N40085-22-R-2691_P-828S_1.PDF

H A Z A R D O U S M A T E R I A L S U R V E Y

R E P O R T

EDI – EXCEL L E NCE , DE DICATIO N & IN NO VATI O N

(312) 345-1400 • www.envdesigni.com

LIMITED ASBESTOS AND PAINT SURVEY

AT

GREAT LAKES NAVAL TRAINING CENTER

P-828 SMART ENERGY PROJECT

GREAT LAKES, ILLINOIS

PREPARED BY:

Environmental Design International inc.

33 West Monroe Street, Suite 1825 Chicago, Illinois 60656

(312) 345-1400

(312) 345-0529 (fax) www.envdesigni.com

PREPARED FOR:

Jacobs 7501 North Broadway St. Louis, Missouri 63102

EDI Project #: 1584.011.01

Date of Report: December 17, 2020

Revision 2: February 21, 2022

(312) 345-1400 • www.envdesigni.com

33 W. Monroe St., Suite 1825 Chicago, Illinois 60656 phone: 312.345.1400 fax: 312.345.0529 www.envdesigni.com

December 17, 2020

Revision 1, April 13, 2021 Revision 2, February 21, 2022

Mr. Jeff Farah, Sr. Project Manager Jacobs 7501 North Broadway St. Louis, Missouri 63102

Re: Professional Environmental Services

P-828 Smart Energy Great Lakes Naval Training Center Great Lakes, Illinois

Dear Mr. Farah:

Enclosed please find the hazardous material survey and assessment report for the above-referenced project property, prepared by Environmental Design International inc. (EDI).

EDI performed the environmental survey to identify and sample suspect asbestos-containing materials (ACM) and lead–based paint (LBP) for the P-828 Smart Energy Great Lakes Naval Training Center (GLNTC) in Great Lakes, Illinois. The survey was completed on December 1 and 2, 2020. On March 30 and 31, 2021, EDI performed the environmental survey to identify and sample suspect painted surfaces to include Cadmium (Cd) and Hexavalent Chromium (CrVI) analysis. On February 8 and 9, 2022 EDI performed the environmental survey to identify additional ACM, LBP, Cd and CrVI impacted by the project as defined by Client and is not a comprehensive survey of the complete facilities. The results of the survey are provided in this report.

Please feel free to contact Jose Aguilera at 773-559-0422 or jaguilera@envdesigni.com with any comments or questions regarding EDI’s investigation and this report.

Sincerely, Environmental Design International Inc.

Jose Aguilera Felix R. Moran, PE Project Manager Department Manager, Industrial Hygiene

Asbestos and Paint Survey P-828 Smart Energy Project

Great Lakes Naval Training Center

Revision 2

(312) 345-1400 • WWW .EN VDE SIGN I .COM

i

Table of Contents Page

1.0 Introduction

1.1 Scope of Work

2.0 Asbestos Survey

2.1 ACM Survey Methodology

2.2 Asbestos Results

2.3 Applicable Regulations

3.0 Limited Lead Based Paint Survey

3.1 Limited LBP, Cd and CrVI Survey Methodology

3.2 LBP, Cd and CrVI Survey Results

3.4 Recommendations

3.5 Applicable Regulations and Guidelines

4.0 Findings and Recommendations

4.1 Asbestos Building Survey

4.2 Paint Building Survey

5.0 Limitations

6.0 Definitions

Appendices

Appendix A: Asbestos Laboratory Results, Laboratory Certification and Chain-of-Custody Appendix B: Paint Survey Laboratory Results, Laboratory Certification and Chain-of-Custody Appendix C: EDI Employee Certifications Appendix D: Photographic Log Appendix E: Drawings of Asbestos Sample Locations Appendix F: Drawing of Paint Chip Sample Locations

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Executive Summary

Environmental Design International inc. (EDI) was retained by Jacobs to provide an ACM and LBP survey of the Great Lakes Naval Training Center located in Great Lakes, Illinois.

The survey was performed on December 1 and 2, 2020 by Mr. Jose Aguilera, Illinois Department of Public Health (IDPH) license #100-10088, IDPH lead risk assessor license #009320 with assistance from Mr. Anthony Spalla, a sampling technician. On March 30 and 31, 2021, Mr. Jose Aguilera performed the environmental survey to identify, and sample suspect painted surfaces to include Cadmium (Cd) and Hexavalent Chromium (CrVI) analysis. On February 8 and 9, 2022 Mr. Jose Aguilera performed the environmental survey to identify additional ACM, LBP, Cd and CrVI impacted by the project. The surveys were conducted for the P-828 Smart Energy Project.

EDI performed a visual survey of building materials, and collected representative samples of homogeneous suspect ACM, in accordance with EPA requirements, guidelines and standard industry practices. The samples were submitted to a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory for bulk analysis.

Based on the bulk sample laboratory analysis, the following suspect materials were reported to contain asbestos:

Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

3114A M-1-2 Mastic Fair Interior Wall 5.2-5.5%

Chrysotile

3114A M-1-3 Mastic Fair Interior Wall 5.2-5.5%

Chrysotile

621 CT-621-1-1

2’x2’ Ceiling

Tile Fair Room 109

1-5% Chrysotile

621 CT-621-1-2

2’x2’ Ceiling

Tile Fair Room 107

1-5% Chrysotile

621 CT-621-1-3

2’x2’ Ceiling

Tile Fair Room 125

1-5% Chrysotile

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Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

621 FT-621-1-1

12”x12” Multilayer Floor Tile and Associated

Mastic

Fair Room 109 1-10%

Every attempt was made to thoroughly evaluate and assess the presence and condition of suspect ACM throughout the building impacted by renovation activities. Any suspect ACM identified during renovation that is not specifically listed in this report should be assumed positive until it can be thoroughly evaluated, assessed, sampled, and analyzed prior to disturbance, in accordance with applicable regulatory standards.

Paint Survey

The presence of painted surfaces was evaluated in the areas included as part of the P-828 Smart Energy project. EDI performed paint assessment and survey, including sampling of select surfaces that may be impacted by planned renovation activities to identify LBP, Cd and CrVI.

EDI utilized paint chip collection and laboratory analysis, for selected surfaces/components throughout the proposed renovation area. Nine (9) Representative sampling areas (RSAs), consisting of similar components with similar paint color and application based on the age and era of construction, were defined, and sampled for LBP. Six (6) RSAs were defined and sampled for Cd and CrVI. The limited paint survey was focused to determine surfaces/components that may require special handling during renovation.

Based on the laboratory results analysis, one (1) of the RSAs tested surfaces were reported to contain lead above the EPA/HUD regulatory limit of 0.5% or 5000 parts per million (ppm) by weight. Paint containing greater than 0.0%, but less than 0.5% and 0-2 ppm are considered lead containing paint and are regulated by OSHA. One of the samples collected was reported as lead containing paint.

The following table lists the suspect LBP materials identified during the survey.

Sample Number

Component Color Substrate Location Results (% By

Weight)

1912 PC-1

Wall White Cinder

Block Exterior

Wall <0.0079

1912 PC-2 Wall Teal Cinder Block

Interior Wall

<0.0085

68 PC-3 Wall Teal Drywall Tech Room

<0.0088

2018 PC-4 Wall Beige Cinder Block

Interior Wall

<0.0081

Great Lakes Naval Training Center iv

Building Number

Sample Number

Component Color Substrate Location Results (% By

Weight)

1506 PC-5 Wall Beige Cinder Block

Interior

<0.0054

Sample Number

Component Color Substrate Location Results (ppm By Weight)

7260 Pb-7260-1 Wall White Drywall Interior

Wall 91*

7111 Pb-7111-1 Wall White Cinder Block

Interior Wall < 84*

7101 Pb-7101 I-Beam White Fire

Proofing IT Room

< 100*

26 Pb-26 Wall Blue Drywall Basement

Mechanical Room 006

17000**

*Laboratory reports are in mg/Kg which is the same as PPM. Bolded sample results are considered lead containing.

**Sample reported above EPA/HUD regulatory level.

Based on the laboratory results analysis, none of the tested surfaces were reported to contain cadmium or chromium above the regulatory limit of 0.1% by weight. Paint containing greater than 0.0%, but less than 0.1% are considered cadmium or chromium containing paint and are regulated by OSHA.

The following table lists the suspect Cd containing materials identified during the survey.

Sample Number

Component Color Substrate Location Results (% By

Weight)

26 CD-26-1 Wall Blue Drywall Basement

Mechanical Room 006

0.0027

68 CD-68-1 Wall Teal Drywall Tech Room ND 7260 CD-7260-1 Wall White Drywall Interior Wall ND

1506 CD-1506-1 Wall Beige Cinder Block

Interior wall

ND

7111 CD-7111-1 Wall White Cinder Block

Interior Wall

ND

7101 CD-7101-1 I-Beam White Fire

Proofing IT Room

ND

*Laboratory reports are in mg/Kg converted to percent by weight. Bolded sample results are considered Cadmium containing.

ND - Not Detected at the Reporting Limit.

Great Lakes Naval Training Center v

The following table lists the suspect CrVI containing materials identified during the survey.

Sample Number

Component Color Substrate Location Results (% By

Weight)

26 CR-26-1 Wall Blue Drywall Basement

Mechanical Room 006

0.0017

68 CR-68-1 Wall Teal Drywall Tech Room ND 7260 CR-7260-1 Wall White Drywall Interior Wall ND

1506 CR-1506-1 Wall Beige Cinder Block

Interior wall

ND

7111 CR-7111-1 Wall White Cinder Block

Interior Wall

ND

7101 CR-7101 I-Beam White Fire

Proofing IT Room

ND

*Laboratory reports are in mg/Kg converted to percent by weight. Bolded sample results are considered Hexavalent Chromium VI containing.

Great Lakes Naval Training Center

1.0 Introduction

Environmental Design International inc. (EDI) was retained by Jacobs to provide an ACM and LBP survey of the Great Lakes Naval Training Center located in Great Lakes, Illinois. The survey was performed on December 1 and 2, 2020 by Mr. Jose Aguilera, Illinois Department of Public Health (IDPH) license #100-10088, IDPH lead risk assessor license #009320 with assistance from Mr. Anthony Spalla, a sampling technician. On March 30 and 31, 2021, Mr.

Jose Aguilera performed the environmental survey to identify and sample suspect painted surfaces to include Cadmium (Cd) and Hexavalent Chromium (CrVI) analysis. On February 8 and 9, 2022 Mr. Jose Aguilera performed the environmental survey to identify additional ACM, LBP, Cd and CrVI impacted by the project. The surveys were conducted for the P-828 Smart Energy Project.

1.1 Scope of Work

EDI completed a hazardous material survey of the designated rooms in the buildings to identify suspect asbestos-containing materials (ACM) and painted surfaces for LBP, Cd and CrVI.

Buildings with existing usable penetrations did not require sampling.

ACM Survey

EDI performed a building visual survey to identify suspect ACM. The ACM survey services were performed in accordance with the requirements established in the National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations (40 CFR Part 61, subpart M). All bulk samples collected as part of an asbestos survey were collected by IDPH-licensed asbestos inspector and analyzed by National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory, see Appendix A - Asbestos Laboratory Results, Laboratory Certification and Chain-of-Custody.

Visual inspection and physical assessment of accessible areas.

Collection and analysis of bulk materials samples from representative sampling areas.

Preparation of a final report that includes a suspect ACM sample log and employee licenses and certifications.

LBP, Cadmium and Chromium Survey

EDI performed a limited LBP survey, including sampling of select surfaces that may be impacted by project activities. EDI collected paint chip samples of representative suspect painted components. EDI’s LBP survey was consistent with the U.S. Department of Housing and Urban Development (HUD) guidelines. The Cadmium and Chromium survey was completed utilizing the same procedures that are consistent with the U.S. Department of Housing and Urban Development (HUD) guidelines. Representative sampling areas (RSAs), consisting of similar components with similar paint color and application, were defined and tested. The survey included the following activities:

Great Lakes Naval Training Center

Visual inspection and physical assessment of accessible areas.

Collection and analysis of paint chip samples from representative sampling areas.

Preparation of a final report that includes a lead sample log and employee licenses and certifications.

All paint chip samples collected as part of a limited lead-based paint survey were collected by IDPH-licensed lead risk assessor inspector and analyzed by National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory; see Appendix B Lead Paint Chip Laboratory Results, Laboratory Certification and Chain-of-Custody. Samples were analyzed following EPA Method SW-846, 3050B, 7000B, SW6020A SW7196A and SW3060A (flame atomic absorption spectroscopy). Refer to Appendix B for paint results.

Great Lakes Naval Training Center

2.0 Asbestos Survey

2.1 ACM Survey Methodology

EDI staff performed a visual inspection to identify suspect ACM in accessible areas of the survey area. Ninety-Four (94) bulk samples of suspect ACM were collected, representing nineteen (19) different homogeneous sampling areas (HSAs). Some samples consist of layered materials; each layer is analyzed separately if present. HSAs are areas containing materials that are similar in color, texture, and general appearance, and which appear to have been uniformly installed during the same time in the same building. The ACM survey was performed in accordance with the United States Environmental Protection Agency (USEPA) Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing Materials (USEPA 560/5085-030a, October 1985). Employee licenses and certifications are presented in Appendix C.

Bulk samples of suspect ACM were collected using wet sampling methods with a coring device or a sample cutter, as appropriate, to collect a cross-section of the suspect ACM. Sample collection tools were decontaminated after each sample by washing with soap and water and dried by disposable towels to avoid cross contamination.

Bulk ACM samples were placed into clean unused bags marked with a unique sample identification number. For each sample, the identification number, brief material description, location, condition, and estimated quantity of suspect ACM were recorded on a bulk sample log sheet.

Chain-of-Custody (COC) procedures were followed for the ACM survey. These procedures provide a written tracking mechanism that lists the person responsible for the sample from collection to delivery to the laboratory. Sample identification numbers, sample locations, and material descriptions were recorded on the chain-of-custody forms.

Samples were analyzed by International Asbestos Testing Laboratories of Mt. Laurel, New Jersey (IATL), and STAT Analysis Corporation both a National Voluntary Laboratory Accreditation Program (NVLAP) accredited asbestos laboratories. Laboratory accreditations are provided in Appendix A. Samples were analyzed by polarized light microscopy (PLM) supplemented with dispersion staining. PLM is an USEPA-approved method that utilizes a light microscope equipped with polarized filters (USEPA Method 600/R-93/116).

Great Lakes Naval Training Center

2.2 Asbestos Results

The following buildings did not have suspect asbestos containing materials. In addition, buildings with existing usable penetrations did not require sampling.

Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

R20 N/A Metal Structure

Fair Support Shed Interior and Exterior Walls

Non-Suspect

F10 N/A Metal Structure

Fair Support Shed Interior and Exterior Walls

Non-Suspect

A450 N/A Metal Structure

Fair Support Shed Interior and Exterior Walls

Non-Suspect

The following suspect asbestos containing materials were identified and sampled:

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

DW-26-1-1 Drywall Fair Basement Mechanical Room 006

ND

DW-26-1-2 Drywall Fair

Mechanical Room 006

DW-26-1-3 Drywall Fair

Mechanical Room 006

DW-26-2-1 Drywall Fair

IT Room

DW-26-2-2 Drywall Fair

IT Room

DW-26-2-3 Drywall Fair

IT Room

Great Lakes Naval Training Center

Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

621 CT-621-1-1

2’x2’ Ceiling

Tile Fair Room 109

1-5% Chrysotile

621 CT-621-1-2

2’x2’ Ceiling

Tile Fair Room 107

1-5% Chrysotile

621 CT-621-1-3

2’x2’ Ceiling

Tile Fair Room 125

1-5% Chrysotile

621 FT-621--1-1

12”x12” Multilayer

Floor Tile and Associated

Mastic

Fair Room 109 1-10%

DW-1-1 Drywall Fair Tech Room ND

DW-1-2 Drywall Fair Tech Room ND

DW-1-3 Drywall Fair Tech Room ND

MRTR-1-1 Mortar Fair Exterior

Wall

ND

68 MRTR-1-1 Mortar Fair Exterior

Wall

ND

68 MRTR-1-1 Mortar Fair Exterior

Wall

ND

68 CT-68-1-1

2’x2’ Ceiling

Tile Fair

Tech/Server Room

ND

68 CT-68-1-2

2’x2’ Ceiling

Tile Fair

Open Office Area

Great Lakes Naval Training Center

Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

68 CT-68-1-2

2’x2’ Ceiling

Tile Fair

Open Office Area

ND

7811 MRTR-2-1 Mortar Fair Interior Wall ND

7811 MRTR-2-2 Mortar Fair Interior Wall ND

7811 MRTR-2-3 Mortar Fair Interior Wall ND

7811 MRTR-3-1 Mortar Fair Exterior

Wall

ND

7811 MRTR-3-2 Mortar Fair Exterior

Wall

ND

7811 MRTR-3-3 Mortar Fair Exterior

Wall

ND

2018 MRTR-4-1 Mortar Fair Exterior

Wall

ND

2018 MRTR-4-2 Mortar Fair Exterior

Wall

ND

2018 MRTR-4-3 Mortar Fair Exterior

Wall

ND

2018 MRTR-5-1 Mortar Fair Interior Wall ND

2018 MRTR-5-2 Mortar Fair Interior Wall ND

2018 MRTR-5-3 Mortar Fair Interior Wall ND

Great Lakes Naval Training Center

Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

3114A M-1-1 Mastic Fair Interior Wall ND

3114A M-1-2 Mastic Fair Interior Wall 5.2-5.5%

Chrysotile

3114A M-1-3 Mastic Fair Interior Wall 5.2-5.5%

Chrysotile

3114A DW-2-1

Drywall System

Fair Interior Wall ND

3114A DW-2-1

Drywall System

Fair Interior Wall ND

3114A DW-2-1

Drywall System

Fair Interior Wall ND

3114A MRTR-6-1 Mortar Fair Exterior

Wall

ND

3114A MRTR-6-2 Mortar Fair Exterior

Wall

ND

3114A MRTR-6-3 Mortar Fair Exterior

Wall

ND

1912 MRTR-7-1 Mortar Fair

Exterior Wall same cinder block as Interior

Wall

ND

1912 MRTR-7-2 Mortar Fair

Exterior Wall same cinder block as Interior

Great Lakes Naval Training Center

Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

1912 MRTR-7-3 Mortar Fair

Exterior Wall same cinder block as Interior

Wall

ND

3504 MRTR-8-1 Mortar Fair Exterior

Wall

ND

3504 MRTR-8-2 Mortar Fair Exterior

Wall

ND

3504 MRTR-8-3 Mortar Fair Exterior

Wall

ND

1506 MRTR-9-1 Mortar Fair Exterior

Wall

ND

1506 MRTR-9-2 Mortar Fair Exterior

Wall

ND

1506 MRTR-9-3 Mortar Fair Exterior

Wall

ND

1506 MRTR-10-1 Mortar Fair Interior Wall ND

1506 MRTR-10-2 Mortar Fair Interior Wall ND

1506 MRTR-10-3 Mortar Fair Interior Wall ND

1506 CT-1506-1-1

2’x2’ Ceiling

Tile Fair Break Room ND

1506 CT-1506-1-2

2’x2’ Ceiling

Tile Fair

West Vestibule

Great Lakes Naval Training Center

Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

1506 CT-1506-1-3

2’x2’ Ceiling

Tile Fair Hallway ND

1506 CT-1506-2-1

2’x4’ Ceiling

Tile Fair

Receiving Room 129

ND

1506 CT-1506-2-2

2’x4’ Ceiling

Tile Fair

Receiving Room 129

ND

1506 CT-1506-2-3

2’x4’ Ceiling

Tile Fair

Server Room 118

ND

190 MRTR-11-1 Mortar Fair Exterior

Wall

ND

190 MRTR-11-2 Mortar Fair Exterior

Wall

ND

190 MRTR-11-3 Mortar Fair Exterior

Wall

ND

190 MB-1-1 Black Sealant Fair Exterior

Wall

ND

190 MB-1-1 Black Sealant Fair Exterior

Wall

ND

190 MB-1-1 Black Sealant Fair Exterior

Wall

ND

190 MRTR-2-1 Mortar Fair Interior Wall ND

190 MRTR-2-2 Mortar Fair Interior Wall ND

190 MRTR-2-3 Mortar Fair Interior Wall ND

Great Lakes Naval Training Center

Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

190 CT-190-1-1

2’x2’ Ceiling

Tile Fair

By Room

ND

190 CT-190-1-2

2’x2’ Ceiling

Tile Fair

By Room

ND

190 CT-190-1-3

2’x2’ Ceiling

Tile Fair

By Room

ND

190 CT-190-2-1

2’x4’ Ceiling

Tile Fair

223A Classrooms

ND

190 CT-190-2-2

2’x4’ Ceiling

Tile Fair

223A Classrooms

ND

190 CT-190-2-3

2’x4’ Ceiling

Tile Fair

223A Classrooms

ND

7101 MRTR-7101-1 Mortar Fair Interior Wall ND

7101 MRTR-7101-2 Mortar Fair Interior Wall ND

7101 MRTR-7101-3 Mortar Fair Interior Wall ND

7101 SOFP-1-1

Sprayed-on Fire Proofing

Fair I-Beam ND

7101 SOFP-1-2

Sprayed-on Fire Proofing

Fair I-Beam ND

7101 SOFP-1-3

Sprayed-on Fire Proofing

Fair I-Beam ND

7260 SOFP-7260-1-1

Sprayed-on Fire Proofing

Fair Basement Mechanical

Room

Great Lakes Naval Training Center

Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

7260 SOFP-7260-1-2

Sprayed-on Fire Proofing

Fair By Room

ND

7260 SOFP-7260-1-3

Sprayed-on Fire Proofing

Fair Hallway 1st

Floor

ND

7260 DW-7260-1-1 Drywall Fair Interior Wall ND

7260 DW-7260-1-2 Drywall Fair Interior Wall ND

7260 DW-7260-1-3 Drywall Fair Interior Wall ND

7111 MRTR-7111-1 Mortar Fair Interior Wall ND

7111 MRTR-7111-2 Mortar Fair Interior Wall ND

7111 MRTR-7111-3 Mortar Fair Interior Wall ND

236 MRTR-236-1 Mortar Fair Interior Wall ND

236 MRTR-236-2 Mortar Fair Interior Wall ND

236 MRTR-236-3 Mortar Fair Interior Wall ND

236 CT-236-1-1

2’x2’ Ceiling

Tile Fair Room 160 ND

236 CT-236-1-2

2’x2’ Ceiling

Tile Fair Room 150 ND

Great Lakes Naval Training Center

Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

236 CT-236-1-3

2’x2’ Ceiling

Tile Fair

North Vestibule

ND= Non-Detect

According to the AHERA Model Accreditation Plan, non-suspect material such as fiberglass, foam rubber, and plastics do not warrant sampling. Two of the suspect materials collected were reported as ACM. In addition, buildings with existing usable penetrations did not require sampling.

2.3 Applicable Regulations

EPA's National Emission Standard for Hazardous Air Pollutants (NESHAP) (40 CFR 61, Subpart M) defines asbestos-containing material (ACM) as any material with analysis reported as greater than 1% asbestos. Additionally, EPA NESHAP categorizes asbestos-containing thermal system insulation (TSI) and sprayed-on or troweled-on asbestos as regulated ACM (RACM). Miscellaneous materials (floor tile and floor tile mastic) are classified as Category I Non-Friable Asbestos; and transite material is classified as Category II Non-Friable Asbestos unless the material is made friable during demolition. Friable ACM is material that can be crumbled, pulverized, or reduced to a powder by hand. NESHAP requires at least ten working days’ notification prior to any renovation or demolition activity that will disturb greater than 160 square feet or 260 linear feet of ACM materials. ACM removed during abatement must be disposed of at a landfill approved by the EPA to receive asbestos wastes.

The Occupational Safety and Health Administration (OSHA) recognizes occupational exposure potential to any material that contains any quantity of asbestos that will be impacted during construction. OSHA’s Construction Industry Standard (29 CFR 1926.1101) categorizes the removal of asbestos containing materials by “class” of material. Specific requirements for the removal of OSHA classified materials include, but are not limited to, regulated work areas, air monitoring, engineering controls, work practices, personal protective equipment, notification, and training.

The U.S. Department of Transportation (DOT) requires special procedures for packaging, labeling, and transportation of asbestos wastes to disposal facilities. Other regulations may apply depending upon the contractor’s means and methods.

Great Lakes Naval Training Center

3.0 Limited Lead Based Paint Survey

3.1 Limited LBP, Cd and CrVI Survey Methodology

EDI staff performed a limited visual survey of the building to identify representative painted surfaces for LBP testing. Employee certifications are presented in Appendix C. The limited LBP, Cd and CrVI survey was conducted following a modified and limited sampling plan based on the U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (1995 and 1997 Revision). The limited LBP survey was conducted by a certified and licensed lead inspector/risk assessor. Paint chip collection was used for this survey.

Samples were placed into clean unused sample containers marked with a unique sample identification number. For each sample, the identification number, brief material description, location, condition, and estimated quantity of representative paint was recorded on a bulk sample log sheet. Chain-of-Custody (COC) procedures were followed for the lead survey.

These procedures provide a written tracking mechanism that lists the person responsible for the sample from collection to delivery to the laboratory. Sample identification numbers, sample locations, and material descriptions were recorded on the chain-of-custody forms. COC forms are provided in Appendix B.

EDI submitted paint chip samples to International Asbestos Testing Laboratories (IATL), in Mt Laurel, New Jersey. IATL and STAT Analysis Corporation are accredited through the Environmental Lead Laboratory Accreditation Program (ELLAP). Samples were analyzed following EPA Method SW-846, 3050B, 7000B, SW6020A SW7196A and SW3060A (flame atomic absorption spectroscopy). Refer to Appendix B for paint results.

3.2 LBP, Cd and CrVI Survey Results

The following buildings did not have suspect LBP, Cd and CrVI surfaces. In addition, buildings with existing usable penetrations did not require sampling.

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

R20 N/A

Non- Painted Metal

Structure

Fair Support Shed Interior and

Exterior Walls Non-Suspect

F10 N/A

Non- Painted Metal

Structure

Fair Support Shed Interior and

Exterior Walls Non-Suspect

A450 N/A

Non- Painted Metal

Structure

Fair Support Shed Interior and

Exterior Walls Non-Suspect

Great Lakes Naval Training Center

Building Number

Sample Number

Material Description

Material Condition

Material Location

Laboratory Results

190 N/A

Non- Painted Cinder Block

Fair Interior Walls Non-Suspect

7811 N/A

Non- Painted Cinder Block

Fair Interior Walls Non-Suspect

The following table lists the suspect LBP materials identified during the survey.

Sample Number

Component Color Substrate Location Results (% By

Weight)

1912 PC-1

Wall White Cinder

Block Exterior

Wall <0.0079

1912 PC-2 Wall Teal Cinder Block

Interior Wall

<0.0085

68 PC-3 Wall Teal Drywall Tech Room

<0.0088

2018 PC-4 Wall Beige Cinder Block

Interior Wall

<0.0081

1506 PC-5 Wall Beige Cinder Block

Interior

<0.0054

Sample Number

Component Color Substrate Location Results (ppm By Weight)

7260 Pb-7260-1 Wall White Drywall Interior

Wall 91*

7111 Pb-7111-1 Wall White Cinder Block

Interior Wall < 84*

7101 Pb-7101 I-Beam White Fire

Proofing IT Room

< 100*

26 Pb-26-1 Wall Blue Drywall Basement

Mechanical Room 006

17000**

*Laboratory reports are in mg/Kg which is the same as PPM. Bolded sample results are considered lead containing.

**Sample reported above EPA/HUD regulatory level.

Based on the laboratory results analysis, one (1) of the RSAs tested surfaces were reported to contain lead above the EPA/HUD regulatory limit of 0.5% or 5000 parts per million (ppm) by weight. Paint containing greater than 0.0%, but less than 0.5% and 0-2 ppm are considered lead

Great Lakes Naval Training Center containing paint and are regulated by OSHA. One of the samples collected was reported as lead containing paint.

The following table lists the suspect Cd containing materials identified during the survey.

Sample Number

Component Color Substrate Location Results (% By

Weight)

26 CD-26-1 Wall Blue Drywall Basement

Mechanical Room 006

0.0027

68 CD-68-1 Wall Teal Drywall Tech Room ND 7260 CD-7260-1 Wall White Drywall Interior Wall ND

1506 CD-1506-1 Wall Beige Cinder Block

Interior wall

ND

7111 CD-7111-1 Wall White Cinder Block

Interior Wall

ND

7101 CD-7101-1 I-Beam White Fire

Proofing IT Room

ND

*Laboratory reports are in mg/Kg converted to percent by weight. Bolded sample results are considered Cadmium containing.

The following table lists the suspect CrVI containing materials identified during the survey.

Sample Number

Component Color Substrate Location Results (% By

Weight)

26 CR-26-1 Wall Blue Drywall Basement

Mechanical Room 006

0.0017

68 CR-68-1 Wall Teal Drywall Tech Room ND 7260 CR-7260-1 Wall White Drywall Interior Wall ND

1506 CR-1506-1 Wall Beige Cinder Block

Interior wall

ND

7111 CR-7111-1 Wall White Cinder Block

Interior Wall

ND

7101 CR-7101 I-Beam White Fire

Proofing IT Room

ND

*Laboratory reports are in mg/Kg converted to percent by weight. Bolded sample results are considered Hexavalent Chromium VI containing.

Based on the laboratory results analysis, none of the tested surfaces were reported to contain cadmium or chromium above the regulatory limit of 0.1% by weight. Paint containing greater than 0.0%, but less than 0.1% are considered cadmium or chromium containing paint and are regulated by OSHA.

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3.4 Recommendations

Recommended Response Action

The following response actions would be recommended in the event LBP is discovered in the work areas:

Interim Controls – Interim controls temporarily reduce exposure to lead-based paint hazards through repairs, painting, maintenance, special cleaning, occupant protection measures, clearance, and education programs. Interim control methods require safe practices and include:

Paint stabilization – all deteriorated lead-based paint on exterior and interior surfaces must be stabilized through repairs, safe paint removal and repainting.

Treatment for friction and impact surfaces – If abraded lead-based paint is found and associated dust lead levels exceed or are presumed to exceed acceptable levels, the condition creating friction or impact with surfaces with lead-based paint such as those that rub, bind or crush must be corrected.

Treatment for chewable surfaces – If a child under age six has chewed surfaces known or presumed to contain lead-based paint, these surfaces must be enclosed or coated so they are impenetrable.

Lead-contaminated dust control – All horizontal surfaces that are rough, pitted or porous such as bare floors, stairs, window sills, and window troughs must be covered with a smooth cleanable covering or coating such as metal coil stock, plastic polyurethane or linoleum. Carpeting must be vacuumed, or rugs must be removed and vacuumed on both sides. Vacuuming must be done using HEPA vacuums or equivalent.

Lead-contaminated soil control – If bare soil is lead-contaminated, interim controls that may be used include impermanent surface coverings such as gravel, bark and sod as well as land use controls such as fencing, landscaping and warning signs.

Abatement – Abatement permanently removes or controls lead-based paint and lead-based paint hazards by removing lead-based paint and its dust, or permanently encapsulation or enclosing the lead-based pain, replacing components with lead-based paint and removing or permanently covering lead contaminated soil. Encapsulation and enclosure require ongoing maintenance to check their effectiveness.

3.5 Applicable Regulations and Guidelines

The HUD guidelines cover topics such as lead-based paint inspections/risk assessments, abatement options and methods, worker protection, occupant protection, cleanup, clearance, and waste disposal. Except for those parts pertaining exclusively to housing, the guidelines can be used as resource information and methodologies for identifying and abating lead-based paint hazards in buildings.

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Illinois Administrative Code 845 (Title 77, Chapter I, and Subchapter P, Part 845) defines lead abatement/mitigation as the remediation of a lead hazard so that the lead bearing substance does not pose an immediate health hazard to humans. A lead hazard is deemed to have been mitigated if the following conditions have been met:

The surface that is the source of lead is no longer in a condition that produces a hazardous level of leaded chips, flakes, dust or any other form of leaded substances that can be ingested or inhaled by humans; or

The leaded surface is not accessible to children, the surface coating is covered or the access to the leaded surface is otherwise prevented.

According to the Illinois Resource Conservation and Recovery Act (35 IAC 721), and IEPAs Information Statement on the Removal of Lead-Based Paint, workers handling LBP coated building materials must be protected from exposure following OSHA regulations.

USDOT and IDOT require lead-based paint waste to be properly containerized and transported by a licensed waste hauler.

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4.0 Findings and Recommendations

4.1 Asbestos Building Survey

EPA regulation establishes that material with greater than one percent asbestos is considered regulated. Based on laboratory analysis of the samples collected in accordance with the survey methodology, the following materials will need to be abated if they are disturbed during renovation and/or demolition activities:

Black Mastic on Walls Building 3114A.

Prior to renovation of the building, ACM that will be disturbed must be abated by a licensed contractor using licensed supervisors and workers, according to applicable federal, state and local regulations.

Every attempt was made to thoroughly evaluate and assess the presence and condition of suspect ACM throughout the building impacted by renovation activities. Any suspect ACM identified during renovation that is not specifically listed in this report should be assumed positive until it can be thoroughly evaluated, assessed, sampled, and analyzed prior to disturbance, in accordance with applicable regulatory standards.

4.2 Paint Building Survey

Based on the laboratory results analysis, one (1) of the RSAs tested surfaces were reported to contain lead above the EPA/HUD regulatory limit of 0.5% or 5000 parts per million (ppm) by weight. Paint containing greater than 0.0%, but less than 0.5% and 0-2 ppm are considered lead containing paint and are regulated by OSHA. One of the samples collected was reported as lead containing paint.

Based on the laboratory results analysis, none of the tested surfaces were reported to contain cadmium or chromium above the regulatory limit of 0.1% by weight. Paint containing greater than 0.0%, but less than 0.1% are considered cadmium or chromium containing paint and are regulated by OSHA.

If additional suspect coated surfaces are identified during the renovation, those materials should be assumed to be positive for LBP, Cd and CrVI until they can be assessed, sampled, and analyzed by an ELLAP accredited laboratory.

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5.0 Limitations

This report is based solely on the scope of work provided and the assumptions identified in this survey. Any new information that becomes available concerning the subject sites should be provided to EDI so that our evaluations, conclusions, and recommendations may be revised and modified accordingly. All materials tested are assumed homogeneous throughout the proposed individual, building renovation areas. EDI staff walked the site area with building representatives to identify accessible areas to be included in the survey. Every attempt was made to thoroughly evaluate and assess the presence and condition of suspect asbestos and lead containing materials. Suspect materials may exist within inaccessible areas. Any suspect material identified during renovation or demolition that is not specifically listed herein should be assumed positive until thoroughly assessed, sampled and analyzed prior to disturbance, in accordance with applicable regulatory standards.

The findings and conclusions in this report are not specific certainties; rather they are probabilities based on professional judgment concerning the significance of the data collected.

EDI claims to represent only the specific findings documented herein and does not claim knowledge of conditions beyond the scope of the survey.

The surveys were conducted in a manner consistent with that level of care and skill ordinarily exercised by members of the environmental profession under similar conditions. No other warranty or guarantee, express or implied, is included or intended in this Report or otherwise.

This report is intended for the use of the client, subject to the terms and conditions of EDI's Scope of Services and Fees for Professional Services Agreement.

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6.0 Definitions

The following definitions are intended to provide the reader with a better understanding of the terminology used in this report.

Asbestos The general name given to a number of naturally occurring hydrated mineral silicates that possess a unique crystalline structure, are incombustible in air, and are separable into fibers.

Asbestos includes the asbesti-form varieties of chrysotile (serpentine); crocidolite (riebeckite);

amosite (cummingtonite-frunertie); anthophyllite; and actinolite.

Asbestos-Containing Material Asbestos contain materials (ACM) are materials that are found to contain greater than one percent by weight asbestos content as determined by polarized light microscopy (PLM) analysis.

Accessible Areas An accessible area of the building is any area that the survey team is permitted to inspect and that can be inspected without the disassembly of complicated mechanical or rigid structural components of the building. Examples of accessible areas of the building are interior floors, walls, ceilings, areas above suspended ceilings, return air shafts (normally), mechanical piping exteriors, and equipment exteriors, etc.

Damaged material A “damaged” material contains a few water stains or less than one-tenth of insulation with missing jackets and/or crushed insulation or water stains, gouges, punctures, or mars on surface up to one-tenth of the insulation if the damage is evenly distributed or up to one-quarter if the damage is localized.

Inaccessible Areas An inaccessible area is any area where inspection access is not permitted or requires a considerable amount of mechanical or structural disassembly to inspect. Inaccessible areas normally only investigated prior to renovation or demolition activities. Examples of inaccessible areas are pipe chases behind solid walls, mechanically encased insulation, crawlspaces or unsafe areas.

Friable Material A material, that when dry, may be crumbled, pulverized or reduced to powder by hand pressure is a friable material. Examples of friable materials include pipe insulation, boiler or tank insulation, or sprayed-on fireproofing.

Non-friable Material A material, that when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure. Non-friable materials may become friable through damage or deterioration. Examples of non-friable materials include intact floor tile, transite building panels, or well-maintained roofing materials.

Homogeneous Area

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A homogeneous area is defined as a group of materials that is uniform in texture and appearance, was stalled at one time, and is likely to consist of more than one type or formation of material.

Significantly Damaged Material A “significantly damaged” material contains missing jackets on at least one-tenth of the piping or equipment and/or is crushed, heavily gouged, or punctured insulation on at least one-tenth of pipe runs/rises, boilers, tanks, ducts, etc., if the damage is evenly distributed or one-quarter of the damage is localized.