Hazard_Assessment_Survey_2013.pdf

HQ: 3015 DUMBARTON ROAD RICHMOND, VA 23228 USA T 804.264.2701 F 804.264.1202 www.FandR.com

VIRGINIA • NORTH CAROLINA • SOUTH CAROLINA • MARYLAND • DISTRICT OF COLUMBIA • EASTERN EUROPE

FROEHLING & ROBERTSON, INC.

Engineering Stability Since 1881

3015 Dumbarton Road

Richmond, Virginia 23228-5831 T 804.264.2701 I F 804.264.1202

HAZARDOUS MATERIALS SURVEY REPORT

Fort Lee Building 3024

Fort Lee, Virginia

Prepared For:

Donald Booth

DJG, Inc.

449 McLaws Circle

Williamsburg, Virginia 23185 T 757-253-0673 F 757-253-2319 dbooth@djginc.com

Prepared By:

Froehling & Robertson, Inc.

Richmond, Virginia 23228

F&R Project Number 60P-0846

December 21, 2012

Prepared by: Reviewed by:

Tariq Mohammed Alan Lederman, CIH, CHMM Industrial Hygienist Project Manager Environmental Services Environmental Services

TABLE OF CONTENTS

1.0 Introduction

2.0 Asbestos-Containing Material (ACM)

2.1 Prior Reports

2.2 Methodology

2.3 Results (Refer also to Appendix A for Laboratory Reports)

2.4 Conclusions and Recommendations

2.5 Applicable Regulations

3.0 Lead-Based Paint (LBP)

3.1 Methodology

3.2 Results (Refer to Appendix B, XRF Data Table for complete listing of sample information)

3.3 Recommendations

4.0 PCB-Containing Light Ballasts

4.1 Methodology

4.2 Results

4.3 Findings and Recommendations

5.0 Mercury-Containing Components

5.1 Methodology

5.2 Results

5.3 Findings and Recommendations

6.0 CFC’s and HCFC’s

6.1 Methodology

6.2 Results

6.3 Conclusions/Recommendations

7.0 Chemical Storage

8.0 Mold

9.0 Limitations

Appendix A – Asbestos Documentation, Laboratory Reports

Appendix B – XRF Data Table Explanation of XRF Data

Appendix C – ACM Location Diagram

Appendix D – Site Photographs

DJG, Inc. Building 3024 HazMat Survey Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

1.0 Introduction

As authorized by Mr. Donald Booth of DJG, Inc., Froehling & Robertson, Inc. (F&R) personnel performed a non-invasive hazardous materials survey at the Fort Lee Building 3024 located in Fort Lee, Virginia, in December 2012. This report serves as an update of a Limited Hazardous Materials Survey Report prepared for the building by F&R and dated December 23, 2010. The information contained in this report supersedes the information contained in the prior report.

The Fort Lee Building 3024 is a CMU frame structure with a brick façade. The original construction date is unknown. The building consists of three (3) above grade levels and a subterranean boiler room. The building is currently being used as housing for soldiers at Fort Lee. F&R was furnished with an Asbestos Management Plan prepared by Versar, Inc. which includes laboratory results of asbestos samples collected in 1987, 1991, 2000, and 2002.

The scope of the hazardous materials survey for this building was limited to the following items:

Non-invasive survey for suspect asbestos-containing materials (ACM);

Screening of surface coatings that may contain lead-based paint (LBP);

Non-invasive inventory of suspect PCB-containing light ballasts, mercury-containing components and CFC/HCFC-containing equipment, chemicals; and a Limited visual survey for mold.

2.0 Asbestos-Containing Material (ACM)

2.1 Prior Reports

F&R was provided an Asbestos Management Plan for Building 3024 prepared by Versar, Inc. which included results of asbestos bulk sample analysis from samples collected in 1987, 1991, 2000, and 2002. F&R also collected asbestos samples in December 2010. The following materials were identified as asbestos-containing in the prior reports:

12”x12” Vinyl Floor Tile in 1st Floor, Lounge Entrance, and Kitchen-10% Chrysotile Pipe Insulation in Mechanical Room-45%-70% Chrysotile Boiler Insulation in Mechanical Room-45% Chrysotile Tank Insulation in Mechanical Room-55% Asbestos (Asbestos material not identified) 9”x9” Tan/Green Vinyl Floor Tile in Mechanical Rooms 317 and 341-2% Chrysotile Roof Vent Flashing-15% Chrysotile Roof Membrane-<1% Chrysotile Yellow Duct Pin Mastic In Room 341 – 5% Chrysotile Black Ceramic Baseboard Mastic in 3rd Floor West Women’s Room – 7% Chrysotile Gray Ceramic Baseboard Mastic in 3rd Floor West Women’s Room - <1% Chrysotile Black Floor Mastic in 3rd Floor West and 2nd Floor East Mechanical Rooms – 4% Chrysotile Door Core Material in 2nd Floor East Mechanical Room – 10% Chrysotile Black Mastic on Both Layers of 12”x12” Floor Tile in 2nd Floor Classroom – 4% Chrysotile

DJG, Inc. Building 3024 HazMat Survey Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

Black Mastic Under Floor Leveling Compound in 1st Floor Hallway – 2% Chrysotile Expansion Joint Caulk at the Rear Exterior of the Building – 3% Chrysotile Exterior Remnant Door Caulk at the Rear Exterior of the Building – 4% Chrysotile Exterior Window Sill Caulk at the Rear Exterior of the Building – 4% Chrysotile Transite Pipe in the Boiler Room – 20% Chrysotile

Based on observations made during our investigation, it appeared that the asbestos-containing 12”x12” and 9”x9” vinyl floor tile, boiler insulation, tank insulation, and roof membrane had been abated and therefore these materials were not included in Table 2-ACM Summary.

2.2 Methodology

For this project, a non-invasive visual survey and sampling for suspect asbestos containing materials were conducted at the above referenced site. All samples were collected by Virginia licensed Asbestos Inspectors and submitted to SanAir Technologies Laboratory (SanAir) in Powhatan, Virginia. SanAir is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) and the Commonwealth of Virginia to analyze suspect asbestos-containing bulk materials. A total of four (4) samples were analyzed using Polarized Light Microscopy (PLM) following EPA Method 600/R-93/116.

2.3 Results (Refer also to Appendix A for Laboratory Reports)

Table 1 ACM Laboratory Results – Fort Lee Building 3024

Sample # Sample Location Material Analytical Results

3024-01 1st Floor Roof Roof Core NAD 3024-02 2nd Floor Roof Roof Core NAD 3024-03 3rd Floor Roof Roof Core NAD 3024-04 1st Floor East Laundry Room Mastic Behind Ceramic Base NAD

NAD – No Asbestos Detected

DJG, Inc. Building 3024 HazMat Survey Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

2.4 Conclusions and Recommendations

Please see Table 2 below for a summary of the ACM and Presumed Asbestos-Containing Materials (PACM) located within Building 3024.

Table 2 ACM and PACM Summary – Fort Lee Building 3024

Material

Description Location Estimated

Quantity Friable? NESHAP

Category Condition Asbestos

Content

Black Floor Tile Mastic*

Throughout Building

30,000 Square Feet No

Category I Non-Friable

ACM

Good 2%-4%

Chrysotile

Yellow Duct Pin Mastic

1st and 3rd Floor Hall HVAC

Chases and Associated

Dorm Rooms

1,000 Square Feet No

Category II Non-Friable

ACM

Fair 5% Chrysotile

Ceramic Baseboard

Mastic/Backing

Restrooms and Laundry Rooms 500 Linear Feet No

Category II Non-Friable

ACM

Fair 7% Chrysotile

Metal Fire Door Insulation

Throughout Exterior, Offices, Dorm Rooms, and Stairwells

150 Doors No Regulated ACM Good 10%

Chrysotile

Expansion Joint Caulk

Expansion Joints

Throughout Exterior

500 Linear Feet No Category II Non-Friable

ACM

Fair 3% Chrysotile

Exterior Remnant Door

Caulk

Exterior Doors Throughout 15-3’x7’ Doors No

Category II Non-Friable

ACM

Fair 4% Chrysotile

Exterior Window Sill

Caulk

Exterior Window Sills Throughout

350-3’x4’ Windows No

Category II Non-Friable

ACM

Fair 4% Chrysotile

Transite Pipe Boiler Room

1 Linear Foot 18” Diameter

Pipe (Unknown Length

Underground)

No Category II Non-Friable

ACM

Fair 20%

Chrysotile

Roof Vent Flashing Roof Vents 200 Linear Feet No

Category I Non-Friable

ACM

Unknown 15%

Chrysotile

DJG, Inc. Building 3024 HazMat Survey Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

ACM and PACM Summary – Fort Lee Building 3024

Material

Description Location Estimated

Quantity Friable? NESHAP

Category Condition Asbestos

Content Non-Fiberglass Pipe and Pipe

Fitting Insulation

Behind Solid Walls and Ceilings

Throughout

Unknown Yes Regulated ACM Unknown 45%-70%

Chrysotile

Pipe Flanges and Gaskets

Behind Solid Walls and Ceilings

Throughout

Unknown No Category I

Non-Friable

ACM

Unknown Presumed

ACM

Interior Boiler Components Boiler Room 1 Boiler No

Category I Non-Friable

ACM

Unknown Presumed

ACM

Vermiculite Insulation within Cinderblock

Walls

Cinderblock Walls

Throughout Building

25,000 Square Feet Yes Regulated

ACM Unknown Presumed

ACM

Vapor Barrier and Associated

Mastic

Behind Brick Façade

25,000 Square Feet No

Category II Non-Friable

ACM

Unknown Presumed

ACM

Freezer Insulation

Walk-In Freezer Outside Kitchen

500 Square Feet Yes Regulated ACM Unknown Presumed

ACM

*All floor tile associated with this mastic should be considered asbestos-containing due to contamination with the asbestos-containing mastic.

F&R offers the following observations in regards to the information presented in Table 2:

Areas behind solid walls and ceilings were inaccessible and could not be visually surveyed for the presence of ACM. ACM including, but not limited to, thermal pipe and pipe fitting insulation may exist in these locations.

The estimates provided are preliminary and are not meant for contractor bidding purposes.

Additional and/or greater quantities of these ACM’s may be discovered during renovation/demolition activities.

F&R recommends that an asbestos abatement specification be developed and incorporated into the overall project prior to renovation and/or demolition of the building.

DJG, Inc. Building 3024 HazMat Survey Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

F&R recommends that an Operation and Maintenance (O&M) plan be developed and implemented to manage all known and suspect ACMs in the building in accordance with 29 CFR 1926.1101 until the building is demolished.

F&R was not granted access to all dorm rooms, and therefore made assumptions related to ACM that may be located in inaccessible rooms based upon the dorm rooms accessed.

The following areas were inaccessible at the time of our site visit: 1st Floor Hallway Mechanical

Rooms and 2nd Floor Roof Mechanical Room.

2.5 Applicable Regulations

EPA / NESHAP Regulations for Asbestos Containing Materials

The U.S. Environmental Protection Agency promulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP) [40 CFR Part 61], which addresses the application, removal, and disposal of asbestos-containing materials (ACM). Under NESHAP the following categories are defined for asbestos-containing materials:

Friable - When dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Non-Friable - When dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Category I Non-Friable ACM - Packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1% asbestos.

Category II Non-Friable ACM – Any material, excluding Category I Non-friable ACM, containing more than 1% asbestos.

Regulated Asbestos Containing Material (RACM) – One of the following:

1. Friable ACM

2. Category I Non-friable ACM that has become friable.

3. Category I Non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading.

4. Category II Non-friable ACM that has a high probability of becoming, or has become, friable by the forces expected to act on the material in the course of demolition or renovation operations.

Under NESHAP, the following actions are required:

1. Prior to the commencement of demolition or renovation activities, the building owner must inspect the affected facility or part of the facility where the demolition or renovation activities will occur for the presence of asbestos.

DJG, Inc. Building 3024 HazMat Survey Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

2. Remove all RACM from the facility before any activity begins that would break up, dislodge, or similarly disturb the material or preclude access for subsequent removal.

3. RACM need not be removed if:

a) It is Category I non-friable ACM that is not in poor condition.

b) It is on a facility component that is encased in concrete or other similar material and is adequately wet whenever exposed.

c) It was not accessible for testing and was therefore not discovered until after demolition began and because of the demolition the material cannot be safely removed.

d) It is Category II non-friable ACM and the probability is low that the material will become crumbled, pulverized, or reduced to powder during demolition.

4. If Category I and Category II Non-Friable ACM’s stay in-place during demolition, then all demolition debris should be disposed of at a landfill that accepts these wastes. Furthermore, if these materials stay in-place during demolition, then some building materials may not be able to be recycled.

3.0 Lead-Based Paint (LBP)

3.1 Methodology

A Commonwealth of Virginia Licensed LBP Inspector performed the testing of painted surfaces for lead during F&R’s December 2010 survey. The testing was conducted by using a Niton XLp-300 X-Ray Fluorometer (XRF) Lead Paint Analyzer. The XRF contains a small radioisotopic source and operates on the principle of x-ray fluorescence, whereby lead atoms in paint are stimulated to emit characteristic x-rays, which are then detected by the instrument. The XRF can measure surface or non-surface concentrations of lead with 95% accuracy at the HUD action level of 1.0 mg/cm2. Levels of lead are reported in units of milligrams per square centimeter (mg/cm2). The XRF is able to accurately detect as little as 0.1 mg/cm2 of lead. The XRF classifies painted surfaces as “positive” or “negative” for lead content based on the HUD action level (1.0 mg/cm2) and the performance characteristics of the XRF.

Positive: Lead is present at or above the HUD standard of 1.0 mg/cm2 on one or more of the components.

Negative: Lead is not present at or above the HUD standard of 1.0 mg/cm2 on any of the components.

The survey was generally conducted using the methodology recommended by the U.S. Department of Housing and Urban Development (HUD). Modifications were made where appropriate for this project. It is important to note that this survey was not a comprehensive, surface-by-surface evaluation, but rather a screening survey of major painted components, which may contain LBP.

DJG, Inc. Building 3024 HazMat Survey Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

3.2 Results (Refer to Appendix B, XRF Data Table for complete listing of sample information)

Lead based paint or lead based glazing was detected on the following representative painted surfaces:

Metal Door Frames Throughout Ceramic Baseboards Throughout Ceramic Block Walls Throughout

3.3 Recommendations

Positive and negative results are based on Commonwealth of Virginia, HUD, and Environmental Protection Agency (EPA) standards. It is important to note that even if a component is negative based on the Commonwealth of Virginia, HUD, and EPA standards, it may still contain concentrations of lead in the paint, which when disturbed, may generate lead dust greater than the Permissible Exposure Limit (PEL) of 50 micrograms per cubic millimeter (ug/m3) as an 8-hour Time Weighted Average (TWA) established by the Occupational Safety and Health Administration (OSHA) “Lead Exposure in Construction Rule (29 CFR 1926.62).”

The OSHA standard gives no guidance on acceptable levels of lead in paint at which no exposure to airborne lead (above the action level) would be expected. Rather, OSHA defines airborne concentrations, and references specific types of work practices and operations from which a lead hazard may be generated (reference 29 CFR 1926.62, section d). Environmental and personnel monitoring should be conducted during any removal/demolition process (as appropriate) to verify that actual personal exposures are below the Permissible Exposure Limit (PEL). Under OSHA requirements, the contractor performing the work will be required to conduct this monitoring and follow all of the other requirements found under 29 CFR 1926.62.

Based on the levels of lead found on painted building components at Building 3024, it is anticipated that these components can be disposed of as non-hazardous waste. However, it is recommended that a Toxic Characteristic Leaching Procedure (TCLP) sample of the waste stream from demolition and renovation activities be collected to verify compliance with Resource Conservation and Recovery Act (RCRA) regulations related to lead. Should painted components from this facility be sent to a recycling facility, this report should be made available to the accepting facility to properly notify them of the lead content of these components. Please not that compliance with RCRA regulations does not relieve the demolition contractor of the personnel air monitoring and respiratory protection required under 29 CFR 1926.62.

4.0 PCB-Containing Light Ballasts

4.1 Methodology

Light ballasts are the electrical components attached to fluorescent light fixtures usually found under a metal overplate. Prior to 1978, ballasts were commonly manufactured with polychlorinated biphenyls (PCBs). PCBs were used in fluorescent light ballasts because of their good electrical insulating capabilities.

Ballasts made after 1978 are usually marked "Non-PCB."

DJG, Inc. Building 3024 HazMat Survey Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

4.2 Results

During this survey, F&R personnel observed approximately six hundred (600) light ballasts throughout the building.

4.3 Findings and Recommendations

F&R recommends that all fluorescent light ballasts in the building that do not contain the “Non-PCB” label be assumed to contain PCBs. Ballasts with a clearly marked “Non-PCB” label are not regulated and can be disposed of with general construction and demolition debris. The fluorescent light ballasts without the “Non-PCB” label should be removed, disposed of and/or recycled according to Federal and Commonwealth of Virginia waste disposal guidelines by an appropriately licensed contractor.

5.0 Mercury-Containing Components

5.1 Methodology

Mercury is used in several building components including fluorescent lamps, thermostats and thermometers.

F&R conducted a visual non-invasive survey to identify mercury-containing components throughout the building.

5.2 Results

During this survey, F&R personnel observed approximately one thousand two hundred (1,200) fluorescent lamps throughout the building and twenty (20) thermometers associated with mechanical equipment in the boiler room and mechanical rooms suspected to contain mercury. No thermostats suspected to contain mercury were observed during our investigation.

5.3 Findings and Recommendations

F&R recommends that all fluorescent lamps and thermometers associated with mechanical equipment be presumed to be mercury-containing. The mercury-containing building components that are to be impacted as part of renovation/demolition activities should be removed, disposed of and/or recycled according to Federal and Commonwealth of Virginia hazardous waste disposal guidelines by an appropriately licensed contractor.

6.0 CFC’s and HCFC’s

6.1 Methodology

Chlorofluorocarbons (CFC’s) and Hydro-chlorofluorocarbons (HCFC’s) are manmade substances commonly found in refrigeration and air conditioning equipment. CFC and HCFC use and disposal is regulated by the Clean Air Act (CAA). F&R performed a visual inspection to identify refrigeration and air conditioning equipment likely to contain CFC’s and HCFC’s.

DJG, Inc. Building 3024 HazMat Survey Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

6.2 Results

A total of six (6) water fountains, two (2) exterior chillers, two (2) exterior air handling units, and one (1) exterior walk-in freezer were observed during our survey. Based on information contained on a tag on the chillers and exterior air handling units, F&R was able to determine that the two (2) air handling units each contained approximately one (1) gallon of R-22 refrigerant and the exterior chillers contained approximately five (5) gallons of R-22 refrigerant each. Based on these figures, F&R assumes approximately two (2) gallons total combined refrigerant in the six (6) water fountains and the exterior walk-in freezer.

Based on this information, F&R estimates that 14 total gallons of R-22 or similar refrigerant are currently contained within the refrigeration lines of the above referenced equipment within Building 3024.

6.3 Conclusions/Recommendations

Prior to disposal, F&R recommends that the refrigerants for the water fountains, chillers, air handling units, and walk-in freezer be recycled by a Commonwealth of Virginia Licensed Heating Ventilation and Air Conditioning contractor.

7.0 Chemical Storage

F&R observed the general storage of three (3) 1-gallon-sized containers of Break-Free CLP gun cleaning solution at the gun cleaning station in the Day Room. General housekeeping measures associated with this product appeared to be good during F&R's site reconnaissance. Obvious evidence of spillage and/or leakage was not observed.

8.0 Mold

F&R conducted a limited visual evaluation for signs of mold/microbial growth. F&R made the following observations during our limited evaluation:

Mold growth was observed above the drop ceiling in Room 334.

F&R recommends that Fort Lee consult with a qualified contractor to verify that all sources of moisture intrusion have been identified and corrected prior to, or concurrently with any mold remediation. All mold remediation activities should be performed in general accordance with the guidelines described in EPA’s September 2008 document “Mold Remediation in Schools and Commercial Buildings”. Due to the visible fungal growth in the affected areas, F&R recommends following the procedures recommended for remediating areas less than 100 square feet.

9.0 Limitations

This report has been prepared for the exclusive use of DJG, Inc. and/or their agents. This service was performed in accordance with generally accepted environmental practices. No other warranty, expressed or implied, is made. Our conclusions and recommendations are based, in part, upon information provided to us by others and our site observations. We have not verified the completeness or accuracy of the information provided by others, unless otherwise noted. Our observations and recommendations are based upon conditions readily

DJG, Inc. Building 3024 HazMat Survey Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012 visible at the site at the time of our site visit, and upon current industry standards. During F&R’s non-invasive inspection, accessible areas were visually surveyed for the presence of suspect asbestos materials, lead-based paint, PCB light ballasts, mercury-containing building components, mechanical equipment likely to contain CFC and HCFC refrigerants, and visual survey for mold. Areas inspected for the above-referenced materials were limited to those designated by the Client.

During this study, suspect asbestos samples were submitted for analysis at an NVLAP-accredited laboratory via polarized light microscopy. As with any similar survey of this nature, actual conditions exist only at the precise locations from which suspect asbestos samples were collected. Certain inferences are based on the results of this sampling and related testing to form a professional opinion of conditions in areas beyond those from which the samples were collected. It is also understood that this is a non-invasive survey so that it is possible that concealed materials may be present that were not accessible during the original survey.

No other warranty, expressed or implied, is made.

During this study, areas were visually inspected for possible mold/microbial growth and moisture intrusion.

Our observations and findings are based upon conditions readily visible at the site at the time of our site visit, analytical tests, and upon current accepted industry standards. The scope of services performed was limited to those requested by the Client and does not constitute a full microbial assessment of the site or a comprehensive moisture survey of the site.

Under this scope of services, F&R assumes no responsibility regarding response actions (e.g. O&M Plans, Encapsulation, Abatement, Removal, etc.) initiated as a result of these findings. F&R assumes no liability for the duties and responsibilities of the Client with respect to compliance with these regulations. Compliance with regulations and response actions are the sole responsibility of the Client and should be conducted in accordance with local, state, and/or federal requirements and should be performed by appropriately qualified and licensed-personnel, as warranted.

Froehling & Robertson, Inc. by virtue of providing the services described in this report, does not assume the responsibility of the person(s) in charge of the site, or otherwise undertake responsibility for reporting to any local, state, or federal public agencies any conditions at the site that may present a potential danger to public health, safety, or the environment. The Client agrees to notify the appropriate local, state, or federal public agencies as required by law, or otherwise to disclose, in a timely manner, any information that may be necessary to prevent any danger to public health, safety, or the environment. The contents of the report should not be construed in any way as a recommendation to purchase, sell, or develop the project site.

APPENDIX A

ASBESTOS DOCUMENTATION, LABORATORY REPORTS

SanAir Technologies LaboratorySanAir Technologies Laboratory

Analysis Report prepared for

Froehling and Robertson, Inc.

Report Date: 12/11/2012 Project Name: Fort Lee Bldg 3024 Project #: 60P-0846 SanAir ID#: 12024514

804.897.1177 www.sanair.com804.897.1177 www.sanair.com

SanAir Technologies Laboratory, Inc.

1551 Oakbridge Drive, Suite B, Powhatan, VA 23139

804.897.1177 Toll Free: 888.895.1177 Fax: 804.897.0070

Web: http://www.sanair.com E-mail: iaq@sanair.com

Froehling and Robertson, Inc.

3015 Dumbarton Road Richmond, VA 23228

December 11, 2012

SanAir ID # 12024514 Project Name: Fort Lee Bldg 3024 Project Number: 60P-0846

Dear T Mohammed, We at SanAir would like to thank you for the work you recently submitted. The 4 sample(s) were received on Friday, December 07, 2012 via Hand Delivered. The final report(s) is enclosed for the following sample(s): 3024-1, 3024-2, 3024-3, 3024-4.

These results only pertain to this job and should not be used in the interpretation of any other job.

This report is only complete in its entirety. Refer to the listing below of the pages included in a complete final report.

Sincerely, Sandra Sobrino Asbestos & Materials Laboratory Manager SanAir Technologies Laboratory

Final Report Includes:

- Cover Letter

- Analysis Pages

- Disclaimers and Additional Information sample conditions:

4 sample(s) in Good condition

804.897.1177 Toll Free: 888.895.1177 Fax: 804.897.0070

Web: http://www.sanair.com E-mail: iaq@sanair.com

Name:

Address:

Froehling and Robertson, Inc.

3015 Dumbarton Road Richmond, VA 23228

Project Number:

P.O. Number:

Project Name:

60P-0846 60P-0846 Fort Lee Bldg 3024

Collected Date:

Received Date:

Report Date:

Analyst:

12/4/2012

12/7/2012 10:45:00 AM

12/11/2012 9:54:28 AM

Tallert, Jonathan G.

Asbestos Bulk PLM EPA 600/R-93/116 Stereoscopic Components Asbestos

SanAir ID / Description Appearance % Fibrous % Non-Fibrous Fibers 3024-1 / 12024514-001 Various 25% Cellulose 65% Other None Detected 1st Floor Roof Core Above Day Non-Fibrous 10% Glass Room Heterogeneous

Stereoscopic Components Asbestos SanAir ID / Description Appearance % Fibrous % Non-Fibrous Fibers 3024-2 / 12024514-002 Various 15% Cellulose 75% Other None Detected 2nd Floor Roof Core Above Day Non-Fibrous 10% Glass Room Heterogeneous

Stereoscopic Components Asbestos SanAir ID / Description Appearance % Fibrous % Non-Fibrous Fibers 3024-3 / 12024514-003 Various 30% Cellulose 60% Other None Detected 3rd Floor Roof Core At Women's Non-Fibrous 10% Glass Staircase Hatch Heterogeneous

Stereoscopic Components Asbestos SanAir ID / Description Appearance % Fibrous % Non-Fibrous Fibers 3024-4 / 12024514-004 Yellow 100% Other None Detected 1st Floor East Landing Mastic Non-Fibrous Behind Ceramic Base Homogeneous

12024514 SanAir ID Number

FINAL REPORT

Certification

Signature: Reviewed:

Date: 12/11/2012 Date: 12/11/2012 Page 1 of 1

Disclaimer

The final report cannot be reproduced, except in full, without written authorization from SanAir.

Fibers smaller than 5 microns cannot be seen with this method due to scope limitations. The accuracy of the results is dependent upon the client’s sampling procedure and information provided to the laboratory by the client. SanAir assumes no responsibility for the sampling procedure and will provide evaluation reports based solely on the sample and information provided by the client. This report may not be used by the client to claim product endorsement by NVLAP, AIHA or any other agency of the U.S. government; and may not be certified by every local, state and federal regulatory agencies.

Revision Date 1/17/2011 Page 1 of 1

APPENDIX B

XRF DATA TABLES

EXPLANATION OF XRF DATA

Re ad in g

N o

Ar ea

Co m po ne nt Su bs tr at e

Co nd iti on

Co lo r U ni ts

Ac tio n Le ve l

Pb C

LB

P

Y/ N m g/ cm

^2

N

/A m g/ cm ^2

0.

N

/A m g/ cm ^2

0.

N

/A

1s t F lo or

H al lw ay

W al l Ci nd er bl oc k Go od W hi te m g/ cm ^2

0.

N o

1s t F lo or

H al lw ay

Ba se bo ar d Ce ra m ic G oo d

Ta n m g/ cm ^2

2.

Ye s

1s t F lo or

H al lw ay

Co lu m n

Co nc re te

Go od

W hi te m g/ cm

^2

0.

N o

Ex er ci se R oo m

Do or

F ra m e

M et al G oo d

Bl ue m g/ cm ^2

1.

Ye s

Ex er ci se

R oo m Do or M et al

Go od

Bl ue m g/ cm ^2

0.

N o

Ex er ci se

R oo m Ce ili ng

W oo d Go od W hi te m g/ cm ^2

N o

Ex er ci se R oo m

W al l Pl as te r Go od W hi te m g/ cm ^2

N o

Ex er ci se R oo m

Fl oo r T ile

Ce ra m ic

Go od

Re d m g/ cm ^2

0.

N o

Ex er ci se

R oo m Do or F ra m e W oo d

Go od

Bl ue m g/ cm ^2

N o

Ex er ci se R oo m

Do or

W oo d Go od Bl ue m g/ cm

^2

0.

N o

Ex er ci se R oo m

W in do w

S ill

W oo d Go od W hi te m g/ cm ^2

N o

1s t F lo or L au nd ry R oo m

Fl oo r T ile

Ce ra m ic

Go od

Br ow n m g/ cm

^2

0.

N o

1s t F lo or L au nd ry R oo m

W al l Ci nd er bl oc k Go od W hi te m g/ cm ^2

0.

N o

1s t F lo or

L au nd ry

R oo m Du ct M et al

Go od

W hi te m g/ cm

^2

0.

N o

1s t F lo or L au nd ry R oo m

Ce ili ng Co nc re te Go od W hi te m g/ cm ^2

N o

1s t F lo or L au nd ry R oo m

Ra di at or

M et al Go od W hi te m g/ cm ^2

N o

1s t F lo or L au nd ry R oo m

W al l Co nc re te Go od Bl ue m g/ cm

^2

0.

N o

1s t F lo or M en 's

Ro om

Sh ow er T ile Ce ra m ic Go od Gr ay m g/ cm

^2

0.

N o

1s t F lo or M en 's

Ro om

W al l T ile

Ce ra m ic

Go od

Ta n m g/ cm ^2

0.

N o

2n d

Fl oo r S ta irw el l Do or F ra m e M et al

G oo d Bl ue m g/ cm

^2

1.

Ye s

2n d Fl oo r H al lw ay W al l

Ci nd er bl oc k

Go od

W hi e m g/ cm

^2

N o

2n d

Fl oo r H al lw ay

Do or

W oo d Go od Bl ue m g/ cm

^2

0.

N o

2n d Fl oo r L au nd ry R oo m

Bl oc k W al l

Ce ra m ic

G oo d Ta n m g/ cm

^2

2.

Ye s

2n d Fl oo r L au nd ry R oo m

W al l Ci nd er bl oc k Go od W hi te m g/ cm ^2

0.

N o

2n d

Fl oo r L au nd ry

R oo m Du ct M et al

Go od

W hi te m g/ cm

^2

N o

2n d

Fl oo r G am e Ro om W al l

Sh ee tr oc k Go od W hi te m g/ cm ^2

N o

2n d Fl oo r G am e

Ro om

Ch ai r R ai l W oo d

Go od

Bl ue m g/ cm ^2

N o

2n d Fl oo r G am e

Ro om

W an sc ot in g

W oo d Go od Bl ue m g/ cm

^2

N o

2n d

Fl oo r G am e Ro om Ba se bo ar d

W oo d Go od Bl ue m g/ cm

^2

N o

CA

LI

BR

AT

E

CA

LI

BR

AT

E

CA

LI

BR

AT

E in g

N o

Ar ea

Co m po ne nt Su bs tr at e

Co nd iti on

Co lo r U ni ts

Ac tio n Le ve l

Pb C

LB

P

Y/ N

Fo ye r

W al l Br ic k

Go od

W hi te m g/ cm

^2

0.

N o

Fo ye r

W al l Br ic k

Go od

Re d m g/ cm ^2

0.

N o

Ex te rio r

Do or

M et al Go od Br ow n m g/ cm ^2

N o

Ex te rio r Do or F ra m e M et al

Go od

Br ow n m g/ cm

^2

N o m g/ cm ^2

N /A m g/ cm

^2

N

/A m g/ cm ^2

N /A

CA

LI

BR

AT

E

CA

LI

BR

AT

E

CA

LI

BR

AT

The table header displays Inspector’s name and license number, XL-309 serial number, the job site location, and sampling date.

Column Description

No Consecutive sample numbers assigned by the instrument at testing time.

Area Testing site location(s).

Component The building component being tested.

Substrate The type of material underlying the painted surface.

Clr Color of the painted or varnished surface.

Result Result of the test: NEG = negative

POS = positive INCOM = incomplete test / reading error

There is no inconclusive range for the Niton XL-309.

Action Level Concentration of lead defined as lead-based paint.

Pbc Combined L and K-Shell x-ray readings of lead level (in milligrams per square centimeter).

APPENDIX C

ACM LOCATION DIAGRAMS

BUILDING 3024 1st FLOOR ACM LOCATIONS

DORM ROOMS

DORM

ROOM

DORM

ROOM

DORM

DORM

ROOM DORM ROOMS

STAIRWELL

DORM ROOMS DORM ROOMS

STORAGE

OFFICE

O F F I C

S

LATRINE

LAUNDRY

LATRINE

SUPPLY

STORAGE

NOTE: DRAWING NOT TO SCALE

DAY

KITCHEN

BOILER ROOM

Yellow Duct Pin Mastic

Black Ceramic Baseboard Mastic

Transite Pipe

Asbestos-containing black floor tile mastic and fire doors were identified throughout the interior.

Asbestos-containing expansion joint caulk, remnant door caulk, and window sill caulk was identified throughout the exterior. Asbestos-containing roof vent flashing was identified on the roof. Refer to the Hazardous Materials Survey Report, prepared by Froehling & Robertson, dated December 21, 2012.

LAUNDRY

BUILDING 3024 2nd FLOOR SAMPLE LOCATIONS

DORM

ROOM

DORM

ROOM

DORM

ROOM

DORM

ROOM

DORM ROOMS DORM

MECHANICAL ROOM

DORM

MECHANICAL ROOM

D O R M

R O O M S

LATRINE

LAUNDRY

LAUNDRY

Black Ceramic Baseboard Mastic

Asbestos-containing black floor tile mastic and fire doors were identified throughout the interior.

Asbestos-containing expansion joint caulk, remnant door caulk, and window sill caulk was identified throughout the exterior. Asbestos-containing roof vent flashing was identified on the roof. Refer to the Hazardous Materials Survey Report, prepared by

BUILDING 3024 3rd FLOOR SAMPLE LOCATIONS

DORM

ROOM

DORM

ROOM

DORM

ROOM

DORM

ROOM

DORM ROOMS DORM

MECHANICAL ROOM

DORM

MECHANICAL ROOM

D O R M

R O O M S

LATRINE

LAUNDRY

LAUNDRY

Yellow Duct Pin Mastic

Black Ceramic Baseboard Mastic

Asbestos-containing black floor tile mastic and fire doors were identified throughout the interior.

Asbestos-containing expansion joint caulk, remnant door caulk, and window sill caulk was identified throughout the exterior. Asbestos-containing roof vent flashing was identified on the roof. Refer to the Hazardous Materials Survey Report, prepared by

APPENDIX D

SITE PHOTOGRAPHS

1. View of mercury-containing thermometer associated with mechanical equipment.

2. View of asbestos-containing black floor tile mastic in 3rd Floor West

Mechanical Room

3. View of suspect visible mold growth on ceiling of Room 334.

4. View of asbestos-containing door core material.

5. View of 12”x12” gray vinyl floor tile with brown and white streaks with asbestos-containing black mastic.

6. View of asbestos-containing yellow duct pin mastic.

7. View of asbestos-containing ceramic baseboard mastic.

8. View of asbestos-containing expansion joint caulk.

9. View of asbestos-containing window sill caulk.

10. View of asbestos-containing remnant door caulk.

11. View of chiller with CFC/HCFC-containing refrigerant.

12. View of asbestos-containing transite pipe in boiler room.

HQ: 3015 DUMBARTON ROAD RICHMOND, VA 23228 USA T 804.264.2701 F 804.264.1202 www.FandR.com

FROEHLING & ROBERTSON, INC.

Engineering Stability Since 1881

Richmond, Virginia 23228-5831 T 804.264.2701 I F 804.264.1202

Building 3118

DJG, Inc.

449 McLaws Circle

Williamsburg, Virginia 23185

1.0 Introduction

2.0 Asbestos-Containing Material (ACM)

2.1 Prior Reports

2.2 Methodology

2.3 Results (Refer also to Appendix A for Laboratory Reports)

2.4 Conclusions and Recommendations

2.5 Applicable Regulations

3.0 Lead-Based Paint

3.1 Methodology

3.2 Results

3.3 Recommendations

4.0 PCB-Containing Light Ballasts

4.1 Methodology

4.2 Results

4.3 Findings and Recommendations

5.0 Mercury-Containing Components

5.1 Methodology

5.2 Results

5.3 Findings and Recommendations

6.0 CFC’s and HCFC’s

6.1 Methodology

6.2 Results

6.3 Conclusions/Recommendations

7.0 Chemical Storage

8.0 Mold

9.0 Limitations

Appendix A – Asbestos Documentation, Laboratory Reports

Appendix B – XRF Data Table Explanation of XRF Data

Appendix C – ACM Location Diagram

Appendix D – Site Photographs

DJG, Inc. Building 3118 Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

As authorized by Mr. Donald Booth of DJG, Inc., Froehling & Robertson, Inc. (F&R) personnel performed a non-invasive hazardous materials survey at the Fort Lee Building 3118 located in Fort Lee, Virginia, in December 2012. This report serves as an update of a Limited Hazardous Materials Survey Report prepared for the building by F&R and dated December 23, 2010. The information contained in this report supersedes the information contained in the prior report.

The Fort Lee Building 3118 is a CMU frame structure with a brick façade. The original construction date is 1960. The building consists of three above grade levels and one subterranean level. The building is currently being used as housing for soldiers at Fort Lee. F&R was furnished with an Asbestos Management Plan prepared by Versar, Inc. which includes laboratory results of asbestos samples collected between 1987 and 2003.

The scope of the hazardous materials survey for this building consisted of the following items only:

Screening of surface coatings that may contain lead-based paint (LBP);

Non-invasive inventory of suspect PCB-containing light ballasts, mercury-containing components and CFC/HCFC-containing equipment, chemical storage; and

F&R was provided an Asbestos Management Plan for Building 3118 prepared by Versar, Inc. which included results of asbestos bulk sample analysis from samples collected in 1987 and 2003. F&R also collected asbestos samples in November 2010. The following materials were identified as asbestos-containing in the prior reports:

Vinyl Floor Tile Mastic Throughout Building-5%-19% Chrysotile Asbestos Aircell Pipe Insulation in 1st Floor Pipe Chase Beneath N,S Stairwells-80% Asbestos (asbestos material not identified) Roof Vent Flashing-15%-20% Chrysotile Asbestos Damper Cloth on Roof-90% Chrysotile Asbestos Boiler Door Insulation-5% Chrysotile Asbestos (asbestos material not identified) Floor Expansion Caulk on Metal Floor Divider in Mess Hall – 2% Chrysotile Exterior Window Concrete Sill Caulking – 5% Chrysotile

Based on observations made during our investigation it appeared that the boilers were replaced circa 2003/2004 and therefore the boiler door insulation material was not included in Table 2-ACM Summary of this report.

DJG, Inc. Building 3118 Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

2.2 Methodology

For this project, a non-invasive visual survey and sampling for suspect asbestos containing materials were conducted at the above referenced site. All samples were collected by Virginia licensed Asbestos Inspectors and submitted to SanAir Technologies Laboratory (SanAir) in Powhatan, Virginia. SanAir is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) and the Commonwealth of Virginia to analyze suspect asbestos-containing bulk materials. A total of four (4) samples were analyzed using Polarized Light Microscopy (PLM) following EPA Method 600/R-93/116.

2.3 Results (Refer also to Appendix A for Laboratory Reports)

ACM Laboratory Results – Fort Lee Building 3118

Sample # Sample Location Sample Type Analytical Results

3118-1 1st Floor Day Room Roof Roof Core NAD

3118-2 2nd Floor Day Room Roof Roof Core NAD

3118-3 3rd Floor Roof Roof Core NAD

3118-4 1st Floor Laundry Room Mastics Behind Ceramic Base NAD

NAD – No Asbestos Detected

2.4 Conclusions and Recommendations

Please see Table 2 below for a summary of the ACM and Presumed Asbestos-Containing Materials (PACM) located within Building 3118.

ACM and PACM Summary – Fort Lee Building 3118

Sample Description Location Estimated Quantity Friable? Asbestos Content

Black Floor Tile Mastic*

Throughout Building 40,000 Square Feet No 3%-5% Chrysotile

Floor Expansion Joint Caulk Mess Hall 25 Linear Feet No 2% Chrysotile

Exterior Window Sill Caulk

Throughout Exterior 350-3’x4’ Windows No 5% Chrysotile

DJG, Inc. Building 3118 Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

ACM and PACM Summary – Fort Lee Building 3118

Aircell Pipe Insulation (and other non-fiberglass pipe and pipe fitting insulation)

Behind Solid Walls and Ceilings Throughout

Unknown Yes 80% Asbestos

(asbestos material not identified)

Roof Vent Flashing Roof 300 Linear Feet No 15%-20% Chrysotile

Damper Cloth Roof 50 Linear Feet No 90% Chrysotile

Metal Fire Door Insulation

Throughout Exterior and

Stairwells 150 Doors No Presumed ACM

Water Fountain Pipe Wrap

Water Fountains at Restrooms 6 Water Fountains No Presumed ACM

Pipe and Mechanical

Equipment Flanges and Gaskets

Behind Solid Walls and Ceilings Throughout

Unknown No Presumed ACM

Vermiculite Insulation within

Cinderblock Walls

Cinderblock Walls Throughout

Building 35,000 Square Feet Yes Presumed ACM

Vapor Barrier and Associated Mastic

Behind Brick Façade at Building Foundation

35,000 Square Feet No Presumed ACM

Cementitious Pipe Mechanical Room Underground Unknown No Presumed ACM

Cementitious Panels

Above Exterior Windows and Doors

Throughout Building

300-1’x3’ Panels No Presumed ACM

Freezer Insulation Kitchen Walk-In Freezer 500 Square Feet Yes Presumed ACM

*All floor tile associated with this mastic should be considered asbestos-containing due to contamination with the asbestos-containing mastic.

F&R offers the following observations in regards to the information presented in Table 2:

DJG, Inc. Building 3118 Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012 renovation/demolition activities.

2.5 Applicable Regulations

EPA / NESHAP Regulations for Asbestos Containing Materials

The U.S. Environmental Protection Agency promulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP) [40 CFR Part 61], which addresses the application, removal, and disposal of asbestos-containing materials (ACM). Under NESHAP the following categories are defined for asbestos-containing

Non-friable - When dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Category I Non-friable ACM - Packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1% asbestos.

Category II Non-friable ACM – Any material, excluding Category I Non-friable ACM, containing more than 1% asbestos.

Regulated Asbestos Containing Material (RACM) – One of the following:

1. Friable ACM

2. Category I Non-friable ACM that has become friable.

3. Category I Non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading.

4. Category II Non-friable ACM that has a high probability of becoming, or has become, friable by the

1. Prior to the commencement of demolition or renovation activities, the building owner must inspect the affected facility or part of the facility where the demolition or renovation activities will occur for the

DJG, Inc. Building 3118 Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

2. Remove all RACM from the facility before any activity begins that would break up, dislodge, or similarly

b) It is on a facility component that is encased in concrete or other similar material and is adequately wet whenever exposed.

c) It was not accessible for testing and was therefore not discovered until after demolition began and because of the demolition the material cannot be safely removed.

d) It is Category II non-friable ACM and the probability is low that the material will become crumbled, pulverized, or reduced to powder during demolition.

4. If Category I and Category II Non-Friable ACM’s stay in-place during demolition, then all demolition debris should be disposed of at a landfill that accepts these wastes. Furthermore, if these materials stay in-place during demolition, then some building materials may not be able to be recycled.

3.0 Lead-Based Paint

3.1 Methodology

A Commonwealth of Virginia Licensed LBP Inspector performed the testing of painted surfaces for lead during F&R’s November 2010 survey. The testing was conducted by using a Niton XLp-300 X-Ray Fluorometer (XRF) Lead Paint Analyzer. The XRF contains a small radioisotopic source and operates on the principle of x-ray fluorescence, whereby lead atoms in paint are stimulated to emit characteristic x-rays, which are then detected by the instrument. The XRF can measure surface or non-surface concentrations of lead with 95% accuracy at the HUD action level of 1.0 mg/cm2. Levels of lead are reported in units of milligrams per square centimeter (mg/cm2). The XRF is able to accurately detect as little as 0.1 mg/cm2 of lead. The XRF classifies painted surfaces as “positive” or “negative” for lead content based on the HUD action level (1.0 mg/cm2) and the performance characteristics of the XRF.

During F&R’s December 2012 survey, a paint chip sample was submitted under chain-of-custody to SanAir Technologies Laboratory (SanAir), an American Industrial Hygiene Association (AIHA) Laboratory Accreditation Programs, LLC (LAP) accredited laboratory for the analysis of Environmental Lead. SanAir analyzed the lead content of the sample utilizing Flame Atomic Absorption via Environmental Protection Agency (EPA) Method SW846 7420. The reporting limit for this method is 10 micrograms of lead. The results of this analysis were compared to the U.S. Housing and Urban Development (HUD) and Virginia Department of Professional and Occupational Regulation (DPOR) threshold for lead-based paint of 0.5% by weight.

Positive: Lead is present at or above the HUD standard of 1.0 mg/cm2 on one or more of the components.

Negative: Lead is not present at or above the HUD standard of 1.0 mg/cm2 on any of the components.

DJG, Inc. Building 3118 Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

The survey was generally conducted using the methodology recommended by the U.S. Department of Housing and Urban Development (HUD). Modifications were made where appropriate for this project. It is important to note that this survey was not a comprehensive, surface-by-surface evaluation, but rather a screening survey of major painted components, which may contain LBP.

3.2 Results (Refer to Appendix A, Laboratory Reports and Appendix B, XRF Data Table for complete listing of sample information)

Lead based paint or lead based glazing was detected on the following representative painted surfaces:

Tan Ceramic Baseboard Tiles Throughout Hallways, Laundry Rooms, and Restrooms;

Tan Ceramic Wall Tile Throughout Laundry Rooms and Restrooms; and Metal Door Frames Throughout.

3.3 Recommendations

Positive and negative results are based on Commonwealth of Virginia guidelines. It is important to note that even if a component is negative based on the Commonwealth of Virginia’s standard, it may still contain concentrations of lead in the paint, which when disturbed, may generate lead dust greater than the Permissible Exposure Limit (PEL) of 50 micrograms per cubic millimeter (ug/m3) as an 8-hour Time Weighted Average (TWA) established by the OSHA “Lead Exposure in Construction Rule (29 CFR 1926.62).”

The OSHA standard gives no guidance on acceptable levels of lead in paint at which no exposure to airborne lead (above the action level) would be expected. Rather, OSHA defines airborne concentrations, and references specific types of work practices and operations from which a lead hazard may be generated (reference 29 CFR 1926.62, section d). Environmental and personnel monitoring should be conducted during any removal/demolition process (as appropriate) to verify that actual personal exposures are below the Permissible Exposure Limit (PEL). Under OSHA requirements, the contractor performing the work will be required to conduct this monitoring and follow all of the other requirements found under 29 CFR 1926.62.

Based on the levels of lead found on painted building components at Building 3118, it is anticipated that these components can be disposed of as non-hazardous waste. However, it is recommended that a Toxic Characteristic Leaching Procedure (TCLP) sample of the waste stream from demolition and renovation activities be collected to verify compliance with Resource Conservation and Recovery Act (RCRA) regulations related to lead. Should painted components from this facility be sent to a recycling facility, this report should be made available to the accepting facility to properly notify them of the lead content of these components. Please not that compliance with RCRA regulations does not relieve the demolition contractor of the personnel air monitoring and respiratory protection required under 29 CFR 1926.62.

DJG, Inc. Building 3118 Fort Lee, Virginia F&R Project # 60P0846 December 21, 2012

4.0 PCB-Containing Light Ballasts

4.1 Methodology

Light ballasts are the electrical components attached to fluorescent light fixtures usually found under a metal overplate. Prior to 1978, ballasts were commonly manufactured with polychlorinated biphenyls (PCBs). PCBs were used in fluorescent light ballasts because of their good electrical insulating capabilities.

Ballasts made after 1978 are usually marked "Non-PCB."

4.2 Results

During this survey, F&R personnel observed approximately five hundred (500) light ballasts throughout the building.

4.3 Findings and Recommendations

F&R recommends that all fluorescent light ballasts in the building that do not contain the “Non-PCB” label be assumed to contain PCBs. Ballasts with a clearly marked “Non-PCB” label are not regulated and can be disposed of with general construction and demolition debris. The fluorescent light ballasts without the “Non-PCB” label should be removed, disposed of and/or recycled according to Federal and Commonwealth of Virginia waste disposal guidelines by an appropriately licensed contractor.

5.0 Mercury-Containing Components

5.1 Methodology

Mercury is used in several building components including fluorescent lamps, thermostats and thermometers.

F&R conducted a visual non-invasive survey to identify mercury-containing components throughout the building.

5.2 Results

During this survey, F&R personnel observed approximately one thousand (1,000) fluorescent lamps and ten

(10) thermometers associated with mechanical equipment suspected to contain mercury. No thermostats suspected to contain mercury were observed during our investigation.

5.3 Findings and Recommendations

F&R recommends that all fluorescent lamps and thermometers associated with mechanical equipment…