RIANG Building 12 Hazardous Materials Inspection Report DRAFT 12-17-15.pdf

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HAZARDOUS MATERIALS INSPECTION REPORT

RHODE ISLAND AIR NATIONAL GUARD

BUILDING 12

2 HERCULES DRIVE

NORTH KINGSTOWN, RI 02852

PREPARED FOR:

MR. GREGORY CULPEPPER

POND AND COMPANY, INC.

3500 PARKWAY LANE/SUITE 600

NORCROSS, GA 30092

PREPARED BY:

ATC GROUP SERVICES

333 GEORGE WASHINGTON HIGHWAY

SMITHFIELD, RI 02917

ATC GROUP SERVICES PROJECT 3010000170

JANUARY 9, 2016

TABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY

1.1 ASBESTOS

1.2 LEAD-CONTAINING PAINT

LIMITATIONS

CERTIFICATION OF RESULTS

2.0 ASBESTOS-CONTAINING MATERIALS

2.1 SAMPLING METHODOLOGY

2.2 IDENTIFIED ASBESTOS-CONTAINING MATERIALS

Table 1: Identified Asbestos-Containing Materials

2.3 ANALYTICAL METHOD

2.4 CONSIDERATION FOR HIDDEN MATERIALS

2.5 RECOMMENDATIONS

Table 2: Summary of Non-Asbestos Containing Materials……………………………………………..5

Table 3: Cost Estimates For Removal of Asbestos Containing Materials…………………………….6

3.0 LEAD-CONTAINING PAINT DETERMINATION

3.1 TESTING PROCEDURES - RMD LPA-1 XRF ANALYZER

3.2 SUMMARY OF FINDINGS

Table 4: Lead-Containing Paint Testing Results by XRF

3.3 REGULATORY IMPLICATIONS AND REGULATIONS

APPENDIX A: ASBESTOS BULK SAMPLE ANALYTICAL RESULTS

Pond and Company, Inc. Hazardous Materials Inspection RIANG/Building 12, 2 Hercules Drive, N. Kingstown, RI January 9, 2016

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1.0 EXECUTIVE SUMMARY

ATC Group Services of Smithfield, RI was retained by Pond and Company, Inc. to perform a hazardous building materials inspection of Building #12 located at 2 Hercules Drive, North Kingstown, RI. The inspection was performed in accordance with Cardno ATC Proposal 301-2015-0127.

ATC Group Services’ scope of work included conducting an inspection for asbestos-containing materials (ACM), and lead-containing paint (LCP). ATC Group Services’ scope of work did not include extensive exploratory demolition, disassembly of mechanical / electrical equipment, or investigation of underground storage tanks / structures. ATC Group Services did not conduct exterior below-grade investigations during this survey.

1.1 ASBESTOS

Section 2.0 discusses the asbestos-containing materials inspection and sampling methodology. The inspection involved visual assessment, bulk sampling and inventory of suspect ACM, including locating and quantifying the identified ACM within accessible interior, exterior, and roof areas of Building 12.

The asbestos inspection was performed by ATC Group Services representative Michael Puyana (AAC- 0729) from November 12 to December 9, 2015. A total of forty-seven (47) samples of suspect ACM were collected with forty-three (43) analyzed to determine asbestos content. ATC Group Services’ inspector performed both the visual inspection and bulk sampling in accordance with methods outlined in the U.S.

Environmental Protection Agency (EPA) guidance document titled, "Guidance for Controlling Asbestos- Containing Materials in Buildings" (Document No. 560/5-85/024). Bulk samples were submitted to ProScience Analytical Services, Inc. for analysis. Laboratory analytical results are included as Appendix A. Table 1, found in Section 2.2 presents a list of identified ACM and plans indicating the locations of identified ACM are included as Appendix B.

1.2 LEAD-CONTAINING PAINT

ATC Group Services performed a lead-containing paint determination of representative interior painted surfaces throughout Building 12. The lead-containing paint determination was performed by ATC Group Services representative Xeson Leon on December 3 & 4, 2015. Lead-containing paint testing was performed utilizing an RMD Lead Paint Analyzer via X-Ray Fluorescence (XRF) analysis.

Results of the lead-containing paint determination indicate that lead is present on interior walls, wood, metal, plaster, and structural steel components. Note that contractors performing work at the building where the painted surfaces will be disturbed must comply with the Occupational Safety and Health Administration (OSHA) 29 CFR 1926.62, Lead in Construction. Additional waste disposal requirements may apply in accordance with EPA and RIDEM regulations. Table 4, found in Section 3.2 presents the findings of ATC Group Services lead-containing paint determination.

LIMITATIONS

Our professional services have been performed, our findings obtained and our recommendations prepared in accordance with customary principles and practices in the field of environmental science and engineering. This statement is in lieu of other statements either expressed or implied. This report does not warrant against future operations or conditions, nor does it warrant against operations or conditions present of a type or at a location not investigated.

Environmental evaluations are limited in the sense that conclusions and recommendations are developed and information obtained from limited research and secondary sources. Except as set forth in this report, ATC Group Services has made no independent investigations as to the accuracy or completeness of the information derived from the secondary sources and personal interviews and has presumed that such information was accurate and complete.

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This report is intended for the sole use of Pond and Company, Inc. The scope of services performed in execution of this evaluation may not be appropriate to satisfy the needs of other users, and use or re-use of this document or the findings, conclusions, or recommendations, is at risk of said user.

CERIFICATION OF RESULTS

This report has been prepared for the exclusive use of Pond and Company, Inc. Photocopying of this document by parties other than those designated by the Client, or use of this document for purposes other than it is intended, is prohibited.

Respectfully submitted this 9 th day of January, 2016.

ATC Group Services

Michael Puyana Kelly Hurstak Project Manager District Manager for ATC Group Services for ATC Group Services Direct Line +1 401-640-2080 Direct Line + 1 781-404-1303 Email: michael.puyana@atcassociates.com Email:Kelly.hurstak@atcassociates.com mailto:michael.puyana@atcassociates.com

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2.0 ASBESTOS-CONTAINING MATERIALS

2.1 SAMPLING METHODOLOGY

The inspection was performed by an EPA-accredited and RIDOH certified asbestos inspector. Bulk samples, representing individual homogenous areas of suspect materials, were collected in a randomly distributed manner, in accordance with the methods outlined below.

Building materials exist in the form of thermal systems insulation (TSI), surfacing materials, and miscellaneous materials.

The following generally illustrates the sampling strategy employed by ATC Group Services where feasible:

(a) Surfacing materials - In a randomly distributed manner, collect bulk samples of surfacing materials, representative of each homogeneous area, and not assumed to be ACM.

(1) Collect at least three bulk samples from each homogeneous area that is less than or equal to 1,000 ft

(2) Collect at least five bulk samples from each homogeneous area that is greater than 1,000 ft

, but less than or equal to 5,000 ft

(3) Collect at least seven bulk samples from each homogeneous area that is greater than 5,000 ft

(b) Thermal systems insulation.

(1) In a randomly distributed manner, collect at a minimum, three (3) bulk samples of thermal systems insulation material, representative of each homogeneous area, and not assumed to be ACM.

(2) Collect, at a minimum, one (1) bulk sample of patched thermal systems insulation, representative of each homogenous area, and not assumed to be ACM, providing the section of patch was less than 6 linear or square feet.

(3) Collect, at a minimum, three (3) representative bulk samples of each insulated mechanical system not assumed to be ACM, including, but not limited to cementitious material used on pipe fittings such as tees, elbows, or valves.

Representative sampling was conducted in a manner sufficient as to identify whether each homogenous area is either asbestos or non-asbestos containing.

(4) Bulk samples are not required to be collected from any homogeneous area where the accredited asbestos inspector has determined that the thermal systems insulation is a non-suspect material (i.e., fiberglass, foam glass, rubber, or any other non-ACM).

(c) Miscellaneous materials - Collect, at a minimum, two (2) representative bulk sample of each miscellaneous material not assumed to be ACM, including, but not limited to ceiling tiles, floor tiles, associated floor tile mastic, roofing materials, waterproofing, etc.

Representative sampling was conducted in a manner sufficient as to identify whether each homogenous area is either asbestos or non-asbestos containing.

2.2 IDENTIFIED ASBESTOS-CONTAINING MATERIALS

The following table presents a list of the identified ACM in Building 12. Note that an ACM is defined by state and federal regulations as any material or product containing one percent or greater asbestos by weight.

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Table 1: Identified Asbestos-Containing Materials RIANG/Building 12 – 2 Hercules Drive, N. Kingstown, RI

MATERIAL LOCATION(S)

ESTIMATED

QUANTITY

CONDITION ACM TYPE

Steel Window Glazing

Compound Exterior Walls 12 EA Good 2% Chrysotile

Asphalt Seam Caulking

Compound 1 Interior of Metal Siding 1,000 LF Good 25% Chrysotile

Mudded Thermal

Insulation on Pipe

Fittings

Fiberglass-Insulated Pipe in Rear Storage 2 EA Good 2% Chrysotile

SF: Square Feet; LF: Linear Feet; EA: Each

Notes: 1 – ACM was observed in accessible areas of the Rear Storage area. It is assumed to be present on interior metal siding throughout the building.

2 - Access to the Northwest Storage space was not possible. This space may contain ACM, and should be inspected.

2.3 ANALYTICAL METHOD

Bulk samples of suspect materials were analyzed by ProScience Analytical Services, Inc., of Woburn, Massachusetts (ProScience) using the EPA approved method (EPA/600R-93/116) for polarized light microscopy with dispersion staining (PLM/DS), using the visual estimation technique for asbestos quantification. By using the PLM/DS method, a trained microscopist is able to identify and distinguish between asbestos group minerals and other fibrous materials such as cellulose (paper), mineral (rock), wood or glass fiber. The quantity of each of these substances is estimated on a weight basis and recorded as a percent. Only the asbestos content, if any, is recorded in the bulk sample ‘Report of Analysis’ (Appendix A).

ProScience is certified by the Rhode Island DOH (certification AAL-093) to perform all types of asbestos analysis. ProScience, is also accredited by the EPA National Voluntary Laboratory Accreditation Program (NVLAP). The PLM/DS analytical method is modeled after 40 CFR Part 763, Subpart F, Appendix A: "Interim Method for the Determination of Asbestos in Bulk Insulation Samples."

2.4 CONSIDERATION FOR HIDDEN MATERIALS

ATC Group Services recommends that if a suspect material has not been positively identified, but is similar in mode of occurrence or physical properties as other identified ACM, it should be considered asbestos containing. Only through further sampling and analysis should a suspect material be identified as non-asbestos.

Various areas of Building 12 such as potential wall chases were not accessible during the survey. These spaces may contain suspect building materials. ATC Group Services recommends that any building materials which have not been confirmed through bulk sampling to be non-ACM either be sampled and analyzed to determine their asbestos content, or they be classified as ACM.

Destructive sampling was not permitted during the survey.

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2.5 RECOMMENDATIONS

ATC Group Services recommends that all identified ACM that will be impacted by the proposed construction activity should be removed and disposed of by a Rhode Island licensed Asbestos Contractor prior to disturbance in either routine maintenance activities or planned renovations, and in accordance with applicable local, state and federal regulations.

Table 2: Summary of Non-Asbestos Containing Materials RIANG/Building 12 – 2 Hercules Drive, N. Kingstown, RI

Material Location(s) Sampled

Gypsum Wallboard Stockroom, Restrooms

Joint Compound Associated With Gypsum Wallboard

Lounge

Grout on Floor Drain Lounge Bar Area

Wall Paneling Glue Lounge Bar Area

2’x 2’ & 2’ x 4’ Suspended Ceiling Tile Lounge, Rear Room

Resilient Floor Linoleum & Associated Backing/Adhesives Lounge Bar Area

12”x 12” Floor Tile & Associated Black Mastic– Grey Speckled

Lounge

Metal Siding Seam Caulk South Side Exterior

Masonite Board on Siding Interior Rear Storage

Entryway Roofing Shingle South Side

Entryway Roof Paper South Side

Ceramic Wall Tile & Associated Grout & Adhesive

Restrooms

4” Covebase Molding – Grey, Blue Restrooms, Lounge

Glue Associated With 4” Covebase Molding – Yellow

Restrooms, Lounge

Notes:

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The following table details ATC Group Services’ cost estimates for removal and disposal of the identified ACM associated with Building 12.

Table 3: Cost Estimates for Removal of Identified Asbestos-Containing Materials

Material Estimated Quantity Estimated Unit Cost

Estimated Cost

Steel Window Glazing Compound

12 EA

$200.00 – $250.00 /

EA

$2,400.00 - $3,000.00

Asphalt Seam Caulking Compound

1 1,000 LF $4.00 - $6.00 / LF $4,000.00 - $6,000.00

Mudded Thermal

Insulation on Pipe Fittings

2 EA

$20.00 – $25.00 /

EA

$40.00 - $50.00

Estimated Total $6,440.00 - $9,050.00

Notes: 1 – Cost does not include dismantling and demolition of interior structural building systems to access the seam caulking compound.

3.0 LEAD-CONTAINING PAINT DETERMINATION

ATC Group Services performed a lead-containing paint (LCP) determination of representative interior painted surfaces. Lead-containing paint testing was performed utilizing an RMD Lead Paint Analyzer via X-Ray Fluorescence (XRF) analysis.

3.1 TESTING PROCEDURES - RMD LPA-1 XRF ANALYZER

The RMD Lead Paint Analyzer is a complete lead paint analysis system, which quickly, accurately and non-destructively measures the concentration of Lead Paint on surfaces. The RMD relies on the measurement of the L-shell and K-shell X-rays to determine the amount of lead present in the painted surface. K-shell X-rays can penetrate many layers of paint and allow a good measurement of the lead content of paint to be made without being significantly affected by the thickness or number of layers of paint on the surface of the sample. L-shell X-rays have less penetration and provide a measurement of the surface level lead content of paint.

The RMD has the ability to analyze and compute corrections for the differences in the energy spectrums relating to different substrates. This analysis of the energy spectrum means that the lead paint reading displayed on the instrument already accounts for any substrate effects and no correction is required by the operator.

Upon arrival at the job site, a “validation test” was performed to assure that the instrument was operating properly. A series of three test measurements using the nominal time which was used during the inspection were taken on the NIST Paint Film Standard (SRM No. 2579) as required by the instrument’s Performance Characteristic Sheet (PCS). The individual readings and an average of the three readings were recorded and compared to the standards. In all cases the instrument was functioning within the standard deviation as defined by the manufacturer and the PCS. All validation readings were recorded in the field data of each unit where validation tests were performed.

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3.2 SUMMARY OF FINDINGS

The following XRF readings are in milligrams per square centimeter (mg/cm

). Readings above 0.0 have been highlighted in red.

TABLE 4: LEAD-CONTAINING PAINT TESTING RESULTS BY XRF

RIANG/BUILDING 12 – 2 HERCULES DRIVE, N. KINGSTOWN, RI

LOCATION COMPONENT SUBSTRATE COLOR XRF

RESULTS

(MG/CM2)

BUILDING # 12

UPPER WALL DRY WALL OFF WHITE 0.1

BAR & LOUNGE AREA

LOWER WALL DRY WALL PURPLE 0.0

CHAIR RAIL WOOD VARNISH 0.0

DOOR METAL GREY 0.2

DOOR CASING METAL GREY 0.3

WINDOW SASH WOOD VARNISH 0.0

WINDOW CASING WOOD VARNISH 0.0

RESTROOMS

UPPER WALL PLASTER OFF WHITE 0.0

LOWER WALL PLASTER BROWN 0.1

CEILING DRY WALL OFF WHITE -0.1

DOOR WOOD VARNISH -0.1

DOOR CASING WOOD VARNISH 0.0

3.3 REGULATORY IMPLICATIONS AND REGULATIONS

The implications of lead paint existing in a non-residential building are related to the future use of the facility and the need to impact these painted surfaces during the renovation and demolition process.

The Occupational Safety and Health Administrative (OSHA) does not acknowledge any quantitative threshold for a lead-based paint. Paint with a detectable amount of lead, regardless of the level, is recognized as a lead-containing paint. The possible exposure hazard to workers impacting these coated surfaces should be assessed and contractors and their employees must adhere to the OSHA Lead in Construction standard found at 29 CFR 1926.62. Although OSHA does not recognize negative XRF results as proof that paint does not contain lead, the use of XRF is an efficient real time screening technique for identifying lead-containing paints. To comply with OSHA requirements, a negative XRF result would have to be confirmed by other approved methods. Positive XRF results do not need to be confirmed. Regardless of analytical results, OSHA still requires that personal exposure monitoring be conducted when appropriate to determine lead exposure, even for zero results as determined by any method. To fully comply with EPA regulations, sampling of demolition debris waste streams may be required, depending on the requirements of the receiving facility.

OSHA recognizes that construction type work on surfaces coated with lead-containing paint has a potential to expose workers to hazardous levels of lead and requires that appropriate safety and health measures be followed as stated in 29 CFR 1926.62. OSHA states that until the employer performs an exposure assessment and documents that employees are not exposed above the permissible exposure limit (PEL) of greater than 50 micrograms per cubic meter (µg/m

) of air, the employer must treat employees as if they were exposed above the PEL for the following operations:

Manual renovation and demolition of structures, manual scraping, manual sanding, and use of heat

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Abrasive blasting;

Power tool cleaning;

Lead burning;

Using lead-containing mortar or spray painting with lead-containing paint;

Abrasive blasting, rivet busting, or welding, cutting, or burning on any structure where lead-containing coatings or paint are present;

Cleanup activities where dry expendable abrasives are used; and

Any other task the employer believes may cause exposure in excess of the PEL.

Work precautions include providing respiratory protection, protective work clothing and equipment, change areas, hand washing facilities, biological monitoring, and training until an exposure assessment has determined that the work activity will result in an exposure below the PEL. Additional requirements under this standard include a written compliance program as well as record keeping.

APPENDIX A

ASBESTOS BULK SAMPLE ANALYTICAL RESULTS