DRYDP678_HZMT-rpt_052021_Final.pdf

Prepared For:

Hazardous Material Inspection Report Drydock #8

Norfolk Naval Shipyard, Portsmouth, VA

May 2021

Environmental Consultants

FINAL

HAZARDOUS MATERIAL INSPECTION

REPORT

Dry Dock #8

Norfolk Naval Shipyard Portsmouth, VA

Prepared For:

NAVFAC Mid-Atlantic and

Burns McDonnell

Contract No. N40085-18-D-1100 Task Order No. N4008518F4635 AH Project Number: 130-07B

FINAL

May 2021

AH Environmental Consultants, Inc.

11837 Rock Landing Drive, Suite 300

Newport News, VA 23606 757.873.4959 solutions@ahenv.com

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NNSY DRYDOCK #8 TABLE OF CONTENTS

AH Environmental Consultants i May 2021 130-07B

EXECUTIVE SUMMARY ........................................................................................ iii

1. ASBESTOS .......................................................................................... 1-1

1.1 ASBESTOS INSPECTIONS .......................................................................... 1-3

1.1.1 DD8 Samples .............................................................................. 1-4

1.1.2 DD8T Samples............................................................................ 1-5

1.1.3 828 Samples ............................................................................... 1-6

1.1.4 829 Samples ............................................................................... 1-7

1.1.5 Pump well Samples .................................................................... 1-8

1.1.6 1490 Samples ............................................................................. 1-9

1.2 ACM COMMENTS ................................................................................... 1-10

1.3 RECOMMENDATIONS FOR ACM ............................................................... 1-10

1.4 CERTIFICATION ...................................................................................... 1-11

2. LEAD .................................................................................................... 2-1

2.1 SAMPLING ................................................................................................ 2-2

2.2 RANGES OF METALS ................................................................................. 2-2

2.3 RESULTS ................................................................................................. 2-3

2.3.1 DD8/ DD8T Lead Testing ............................................................ 2-3

2.3.2 PW Lead Testing ........................................................................ 2-4

2.3.3 828 Lead Testing ........................................................................ 2-6

2.3.4 829 Lead Testing ........................................................................ 2-6

2.3.5 1490 Lead Testing ...................................................................... 2-7

2.3.6 1528 Lead Testing ...................................................................... 2-7

2.4 COMMENTS/RECOMMENDATIONS .............................................................. 2-8

2.5 CERTIFICATION ...................................................................................... 2-10

3. OTHER HAZARDS ............................................................................... 3-1

3.1 MERCURY ................................................................................................ 3-1

3.1.1 Mercury Lamps ........................................................................... 3-2

3.1.2 Mercury Switch Inspection .......................................................... 3-2

3.2 PCBS ...................................................................................................... 3-2

3.3 SOIL HYDROCARBONS .............................................................................. 3-3

3.4 OTHER ITEMS OF NOTE............................................................................. 3-3

3.5 RECOMMENDATIONS ................................................................................. 3-4

NNSY DRYDOCK #8 TABLE OF CONTENTS

AH Environmental Consultants ii May 2021

TABLES

TABLE PAGE

Table 1-1 DD8 Asbestos Summary ..................................................................... 1-5 Table 1-2 PWL Asbestos Summary ..................................................................... 1-5 Table 1-3 PWL Asbestos Summary ..................................................................... 1-6 Table 2-1 DD8 Paint Samples ............................................................................. 2-4 Table 2-1 DD8 Paint Samples ............................................................................. 2-8

APPENDICES

A. HAZMAT Inspection Drawings

B. Laboratory Reports

C. Certifications

NNSY DRYDOCK #8 EXECUTIVE SUMMARY

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EXECUTIVE SUMMARY

AH Environmental Consultants (AH) has prepared this Hazardous Material Inspection

Report for the use of the Naval Facility Engineering Command (NAVFAC) Mid-

Atlantic and Burns McDonnell (BM) engineers to provide information concerning asbestos containing materials, paints containing hazardous metals, or other recognized hazardous materials (HAZMAT) identified at Norfolk Naval Shipyard

(NNSY) structures that may be impacted by work associated with the planned saltwater system upgrades at Dry Dock 8.

This site inspection and assessment was conducted by AH and Marine Chemist

Service (MCS) staff and involved sampling of suspect asbestos containing materials

(ACM), testing of paint/coatings, investigation for other potentially hazardous materials (OPHM) anticipated to be impacted by proposed work.

The primary HAZMAT concern for planned work activities appears to be paint coatings of some components that contain lead and chromium, in fair to poor condition. The precise means and methods to handle the identified hazardous materials are covered under project specifications separate from this document. This inspection cannot verify nor attest to components not accessible (e.g. encased in concrete or presently buried subgrade).

Inspections at the facility were conducted 27-29 October, 9-13 and 23-24 November, 2020 and included identification, sampling and analysis, evaluation of paint coatings and suspect ACM, and inventory of OPHM that could impact planned work actions.

Work included all components of the main drydock structure, adjacent pump wells and water transfer systems, and adjacent utility tunnels. The caisson gate was not included but is scheduled to be inspected as a separate effort. Confined space entry was conducted where permitted and possible to examine the interior and exterior of the structures and utility areas.

NNSY DRYDOCK #8 EXECUTIVE SUMMARY

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Asbestos inspection information is provided in Section 1. Lead inspection information is provided in Section 2. Section 3 contains information pertaining to additional

HAZMAT issues.

Site drawings indicating sample locations and information concerning the location of

HAZMAT are provided in Appendix A and the laboratory reports of analysis for all samples collected are provided in Appendix B. Appendix C contains other supporting information provided to AH during execution of this project. It should be noted that photography was not permitted at this location and therefore no photo-log can be prepared.

HAZARDOUS MATERIAL INSPECTION SECTION 1

NNSY DRYDOCK #8 ASBESTOS

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1. ASBESTOS

There is a well-known link between the inhalation of asbestos fibers and various diseases such as asbestosis, mesothelioma, lung and other cancers. As a result, the

Asbestos Hazard Emergency Response Act (AHERA, 40 CFR Part 763) was enacted. An AHERA inspection requires an accredited inspector to visually inspect and assess the condition of all known or assumed friable asbestos-containing building materials (ACM); to visually inspect non-friable ACM and touch it to determine friability; and to identify homogeneous areas of friable materials. The

National Emission Standards for Hazardous Air Pollutants (NESHAPs) require thorough inspections for asbestos in structures before renovation or demolition.

The intent of the inspection was to provide sufficient information to involved parties that may impact the renovations of project buildings and to prepare adequate abatement specifications for such. Bulk sampling of suspect ACM was performed.

Samples were analyzed utilizing Polarized Light Microscopy (PLM) with dispersion staining (EPA method 600/M4/82/020). For confirmation, two floor tile samples were analyzed by Transmission Electron Microscopy (TEM), National Institute of

Occupational Safety and Health (NIOSH) method 7402. The accredited laboratory reports of analysis are provided in Appendix B.

The sample identification system of this report consists of a three-unit sample identification number. The first set of digits indicates the building designation, the next set indicates the homogenous material grouping for the building, and the last two numbers indicate the consecutive sample number as collected in the field. For example, 44-01-03 would indicate that the sample was collected from Building 44, homogenous area one, and was the third sample collected [of that homogenous material] during the inspection. These sample numbers match the chain-of-custody, lab reports of analysis, and sample identification numbers on the drawings (Appendix

A). No historical sample data was provided or referenced for this project.

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Sample result summaries are provided in table format. Note that NAD in the % asbestos column indicates that there was No Asbestos Detected in the sample.

Some sample results in this column may be displayed in this report with a slash between two numbers, (#/#). The first number represents the first material listed under the material location/description and the second number represents the second material listed. Sampled materials that contain asbestos are highlighted in bold red and underlined.

The samples are also grouped into homogeneous material/area groups.

Homogeneous materials are suspect materials that are uniform by color, texture, construction/application date and general appearance. Photos of ACM could not be provided for site security reasons.

Sample summary tables also distinguish whether materials are considered friable

(able to be crushed or pulverized by hand pressure) or non-friable (not able to be crushed or pulverized by hand pressure) for the purpose of determining the ACM category. The collected samples were at least one cubic centimeter and were placed in a sealed container at the time of collection. Appropriate precautions were taken to prevent exposure to those present in or around the facility during the collection of samples, including wet collection methods.

As previously mentioned, the asbestos NESHAP (40 CFR 61, subpart M) requires a thorough inspection for asbestos in structures before the renovation or demolition of those structures. Materials determined to be ACM (containing greater than one percent asbestos) must also be categorized for removal and demolition purposes.

The various categories for ACM are shown in the following chart.

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ACM Category (NESHAP)

Categories Typical Material

Type Guidance for RACM

Friable ACM Pipe insulation fittings

Able to crush with hand pressure

Cat I, Non-friable

Floor coverings, Roofing products, Gaskets

Non-friable materials that have become friable, or Non-friable material that is or will be damaged due to sanding, grinding, cutting, or abrading

Cat II, Non-friable

Cement siding (Transite), Significantly damaged tile

Non-friable material that has a high probability of becoming or has become friable by forces expected to act on the material in the course of renovation or demolition

Any ACM that is Friable or Category I and II Non-friable, that meets the qualifications to be considered a Regulated Asbestos-Containing Material (RACM), must be removed prior to demolition or disturbance that would break up, dislodge, or similarly destroy the material or preclude access to the material for subsequent removal. This includes gasket materials.

The findings of the asbestos inspections are detailed in the following section, including recommendations for action.

1.1 ASBESTOS INSPECTIONS

The building inspections were conducted for potential disturbance and localized demolition required for future improvements of the site. A visual survey was performed of accessible suspect ACM at all aforementioned sites. Selective demolition was also performed where warranted to identify commonly hidden materials that were suspected.

Individual inspection data for the site buildings and structures is provided following.

Work included the following designated areas:

Dry Dock 8 [DD8] including gallery and dock structure

Dry Dock 8 Utility Tunnels [DD8T], north and south of the dry dock

Building 828, south pump house

Building 829, north pump house

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Building 1490, south side support building

Building 1528, south side support building

Pump wells/ Sluice Gates [PWL], including all flood system operations

1.1.1 DD8 Samples

Inspections of DD8 occurred October and November 2020 as previously indicated.

The construction of DD8 is estimated 1940, with much of the main structure renovated or added to the original. There have been apparent repairs and renovations to utilities, steam supply, and other various supporting components. The structure is primarily concrete and steel components.

No known previous comprehensive inspection was conducted, and no official supporting documentation was provided. This report will supersede other reports where inspections were conducted previously.

The current asbestos survey identified three (3) homogenous suspect materials including:

Concrete material

Gasket material

Pipe sealant, gray

Bulk sampling was performed on the suspect ACM found in the survey area. Six (6) samples were collected that included six (6) individual layers for analysis. A summary of sample results, current and previous, are provided in Table 1-1. Graphic depiction of ACM locations are shown on drawings (Appendix A). No asbestos containing materials (ACM) identified.

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Table 1-1 DD8 Asbestos Summary

Sample # Description [location] Asbestos

Friable?

DD8-01-01

DD8-01-02

Concrete [lower dock sidewall]

Concrete [upper dock]

NAD

NAD

N/A

DD8-02-01

DD8-02-02

Gasket material, black [lower dock]

Gasket material, black [upper dock]

NAD

NAD

N/A

DD8-03-01

DD8-03-02

Pipe sealer, gray [lower dock]

Pipe sealer, gray [upper dock]

NAD

NAD

N/A

1.1.2 DD8T Samples

Inspections of the utility tunnels (DD8T) were conducted via confined space entry protocols November 2020. No records of a previous inspection were provided. The current asbestos survey identified three (3) homogenous suspect materials. The homogenous materials identified during the inspection included:

Miscellaneous sealant

Pipe insulation

Gasket materials

Bulk sampling was performed on the suspect ACM found in the survey area. Thirty-six (36) samples were collected which included forty-two (42) layers for analysis. A summary of sample results are provided in Table 1-2. Locations are from the North

(N) or South (S) tunnels and notated entry manhole field designation (east to west).

Table 1-2 PWL Asbestos Summary

Sample # Description [location] Asbestos

Friable?

DD8T-01-01

DD8T-01-02

Miscellaneous sealant [S1-S2] Miscellaneous sealant [N5-N6]

NAD

NAD

N/A

Table continues on following page

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Table 1-3 PWL Asbestos Summary

Sample # Description [location] Asbestos

Friable?

DD8T-02-01

DD8T-02-02

DD8T-02-03

DD8T-02-04

DD8T-02-05

DD8T-02-06

DD8T-02-07

DD8T-02-08

DD8T-02-09

DD8T-02-10

DD8T-02-11

DD8T-02-12

DD8T-02-13

DD8T-02-14

DD8T-02-15

DD8T-02-16

DD8T-02-17

DD8T-02-18

DD8T-02-19

Pipe insulation [S1-S2] Pipe insulation [S2-S3] Pipe insulation [S3-S4] Pipe insulation [S4-S5] Pipe insulation [S5-S6] Pipe insulation [S6-S7] Pipe insulation [S7-S8] Pipe insulation [S9-S10] Pipe insulation [N8-N9] Pipe insulation [N9-N10] Pipe insulation [N10] Pipe insulation [N1-N2] Pipe insulation [N2-N3] Pipe insulation [N3-N4] Pipe insulation [N4-N5] Pipe insulation [N5-N6] Pipe insulation [N6-N8] Pipe insulation [S8-S9] Pipe insulation [S9-S10]

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

NAD

N/A

1.1.3 828 Samples

Inspection of the Building 828 pump house was conducted on 29 October 2020. No records of a previous inspection were provided although information provided determined that duct insulation contained asbestos. The current asbestos survey identified eight (8) homogenous suspect materials. The homogenous materials identified during the inspection included:

Electrical sealant

Caulking

Stucco material

Gasket materials

Pipe sealants

Pitch-pocket tar

Expansion joint flashing

Bulk sampling was performed on the suspect ACM found in the survey area. Fifteen

(15) samples were collected which included sixteen (16) layers for analysis. A summary of sample results, current and previous, are provided in Table 1-3.

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Table 1-3 828 Asbestos Summary

Sample # Description [location] Asbestos

Friable?

828-01-01 828-01-02

Electrical sealant, black Electrical sealant, gray

NAD

NAD

N/A

828-02-01 828-02-02

Caulking [exterior wall] Caulking [exterior wall]

NAD

<1%

N/A

828-03-01 828-03-02

Stucco [exterior wall] Stucco [exterior wall]

NAD

NAD

N/A

828-04-01 Gasket material, black/red [exterior] NAD N/A

828-05-01 828-05-02

Pipe sealant [diesel pump] Pipe sealant [diesel pump]

NAD

NAD

N/A

828-06-01 828-06-02

Gasket material, black [Gallery 1] Gasket material, black [Gallery 1]

NAD

NAD

N/A

828-07-01 Expansion joint flashing [roof] NAD N/A

828-08-01 828-08-02 828-08-03

Gasket material, gray [interior] Gasket material, black [interior] Gasket material, red [interior]

NAD

NAD

NAD

N/A

1.1.4 829 Samples

Inspection of the Building 829 pump house was conducted on 29 October 2020. No records of a previous inspection were provided although information provided determined that duct insulation contained asbestos. The current asbestos survey identified six (6) homogenous suspect materials. The homogenous materials identified during the inspection included:

Block mortar

Stucco

Pitch-pocket tar

Pipe sealants

Gasket materials

Bulk sampling was performed on the suspect ACM found in the survey area. Thirteen

(13) samples were collected which included seventeen (17) layers for analysis. A summary of sample results, current and previous, are provided in Table 1-4.

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Table 1-4 829 Asbestos Summary

Sample # Description [location] Asbestos

Friable?

829-01-01 Block mortar [exterior wall] NAD N/A

829-02-01 829-02-02

Stucco [exterior wall] Stucco [exterior wall]

NAD

NAD

N/A

829-03-01 829-03-02

Pitch-pocket material [roof] Pitch-pocket material [roof]

NAD

NAD

N/A

829-04-01 829-04-02

Pipe sealant [diesel pump] Pipe sealant [diesel pump]

NAD

NAD

N/A

829-05-01 829-05-02 829-05-03 829-05-04

Gasket material, black [interior] Gasket material, black [interior] Gasket material, red [interior] Gasket material, pink [interior]

NAD

NAD

NAD

NAD

N/A

829-06-01 829-06-02

Vibration cloth [Interior B Deck] Vibration cloth [Interior B Deck]

NAD

NAD

N/A

1.1.5 Pump well Samples

Inspections of the pump well took place on 29 October 2020 and 31 March 2021.

The construction date is unknown and the structure is believed original. No known previous comprehensive inspection was conducted, and no official supporting documentation was provided. The current asbestos survey identified seven (7) homogenous suspect materials including:

Non-skid coating

Caulking

Gasket material

Drywall

Electrical high voltage block

Electrical connector block

Electrical wire covering

Bulk sampling was performed on the suspect ACM found in the survey area.

Fourteen (14) samples were collected for analysis. A summary of sample results, current and previous, are provided in Table 1-5. Graphic depiction of ACM locations are shown on drawings (Appendix A). No asbestos containing materials (ACM) were identified. The electrical control panel was also inspected.

AH Environmental Consultants 1-9 May 2021

Table 1-5 Pump Well Asbestos Summary

Sample # Description [location] Asbestos

Friable?

PW-01-01

PW-01-01TEM

PW-01-02

PW-01-03

Non-skid coating [exterior]

Non-skid coating 01-01 (via TEM analysis)

Non-skid coating [exterior]

Non-skid coating [exterior]

NAD

NAD

NAD

NAD

N/A

PW-02-01

PW-02-02

Gasket material, black [lower dock]

Gasket material, black [upper dock]

NAD

NAD

N/A

PW-03-01

PW-03-02

Pipe sealer, gray [lower dock]

Pipe sealer, gray [upper dock]

NAD

NAD

N/A

PW-20-01

PW-20-01T

PW-20-02

Control panel, high voltage block, black (#4)

TEM analysis 20-01

Control panel, high voltage block, black (#3)

NAD

Trace

NAD

N/A

PW-21-01

PW-21-01T

PW-21-02

PW-21-03

Control panel, connector bar, black (#4)

TEM analysis 21-01

Control panel, connector bar, black (#2)

Control panel, connector bar, black (#1)

NAD

Trace

NAD

NAD

N/A

PW-22-01

PW-22-02

Control panel, electrical wire wrap (#3)

Control panel, electrical wire wrap (#3)

NAD

NAD

N/A

1.1.6 1490 Samples

Inspections of 1490 transpired on 29 October 2020. The construction date is unknown and the structure is believed original. No known previous comprehensive inspection was conducted, and no official supporting documentation was provided.

The current asbestos survey identified one (1) homogenous suspect materials including:

Exterior sealant, black

Bulk sampling was performed on the suspect ACM found in the survey area. One (1) sample was collected that included one (1) individual layers for analysis. A summary of sample results, current and previous, are provided in Table 1-6. Graphic depiction of ACM locations are shown on drawings (Appendix A). Asbestos was identified in the sample.

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Table 1-6 1490 Asbestos Summary

Sample # Description [location] Asbestos

Friable?

1490-01-01 Exterior sealant, black [exterior wall] 10 NO

1.2 ACM COMMENTS

1490, HM01- Exterior Sealant: This material was identified as a patch present on the east exterior of the CONEX box building wall. There is approximately 3 square feet of this ACM present. It is anticipated this material will be removed and disposed of as asbestos waste. If recycling is conducted on the metal building, classification would be non-regulated non-friable material for the purpose of NESHAP. However, use of a landfill that accepts non-friable ACM construction wastes would be required for disposal.

1.3 RECOMMENDATIONS FOR ACM

The following general recommendations are provided to assist in the renovations of the existing structures with ACM. Note that any building material that is not identified as homogenous with those addressed in this report must be considered as an ACM unless additional testing indicates otherwise. Locations of samples and known ACM are indicated on the inspection drawings (Appendix A).

The following work practice should be followed whenever activities involving any ACM occur at this facility:

Ensure any ACM is managed in accordance with Federal and Virginia regulations.

Remove any ACM that may be disturbed during renovation or demolition to ensure the material will not be disturbed.

Always keep any ACM adequately wet before, during, and after removal operations.

Conduct activities in a manner which produces no visible emissions to the outside air.

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Handle and dispose of all ACM in accordance with Federal and Naval regulations.

Although work may be performed with the ACM in place, removal of the identified

ACM that may be disturbed is recommended to provide a worksite free of identified

ACM and therefore standard activities could proceed without concern (with regards to

ACM).

The removal of the sealant is considered an operations and maintenance level task, requiring minimal time and effort. It is anticipated two men can complete the task in less than one hour with basic tools. The opinion of probable cost to remove the sealant is $1000.

Additional inspection information is included in the appendices on the lab reports of analysis chain of custody documents and on building drawings.

1.4 CERTIFICATION

The American Industrial Hygiene Association (AIHA) and National Voluntary

Laboratory Accreditation Program (NVLAP) laboratories selected to analyze the bulk samples for asbestos content by PLM NIOSH method 7402 and TEM Chatfield methods, equivalent to the "Interim Method for the Determination of Asbestos in Bulk

Insulation Samples” (Appendix A to Subpart F in 40 CFR Part 763) was:

SanAir Technologies Laboratory, Inc.

1551 Oakbridge Dr, Suite B Powhatan, VA 23139

(804) 897-1177

Hayes Microbial Consulting 3005 East Boundary Terrace, Suite F

Midlothian, VA 23112

(804) 562-3435

The EPA-approved and trained inspector and management planner who supervised the project and prepared the inspection report is:

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David Dobson, EHSP AH Environmental Consultants, Inc.

Newport News, VA 23606

(757) 873-4959

SIGNATURE:

The above-signed listed inspector certifies information contained within this asbestos inspection report is true and correct concerning site conditions at the time of survey only.

Every reasonable attempt was made to identify all ACM. However, locations not accessible such as encased concrete or subgrade locations may contain materials not yet identified.

The EPA-approved and trained inspectors who physically surveyed the project site are:

Patrick Studley, CIH and

Shawn Cowden

Marine Chemist Service, Inc.

11850 Tug Boat Lane

(757) 873-0933

HAZARDOUS MATERIAL INSPECTION SECTION 2

NNSY DRYDOCK #8 LEAD

AH Environmental Consultants 2-1 May 2021

2. LEAD

Since 1971, the construction industry has been required to protect workers from exposure to lead through engineering and work practice controls. Since lead-based paint has been determined to be a health threat, assessment of buildings and structures for the presence of lead-based paint is required in order to prevent occupational exposure to personnel or the general public, and to enact appropriate control measures for lead hazards.

OSHA and EPA regulations must be followed when renovation or demolition work affects any lead based paint (LBP) or paints with detectable lead levels referred to as paint containing lead (PCL). Additionally, industrial settings are also known to have potential for Resource Conservation and Recovery Act (RCRA) metals within paints or coatings.

Testing included the RCRA 8 metals (Arsenic/ As; Barium/ Ba; Cadmium/Cd;

Chromium/ Cr; Mercury/Hg; Lead/Pb; Selenium/Se; and Silver/Ag). Samples collected were tested for some or all, dependent on the location and type of coating.

The preconstruction inspections primary purpose is to identify major components containing lead in order to properly address the RCRA metals in coatings during renovation or demolition that may be impacted by the proposed work for the purpose of OSHA compliance. The inspection was conducted using the EPA’s work practice standards for conducting lead-based paint activities (40 CFR 745.227) as a guide and all State and local regulations.

Disturbance of paint containing lead or RCRA metals requires special training and initial exposure monitoring at a minimum. Above 0.5% by weight (bulk paint), paint is considered to be lead-based. However, in the interest of safety, lower thresholds are utilized in construction since OSHA regulations are invoked if any lead is present in the paint; there is no minimum concentration level. This standard is also applied to

AH Environmental Consultants 2-2 May 2021 the presence of RCRA metals in paints for the purpose of this report. The following governing standards will apply:

OSHA Chromium standards 29 CFR 1910.1026

OSHA Lead standards 29 CFR 1926.62

OSHA Gas, vapor, fume, dust, and mist standards 29 CRF 1926.55

These standards set forth the regulations that apply with regards to construction or renovation of painted materials or structures that contain detectable amounts of lead and/or RCRA metals.

2.1 SAMPLING

Most components tested are believed to contain several layers of paint film and are difficult to interpret. Bulk paint analysis does not differentiate which layer of paint may contain lead or RCRA metals. The results only indicate the amount of RCRA metal that is present in the sample/test location. Lead or other RCRA metals are likely to be present at a higher percentage in a particular layer than reported due to averaging the weight of other layers of paint into the calculation. For this reason, OSHA standards apply to any sample with detectable RCRA metals. Construction activities that impact these paints may result in exposure, even though they are not technically considered lead-based paints.

Results of the lead testing conducted are presented in the following sections.

2.2 RANGES OF METALS

An inspection was performed on painted components to be suspect for the presence of lead or RCRA metals found at the project site, including interior and exterior areas of DD8, DD8T, 828, 829, PW, 1490, and 1528. Samples were then taken of a representative number of surfaces, dependent on the quantity of the particular material present. Although OSHA utilizes the term “any detectable lead”, the amount detectable is relevant in order to determine the potential for exposure. Information is presented in a range format to assist in determining protective measures and special procedures that may be required during renovation/ demolition activities.

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The readings were categorized as follows:

Lead/RCRA based paint [L] or 0.5% by weight or 5000 ppm lead/ RCRA metals;

Containing elevated lead or RCRA metal levels [E] or 0.499-0.3% or 4999-

3000 ppm lead/ RCRA metals;

Containing lead or RCRA metals of concern [C] or 0.299-0.100 or 2999-1000 ppm lead; and

Detectable levels of lead or RCRA metals [D] or 0.099-0.005 or 999-50 ppm or between 0.33 and 0.05 mg/cm2 lead.

Readings below the laboratory Minimum Reporting Level (MRL) or 50 ppm or

0.05 mg/cm2 lead were considered insignificant.

2.3 RESULTS

Inspections were conducted 27-29 October and 9 November 2020. A summary of the components tested and determined to contain lead are presented in the following sections. A description of the location, component (including color and substrate) is listed.

Some sampling was done as a “composite” method where paint was collected from a variety of surfaces to obtain a single sample for analysis. The composite method is used to indicate the general findings of RCRA paints in any particular area.

The complete results of analysis are presented in Appendix B. Note: the MRL/ lab detection limit for the RCRA metals sampled is 25.0 micrograms. The MRL for mercury (Hg) is 0.5 micrograms.

2.3.1 DD8/ DD8T Lead Testing

Bulk paint composite sampling was conducted at DD8 and included ten (10) samples analyzed for lead, with two (2) samples additionally tested for the 8 RCRA metals.

Results are shown in Table 2-1.

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Table 2-1 DD8 Paint Samples

Sample Description Metal/ Analyte Result in ug/g or ppm

DD8-L01 Yellow, asphalt markings, upper

Ag/ Silver <25.0

As/ Arsenic <25.0

Ba/ Barium 711

Cd/ Cadmium <25.0

Cr/ Chromium 948

Pb/ Lead 3,900

Hg/ Mercury <0.5

Se/ Selenium <25.0

DD8-L02 Lt. Yellow, metal cleat, upper

Ag/ Silver <25.0

As/ Arsenic 51.7

Ba/ Barium 59.3

Cd/ Cadmium <25.0

Cr/ Chromium 372

Pb/ Lead 5,140

Hg/ Mercury <0.5

Se/ Selenium 103

DD8-L03 Gray, metal pipe, lower Pb/ Lead <25.0

DD8-L04 Gray, metal substation, upper Pb/ Lead <25.0

DD8-L05 Beige, metal valve, upper Pb/ Lead <25.0

DD8-L06 Gray, metal rail, lower Pb/ Lead 4,340

DD8-L07 Black, metal valve, upper Pb/ Lead 35.1

DD8-L08 Red, metal valve, mezzanine Pb/ Lead 33.2

DD8-L09 Gray, metal valve, mezzanine Pb/ Lead <25.0

DD8T-L10 Red, metal valve Pb/ Lead <25.0

2.3.2 PW Lead Testing

Bulk paint composite sampling was conducted at the pump well area and included seventeen (17) samples analyzed for lead, with four (4) samples additionally tested for the RCRA metals Arsenic, Barium, Cadmium, and Chromium. Results are shown in Table 2-2.

AH Environmental Consultants 2-5 May 2021

Table 2-2 PW Paint Samples

Sample Description Metal/ Analyte Result in ug/g or ppm

PW-L01 Gray, metal cover, exterior

As/ Arsenic 50.6

Ba/ Barium 3,910

Cd/ Cadmium <25.0

Cr/ Chromium 4,860

Pb/ Lead 145

PW-L02 Yellow, metal bollard, exterior Pb/ Lead <25.0

PW-L03 Red, concrete wall, exterior Pb/ Lead 1,624

PW-L04 Yellow, metal handrail, interior Pb/ Lead 37,700

PW-L05 Orange/Yellow, metal door, interior Pb/ Lead 35,640

PW-L06 Red, metal pipe, interior Pb/ Lead <25.0

PW-L07 Beige, concrete wall, exterior Pb/ Lead 27,630

PW-L08 Black, metal sink, main level Pb/ Lead 29.4

PW-L09 White, metal wall, main level

As/ Arsenic <25.0

Ba/ Barium 21,430

Cd/ Cadmium <25.0

Cr/ Chromium <25.0

Pb/ Lead 10,920

PW-L10 Red, metal door casing, main level Pb/ Lead <25.0

PW-L11 Gray/Green, metal wall, interior Pb/ Lead 7,390

PW-L12 Blue, metal floor, interior Pb/ Lead 57.0

PW-L13 Gray, metal motor housing Pb/ Lead 8,730

PW-L14 Yellow, metal handrail, main level Pb/ Lead 7,171

PW-L15 White, metal wall, bilge level

As/ Arsenic <25.0

Ba/ Barium 5,910

Cd/ Cadmium <25.0

Cr/ Chromium 43.4

Pb/ Lead 53.2

PW-L16 Yellow, metal handrail, bilge level Pb/ Lead 75.5

PW-L17 Gray, metal beam, bilge level Pb/ Lead 440

AH Environmental Consultants 2-6 May 2021

2.3.3 828 Lead Testing

Bulk paint composite sampling was conducted at Building 828 and included twelve

(12) samples analyzed for lead. Results are shown in Table 2-3.

Table 2-3 828 Paint Samples

Sample Description Metal/ Analyte Result in ug/g or ppm

828-L01 Red, metal diesel pump Pb/ Lead <25.0

828-L02 Blue, metal diesel pump Pb/ Lead <25.0

828-L03 Gray, metal door, exterior Pb/ Lead 66,430

828-L04 Red, fire main, exterior Pb/ Lead 21,840

828-L05 Beige, block wall, exterior Pb/ Lead 2,572

828-L06 Gray, metal pipe, interior Pb/ Lead 134

828-L07 White, block wall, interior Pb/ Lead 552

828-L08 Yellow, metal handrail, interior Pb/ Lead 12,610

828-L09 Blue, metal tank, interior Pb/ Lead 85.5

828-L10 Red, concrete floor, interior Pb/ Lead 89.3

828-L11 Lt. Gray, metal beam, interior Pb/ Lead 111,500

828-L12 Lt. Green, motor, interior Pb/ Lead 45,000

2.3.4 829 Lead Testing

Bulk paint composite sampling was conducted at Building 829 and included twelve

(12) samples analyzed for lead, with two (2) additionally analyzed for Cadmium (Cd) and chromium (Cr). Results are shown in Table 2-4.

Table 2-4 829 Paint Samples

Sample Description Metal/ Analyte Result in ug/g or ppm

829-L01 Brown, metal door, exterior Pb/ Lead 23,340

829-L02 Red, metal fire main, exterior

Cd/ Cadmium <25.0

Cr/ Chromium 30.8

Pb/ Lead 853

829-L03 Yellow, metal bollard, exterior Pb/ Lead 228

829-L04 Black, metal bollard, exterior Pb/ Lead 140

Table continues on following page

AH Environmental Consultants 2-7 May 2021

Table 2-4 829 Paint Samples

Sample Description Metal/ Analyte Result in ug/g or ppm

829-L05 Beige, block wall, exterior Pb/ Lead 1,540

829-L06 Red, diesel pump, exterior Pb/ Lead <25.0

829-L07 White, block wall, interior Pb/ Lead 73.2

829-L08 Red, concrete floor, interior Pb/ Lead 385

829-L09 Blue, metal motor, interior Pb/ Lead 402

829-L10 Black, metal tank, interior Pb/ Lead 1,760

829-L11 Gray, metal handrail, interior

Cd/ Cadmium <25.0

Cr/ Chromium 1,620

Pb/ Lead 28,420

829-L12 Gray, metal window frame Pb/ Lead 15,800

2.3.5 1490 Lead Testing

Bulk paint composite sampling was conducted at Building 1490 and included two (2) samples analyzed for lead, with one (1) additionally analyzed for Cadmium (Cd) and chromium (Cr). Results are shown in Table 2-5.

Table 2-5 1490 Paint Samples

Sample Description Metal/ Analyte Result in ug/g or ppm

1490-L01 White/Green, metal wall, exterior

Cd/ Cadmium <25.0

Cr/ Chromium 4,260

Pb/ Lead 67,700

1490-L02 Green, metal wall, interior Pb/ Lead 815

2.3.6 1528 Lead Testing

Bulk paint composite sampling was conducted at Building 1528 and included two (2) samples analyzed for lead. Results are shown in Table 2-6.

Table 2-6 1528 Paint Samples

Sample Description Metal/ Analyte Result in ug/g or ppm

1528-L01 Green, metal wall, interior Pb/ Lead 928

1528-L02 Green, metal wall, interior Pb/ Lead <25.0

AH Environmental Consultants 2-8 May 2021

Soil Sampling

The industrial area surrounding DD8 consists of small trenches at crane rails and build-up of wind-blown debris, soil, and other dirt. Sampling of this “soil” was conducted as a preliminary step for site excavation.

Four (4) composite samples were collected of loose soils and analyzed for lead. One was analyzed for the 8 RCRA metals. Results are shown in Table 2-7.

Table 2-2 DD8 Paint Samples

Sample Description Metal/ Analyte Result in ug/g or ppm

DD8-S01

Soil: Topside debris and rail troughs (perimeter)

Ag/ Silver <25.0

As/ Arsenic 43.1

Ba/ Barium 704

Cd/ Cadmium <25.0

Cr/ Chromium 3,235

Pb/ Lead 61.5

Hg/ Mercury <0.5

Se/ Selenium 40.3

DD8-S02

Soil: Topside debris and rail troughs (south central)

Pb/ Lead 183.6

DD8-S03

Soil: Topside debris and rail troughs (west, dock head)

Pb/ Lead <96.9

DD8-S04

Soil: Topside debris and rail troughs (north central)

Pb/ Lead 191.6

2.4 COMMENTS/RECOMMENDATIONS

Based upon the RCRA metals sampling results, lead, chromium, and other RCRA metals are present in paints and soils at the site. Some paints are in poor condition which likely will create lead paint debris. It is the opinion of the inspector that paint and soil hazards must be addressed as they pose an exposure concern to site workers. RCRA metals are due consideration when conducting demolition as this is the likely trigger for airborne contaminants. Proper hygiene will also assist in reducing exposure.

AH Environmental Consultants 2-9 May 2021

Worker exposure testing would be required during the construction/ demolition activities for areas known to have bulk lead [or RCRA metals] paint and debris. Areas containing loose and peeling paints and may pose additional hazards when disturbed.

Under no circumstances should torch cutting of metals coated with lead since it poses an immediate hazard as heavy metal vapors resulting from the intense heat and are acutely more toxic than airborne particulates.

Occupational exposure to persons conducting disturbance or removal of paint can result in elevated blood lead levels. Lead paint becomes an increased hazard when it deteriorates and oxidizes and/or is present as lead dust. Ingestion and potentially inhalation of resulting dusts may cause lead related health problems.

A toxicity characteristic leachate procedure (TCLP) test was not conducted on bulk structural components of this project since the mass of debris for disposal will substantially be recycled steel and metal components. When scrap metal is disposed of at a reclamation facility, the materials are exempt from regulation as a potentially hazardous waste [EPA 40 CFR 261.6 (a)(3)(ii)]. The planned reuse of materials from demolition debris is acceptable in most cases provided the reused materials do not exhibit hazardous characteristics based on Resource Conservation and Recovery Act

(RCRA) guidelines listed in 40 CFR 257.

A TCLP sample will be required for disposal of loose debris and materials destined for a construction/ demolition landfill or reuse. Any debris containing loose paint should be collected, segregated from other debris, and tested for disposal classification based on current findings.

The following measures are recommended to conduct operations safely during demolition operations.

Remove bulk loose and flaky lead paint [debris] and perform HEPA vacuum and wash of major metal components prior to commencing renovation/ demolition operations.

Recycle all metal components of the waste stream.

TCLP all fill material for adequate documentation of hazard characteristics per

40 CFR 261.

AH Environmental Consultants 2-10 May 2021

Follow OSHA and EPA regulations when performing construction operations affecting paints containing lead.

Inform facility personnel of the inspection findings.

Conduct personal air monitoring when performing construction work on painted surfaces until a negative exposure assessment can be completed and approved by appropriate personnel.

2.5 CERTIFICATION

The AIHA and NVLAP Accredited laboratory selected to analyze the bulk material samples for lead and RCRA metals content, using EPA Methods M3050B/ 6010C/ and 7471B was:

SanAir Technologies Laboratory, Inc.

1551 Oakbridge Dr, Suite B

Powhatan, VA 23139

(804) 897-1177

The EPA-approved and trained inspector who managed the project and prepared the inspection report is:

David Dobson, EHSP AH Environmental Consultants, Inc.

(757) 873-4959

SIGNATURE:

The EPA-approved and trained inspector who physically surveyed the project site is

Patrick Studley, CIH Marine Chemist Service, Inc.

11850 Tug Boat Lane

(757) 873-0933

The above-signed inspectors certify information contained within this inspection report is true and correct concerning site conditions at the time of survey only.

HAZARDOUS MATERIAL INSPECTION SECTION 3

NNSY DRYDOCK #8 OTHER HAZARDS

AH Environmental Consultants 3-1 May 2021

3. OTHER HAZARDS

In addition to asbestos, lead, various additional issues relevant to the project may be present and should be considered present unless proven otherwise. Other potentially hazardous materials (OPHM) to be aware of during the assessment are described in this section.

Older building and structure demolition creates additional items of concern;

fluorescent lighting fixtures have elemental mercury in the fluorescent bulbs and may also contain polychlorinated biphenyls (PCB) ballasts or high voltage wire sheathing.

Buildings may also contain mercury switches inside of thermostats, lead or other chemical containing batteries, and other materials of special concern. A brief narrative concerning the other hazards to be cognizant of are discussed below.

3.1 MERCURY

Mercury is a toxic elemental metal with unique properties, including being in a liquid state at room temperatures. Human intake of mercury is primarily through oral means. Inhalation of mercury vapor is another source of human exposure. Once absorbed, mercury in all forms is distributed via the blood steam to all tissues in the body. Chronic exposure to mercury primarily affects the central nervous system and kidneys.

Mercury is used in a wide variety of common products including:

Fluorescent and neon lamps, Mercury vapor and high pressure sodium lamps, Switches and relays, Thermostats and regulators, and

Thermometers and manometers.

AH Environmental Consultants 3-2 May 2021

3.1.1 Mercury Lamps

In recent years, the use of fluorescent and high-intensity discharge (HID) lamps has become the standard choice for lighting sources since they can use up to 50 percent less energy than incandescent lighting. However, fluorescent and HID lamps contain mercury and therefore must be properly managed. This includes new “low mercury” lamps. Although low mercury lamps contain approximately one-tenth the amount of mercury as standard lamps, they still must be handled properly.

3.1.2 Mercury Switch Inspection

Areas were inspected for older style thermostats that are likely to contain mercury tilt switches. When an older thermostat was identified, the cover was removed to determine if a mercury-filled glass vial was present. The number and location of each mercury switch identified was noted on the field sketches.

No such old style thermostats containing mercury vial were identified.

3.2 PCBS

Another potential concern associated with structural demolition in industrial or shipyard confines is the presence of PCBs. Inspections included a visual survey.

Fluorescent lighting fixtures have the potential to contain ballasts with PCB capacitors. High voltage wiring is also suspected to contain PCB oil soaked sheathing.

PCBs are synthetic organic chemicals that were produced in the United States from

1929 to 1977. Due to their non-flammability, chemical stability, high boiling point and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications including electrical, heat transfer, and hydraulic equipment;

as plasticizers in paints, plastics and rubber products, in pigments, dyes and carbonless copy paper and many other applications. A major use of PCBs was also in fluorescent light fixture ballasts (in the capacitor).

AH Environmental Consultants 3-3 May 2021

PCBs have been demonstrated to cause a variety of adverse health effects including cancer and a number of serious non-cancer health effects in animals. These effects include damage to the immune system, reproductive system, nervous system, and endocrine system. Studies in humans provide evidence for carcinogenic and non-carcinogenic effects of PCBs. Concern over PCBs in the environment led Congress in 1976 to enact §6(e) of the Toxic Substances Control Act (TSCA) that included among other things, prohibitions on the manufacture, processing, and distribution in commerce of PCBs.

3.3 SOIL HYDROCARBONS

Since demolition and excavation of the area will occur, the issue of soil disturbance is relevant. The site is primarily asphalt or concrete and observations of subgrade materials was not conducted. There are no known underground storage tanks (UST) at the site.

Any excavated materials of the general NNSY base should always be considered suspect, as various hazardous waste sites have been identified previously. Soil sampling will be required of material excavated to determine any hazardous constituents present that may require special handling and disposal.

Testing of the soils at the area should include:

Total petroleum hydrocarbons (TPH) as diesel range organics (DRO);

Benzene, Toluene, Ethylbenzene, Xylene (BTEX), volatile organic compounds (VOCs) found in petroleum products;

RCRA metals; and

Verification of any hazardous, toxic, or reactive waste (HTRW) characteristics.

3.4 OTHER ITEMS OF NOTE

Additional OPHM with possibility to be present at the site that would require special handling or disposal, include smoke detectors, various cell type batteries, and ozone depleting substances (ODS).

AH Environmental Consultants 3-4 May 2021

Any refrigeration lines uncovered may be subject to Section 608 of the Clean Air Act

(CAA) prohibits individuals from intentionally venting ODS refrigerants including hydro-chlorofluoro carbons (HCFC’s) or chlorofluorocarbons (CFCs) and their substitutes to the environment while maintaining, servicing, repairing, or disposing of air conditioning or refrigeration equipment.

3.5 RECOMMENDATIONS

Broken or crushed, fluorescent and HID lamps must be managed as a hazardous waste. The Federal Government and most locales, have adopted disposal regulations for handling fluorescent and HID lamps as a universal waste based upon a “recycling presumption”. Through recycling and proper handling of spent lamps as a universal waste, the burdens and liabilities placed upon disposers are reduced.

The universal waste rule does not authorize disposal of mercury containing lamps in landfills, but has created a cost effective alternative for disposal through recycling.

All fluorescent light tubes (including those deemed low mercury), HID lights, and all ballasts should be packaged intact and sent to an approved recycling facility for disposal/recycling. Once power supply lines are uncovered, testing of coatings should be made to determine the presence of PCBs.

Implementation of a dust control plan is recommended to prevent dusts which may contain hazardous constituents from becoming airborne. Dust control is an integral part of demolition work.

Properly trained personnel using adequate protective equipment should perform work on-site in the event unforeseen hazards are identified.

HAZARDOUS MATERIAL INSPECTION APPENDIX A

NNSY DRYDOCK #8 HAZMAT INSPECTION DRAWINGS

AH Environmental Consultants May 2021

APPENDIX A

HAZMAT Inspection Drawings

HAZARDOUS MATERIAL INSPECTION APPENDIX A

NNSY DRYDOCK #8 HAZMAT INSPECTION DRAWINGS

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DI

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SMH

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DI

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STOMH

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AutoCAD SHX Text B.

AutoCAD SHX Text B.

AutoCAD SHX Text B.

AutoCAD SHX Text B.

AutoCAD SHX Text B.

AutoCAD SHX Text B.

AutoCAD SHX Text B.

AutoCAD SHX Text B.

AutoCAD SHX Text B.

AutoCAD SHX Text B.

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10" SEWER C.I.P.

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ELEC. TERMINALS

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6" SEWER C.I.P.

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S. TO S. HOSE CONN.

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ELEC. TERMINALS

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3/4" PROPANE

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1/2" OXYGEN

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3" STEAM

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6" SEWER C.I.P.

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2" AIR

AutoCAD SHX Text 2-1/2" S.W.

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S. TO S. HOSE CONN.

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CRANE RAIL

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R.R. TRACKS

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ABANDONED R.R. TRACKS

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R.R. TRACKS

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CRANE RAIL

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PIPE TUNNEL UNDER R.R. TRACKS

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R.R. TRACKS

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R.R. TRACKS

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R.R. TRACKS

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BLDG. NO. 270

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END OF PIPE TUNNEL

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PIPE TUNNEL

AutoCAD SHX Text D-119"

AutoCAD SHX Text D-121"

AutoCAD SHX Text

WELL D-264

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SLIP NO. 5

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BERTH NO. 39

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BERTH NO. 40

AutoCAD SHX Text T.B.

AutoCAD SHX Text M.H.584

AutoCAD SHX Text D-92"

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20-4" F.D. & 1-2" COND. 4W X 5D

AutoCAD SHX Text 14-4" F.D.

AutoCAD SHX Text 7W X 2D

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16-4" F.D. & 1-2" COND. 4W X 4D

AutoCAD SHX Text M.H.585

AutoCAD SHX Text D-92"

AutoCAD SHX Text D-91"

AutoCAD SHX Text M.H.586

AutoCAD SHX Text 14-4" F.D.

AutoCAD SHX Text 7W X 2D

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FLOODLIGHT TOWER

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4-4" F.D. & 1 1-1/2" COND.

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ELECTRIC TERMINALS

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2-4" F.D. & 1- 1 1/2" COND.

AutoCAD SHX Text 6-4" F.D.

AutoCAD SHX Text 8-4" F.D.

AutoCAD SHX Text D-119"

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CAPSTAN

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NO.34

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CAPSTAN

AutoCAD SHX Text D-173"

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1 WAY

AutoCAD SHX Text D-101"

AutoCAD SHX Text M.H.860

AutoCAD SHX Text 1-4" F.D.

AutoCAD SHX Text D-40"

AutoCAD SHX Text 1-4" F.D.

AutoCAD SHX Text 2-4" F.D.

AutoCAD SHX Text 4-4" F.D.

AutoCAD SHX Text 2-4" F.D.

AutoCAD SHX Text 2" F.D.

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AutoCAD SHX Text

AutoCAD SHX Text 10-4" F.D.

AutoCAD SHX Text 5-4" F.D.

AutoCAD SHX Text 2-4" F.D.

AutoCAD SHX Text 3-4" F.D.

AutoCAD SHX Text 2-4" F.D.

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ELEC. CUTOUT BOX

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INV.96"

AutoCAD SHX Text D-96"

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6" VIT.