6112 YORK ROAD

BALTIMORE, MD 21212

PREPARED BY:

ARIA ENVIRONMENTAL, INC.

PO BOX 286

WOODBINE, MD 21797

SEPTEMBER 26, 2012

090435

TABLE OF CONTENTS

EXECUTIVE SUMMARY ....................................................................................................................................... II

I. INTRODUCTION

II. METHODOLOGY

A. Asbestos

B. Lead

C. Polychlorinated Biphenyls

D. Mercury

E. Ozone Depleting Substances

III. RESULTS

A. Asbestos

B. Lead

C. Polychlorinated Biphenyls

D. Mercury

E. Ozone Depleting Substances

F. Other Universal or Regulated Waste

V. CONCLUSIONS AND RECOMMENDATIONS

VI. LIMITATIONS

Tables

Table 1: Asbestos Bulk Sampling Results for Buildings 74 and 81

Table 2: Mercury-Containing Materials for Buildings 74 and 81

Table 3: ODS Materials for Buildings 74 and 81

Attachments

Attachment A: Inspector’s Credentials

Attachment B: Asbestos Certificates of Analysis and Chain-of-Custody Forms

Attachment C: Asbestos Sample Location Plan - Drawings

Attachment D: Hazardous Materials Quantity Table

Hazardous Materials Survey Report September 26, 2012

Buildings 74 and 81, Naval Research Laboratory Page ii

EXECUTIVE SUMMARY

Aria Environmental, Inc. (AEI) was contracted by Marshall Craft Associates to perform the hazardous materials survey for the renovation and addition of a second floor to Building 74 at the Naval Research Laboratory, located in Washington, DC. The Design Services Scope of Work dated May 12, 2009 calls for the investigation, survey and analysis of asbestos-containing materials, lead-based paint, mercury, PCBs and ozone depleting substances in buildings 74 and

81. This report presents our methodologies; results of sampling and analysis activities; and our conclusions and recommendations for abatement as of the conceptual design phase of the project.

Building 74 is a two-story concrete masonry unit (CMU) building enclosing approximately

17,900 square feet. The building, and auxiliary metal shed were constructed in the early 1950’s.

An addition located between Buildings 74 and 81 was constructed in the early 1960’s. An addition on the west side of the building followed in the 1990’s. Limited renovation activities have occurred on the first floor and mezzanine levels to accommodate clean rooms and the draw tower. Building finish materials include: CMU, corrugated metal siding, Dryvit exterior finish, drywall and transite wall finishes, concrete floors covered in areas by several styles of floor tile, suspended and drywall ceilings, various styles of cove base, aluminum windows, wood framing, an asbestos membrane roof over the original building and a flat built-up roof on the additions.

Building 81 is connected to the eastern addition of Building 74. The building encloses approximately 1,400 square feet of space. Building finish materials include: CMU, drywall and wood paneling walls, concrete floors covered in areas by several styles of floor tile, suspended and fixed ceilings, cove base, aluminum windows, wood framing, and a flat built-up roof.

The survey for hazardous materials included all accessible spaces of both buildings.

Based upon the findings of the survey and the scope of work, the following recommendations for hazardous and regulated materials removal and disposal are presented:

1. The removal and disposal of all friable asbestos-containing materials and those asbestos-containing materials which are likely to become friable during the project.

Asbestos-containing materials include:

a. Various styles of asbestos-containing 9” x 9” and 12” x 12” floor tile and mastic;

b. Transite wall panels;

c. Window glazing compound;

d. Ten vibration dampers;

e. Two woven gaskets on roof top exhaust ducts;

f. Presumed asbestos-containing fire doors;

g. Transite fume hood;

h. Buried steam pipes, fittings, gaskets and packings; and

i. Asbestos-containing thermal system insulation concealed in walls, chases or above hard ceilings.

2. Follow USEPA and District of Columbia regulations for the cutting of the roofing system covering Building 74.

3. The removal and disposal of lead-containing paint and lead sheeting in accordance with USEPA and District of Columbia regulations.

a. All paint is to be considered lead-containing; and

b. The removal of the nine lead caps on roof vents on Building 74.

4. The recovery or proper disposal of refrigerants from the twenty-four pieces of equipment in the building that possibly contain refrigerants.

Buildings 74 and 81, Naval Research Laboratory Page iii

5. The removal of universal wastes including the mercury-containing fluorescent light tubes.

6. The removal and disposal of the mercury thermometers from the building.

7. The removal and disposal of all batteries including those which may be present in emergency exit lighting.

8. The removal and disposal of all hydraulic oil filled automatic door closers and the overhead crane located in Room 100.

9. The removal and disposal of the low level radioactive source inside the smoke detector.

10. The further investigation and decommissioning of the west wall by the Pelletron Van de Graff Accelerator and Ion Implanter due to occasional neutron activity.

11. The removal and disposal of PCB-containing equipment:

a. The removal, segregation and disposal of PCB-containing light ballasts; and

b. The de-energizing and testing of dielectric fluid for PCBs in transformers to be removed.

Buildings 74 and 81, Naval Research Laboratory Page 1

I. INTRODUCTION

Aria Environmental, Inc. (AEI) was contracted by Marshall Craft Associates to perform the hazardous materials survey for the renovation and addition of a second floor to Building 74 at the Naval Research Laboratory, located in Washington, DC. Previous hazardous materials surveys were not available. The Design Services Scope of Work dated May 12, 2009 calls for the investigation, survey and analysis of asbestos-containing materials, lead-based paint, mercury, PCBs and ozone depleting substances in buildings 74 and 81. This report presents our methodologies; results of sampling and analysis activities; and our conclusions and recommendations for abatement as of the conceptual design phase of the project.

Building 74 is a two-story concrete masonry unit (CMU) building enclosing approximately

17,900 square feet. The building, and auxiliary metal shed were constructed in the early 1950’s.

An addition located between Buildings 74 and 81 was constructed in the early 1960’s. An addition on the west side of the building followed in the 1990’s. Limited renovation activities have occurred on the first floor and mezzanine levels to accommodate clean rooms and the draw tower. Building finish materials include: CMU, corrugated metal siding, Dryvit exterior finish, drywall and transite wall finishes, concrete floors covered in areas by several styles of floor tile, suspended and drywall ceilings, various styles of cove base, aluminum windows, wood framing, an asbestos membrane roof over the original building and a flat built-up roof on the additions.

Building 81 is connected to the eastern addition of Building 74. The building encloses approximately 1,400 square feet of space. Building finish materials include: CMU, drywall and wood paneling walls, concrete floors covered in areas by several styles of floor tile, suspended and drywall ceilings, cove base, aluminum windows, wood framing, and a flat built-up roof. The survey for hazardous materials included all accessible spaces of both buildings.

II. METHODOLOGY

AEI performed the hazardous materials surveys between September 29, 2009 and

September 12, 2012. The scope of survey work included the investigation, survey and analysis of asbestos-containing materials, lead-based paint, mercury, PCBs and ozone depleting substances in two structures that will be renovated. Buildings 74 and 81 were surveyed in their entirety. The following section presents our methodologies for the sampling and analysis activities.

A. Asbestos

Representatives of AEI conducted an asbestos survey of the interior and exterior of buildings 74 and 81. Work was performed between September 29, 2009 and September 12, 2012 by Michele Twilley and Brian Sciorilli. A visual inspection for suspected asbestos-containing materials was performed followed by asbestos sample collection and laboratory analysis.

Copies of the inspector’s credentials are located in Attachment A.

Bulk samples of each suspect asbestos-containing material encountered by the inspector were collected in randomly located areas. A clean sampling tool was used to obtain a “thumbnail” sized bulk sample. This sample was placed in a single-use 4-mil plastic bag, sealed and labeled. The sampling tool was cleaned with an amended water solution before and between uses. Samples were submitted to IATL, Inc. of Mt Laurel, NJ 08054 (NIST-NVLAP

Accreditation No. 101165-0) or AMA Analytical Services, Inc. (NIST-NVLAP Accreditation No.

101143-0) for analysis by Polarized Light Microscopy (PLM) using EPA method 600/R-93/116. The

Buildings 74 and 81, Naval Research Laboratory Page 2

EPA defines an asbestos-containing material as one percent (1%) or more asbestos by visual estimation. Suspect asbestos-containing materials were not sampled if they were located in solid walls or buried underground as in the case of steam supply lines.

B. Lead

A comprehensive lead-based paint survey was not conducted. In accordance with

Navy policy, all painted surfaces in Buildings 74 and 81 are assumed to contain lead. The information contained within this report is intended to address the presence of lead-based paint or lead-containing paints to ensure worker protection requirements are met under the

Occupational Safety and Health Administration’s (OSHA) “Lead in Construction Rule (29 CFR

1926.62).” The presence of lead-containing substances is presumed in any residential building construction before 1978 and in all commercial, industrial, and public structures unless it is determined that all painted surfaces are lead-free.

C. Polychlorinated Biphenyls

Polychlorinated biphenyls (PCB’s) are a class of chemicals that were used in a wide variety of applications. PCBs are often found in dielectric fluids, cooling fluids, transformers, capacitors and caulks. PCB-containing equipment must often be disposed of as part of renovation projects. The EPA definition of PCB-containing materials is 50 part per million (ppm) or milligrams per kilogram (mg/kg). A representative number of fluorescent light ballasts were inspected for the presence or absence of the “No PCBs” label. If the “No PCBs” label is absent then the ballast is considered to contain PCBs. The number of ballasts was estimated based upon the type of light fixture observed in the building. Light ballasts were counted as follows:

one ballast for every two four-foot fluorescent light tube observed in a multi-tube fixture and one ballast for every one four-foot or eight-foot fluorescent light tube observed in a single fluorescent light tube fixture that is not joined to a second light fixture with a shared ballast.

D. Mercury

Mercury within fluorescent lamps, thermostats and other mechanical equipment often must be disposed of during renovation and demolition activities. Each area was surveyed for the presence of thermostats and/or equipment that may contain liquid mercury. Fluorescent light tubes may contain small amounts of mercury vapor and lead. Because disposal of fluorescent light tubes is regulated under the EPA Universal Waste rule, a count of fluorescent lamps is presented in this report.

E. Ozone Depleting Substances

Refrigerant-containing equipment including refrigerators, freezers, and air conditioning units were identified for the purpose of recycling chlorofluorocarbon (CFC) and hydrochlorofluorocarbon (HCFC) refrigerants that are known to deplete ozone. Under EPA's

Refrigerant Recycling Rule, equipment that is typically dismantled on-site before disposal (e.g., retail food refrigeration, central residential air conditioning, chillers, and industrial process refrigeration) requires refrigerant recovery in accordance with EPA's requirements for servicing.

III. RESULTS

A. Asbestos

Thirty-six (36) bulk samples of suspect asbestos-containing materials were collected and submitted to IATL and AMA for asbestos analysis by PLM. Samples of several sizes and styles of floor tile and mastic, transite wall panels, window glazing compound and the built-up roof covering Building 74 contained asbestos at greater than one percent (1%). One sample of 12” x

12” white floor tile and one sample of 12” x 12” beige floor tile contained less than 1% asbestos and is therefore not considered asbestos-containing. The Certificate of Analysis and Chain-of-

Buildings 74 and 81, Naval Research Laboratory Page 3

Custody forms are provided in Attachment B. Drawings depicting sample locations are presented in Attachment C. The Room Assessment Table is found in Attachment D.

Table 1 - Asbestos Bulk Sampling Results for Buildings 74 and 81

Sample

Number Material Description

Sample Location

Asbestos

74-ASB-01

2’ x 4’ deep fissure suspended ceiling tile Room 124 middle of the room NAD

74-ASB-02 Yellow carpet mastic Room 124, northwest corner NAD

74-ASB-03 Clear covebase mastic Room 124, northwest corner NAD

74-ASB-04 Window caulk Room 124, west wall NAD

74-ASB-05 Vinyl/Styrofoam coating Room 124, from east wall above ceiling

NAD

74-ASB-06

2’ x 4’ divot and pinhole suspended ceiling tile Room 191 NAD

74-ASB-07 Vinyl floor mastic Room 191 east wall NAD

74-ASB-08 Drywall and joint compound Room 124 east wall NAD

74-ASB-09 12” x 12” beige floor tile Room 100 Tile – NAD

Mastic – 1.5% Chrysotile

74-ASB-10 9” x 9” pink floor tile Outside Room 110 Tile – Trace

Mastic – 3.8% Chrysotile

74-ASB-11 Window glazing compound Room 114 Gray – 1.4% Chrysotile

Tan – 1.2% Chrysotile

74-ASB-12 Brown covebase mastic Room 152 NAD

74-ASB-13 12” x 12” white floor tile Room 152 Tile – Trace

Mastic – 3.1% Chrysotile

74-ASB-14 Transite panel Room 154 25% Chrysotile

Buildings 74 and 81, Naval Research Laboratory Page 4

74-ASB-15 White duct mastic Room 151 above ceiling NAD

74-ASB-16

9” x 9” beige with brown streaks floor tile Room 153

Tile – 7.3% Chrysotile

Mastic – 3.8% Chrysotile

74-ASB-17 Black countertop From sink in Room 100A NAD

74-ASB-18

2’ x 4’ large and small hole suspended ceiling tile Room 100 NAD

74-ASB-19 Red with white stipple floor tile Room 100A NAD

74-ASB-20

2’ x 4’ divot and dot suspended ceiling tile

Room 206, 4’ south of north wall, 6” west of east wall, 10’

AFF

NAD

74-ASB-21

1’ x 1’ large and small dot acoustical tile

Room 202 on east wall, 4’ south of north wall, 10’ AFF

NAD

74-ASB-22

1’ x 1’ large and small dot acoustical tile mastic patty

Room 202 on east wall, 4’ south of north wall, 10’ AFF

NAD

74-ASB-23 Accordion door Room 202 on east wall at hinge

NAD

74-ASB-24 9” x 9” brown floor tile Room 204A Tile – 7.4% Chrysotile

Mastic – 3.7% Chrysotile

74-ASB-25

9” x 9” dark brown with red streaks floor tile Room 204A 8.2% Chrysotile

74-ASB-26 Black floor tile mastic Room 204A NAD

74-ASB-27 9“ maroon floor tile strips Room 204A 7.8% Chrysotile

74-ASB-28 9” x 9” maroon floor tile Room 204A 7.5% Chrysotile

74-ASB-29 Main building roof High bay at west wall, 2nd column south of north wall 12% Chrysotile

74-ASB-30 Dryvit

East face at double doors, north doorjamb, 3” aboveground

NAD

Buildings 74 and 81, Naval Research Laboratory Page 5

74-ASB-31 Building 74 addition roof From building 74 addition roof NAD

74-ASB-32 Building 81 roof Roof of building 81 NAD

20120912-01 Blue sheet flooring and mastic Building 74 2nd Floor

Drawtower Room

NAD

20120912-02 Vinyl tread mastic Building 74 1st Floor Drawtower

Room

NAD

20120912-03 Black granite sheet flooring Building 74 1st Floor

Cleanroom Workroom

NAD

20120912-04 White sheet flooring with pebble pattern

Building 74 1st Floor

Cleanroom Anteroom

NAD

NAD - No asbestos Detected

AFF – Above Finished Floor

The following suspect materials are presumed to contain asbestos: fire doors, vibration dampers, woven gaskets and transite fume hood. Fiberglass wrapped piping was observed on the exterior of building. Asbestos-containing insulation is suspected on buried steam pipes and was not observed during the survey. Suspect asbestos-containing materials were not collected for analysis if they were inaccessible because they were located behind solid walls and ceilings, in enclosed pipe chases or miscellaneous materials under modular clean room equipment. The presence of asbestos in inaccessible spaces was presumed.

B. Lead

No comprehensive lead-based paint survey was conducted. All paint surfaces in buildings 74 and 81 are assumed to contain lead. Examples of painted surfaces in the buildings included walls, doors and door frames, interior window frames and exterior surfaces. The information contained within this report is intended to address the presence of lead-based paint or lead-containing paints to ensure worker protection requirements are met under the

Occupational Safety and Health Administration’s (OSHA) “Lead in Construction Rule (29 CFR

1926.62).” The presence of lead-containing substances is presumed in any residential building construction before 1978 and in all commercial, industrial, and public structures unless it is determined that all painted surfaces are lead-free. Additionally, vent caps constructed of lead sheeting were located on roof vents on both buildings.

C. Polychlorinated Biphenyls

Where fluorescent light fixtures were observed, a representative number of ballasts were inspected for the presence or absence of the “No PCBs” label. Approximately eighty percent of inspected light ballasts contained a label stating “No PCBs”. Before removing any fluorescent lights that were installed before 1978, the ballast should be inspected for PCB content. Any

Buildings 74 and 81, Naval Research Laboratory Page 6 ballast which does not have a ”No PCB” label must be treated as PCB-containing until proven otherwise through sampling and analysis. In lieu of sampling and analysis, any fluorescent light ballast that does not clearly state “No PCB’s” on the ballast label should be considered a PCB-containing ballast, and therefore treated as PCB waste upon disposal. Approximately one hundred ninety-five (195) light ballasts are located in Building 74 and fifty (50) light ballasts are located in Building 81.

One Westinghouse transformer containing three hundred sixty-seven gallons of dielectric fluid is located outside of Room 114. The transformer was marked with the blue “no PCBs” label.

The transformer may have been drained of PCB-containing dielectric fluid and refilled with fluid containing less than 50 parts per million PCBs. It is possible that residual PCBs may exist in the transformer.

D. Mercury

Five hundred and forty seven (547) fluorescent light tubes were counted in Buildings 74 and 81. High Intensity Discharge (HID) lamps and incandescent lights were observed in the building but were not counted in the room inventory. Additionally, nineteen (19) mercury-containing devices were observed in the buildings. Other thermostats and thermometers are present in the building but are not suspected of containing mercury. Table 2 below summarizes mercury-containing devices located in the building.

Table 2 – Mercury-Containing Materials for Buildings 74 and 81

Building Material Quantity

Fluorescent Light Tubes 447 Each

Thermometers 19 Each

81 Fluorescent Light Tubes 100 Each

E. Ozone Depleting Substances

Twenty-four (24) units containing refrigerants were observed in Buildings 74 and 81.

Table 3 presents an inventory of refrigerant-containing equipment by type and building. The refrigerant type and factory charge are presented if known. Disposal or recovery of refrigerants by properly trained, equipped and licensed refrigeration technicians will be required.

Table 3 – Ozone Depleting Substances for All Buildings

Building Material Quantity

Air handling units – 8 units Unknown

Air handling units – 5 units 48 oz of R-22 per unit

Carrier Liquid Chiller/Refrigerating machine Unknown

Fan coil units – 3 units Unknown

Refrigerator – Room 153 Unknown

Water fountains – Corridor 291 Unknown

Water fountains – Room 100 5.5 oz of R-22

McQuay Air Conditioner Unknown

Trane Chiller 5 lb R-22 Factory charge

31 lb R-22 Field charge

81 Refrigerator Unknown

Buildings 74 and 81, Naval Research Laboratory Page 7

F. Other Universal or Regulated Waste

Thirty-eight (38) automatic door closers which may contain hydraulic fluid were observed in Building 74. Additionally, one overhead crane located in room 100 most likely contains hydraulic fluid. Two (3) automatic door closers which may contain hydraulic fluid were observed in Building 81. All hydraulic fluid should be recovered and disposed of prior to renovation.

Sixteen (16) Chloride batteries located in emergency exit lights were identified in Building

74. Two (2) Chloride batteries located in emergency exit lights were identified in Building 81. All batteries, including those located in emergency exit lighting, should be collected and properly disposed of as universal waste.

Many smoke detectors contain a small low-level radioactive source. The most common types of ionizing smoke detectors contain Americium 241 which emits both alpha and gamma radiation that are shielded by the detector. One (1) smoke detector was identified in Building 74.

Radioactive materials have historically been used in Building 74. The Pelletron Van de

Graff Accelerator and Ion Implanter (x-ray) is currently located in Building 74 and generates man-made radioactivity. Occasional neutron activation of the west wall was reported in a

Health Physics Survey Report dated 28 August 2009 provided to AEI by the NRL Radiation Safety

Office.

V. CONCLUSIONS AND RECOMMENDATIONS

The survey for hazardous materials in Buildings 74 and 81 for the renovation of Building 74 and addition of a second floor indicated the presence of hazardous or regulated materials that will require proper packaging and disposal prior to renovation. Our conclusions and recommendations are presented below.

Asbestos: According to the District of Columbia and USEPA National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations, all friable asbestos-containing materials and those materials likely to become friable during renovation must be removed by a District of

Columbia licensed asbestos abatement contractor. The NESHAP regulation expressly prohibits cutting, sanding or sawing asbestos-containing materials. EPA Region III and the District of

Columbia Department of the Environment must be notified of the planned renovation as asbestos abatement activities in the buildings will exceed NESHAP notification size. Asbestos-containing materials identified within the building include:

Various styles of 9” x 9” and 12” x 12” floor tile and mastic (approximately 7,639 square feet);

Transite wall panels (approximately 900 square feet);

Roofing system covering Building 74 (approximately 8,300 square feet)

Transite fume hood;

Window glazing compound on 20 windows;

Ten vibration dampers were assumed to be asbestos-containing;

Two woven gaskets were assumed to be asbestos-containing;

All fire doors were assumed to be asbestos-containing fire doors; and

Asbestos-containing insulation is suspected on buried steam pipes and was not observed during the survey

The following suspect materials are presumed to contain asbestos: fire doors, vibration dampers, woven gaskets and transite fume hood. Fiberglass wrapped piping was observed on

Buildings 74 and 81, Naval Research Laboratory Page 8 the exterior of building. Asbestos-containing insulation is suspected on buried steam pipes and was not observed during the survey. Suspect asbestos-containing materials were not collected for analysis if they were inaccessible because they were located behind solid walls and ceilings, in enclosed pipe chases or miscellaneous materials under modular clean room equipment. The presence of asbestos in inaccessible spaces was presumed.

Lead: No comprehensive lead-based paint survey was conducted. All painted surfaces in buildings 74 and 81 are assumed to contain lead. Examples of painted surfaces in the buildings included walls, doors and door frames, interior window frames and exterior surfaces.

Paint may contain lead which when disturbed may generate lead dust greater than the permissible exposure limit of 50 micrograms per cubic meter (µg/m3) of air established by the

OSHA Lead Exposure in Construction Rule. The renovation contractor shall be informed of the presence of lead in the paint in accordance with the OSHA Lead in Construction Standard. All lead-related waste must be tested by the Toxicity Characteristic Leaching Procedure (TCLP) for lead to determine proper disposal requirements. Other waste characterization testing may be required by the disposal facility.

Polychlorinated Biphenyls: Approximately twenty percent of the inspected light ballasts contained PCBs. Before removing and disposing of any fluorescent lights, the ballast should be inspected for PCB content. Any ballast which does not have a label must be treated as PCB-containing until proven otherwise through sampling and analysis. In lieu of sampling and analysis, any fluorescent light ballast that does not clearly state “No PCB’s” on the ballast label should be treated as PCB-containing ballast and therefore treated as PCB waste upon disposal.

Approximately one hundred ninety-five (195) light ballasts are located in Building 74 and fifty (50) light ballasts are located in Building 81.

One Westinghouse transformer containing three hundred sixty-seven gallons of dielectric fluid is located outside of Room 114. The transformer was marked with the blue “No PCBs” label.

Due to the apparent age of the transformer, it is possible that PCB-containing dielectric fluids had historically been used in the equipment. The transformer may have been drained of PCB-containing dielectric fluid at one time and refilled with fluid containing less than 50 parts per million PCBs. It is possible that residual PCBs may exist in the transformer causing the replacement oil to exceed the 50 ppm PCB-containing definition established by the EPA.

Mercury: Five hundred and forty-seven (547) fluorescent light tubes were counted in

Buildings 74 and 81. Disposal of fluorescent light tubes is regulated under the EPA Universal

Hazardous Waste Rule because they may contain mercury and/or small quantities of lead. Light tubes should be packaged and disposed of in accordance with 40 CFR 273.9. High Intensity

Discharge (HID) lamps and incandescent lights were observed in the building but were not counted in the room inventory.

Additionally, nineteen (19) mercury-containing devices were observed in the buildings.

Other thermostats and thermometers are present in the building but are not suspected of containing mercury.

Refrigerants: Twenty-four (24) units containing refrigerants were observed in Buildings 74 and 81. Equipment that is typically dismantled on-site before disposal (e.g., retail food refrigeration, central residential air conditioning, chillers, and industrial process refrigeration) has to have the refrigerant recovered in accordance with EPA's requirements for servicing.

However, equipment that typically enters the waste stream with the charge intact (e.g., motor vehicle air conditioners, household refrigerators and freezers, and room air conditioners) is subject to special safe disposal requirements.

Buildings 74 and 81, Naval Research Laboratory Page 9

Under EPA requirements, the final person in the disposal chain (e.g., a scrap metal recycler or landfill owner) is responsible for ensuring that refrigerant is recovered from equipment before the final disposal of the equipment. However, persons "upstream" can remove the refrigerant and provide documentation of its removal to the final person if this is more cost-effective. If the final person in the disposal chain (e.g., a scrap metal recycler or landfill owner) accepts appliances that no longer hold a refrigerant charge, that person is responsible for maintaining a signed statement from whom the appliances is being accepted. The signed statement must include the name and address of the person who recovered the refrigerant, and the date that the refrigerant was recovered, or a copy of a contract stating that the refrigerant will be removed prior to delivery. The EPA does not mandate a sticker as a form of verification that the refrigerant has been removed prior to disposal of the appliance. Such stickers do not relieve the final disposer of their responsibility to recover any remaining refrigerant in the appliance, unless the sticker contains a signed statement that includes the name and address of the person who recovered the refrigerant, and the date that the refrigerant was recovered.

Other: Thirty-eight (38) automatic door closers which may contain hydraulic fluid were observed in Building 74. Additionally, one overhead crane located in room 100 most likely contains hydraulic fluid. Two (2) automatic door closers which may contain hydraulic fluid were observed in Building 81. All hydraulic fluid should be recovered and disposed of prior to renovation.

Sixteen (16) chloride batteries located in emergency exit lights were identified in Building

74. Two (2) chloride batteries located in emergency exit lights were identified in Building 81. All batteries, including those located in emergency exit lighting, should be collected and properly disposed of as universal waste.

Many smoke detectors contain a small low-level radioactive source. The most common types of ionizing smoke detectors contain Americium 241 which emits both alpha and gamma radiation that are shielded by the detector. One (1) smoke detector was identified in Building 74.

The Nuclear Regulatory Commission, under 10 CFR 32.27, requires the safe disposal of low level radioactive waste such as that found in discarded smoke detectors. The NRC requires manufacturers of smoke detectors to dispose of returned intact smoke detectors at a radioactive waste disposal site.

Radioactive materials have historically been used in Building 74. The Pelletron Van de

Graff Accelerator and Ion Implanter (x-ray) in currently located in Building 74 generates man-made radioactivity. Occasional neutron activation of the west wall was reported in a Health

Physics Survey Report dated 28 August 2009 provided to AEI by the NRL Radiation Safety Office.

The Navy is responsible for conducting radiation surveys and determining acceptance criteria for the release of the building for renovation.

Recommendations: The scope of work calls for the renovation and addition of a second floor to Building 74. Hazardous and regulated materials in the building have to be considered in the scope of the project. A listing of hazardous materials observed in each accessible room of the surveyed buildings is provided in Attachment D. Recommendations for further consideration include:

1. The removal and disposal of all friable asbestos-containing materials and those asbestos-containing materials which are likely to become friable during the project.

Asbestos-containing materials include:

Buildings 74 and 81, Naval Research Laboratory Page 10

a. Various styles of asbestos-containing or asbestos-containing mastic covered 9” x

9” and 12” x 12” floor tile and mastic were located throughout the buildings;

b. Transite wall panels located in Room 154;

c. Window glazing compound found on windows throughout the buildings;

d. Ten vibration dampers in Room 106;

e. Two woven gaskets were located on the roof over Rooms 150-157;

f. Presumed asbestos-containing fire doors located in Rooms 291 and 292;

g. Transite fume hood located in Room 152;

h. Buried asbestos on steam lines; and

i. Concealed sources of asbestos.

2. Follow USEPA and District of Columbia asbestos regulations for the cutting of the roofing system covering Building 74

3. The removal and disposal of lead-containing paint and lead sheeting in accordance with USEPA and District of Columbia regulations.

a. All paint is to be considered lead-containing; and

b. The removal of the nine lead caps on roof vents on Building 74.

4. The recovery or proper disposal of refrigerants from the twenty-four pieces of equipment in the building that possibly contain refrigerants.

5. The removal of universal wastes including the mercury-containing fluorescent light tubes.

6. The removal and disposal of the mercury thermometers from the building.

7. The removal and disposal of all batteries including those which may be present in emergency exit lighting.

8. The removal and disposal of all hydraulic oil filled automatic door closers and the overhead crane located in Room 100.

9. The removal and disposal of the low level radioactive source inside the smoke detector.

10. The further investigation and decommissioning of the west wall by the Pelletron Van de Graff Accelerator and Ion Implanter due to occasional neutron activity.

11. The removal and disposal of PCB-containing equipment:

a. The removal, segregation and disposal of PCB-containing light ballasts; and

b. The denergizing and testing of dielectric fluid for PCBs in transformers to be removed.

VI. LIMITATIONS

This report has been prepared for the exclusive use of Marshall Craft Associates and/or their agents. This service has been performed in accordance with generally accepted environmental practices. No other warranty, expressed or implied, is made. Our conclusions and recommendations are based, in part, upon information provided to us by others and our site observations. We have not verified the completeness or accuracy of the information provided to us by others, unless otherwise noted. Our observations and recommendations are based upon conditions readily visible at the site at the time of our site visit, and upon current industry standards. Destructive sampling was not performed as part of this survey. No observations were made behind solid walls, ceilings or in pipe chases. The report presents assumptions for the existence of hazardous materials in these locations.

By virtue of providing the services described in this report, the preparer does not assume the responsibility of the person(s) in charge of the site, or otherwise undertake responsibility for reporting to any local, state, or federal public agencies any conditions at the site that may present a potential danger to public health, safety, or the environment. It is the Client’s responsibility to notify the appropriate local, state, or federal public agencies as required by law, or otherwise to disclose, in a timely manner, any information that may be necessary to prevent

Buildings 74 and 81, Naval Research Laboratory Page 11 any danger to public health, safety, or the environment. Under this scope of services, the preparer assumes no responsibility regarding response actions (e.g. O&M plan, encapsulation, abatement, removal, etc.) initiated as a result of these findings. Response actions are the sole responsibility of the Client and should be conducted in accordance with local, sate, and/or federal requirements, and should be performed by appropriately licensed personnel as warranted.

Buildings 74 and 81, Naval Research Laboratory Page A1

Attachment A:

Inspector’s Credentials

Buildings 74 and 81, Naval Research Laboratory Page A2

Attachment B:

Certificates of Analysis and Chain-of-Custody Forms

International Asbestos 9000 Commerce Parkway Suite B Mt. Laurel, NJ 08054 Telephone: 856-231-9449 Fax: 856-231-9818Testing LaboratoriesIA.TL

CERTIFICATE OF A]~ALYSIS

Client: Aria Environmental Report Date: 10/13/2009

PO Box 286 Project: NRL Bldg 74

Woodbine MD 21797 Project No.: 090435

BULK SAMPLE ANALYSIS SU1\1MARY

Lab No.: 3756810

Client No.: 74-ASB-\

None Detected None Detected

Lab No.: 3756811

Client No.: 74-ASB-2

None Detected None Detected

Description I Location: WhitelTan Ceiling Tile

% Non-Asbestos Fibrous Material

None Detected None Detected

Description / Location: Yellow Mastic

% Non-Asbestos Fibrous Material

None Detected None Detected

Lab No.: 3756812

Client No.: 74-ASB-3

None Detected None Detected

Description I Location: Off-White Caulk

% Non-Asbestos Fibrous Material

None Detected None Detected

Lab No.: 3756813

Client No.: 74-ASB-4

% Asbestos

None Detected None Detected

Description I Location: Brown Caulk

% Non-Asbestos Fibrous Material

None Detected None Detected

% ~Q!1-Fibrous Material

'Yo Non-Filrrolls Material

% NOll-Fibrous Material

% Non-Fibrous Material

NIST-NVLAP No. 101165-0 NY-DOH No. 11021

Comments: (PC) Indicates Stratified Point Count Method performed. Method not perfonned tUlless stated. Quantification at <0.25% this limit of quantitation. (pC-Trace) means that asbestos was detected but is not quantifiable under the Point accordance with EPA 600 Method. If not reported or otherwise noted. layer is either not present Or the client has spe,;lIlc.ally be missed PLM due to resolution limitations of the PLM results cannot

Analysis Performed By: L. Solebello Approved By:

Date: 10/13/2009 Page I of 12

AIHA Lab No. 100188 with this method. (PC-Trace) represents includes all distinct separable layers in that it not be analyzed. Small asbestos fibers may

Laboratory Director

Telephone: 856-231-9449 Fax: 856-231-9818Testing LaboratoriesIA_TL

CERTIFICATE OF ANALYSIS

Client: Aria Environmental Report Date: 10113/2009

PO Box 286 ]>roject: NRL Bldg 74

Woodbine MD 21797 ]>roject No.: 090435

BULK SAMPLE ANALYSIS SUT\1MARY

Lab No.: 3756814 Description / Location: White Stucco

Client No.: 74-ASB-5

% Asbestos % Non-Asbestos Fibrous Material % Non-Fibrous Material

None Detected None Detected 5 Fibrous Glass 95

Lab No.: 3756815 Description / Location: Whiterran Ceiling Tile

Client No.: 74-ASB-6

% Asbestos % Non-Asbestos Fibrous Material % Non-Fibrous Material

None Detected None Detected 35 Cellulose 30

35 Fibrous Glass

NIST-NVLAP No. 101165-0 NY-DOH No. 11021 AffiA Lab No. 100188 11,is confidential repart relates anly ta those itemr» tested and does not represel1l an endorsement by NIST-NVLAP, AlHA or any agency ofthe US, government

This be without written

Analysis Method: EPA 600/R-931l16

Comments: (PC) Indicates Stratified Point Count Method performed, Method not performed unless stated, Quantification at <0,25% by volume is possible with this method, (PC-Trace) represents this limit of quantitation, (PC-Trace) means that asbestos was detected but is not quantifiable under the Point Counting regimen, Analysis includes all distinct separable layers in accordance with EPA 600 Method, If not reported or otherwise noted, layer is either not present or the client has specifically requested that it not be analyzed, Small asbestos fibers may be missed by PLM due to resolution limitations of the optical microscope. Therefore, negative PLM results cannot be guaranteed, Electron Microscopy can be used as a confinnmg

Ke''lllaitorv Limit is based matrix, Analysis Performed By: L. Solebello

Date: 10113/2009 Page2 ofl2

International Asbestos 9000 Commerce Parkway Suite B Mt. Laurel, N] 08054 Telephone: 856-231-9449 Fax: 856-231-9818Testing Laboratories IA.TL

Client: Aria Environmental Report Date: 10113/2009

PO Box 286 Project: NRLBldg 74

Woodbine MD 21797 Project No.: 090435

BULK SAMPLE ANALYSIS SU:rVIMARY

Lab No.: 3756816

Client No.: 74-ASB-7

% Asbestos

None Detected None Detected

Lab No.: 3756816

Client No.: 74-ASB-7

% Asbestos

None Detected None Detected

Lab No.: 3756816

Client No.: 74-ASB-7

% Asbestos

None Detected None Detected

Description I Location: Tan Rubber

% Non-Asbestos Fibrous Material

None Detected None Detected

Description I Location: Yellow Mastic

% Non-Asbestos Fibrous Material

None Detected None Detected

Description I Location: White Leveling Compound

% Non-Asbestos Fibrous Material

None Detected None Detected

'29 Non-Fibrous Material

Layer No.: 2

% Non-Fibrous Material

Layer No.: 3

% Non-Fii:>rQus Material

NIST-NVLAP No. 101165-0 NY-DOH No. 11021 AIHA Lab No. 100188 This confidential report relates only to those item(s) tested and does not represent an endorsement by NIST·NVLAP, AIHA or any agency ofthe US. government

This shall not be

Analysis Method: EPA 600/R-93/116 without written

Comments: (PC) Indicates Stratified Point Count Method performed. Method lIot performed unless stated. Quantification at <0.25% by volume is possible with this method. (pC-Trace) represents this limit ofquantitation. (pC-Trace) means that asbestos was detected but is not quantifiable under the Point Counting regimen. Analysis includes all distinct separable layers in accordance with EPA 600 Method. If not reported or otherwise noted, layer is either not present or the client has specifically requested that it not be analyzed. Small asbestos fibers may be missed by PLM due to resolution limitations of the optical microscope. Therefore, negative PLM results cannot be guaranteed Electron Microscopy can be used as a confirming

Limit is based upon the matrix.

Analysis Performed By: L. Solebello

Date: 10/13/2009

Telephone: 856-231-9449 Fax: 856-231-9818 Testing Laboratories

CERTIFICATE OF A~'~j\LYSIS

Client: Aria Environmental Report Date: 10/13/2009

PO Box 286 Jl'ro,ject: NRLBldg 74

Woodbine MD 21797 ProJiect No.: 090435

BULK SAMPLE ANALYSIS SUMMARY

Lab No.: 3756817 Client No.: 74-ASB-8

% Asbestos

None Detected None Detected

Lab No.: 3756817 Client No.: 74-ASB-8

% Asbestos

None Detected None Detected

Lab No.: 3756818 Client No.: 74-ASB-9

% Asbestos

None Detected None Detected

Lab No.: 3756818 Client No.: 74-ASB-9

% Asbestos

PC 1.5 Chrysotile

Description / Location: Pink/Tan Sheetrock

% Non-Asbestos Fibrous Material

15 Cellulose

Description / Location: White Joint Compound

% Non-Asbestos Fibrous Material

None Detected None Detected

Description / Location: Lt.Tan Floor Tile

% Non-Asbestos Fibrous Material

None Detected None Detected

Description / Location: YellowlBlack Mastic

% Non-Asbestos Fibrous Material

None Detected None Detected

% Non-Fibrous Material

Layer No.: 2

% Non-Fibrous Material

% Non-Fibrous Material

Layer No.: 2

% Non-Fibrous Material

PC 98.5

NIST-NVLAP No. 101165-0 NY-DOH No. 11021 AIHA Lab No. 100188 This confidential report relates only to those item(s) tested and does not represent an endorsement by NlST-NVLAP, AlHA or any agency ofthe Us. government

This report shall not be reproduced except infull, without written Qppro_va_l-'of_t_h_e_lQ_b_or_Q_to_ry'--.___________..______

Analysis Method: EPA 600/R-93/116

Comments: (PC) Indicates Stratified Point Count Method perfonned. Method not perfonned unless stated. Quantification at <0.25% by volume is possible with this method. (PC-Trace) represents this limit of quantitation. (PC-Trace) means that asbestos was detected but is not quantifiable under the Point Counting regimen. Analysis includes all distinct separable layers in accordance with EPA 600 Method. If not reported or otherwise noted, layer is either not present or the eli''llt has specifically requested that it not be analyzed. Small asbestos fibers may be missed by PLM due to resolution limitations of the optical microscope. Therefore, negative PLM results canlot be guaranteed. Electron Microscopy can be used as a confinning technique. Regulatory Limit is based upon the sample matrix.

Analysis Performed By: L. Solebello

International Asbestos 9000 Commerce Parkway Suite B ~1t. Laurel, ;\IJ 08054 Telephone: 856-231-9449 Fax: 856-231-9818Testing Laboratories IATL

Client: Aria Environmental Report Date: 10/13/2009

Woodbine MD 21797 Project No.: 090435

BULK SAMPLE ANALYSIS SUMMARY

Lab No.: 3756819 Client No.: 74-ASB-1O

PC Trace Chrysotile

Lab No.: 3756819 Client No.: 74-ASB-1O

% Asbestos

PC 3.8 Chrysotile

Lab 1\"0.: 3756820 Client 1\"0.: 74-ASB-II

%A,bestos ~

PC 14 Chrysotile

Lab No.: 3756820 Client No.: 74-ASB-ll

% Asbestos

PC 1.2 Chrysolile

Description I Location: Tan Floor Tile

% Non-Asbestos Fibrous Material

None Detected None Detected

Description I Location: Black Mastic

% Non-Asbestos Fibrous Material

None Detected None Detected

Description I Location: Grey Glazing

% Non-Asbestos Fibrous Material

None Detected ;\lone Detected

Description I Location: Tan Glazing

% Non-Asbestos Fibrous Material

None Detected None Detected

% Non-Fibrous Material

Layer No.: 2

% Non-Fibrous Material

PC 96.2

% Non-Fibrous Material

PC 98.6

Layer No.: 2

% Non-Fibrous Material

PC 98.8

NIST-NVLAP No. 101165-0 NY-DOH No. 11021 AIHA Lab No. 100188 This confidential report relates only to those item(s) tested and does not represent an endorsement by NIST-NVL4P, AIHA or any agency ofthe U.S. government without written

Comments: (PC) Indicates Stratified Point Count Method perfonned. Method not performed unless stated. Quantification at <0.25% by YOlunl" is possible with this method. (PC-Trace) represents this limit of quanlltation. (PC-Trace) means that asbestos was detected but is not quantifiable under the Point Counting regimen. Analysis mcludes all distinct separable layers in accordance with EPA 600 Method. Ifnot reported or otherwise noted, layer is either not present or the client has specificaEy requested that it not be analyzed. Small asbeslos flbers missed by PLM due to resolution limitations of the optical microscope. Therefore, negative PLM results cannot be guaranteed. Electron Microscopy can be used as a Regulatory Lim;1.

is based upon the sample matrix.

Analysis Performed By: L. Solebello

Date: 10/1312009 Page 5 ofl2

International Asbestos 9000 Commerce Parkway Suite B Mt Laurel, NJ 08054 Telephone: 856-231-9449 Fax: 856-231-9818 Testing Laboratories IA,TL

Client: Aria Environmental Report Date: 10/13/2009

PO Box 286 »roject: NRLBldg 74

Lab No.: 3756821

Client No.: 74-ASB-12

% Asbestos

None Detected None Detected

Lab No.: 3756822

Client No.: 74-ASB-13

% Asbestos

None Detected None Detected

Lab No.: 3756822

Client No.: 74-ASB-13

PC3,l Chrysotile

Lab No.: 3756823

Client No.: 74-ASB-14

% Asbestos

ChrysotiJe

Description I Location: Brown Mastic

% Non-Asbestos Fibrous Material

2 Other

Description I Location: Off-White Floor Tile

% Non-Asbestos Fibrous Material

None Detected None Detected

Description I Location: Black Mastic

% Non-Asbestos Fibrous Material

None Detected None Detected

Description I Location: Grey Transite

'l11l'1on-Asbestos Fibrous Material IYID< None Detected None Detected

% Non-Fibrous Material

% Non-Fibrous Material

Layer No.: 2

% Non-Fibrous Material

PC 96.9

% Non-Fibrous Material

7-'"

NIST-NVLAP No. 101165-0 NY-DORNo.H021 AIHA Lab No. 100188 This confidential report relates only to those

This

Analysis Method: EPA 600/R-93/1 16

Comments: (PC) Indicates Stratified Point Count Method perfonned. Method not perl'ormed unless stated. Quantification at <0.25% by volume is possible \-vith this method. (PC-Trace) represents this limit of quantitation. (PC-Trace) means that asbestos was detected but is not quantifiable under the Point Counting regimen. Analysis includes all distinct separable layers in accordance ... ith EPA 600 Method. Ifnot repotted or otherwise noted, layer is either not present or the client has specifically requested that it not be analyzed. Small asbestos fibers may be missed by PLM due to resolution limitations of the optical microscope. Therefore, negative PLM results cannot be guaranteed. Electron Microscopy can be used as a confirming matrix.Limit is based the

Analysis Performed By: L. Solebello

International Asbestos 9000 Commerce Parkway Suite B Mt Laurel, NJ 08054

Client: Aria Environmental Report Date: 10/1312009

Lab No.: 3756824

Client No.: 74-ASB-15

% Asbestos

None Detected N one Detected

Lab No.: 3756825

Client No.: 74-ASB-16

% Asbestos ~

PC 7.3 Chrysotile

Lab No.: 3756825

Client No.: 74-ASB-16

% Asbestos

PC3.8 Chrysotile

Description I Location: Brown Paper

% Kon-Asbestos Fibrous Material

90 Cellulose

Description I Location: TanlBrown Floor Tile

% Non-Asbestos Fibrous Material

None Detected None Detected

Description I Location: Black Mastic

% Non-Asbestos Fibrous Material

None Detected None Detected

% Non-Fibrous Material

% Kon-Fibrous Material

PC 92.7

Layer No.: 2

% Non-Fibrous Material

PC 96.2

Lab No.: 3756826 Description I Location: Dk. Green Countertop/Soapstone

Client No.: 74-ASB-17

% Asbestos % Non-Asbestos Fibrous :Vfaterial % Non-Fibrous Material

None Detected None Detected None Detected None Detected 100

NIST-NVLAP No. 101165-0 NY-DOH No. 11021 AIHA Lab No. 100188 Th,s confidential report relates only to those item(s) tested and does not represent an endorsement by1,7ST-NVLAP, AIHA or any agency a/the U.S. government

Analysis Method: EPA 600/R-93/J 16

Comments: Indicates Stratified Point Count Method performed. stated. Quantification at <0.25% by volume is quan",aLlon. (pC-Trace) means that asbestos was detected but qUantlilable under the Point Counting regimen.

or the client has specifically requested If not reported or otherwise noted, dUe to resolution limitations afthe optical microscope.

based upon the sample matrix.

cannot be guaranteed.

Analysis Performed By: L. Solebello

Page 7 of12

International Asbestos 9000 Commerce Parkway Suite B Mt. Lamel, NJ 08054 Telephone: 856-231-9449 Fax: 856-231-9818Testing LaboratoriesIA"TL

Client: Aria Environmental Report Date: 10/1312009

Lab No.: 3756827

Client No.: 74-ASB-18

% Asbestos

None Detected None Detected

Description I Location: Tan Ceiling Tile

'lIc!NQI!:Asbestos Fibrous Material

35 Cellulose

35 Fibrous Glass

Lab No.: 3756828 Description I Location: Red Floor Tile

Client No.: 74-ASB-19

% Asbestos % Non-Asbestos Fibrous Material

None Detected None Detected None Detected None Detected

% Non-Fibrous Material

% Non-Fibrous Material

Lab No.: 3756829 Description I Location: Whiterran Ceiling Tile

Client No.: 74·ASB-20

% Asbestos % Non-Asbestos Fibrous Material % Nol1~Fibrous Material

None Detected None Detected 35 Cellulose 30

35 Fibrous Glass

Lab No.: 3756830 Description I Location: Whiterran Ceiling Tile

Client No.: 74-ASB-21

% Asbestos % Non-Asbestos Fibrous Material % Non-Fibrous Material

None Detected None Detected 20 Cellulose 20

60 Fibrous Glass

NIST-NVLAP No. 101165-0 NY-DOH No. 11021 AIHA Lab No. 100188 This confidential report relates Dilly to those item(s) tested and does not represent an endorsement by N1ST-NVLAP, AfHA or any agency ofthe u.s. government

This shall not be

Analysis Method: EPA 6001R-93/lJ6 without written

Comments: (PC) Indicates Stratified Point…