Attachment_PPI-5_20210226_164 Basis of Design - IFC Submission - HAZMAT Report.pdf

Renovate Building 164 26 February 2021 Basis of Design Report IFC Submission NSA South Potomac, Indian Head, Maryland

Appendix G. Hazardous Materials Report

Renovate Building 164 26 February 2021 Basis of Design Report IFC Submission NSA South Potomac, Indian Head, Maryland

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HAZARDOUS MATERIAL SURVEY

NAVAL FACILITIES ENGINEERING COMMAND - ATLANTIC

NSF INDIAN HEAD BUILDING 164

INDIAN HEAD EODTD, INDIAN HEAD, MD

CONTRACT # N40080-17-D-0018

PROJECT # F5Y67309

Prepared for:

JACOBS GOVERNMENT SERVICE COMPANY

1100 North Glebe Road, Suite 500 Arlington, VA 22201

Submitted by:

6401 Golden Triangle Drive, #304

Greenbelt, MD 20770

January 2, 2020

Architect-Engineer Services Contract Naval Facilities Engineering Command - Atlantic

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

Delivery Order – 148008267 Project Number – F5Y67309 i

Table of Contents

EXECUTIVE SUMMARY

ACRONYMS

1.0 INTRODUCTION

2.0 ASBESTOS SURVEY REPORT

2.1 Survey Methodology

2.2 Analytical Procedures

2.3 Inaccessible and Limited-Access Spaces

2.4 Survey Limitations

2.5 Asbestos Survey Results

2.6 Asbestos Conclusions and Recommendations

3.0 LEAD-BASED PAINT SURVEY REPORT

3.1 LBP Survey Methodology

3.2 LBP Survey Results

3.3 LBP Conclusions and Recommendations

4.0 POLYCHLORINATED BIPHENYL (PCB) REPORT

4.1 Methodology

4.2 PCB Results and Interpretation

4.3 PCB Conclusions and recommendations

5.0 WOOD ROOF FRAMING MATERIALS TESTING

5.1 Methodology

5.2 Wood Roof Results and Interpretation

5.3 Wood Roof Conclusions and Recommendations

6.0 DISCLAIMER

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

Delivery Order – 148008267 Project Number – F5Y67309 ii

Appendices:

Appendix 1 – ACM Analytical Results Appendix 2 – Bulk Sample Locations Appendix 3 – Lead XRF Results Appendix 4 – PCB Results Appendix 5 – Wood Sampling Results Appendix 6 – Wood Testing Analytical Reports Appendix 7 – Inspector Certification(s)/License(s)

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018 i

EXECUTIVE SUMMARY

The Naval Facilities Engineering Command (NAVFAC) retained Jacobs Government Services Company (Jacobs) to provide Architect-Engineering Services for the Indian Head Explosive Ordnance Disposal Technology Division (EODTD), Indian Head, MD upgradation of the testing laboratories project at Building 164. Jacobs retained Global Consulting, Inc. (GCI) to perform the environmental and hazardous material survey associated with this project. This report documents the survey of the Facility by certified inspectors for asbestos-containing material (ACM), lead-based paint (LBP), polychlorinated biphenyls (PCBs), and other hazardous materials. Building 164 is a 10,900 square foot (SF) high-bay industrial building with large open areas divided between the original building and two subsequent additions. Interior finished are generally rough concrete flooring, exposed brick masonry exterior walls, exposed ceilings, and sections of metal grating and catwalks assumed to have supported previous activities within the building. This building will house approximately 75 personnel in a combination of open and enclosed offices. Areas for utility rooms, vertical circulation, conferencing, and restrooms will be incorporated. This survey was intended to identify the potentially hazardous materials and conditions likely to be impacted by the proposed project.

Asbestos:

GCI’s EPA-accredited, Maryland-licensed Asbestos Inspector assessed the existing building materials suspected to contain asbestos and to be impacted during renovation. The asbestos survey was conducted on October 2, 2019. A total of 17 bulk samples of six homogeneous suspect materials were collected and submitted for analysis to the project laboratory.

The following materials are confirmed ACM via laboratory analysis:

White pipe insulation-thermal system insulation (TSI) (friable) Gray/brown window caulk (non-friable) Gray caulking on the interior brick (non-friable) Gray corrugated cementitious siding (non-friable)

Red mechanical gaskets and fire doors were not sampled in order to maintain their functional integrity and safety rating. These materials are presumed asbestos-containing and should be handled as ACM until future bulk sampling confirms otherwise.

Remedial action (abatement) is required if these materials are disturbed/impacted by the proposed renovation.

The analytical results for all other materials sampled indicated that no asbestos was detected, and the materials are not considered to be ACM. Remedial action is, therefore, not indicated

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018 ii for those materials. Details of the survey are presented in Section 2.0 – Asbestos Survey Report. Analytical results are presented in Appendix 1 – ACM Analytical Results.

Lead-Based Paint:

GCI’s EPA-accredited Lead Risk Assessor and Industrial Hygienist (IH) performed a survey of Building 164 on October 2, 2019. All areas of the facility were accessible at the time of survey. The sampling and analysis of suspect surfaces indicates that Lead-Based Paint (LBP) and Lead-Containing Paint (LCP) are present in the facility and they have an elevated potential to be impacted during the renovation of the building.

The following materials were identified as coated/painted with LBP:

Grey structural steel columns found throughout the building and associated pieces of structural steel

Grey painted stairways and associated hand rails (leading to second level of structure)

Silver painted interior large sliding doors White painted exterior windows and associated window frames White painted exterior doors and door frames (on the exterior of building) Brown painted wooden doors and associated door frames Silver painted ether tanks Yellow painted access handrails present in ether tank room Silver painted circular columns in ether tank room White painted riser pipe at exterior

The following materials were identified as coated/painted with LCP:

Trace amounts of red paint present on structural steel columns White paint present on brick walls on first and second floor Silver paint on interior of door trim in ether tank room Red paint present under silver top coat on ether tanks Brown paint on pit guardrails in 164A

Details of the survey are presented in Section 3.0 – Lead-Based Paint Survey Report.

Analytical results are presented in Appendix 3 – Lead XRF Results.

Polychlorinated Biphenyls (PCBs)

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018 iii

The EPA considers a material to be PCB-containing if it contains equal to or greater than 50 parts per million (ppm) of PCBs. Laboratory analysis (Method 8082) by ALS Laboratory Group in Holland, MI, confirmed that none of the six bulk window caulk samples contained detectable concentrations of PCBs.

Wood Roof Framing Materials Testing

Testing of the existing wood framed roofing system for materials that may be harmful to occupants or the other building components was conducted on October 25, 2019. Thirty samples were analyzed for arsenic, barium, cadmium, chromium, lead, selenium, silver, and mercury.

While barium, lead, chromium, and cadmium were detected in concentrations that would qualify some of the wood components as hazardous waste, as part of historical preservation, the existing wood framed roof system will be retained to the fullest extent possible. The EPA and State of Maryland indicate that encapsulation, especially when dealing with historic buildings/structures, is an approved, viable method for managing the materials in place and preventing exposure to lead and other heavy metals to building occupants.

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018 iv

ACRONYMS

ACM Asbestos-Containing Material

AHERA Asbestos Hazard Emergency Response Act

CFR Code of Federal Regulations

CSP Certified Safety Professional

CPSC Consumer Product Safety Commission

EPA Environmental Protection Agency

EPDTD Explosive Ordnance Disposal Technology Division

HVAC Heating, Ventilation, and Air Conditioning

IH Industrial Hygienist

LBP Lead-Based Paint

LCP Lead-Containing Paint

MDE Maryland Department of the Environment

MOSH Maryland Occupational Safety and Health

NVLAP National Voluntary Laboratory Accreditation Program

NOB Non-Friable Organically Bound

NESHAP National Emission Standards for Hazardous Air Pollution

OSHA Occupational Safety & Health Administration

PCB Polychlorinated Biphenyl

PLM Polarized Light Microscopy

PACM Presumed Asbestos-Containing Material

PCS Performance Characteristic Sheet

ODS Ozone Depleting Substances

RACM Regulated Asbestos-Containing Material

TEM Transmission Electron Microscopy TCLP Toxicity Characteristic Leaching Procedure

TSCA Toxic Substances Control Act (1976)

XRF X-ray Fluorescence

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

1.0 INTRODUCTION

The Naval Facilities Engineering Command (NAVFAC) retained Jacobs Government Services Company (Jacobs) to provide Architect-Engineering Services for the Indian Head EODTD, Indian Head, MD upgradation of the testing laboratories project at Building 164.

Jacobs retained Global Consulting, Inc. (GCI) to perform the environmental and hazardous material survey associated with this project. The mutual goal of the contractor and the government is to achieve a quality product, safely, within the expected timeframe and budget.

The purpose of the survey was to identify potential Asbestos-Containing Materials (ACM), Lead-Based Paint (LBP), polychlorinated biphenyls (PCBs), and other potential hazardous and regulated material in the Facility that maybe impacted by the proposed renovation.

The scope of work for this survey consisted of the following tasks:

1. Review of available records for identified and suspect ACM, LBP, PCB, and other hazardous and regulated materials that may be impacted by the scope of work;

2. Conduct a visual survey of the project area to identify potential location(s) of hazardous materials that may be affected by the scope of work.

3. Collect bulk samples of suspect ACMs; Assess building components for LBP using an X-ray fluorescence (XRF) analyzer Collect bulk samples of suspect PCB-containing materials; and Inventory other visible hazardous and regulated materials.

4. Submit the suspect ACM bulk samples to a certified laboratory for Polarized Light Microscopy (PLM) and/or Transmission Electron Microscopy (TEM) -where applicable; Download the XRF results; Submit the suspect PCB-containing samples to a certified laboratory for analysis.

5. Prepare a report summarizing data, collection techniques, analysis procedures, location and quantity of ACM, LBP/LCP, PCB, and other hazardous and regulated materials observed and detailed recommendations for any indicated response actions.

6. Abatement specifications will be prepared separately, if required.

2.0 ASBESTOS SURVEY REPORT

This section describes the site survey and sample collection of suspect ACMs. The site survey was completed on October 3, 2019, by GCI’s EPA-accredited Asbestos Hazard Emergency Response Act (AHERA) and State of Maryland Department of Environmental (MDE)-accredited asbestos inspector, Ms. Judi Todd Darnell (MDE License# 18034611).

A copy of Ms. Darnell’s license is included in Appendix 7.

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

The Environmental Protection Agency (EPA) and the State of Maryland are the authorities that regulate activities related to asbestos-containing materials (ACMs) within the State of Maryland. The EPA regulations enforce four asbestos activities; (1) removal, repair, or encapsulation of asbestos-containing materials (ACM), (2) approval of asbestos training providers, (3) regulation of professionals accredited to perform asbestos-related activities, and (4) asbestos in schools. The Maryland Department of the Environment (MDE) regulates the enforcement of the EPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP), and enforcement of the asbestos notification regulations.

2.1 Survey Methodology

The asbestos survey was divided into two distinct phases: pre-survey planning and field survey.

2.1.1 Pre-Survey Planning

The pre-survey planning phase includes reviewing previous survey reports, drawings, management plans, and abatement reports, if available. Jacobs provided GCI with information regarding the planned renovations and upgrades of the property for this project.

GCI planned a survey strategy and scheduled the survey work. It was determined that this survey should include selected portions of the Facility designated on the project drawings to ensure that intended renovations and/or related renovation, can be conducted in an efficient and safe manner compliant with applicable Federal, state, and local regulations.

2.1.2 Field Survey

The field survey was conducted on affected spaces to be renovated as determined in the planning phase, and building materials related to the testing facilities were identified and considered to be suspect ACM.

Suspect materials that were homogeneous in nature (i.e., uniform in color and texture, installation date) were identified, touched to determine friability, and sampled by removing a small amount of material. Extreme care was taken to avoid potential fiber release during the sampling process. Before sample collection, a fine mist of water was typically applied to the sampling location. Samples were collected using sharpened core samplers and/or utility knives, where necessary, and immediately placed in labeled containers and sealed.

Any dust generated was wet-wiped to minimize the potential fiber release. All sampling locations were promptly patched and repaired. The location and condition of each homogeneous material were recorded. This is a limited survey of testing laboratories and is not intended to serve as a complete building assessment.

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

2.2 Analytical Procedures

The samples of suspect ACMs were packaged and delivered under strict chain of custody procedures to AMA Analytical Services of Lanham, MD, a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory.

Quantification of asbestos content in bulk samples was performed via EPA 600/R-93/116 Method using Polarized Light Microscopy (PLM). This method of analysis involves the dispersion staining of a suspect material in a solution of known refractive index and then subjected to illumination by polarized light. The resulting color display enables mineral identification. The EPA, Occupational Health and Safety Administration (OSHA) and the State of Maryland defines an ACM as any material containing greater than 1% asbestos. If and when PLM analysis confirmed a trace amount of asbestos in a sample set, GCI instructed the laboratory to upgrade the analysis to Transmission Electron Microscopy (TEM) for Non-Friable Organically Bound (NOB) materials.

A summary of field data including the sample designations, gross descriptions, and analytical results are provided in Table 2. The analytical results of all bulk samples and chain of custody documents are provided in Appendix 1.

2.3 Inaccessible and Limited-Access Spaces

Every reasonable effort was made to locate suspect ACM at elevated potential to be impacted by this project. Areas that were inaccessible, or where the survey was limited to visual observation only, are identified in this report’s narrative. Such inaccessible areas might include, but are not limited to, those listed in Table 1: Description of Potential Inaccessible Locations.

Table 1: Description of Potential Inaccessible Locations

Mechanical and plumbing system above the reach of readily accessible ladders

Concealed by waterproofing systems including roofs and wall systems

Enclosed pipe/duct chases/floor penetrations Inside mechanical equipment/ductwork

Inside Fire Doors Above the reach of a 6’ ladder

2.4 Survey Limitations

This survey was limited to areas and building systems scheduled for the upgradation as part of the scope of this project. Other suspect materials observed or discovered during renovation or demolition activities not identified within this report should be considered as

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018 presumed asbestos-containing material (PACM) and treated as ACM until sampling and laboratory analysis confirms otherwise. Roofing and waterproofing membranes were not sampled and should be considered PACM and treated as ACM until laboratory analysis confirms otherwise.

2.5 Asbestos Survey Results

A total of seventeen (17) bulk samples were collected from six (6) homogeneous suspect materials during the survey of Building 164. The suspect ACM and asbestos laboratory analytical results are summarized in Table 2: Description of Homogeneous Areas and Sampling Results. Asbestos bulk sample locations are illustrated in the drawings in Appendix 2.

Table 2: Description of Homogeneous Areas and Sampling Results Material

Description Sample Number Sample Location Asbestos

Content Photo

Gray/brown window caulk/glazing

(homogeneous area #01)

AA160-B164-01A

In 164A second floor

1.4% Anthophyllite*

AA160-B164-01B 8.5% Chrysotile*

AA160-B164-01C 4.2% Chrysotile*

White window caulk/glazing

(homogeneous area #02)

AA160-B164-02A,

2B, 2C

Center room exterior wall road side Non-Detect

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

Table 2: Description of Homogeneous Areas and Sampling Results Material

Description Sample Number Sample Location Asbestos

Content Photo

Gray caulking on brick (homogeneous area #03)

AA160-B164-03A

On interior brick in center room

3% Chrysotile

AA160-B164-03B 4% Chrysotile

White pipe insulation with cloth wrap on 2.5” OD pipe (homogeneous area #04)

AA160-B164-04A,

04B, 04C

Back left side of center room 30% Chrysotile

Beige brick mortar (homogeneous area

#05)

AA160-B164-05A,

05B, 05C

Center room exterior wall road side Non-Detect

Gray corrugated cementitious siding (homogeneous area

#06)

AA160-B164-06A

Interior wall 2nd floor B164A

18% Chrysotile 2% Crocidolite

AA160-B164-06B 20% Chrysotile

AA160-B164-06C 10% Chrysotile

*PLM analysis confirmed trace asbestos (<1%); TEM analysis confirmed the material as ACM.

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

Red mechanical gaskets and fire doors were not sampled so to maintain their integrity and safety rating. Roofing and waterproofing membranes were not sampled. These materials are presumed asbestos-containing and should be handled as ACM until future bulk sampling confirms otherwise.

2.6 Asbestos Conclusions and Recommendations

Regulated asbestos-containing material (RACM) is defined as friable asbestos-containing material (ACM) or non-friable asbestos-containing material (ACM) with an asbestos fiber content greater than 1%. The regulations require that RACM not be subjected to sanding, grinding, cutting, or abrading or has crumbled, pulverized, or reduced to powder during demolition or renovation operations. All RACM with the potential to be impacted by the renovation/demolition should be abated in accordance with all applicable Federal, state and local regulations.

The following materials are confirmed ACM via laboratory analysis:

White pipe insulation-thermal system insulation (TSI) (friable) Gray/brown window caulk (non-friable) Gray caulking on the interior brick (non-friable) Gray corrugated cementitious siding (non-friable)

Red mechanical gaskets and fire doors were not sampled so to maintain their integrity and safety rating. These materials are presumed asbestos-containing and should be handled as ACM until future bulk sampling confirms otherwise.

Remedial action (abatement) is required if these materials are disturbed/impacted by the proposed renovation.

The analytical results for all other two materials sampled indicated that no asbestos was detected, and the materials are not considered to be ACM. Remedial action is, therefore, not indicated for those materials. Details of the survey are presented in Section 2.0 – Asbestos Survey Report. Analytical results are presented in Appendix 1 – ACM Analytical Results.

If additional suspect materials are identified during renovation/demolition, and they will be disturbed by the proposed work and have not been tested to determine the presence of asbestos, those materials should be protected from impact until further investigated and the asbestos content determined.

All quantities must be field-verified by a licensed asbestos abatement contractor(s) prior to demolition or renovation.

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

Sampling locations and positively-identified ACMs are illustrated on Drawings presented in Appendix 2.

3.0 LEAD-BASED PAINT SURVEY REPORT

This section describes data collection activities including the site survey and sample collection for Lead-Based Paint (LBP) that will be affected by the renovation of Indian Head Naval Surface Warfare Center, Building 164. The site survey was completed on October 2, 2019, by GCI’s Industrial Hygienist and EPA-accredited Risk Assessor, Judi Darnell (certificate # 107081.) Ms. Darnell’s certificate may be found in Appendix 7.

3.1 LBP Survey Methodology

Testing for LBP was conducted using a Niton XLP 300A X-ray fluorescence (XRF)-type analyzer (serial number 18595); hereto referred to as XRF. Prior to XRF analysis, the instrument was calibrated against reference standards of known lead concentrations. Those components that may be impacted by the building renovation were screened for LBP.

The XRF detects lead in the field by reading fluorescence emanating from a painted surface when exposed to small amounts of radiation. XRF readings are in milligrams per square centimeter (mg/cm2), a mass per area unit. LBP is defined as a point containing greater than

0.7 mg/cm2 lead according to the Maryland Department of the Environment and Lead-containing paint (LCP) is defined by any Components/Paints with greater than 0.009% lead by weight (90 parts per million) according to the U.S. CPSC. Prior to testing, the composition of the test building substrate (e.g., wood, metal, etc.) was determined by the lead inspector, and subsequently logged into the XRF analyzer. The Niton XLP 300A automatically performs a substrate correction to ensure that this factor does not result in false negative readings.

At the end of each sampling session, a calibration re-check is performed to ensure that the instrument has maintained accuracy and precision during the measurement period. The instrument is also calibrated each time it is turned off, or on, and typically at four (4) hour intervals during the workday for the same reasons. The use of the XRF was in general accordance with the Performance Characteristic Sheet (PCS) methodology for the specific instrument. XRF instrument calibration checks were performed according to the Performance Characteristic Sheet (PCS).

The XRF data was downloaded directly to a computer to generate a report detailing the date/time, materials sampled, location, substrate and lead content. This survey included only painted surfaces.

The raw data is presented in Appendix 3 – Lead XRF Results.

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

3.2 LBP Survey Results

The following materials in Building 164 tested positive for LBP at the time of the inspection:

Grey structural steel columns found throughout the building and associated pieces of structural steel

Grey painted stairways and associated hand rails (leading to second level of structure)

Silver painted interior large sliding doors White painted exterior windows and associated window frames White painted exterior doors and door frames (on the exterior of building) Brown painted wooden doors and associated door frames Silver painted ether tanks Yellow painted access handrails present in ether tank room Silver painted circular columns in ether tank room White painted riser pipe at exterior

The following material in Building 164 tested positive for LCP at the time of the inspection:

Trace amounts of red paint present on structural steel columns White paint present on brick walls on first and second floor Silver paint on interior of door trim in tank room Red paint present under silver top coat on Ether tanks Brown paint on pit guardrails in 164A

3.3 LBP Conclusions and Recommendations

The results of the survey for LBP indicate that much of the structural steel as well as several other building components contain LBP. Additionally, many other components featured in the survey fall under the category of lead-containing. OSHA Lead in Construction should be followed for all painted surfaces containing a detectable amount of lead, that may be disturbed during the renovation. It is recommended, where possible, to use a mechanical connection to attach to LBP-painted structures rather than welding, in order to minimize the impact to LBP/LCP.

U.S. Navy guidelines should be followed concerning the stabilization of LBP at military facilities. Under an agreement with the United States Occupational Safety and Health

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

Administration (OSHA), MOSH (Maryland Occupational Safety and Health) promotes occupational safety and health in workplaces across Maryland. In addition to adopting many of the Federal standards pertaining to lead-containing paint under General Industry (29 CFR 1910), Construction (29 CFR 1926). MOSH has supplemented the OSHA standards with several requirements unique to Maryland.

Contractors must be trained and accredited through the Maryland Department of the Environment (MDE). Lead paint contractors include those who work on residential, public, and commercial buildings as well as the maintenance work required in rental housing;

structural steel projects, such as bridges, water tanks, and industrial structures; and conducting lead paint surveys. Abatement supervisors and workers must be trained in accordance with State of Maryland laws.

The LBP and LCP painted surfaces that will be impacted during demolition should be managed in accordance with Federal, state, and local regulations. If lead paint-containing components are not to be abated, lead safe construction practices should be followed.

Painted metal components being disposed of during this renovation should be managed as scrap metal and the Facility notified of the LBP and LCP contents of the paint. The disposal of lead-containing waste materials generated during renovation/demolition shall be properly characterized via Toxicity Characteristic Leaching Procedure (TCLP), and disposed of at a facility licensed to accept the waste profile generated during characterization and the facility should be notified the material has LBP or LCP.

4.0 POLYCHLORINATED BIPHENYL (PCB) REPORT

The Toxic Substances Control Act (TSCA) of 1976 authorized the U.S. Environmental Protection Agency (EPA) to control substances that were determined to cause unreasonable risk to public health or the environment. In 1979, the U.S. EPA banned the manufacture of new products containing PCBs and developed regulatory requirements for the storage, labeling, use, and disposal of materials containing PCBs at levels above the regulatory thresholds. In addition, the regulations under TSCA specify allowed or authorized uses of PCBs in certain situations. If a material or item is not specifically listed, it is considered unauthorized. The U.S. EPA considers building materials containing PCBs, including caulk, with PCB concentration exceeding 50 ppm to be a regulated material that requires specific abatement requirements and worker protection considerations.

4.1 METHODOLOGY

The inspection included a visual inspection as well as bulk sampling. Six bulk samples of window caulk were submitted under strict chain of custody to ALS Laboratory Group of Holland, Michigan. EPA Method 8082 was used to determine the concentrations of various Aroclors using dual capillary columns with electron capture detectors. Aroclor is a PCB

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018 mixture produced from approximately 1930 to 1979; it is one of the most commonly known trade names for PCB mixtures. There are many types of Aroclors, and each has a distinguishing suffix number that indicates the degree of chlorination.

4.2 PCB RESULTS AND INTERPRETATION

Laboratory analysis confirmed that none of the six samples contained detectable concentrations of PCBs. Laboratory results are presented in Appendix 4.

4.3 PCB CONCLUSIONS AND RECOMMENDATIONS

No recommendations for PCB-containing materials are warranted for Building 164.

5.0 WOOD ROOF FRAMING MATERIALS TESTING

Testing of the existing wood framed roofing system for materials that may be harmful to occupants or the other building components was conducted on October 25, 2019.

5.1 METHODOLOGY

Thirty samples were submitted to ALS Environmental of Middletown, PA for RCRA 8 analysis via EPA Method SW-846 6010C (for arsenic, barium, cadmium, chromium, lead, selenium, and silver, and Method SW-846 7471B (for mercury). GCI collected six to nine (6-9) material samples from four areas. Components sampled included timber struts spanning between bottom chords of steel roof trusses, timber purlins bearing on the steel roof truss top chords, planks, rough sawn timber roof joists, and wooden sleepers bearing on the joints.

5.2 WOOD ROOF RESULTS AND INTERPRETATION

While barium, lead, chromium, and cadmium were detected in concentrations that would qualify some of the wood components as hazardous waste, as part of historical preservation, the existing wood framed roof system will be retained to the fullest extent possible, and will not be removed.

A summary of results may be found in Appendix 5. Laboratory analytical results are provided in Appendix 6.

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

5.3 WOOD ROOF CONCLUSIONS AND RECOMMENDATIONS

The EPA and State of Maryland indicate that encapsulation, especially when dealing with historic buildings/structures, is an approved, viable method for managing the materials in place and preventing exposure to lead and other heavy metals to building occupants.

6.0 DISCLAIMER

Information in this survey report relating to hazardous materials (i.e., asbestos and lead), although believed to be inclusive and accurate, was based on visual observations and field sampling of accessible areas at the time of survey. Limiting conditions included non-destructive sampling, inaccessible areas such as between walls and floors of the structure.

Global Consulting, Inc. reserves the right to revise any recommendations and conclusions based on new information that may become available and does not guarantee or accept any liability that encompasses this survey of hazardous or regulated materials located within this Facility. This survey report is not intended to serve as a comprehensive survey of the entire facility and is limited to materials likely to be impacted by the scope of work of this project

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

Appendix 1 – ACM Analytical Results

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

Appendix 2- Bulk Sample Locations

Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

Appendix 3 – Lead XRF Results

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Hazardous Material Survey Building 164– Renovation

Indian Head EODTD, Indian Head, MD Prime Contract - N40080-17-D-0018

Appendix 4 – PCB Results

22-Oct-2019

Global Consulting, Inc.

Judi Darnell

Dear Judi, Re: Indian Head B164 Work Order: 19100777

1818 New York Avenue NE

Washington, DC 20002 Suite 111

ALS Environmental received 6 samples on 09-Oct-2019 10:00 AM for the analyses presented in the following report.

Project Manager Chad Whelton Electronically approved by: Chad Whelton

The analytical data provided relates directly to the samples received by ALS Environmental - Holland and for only the analyses requested.

Sample results are compliant with industry accepted practices and Quality Control results achieved laboratory specifications. Any exceptions are noted in the Case Narrative, or noted with qualifiers in the report or QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained from ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made.

The total number of pages in this report is .

If you have any questions regarding this report, please feel free to contact me:

ADDRESS: 3352 128th Avenue, Holland, MI, USA

PHONE: +1 (616) 399-6070 FAX: +1 (616) 399-6185

Sincerely, ALS GROUP USA, CORP Part of the ALS Laboratory Group A Campbell Brothers Limited Company

Report of Laboratory Analysis Certificate No: MN 026-999-449

Date: 22-Oct-19ALS Group, USA

Project: Indian Head B164 Client: Global Consulting, Inc.

Work Order: 19100777 Work Order Sample Summary

Lab Samp ID Client Sample ID Collection DateTag Number Date ReceivedMatrix Hold 19100777-01 AA160-B164-PCB-01A Solid 10/2/2019 10:00 10/9/2019 10:00 19100777-02 AA160-B164-PCB-01B Solid 10/2/2019 10:00 10/9/2019 10:00 19100777-03 AA160-B164-PCB-01C Solid 10/2/2019 10:00 10/9/2019 10:00 19100777-04 AA160-B164-PCB-02A Solid 10/2/2019 10:00 10/9/2019 10:00 19100777-05 AA160-B164-PCB-02B Solid 10/2/2019 10:00 10/9/2019 10:00 19100777-06 AA160-B164-PCB-02C Solid 10/2/2019 10:00 10/9/2019 10:00

Sample Summary Page 1 of 1

Client: Global Consulting, Inc.

Work Order: 19100777 Case Narrative

Samples for the above noted Work Order were received on 10/09/2019. The attached "Sample Receipt Checklist" documents the status of custody seals, container integrity, preservation, and temperature compliance.

Samples were analyzed according to the analytical methodology previously transmitted in the "Work Order Acknowledgement". Methodologies are also documented in the "Analytical Result" section for each sample. Quality control results are listed in the "QC Report" section.

Sample association for the reported quality control is located at the end of each batch summary. If applicable, results are appropriately qualified in the Analytical Result and QC Report sections. The "Qualifiers" section documents the various qualifiers, units, and acronyms utilized in reporting. A copy of the laboratory's scope of accreditation is available upon request.

With the following exceptions, all sample analyses achieved analytical criteria.

Extractable Organics:

Batch 144028, Method PCB2_8082_S, Sample 19100777-03A: One or more surrogate recoveries were below the lower control limits. The sample results may be biased low.

Surrogate recoveries affected by matrix interference.

Case Narrative Page 1 of 1

ALS Group, USA Date: 22-Oct-19

QUALIFIERS,

ACRONYMS, UNITSProject: Indian Head B164

Client: Global Consulting, Inc.

WorkOrder: 19100777

Units Reported Description

Qualifier Description

Acronym Description

Milligrams per Kilogrammg/Kg

Value exceeds Regulatory Limit* Estimated Value** Analyte is non-accrediteda Analyte detected in the associated Method Blank above the Reporting LimitB Value above quantitation rangeE Analyzed outside of Holding TimeH BOD/CBOD - Sample was reset outside Hold Time, value should be considered estimated.Hr Analyte is present at an estimated concentration between the MDL and Report LimitJ Not Detected at the Reporting LimitND Sample amount is > 4 times amount spikedO Dual Column results percent difference > 40%P RPD above laboratory control limitR Spike Recovery outside laboratory control limitsS Analyzed but not detected above the MDLU Analyte was detected in the Method Blank between the MDL and Reporting Limit, sample results may exhibit background or reagent contamination at the observed level.

X

Method DuplicateDUP

Laboratory Control SampleLCS

Laboratory Control Sample DuplicateLCSD

Limit of Detection (see MDL)LOD

Limit of Quantitation (see PQL)LOQ

Method BlankMBLK

Method Detection LimitMDL

Matrix SpikeMS

Matrix Spike DuplicateMSD

Practical Quantitation LimitPQL

Relative Percent DifferenceRPD

Target Detection LimitTDL

Too Numerous To CountTNTC

APHA Standard MethodsA

ASTMD

EPAE

SW-846 Update IIISW

QF Page 1 of 1

Sample ID: AA160-B164-PCB-01A Collection Date: 10/2/2019 10:00 AM Matrix: SOLID

Analyses Result Qual Units Date Analyzed Report Limit

Client: Global Consulting, Inc.

Work Order: 19100777

Dilution Factor

Lab ID: 19100777-01

ALS Group, USA Date: 22-Oct-19

PCBS SW8082 Analyst: KBPrep: SW3540C 10/10/19 11:04

Aroclor 1016 10/16/2019 01:41 PM0.083 mg/Kg 1ND Aroclor 1221 10/16/2019 01:41 PM0.083 mg/Kg 1ND Aroclor 1232 10/16/2019 01:41 PM0.083 mg/Kg 1ND Aroclor 1242 10/16/2019 01:41 PM0.083 mg/Kg 1ND Aroclor 1248 10/16/2019 01:41 PM0.083 mg/Kg 1ND Aroclor 1254 10/16/2019 01:41 PM0.083 mg/Kg 1ND Aroclor 1260 10/16/2019 01:41 PM0.083 mg/Kg 1ND Aroclor 1262 10/16/2019 01:41 PM0.083 mg/Kg 1ND Aroclor 1268 10/16/2019 01:41 PM0.083 mg/Kg 1ND PCBs, Total 10/16/2019 01:41 PMmg/Kg 1ND Surr: Decachlorobiphenyl 10/16/2019 01:41 PM40-140 %REC 161.1 Surr: Tetrachloro-m-xylene 10/16/2019 01:41 PM45-124 %REC 172.1

Analytical Results Page 1 of 6

Note: See Qualifiers page for a list of qualifiers and their definitions.

Sample ID: AA160-B164-PCB-01B Collection Date: 10/2/2019 10:00 AM Matrix: SOLID

Analyses Result Qual Units Date Analyzed Report Limit

Client: Global Consulting, Inc.

Work Order: 19100777

Dilution Factor

Lab ID: 19100777-02

ALS Group, USA Date: 22-Oct-19

PCBS SW8082 Analyst: KBPrep: SW3540C 10/16/19 15:14

Aroclor 1016 10/21/2019 01:43 PM0.37 mg/Kg 1ND Aroclor 1221 10/21/2019 01:43 PM0.37 mg/Kg 1ND Aroclor 1232 10/21/2019 01:43 PM0.37 mg/Kg 1ND Aroclor 1242 10/21/2019 01:43 PM0.37 mg/Kg 1ND Aroclor 1248 10/21/2019 01:43 PM0.37 mg/Kg 1ND Aroclor 1254 10/21/2019 01:43 PM0.37 mg/Kg 1ND Aroclor 1260 10/21/2019 01:43 PM0.37 mg/Kg 1ND Aroclor 1262 10/21/2019 01:43 PM0.37 mg/Kg 1ND Aroclor 1268 10/21/2019 01:43 PM0.37 mg/Kg 1ND PCBs, Total 10/21/2019 01:43 PMmg/Kg 1ND Surr: Decachlorobiphenyl 10/21/2019 01:43 PM40-140 %REC 166.1 Surr: Tetrachloro-m-xylene 10/21/2019 01:43 PM45-124 %REC 172.1

Analytical Results Page 2 of 6

Sample ID: AA160-B164-PCB-01C Collection Date: 10/2/2019 10:00 AM Matrix: SOLID

Analyses Result Qual Units Date Analyzed Report Limit

Client: Global Consulting, Inc.

Work Order: 19100777

Dilution Factor

Lab ID: 19100777-03

ALS Group, USA Date: 22-Oct-19

PCBS SW8082 Analyst: KBPrep: SW3540C 10/16/19 15:14

Aroclor 1016 10/21/2019 01:58 PM0.29 mg/Kg 1ND Aroclor 1221 10/21/2019 01:58 PM0.29 mg/Kg 1ND Aroclor 1232 10/21/2019 01:58 PM0.29 mg/Kg 1ND Aroclor 1242 10/21/2019 01:58 PM0.29 mg/Kg 1ND Aroclor 1248 10/21/2019 01:58 PM0.29 mg/Kg 1ND Aroclor 1254 10/21/2019 01:58 PM0.29 mg/Kg 1ND Aroclor 1260 10/21/2019 01:58 PM0.29 mg/Kg 1ND Aroclor 1262 10/21/2019 01:58 PM0.29 mg/Kg 1ND Aroclor 1268 10/21/2019 01:58 PM0.29 mg/Kg 1ND PCBs, Total 10/21/2019 01:58 PMmg/Kg 1ND Surr: Decachlorobiphenyl S 10/21/2019 01:58 PM40-140 %REC 112.0 Surr: Tetrachloro-m-xylene S 10/21/2019 01:58 PM45-124 %REC 118.0

Analytical Results Page 3 of 6

Sample ID: AA160-B164-PCB-02A Collection Date: 10/2/2019 10:00 AM Matrix: SOLID

Analyses Result Qual Units Date Analyzed Report Limit

Client: Global Consulting, Inc.

Work Order: 19100777

Dilution Factor

Lab ID: 19100777-04

ALS Group, USA Date: 22-Oct-19

PCBS SW8082 Analyst: KBPrep: SW3540C 10/16/19 15:14

Aroclor 1016 10/21/2019 02:13 PM0.46 mg/Kg 1ND Aroclor 1221 10/21/2019 02:13 PM0.46 mg/Kg 1ND Aroclor 1232 10/21/2019 02:13 PM0.46 mg/Kg 1ND Aroclor 1242 10/21/2019 02:13 PM0.46 mg/Kg 1ND Aroclor 1248 10/21/2019 02:13 PM0.46 mg/Kg 1ND Aroclor 1254 10/21/2019 02:13 PM0.46 mg/Kg 1ND Aroclor 1260 10/21/2019 02:13 PM0.46 mg/Kg 1ND Aroclor 1262 10/21/2019 02:13 PM0.46 mg/Kg 1ND Aroclor 1268 10/21/2019 02:13 PM0.46 mg/Kg 1ND PCBs, Total 10/21/2019 02:13 PMmg/Kg 1ND Surr: Decachlorobiphenyl 10/21/2019 02:13 PM40-140 %REC 178.1 Surr: Tetrachloro-m-xylene 10/21/2019 02:13 PM45-124 %REC 183.1

Analytical Results Page 4 of 6

Sample ID: AA160-B164-PCB-02B Collection Date: 10/2/2019 10:00 AM Matrix: SOLID

Analyses Result Qual Units Date Analyzed Report Limit

Client: Global Consulting, Inc.

Work Order: 19100777

Dilution Factor

Lab ID: 19100777-05

ALS Group, USA Date: 22-Oct-19

PCBS SW8082 Analyst: KBPrep: SW3540C 10/16/19 15:14

Aroclor 1016 10/21/2019 02:28 PM0.70 mg/Kg 1ND Aroclor 1221 10/21/2019 02:28 PM0.70 mg/Kg 1ND Aroclor 1232 10/21/2019 02:28 PM0.70 mg/Kg 1ND Aroclor 1242 10/21/2019 02:28 PM0.70 mg/Kg 1ND Aroclor 1248 10/21/2019 02:28 PM0.70 mg/Kg 1ND Aroclor 1254 10/21/2019 02:28 PM0.70 mg/Kg 1ND Aroclor 1260 10/21/2019 02:28 PM0.70 mg/Kg 1ND Aroclor 1262 10/21/2019 02:28 PM0.70 mg/Kg 1ND Aroclor 1268 10/21/2019 02:28 PM0.70 mg/Kg 1ND PCBs, Total 10/21/2019 02:28 PMmg/Kg 1ND Surr: Decachlorobiphenyl 10/21/2019 02:28 PM40-140 %REC 186.1 Surr: Tetrachloro-m-xylene 10/21/2019 02:28 PM45-124 %REC 191.1

Analytical Results Page 5 of 6

Sample ID: AA160-B164-PCB-02C Collection Date: 10/2/2019 10:00 AM Matrix: SOLID

Analyses Result Qual Units Date Analyzed Report Limit

Client: Global Consulting, Inc.

Work Order: 19100777

Dilution Factor

Lab ID: 19100777-06

ALS Group, USA Date: 22-Oct-19

PCBS SW8082 Analyst: KBPrep: SW3540C 10/16/19 15:14

Aroclor 1016 10/21/2019 02:43 PM0.68 mg/Kg 1ND Aroclor 1221 10/21/2019 02:43 PM0.68 mg/Kg 1ND Aroclor 1232 10/21/2019 02:43 PM0.68 mg/Kg 1ND Aroclor 1242 10/21/2019 02:43 PM0.68 mg/Kg 1ND Aroclor 1248 10/21/2019 02:43 PM0.68 mg/Kg 1ND Aroclor 1254 10/21/2019 02:43 PM0.68 mg/Kg 1ND Aroclor 1260 10/21/2019 02:43 PM0.68 mg/Kg 1ND Aroclor 1262 10/21/2019 02:43 PM0.68 mg/Kg 1ND Aroclor 1268 10/21/2019 02:43 PM0.68 mg/Kg 1ND PCBs, Total 10/21/2019 02:43 PMmg/Kg 1ND Surr: Decachlorobiphenyl 10/21/2019 02:43 PM40-140 %REC 180.1 Surr: Tetrachloro-m-xylene 10/21/2019 02:43 PM45-124 %REC 186.1

Analytical Results Page 6 of 6

Client: Global Consulting, Inc.

Work Order: 19100777

QC BATCH REPORT

Batch ID: 143766 Instrument ID GC14 Method: SW8082

Qual

RPD

Limit

Analysis Date: 10/16/2019 09:42 A

Prep Date: 10/10/2019

Analyte Result %REC %RPD

Units: μg/Kg

PQL

Client ID: SeqNo: 5992012

MBLK

Run ID: GC14_191015A

SPK Val SPK Ref

Value RPD Ref

Value Control

Limit

DF: 1

Sample ID: PBLKS1-143766-143766

Aroclor 1016 83ND Aroclor 1221 83ND Aroclor 1232 83ND Aroclor 1242 83ND Aroclor 1248 83ND Aroclor 1254 83ND Aroclor 1260 83ND Aroclor 1262 83ND Aroclor 1268 83ND PCBs, Total 0ND

0033.3 Surr: Decachlorobiphenyl 124 40-140041.33

S0033.3 Surr: Tetrachloro-m-xylene 134 45-124044.67

Qual

RPD

Limit

Analysis Date: 10/16/2019 09:58 A

Prep Date: 10/10/2019

Analyte Result %REC %RPD

Units: μg/Kg

PQL

Client ID: SeqNo: 5992013

LCS

Run ID: GC14_191015A

SPK Val SPK Ref

Value RPD Ref

Value Control

Limit

DF: 1

Sample ID: PLCSS1-143766-143766

001666Aroclor 1016 88.8 50-130831480 001666Aroclor 1260 80.5 50-130831341

0033.3 Surr: Decachlorobiphenyl 135 40-140045

S0033.3 Surr: Tetrachloro-m-xylene 147 45-124049

Qual

RPD

Limit

Analysis Date: 10/16/2019 10:12 A

Prep Date: 10/10/2019

Analyte Result %REC %RPD

Units: μg/Kg

PQL

Client ID: SeqNo: 5992014

LCSD

Run ID: GC14_191015A

SPK Val SPK Ref

Value RPD Ref

Value Control

Limit

DF: 1

Sample ID: PLCSDS1-143766-143766

148001666Aroclor 1016 76.8 50-130 083 14.51279 134101666Aroclor 1260 69.6 50-130 083 14.41160

45033.3 Surr: Decachlorobiphenyl 116 40-140 00 15.138.67

S49033.3 Surr: Tetrachloro-m-xylene 131 45-1240 11.543.67

The following samples were analyzed in this batch: 19100777- 01A

QC Page: 1 of 2 Note: See Qualifiers Page for a list of Qualifiers and their explanation.

Client: Global Consulting, Inc.

Work Order: 19100777

QC BATCH REPORT

Batch ID: 144028 Instrument ID GC14 Method: SW8082

Qual

RPD

Limit

Analysis Date: 10/16/2019 04:52 P

Prep Date: 10/16/2019

Analyte Result %REC %RPD

Units: μg/Kg

PQL

Client ID: SeqNo: 5993178

MBLK

Run ID: GC14_191015A

SPK Val SPK Ref

Value RPD Ref

Value Control

Limit

DF: 1

Sample ID: PBLKS1-144028-144028

Aroclor 1016 83ND Aroclor 1221 83ND Aroclor 1232 83ND Aroclor 1242 83ND Aroclor 1248 83ND Aroclor 1254 83ND Aroclor 1260 83ND Aroclor 1262 83ND Aroclor 1268 83ND PCBs, Total 0ND

0033.3 Surr: Decachlorobiphenyl 84.1 40-140028

0033.3 Surr: Tetrachloro-m-xylene 87.1 45-124029

Qual

RPD

Limit

Analysis Date: 10/16/2019 05:07 P

Prep Date: 10/16/2019

Analyte Result %REC %RPD

Units: μg/Kg

PQL

Client ID: SeqNo: 5993179

LCS

Run ID: GC14_191015A

SPK Val SPK Ref

Value RPD Ref

Value Control

Limit

DF: 1

Sample ID: PLCSS1-144028-144028

00833Aroclor 1016 118 50-13083983.7 00833Aroclor 1260 112 50-13083934.3

0033.3 Surr: Decachlorobiphenyl 86.1 40-140028.67

0033.3 Surr: Tetrachloro-m-xylene 87.1 45-124029

Qual

RPD

Limit

Analysis Date: 10/16/2019 05:22 P

Prep Date: 10/16/2019

Analyte Result %REC %RPD

Units: μg/Kg

PQL

Client ID: SeqNo: 5993180

LCSD

Run ID: GC14_191015A

SPK Val SPK Ref

Value RPD Ref

Value Control

Limit

DF: 1

Sample ID: PLCSDS1-144028-144028

983.70833Aroclor 1016 121 50-130 083 2.511009 934.30833Aroclor 1260 122 50-130 083 8.61018

28.67033.3 Surr: Decachlorobiphenyl 87.1 40-140 00 1.1629

29033.3 Surr: Tetrachloro-m-xylene 94.1 45-1240 7.7331.33

The following samples were analyzed in this batch: 19100777- 02A

19100777- 03A

19100777- 04A

19100777- 05A

19100777- 06A

QC Page: 2 of 2 Note: See Qualifiers Page for a list of Qualifiers and their explanation.

ALS Group, USA

Sample Receipt Checklist

Client Name: GLOBALCONSULTING

Work Order: 19100777

Date/Time Received: 09-Oct-19 10:00

Received by: MJG

Checklist completed by eSignature Date

Reviewed by:

DateeSignature

Matrices: Solid Carrier name: FedEx

Shipping container/cooler in good condition? Yes No Not Present

Custody seals intact on shipping container/cooler? Yes No Not Present

Custody seals intact on sample bottles? Yes No Not Present

Chain of custody present? Yes No

Chain of custody signed when relinquished and received? Yes No

Chain of custody agrees with sample labels? Yes No

Samples in proper container/bottle? Yes No

Sample containers intact? Yes No

Sufficient sample volume for indicated test? Yes No

All samples received within holding time? Yes No

Container/Temp Blank temperature in compliance? Yes No

Yes No No VOA vials submittedWater - VOA vials have zero headspace?

Water - pH acceptable upon receipt? Yes No N/A

Temperature(s)/Thermometer(s): 4.0/4.0C

Login Notes:

SR2

Cooler(s)/Kit(s):

09-Oct-19 10-Oct-19 Matthew Gaylord Chad Whelton pH adjusted? Yes No N/A pH adjusted by:

Date/Time sample(s) sent to storage: 10/9/2019 4:41:12 PM

Sample(s) received on…