2014_05_01_Hazardous_Material_Report.pdf

National Park Service

U.S. Department of the Interior

NATIONAL CAPITAL REGION

LANDS PLANNING AND DESIGN

WASHINGTON, D.C.

Install Fire Protection & Security Systems

Mary McLeod Bethune Council House Hazardous Material Report

National Park Service National Capital Parks – East (NACE)

Washington, DC

May 2014

Prepared by:

Protection Engineering Group Chantilly, VA

Contract No. P09PC60802

Task Order No. 24

PMIS No. 169326

Mary McLeod Bethune Council House/PE Group/March 2014

REPORT OF LIMITED HAZARDOUS

BUILDING MATERIALS SURVEY

National Historic Site

1318 Vermont Avenue NW Washington, DC 20005

Prepared for:

Mr. Matthew J. Batbouta, PE

The Protection Engineering Group, Inc.

14585 Avion Parkway, Suite 150

Chantilly, Virginia 20151 mbatbouta@pegroup-inc.com

703-488-2294

Prepared by:

AMEC Environment and Infrastructure, Inc.

14424 Albemarle Point Place, Suite 115 Chantilly, Virginia 20151

703-488-3700

April 29, 2014

AMEC Project: 3552-14-0007 mailto:mbatbouta@pegroup-inc.com

Mary McLeod Bethune Council House April 29, 2014 AMEC Project: 3552-14-0007 Report of Limited Hazardous Building Materials Survey i

TABLE OF CONTENTS

SECTION PAGE

1.0 INTRODUCTION

2.0 ASBESTOS-CONTAINING MATERIALS

2.1 SCOPE OF SERVICES

2.2 FINDINGS AND RESULTS

2.3 ASBESTOS REGULATIONS

2.4 CONCLUSIONS AND RECOMMENDATIONS

3.0 LEAD-CONTAINING SURFACE COATINGS

3.1 SCOPE OF SERVICES

3.2 LEAD SCREENING SURVEY FINDINGS AND RESULTS

3.3 CONCLUSIONS AND RECOMMENDATIONS

Appendix A Asbestos Laboratory Analytical Report Appendix B Lead Laboratory Analytical Report Appendix C Sample Location Drawings & Photograph Log

Correspondence:

AMEC Environment and Infrastructure, Inc.

14424 Albemarle Point Place, Suite 115 Ashburn, Virginia 20147 Tel (703) 488-3700 Fax (703) 488-3701 amec.com

April 29, 2014

Mr. Matthew Batbouta, PE Fire Protection The Protection Engineering Group, Inc.

14585 Avion Parkway, Suite 150 Chantilly, Virginia 20151 mbatbouta@pegroup-inc.com Phone: 703-488-2294

Subject: Limited Hazardous Building Materials Survey Report

14585 Vermont Avenue NW Washington, DC 20005 (38.908205, -77.030974) AMEC Project No. 3552-14-0007

Dear Mr. Batbouta, AMEC Environment and Infrastructure, Inc., (AMEC) is pleased to offer this report for our

Limited Hazardous Building Materials (HBM) survey of the Mary McLeod Bethune Council

House located at 1318 Vermont Avenue NW in Washington, DC. Our services have been provided in accordance with the Standard Form of Agreement between The Protection

Engineering Group, Inc. (PE Group) and AMEC Environment and Infrastructure, Inc. for

Environmental Engineering Consulting Services, and AMEC proposal 3552.PROP14.03, dated

January 31, 2014. This report includes a summary of the project information, scope of services, results, findings, and conclusions and recommendations. Also included with this report are

Asbestos and Lead Laboratory Analytical Results, Sample Location Drawings and Photograph

Log.

The findings and conclusions contained herein are based upon the data that was reviewed and documented in this report, as well as our experience on similar projects. The discovery of any additional information concerning the conditions at the subject property should be reported to us for our review so that we can reassess potential impacts and modify our conclusions, if necessary.

mailto:mbatbouta@pegroup-inc.com iii

This report has been prepared on behalf of and exclusively for the use of PE Group. Should this report and the findings contained herein, in whole or in part, be disseminated or conveyed to any other party or be used or relied upon by any other party, whole or in part, any interpretations made, opinions formed, and conclusions drawn, as a result of examining this report, those interpretations, opinions, and conclusions will be those made, formed, and drawn solely by that party.

We appreciate the opportunity to be of continued service to PE Group. Please call us if you have any questions or if we may be of further service.

Sincerely, AMEC Environment & Infrastructure, Inc.

Brian Rich Joseph Buchy Industrial Hygienist Unit/Project Manager

1.0 INTRODUCTION

Based on information provided by Mr. Matthew Batbouta of The Protection Engineering Group, Inc. (PE Group), AMEC understands that PE Group plans to renovate the Mary McLeod

Bethune Council House located at 1318 Vermont Avenue NW in Washington, DC. It is our understanding that the renovation is limited to installation of a sprinkler and fire alarm system.

Prior to planned renovation activities, PE Group requested that AMEC collect samples of suspect asbestos-containing material (ACM) and suspect lead-containing surface coatings

(LCSC) that were anticipated to be impacted by the planned renovation.

The limited hazardous building material (HBM) survey was conducted by a United States (U.S.)

Environmental Protection Agency (EPA) accredited asbestos inspector licensed in the

Commonwealth of Virginia and experienced in conducting pre-renovation/demolition HBM surveys.

The following sections of this report summarize the survey procedures, results, conclusions, and recommendations for the regulated materials located during the survey.

2.0 ASBESTOS-CONTAINING MATERIALS

2.1 Scope of Services

The limited asbestos survey was performed to locate ACM in locations designated by PE Group within the subject building prior to the planned renovation. ACM is defined by the U.S.

Environmental Protection Agency (EPA) as any material containing greater than one percent asbestos. Friable ACM is defined by the EPA as any ACM which, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. Consideration was also given during the survey to non-friable materials that could be rendered friable by the forces expected to act upon them during the planned renovation activity.

The field efforts were performed by Mr. Brian Rich, a U.S. EPA AHERA-accredited Building

Inspector, with AMEC. Mr. Rich is also an Asbestos Inspector that is licensed by the Virginia

Department of Professional and Occupational Regulation (VDPOR). Field efforts were performed on March 14 and April 1, 2014. This survey was limited to those areas specifically designated by PE group where they anticipated disturbances to suspect asbestos-containing ceiling materials as part of the planned renovation. Our evaluation focused exclusively on suspect asbestos-containing ceiling materials. No attempt was made to disassemble equipment or demolish structural elements or architectural finishes, as this was beyond our scope of authorized services. Due to these limitations, wall voids, building cavities, interior of mechanical equipment, and other areas that were designated by PE Group for inclusion in the survey may contain undocumented ACM or additional quantities of ACM located during the survey.

The sampling protocol was performed in general accordance with EPA Asbestos Hazard

Emergency Response Act (AHERA) (40 CFR Part 763, Subpart E), National Emission

Standards for Hazardous Air Pollutants (NESHAP), (40 CFR Part 61, Subpart M) and U.S.

Occupational Safety and Health Administration (OSHA) Asbestos in Construction Standard (29

CFR Part 1926.1101) sampling protocols. Following a visual inspection of the areas designated by PE Group for suspect ACM, AMEC observed two homogeneous areas (HAs) that were suspected to contain asbestos. A homogeneous area (HA) is defined by AHERA as surfacing material, thermal system insulation material, or miscellaneous material that is uniform in color and texture. Materials suspected of containing asbestos that appear to have similar uses or to have been applied or installed during the same general time period may also be considered homogeneous. AMEC subsequently collected a total of 8 bulk samples (including 10 layers) on

March 14, 2014. Following initial review of analytical results, AMEC returned to the site and collected an additional 6 samples (including 9 layers) on April 1, 2014.

The bulk samples collected during the sampling were submitted under secure chain-of-custody protocols to AMA Analytical Services, Inc. (AMA) laboratory located in Lanham, Maryland for analysis by Polarized Light Microscopy (PLM) coupled with dispersion staining. Samples were analyzed in general accordance with the EPA Method for the Determination of Asbestos in Bulk

Building Materials (EPA 600/R-93/116). AMA is a National Voluntary Laboratory Accreditation

Program (NVLAP) accredited laboratory (Certification #101143-0). Table 1 – Summary of Bulk

Samples below summarizes the suspect ACM observed and sampled during our survey.

Table 1 - Summary of Bulk Samples

Sample Number Sample Description Sample Location

301-01 Decorative Ceiling Plaster Basement Office #1, adjacent to light fixture

301-02 Decorative Ceiling Plaster Basement Office #1, closet (left side)

301-03 Decorative Ceiling Plaster Basement Office #1, closet (right side)

302-01 Drywall 1st Floor, Exhibit next to Bookstore, adjacent to defibrillator

302-02 Drywall 1st Floor, Exhibit next to Bookstore, adjacent to defibrillator

302-03 Drywall/Joint Compound 2nd Floor, Back Office Ceiling

302-04 Drywall/Joint Compound 3rd Floor Bathroom, Above Drop Ceiling Tile

302-05 Drywall/Joint Compound 3rd Floor, Top of Stairwell

1-01 Joint Compound 1st Floor Exhibit Area

1-02 Joint Compound 1st Floor, Stairwell

2-01 Drywall/Joint Compound 2nd Floor, Rear Office

2-02 Drywall/Joint Compound 2nd Floor, Exhibit Closet

Sample Number Sample Description Sample Location

3-01 Drywall/Joint Compound 3rd Floor, Bathroom

3-02 Drywall/Joint Compound 3rd Floor, Office

The asbestos sample location sketch is provided in Appendix C for your reference.

Photographs of the suspect ACM are also presented in Appendix C.

2.2 Results and Findings

Table 2 – Summary of Suspect ACM below summarizes the suspect ACM observed and sampled during our survey.

Table 2 - Summary of Suspect ACM

Suspect Asbestos-Containing Material Description Sample Results Approximate Location

Drywall joint compound No Asbestos Detected Throughout First Floor and Second Floor

Drywall joint compound Trace to 19-percent Chrysotile Asbestos Detected* Throughout Third Floor

Plaster ceiling No Asbestos Detected Basement Office #1 Ceiling

* One sample of joint compound (302-04) was reported to contain trace chrysotile asbestos.

Quantities of asbestos which are reported through PLM analysis to be less than one-percent are considered trace amounts. When PLM analysis of a bulk sample of suspect material indicates that less than ten-percent of asbestos is detected in the material, the material may be assumed to be an asbestos-containing material. To determine that the material is not

ACM, supplemental analysis is required to verify the percentage of asbestos in the bulk sample. As a result, sample number 302-04 was analyzed by Transmission Electron

Microscopy (TEM). AMA subsequently reported 19-percent Chrysotile asbestos in sample number 302-04. AMEC returned to the Mary McLeod Bethune Council House on April 1, 2014 to collect supplemental bulk samples. AMA reported trace Chrysotile asbestos in sample number 3-02 of joint compound. No asbestos was reported in the remaining samples collected on April 1, 2014.

The laboratory analytical reports are provided in Appendix A for your reference.

Findings The following asbestos-containing materials were located during the survey:

Drywall Joint Compound – This material is currently categorized as a Category II non-friable asbestos-containing material by EPA NESHAP, but for renovation/demolition purposes is to be considered Regulated Asbestos-Containing Material (RACM). The drywall joint compound was reported as containing 19-percent Chrysotile asbestos. Due to the inability to separate the drywall and joint compound during removal, it is assumed that the drywall will be removed with the joint compound. Therefore, the estimated quantity of drywall joint compound is based on the estimated quantity of drywall. Approximately 2,000 square feet of ceiling with asbestos-containing joint compound is estimated to be present on the ceiling throughout the second and third floors. Based on the survey observations, the drywall joint compound in the basement is homogeneous with the material located on the third floor and should be treated as ACM if disturbed.

No asbestos was detected in the samples of drywall or joint compound collected from the first or second floors. Based on the PE Group’s statement that the ceilings within the first and second floors had been previously replaced, as well as our observations during our site visit and evaluation of the analytical results, the gypsum board ceilings located on the first and second floors have not been included in the estimated quantity of asbestos-containing joint compound.

2.4 Conclusions and Recommendations

Based on our site observations we offer the following conclusions and recommendations:

1. The sampling located asbestos-containing materials.

2. It is the Building Owner’s responsibility to inform contractors of the known or suspected hazardous or potentially hazardous materials that may be impacted during renovation or demolition.

3. Current NESHAP regulations, as well as the D.C. Municipal Regulations, require that RACM be removed and properly disposed of prior to demolition or renovation activities that disturb RACM. NESHAP regulations also require a notification to be submitted 10 working days prior to any demolition project, regardless of the presence or absence of ACM. The OSHA Construction Standard and the EPA-NESHAP require that contractors have a “Competent Person” on site to identify and properly address unreported suspect asbestos-containing materials that may be discovered during renovation or demolition activities. Current NESHAP regulations require that all RACM be disposed of in landfills approved to accept asbestos waste and that proper waste manifest documentation be prepared and maintained.

4. We recommend that the asbestos-containing materials or portions thereof be removed and disposed of prior to disturbance. The ACM removal should be performed by a qualified and licensed asbestos abatement contractor under controlled conditions.

5. It is important to note that this report is not intended to replace a design for asbestos abatement or to be used as a sole source for obtaining bids for asbestos abatement.

AMEC recommends that an abatement design be prepared for the removal of ACM prior to renovation or demolition.

6. In the event areas of plaster ceilings located within the first or second floor, gypsum board ceilings located within the basement, or ceilings located within the first or second floors that do not appear homogeneous with those sampled will be disturbed, AMEC recommends that the materials be treated as ACM or perform additional appropriate sampling and analyses to confirm or rebut the presence of asbestos.

7. Although our asbestos survey efforts attempted to locate suspect ACM present within the subject building, it is possible that additional suspect ACM or additional quantities of confirmed ACM may be present. Should suspect materials in addition to those reported herein be uncovered or be planned for disturbance, AMEC recommends that work activities be immediately halted until the materials can be sampled and analyzed to confirm or rebut the presence of asbestos.

3.0 LEAD-CONTAINING SURFACE COATINGS

3.1 Scope of Services

AMEC performed visual observations during the survey to identify suspect lead-containing surface coatings within the building. The purpose of the limited screening survey was to provide generalized information regarding the presence of lead-containing building materials for notification to contractors for compliance with the U.S. OSHA Lead in Construction Standard (29

CFR Part 1926.62) during the renovation of the building. AMEC collected 7 paint chip samples from representative suspect surfaces to be analyzed for the presence of lead. The samples were collected from the components by removing a representative sample of the coating from the components until the substrate was visible. The paint chip samples collected during the screening were submitted under secure chain-of-custody protocols to AMA for analysis by

Flame Atomic Absorption Spectrometry (FAA) in accordance with EPA testing methods. The laboratory analytical reports are provided in Appendix B for your reference.

3.2 Results and Findings

The painted components sampled during our efforts, along with corresponding lead content

(percent by weight), are summarized in Table 3 - Lead Paint Chip Sample Summary.

Table 3 - Lead Paint Chip Sample Summary

Sample Number Surface Paint Color Substrate Component Percent Lead by Weight*

Pb-01 Beige Gypsum Board Wall <0.007 Pb-02 Beige Gypsum Board Wall 0.0083 Pb-03 Beige Gypsum Board Wall 0.59 Pb-04 White Gypsum Board Archway <0.01 Pb-05 White Gypsum Board Ceiling <0.0081 Pb-06 Beige Gypsum Board Ceiling <0.0085 Pb-07 White Gypsum Board Wall <0.01

* - The reporting limit for the lead paint chip samples is based on the weight of each sample.

The reporting limit for these samples ranged from 0.0039 to 0.01 percent lead by weight.

Results reported less than (<) a numerical value are below the detection limit for the analytical method.

The evaluation of lead in paint does not meet U.S. Department of Housing and Urban

Development (HUD) guidelines and was not intended for that purpose. The purpose of the evaluation for lead in paint was to provide data to the building owner for notification purposes to individuals and companies working at the facility so that they may be informed to comply with the Lead in Construction Standard.

3.3 Conclusions and Recommendations

The OSHA Lead in Construction Standard does not currently define a specific concentration of lead that must be present within paint for it to be considered "lead-containing." Therefore, painted and glazed surfaces that contain detectable concentrations of lead must be handled in accordance with the OSHA Lead in Construction Standard. Any contractor performing work that could impact paint films or glazing that have detectable concentrations of lead should be informed of the testing results, and should take appropriate actions to comply with the OSHA

Lead in Construction Standard. These appropriate actions would include performing air monitoring to measure worker exposure, assuring that the workers are provided with adequate respiratory protection, and assuring that workers are provided with appropriate training.

Workers performing demolition or stripping of LCSC must have training in accordance with

OSHA Standard 29 CFR Part 1926.62. Personal air sampling must be performed in accordance with the OSHA Lead in Construction regulation to determine if workers are exposed to airborne lead levels above the current OSHA Action Level of 30 micrograms per cubic meter of air

(µg/M³) unless the contractor has previous exposure monitoring data that is representative of the exact nature of each work activity, building component and substrate, and surface coating lead concentration. Under no circumstances should high temperature or abrasive cutting or high speed sanding be performed on any building components that have detectable surface concentrations of lead.

The disposal of waste generated during any restoration, renovation, or demolition operations, including items coated with lead paint, is regulated by U.S. EPA Standard 40 CFR Part 261, Subpart C. This regulation requires that a Toxicity Characteristic Leacheate Procedure (TCLP) be utilized to determine if the waste is to be considered hazardous waste. A material is also considered hazardous if it is ignitable, reactive, corrosive, or toxic.

APPENDIX A

Asbestos Laboratory Analytical Reports

APPENDIX B

Lead Laboratory Analytical Reports

APPENDIX C

Sample Location Drawings and Photographs

Mary McLeod Bethune Council House Photographs Taken March 14 & April 1, 2014 AMEC Project 3552.14.0007 Photo Log

Photograph #1)

View of Office #1 ceiling plaster (301-01)

Photograph #2)

View of Office #1

Photograph #3)

View of Office #1 ceiling plaster (301-01)

Photograph #4)

View of Office #1

Photograph #5)

View of Office #1 closet (sample 301-02)

Photograph #6)

View of Office #1 Closet (sample 301-03)

Photograph #7)

View of drywall of exhibit adjacent to Bookstore (Samples 302-01/02, Pb-01)

Photograph #8)

View of 1st Floor Back Stairwell peeling paint (sample Pb-02, LCSC)

Photograph #9)

View of 2nd Floor exhibit closet (sample Pb-03, LBP)

Photograph #10)

View of 2nd Floor Back Exhibit (sample Pb-03 collected in closet, LBP)

Photograph #11)

View of 2nd floor archway above stairs (sample Pb-04).

Photograph #12)

View of peeling paint on 2nd floor archway above stairs (sample Pb-04).

Photograph #13)

View of 2nd Floor Archway above stairs (Pb-04).

Photograph #14)

View of 2nd Floor Back Office Ceiling (sample 302-03, Pb-05).

Photograph #15)

View of 3rd Floor Bathroom above drop ceiling tile (sample 302-04, 19% Chrysotile).

Photograph #16)

View of 3rd Floor Bathroom above drop ceiling tile (sample 302-04, Pb-06).

Photograph #17)

View of 3rd Floor drywall at top of stairs (Pb-07, 302-05)

Photograph #18)

View of Basement Furnace Room (No suspect ACM observed).

Photograph #19)

Photograph #20)

Photograph #21)

Photograph #22)

View of 2nd floor back office drywall/joint compound (sample 2-01)

Photograph #23)

View of 3rd Floor Bathroom drywall/joint compound (sample 3-01)

Photograph #24)

View of 3rd floor office drywall/joint compound (sample 3-02, trace Chrysotile)

Photograph #25)

View of 2nd Floor exhibit closet (sample 2-02)

Photograph #26)

View of 1st floor exhibit area (sample 1-01)

Photograph #27)

View of 1st floor stairwell drywall/joint compound (sample 1-02)