P197_1620400 SIGN RFP_Parts 6 (3 of 11).pdf

HAZARDOUS MATERIALS SURVEY

MCAS CHERRY POINT - BUILDINGS 1670, 1699, 4157, 4158, AND 4159

WRIGHT ROAD AND A STREET

HAVELOCK, NORTH CAROLINA 28532

ECS PROJECT NO. 49:11900

FOR: HDR ENGINEERING, INC. OF THE CAROLINAS

SEPTEMBER 9, 2020

September 9, 2020

Mr. Nick Overby HDR Engineering, Inc. of the Carolinas 440 S. Church Street Suite 1000 Charlotte, North Carolina 29405

ECS Project No. 49:11900

Reference: Hazardous Materials Survey, MCAS Cherry Point - Buildings 1670, 1699, 4157, 4158, and 4159, Wright Road and A Street, Havelock, North Carolina

Dear Mr. Overby:

ECS Southeast, LLP (ECS) is pleased to provide HDR Engineering, Inc. of the Carolinas with the results of the above referenced Hazardous Materials Survey performed at MCAS Cherry Point - Buildings 1670, 1699, 4157, 4158, and 4159 located at Wright Road and A Street in Havelock, North Carolina. This report summarizes our observations, analytical results, findings, and recommendations related to the work performed. The work described in this report was performed by ECS in general accordance with the Scope of Services described in ECS Proposal Number 49:11837 and the terms and conditions of the agreement authorizing those services.

ECS appreciates this opportunity to provide HDR Engineering, Inc. of the Carolinas with our services.

If we can be of further assistance to you, please do not hesitate to contact us.

Sincerely, ECS Southeast, LLP

Amy DeSaix, REM Lindsey Lucas, REM Environmental Assistant Department Manager Environmental Principal adesaix@ecslimited.com llucas1@ecslimited.com

(910) 520-2141 (864) 345-0809

6714 Netherlands Drive, Wilmington, North Carolina 28405 • T: (910) 686-9114 • F: 703-834-5527 • ecslimited.com

PAGETABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY

2.0 SITE DESCRIPTION

3.0 PURPOSE

4.0 METHODOLOGY

4.1 Asbestos-Containing Materials

4.2 Metals in Paint

4.3 Suspect Liquid PCB and Mercury Containing Equipment and Universal Waste

4.4 Groundwater Monitoring Wells

5.0 RESULTS

5.1 Asbestos-Containing Materials

5.2 Suspect or Presumed Asbestos-Containing Materials

5.3 Lead and Metals in Paint

5.4 Suspect Mercury and PCB-Containing Equipment and Universal Waste

5.4.1 Suspect Polychlorinated Biphenyl (PCB) Containing Ballasts and Equipment

5.4.2 Mercury-Containing Components

5.4.3 Other Materials Observed

5.5 Groundwater Monitoring Wells and Regulatory File Review

5.5.1 Regulatory File Review

5.5.2 Groundwater Monitoring Wells

6.0 RECOMMENDATIONS AND REGULATORY REQUIREMENTS

6.1 Asbestos-Containing Materials

6.2 Lead in Paint & Surface Coatings

6.3 Barium in Paint & Surface Coatings

6.4 Chromium in Paint Surfaces & Coatings

6.5 Universal Waste and Liquid PCBs in Equipment

6.6 Monitoring Wells and Regulatory Records Review

7.0 LIMITATIONS

8.0 REFERENCES

ECS Project # 49:11900

TABLE OF APPENDICES

Appendix I: Figures

Appendix II: Site Photographs

Appendix III: Asbestos Prior Reports Bulk Sample Results

Appendix IV: Paint Laboratory Analytical Results

Appendix V: PCB Analytical Results

Appendix VI: Certifications/Licenses

Appendix VII: EDR Report

Appendix VIII: P-120 Fuel Hydrant System Groudwater Report

Appendix IX: OU1 Groundwater Report

Appendix X: OU14 Groundwater Reports

1.0 EXECUTIVE SUMMARY

The subject property consists of five buildings: buildings 1670, 1699, 4157, 4158, and 4159, each of which are located on Marine Corps Air Station (MCAS) Cherry Point at the intersection of Wright Road and A Street in Havelock, North Carolina. Each of the following buildings were occupied at the time of the assessment and are scheduled to be demolished:

• Building 1670 is a two-story, approximate 9,650 square foot group-headquarters building constructed in 1959;

• Building 1699 is a two-story, approximate 10,000 square foot administrative office building constructed in 1962;

• Building 4157 is a single story, approximate 2,300 square feet fitness training building constructed in 1986;

• Building 4158 is a single-story, approximate 782 square feet utility building constructed in 1986; and

• Building 4159 is a a single-story, approximate 854 square feet utility building constructed in 1986.

The purpose of the assessment was to evaluate if asbestos-containing materials (ACMs), metal-containing (metallic) paints, poly-chlorinated biphenyls (PCBs), mercury-containing equipment or universal wastes are present on the site. ECS performed this assessment by reviewing prior reports, conducting on-site observations and through supplemental sampling activities.

As part of this assessment, ECS conducted a site reconnaissance for water wells (water supply or groundwater monitoring wells) on the site. A review of nearby groundwater incidents was conducted through the North Carolina Department of Environmental Quality (NCDEQ) records. The non-invasive assessment was performed on July 9, 13, and 14, 2020.

Summary of Findings

Asbestos

Asbestos was identified in the following materials at concentrations >1% and therefore considered to be ACMs requiring removal prior to demolition:

• Building 1670 - Confirmed asbestos containing pipe insulation (runs and elbows) were observed in the closet under the stairs which contains the hot water heater. The pipes appear to extend into areas above the plaster ceiling on the first floor and should be presumed to be present in runs and risers above the plaster ceilings. Approximately 22 linear feet (LF) and nine elbows of confirmed asbestos pipe insulation was observed; we would estimate an additional 200 LF of presumed asbestos pipe insulation and 20 presumed asbestos hard elbows and tees could be present above the plaster ceiling. Additionally, suspected asbestos pipe insulation debris was observed in the back portion of the closet, under the stairs.

• Building 1670 - Confirmed asbestos containing residual mastic is present on the second floor under the confirmed non-asbestos floor tile; we would estimate approximately 1,800 square feet (SF) of material.

September 9, 2020

• Building 1699 - Confirmed asbestos containing black mastic on the HVAC duct above the drop ceiling in the hallway corridor and lobby on the first and second floors; we would estimate 275 SF of confirmed asbestos mastic on 4,860 SF of HVAC duct work. It should be noted that suspected asbestos black mastic was observed on the pipe insulation wrap of a pipe which connects to HVAC duct work (and associated wrap) on the first floor in Room 114.

Metallic Paint

Paint chip samples collected from the buildings were analyzed for the Resource Conservation and Recovery Act (RCRA) 8 metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver. The results indicated detectable concentrations of metals in each paint sample. The metals concentrations for barium (Ba), chromium (Cr) and lead (Pb) showed the most variation among the samples. The samples with the greater concentrations were collected from the following materials:

• Building 1699 - Brown Metal Doors, Orange Metal Ceiling Rafters, and Black/Red Metal Stairs.

• Building 1670 - Grey Concrete and White Plaster Walls.

• Building 4157 - White/Yellow Metal Ceiling Rafters, Grey Metal Door and Grey Metal Vault

Door.

• Buildings 4158 and 4159 - Brown Metal Equipment, White Metal Ceiling and Rafters.

• Parking Lot Area - Yellow Concrete Bollards, Steam Pit, Curbs.

PCBs, Mercury, Universal Waste

In addition to survey for ACMs and LBPs, ECS assessed the building for various materials classified as Hazardous Wastes or Universal Wastes which may require special handling or disposal if removed from the buildings. Materials identified in the assessment are referenced below:

• Mercury containing fluorescent lights were observed in each building.

• One pad-mounted transformer without a PCB indicator label was observed outside building

4159.

• A "non-PCB indicator" label was not observed on light ballasts in buildings 4157, 4158, or

4159.

• One composite caulk sample was collected from each building and one from the caulk in the parking lot was analyzed for PCBs. The caulk sample collected from the doors and windows of building 1670 contained a PCB concentration of 210 mg/kg, which is considered to be PCB containing.

Groundwater Monitoring Well and Regulatory File Review

ECS observed nine potential monitoring wells. Two potential wells were located on the southern portion of the site, in the parking lot. These wells contained manhole well covers and were labeled IW90 and IW91. Seven of the wells were flush-mounted and contained one foot diameter well covers.

One of the wells was labeled 74GW14 and another well was labeled 72GW35. A third and fourth well, upon document review, were identified to be 72GW26 and 72GW27. Three additional wells, which were observed at the time of the assessment, were not labeled. These seven wells were located on the northern and eastern portion of the site.

September 9, 2020

Cherry Point is listed on the Superfund database as incident number NC1170027261. The contamination documented as part of the Superfund listing are broken up into multiple Operable Units based on the nature of the contamination. The site area is identified as part of the Operable Unit 1 (OU1) and south of OU14. These two OUs contain chlorinated volatile organic compounds (cVOCs) in the groundwater. The depth to water at this location is historically measured around 8 feet below ground surface. The site is still located within the Land Use Control (LUC) Boundary which states that intrusive activities below the water table are prohibited. A vapor intrusion evaluation is required for building/construction modification. Well installation and groundwater use is prohibited except for monitoring and remediation purposes.

Recommendations and Regulatory Requirements

Asbestos

ECS recommends that asbestos containing materials are removed prior to disturbance by demolition activities. Additionally, where a material type has been identified as asbestos containing other materials with similar color, texture, age and size throughout the building’s interior and exterior should be presumed to contain asbestos. Please refer to Section 4.1 for a complete list of building materials that were reported positive for asbestos and to Section 4.2 for materials that were presumed to contain asbestos.

If ACMs are to be removed, it is recommended that an industrial hygienist monitor the project.

This involves collecting air samples from within and outside abatement work areas to monitor the asbestos abatement contractor’s work practices over the course of the project. The industrial hygienist should evaluate if the asbestos abatement work is in accordance with project specifications, U.S. EPA regulation 40 CFR Part 61-National Emission Standards for Hazardous Air Pollutants Subpart M: National Emission Standard for Asbestos, and U.S. Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1926.1101 – Asbestos in Construction. The industrial hygienist should assess each work area to monitor the removal of ACMs. Only after the industrial hygienist has determined the identified ACMs have been removed should final clearance air samples be collected (if necessary).

A trace amount of asbestos (≤1%) was detected in the bulk sample(s). Although materials that contain trace amounts of asbestos are not subject to U.S. EPA or North Carolina regulations for the handling and disposal of asbestos, OSHA still regulates any work which will disturb materials identified with trace amounts of asbestos (reference the November 24, 2003 OSHA Interpretation document - Compliance Requirements For Renovation Work Involving Materials Containing Less Than 1% Asbestos). Therefore, any Contractors disturbing these materials will need to comply with components of 29 CFR 1926.1101, as detailed in the 2003 OSHA Interpretation document.

Suspect ACMs not observed due to inaccessibility or not sampled due to the destructive means that sampling would require may also be encountered during construction activities. At the time of the survey, only limited destructive means were used to locate or sample suspect ACMs; therefore, additional suspect ACMs may remain within inaccessible areas that include, but are not limited to, sub-grade walls, structural members, topping slabs, exterior areas, sub-grade sealants, flooring located below underlayments, vapor barriers, pipe trenches and other subsurface utilities, etc. If additional suspect ACMs are uncovered which were not accessible during this survey, it is

September 9, 2020 recommended that these materials either be presumed to contain asbestos or be sampled prior to disturbance upon discovery for asbestos content by an asbestos inspector in accordance with 29 CFR 1926.1101.

Lead-Based and Metal Containing (Metallic) Paint

The OSHA standard gives no guidance on acceptable levels of lead or metals in paint at which no exposure to airborne lead (above the action level) would be expected. Rather, OSHA defines airborne concentrations, and references specific types of work practices and operations from which a lead hazard may be generated (reference 29 CFR 1926.62, section d). Environmental and personnel monitoring should be conducted during any removal/demolition process (as appropriate) to verify that actual personal exposures are below the Permissible Exposure Limit (PEL) of 50 micrograms per cubic meter (µg/m3) as an 8-hour Time Weighted Average (TWA). Under OSHA requirements, the contractor performing renovation work will be required to conduct this monitoring and follow applicable requirements under 29 CFR 1926.62 if disturbing lead-containing paint.

OSHA has a legally enforceable occupational exposure limit of 0.5 mg of soluble barium compounds per cubic meter (m3) of air averaged over an 8-hour work day. The OSHA 8-hour exposure limit for barium sulfate dust in air is 15 mg/m3 for total dust. NIOSH considers exposure to barium chloride levels of 50 mg/m3 and higher as immediately dangerous to life or health.

OSHA has limited workers exposure to an average of 0.005 mg/m3 chromium(VI), 0.5 mg/ m3 chromium(III), and 1.0 mg/m3 chromium(0) for an 8-hour workday, 40-hour workweek.

ECS recommends performing a Total Characteristic Leaching Procedure (TCLP) analysis on the waste stream for hazardous classification for waste disposal purposes associated with demolition.

PCB and Mercury (Universal Waste)

ECS recommends that all ballasts suspected to contain PCBs be properly recycled or disposed of in accordance with US EPA and regulations. In practice, many ballasts lacking the "No-PCBs" label have been removed from buildings as part of routine maintenance; however, inspection of each ballast by the contractor performing removal is still recommended to ensure proper disposal into the proper waste stream.

ECS recommends that fluorescent lamp tubes/bulbs suspected to contain mercury be properly recycled or disposed of in accordance with EPA and North Carolina and EPA regulations.

PCB Containing Caulk

ECS recommends the PCB containing caulk be removed using lower temperature and low dust methods. The PCB containing caulk must be handled and disposed of as PCB Bulk Product Waste in accordance with 40 CFR part 761.62. North Carolina does not allow PCB products or waste to be disposed in solid waste landfills. The buildings components in contact with the PCB containing caulk should be removed and disposed of as PCB remediation waste in accordance with 40 CFR part 761.61.

Groundwater Monitoring Wells

September 9, 2020

The LUC states that intrusive activities below the water table are prohibited. A vapor intrusion evaluation is required for building/construction modification. Well installation and groundwater use is prohibited except for monitoring and remediation purposes.

If monitoring wells are located in the path of construction and will require abandonment as part of the redevelopment, ECS recommends consulting with the incident manager during the redevelopment phase. If dewatering will be required as part of redevelopment, the groundwater should be appropriately disposed in accordance with Base and NCDEQ regulations. Per the LUC, vapor intrusion should be evaluated during construction activities.

The executive summary is an integral portion of this report, however, ECS recommends the report be read in its entirety.

2.0 SITE DESCRIPTION

The subject property consists of five buildings: buildings 1670, 1699, 4157, 4158, and 4159, each of which are located on Marine Corps Air Station (MCAS) Cherry Point at the intersection of Wright Road and A Street in Havelock, North Carolina, as shown on Figure 1. The structures are currently occupied and are proposed for demolition. It should be noted that buildings 1670, 1699, and 4157 contain steam pits underneath each of the buildings and within the landscaped area. ECS did not access the pits at the time of the assessment. Photographs of the structures are included in Appendix II.

Building 1670 is a two-story, approximately 9,650 square foot large group headquarters building constructed in 1959. The building consists of brick exterior walls, concrete masonry unit (CMU), drywall and plaster interior walls, concrete floor with vinyl floor tile and carpet, suspended ceiling tiles, and bituminous roof. The building contains white paint on the exterior CMU wall and numerous painted components on the interior. A 2019 asbestos survey documented approximately 10 linear feet of asbestos grey pipe insulation leading to the hot water tank in the 1st floor closet on the west end of the building. Approximately 1,800 square feet of residual asbestos mastic was documented in the north offices on the second floor. Materials which were previously tested as non-asbestos containing included white TSI tape, grey and yellow 12x12 inch floor tile and mastic, white TSI and wrap in the crawlspace, white ceiling plaster, black mastic with 12x12 floor tile in the first floor, drywall and joint compound, built up roofing material, 2x4 foot ceiling tiles, and black 12x12 inch floor tile. Asbestos materials previously removed included pipe insulation and mudded fittings in the equipment room, window glazing, 9x9 inch green floor tile and associated mastic, and grey 12x12 inch floor tile.

Building 1699 is a two-story, approximately 10,000 square foot administration office building constructed in 1962. The building consists of brick exterior walls, CMU, drywall, metal, brick, and plaster interior walls, concrete floor with vinyl floor tile and carpet, suspended ceiling tiles, and bituminous roof. The building contains white paint on the exterior CMU wall and numerous painted components on the interior. A 2017 asbestos survey documented approximately 275 square feet of asbestos black mastic on the HVAC duct insulation in the 1st and 2nd floor corridors. Materials which were previously tested as non-asbestos containing included white paint, grey and beige floor tile with brown mastic, grey floor tile with tan mastic, grey cove base with tan mastic, black stair cover, grey exterior building finish, white window glazing, black roof flashing with silver sealer materials, silver

September 9, 2020 sealer coat, white door caulking, black and grey caulking/flashing at awnings, plaster walls, built up roofing, black cove base mastic, and 2x4 foot ceiling tiles. Asbestos containing materials previously removed included 9x9 inch floor tiles and black mastic.

Building 4157 is a single-story, approximate 2,300 square foot building constructed in 1986. The building is currently used for the MAG-14 Athletic Training Facility. The building consists of brick exterior walls, CMU interior walls, concrete or vinyl tile floors, a metal roof deck and a modified bituminous roof.

Building 4158 is a single-story, approximate 782 square foot utility building constructed in 1986 and divided into an enclosed mechanical room and a covered storage area. The building consists of brick exterior walls, CMU interior walls, concrete floor, and rubber membrane roof. The building contains white paint on metal rafters, brown paint on metal doors and equipment, and white paint on the CMU walls.

Building 4159 is a single-story, approximate 854 square foot utility building construed in 1986 and divided into an enclosed mechanical room and a covered storage area. The building consists of brick exterior walls, CMU interior walls, concrete floor, and rubber membrane roof. The building contains white paint on metal rafters, brown paint on metal doors and equipment, and white paint on the CMU walls.

3.0 PURPOSE

The purpose of the Hazardous Materials Survey was to identify asbestos-containing materials (ACMs), lead-based paint (LBP) and associated metal containing (metallic) paint, suspect mercury containing equipment, suspect liquid PCB containing equipment, other universal waste, and contaminated soil or groundwawter which may require special handling and/or disposal if removed during construction activities. The identification of ACMs may require trained labor, regulated work practices, and special disposal. The identification of LBP or other hazards may require disclosure to contractors and monitoring of lead or other metal exposure. The identification of other regulated materials such as PCB and mercury containing equipment and universal waste may require personal protective equipment, training, special handling, packaging, and disposal.

4.0 METHODOLOGY

ECS performed the authorized Scope of Services in general accordance with our proposal, standard industry practice(s) and methods specified by regulation(s) for the identification on site of of ACMs, LBPs, universal waste, suspect liquid PCB-containing equipment and fixtures, and documented soil and groundwater contamination.

4.1 Asbestos-Containing Materials

ECS was provided with an asbestos survey dated 2019 for Building 1670 and 2017 for Building 1699.

The Building 1670 asbestos survey documented approximately 10 linear feet of asbestos grey pipe insulation leading to the hot water tank in the 1st floor closet on the west end of the building.

Approximately 1,800 square feet of residual asbestos mastic was documented in the north offices on the second floor. Materials which were previously tested as non-asbestos containing included white

September 9, 2020

TSI tape, grey and yellow 12x12 inch floor tile and mastic, white TSI and wrap in the crawlspace, white ceiling plaster, black mastic with 12x12 floor tile in the first floor, drywall and joint compound, built up roofing material, 2x4 foot ceiling tiles, and black 12x12 inch floor tile. Asbestos materials previously removed included pipe insulation and mudded fittings in the equipment room, window glazing, 9x9 inch green floor tile and associated mastic, and grey 12x12 inch floor tile.

The Building 1699 asbestos survey documented approximately 275 square feet of asbestos black mastic on the HVAC duct insulation in the 1st and 2nd floor corridors. Materials which were previously tested as non-asbestos containing included white paint, grey and beige floor tile with brown mastic, grey floor tile with tan mastic, grey cove base with tan mastic, black stair cover, grey exterior building finish, white window glazing, black roof flashing with silver sealer materials, silver sealer coat, white door caulking, black and grey caulking/flashing at awnings, plaster walls, built up roofing, black cove base mastic, and 2x4 foot ceiling tiles. Asbestos containing materials previously removed included 9x9 inch floor tiles and black mastic.

ECS was requested to perform an asbestos survey to update the above mentioned surveys. Materials previously sampled in the prior surveys were not sampled but were identified and quantified if needed.

The non-destructive asbestos survey was performed on July 9, 2020, July 13, 2020 and July 14, 2020 by asbestos inspector Ms. Amy DeSaix (NC License #12107) who has received EPA accredited training and is licensed by North Carolina. Samples of suspect ACMs were collected utilizing hand tools and placed into individual, labeled plastic bags. Unique bulk suspect ACM samples were submitted to Environmental Hazards Services, L.L.C (EHS) in Richmond, Virginia for analysis via Polarized Light Microscopy (PLM) in accordance with current EPA-600 methodology. Materials consisting of additional layers were analyzed separately. EHS is listed as an accredited laboratory by the National Voluntary Laboratory Accreditation Plan (NVLAP) managed by the National Institute of Standards and Technology (NIST) for bulk sample analysis by currently approved EPA methodology by PLM.

During the survey, ECS attempted to identify suspect ACMs in readily accessible areas. However, due to the destructive means required to identify some materials, certain areas were deemed inaccessible (i.e. behind walls or sub grade materials) and were not surveyed for suspect ACMs.

Samples were collected in general accordance with EPA Standard 40 CFR 763 Subpart E, Asbestos Hazard Emergency Response Act (AHERA) and OSHA Standard 29 CFR 1926.1101 Inspection Protocol.

Multiple samples of each unique material were submitted. However, as mentioned, material included in the prior survey were not re-sampled. Samples were analyzed using “Positive Stop” methodology.

If one sample of a homogeneous material is reported to contain asbestos, the remaining samples of that material are not analyzed. EPA regulations stipulate that if one sample contains asbestos the entire quantity of that material contains asbestos, regardless of additional analysis.

4.2 Metals in Paint

The Lead-Based Paint (LBP) and metal containing (metallic) paint assessment was performed by a Ms. Amy DeSaix (NC License #110230) a North Carolina licensed Lead Inspector to identify metal concentrations in painted surfaces. The assessment was conducted utilizing the U.S. EPA

September 9, 2020 definition of LBP. Under this definition, painted surfaces which contain lead in concentrations equal to or greater than 5,000 milligrams per kilogram (mg/kg) (or ≥ 1.0 mg/cm2) are classified as coated with LBP.

The LBP and metallic paint assessment was performed in general accordance with the U.S.

Department of Housing and Urban Development (HUD) “Guidelines for the Evaluation and Control of Lead-Based Paint Hazard in Housing", however, the scope of this study is not intended to meet the requirements for surface-by-surface investigation per HUD Chapter 7 guidelines and for lead free certification purposes, but rather a screening survey of painted surfaces where the presence of lead-based paint is suspected for demolition. Composite paint chip samples were collected from the prominent testing combinations observed and surrounding the buildings, including driveways and curbs.

Paint chip samples were collected utilizing hand tools and placed into individual, labeled plastic bags.

Unique bulk suspect lead-based paint samples were submitted to Environmental Hazards Services, L.L.C (EHS) in Richmond, Virginia for analysis of lead and RCRA 8 metals using EPA Method 6010D.

4.3 Suspect Liquid PCB and Mercury Containing Equipment and Universal Waste

ECS performed a visual survey within the buildings and exterior areas of the site for the presence of suspect liquid PCB and mercury containing equipment and universal waste. ECS entered the accessible areas to identify universal waste materials including mercury containing equipment, suspect liquid PCB-containing equipment and materials, ozone depleting substances (ODS), and low-level radiation materials. The scope included the following:

• Inventory of 10% to 25% of the lights ballast for Non-PCB indicator labeling.

• Inventory of 10% to 25% of the lights for mercury containing bulbs.

• Visual survey for ODS such as refrigeration and air conditioning systems using

Chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs).

• Visual survey for potential mercury containing devices and equipment (thermostats, light switches, gauges, etc.).

• Visual survey for potential low-level radiation materials, such as tritium exit signs and gauges.

• Visual survey of suspect PCB containing materials and equipment, such as window glazing, caulking, seam sealers, transformers, etc.)

• Sampling of suspect PCB containing caulk and oil staining if observed using an enhancement of U.S. EPA SW846 Method 8082A, extending its application to an additional matrix (caulk).

4.4 Groundwater Monitoring Wells

ECS performed a reconnaissance of the project site to document observed wells (monitoring well, water supply wells, and/or remediation wells). Additionally, ECS performed a regulatory review of documented incidents within the federal or state databases listed in the ASTM Standard E1527-13, Standard Practice for Phase I Environmental Site Assessments. The review extended 1/8 mile outside the project site boundary. ECS obtained reports and documents from the North Carolina Department of Environmental Quality (NCDEQ) laserfiche records for adjacent documented incidents. The results of the reconnaissance and regulatory review are discussed in Section 5.5.

September 9, 2020

5.0 RESULTS

The following is a summary of laboratory results, findings and observations.

5.1 Asbestos-Containing Materials

An Asbestos-Containing Material (ACM) is defined as any material containing more than one percent (>1%) asbestos as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM. Materials are categorized by the U.S. EPA in the following categories:

• Friable ACMs are defined as any ACM that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. Non-friable ACMs are defined as any ACM that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

• Category I non-friable ACM are listed as following: packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than one percent (>1%) asbestos.

• Category II non-friable ACM are listed as any material, excluding Category I non-friable ACM, containing more than one percent (>1%) asbestos.

Regulated Asbestos Containing Materials (RACM) are friable ACM or non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading or has crumbled, been pulverized, or reduced to powder in the course of renovation and/or demolition operations.

EHS submitted a signed final laboratory report to ECS of the bulk samples submitted for analysis.

These materials are summarized below. A complete list of the sampled materials submitted for analysis and sample locations are located in the Appendix of this report. Additional details regarding the overall locations of the materials identified as asbestos-containing are provided further in the report. Photographs of collected samples reported as asbestos-containing are also located in the Appendix of this report.

In total, 103 bulk samples from 37 homogeneous areas were submitted to the laboratory of which 131 layers were analyzed, as summarized below. Concentrations in bold are considered by the EPA to be asbestos containing materials (>1% asbestos). Concentrations listed as NAD were identified in the laboratory report as No Asbestos Detected. Figures 2 through 9 depict the sample locations along with the locations of confirmed and presumed ACMs.

Summary of Suspect Asbestos-Containing Material Sample Results

Building Number

Sample

ID

Material Description Location Category Condition

Analytical Results

Estimated Quantity

1699 Prior

Reports

White Paint 2nd Floor Non-ACM Damaged NAD Not

Measured

1699 Prior

Reports

12" Grey FT and Beige

Mastic

1st Floor Non-ACM Good NAD Not

Measured

September 9, 2020

Building Number

Sample

ID

Material Description Location Category Condition

Analytical Results

Estimated Quantity

1699 Prior

Reports

12" Grey FT and Tan

Mastic

1st Floor Non-ACM Good NAD Not

Measured

1699 Prior

Reports

Grey Cove

Base and Tan

Mastic

1st Floor Non-ACM Good NAD Not

Measured

1699 Prior

Reports

Black Stair

Cover

Stairways Non-ACM Good NAD Not

Measured

1699 Prior

Reports

Exterior

Building Finish

Rear Non-ACM Good NAD Not

Measured

1699 Prior

Reports

Window

Glazing

Rear

Center

Windows

Non-ACM Good NAD Not

Measured

1699 Prior

Reports

Roof Flashing/

Sealer/Silver

Coat

South Roof

Vents and

Front Drip

Edge

Non-ACM Good NAD Not

Measured

1699 Prior

Reports

White Caulk Front

Doors

Non-ACM Good NAD Not

Measured

1699 Prior

Reports

Black/Grey

Caulk

Rear

Awning

Flashings

Non-ACM Good NAD Not

Measured

1699 Prior

Reports

Plaster Walls Corridors Non-ACM Good NAD Not

Measured

1699 Prior

Reports

Built-UP

Roofing

1st Floor

Roof

Non-ACM Good NAD Not

Measured

1699 Prior

Reports

2x4 Fissured

CT

1st Floor Non-ACM Good NAD Not

Measured

1699 Prior

Reports

Black FT

Mastic

Throughout Non-ACM Good NAD Not

Measured

1699 Prior

Reports

Black Mastic on HVAC Duct and Pipe Wrap

1st and 2nd

Floor

Corridor

Cat. I Good 10% Chrysotile

275 SF of

Mastic on

4,860 SF of

Duct and TSI

1699 1-1, 1-2, 1-3

TSI Wrap Mechanical

Room

Non-ACM Good NAD 125 LF

September 9, 2020

Sample

ID

Material Description Location Category Condition

Analytical Results

Estimated Quantity

1699 2-1, 2-2 Red Fire Stop Mechanical

Room

Non-ACM Good NAD 5 SF

1699 3-1, 3-2, 3-3

Brick/CMU

Skim Coat

Interior on

Exterior

Walls

Non-ACM Damaged NAD 7,000 SF

1699 5-1, 5-2 2x2 CT Office 114 Non-ACM Good NAD 768 SF

1699 6-1, 6-2 Drywall/Joint

Compound

Walls Non-ACM Damaged NAD 13,000 SF

1699 7-1, 7-2, 7-3

TSI Older

Paper Wrap

Corridors above the ceiling tiles

Non-ACM Good NAD 150 LF

1699 8-1. 8-2 Carpet Mastic Offices Non-ACM Good NAD 768 SF

1699 9-1, 9-1 Residual Black

Mastic

Scattered

Throughout

Non-ACM Good <1%

Chrysotile

6,000 SF

1699 10-1, 10-2

Roof Flashing Parapet

Wall

Non-ACM Good NAD 64 SF

1699 11-1, 11-2

Asphalt Layer Roof Non-ACM Good NAD 100 SF

1699 12-1, 12-2

Gypsum

Insulation

Roof Non-ACM Good NAD 4,800 SF

1699 13-1, 13-2, 13-3

Ceiling Texture Front Porch Non-ACM Good NAD 150 SF

Building 1670

1670 Prior

Reports

White TSI Tape Mechanical

Room

Non-ACM Good NAD Not

Measured

1670 Prior

Reports

12" Grey FT and Yellow

Mastic

Throughout Non-ACM Good NAD Not

Measured

1670 Prior

Reports

White TSI Crawl

Space

Non-ACM Good NAD Not

Measured

1670 Prior

Reports

Black FT

Mastic

Throughout Non-ACM Good NAD Not

Measured

September 9, 2020

Sample

ID

Material Description Location Category Condition

Analytical Results

Estimated Quantity

1670 Prior

Reports

Drywall and

Joint

Compound

Throughout Non-ACM Good NAD Not

Measured

1670 Prior

Reports

Built Up Roof Roof Non-ACM Good NAD Not

Measured

1670 Prior

Reports

2x4 CT Offices Non-ACM Good NAD Not

Measured

1670 Prior

Reports

12" Black FT Throughout Non-ACM Good NAD Not

Measured

1670 Prior

Reports

TSI (Chalky) 1st Floor

Hot Water

Heater &

Assume

Above

Ceiling in

Corridor

Friable Damaged 35% Chrysotile

222 LF

1670 Prior

Reports

TSI Elbows/Ts

(Hard)

1st Floor

Hot Water

Heater

Closet

Friable Good Presumed 29

1670 Prior

Reports

TSI Debris

(Aircell)

Under stairs behind hot water heater

Friable Significantly

Damaged

Presumed 1 LF

1670 Prior

Reports

Black Mastic 2nd Floor Cat. I Good Presumed 1,800 SF

1670 1-1, 1-2, 1-3

Black Mastic on HVAC Duct

Mechanical

Room

Non-ACM Good NAD 150 LF

1670 2-1, 2-2, 2-3

TSI Wrap and

Mastic (paper on fiberglass)

Mechanical

Room

Non-ACM Good NAD 200 LF

1670 3-1, 3-2, 3-3, 3-4, 3-5, 3-6, 3-7

CMU Block

Coating

Throughout Non-ACM Good NAD 9,000 SF

September 9, 2020

Sample

ID

Material Description Location Category Condition

Analytical Results

Estimated Quantity

1670 4-1, 4-2 Grey Cove

Base and Glue

Throughout Non-ACM Good NAD 2,000 LF

1670 5-1, 5-2, 5-3, 5-4, 5-5, 5-6, 5-7

Textured Paint Exterior

Wall

Non-ACM Good NAD 7,200 SF

1670 6-1, 6-2 12" Blue FT and Brown

Mastic

Throughout Non-ACM Good NAD 9,000 SF

1670 7-1, 7-2 12" Grey FT and Yellow

Mastic

Throughout Non-ACM Good NAD 115 SF

1670 8-1, 8-2 Sealant Roof Vent Non-ACM Good NAD 5 LF

1670 9-1 9-2 Flashing Roof Seam Non-ACM Good NAD 60 LF

1670 10-1, 10-2

Caulk Door Non-ACM Good NAD 100 LF

Building 4157

4157 1-1, 1-2, 1-3, 1-4, 1-5, 1-6, 1-7

CMU Block

Coating

Walls Non-ACM Good NAD 8,460 SF

4157 2-1, 2-2, 2-3

TSI Wrap Mechanical

Room

Non-ACM Good NAD 200 LF

4157 3-1, 3-2, 3-3

HVAC Duct

Mastic

Office Non-ACM Good NAD 85 LF

4157 4-1, 4-2 Caulk Exterior

Doors

Non-ACM Good NAD 97 LF

4157 5-1, 5-2 Caulk Interior

Wall

Corners

Non-ACM Good NAD 420 LF

4157 6-1, 6-2 12" Blue and

Grey FT with

Yellow and

Black Mastic

Office Non-ACM Good NAD 85 SF

September 9, 2020

Sample

ID

Material Description Location Category Condition

Analytical Results

Estimated Quantity

4157 7-1, 7-2 Grey Cove

Base and

Mastic

Office Non-ACM Good NAD 40 LF

4157 8-1, 8-2 Black Cove

Base and

Mastic

Office Non-ACM Good NAD 160 LF

4157 9-1, 9-2 Red Fire Stop Mechanical Non-ACM Good NAD 10 SF

Building 4158

4158 1-1, 1-2 Caulk Door Non-ACM Good NAD 20 LF

4158 2-1, 2-2 Caulk Concrete

Floor

Non-ACM Good NAD 40 LF

4158 3-1, 3-2, 3-3, 3-4, 3-5

CMU Block

Coating

Walls Non-ACM Damaged NAD 1,000 SF

Building 4159

4159 1-1, 1-2 Caulk Door Non-ACM Good NAD 20 LF

4159 2-1, 2-2 Caulk Concrete

Floor

Non-ACM Good NAD 45 LF

4159 3-1, 3-2, 3-3, 3-4, 3-5

CMU Block

Coating

Walls Non-ACM Damaged NAD 1,000 SF

A trace amount of asbestos (≤1%) was detected in the bulk samples analyzed by the laboratory.

Although materials that contain trace amounts of asbestos are not subject to U.S. EPA or North Carolina regulations for the handling and disposal of asbestos, OSHA still regulates any work which will disturb materials identified with trace amounts of asbestos (reference the November 24, 2003 OSHA Interpretation document - Compliance Requirements For Renovation Work Involving Materials Containing Less Than 1% Asbestos). Therefore, any Contractors disturbing these materials will need to comply with components of 29 CFR 1926.1101, as detailed in the 2003 OSHA Interpretation document.

Based on the information in the prior reports reviewed and current sampling, the following confirmed and presumed ACMs were identified:

• Building 1670

◦ Confirmed asbestos containing pipe insulation (runs and elbows) were observed in the closet under the stairs which contains the hot water heater. The pipes appear to extend into areas above the plaster ceiling on the first floor and should be

September 9, 2020 presumed to be present in runs and risers above the plaster ceilings. Approximately 22 linear feet (LF) and nine elbows of confirmed asbestos pipe insulation was observed; we would estimate an additional 200 LF of presumed asbestos pipe insulation and 20 presumed asbestos hard elbows and tees could be present above the plaster ceiling.

◦ Additionally, suspected asbestos pipe insulation debris was observed in the back portion of the closet, under the stairs.

• Building 1670

◦ Confirmed asbestos containing residual mastic is present on the second floor under the confirmed non-asbestos floor tile; we would estimate approximately 1,800 square feet (SF) of material.

• Building 1699

◦ Confirmed asbestos containing black mastic on the HVAC duct above the drop ceiling in the hallway corridor and lobby on the first and second floors; we would estimate 275 SF of confirmed asbestos mastic on 4,860 SF of HVAC duct work.

◦ It should be noted that suspected asbestos black mastic was observed on the pipe insulation wrap of a pipe which connects to HVAC duct work (and associated wrap) on the first floor in Room 114.

5.2 Suspect or Presumed Asbestos-Containing Materials

Due to the inaccessibility or the destructive means that asbestos sampling requires, additional suspect ACMs may remain within the building hidden behind inaccessible areas that include, but are not limited to, sub-grade walls, structural members, topping slabs, sub-grade sealants, flooring located below underlayments, areas behind exterior walls, pipe trenches, and subsurface utilities, etc.

These areas were deemed inaccessible and were not assessed.

If these materials are discovered during construction activities, they should be presumed to contain asbestos and be treated as ACMs or be sampled immediately upon discovery and prior to disturbance for asbestos content by a certified asbestos inspector in accordance with 29 CFR 1926.1101.

Asbestos should be presumed to be present in each of the fire doors in the buildings.

5.3 Lead and Metals in Paint

Paint which contain detectable concentrations of lead (Pb) is considered “lead-containing paints”.

Since OSHA has no specific action level for lead in paint, all paint on the site found to have a measurable concentration of lead should be assumed to be lead containing. Work performed which may disturb lead-containing paint is regulated under OSHA as referenced under 29 CFR

1926.62. Lead-based paint is defined by the U.S. EPA and North Carolina as any paint or other surface coatings that contain lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight or 5,000 mg/kg.

A total of 34 paint chips were collected during the assessment. The paint chips were analyzed for the Resource Conservation and Recovery Act (RCRA) 8 metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver. The results indicated detectable concentrations of metals in each paint sample. The table below indications concentrations of metals showing the most variation

September 9, 2020 among the samples. These metals include barium (Ba), chromium (Cr) and lead (Pb). Barium and chromium concentrations in bold are considered elevated when compared to the remainder of the samples. There is currently not a North Carolina, EPA or OSHA standard for barium and total chromium concentrations in paint. However, these metals become regulated when they become airborne, or if the total chromium includes regulated concentrations of hexavalent chromium. Lead concentrations in bold are considered to be lead-based paint.

Summary of Paint Chip Results

Building Number

Sample ID Color Substrate Component Condition

Ba, Cr, and Pb Concentrations

(mg/kg)

Building 1699

1699 P1 Yellow Metal Railing Fair 30, 41, and 150

1699 P2 White Metal Equipment Fair 67, 160, and 910

1699 P3 White Brick Walls Fair 15, 16, 62

1699 P4 Brown Metal Doors Good 2,700, 270, 510

1699 P5 Orange Metal Ceiling Rafters Fair 67, 7,400, 100,000

1699 P6 White Drywall Walls Good 56, 6.5, 13

1699 P7 White Plaster Walls Poor to Fair <4.8, <4.8, <4.8

1699 P8 Black over

Red

Metal Stairs Fair 28, 200, 4,200

1699 P9 White CMU Walls Fair 39, 36, 580

Building 1670

1670 LBP1 White Metal Equipment Good 7.8, 18, 660

1670 LBP2 White CMU Walls Good 20, 23, 21

1670 LBP3 Black Metal Framing Good 20, <4.8, 21

1670 LBP4 Grey Concrete Stairs Good 21, 670, 27,000

1670 LBP5 White Plaster Walls Good 1,400, 62, 930

1670 LBP6 Grey Metal Interior Door Good 17, <4.5, 18

1670 LBP7 Green Plaster Walls Good 15, 5.3, 23

1670 LBP8 Grey Drywall Walls Good 99, <4.7, <4,7

1670 LBP9 Beige Plaster Walls Good 6.6, <5.0, 99

September 9, 2020

Sample ID Color Substrate Component Condition

Ba, Cr, and Pb Concentrations

(mg/kg)

1670 LBP10 Dark

Blue

CMU Walls Good 15, <4.7, <4.7

1670 LBP11 Black CMU Walls Good 35, 4.9, 270

Building 4157

4157 LBP1 White CMU Walls Fair 6.7, 14, 9.1

4157 LBP2 White/

Yellow

Metal Ceiling Rafters Fair 88, 3,900, 59

4157 LBP3 Grey/

Grey

Metal Doors Good 22, 10,000, 82

4157 LBP4 Brown Metal Doors Good 250, <19, 21

4157 LBP5 Grey Metal Vault Door Good 1,200, 270, 68

Building 4158

4158 LBP1 Brown Metal Equipment Fair 230, 3,800, 490

4158 LBP2 White CMU Walls Poor 15, 7.7, 17

4158 LBP3 White Metal Ceiling Poor 24, 5,200, 380

Building 4159

4159 LBP1 Brown Metal Equipment Fair 130, 7,200, 47

4159 LBP2 White CMU Walls Poor 16, 6.6, 13

4159 LBP3 White Metal Ceiling Poor 35, 4,500, 700

Parking

Lot

LBP1 Yellow Concrete Parking

Bollard

Fair 610, 11,000, 49,000

Parking

Lot

LBP2 Yellow Concrete Steam

Exhaust/Curb

Fair 660, 3,800, 16,000

Parking

Lot

LBP3 Yellow Asphalt Parking Lines Fair 81, 5.8, 8.2

As summarized above, the metals concentrations for barium (Ba), chromium (Cr) and lead (Pb) showed the most variation among the samples. The samples with the greater concentrations were collected from the following materials:

• Building 1699

◦ Brown Metal Mechanical Room Doors (Elevated Barium)

September 9, 2020

◦ Orange Metal Ceiling Rafters Observed on First and Second Floor (Elevated Chromium and LBP)

◦ Black/Red Metal Stairs (Elevated Lead But Not LBP)

• Building 1670

◦ Grey On Concrete Stairs (LBP)

◦ White Plaster Walls (Elevated Barium)

• Building 4157

◦ White/Yellow Metal Ceiling Rafters in Mechanical Room (Elevated Chromium)

◦ Grey Metal Door at Mechanical Room (Elevated Chromium)

◦ Grey Metal Vault Door (Elevated Barium)

• Buildings 4158 and 4159

◦ Brown Metal Exterior Equipment (Elevated Chromium)

◦ White Metal Ceiling and Rafters (Elevated Chromium)

• Parking Lot Area

◦ Yellow Concrete Bollards Around Buildings (Elevated Chromium and LBP)

◦ Yellow Concrete Around Steam Pit (Elevated Chromium and LBP)

◦ Yellow Curbs In Parking Lots (Elevated Chromium and LBP)

Recommendations pertaining to regulatory requirements for working with elevated metal containing paint is discussed below in Section 5. Figures 10 through 16 depict the sample locations.

5.4 Suspect Mercury and PCB-Containing Equipment and Universal Waste

The disposal of fixtures and equipment in buildings which contain various substances such as mercury or lead are regulated by local, state, and federal regulation. Collectively most mercury-containing materials and batteries which may contain lead, along with stored pesticides are classified as "Universal Waste". The disposal of lamp ballasts and electrical transformers which contain suspect PCB-containing oils is also regulated at the state and federal level.

5.4.1 Suspect Polychlorinated Biphenyl (PCB) Containing Ballasts and Equipment

PCBs are toxic coolants or lubricating oils used in some electrical transformers and capacitors, hydraulically-operated equipment, light ballasts, and other similar equipment. As part of our survey, ECS attempted to identify potential liquid PCB containing materials and equipment.

Approximately 15% of the accessible light fixtures and fluorescent lamps were visually observed and documented as listed in the table below.

Building Number of Light Ballast

Number of Light Ballast Inspected

Number of Light Ballasts indicated as Non-PCB

Presumed PCB Ballast

4157 25 4 0 25

4158 3 0 Unknown 3

4159 3 0 Unknown 3

1670 103 16 16 0

1699 142 22 22 0

September 9, 2020

The lamp ballast observed in building 4157 did not contain PCB indicators on the labels. The ballasts observed in buildings 1670 and 1699 were labeled as "Non-PCB". ECS was unable to observe the ballasts in buildings 4158 and 4159. At this time it is recommended that all ballasts be assumed to be suspect PCB containing in buildings 1457, 1458, and 1459. Figures 17 through 21 depict the locations of the ballasts observed.

Four pad-mounted transformers were observed on the subject site as summarized below.

Pad-Mounted Transformer Location Label Indicator

Behind Building 1699 <50 ppm PCB (Non-PCB Containing)

Beside Building 4158 <50 ppm PCB (Non-PCB Containing)

Beside Building 4159 No label, assume PCB containing

Beside Building 4160 <50 ppm PCB (Non-PCB Containing)

Three of the transformers contained a label identifying the dielectric fluid as containing less than 50 parts per million (ppm) PCBs. The transformer by building 4159 did not contain a PCB indicator label.

According to 40 CFR § 761.3, Non-PCB transformer is a transformer that contains less than 50 ppm PCB. Therefore, this transformer should be considered to be PCB containing. Figure 22 depicts the locations of the observed transformers.

One composite caulk sample was collected from each building, and from the parking lot caulk to total six samples, as summarized below.

Sample Location Sample Material Sampled # PCB Concentration Estimated Quantity

Bld 1699 Door Caulk PCB1 <0.95 mg/kg per Aroclor 94 LF

Bld 4157 Window/Door Caulk PCB2 <0.99 mg/kg per Aroclor 150 LF

Bld 4159 Door Caulk PCB3 <0.98 mg/kg per Aroclor 20 LF

Bld 4158 Door Caulk PCB4 <0.97 mg/kg per Aroclor 20 LF

Bld 1670 Window/Door Caulk PCB5 210 mg/kg of Aroclor 1254 1,300 LF

Parking Lot Joint Caulk PCB6 <1.0 mg/kg per Aroclor Not Measured

Nine different Aroclor mixtures were analyzed for in each sample. Sample PCB5 indicated a concentration of 210 mg/kg for the PCB compound Aroclor 1254. The sample is a composite sample of the window and door caulk from building 1670. Materials with concentrations of PCB compounds greater than 50 mg/kg are considered to be PCB containing.According to 40 CFR § 761.3, PCB bulk

September 9, 2020 product waste means waste derived from manufactured products containing PCB in a non-liquid state, at any concentration where the concentration at the time of designation for disposal was ≥50 ppm PCBs.

5.4.2 Mercury-Containing Components

The EPA classifies mercury as both hazardous and toxic. The survey included observations for equipment which could contain mercury, such as thermostats, transformers, fluorescent lamps, and switch-containing devices.

As previously discussed and summarized below, fluorescent lamps were observed.

Building Total Number of Lamps

Number of Lamps Observed

Lamps Marked as Mercury Containing

Presumed Mercury Containing Lamps

4157 50 8 8 50

4158 6 6 6 6

4159 6 6 6 6

1670 206 32 32 206

1699 272 42 42 272

The fluorescent lamps may contain small quantities of mercury. Based on the amount of light fixtures observed, it can be assumed that approximately 540 fluorescent bulbs are present among the five buildings. Observations of the lamps revealed labeling identifying the bulbs as mercury containing.

Additionally, exterior pole mounted spot lights should be assumed to contain mercury lamps.

ECS observed the thermostats within the buildings for evidence of mercury and no mercury elements were noted. No mercury switches were observed. ECS observed additional equipment within the mechanical rooms of the buildings; however, no obvious mercury containing components were observed.

5.4.3 Other Materials Observed

As part of assessment, ODS and low-level radiation substances were noted if observed. Evidence of ODS were not noted during the assessment. Additionally, exits signed observed by ECS did not contain a radioactive indicator label.

5.5 Groundwater Monitoring Wells and Regulatory File Review

5.5.1 Regulatory File Review

A regulatory records search of ASTM standard databases typically used in a Phase I Environmental Site Assessment VII. The regulatory search report in the appendix includes additional details about the regulatory databases that were reviewed.