Amendment 0006 - P405 Revised Final Bldg HAZMAT Reports.pdf

REVISED FINAL ASBESTOS-CONTAINING MATERIALS SURVEY, LEAD-BASED

PAINT SURVEY, METAL-BASED COATINGS SURVEY, HAZARDOUS MATERIALS

SURVEY, AND WASTE CHARACTERIZATION FOR LEAD

BUILDING 7012 – STORAGE, P-405 – CHOSIN RANGE

MARINE CORPS RECRUIT DEPOT PARRIS ISLAND

PARRIS ISLAND, BEAUFORT COUNTY, SOUTH CAROLINA

LEO A DALY PROJECT No.: 092-10063-044

CONTRACT No.: N69450-14-D-0025 DELIVERY ORDER: N4008519F6395

PREPARED FOR:

Leo A Daly 10 Tenth Street N.E., Suite 200

Atlanta, Georgia 30309

(404) 874-8333

PREPARED BY:

Aerostar SES LLC 3550 St. Johns Bluff Road South

Jacksonville, Florida 32224

(904) 565-2820

ASL Project # M3010.1385.0022.17

March 26, 2021

SIGNATURE OF ENVIRONMENTAL PROFESSIONALS

This is to certify that the Revised Final Report for the Asbestos-Containing Materials Survey, Lead-Based Paint Survey, Metal-Based Coatings Survey, Hazardous Materials Survey, and Waste Characterization for Lead of Building 7012 – Storage, P-405 – Chosin Range, located at Marine Corps Recruit Depot Parris Island, Parris Island, Beaufort County, South Carolina, has been examined by the undersigned.

DATE: March 26, 2021 SIGNATURE:

John Flanagan Aerostar SES LLC EPA Certified Risk Assessor License No. LBP-R-I208414-1

Miles Eckert Aerostar SES LLC SC DHEC Asbestos Inspector Certification No. BI-01055 EPA Certified Risk Assessor License No. LBP-R-124717-1

John H. Hubbard Jr., CSP, LAC

Senior Project Manager

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page i

TABLE OF CONTENTS

SIGNATURE OF ENVIRONMENTAL PROFESSIONALS

1.0 EXECUTIVE SUMMARY

1.1 Site Name

1.2 Name and Certifications of Inspectors

1.3 Site Description and Activities

1.4 Findings and Results

1.4.1 Asbestos Survey

1.4.2 Lead-Based Paint Survey

1.4.3 Metal-Based Coatings Survey

1.4.4 Waste Characterization

1.4.5 Hazardous Material Survey

2.0 INTRODUCTION

3.0 REGULATORY SUMMARY

3.1 Asbestos

3.1.1 Environmental Protection Agency

3.1.2 Occupational Safety and Health Administration

3.1.3 State of South Carolina

3.2 Lead-Based Paint

3.2.1 Environmental Protection Agency

3.2.2 Occupational Safety and Health Administration

3.2.3 U.S. Department of Housing and Urban Development

3.2.4 State of South Carolina

3.3 RCRA Metals

3.3.1 Occupational Safety and Health Administration

3.3.2 State of South Carolina

3.4 Hazardous Materials

3.4.1 Environmental Protection Agency

3.4.2 United States Department of Transportation

3.4.3 State of South Carolina

4.0 METHODS OF INVESTIGATION

4.1 Asbestos Survey

4.2 Lead-Based Paint Survey

4.3 Metal-Based Coatings Survey

4.4 Waste Characterization

4.5 Hazardous Materials Survey

5.0 RESULTS

5.1 Asbestos Survey Results

5.2 Lead-Based Paint Survey Results

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page ii

5.3 Metal-Based Coatings Sample Results

5.4 Waste Characterization Results

5.5 Hazardous Materials Survey Results

6.0 LIMITATIONS

7.0 CONCLUSIONS AND RECOMMENDATIONS

7.1 Asbestos-Containing Materials

7.2 Lead-Based Paint

7.3 Metal-Based Coatings

7.4 Waste Characterization

7.5 Hazardous Materials

TABLES

TABLE 1 Summary of Asbestos Survey TABLE 2 Summary of XRF Survey TABLE 3 Summary of Metal-Based Coatings Sample Results TABLE 4 Summary of Hazardous Materials Survey

FIGURES

FIGURE 1 Homogeneous Area Sample Locations FIGURE 2 Asbestos-Containing Materials Locations FIGURE 3 XRF and Metal-Based Coatings Sample Locations

APPENDICES

APPENDIX A Certifications APPENDIX B Laboratory Analytical Results APPENDIX C Asbestos Photographic Documentation APPENDIX D Lead-Based Paint and Metal-Based Coatings Photographic Documentation APPENDIX E Hazardous Materials Photographic Documentation

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 1

1.0 EXECUTIVE SUMMARY

1.1 Site Name

Building 7012 – Storage, P-405 – Chosin Range Marine Corps Recruit Depot Parris Island Parris Island, Beaufort County, South Carolina L.A.D. Project No.: 092-10063-044 Contract No.: N69450-14-D-0025 Delivery Order: N4008519F6395

1.2 Name and Certifications of Inspectors

Miles Eckert John Flanagan SC DHEC Asbestos Inspector EPA Certified Risk Assessor Certification No. BI-01055 License No. LBP-R-I208414-1 EPA Certified Risk Assessor License No. LBP-R-124717-1

1.3 Site Description and Activities

On October 16, 2019, Aerostar SES LLC (ASL) conducted an Asbestos-Containing Materials (ACM), Lead-Based Paint (LBP), Metal-Based Coatings (MBC), Hazardous Materials Survey, and Waste Characterization for Lead of Building 7012, P-405 – Chosin Range, located at Marine Corps Recruit Depot (MCRD) Parris Island, Parris Island, Beaufort County, South Carolina. The surveys included all accessible areas throughout the building’s exterior and interior. The building is scheduled for demolition.

1.4 Findings and Results

The following tables summarize the findings throughout the building and identifies material requiring special handling:

Building Friable

ACM

Non-friable Category I

ACM

Non-friable Category II

ACM

Material Containing

<1% Asbestos

LBP

≥1.0 mg/cm2

Hazardous Material

Hazardous Waste for Lead >5.0 mg/L

7012 – Storage No No No No No† Yes** No

* Materials must be handled in accordance with 40 CFR 61 Subpart M and 29 CFR 1926.1101 ** Material must be handled in accordance with applicable sections of 40 CFR 260-299 or 40 CFR 761 † Lead concentrations were also detected <1.0 mg/cm2 which must be handled in accordance with OSHA Standard 29 CFR 1926.62

Arsenic (mg/Kg)

Barium (mg/Kg)

Cadmium (mg/Kg)

Chromium (mg/Kg)

Lead (mg/Kg)

Selenium (mg/Kg)

Silver (mg/Kg)

Mercury (mg/Kg)

7012 – Storage

No

Yes††

Yes†

† Lead concentrations above threshold were detected and must be handled in accordance with 29 CFR 1926.62 †† Must be handled in accordance with applicable OSHA standards

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 2

1.4.1 Asbestos Survey

A South Carolina Department of Health and Environmental Control (SC DHEC)-licensed Asbestos Inspector conducted an asbestos survey of Building 7012 to identify the locations, quantities, and conditions of ACMs. The asbestos survey was performed throughout all accessible areas of the building’s exterior and interior.

A total of 16 materials were identified in Building 7012. A total of 52 samples were collected and submitted to EMSL Analytical, Inc. (EMSL) in Cinnaminson, New Jersey, for analysis by Polarized Light Microscopy (PLM). In accordance with SC DHEC Regulation 61-86.1, Section VI.D.2, negative PLM results for Non-friable Organically Bound (NOB) materials were verified by Transmission Electron Microscopy (TEM) analysis in accordance with ASTM Standard E2356-

14. A total of six samples were reanalyzed by TEM analysis. Analytical results of the samples revealed that none of the materials identified and sampled were found to contain asbestos by PLM or TEM.

Suspect ACMs encountered during renovation/demolition activities that are not identified in this re-inspection should be assumed to contain asbestos or be sampled by a SC DHEC-licensed asbestos inspector and analyzed by an accredited laboratory.

1.4.2 Lead-Based Paint Survey

A LBP survey was performed throughout the building using a Niton XLp 302A series X-Ray Fluorescence (XRF) portable spectrum analyzer, serial number 23358. The LBP inspection was performed by an Environmental Protection Agency (EPA)-licensed Risk Assessor.

No lead concentrations equal to or greater than 1.0 milligrams per centimeter squared (mg/cm2) were found throughout the building. Detectable concentrations of lead below 1.0 mg/cm2 were found in two XRF sample locations. Plaster walls exhibited detectable lead concentrations less than 1.0 mg/cm2.

Handling of paints or coatings with lead must be conducted in accordance with the Occupational Safety and Health Administration’s (OSHA) Construction Standard for Lead 29 Code of Federal Regulations (CFR) 1926.62. Construction and demolition (C&D) debris from commercial or industrial sites that is contaminated with lead-based paint must be managed as Resource Conservation and Recovery Act (RCRA) hazardous waste if a representative sample analyzed by Toxicity Characteristic Leaching Procedure (TCLP) meets the EPA’s toxicity characteristic outlined in 40 CFR 261.24.

1.4.3 Metal-Based Coatings Survey

An EPA-licensed Paint Inspector/Risk Assessor performed a MBC survey throughout Building 7012.

A total of two MBC samples were collected from a cinder block wall and a metal door system as determined by the color, substrate, and location within Building 7012. During sample collection, the inspector recorded location, component, substrate, condition, and color. Samples included all

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 3 layers of coatings to the substrate material. Samples were submitted to an American Industrial Hygiene Association (AIHA)-accredited laboratory under the Environmental Lead Laboratory Accreditation Program (ELLAP) for analysis of 8 RCRA metals by EPA Method 6010D for Inductively Coupled Plasma (ICP) or by EPA Method 7471B for Cold Vapor Atomic Absorption

(CVAA).

Detectable concentrations of RCRA metals barium, chromium, lead, and silver were found in both of the samples collected (Samples 7012-PC-1 and 7012-PC-2).

Handling of paints or coatings with lead must be conducted in accordance with the OSHA Construction Standard for Lead 29 CFR 1926.62. C&D debris from commercial or industrial sites that is contaminated with LBP must be managed as RCRA hazardous waste if a representative sample analyzed by TCLP meets the EPA’s toxicity characteristic outlined in 40 CFR 261.24.

Any paint or coating with detectable concentrations of the RCRA metals that is subjected to cutting, abrading, welding, scraping, and/or sanding, must be handled in accordance with applicable OSHA standards (29 CFR 1926.55, 1926.62, 1926.1118, 1926.1126, and 1926.1127) to prevent employee exposure.

1.4.4 Waste Characterization

Building components to be demolished and disposed of as part of this project were representatively sampled from Building 7012 and analyzed for TCLP lead in accordance with the provisions of 40 CFR 261, Subpart C. One composite sample (7012-TCLP) was collected. The laboratory result of TCLP for lead analysis for the composite sample collected was <0.40 milligrams per liter (mg/L), which is less than the EPA toxicity characteristic level of hazardous material for lead of

5.0 mg/L. Based on the waste characterization analytical result of the composite sample, construction debris generated by demolition or renovation activities may be disposed of as non-hazardous waste.

Potentially hazardous material should be handled in accordance with the applicable sections of the EPA’s Hazardous Waste Regulations, 40 CFR 260-299.

1.4.5 Hazardous Material Survey

ASL inspected light fixtures, thermostats, and other components and systems throughout Building 7012 to evaluate for the presence of hazardous materials which may require special handling.

Approximately ten percent of the light fixtures were dismantled to determine if lighting ballasts were present, if labeling included information regarding polychlorinated biphenyl (PCB) content, as required by EPA regulation 40 CFR 761.45, and if bulbs contained mercury.

ASL observed the following:

One type of 4’fluorescent bulb. According to the manufacturer, the bulbs contain mercury;

however, the bulbs are TCLP compliant.

One type of light ballast in 4’ fluorescent light fixtures labeled “No PCBs.”

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 4

One type of Compact Fluorescent Light (CFL) bulb. According to the manufacturer, the bulbs contain mercury; however, the bulbs are TCLP compliant.

One type of incandescent bulb. Incandescent lights do not require special handling under the Universal Waste Regulations.

ASL also conducted an inventory of potential hazardous components and used hazardous materials within interior and exterior spaces of Building 7012. Examples of items that may contain hazardous and other regulated components include, but are not limited to: mercury thermostats, switches and other devices, PCB and non-PCB transformers, batteries, emergency exit signs, Heating, Ventilation, and Air Conditioning (HVAC) systems, refrigerators, lead-lined vent pipes, and oil-containing equipment.

Emergency exit signs with Light-Emitting Diode (LED) lighting. The exit signs contain Nickel-Cadmium (NiCad) back-up batteries. No indications that the signs contain tritium were observed.

Potentially hazardous material should be handled in accordance with the applicable sections of the EPA’s Hazardous Waste Regulations, 40 CFR 260-299 or the PCBs Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions, 40 CFR 761.

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 5

2.0 INTRODUCTION

On October 16, 2019, ASL conducted surveys for ACM, LBP, MBC, hazardous materials, and waste characterization for lead of Building 7012 – Storage, P-405 – Chosin Range, located at MCRD Parris Island, Parris Island, Beaufort County, South Carolina. The surveys included all accessible areas throughout the building’s exterior and interior. The building is scheduled for demolition. The ACM survey was performed by a SC DHEC-licensed Asbestos Inspector. The LBP and MBC inspections were performed by an EPA-licensed Risk Assessor. Copies of licenses are included in Appendix A.

Building 7012 is a single-story, 1,890-square foot building currently used as storage. The date of construction is unknown. The building construction is slab on grade. Exterior finishes include wood and plaster, and a rolled asphalt roof. Interior finishes include concrete block walls, a concrete ceiling, and a concrete floor. The building is concrete block frame construction. No interior insulation, HVAC, or piping was observed.

3.0 REGULATORY SUMMARY

3.1 Asbestos

3.1.1 Environmental Protection Agency

The EPA has published a list of hazardous air pollutants and promulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations. Since asbestos presents a significant risk to human health as a result of air emissions from one or more source categories, it is therefore considered a hazardous air pollutant. The Asbestos NESHAP Regulation (40 CFR 61, Subpart M) addresses milling, manufacturing and fabricating operations, demolition and renovation activities, waste disposal issues, active and inactive waste disposal sites and asbestos conversion processes.

Friable ACM is defined by the Asbestos NESHAP regulations as any material containing greater than 1% asbestos as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM, that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure (Sec. 61.141).

Non-friable ACM is any material containing greater than 1% asbestos as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure (Sec. 61.141).

EPA also defines two categories of non-friable ACM: Category I and Category II non-friable

ACM.

Category I non-friable ACM is any asbestos-containing packing, gasket, mastic, resilient floor covering or asphalt roofing product which contains greater than 1% asbestos as determined using PLM according to the method specified in Appendix E, Subpart E, 40 CFR Part 763 (Sec. 61.141).

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 6

Category II non-friable ACM is any material, excluding Category I non-friable ACM, containing greater than 1% asbestos as determined using PLM according to the methods specified in Appendix E, Subpart E, 40 CFR Part 763 (Sec. 61.141), that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated Asbestos-Containing Material (RACM) is: (a) friable ACM, (b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

Category I non-friable ACM must be inspected and tested for friability if it is in poor condition prior to demolition to determine whether or not it is subject to NESHAP. If the ACM is friable, it must be handled in accordance with NESHAP. Asbestos-containing packings, gaskets, resilient floor coverings and asphalt roofing materials must be removed prior to demolition only if they are in poor condition and are friable.

NESHAP further requires that if a facility is demolished by intentional burning, all of the facility's ACM, including Category I and II non-friable ACM, must be removed prior to burning (Sec.

61.145(c)(10)).

If Category I or Category II non-friable ACM is to be sanded, ground, cut, or abraded, the material is considered RACM and the owner or operator must abide by the following (Sec. 61.145(c)(1)):

(i) Adequately wet the material during the sanding, grinding, cutting or abrading operations;

(ii) Comply with the requirements of 61.145(c)(3)(i) if wetting would unavoidably damage equipment or present a safety hazard; and

(iii) Handle asbestos material produced by the sanding, grinding, cutting, or abrading, as asbestos-containing waste material subject to the waste handling and collection provisions of Section 61.150.

Except for the following, Section 61.145(c) of the Asbestos NESHAP regulation requires that each owner or operator of a demolition or renovation activity involving RACM remove all such material from a facility being demolished or renovated before any activity begins that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal.

ACM need not be removed before demolition or renovation if it:

(i) Is a Category I non-friable ACM that has not become friable;

(ii) Is on a facility component that is encased in concrete or other similarly hard material and is adequately wet whenever exposed during demolition or renovation;

(iii) Was not accessible for testing and therefore was not discovered until after demolition or renovation began and, as a result of the demolition or renovation, cannot be safely removed. If not removed for safety reasons, the exposed RACM and any asbestos-

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 7 contaminated debris must be treated as asbestos-containing waste material and kept adequately wet at all times until disposed of; or

(iv) Is a Category II non-friable ACM and the probability is low that the material will become crumbled, pulverized, or reduced to powder during demolition or renovation.

3.1.2 Occupational Safety and Health Administration

OSHA regulates asbestos exposure during all construction work including, but not limited to, the following:

Demolition or salvage of structures where asbestos is present;

Removal or encapsulation of materials containing asbestos;

Construction, alteration, repair, maintenance, or renovation of structures, substrates, or portions thereof, that contain asbestos;

Installation of products containing asbestos;

Asbestos spill/emergency cleanup; and Transportation, disposal, storage, containment of and housekeeping activities involving asbestos or products containing asbestos, on the site or location at which construction activities are performed.

The OSHA Standard 29 CFR 1926.1101 requires the use of engineering controls, work practices, and personal protective equipment to reduce or eliminate employee exposure to asbestos. The OSHA standard does not apply to asbestos-containing asphalt roof coatings, cements and mastics.

3.1.3 State of South Carolina

SC DHEC Regulation 61-86.1, Standards of Performance for Asbestos Projects, covers all asbestos-related activities including, but not limited to, the following: Definitions, Applicability, Personnel Licensing Requirements, Asbestos Projects/General Information, Asbestos Building Inspection Requirements, Disposal Requirements, NESHAP Projects, Small Projects, Minor Projects, Operation and Maintenance Activities, Standards for Demolition, Encapsulation and Enclosure, Training Requirements, and Records.

3.2 Lead-Based Paint

3.2.1 Environmental Protection Agency

The EPA requires for C&D debris contaminated with LBP be managed dependent upon the source and type of debris and hazard characteristics. C&D debris from commercial or industrial sites that is contaminated with lead-based paint must be managed as RCRA hazardous waste if a representative sample meets the EPA’s toxicity characteristic outlined in 40 CFR 261.24. Lead-based paint waste from removal or remediation activities, including debris, paint chips, dust, and sludges that exhibit the toxicity characteristic must be managed and disposed of as a RCRA hazardous waste. A representative sample of debris and waste should be characterized using the TCLP, test Method 1311 as described in “Test Methods for Evaluating Solid Waste, Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 8

Physical/Chemical Methods,” EPA Publication SW-846, as incorporated by reference in 40 CFR

260.11 and analyzed by an accredited testing laboratory.

3.2.2 Occupational Safety and Health Administration

OSHA regulates lead exposure during all construction work including, but not limited to, the following:

Demolition or salvage of structures where lead is present;

Removal or encapsulation of materials containing lead;

Construction, alteration, repair, maintenance, or renovation of structures, substrates, or portions thereof, that contain lead;

Installation of products containing lead;

Lead spill/emergency cleanup; and Transportation, disposal, storage, containment of and housekeeping activities involving products containing lead, on the site or location at which construction activities are performed.

The OSHA Standard 29 CFR 1926.62 requires the use of engineering controls, work practices, and personal protective equipment to reduce or eliminate employee exposure to lead.

3.2.3 U.S. Department of Housing and Urban Development

According to the U.S. Department of Housing and Urban Development (HUD) guidelines 20 CFR Part 35, LBP is defined as paint containing a lead concentration greater than or equal to 0.5 % weight (wt.) by laboratory analysis. HUD’s definition of LBP cannot be used to determine safe working conditions under OSHA. OSHA’s Lead in Construction Standard, 29 CFR 1926.62, was intended to apply to any detectable concentration of lead in paint by laboratory analysis. OSHA’s only accepted methodology for determining an employee’s exposure to airborne lead contaminants is through personal air monitoring. Any paint with detectable concentrations of lead by laboratory analysis that is subjected to cutting, abrading, welding, scraping, and/or sanding, must be handled in accordance with 29 CFR 1926.62, to prevent employee exposure.

3.2.4 State of South Carolina

Title IV of the Toxic Substances Control Act (TSCA), as well as other authorities in the Residential Lead-Based Paint Hazard Reduction Act of 1992, directs EPA to regulate LBP hazards.

The EPA administers the LBP program only in areas where states, territories or tribes are not authorized by the EPA to operate their own lead abatement programs. South Carolina is a state administered by the EPA, and the provisions set forth under the EPA’s LBP regulations have been adopted by the State of South Carolina.

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 9

3.3 RCRA Metals

3.3.1 Occupational Safety and Health Administration

Any paint coating with detectable concentrations of RCRA metals by laboratory analysis that is subjected to cutting, abrading, welding, scraping, and/or sanding must be handled in accordance with applicable OSHA standards. In addition to programs for safety and health, training, medical surveillance, decontamination, new technology, and emergency response, employers at RCRA sites also need the following:

A written hazard communication program meeting the requirements of 29 CFR 1910.1200.

Procedures to effectively control and handle drums and containers.

OSHA requirements for the use of engineering controls, work practices, and personal protective equipment to reduce or eliminate employee exposure are outlined in Standard 29 CFR 1926.62 for lead, 29 CFR 1926.1118 for arsenic, 29 CFR 1926.1126 for chromium, 29 CFR 1926.1127 for cadmium, and 29 CFR 1910.1000 for barium, selenium, silver, and mercury.

3.3.2 State of South Carolina

South Carolina Hazardous Waste Management Regulations, Regulation 61-79, covers all hazardous waste related activities including, but not limited to: Permit Administration; Hazardous Waste Management System; Identification and Listing of Hazardous Waste; Standards Applicable to Generators and Transporters of Hazardous Waste; Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities; Interim Status for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities; Standards for the Management of Specific Hazardous Wastes and Specific Types of Hazardous Waste Management Facilities; Land Disposal Restrictions; Permit Requirements; and the Universal Waste Rule. South Carolina Hazardous Waste Management Location Standards, Regulation 61-104, covers all hazardous waste related activities including, but not limited to: Applicability, Definitions, Location Criteria, Certification, and Severability.

3.4 Hazardous Materials

3.4.1 Environmental Protection Agency

EPA's universal waste regulations streamline hazardous waste management standards for federally designated "universal wastes," which include:

batteries pesticides mercury-containing equipment bulbs (lamps) ballasts

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 10

The regulations govern the collection and management of these wastes, thus facilitating environmentally sound collection and proper recycling or treatment.

The regulations also ease the regulatory burden on retail stores and others that wish to collect these wastes and encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors. In addition, the regulations also ensure that the wastes subject to this system will go to appropriate treatment or recycling facilities pursuant to the full hazardous waste regulatory controls.

The federal universal waste regulations are set forth in 40 CFR part 260-299. Equipment found to contain mercury, such as switches or bulbs must be handled in accordance with 40 CFR Part 273.

Materials found to contain PCBs, such as ballasts, must be handled in accordance with 40 CFR Part 761. States can modify the universal waste rule and add additional universal waste(s) in individual state regulations.

Under Section 608 of the Clean Air Act of 1990 (CAA), EPA has established regulations (40 CFR Part 82, Subpart F) that:

Require service practices that maximize recovery and recycling of ozone-depleting substances (both chlorofluorocarbons [CFCs] and hydro chlorofluorocarbons [HCFCs] and their blends) during the servicing and disposal of air-conditioning and refrigeration equipment.

Set certification requirements for refrigerant recycling and recovery equipment, technicians, and refrigerant reclaimers.

Restrict the sale of refrigerant to certified technicians.

Require persons servicing or disposing of air-conditioning and refrigeration equipment to certify to EPA that they have acquired refrigerant recovery and/or recycling equipment and are complying with the requirements of the rule.

Require the repair of substantial leaks in air-conditioning and refrigeration equipment with a refrigerant charge greater than 50 pounds.

Establish safe disposal requirements to ensure removal of refrigerants from goods that enter the waste stream with the charge intact (e.g., motor vehicle air conditioners, home refrigerators, and room air conditioners).

Effective July 1, 1992, Section 608 of the Act prohibits individuals from intentionally venting ozone-depleting substances used as refrigerants (generally CFCs and HCFCs) into the atmosphere while maintaining, servicing, repairing, or disposing of air-conditioning or refrigeration equipment (appliances). Only four types of releases are permitted under the prohibition:

De minimis quantities of refrigerant released in the course of making good faith attempts to recapture and recycle or safely dispose of refrigerant.

Refrigerants emitted in the course of normal operation of air-conditioning and refrigeration equipment (as opposed to during the maintenance, servicing, repair, or disposal of this equipment) such as from mechanical purging and leaks. However, EPA requires the repair of leaks above a certain size in large equipment.

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 11

Releases of CFCs or HCFCs that are not used as refrigerants. For instance, mixtures of nitrogen and R-22 that are used as holding charges or as leak test gases may be released.

Small releases of refrigerant that result from purging hoses or from connecting or disconnecting hoses to charge or service appliances will not be considered violations of the prohibition on venting. However, recovery and recycling equipment manufactured after November 15, 1993, must be equipped with low-loss fittings.

3.4.2 United States Department of Transportation

The Secretary of the Department of Transportation (DOT) receives the authority to regulate the transportation of hazardous materials from the Hazardous Materials Transportation Act (HMTA), as amended and codified in 49 United States Code (U.S.C.) 5101 et seq. The Secretary is authorized to issue regulations to implement the requirements of 49 U.S.C. The Pipeline and Hazardous Materials Safety Administration (PHMSA) (formerly the Research and Special Provisions Administration [RSPA]) was delegated the responsibility to write the hazardous materials regulations, which are contained in 49 CFR Parts 100-180. In order to accomplish his responsibilities under the HMTA the Secretary "...may authorize any officer, employee, or agent to enter upon inspect, and examine, at reasonable times and in a reasonable manner, the records and properties of persons to the extent such records and properties relate to: (1) the manufacture, fabrication, marking, maintenance, reconditioning, repair, testing, or distribution of packages or containers for use by any ‘person’ in the transportation of hazardous materials in commerce; or (2) the transportation or shipment by any ‘person’ of hazardous materials in ‘commerce.’”

The hazardous materials regulations are applicable to the transportation of hazardous materials in commerce and their offering to:

Interstate, intrastate, and foreign carriers by rail car, aircraft, motor vehicle and vessel The representation that a hazardous material is present in a package, container, rail car, aircraft, motor vehicle or vessel The manufacture, fabrication, marking, maintenance, reconditioning, repairing or testing of a package or container which is represented, marked, certified or sold for use in the transportation of hazardous materials (49 CFR 171.1(a))

Most federal agencies are considered "offerors" when they ship hazardous materials by commercial carriers. In those rare instances where governmental agencies transport hazardous materials in commerce on government vehicles/aircraft, the agency is also considered a carrier.

Contractors are fully subject to the requirements of the Federal hazardous materials transportation law.

3.4.3 State of South Carolina

South Carolina Hazardous Waste Management Regulations, Regulation 61-79, covers all hazardous waste related activities including, but not limited to: Permit Administration; Hazardous Waste Management System; Identification and Listing of Hazardous Waste; Standards Applicable to Generators and Transporters of Hazardous Waste; Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities; Interim Status for Owners and

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 12

Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities; Standards for the Management of Specific Hazardous Wastes and Specific Types of Hazardous Waste Management Facilities; Land Disposal Restrictions; Permit Requirements; and the Universal Waste Rule. South Carolina Hazardous Waste Management Location Standards, Regulation 61-104, covers all hazardous waste related activities including, but not limited to: Applicability, Definitions, Location Criteria, Certification, and Severability.

4.0 METHODS OF INVESTIGATION

4.1 Asbestos Survey

Sampling protocols set forth by the EPA under 40 CFR 763.86 were generally followed during the inspection. The asbestos survey was performed by observing, touching, and sampling accessible suspect building materials throughout the facility. The purpose of this survey was to locate and identify suspect ACMs, to quantify the material, and to separate it into unique areas for further assessment. The condition and location of representative suspect materials were defined throughout the facility.

Bulk asbestos sampling procedures utilized for the collection of suspect ACMs first required the establishment of a homogeneous sampling area. A homogeneous sampling area is defined as an area of material of the same type (texture and color) which was applied during the same general time period. Each individual sampling area was then examined and representative samples of suspect materials were collected. The U.S. EPA has published guidelines and recommendations pertaining to surveying and sampling for friable ACMs. The guidelines were followed during the survey where appropriate. U.S. EPA publications and current regulations mainly address friable materials, such as surface finishes and structural fireproofing. The samples were analyzed by PLM with dispersion staining according to EPA Method 600/R-93/116. The PLM test is an EPA-approved analytical method for asbestos identification. Bulk samples were collected by a SC DHEC-licensed Asbestos Inspector, and analyzed by a laboratory that maintains accreditation through the National Voluntary Laboratory Accreditation Program (NVLAP) for the analysis of bulk samples by PLM. The test uses the unique optical properties of mineral forms in the samples to specifically identify the various asbestos types.

In accordance with SC DHEC Regulation 61-86.1, Section VI.D.2, negative PLM results for NOB materials were verified by TEM analysis in accordance with ASTM Standard E2356-14.

Where distinct layers were present, bulk samples were collected to represent each individual layer of the suspect material. Mastic and/or other adhesive substances were included when possible. At the time of sample collection, the inspector noted material type, approximate amount, sampling locations, and condition of the materials.

Samples were labeled with a unique alphanumeric identification system (xxxx-yy-zz). The first set of characters (xxxx) indicates the building number assigned by the facility. The second set of numbers (yy) indicates the homogeneous area designation assigned by the asbestos inspector. The third set of numbers (zz) is the individual sample identification number. Where distinct layers were separated, a letter (A, B, C) was assigned for each additional layer analyzed by the laboratory.

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 13

The surface area of the samples was adequately wetted prior to sample collection. No visible emissions were allowed. Samples were submitted to EMSL for analysis by PLM. A copy of the laboratory analytical results and the appropriate Chain of Custody Record is included in Appendix B.

4.2 Lead-Based Paint Survey

The LBP inspection was performed using Niton XLp 302A series XRF portable spectrum analyzer, serial number 23358. The Niton XLp 302A series XRF uses a Cadmium-109 radioactive source.

The source undergoes a radioactive decay, in a two-step process, that releases x-rays and gamma rays with enough energy to cause both K-shell and L-shell fluorescence. During this process, if the primary x-ray emitted by the XRF has sufficient energy, electrons are ejected from the inner shells of the lead atoms, creating vacancies that cause an unstable condition for the atoms. As the atoms return to their stable condition, electrons from the outer shells are transferred to the inner shells releasing energy. The Niton XLp 302A series XRF uses dual detectors to read the K-shell and L-shell energy spectrums that are produced.

XRF sampling results were obtained from each sampling area throughout the buildings. The sampling locations were determined by the color of paint, substrate, and location throughout the buildings. The sampling locations are identified by room number or description, source, substrate, feature, condition of paint, and color. The building was arbitrarily designated as follows: “A” northwest; and “B”, “C”, and “D” proceeding clockwise in relation to side. The XRF sample results are reported in mg/cm2. Calibration checks were performed immediately before, after, and every four hours during the LBP survey to ensure the sample results were within the tolerance limits of the instrument’s Performance Characteristic Sheet.

4.3 Metal-Based Coatings Survey

MBC samples were collected by an EPA-licensed Paint Inspector/Risk Assessor from surfaces which may be subject to abrasive blasting, torch cutting, welding, or other aggressive handling.

Sample locations were determined by the color of paint, substrate, component, and location within Building 7012. During sample collection, the inspector recorded location, component, substrate, condition of paint, and color. Samples included all layers of paint to the substrate material.

Samples were submitted to an AIHA-accredited laboratory under the ELLAP for analysis of 8 RCRA metals by EPA Method 6010D for ICP or by EPA Method 7471B for CVAA. A copy of the laboratory analytical results and the appropriate Chain of Custody Record is included in Appendix B.

4.4 Waste Characterization

One composite sample of building components to be demolished and disposed of was collected to determine waste characterization for lead. The sample was submitted to EMSL for analysis using TCLP for lead in accordance with the provisions of 40 CFR 261, Subpart C. The sample was collected and analyzed to provide a determination of the hazardous waste characteristics of construction debris resulting from the demolition of the materials. A copy of the laboratory analytical result and the appropriate Chain of Custody Record is included in Appendix B.

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 14

4.5 Hazardous Materials Survey

ASL conducted a survey for potential hazardous components and used hazardous materials. The survey consisted of a visual inspection of the building, including accessible interior and exterior portions where hazardous materials, wastes, and/or components may be present. ASL conducted an inventory of potential hazardous components and used hazardous materials within interior and exterior spaces of the building. Examples of items that may contain hazardous and other regulated components include, but are not limited to: fluorescent and high intensity discharge (HID) lamps, mercury thermostats, switches and other devices, PCB and non-PCB lighting ballasts, batteries, emergency exit signs, HVAC systems, refrigerators, lead-lined vent pipes, and oil-containing equipment. A portion (approximately ten percent) of light fixtures were dismantled. All switches that may contain mercury were dismantled and inspected. Exit signs, systems with refrigerant, and other stationary equipment was visually inspected for placards or manufacturer labels identifying contents. Safety Data Sheets (SDS) were reviewed, when available.

5.0 RESULTS

5.1 Asbestos Survey Results

A SC DHEC-licensed Asbestos Inspector conducted an asbestos survey of Building 7012 to identify the locations, quantities, and conditions of ACMs. The asbestos survey was performed throughout all accessible areas of the building’s exterior and interior.

The following 16 materials were identified in Building 7012:

Caulk (2 types) Concrete (2 types) Block Wall Coating (2 types) (Material described as “Texture” by the laboratory) Expansion Joint Plaster (2 types) Rolled Asphalt Roof Tar Felt Tar Paper Felt Foam Drywall

A total of 52 samples were collected and submitted to EMSL for analysis by PLM. Negative PLM results for NOB materials were verified by TEM analysis. A total of six samples were reanalyzed by TEM analysis. Analytical results of the samples revealed that none of the materials identified and sampled were found to contain asbestos by PLM or TEM.

The results of the asbestos survey are detailed in Table 1. Homogeneous area sample locations are shown on Figure 1. ACM locations are shown on Figure 2. Inspector and laboratory credentials are provided in Appendix A. Copies of the laboratory analytical results and the

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 15 appropriate Chain of Custody Record are included in Appendix B. Asbestos Photographic Documentation is included in Appendix C.

5.2 Lead-Based Paint Survey Results

Based on the HUD guidelines, a laboratory analysis of a paint chip sample equal to or greater than

0.5 % wt., or an XRF sample equal to or greater than 1.0 mg/cm2 is the action level at which the paint is considered to be LBP. XRF sample readings (Pbc ± Pbc Error) are reported as lead concentration (Pbc) in mg/cm2 plus or minus the statistical deviation (Pbc Error) that allows for 95% confidence. To determine the XRF sample result to be positive or negative, the XRF sample readings (Pbc ± Pbc Error) were reported as a 95% confidence interval compared to HUD’s definition of LBP (1.0 mg/cm2). HUD’s definition of LBP cannot be used to determine safe working conditions under OSHA. OSHA’s Lead in Construction Standard, 29 CFR 1926.62, was intended to apply to any detectable concentration of lead in paint by laboratory analysis.

None of the building components exhibited XRF sample results containing lead concentrations greater than or equal to 1.0 mg/cm2.

Detectable concentrations of lead below the level which HUD defines as LBP (1.0 mg/cm2) were recorded in the following building components:

Beige plaster walls on the exterior

XRF Sample results are provided in Table 2. XRF Sample locations are shown on Figure 3.

Inspector credentials are provided in Appendix A. LBP Photographic Documentation is included in Appendix D.

5.3 Metal-Based Coatings Sample Results

A total of two MBC samples were collected from a cinder block wall and a metal door system as determined by the color, substrate, and location within Building 7012. Detectable concentrations of RCRA metals were found in the following paint chip samples by ICP or CVAA:

The white cinder block wall (Sample 7012-PC-1) exhibited detectable concentrations of barium, chromium, lead, and silver

The white metal door system (Sample 7012-PC-2) exhibited detectable concentrations of barium, chromium, lead, and silver

MBC survey results are provided in Table 3. Paint chip sample locations are depicted on Figure

3. Consultant, inspector, and laboratory credentials are provided in Appendix A. Copies of the laboratory analytical results and the appropriate Chain of Custody Record are included in Appendix B. MBC Photographic documentation is included in Appendix D.

5.4 Waste Characterization Results

TCLP waste characterization testing for lead consisted of collecting sub-samples of building components from Building 7012 including, but not limited to, concrete, concrete block, plaster, Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 16 and wood. The laboratory analytical result of the TCLP sample (7012-TCLP) analyzed for lead was <0.40 mg/L, which is less than the EPA toxicity characteristic level of hazardous material for lead of 5.0 mg/L. Copies of the laboratory analytical result and the appropriate Chain of Custody Record are included in Appendix B.

5.5 Hazardous Materials Survey Results

Approximately ten percent of the light fixtures were dismantled to determine if lighting ballasts were present, if labeling included information regarding PCB content, as required by EPA regulation 40 CFR 761.45, and if bulbs contained mercury.

One type of light ballast in 4’ fluorescent light fixtures labeled “No PCBs.”

One type of CFL bulb. According to the manufacturer, the bulbs contain mercury;

however, the bulbs are TCLP compliant.

One type of incandescent bulb. Incandescent lights do not require special handling under the Universal Waste Regulations.

ASL also conducted an inventory of potential hazardous components and used hazardous materials within interior and exterior spaces of Building 7012. Examples of items that may contain hazardous and other regulated components include, but are not limited to: mercury thermostats, switches and other devices, PCB and non-PCB transformers, batteries, emergency exit signs, HVAC systems, refrigerators, lead-lined vent pipes, and oil-containing equipment.

Emergency exit signs with LED lighting. The exit signs contain NiCad back-up batteries.

No indications that the signs contain tritium were observed.

Hazardous components survey results are provided in Table 4. Hazardous Materials Photographic Documentation is included in Appendix E.

6.0 LIMITATIONS

ASL has prepared this ACM, LBP, MBC, Hazardous Materials, and Waste Characterization for Lead Survey Report for Leo A Daly, hereafter referred to as the Client. No ACM, LBP, MBC, hazardous materials, or waste characterization survey can eliminate all uncertainty. Professional judgment and interpretation are inherent in the process and uncertainty is inevitable. Even when sampling is executed with an appropriate site-specific standard of care, certain conditions present especially difficult detection problems. Such conditions may include, but are not limited to, physical limitations imposed by the location and accessibility of possible ACMs, LBP, MBC, hazardous materials, and hazardous waste, and the limitations of assessment technologies. Only reasonably accessible areas were surveyed as part of this investigation. ASL is not responsible for

Building 7012 – Storage, P-405 – Chosin Range, MCRD Parris Island, Parris Island, Beaufort County, South Carolina March 26, 2021 Revised Final ACM, LBP, MBC, HazMat Survey, and Waste Characterization for Lead, ASL Project Number M3010.1385.0022.17 Page 17…