Amendment_0006_Asbestos_Report_170019.pdf

CEMS Engineering

Limited Asbestos Survey Report

M440 - BEQ

Marine Corps Base

Camp Lejeune, North Carolina

June 29, 2017

Limited Asbestos Survey Report

M440 - BEQ

Marine Corps Base Camp Lejeune, NC

Robert Elbertson NC AHERA Inspector

Prepared for:

Mr. Randy Alvar

Prepared by:

Crystal Coast Environmental, Inc.

10302 Bristow Center Dr.

Suite 115

Bristow, VA 20136

Tel: 910.938.7998

Fax: 910.938.3441 www.cceinc.biz

Our Ref.:

17-5033

Date:

June 29, 2017

This document is intended only for the use of the individual or entity for which it was prepared and may contain information that is privileged, confidential and exempt from disclosure under applicable law.

Table of Contents

1. Introduction 1

2. Methodology 1

3. Analytical Methods 2

4. Findings 2

5. Conclusions and Recommendations 2

6 Additional Survey Limitations 4

APPENDICES

A Limitations and Service Constraints

B Inspector Accreditations

C Homogeneous Applications

D Asbestos Sample Locations

E Laboratory Report (NVLAP) – Asbestos Bulk Sample Results

F Photograph Logs

Report

Mr. Randy Alvar CEMS Engineering

1. Introduction

As requested by Mr. Randy Alvar, Crystal Coast Environmental, Inc. (CCEI) conducted a Limited Asbestos Survey of the above-referenced building/project. The survey consisted of visually observing the building, then collecting a representative number of samples for subsequent laboratory analyses as described below. The objective of the survey was to identify and quantify asbestos-containing building materials (ACBMs) as well as verify previous findings for future planned renovations or demolition activity.

As directed by the client, destructive testing was performed on roofing material to identify materials which may be hidden or obstructed by layers of wood substrate.

Unless noted herein, no other destructive testing was conducted to expose other potentially hidden or obstructed material. Examples of other areas include, but are not limited to: interior wall cavities, pipe chases, spaces above fixed ceilings, grout/adhesive beneath ceramic tiles/marble tiles/granite, and adhesives behind wall mounted mirrors, etc

The survey was conducted in accordance with CCEI’s proposal. The survey was conducted on June 16, 2017 by Mr. Robert Elbertson. A copy of inspector’s accreditation is provided in Appendix B.

2. Methodology

CCEI conducted the survey in general accordance with ASTM E2356-09 Standard Practice for Comprehensive Building Asbestos Surveys. ASTM E2356-09 meets the applicable requirements of current Environmental Protection Agency (EPA) National Emission Standards for Hazardous Air Pollutants (NESHAP) Standard 40 CFR 61, Subpart M (Asbestos); EPA Asbestos Hazard Emergency Response Act (AHERA)

Standard 40 CFR 763, Subpart E; and Occupational Safety and Health Administration (OSHA) asbestos survey and/or sampling regulations.

CCEI visually observed readily accessible areas for suspect ACBMs. Identified suspect materials were divided into "Homogeneous Applications" (HAs) - i.e., building materials which were determined by the inspector to be homogeneous based on their color, texture, and assumed date of installation.

Representative samples were then collected from selected HAs. The numbers of samples collected was based on CCEI’s in-house sampling protocol, which is based in part on the U.S. Environmental Protection Agency (U.S. EPA) Asbestos Hazard Emergency Response Act (AHERA) regulations. Each sample was assigned its own

Report

Mr. Randy Alvar CEMS Engineering unique identification number, placed in 4 mil sealable plastic bags, and tightly sealed for subsequent shipment under a chain of custody protocol to Carolina Environmental, Inc. (CEI) located in Cary, North Carolina.

3. Analytical Methods

Material identification was performed by CEI using Polarized Light Microscopy with Dispersion Staining (PLM/DS) method in accordance with the U.S. EPA Method 600/R-93/116. Asbestos content in each sample was evaluated based on a visual examination of each sample using a stereoscope.

CEI is a member of the American Industrial Hygiene Association (AIHA) and accredited through the National Voluntary Laboratory Accreditation Program (NVLAP) administered by the National Institute of Standards and Technology (NIST).

CEI accreditations are provided in Appendix B and laboratory analytical report is provided in Appendix E.

4. Findings

A total of 14 HAs was identified throughout the Site, and a total of nine suspect ACBM bulk samples were collected and submitted for laboratory analysis. A listing of HAs identified along with each HA material description, location, condition, asbestos content and estimated quantity are presented in Appendix C. Approximate sampling locations are shown in the Appendix D.

Prior to commencement of the asbestos survey, CCEI conducted a review of the existing asbestos data (if available).

5. Conclusions and Recommendations

As presented in Appendix C and the laboratory data provided in Appendix E, the results of the asbestos survey did not identify ACBMs at the Site.

In accordance with current EPA National Emission Standards for Hazardous Pollutants (NESHAP) regulations, certain types of ACM must be removed prior to being disturbed by demolition or renovation activities. Current EPA NESHAP and Health Hazards

Control Unit (HHC) of North Carolina Department of Health and Human Service (DHHS) regulations require that all Regulated ACMs (RACM) be removed prior to being disturbed. RACMs are defined as:

Friable ACM.

Report

Mr. Randy Alvar CEMS Engineering

Non-Friable Category 1 ACM that has become friable.

Non-Friable Category 1 ACM that has been or will be subjected to sanding, abrading, grinding, or cutting.

Non-Friable Category 2 ACM that has a high probability of becoming friable or crumbled, pulverized, or otherwise reduced to powder by the demolition or renovation activities.

If other suspect materials that are not referenced in this report are identified during demolition and/or renovation activities, CCEI recommends that these materials be considered as ACBM until they are inspected by an appropriately licensed asbestos inspector and proven otherwise.

Due to the inability to effectively separate some types of multi-layered ACBMs (i.e., floor tile/mastic, mastic/wood subflooring, gypsum board/joint compound, etc.) from non-ACMs these materials are considered “asbestos-contaminated” for the purposes of removal, and should be managed as ACBM.

ACBMs identified at the Site that may be disturbed during demolition activities, must be removed by a licensed asbestos abatement contractor utilizing industry standard work procedures in accordance with all federal, state and local regulations governing asbestos.

Asbestos waste must be disposed at an asbestos waste receiving facility that is duly permitted by the state and/or local municipality in which it resides. The asbestos waste should be disposed in a landfill with a NESHAP condition in the facility’s air permit that allows acceptance of RACM.

6. Additional Survey Limitations

CCEI’s asbestos survey is subject to the following limitations in addition to those presented in Appendix A:

Utilities/services, including electric were assumed to be active in the areas surveyed. Materials associated with electrical components and energized equipment, were not safely accessible and were not sampled.

Subsurface investigations, including access to below grade structures, underground piping, conduits, building footings and extent of subsurface soil asbestos contamination if any was not accessible at the time of the survey.

Should decide to remove/demolish below grade structures, an additional

Limitations and Service Constraints

The opinions, conclusions and recommendations presented in this report are limited to the information obtained during the performance of the specific scope of service identified in the report. To the extent that

Crystal Coast Environmental, Inc. (CCEI) relied upon any information prepared by other parties not under direct contract to CCEI, no representation as to the accuracy or completeness of such information is made. This report is an instrument of professional service and the services described in the report were performed in accordance with generally accepted standards and level of skill and care ordinarily exercised by members of the profession working under similar conditions including comparable budgetary and schedule constraints. No warranty, guarantee or certification express or implied, is intended or given with respect to CCIE’s services, opinions, conclusions or recommendations. This statement is in lieu of any other statement either expressed or implied.

CCEI’s observations, the results of testing and CCEI’s opinions, conclusions and recommendations apply solely to conditions existing at the specific times when and specific locations where CCEI’s investigative work was performed. Observation and testing activities such as those conducted by CCEI are inherently limited and do not represent a conclusive or complete characterization. Conditions in other parts of the project site, building or area may vary from conditions at the specific locations where observations were made and where testing was performed by CCEI. Additionally, other building material hazards which were not identified by CCEI, may also be present in the indoor air, un-accessed areas and in walls, ceilings, cavities and floors. Therefore, the extent of CCEI’s opinions, conclusions and recommendations are limited and 100% confidence in these opinions, conclusions and recommendations cannot reasonably be achieved. Nothing contained in this report shall relieve any other party of its responsibility to abide by contract documents and applicable laws, codes, regulations, or standards nor shall it be considered medical advice or consultation.

This report may document whether work conducted by CCEI or under CCEI’s observation was done so in accordance with applicable regulatory standards. In the absence of standards such as is often the case for microbial assessment and abatement, this report may not be construed as providing clearance, approval, or authorization for use or re-occupancy of a given structure. Actual site conditions and quantities should be field verified and unless expressly stated.

This report is expressly for the sole and exclusive use of the party for whom this report was originally prepared for and for the particular purpose outlined in the report. Only the party for whom this report was originally prepared and/or other specifically named parties have the right to make use of and rely upon this report. Reuse of this report or any portion thereof for other than its intended purpose, or if modified, or if used by third parties, shall be at the user’s sole risk.

Homogeneous Application Table Building M440, Camp Lejeuene, NC

Project No.: 17-5033

HA No. Material Type Primary Color

Texture Description NESHAP Cat. Friable Rooms Location Condition Amt. Units Remarks

1 M - Ceiling Texture White Rough Spray-on Ceiling Texture Non-ACM, Sampled Yes Throughout Ceiling Good Non-ACM are not quantified 2 M - Ceiling Tile - 2' x 2' White Rough 2' x 2' Cellulose Ceiling Tile Non-ACM, Sampled Yes Hallways and Lounges Ceiling Good Non-ACM are not quantified 3 M - Floor Tile - 12" x 12" Gray Smooth 1' x 1' Vinyl Floor Tile Non-ACM, Sampled No Throughout Floor Good Non-ACM are not quantified 4 M - Floor Tile - Mastic/Adhesive Black Rough Mastic Associated with HA-3 Non-ACM, Sampled No Throughout Floor Good Non-ACM are not quantified 5 M - Exterior - Door Caulk Gray Smooth Exterior Door Caulk Non-ACM, Sampled No Exterior Wall Good Non-ACM are not quantified

M - Exterior - Expansion Joint

Caulk/Sealant Gray Smooth Exterior Expansion Joint Caulk Non-ACM, Sampled No Exterior Floor Good Non-ACM are not quantified

7 M - Roof - Built-up Roof - Tar and Felt Black Rough Built-up Roofing with Foam Insulation Non-ACM, Sampled No Roof Roof Good Non-ACM are not quantified 8 M - Roof - Flashing Black Rough Roof Flashing Non-ACM, Sampled No Roof Roof Good Non-ACM are not quantified 9 M - Roof - Caulk Black Smooth Roofing Caulk Non-ACM, Sampled No Roof Roof Good Non-ACM are not quantified

M - Joint Compound (associated with wall/ceiling board/panels) White Rough Joint Compound Non-ACM, Sampled Yes Dorm Rooms Ceiling Good Previously Surveyed

11 M - Mastic on Metal Duct Joints Brown Smooth HVAC Duct Mastic Non-ACM, Sampled No Mechanical Chases Other Good Previously Surveyed

T = Thermal System Insulation (TSI) Material S - Surface Material M - Miscellaneous Material

Results of Sample Analyses Building M440, Camp Lejeune, NC

Project No.: 17-5033

HA No. Material Type ID Location Content Type Sample Date Consultant Method Lab

1 M - Ceiling Texture 5033-1-01 2nd Floor Lounge ND 6/16/2017 CCEI PLM Carolina Environmental, Inc 2 M - Ceiling Tile - 2' x 2' 5033-2-02 1st Floor Hallway ND 6/16/2017 CCEI PLM Carolina Environmental, Inc 3 M - Floor Tile - 12" x 12" 5033-3-03 Room 126 ND 6/16/2017 CCEI PLM Carolina Environmental, Inc 4 M - Floor Tile - Mastic/Adhesive 5033-4-04 Room 126 ND 6/16/2017 CCEI PLM Carolina Environmental, Inc 5 M - Exterior - Door Caulk 5033-5-05 3rd Floor Hallway ND 6/16/2017 CCEI PLM Carolina Environmental, Inc 6 M - Exterior - Expansion Joint Caulk/Sealant 5033-6-06 1st Floor ND 6/16/2017 CCEI PLM Carolina Environmental, Inc 7 M - Roof - Built-up Roof - Tar and Felt 5033-7-07 Roof ND 6/16/2017 CCEI PLM Carolina Environmental, Inc 8 M - Roof - Flashing 5033-8-08 Roof ND 6/16/2017 CCEI PLM Carolina Environmental, Inc 9 M - Roof - Caulk 5033-9-09 Roof ND 6/16/2017 CCEI PLM Carolina Environmental, Inc

T = Thermal System Insulation (TSI) Material S = Surfacing Material M - Miscellaneous Material

SHEET NO.

JOB NO.

ISSUE DATE

APPROVED

CHECKED

DESIGNED

DRAWN

SHEET TITLE

JOB TITLE

B

REVISIONS

C

A

17-0019

INTERIOR & EXTERIOR

REPAIRS AT BEQ M440

AS101

06/01/17

HAZARDOUS

MATERIALS

ABATEMENT FIRST

FLOOR PLAN

NO

. DATE DESCRIPTION

SCALE: 1 : 280

FIRST FLOOR PLAN

PLAN NORTH

5033-2-02 (-)

5033-3-03 (-) 5033-4-04 (-)

5033-6-06 (-)

ISSUE DATE

APPROVED

CHECKED

DESIGNED

DRAWN

SHEET TITLE

JOB TITLE

B

REVISIONS

C

A

17-0019

INTERIOR & EXTERIOR

REPAIRS AT BEQ M440

AS102

06/01/17

HAZARDOUS

MATERIALS

ABATEMENT SECOND

FLOOR PLAN

NO

. DATE DESCRIPTION

SCALE: 1 : 280

SECOND FLOOR PLAN

PLAN NORTH

5033-1-01 (-)

ISSUE DATE

APPROVED

CHECKED

DESIGNED

DRAWN

SHEET TITLE

JOB TITLE

B

REVISIONS

C

A

17-0019

INTERIOR & EXTERIOR

REPAIRS AT BEQ M440

AS103

06/01/17

HAZARDOUS

MATERIALS

ABATEMENT THIRD

FLOOR PLAN

NO

. DATE DESCRIPTION

PLAN NORTH

SCALE: 1 : 280

THIRD FLOOR PLAN

5033-5-05 (-)

ISSUE DATE

APPROVED

CHECKED

DESIGNED

DRAWN

SHEET TITLE

JOB TITLE

B

REVISIONS

C

A

17-0019

INTERIOR & EXTERIOR

REPAIRS AT BEQ M440

AS104

06/01/17

HAZARDOUS

MATERIALS

ABATEMENT ROOF

PLAN

NO

. DATE DESCRIPTION

SCALE: 1 : 280

ROOF PLAN

PLAN NORTH

5033-7-07 (-)5033-8-08 (-)

5033-9-09 (-)

June 21, 2017

Crystal Coast Environmental Inc.

104 Dundee Court Jacksonville, NC 28540

CLIENT PROJECT: Bldg. M 440 Camp Lejeune; 17-5033

CEI LAB CODE: A17-8701

Dear Customer:

Enclosed are asbestos analysis results for PLM Bulk samples received at our laboratory on June 20, 2017. The samples were analyzed for asbestos using polarizing light microscopy (PLM) per the EPA 600 Method.

Sample results containing >1% asbestos are considered asbestos-containing materials (ACMs) per EPA regulatory requirements. The detection limit for the EPA 600 Method is <1% asbestos by weight as determined by visual estimation.

Thank you for your business and we look forward to continuing good relations. If you have any questions, please feel free to call our office at 919-481-1413.

730 SE Maynard Road • Cary, NC 27511 • 919.481.1413

Tianbao Bai, Ph.D., CIH Laboratory Director

Kind Regards, ASBESTOS ANALYTICAL REPORT

By: Polarized Light Microscopy

Prepared for

Crystal Coast Environmental Inc.

TEL: 866-481-1412

www.ceilabs.com

CLIENT PROJECT:

CEI LAB CODE:

TEST METHOD: EPA 600 / R93 / 116 and EPA 600 / M4-82 / 020

REPORT DATE:

TOTAL SAMPLES ANALYZED:

# SAMPLES >1% ASBESTOS:

Bldg. M 440 Camp Lejeune; 17-5033

A17-8701

06/21/17

Asbestos Report Summary By: POLARIZING LIGHT MICROSCOPY

PROJECT: Bldg. M 440 Camp Lejeune; 17-5033 CEI LAB CODE: A17-8701

Client ID Lab ID Color Sample Description

ASBESTOS

%Layer

METHOD: EPA 600 / R93 / 116 and EPA 600 / M4-82 / 020

A2429023 Off-white Ceiling Texture None Detected5033-1-01

A2429024 Off-white Ceiling Tile None Detected5033-2-02

A2429025 Off-white Floor Tile None Detected5033-3-03

A2429026 Black Mastic None Detected5033-4-04

A2429027 Gray Exterior Door Caulk None Detected5033-5-05

A2429028 Gray Expansion Joint None Detected5033-6-06

Layer 1 A2429029 Black Built-Up Roofing None Detected5033-7-07

Layer 2 A2429029 Black Foam None Detected

A2429030 Black,Gray Roof Flashing None Detected5033-8-08

A2429031 Black Roofing Mastic None Detected5033-9-09

ASBESTOS BULK ANALYSIS

CEI Lab Code: A17-8701 Date Received: 06-20-17 Date Analyzed: 06-21-17 Date Reported: 06-21-17

Client ID Lab ID

Lab Attributes

Lab Description

ASBESTOS

ASBESTOS BULK PLM, EPA 600 METHOD

NON-ASBESTOS COMPONENTS

Non-Fibrous

Client: Crystal Coast Environmental Inc.

104 Dundee Court Jacksonville, NC 28540

Project: Bldg. M 440 Camp Lejeune; 17-5033

Fibrous

Off-white Ceiling Texture5033-1-01

A2429023 Heterogeneous

Non-fibrous Bound

5% 85% 10%

Paint Calc Carb Binder

None Detected

Off-white Ceiling Tile5033-2-02

A2429024 15% 75%

Heterogeneous

Fibrous Bound

5% 5%

Cellulose Fiberglass

Paint Perlite

None Detected

Off-white Floor Tile5033-3-03

A2429025 Heterogeneous

Non-fibrous Bound

100% Vinyl None Detected

Black Mastic5033-4-04

A2429026 Heterogeneous

Non-fibrous Bound

85% 15%

Mastic Tar

None Detected

Gray Exterior Door Caulk5033-5-05

A2429027 Heterogeneous

Non-fibrous Bound

95% 5%

Caulk Binder

None Detected

Gray Expansion Joint5033-6-06

A2429028 Heterogeneous

Non-fibrous Bound

100% Binder None Detected

Black 5033-7-07

A2429029

15%Heterogeneous

Fibrous Bound

75% 10%

Cellulose Tar Binder

None Detected Layer 1

Built-Up Roofing

ASBESTOS BULK ANALYSIS

CEI Lab Code: A17-8701 Date Received: 06-20-17 Date Analyzed: 06-21-17 Date Reported: 06-21-17

Client ID Lab ID

Lab Attributes

Lab Description

ASBESTOS

ASBESTOS BULK PLM, EPA 600 METHOD

NON-ASBESTOS COMPONENTS

Non-Fibrous

Client: Crystal Coast Environmental Inc.

104 Dundee Court Jacksonville, NC 28540

Project: Bldg. M 440 Camp Lejeune; 17-5033

Fibrous

Black Foam

A2429029 Heterogeneous

Non-fibrous Bound

100% Foam None DetectedLayer 2

Black,Gray Roof Flashing5033-8-08

A2429030 15% 70%

Heterogeneous

Fibrous Bound

15%Cellulose Fiberglass

Tar None Detected

Black Roofing Mastic5033-9-09

A2429031 Heterogeneous

Non-fibrous Bound

75% 25%

Mastic Tar

None Detected

LEGEND: Non-Anth = Non-Asbestiform Anthophyllite Non-Trem = Non-Asbestiform Tremolite Calc Carb = Calcium Carbonate

METHOD: EPA 600 / R93 / 116 and EPA 600 / M4-82 / 020

REPORTING LIMIT: <1% by visual estimation

REGULATORY LIMIT: >1% by weight

Due to the limitations of the EPA 600 method, nonfriable organically bound materials (NOBs) such as vinyl floor tiles can be difficult to analyze via polarized light microscopy (PLM). EPA recommends that all NOBs analyzed by PLM, and found not to contain asbestos, be further analyzed by Transmission Electron Microscopy (TEM). Please note that PLM analysis of dust and soil samples for asbestos is not covered under NVLAP accreditation. Estimated measurement of uncertainty is available on request.

This report relates only to the samples tested or analyzed and may not be reproduced, except in full, without written approval by CEI Labs, Inc. CEI Labs makes no warranty representation regarding the accuracy of client submitted information in preparing and presenting analytical results. Interpretation of the analytical results is the sole responsibility of the client. Samples were received in acceptable condition unless otherwise noted. This report may not be used by the client to claim product endorsement by NVLAP or any other agency of the U.S. Government.

ANALYST: APPROVED BY:

Tianbao Bai, Ph.D., CIH Laboratory Director

Ritika Seal

Building M440 (BEQ), Camp Lejeune, NC

17-5033 Page 1 of 2

View of the Front of the Building HA-1: Spray-on Ceiling Texture

HA-2: 2’ x 4’ Cellulose Ceiling Tile HA-3: 1’ x 1’ Gray Vinyl Floor Tile

HA-4: Mastic Associated with HA-3 HA-5: Exterior Door Caulk

Building M440 (BEQ), Camp Lejeune, NC

17-5033 Page 2 of 2

HA-6: Exterior Expansion Joint Caulk HA-7: Built-up Roofing

HA-8: Roof Flashing HA-9: Roofing Mastic (Caulk)

HA-10: Joint Compound HA-11: HVAC Duct Mastic