DLA_OPS_Breezeway_Design_Narrative.pdf

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DLA / DSCR Bldg. 31F Operations Breezeway Center Federal contract opportunity
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W91236-17-B-0010
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Department of the Army Corps of Engineers Engineering District Norfolk

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DLA OPS Breezeway Design Narrative

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DLA BUILDING 31-F

OPERATIONS CENTER BREEZEWAY

DEFENSE LOGISTICS AGENCY - AVIATION

Defense Supply Center Richmond (DSCR), Richmond, Virginia

USACE Contract No. W91236-13-D-0035 WTS Project Number 1303-CC

DESIGN ANALYSIS

FINAL SUBMITTAL

Date: 20 SEPTEMBER 2016

Waller, Todd & Sadler Architects, Inc.

Geo Environmental Resources, Inc.

NRW Engineering, P.C.

J.P. Harvey Engineering Solutions

Jensen Hughes, Inc.

TABLE OF CONTENTS

DESIGN ANALYSIS

GENERAL

CHAPTER I ARCHITECTURAL

CHAPTER II STRUCTURAL

CHAPTER III MECHANICAL

CHAPTER IV ELECTRICAL

CHAPTER V FIRE PROTECTION

DESIGN ANALYSIS APPENDICES

TAB A HAZARDOUS MATERIALS REPORTS

TAB B FIRE PROTECTION DESIGN ANALYSIS

GENERAL

1. Directive Authorization

a. Project Title: DLA Building 31-F Operations Center Breezeway, Defense Logistics Agency-Aviation

b. Project Location: Defense Supply Center Richmond (DSCR), Richmond, Virginia

c. Contract Number: W91236-13-D-0035

d. Scope:

The purpose of this project is to Renovate the existing Bay F portion of Warehouse Building 31. Construction provisions shall include demolition and construction of a covered passageway to take DLA personnel from the Parking Lot to the north of Building 31 to the functions located to the south side of Building 31.

2. Purpose and Function

The Phase I Operations Center shall be designed to provide weather protected walk/pathway to entrances of Primary Level Field Activity command headquarters from employee parking at rear of building and between Primary Level Field Activity command headquarters and existing conference center at front of building. Breezeway will provide weather provided exterior seating. The Breezeway is intended to support the entire Operations Center.

3. Design Scope

The design scope of work includes the preparation of construction drawings, specifications, design analysis and design calculations for the construction of the DLA Bay 31-F Operations Center Breezeway and all related work agreed upon in the Scope of Work prepared by the USACE, Norfolk District.

4. Site Visit

The project site has been visited by the Design Team on at least one occasion. Field verification and documentation has been performed by the Design Team and all findings are included in the design documents.

5. Government-Furnished Equipment

Those components that would be considered “built-in” shall be protected/preserved for installation upon the completion of Construction.

6. Waste Areas and Haul Routes

All debris and material resulting from the Contractor's operations will be disposed of off Government Property. Construction traffic will be routed as directed by the Contracting Officer.

Laydown areas, as needed, will be established per the Government as directed at the pre-construction meeting.

8. Security Provisions

Security provisions shall comply with requirements of DLA.

9. Constructability/Project Phasing

The proposed design utilized readily available materials. All materials utilized shall comply with the requirements of the Buy American Act. No unusual trades will be required for this project.

Standard construction methods and practices shall be employed.

CHAPTER I - ARCHITECTURAL

1. Applicable Criteria

a. Unified Facilities Criteria (UFC), latest edition

b. UFC 1-200-01, General Building Requirements, Change 1, 19 July 2011,

c. IBC International Building Code (IBC), 2012 edition National Fire Protection Association

(NFPA)

d. NFPA 101, Life Safety Code (LSC), 2012 edition

e. Other NFPA codes and standards apply to the project and are referenced in these documents.

2. General Summary Statement

This project will renovate Bay-F of Building 31, an approximately 17,900 SF one-story facility.

3. Existing Site Conditions

The site is currently occupied by Building 31, bays F through M. The construction of the DLA Operations Center is adjacent to the west. The Lotts Conference Center is to the east of Bay F (Bay G). To the north of the site is a large parking lot that accommodates employees and visitors to the DLA Operations Center, Building 31 and the DSCR Lotts Conference Center.

Building 32 is south of our project site.

4. Demolition of Existing Elements

Portions of Building 31, Bay F will require demolition as part of the renovation. During demolition, some existing red brick from the warehouse structure will be salvaged and cleaned for use as an accent brick in the renovated Breezeway construction. The exact quantity will be determined prior to bid so prospective contractors can quantify the extent of the salvage effort.

Modifications to existing interior brick walls to remain which will become exterior bricks walls will be required in order to ensure the walls are water tight and structurally sound. During Demolition, it is possible that Hazardous Materials may be present. A complete Hazardous Materials Report can be found in Appendix A.

5. Architectural Design Solution

a. Main Entrance Doors on the South side of the building shall be aluminum doors within in a storefront assembly with an Architectural Class 1 bronze anodized finish, fully glazed, with medium styles and a thermal break design. The North side entrances shall be similar. All exterior aluminum doors and window frames will be “bronze” anodized aluminum with low-E insulated glazing with the interior pane laminated in accordance with AT/FP requirements. All other doors (non-entrance doors) will be galvanized, insulated hollow metal steel doors.

b. Windows integrated within the Storefront assemblies shall be fixed/non-operable with low-E insulated glazing with the interior pane laminated in accordance with AT/FP requirements.

c. Most interior partitions will be cold formed steel studs with painted gypsum board finish unless otherwise noted on the plans. All paints shall be listed on the “Approved Product List” of the Master Painters Institute (MPI). Throughout the Breezeway, salvaged brick from the demolished warehouse building 31 will be used as a wall veneer/accent.

d. At high ceiling areas in the Breezeway, no ceilings will be provided, exposing the lighting, mechanical systems and underside of the structure above.

6. Handicapped Accessibility

The entire Breezeway is designed to meet all handicapped accessibility requirements set forth in the Architectural Barriers Act (ABA).

7. Furnishings/Comprehensive Interior Design (CID)

Those components that would be considered “built-in” are being provided as part of this Scope of Work.

All furniture layouts included in this package have been coordinated to capture all requirements needed within the space. Fabric, laminates, and paint selections for furniture and furnishings will be coordinated with the interior building finishes and fixtures to provide a comprehensive design. All power and communication requirements will be coordinated with the furniture and furnishings layout to provide a turn-key space at project completion.

CHAPTER II– STRUCTURAL

1. Applicable Criteria

a. Unified Facilities Criteria (UFC)

b. UFC 1-200-01, General Building Requirements, 1 July 2013

c. UFC 3-301-01, Structural Engineering, 1 June 2013

d. UFC 3-310-04, Seismic Design for Buildings, 1 June 2013

e. UFC 4-010-01, DoD Minimum Antiterrorism Standards For Buildings, Change 1, 1

October 2013

f. IBC International Building Code (IBC), 2012

g. ACI 318-11, Building Code Requirements for Structural Concrete

h. AISC 360-10, Specification for Structural Steel Buildings

2. Interior Wall Support

a. A new partition wall will consist of metal studs and brick veneer. The studs will be connected to the existing slab on grade with powder actuated fasteners and braced at the roof framing above.

b. New Knee walls will be supported with reinforcement that is doweled in and attached to the existing slab on grade with adhesive.

3. New Wall Openings

a. New wall openings in the existing 8” brick walls will be supported with precast concrete lintels.

4. Antiterrorism/Force Protection

a. The structure shall be designed in accordance with UFC 4-010-01, DoD Minimum Antiterrorism Standards for Buildings, with a low level of protection within a controlled perimeter for a primary gathering building category.

b. A standoff distance of 82 feet to roads and parking will be utilized.

c. Blast Resistance: Frames around glazed openings will be designed to resist blast pressure on the glazed area.

5. Design Loads

a. Structural design criteria including dead, live, wind and seismic design loads shall be in accordance with UFC 3-301-01, Structural Engineering.

(1) Live Loads:

Roof: 20 psf Slab on Grade: 100 psf

(2) Building Risk Category III (Structures representing a substantial hazard to human life).

(3) Snow Loading:

Ground Snow Load: 20 psf Is: 1.10 Exposure Factor 1.0 Thermal Factor: 1.0

(4) Wind Loading

Ultimate Wind Speed: 120 mph Nominal Wind Speed: 93 MPH Exposure C

(5) Seismic Loading

Ss 19.0%g S1 6.0%g Ie: 1.25 Soil Site Class: D Seismic Design Category: B Analysis Procedure: Equivalent Lateral Force

6. Material Properties

a. Cast in Place Concrete Compressive Strength: 3,000 psi

b. Reinforcing Steel Yield Strength: ASTM A615, 60,000 psi

c. Steel WF-Beams & Columns: ASTM A992, Grade 50

d. Steel HSS: ASTM A500, Grade B

e. All Other Steel: ASTM A36

CHAPTER III – MECHANICAL

1. Applicable Governing Criteria /Mechanical Design Criteria:

a. International Building Code (IBC)

b. International Mechanical Code

c. UFC 1-200-01, General Building Requirements

d. UFC 3-410-01, Heating, Ventilating, and Air Conditioning Systems

e. NFPA 90A, Installation of Air Conditioning and Ventilating Systems

f. ASHRAE 62.1, Ventilation for Acceptable Indoor Air Quality

2. Construction Features:

a. Minimum Ventilation

Based on ASHRAE 62.1 – 2013, the required ventilation is based on the occupancy classified as a warehouse. This requires 0.06 cfm/sf, or 384 cfm. There will be a propeller type, wall mounted fan drawing air into the breezeway at the plan south side with a corresponding intake louver on the opposite (plan north) wall. The louver will be located above the two double doors. Current plans show both the fan and louver to include motorized dampers to comply with ATFP, however if this is not required the dampers can be backdraft type. This fan and relief will be operated by a 7-day programmable thermostat based on occupied schedule with override capability.

b. Space Cooling

There will be no mechanical cooling provided for the breezeway. An inline exhaust fan ducted to a new relief hood will be located in the center of the breezeway reusing the existing roof penetration. The use of an inline fan located inside of the breezeway will not require roof access for maintenance. This exhaust fan is sized for 0.5 cfm/sf (3,200 cfm) and operated by a thermostat to energize when space temperature rises above set-point or when manually enabled. The fan will include a damper to avoid infiltration when de-energized. The make-up air for this will come through the architectural louvers as well as by propping the exterior doors open. The purpose of this fan is to provide some comfort during periods of use in warm ambient conditions and to remove odors.

c. Space Heating

Considering the use of the space and continuous opening of exterior doors, infiltration of outside air will be the main factor creating a cold indoor environment. Therefore, gas-fire radiant tube heaters will be used to temper the environment during use. This system warms the occupants directly as well as the floors and materials in the space, using thermal mass to retain heat within the breezeway. There will be two heaters total sized 80 MBH each, one located at each end of the breezeway (north and south) with direct vent exhaust to the exterior, through the roof. Wall mounted thermostat will enable the heaters with manual override available. A 1” gas line will be fed from the adjacent bay ‘F’ where a new meter is being provided for a boiler project. A 1” pipe will serve the radiant heaters from this new meter with an added load of 160 MBH. The heaters will have direct combustion air from roof vents.

CHAPTER IV - ELECTRICAL

1. Electrical Criteria:

a. ANSI C2 National Electric Safety Code

b. IBC International Building Code

c. NFPA 70 National Electric Code

2. General Design Concept:

The electrical characteristics for this building are 208Y/120 volt, three phase, 4 wire. Existing panel boards and circuit breakers will be utilized for new loads.

a. Power

All power connections for mechanical equipment will be coordinated to provide the correct power requirements. General purpose receptacles will also be provided.

Conductors will be type THW, THHN or THWN, with 600 volt insulation. Conductors shall be copper and be sized to limit the voltage drop for feeders to a maximum of two percent and branch circuits to a maximum of three percent. All wiring will be installed in conduit.

b . Lighting

Existing lighting fixtures and associated branch circuits will be reused. Conductors will be type THW, THHN or THWN, with 600 volt insulation for all relocated fixtures and new fixtures. Exit lights will be provided with integral emergency battery packs. Wall mounted emergency battery lighting fixtures will be provided.

CHAPTER V – FIRE PROTECTION

1. General

Jensen Hughes has prepared a fire protection basis of design analysis, as required by Unified Facilities Criteria (UFC) 3-600-01 for the design the DLA Breezeway Project, Building 31, Bay F located at the DLA Richmond, VA. The Fire Protection Design Analysis can be found in Appendix B.

TAB A

HAZARDOUS MATERIALS REPORT

Breezeway, Building 31F, Defense Logistics Agency (DLA)

Defense Supply Center Richmond (DSCR) Richmond, VA

GER 130-6935

Prepared for

Waller Todd & Sadler 1909 Cypress Avenue

Virginia Beach, VA

Prepared by Brian T. Hyde

Virginia Asbestos Inspector # 3303002709

REPORT OF

HAZARDOUS MATERIALS

CONSULTING SERVICES

Southern Professional Center 1 2712 Southern Boulevard, Suite 101 Virginia Beach, Virginia 23452

(757) 463-3200 Fax (757) 463-3080 E-mail germail@geronline.com

April 6, 2016

Waller Todd & Sadler Architects 1909 Cypress Avenue Virginia Beach, VA 23451

Attention: Mr. David Isbell

Subject: Hazardous Materials Study Breezeway, Building 31F, Defense Logistics Agency (DLA) Defense Supply Center Richmond (DSCR) Richmond, VA WTS Project # 1303-CC

GER 130-6935

GeoEnvironmental Resources, Inc. has completed our hazardous materials sampling of the subject facility. This work was completed in accordance with the scope of work and fee outlined in GER proposal P16-130-6361 dated 26 January 2016. This report is relevant to the date of our field work and should not be relied upon for later dates.

We appreciate the opportunity of completing this work for Waller Todd & Sadler. If there are any questions concerning this report, please contact us.

Sincerely, GeoEnvironmental Resources, Inc.

Brian T. Hyde H. Nelson Adcock, Jr., P.E.

Hazardous Materials Project Manager President Virginia Asbestos Inspector (#3303002709) Virginia Asbestos Inspector (#3303001776)

Attachments: (1) Hazardous Materials Report

(2) Laboratory Reports

(3) Sample Location Maps

(4) Previous Environmental Reports

(5) Photographs

(6) Licenses

Southern Professional Center I 2712 Southern Boulevard, Suite 101 Virginia Beach, Virginia 23452

(757) 463-3200 Fax (757) 463-3080 E-mail germail@geronline.com

Section 2 Bulk Sample Results/Laboratory Sheets

Section 1 Report

Section 3 Sample Location Map

Section 4 Previous Hazmat Report

Section 5 Photographic Documentation

Section 5 Licenses

ACRONYMS

AAS Atomic absorption spectroscopy ACBM Asbestos-containing building materials ACM Asbestos-containing materials ACT Acoustical ceiling tile ADA Americans with Disability Act AHERA Asbestos Hazard Emergency Response Act ASHARA Asbestos Schools Hazard Abatement Reauthorization Act ASTM American Society of Testing and Materials CMU Cement masonry unit CFC Chlorofluoro carbons CHMM Certified Hazardous Materials Manager CFR Code of Federal Regulation CMU Concrete masonry unit CSP Certified Safety Professional DEHP Di (2-ethylhexyl) phthalate DRO Diesel Range Organics ECD Electron capture detectors EA Each EPA U.S. Environmental Protection Agency GC Gas chromatography GRO Gasoline Range Organics GWB Gypsum wall board HBM Hazardous building material HID High intensity discharge HM Homogeneous material HUD U.S. Housing and Urban Development LBP Lead-based paint LF Linear feet LS Lump sum MDL Minimum detection limit mg/cm2 Milligrams per square centimeter mg/kg Milligrams per kilogram mg/L Milligrams per Liter ND none detected NVLAP National Voluntary Laboratory Accreditation Program OSHA Occupational Safety and Health Administration PCB Polychlorinated biphenyl PLM Polarized light microscopy ppm Parts per million RCRA Resource Conservation and Recovery Act SAP Sample and Analysis Plan SF Square Feet TCLP Toxicity characteristic leaching procedure TPH Total Petroleum Hydrocarbons TSI Thermal System Insulation VAC Virginia Administration Code VOC Volatile Organic Compound XRF X-Ray Fluorescence

Breezeway, 31F DLA GER 130-6935 Page 1

PROJECT DESCRIPTION

It is our understanding that the project involves the construction of a breezeway in Warehouse #31F.

There is currently approx. 14,400 SF of vacant area within WH 31, Bay ‘F’ for future development which could be converted to administrative space or an expansion of the Lotts Center. The date of construction is unknown.

The breezeway shall be designed to provide a weather protected walk/pathway to entrances of Primary Level Field Activity command headquarters from employee parking at rear of building and between Primary Level Field Activity command headquarters and existing conference center at front of building. The breezeway will provide weather protected exterior seating. Aviation Operations Center Phase 1 will support 875 employees. The breezeway is intended to support entire Operations Center.

This project shall convert a portion of Building 31, Bay F, (Storage, General Purpose, Installation) to an "L" shaped Breezeway (Overhead Protection) at DLA Aviation Richmond, VA. The conversion includes: deconstruction of three rooms, removal of brick interior and exterior wall, provision of full height full length wall within existing 3lF space to separate the new breezeway from the existing storage in 3lF, openings in existing walls to create unconditioned breezeway, full height full width glass partition wall, opening with doors for pathway from new operations center into existing conference center, partial height walls to separate breezeway interior space (walkway from seating), flooring, lighting with dual sensors, electronic display sign, electrical, fire alarm, mass notification and furniture (to be funded by other appropriations). The design of the breezeway shall permit access for the handicapped and be compliant with the American Disabilities Act (ADA).

Prior to the demolition work, hazardous materials must be identified in order to protect workers and the environment.

Our scope of work was to collect bulk samples of suspect asbestos-containing materials (ACM) and paint chip samples to determine lead concentrations. We also inspected existing light fixtures for possible PCB-containing electrical ballast. Bulk samples were collected of visibly accessible building materials expected to be disturbed by the renovation work.

SAMPLING METHODOLOGIES

Suspect Asbestos-Containing Materials

(ACM)

The AHERA regulation, 40 Code of Federal Regulations (CFR) 763, is the primary governing regulation when performing asbestos surveys. This regulation was originally enacted for school buildings, but has since been applied to public and commercial buildings by the Asbestos School Hazard Abatement Reauthorization Act (ASHARA) in 1994 and by the Occupational Safety and Health Administration’s (OSHA) worker protection regulations in 1995, specifically 29 CFR 1926.1101(k). The demolition of structures is also subject to 40 CFR Part 61 “National Emission Standards for Hazardous Air Pollutants” (NESHAPs).

ACM is specifically addressed in 40 CFR 61 Subpart M “National Emission Standard for Asbestos.”

ACM is generally divided into three primary classifications as follows: (a) Surfacing material, (b) Thermal System Insulation, and (c) Miscellaneous material. These classifications are defined in 40 CFR 763.83 as provided below.

Miscellaneous material means interior building on structural components, structural members or fixtures, such as floor and ceiling tiles, and does not include surfacing material or thermal system insulation.

Surfacing material means material in a school building that is sprayed-on, troweled-on, or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes.

Thermal system insulation means material in a school building applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes.

The sampling methodologies employed to address the ACM categories described above are as follows:

Surfacing material – An accredited inspector shall collect, in a statistically random manner that is

Breezeway, 31F DLA GER 130-6935 Page 2

GER

representative of the homogeneous are, bulk samples from each homogeneous area of friable surfacing material that is not assumed to be ACM, and shall collect the samples as follows:

(1) At least three bulk samples shall be collected from each homogeneous area that is 1,000 SF or less.

(2) At least five bulk samples shall be collected from each homogeneous area that is greater than 1,000 SF but less than or equal to 5,000 SF.

(3) At least seven bulk samples shall be collected from each homogeneous area that is greater than 5,000 SF.

Thermal system insulation - An accredited inspector shall collect the samples as follows:

(1) At least three bulk samples, in a random distributed manner from each homogeneous area of thermal system insulation that is not assumed to be ACM.

(2) Collect at least one bulk sample from each homogeneous are of patched thermal system insulation that is not assumed to be ACM if the patched section is less than 6 linear or square feet.

(3) In a manner sufficient to determine whether the material is ACM or not ACM, collect bulk samples from each insulated mechanical system that is not assumed to be ACM where cement or plaster is used on fittings such as tees, elbows, or valves.

(4) Bulk samples are not required to be collected from any homogeneous area where the accredited inspector has determined that the thermal system insulation is fiberglass, foam glass, rubber, or other non-ACBM.

Miscellaneous material - An accredited inspector shall collect the samples as follows:

(1) In a manner sufficient to determine whether material is ACM or not ACM from each homogeneous area of friable miscellaneous material that is not assumed to be ACM.

Non friable suspected ACBM - An accredited inspector shall collect the samples as follows:

If any homogeneous area of non friable suspected ACBM is not assumed to be ACM, then an accredited inspector shall collect, in a manner sufficient to determine whether the material is ACM or not ACM, bulk samples from the homogeneous are of non friable suspected ACBM that is not assumed to be ACM.

Lead Based Paint (LBP)

Testing of painted surfaces for lead, cadmium and chromium was conducted by collecting bulk paint chip samples from various painted surfaces. The inspection was generally conducted using 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 inspection was not a comprehensive, surface-by-surface evaluation, but rather a screening inspection of major painted components, which may contain LBP.

Polychlorinated Biphyenls (PCBs)

On January 1, 1979, the Environmental Protection Agency (EPA) banned the manufacturing of light ballasts which contain PCB’s and phased out most PCB uses. Therefore, all light ballasts manufactured prior to January 1, 1979 without “Non-PCB” markings must be considered PCB containing. The EPA’s actions subject all substances containing over 50 ppm PCBs to regulatory control (with the exception of PCB-contaminated waste oil which is prohibited at any level).

We performed a visual inspection of various fluorescent light ballasts for PCB markings.

ANALYTICAL METHODS

Suspect Asbestos-Containing Materials

(ACM)

Suspect ACM samples were analyzed using polarized light microscopy (PLM) and dispersion staining techniques. The analytical method was conducted in accordance with Method EPA-600/M4-82-020 and/or EPA 600/R-93/116.

Analysis was performed by EMSL Analytical, Inc., Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NYS ELAP

10872, NJ DEP 03036.

Lead Based Paint (LBP)

Paint chip samples were analyzed for lead using inductively coupled plasma (ICP) emission spectroscopy (SW-846, 6010C). Analysis was performed by EMSL Analytical, Inc. Cinnaminson, Breezeway, 31F DLA GER 130-6935 Page 3

NJ NELAP Certifications: 10896, PA 68-00367, AIHA-LAP, LLC ELLAP 100194, A2LA 2845.01

PREVIOUS HAZMAT REPORT

DLA provided a hazardous material report for Warehouse #31. A copy of the report is provided in Section 4 of this report. The report was prepared by Terracon and was dated May 4, 2012. The hazardous material survey report of Warehouse #31, (Bays A-E) identified the following asbestos-containing materials (ACM): (1) roofing materials, (2) vinyl floor tile and mastic, and (3) window glazing. Lead based paint (LBP) and lead-containing paint (LCP) were also identified in the warehouse. For purposes of this report we have assumed the previous report to be accurate and reliable.

ASBESTOS BULK SAMPLING

In March of 2016, a total of seventeen (17) bulk samples of suspect (ACM) were collected by Brian T. Hyde, a Virginia Licensed Asbestos Inspector.

Samples were collected from accessible areas in Bay F in Warehouse #31.

The attached Table 1 is a summary of the sample materials, sample location, and laboratory results.

Laboratory results are contained in Section 2 of this report. Drawings showing the approximate sample locations, are contained in Section 3.

Destructive activities such as breaking into walls, ceilings, or floors were not performed in order to obtain samples. Therefore, if during the renovation process suspect hazardous materials are uncovered, they must be properly addressed.

As the sample results indicate, the following materials were determined to be asbestos-containing material (ACM):

Louver frame caulk

Tan floor tile (mastic only) under carpet

ASBESTOS DISCUSSION

The EPA defines ACM as any material which contains greater than 1% asbestos by weight. The following categories of ACM were identified in Warehouse 31F:

Non-Friable ACM

Exterior louver vent caulk - (8% Chrysotile) Located on exterior louver vent frames on the loading dock area of Bay F. This material is classified as Category I ACM and was in fair condition at the time of the survey. (Estimated quantity 20 LF)

12” tan floor tile (mastic only) - (3% Chrysotile) Located under carpet in office # 2 on the loading dock area of Bay F. The material is found in the mastic only and is classified as Category I ACM and was in good condition at the time of the survey. (Estimated quantity 180

SF)

Assumed Friable ACM

Fire doors - Rolling doors separating the bays have fire rating labels present. These doors are assumed to contain ACM within the core of the door. All doors with fire rating labels should be presumed to contain asbestos until proven otherwise by sampling and testing. The suspect ACM was not accessible for sampling, because cutting a hole in the door would invalidate the fire rating. (Estimated quantity - 2 each)

The National Emission Standard for Hazardous Air Pollutants (NESHAP) requires that all friable ACM must be removed prior to disturbance through either renovation or demolition. Therefore the louver frame caulk, floor tile mastic and fire door insulation shall be removed before disturbance due to renovation.

All asbestos abatement work shall be performed in accordance with local, state and Federal regulations including but not limited to

29CFR1926.1101 - Asbestos

40CFR61 - National Emission Standards for Hazardous Air Pollutants

9VAC 20-81 - Virginia Solid Waste Management Regulations

18VAC 15-20 - Virginia Asbestos Licensing Regulations

PAINT SAMPLING

A total of three paint chip samples were collected by GER. The attached Table 2 summarizes the samples collected and their laboratory results. The laboratory analysis results are contained in Section

2. The purpose of our sampling was to obtain representative data on the concentrations of lead, Breezeway, 31F DLA GER 130-6935 Page 4 cadmium and chromium in the existing painted surfaces scheduled to be disturbed by the work.

Paint samples were collected from walls, door frames, and structural steel.

PAINT DISCUSSION

There are two frequently used standards to define lead-based paint, the Consumer Product and Safety Commission (CPSC) and the Department of Housing and Urban Development (HUD). In 1978, the CPSC, acting under the authority of the Consumer Product Safety Act, banned the sale of paint containing more than 0.06% lead by weight to consumers. The Consumer Product Safety Improvement Act of 2008 lowered the concentration of lead in paint that is permissible from 0.06% (600 ppm) to the new limit of 0.009% (90 ppm). Paint which contains more than 0.009% lead by weight is defined as Lead-containing paint

(LCP).

The Occupational Safety and Health Administration (OSHA) Lead in Construction Standard (29 CFR 1926.62) does not define lead-based paint.

However, to comply with OSHA, all painted surfaces with a lead concentration at or above the laboratory’s reporting limit (RL) should be considered lead containing.

Compliance with this standard is required even for paints with less than 0.5% or 0.06% lead by weight. Therefore, painted surfaces exceeding the MDL should not be disturbed without taking the appropriate precautions when performing certain high risk tasks. Activities such as scraping, sanding, welding/torching and disturbance of painted surfaces could potentially release leaded dust. OSHA has categorized the following high risks tasks into three groups:

Group 1: manual demolition manual scraping heat-gun applications power tool cleaning with dust collection system spray paint with lead-based paints

Group 2: lead burning using lead-containing mortar power tool cleaning without dust collection system rivet blasting cleanup activities where dry expendable abrasives are used movement and removal of abrasive blasting enclosures

Group 3: abrasive blasting welding, cutting and burning on steel structures

Analytical results for lead paint show that all of the samples collected and analyzed were found to have lead concentrations above the laboratory's RL. Two of the paint samples have concentrations indicating lead based paint.

Therefore, all existing painted surfaces scheduled for demolition should be considered lead containing for the purposes of complying with 29 CFR 1926.62 in order to protect workers and the environment.

Paints containing cadmium and chromium are often found as protective coatings on structural steel or exterior coatings on metal surfaces. These paints tend to be red, yellow or orange and are typically the first layer. All of the bulk paint chip samples were also tested for cadmium and chromium.

Analytical results for chromium indicate that all of the samples analyzed resulted in concentrations above the RL. Analytical results for cadmium indicate that two out of three samples analyzed resulted in concentrations above the RL. The National Institute for Occupational Safety and Health (NIOSH) identifies chromium as a confirmed carcinogen and cadmium as a suspect carcinogen.

Construction Standards established by OSHA for lead, cadmium and chromium are:

Lead 29 CFR 1926.62 Cadmium 29 CFR 1926.1127 Chromium 29 CRF 1926.1126

The permissible exposure limits (PEL) established by OSHA are 5 ug/m3 for cadmium, 5 ug/m3 for chromium (chromates) and 50 ug/m3 for lead.

The PEL is an airborne measurement to address worker exposure. There is no direct correlation between lead, cadmium, and chromium concentrations in paint and worker exposure. Only when these concentrations are below the laboratory’s MDL, is worker exposure not an issue.

Appropriate precautions should be taken during the disturbance of all painted

Breezeway, 31F DLA GER 130-6935 Page 5 surfaces to ensure protection of workers and the environment.

All lead, cadmium and chromium paint work shall be performed in accordance with all local, state and Federal regulations to protect workers and the environment, including but not limited to:

29CFR 1926.62 - Lead

29CFR 1926.1126 - Chromium

29CFR 1926.1127 - Cadmium

9VAC 20-60 - Virginia Hazardous Waste Management Regulations

9VAC 20-81 - Virginia Solid Waste Management Regulations

18VAC 15-30 - Virginia Lead-Based Paint Activity Regulations

WASTE CLASSIFICATION FOR PAINTED

BUILDING COMPONENTS

Building components and demolition waste streams which are painted must be properly characterized prior to disposal. The EPA Resource Conservation and Recovery Act (RCRA) regulations establish the limits for RCRA leachable metals (lead, cadmium, chromium, etc.). Leachable metals means the amount of metals likely to leach from the waste into the surrounding soil/groundwater system of a landfill. The leachable concentration of chemicals in a waste stream is determined by an analytical method called the toxicity characteristic leaching procedure (TCLP). Waste stream TCLP concentrations that equal or exceed the RCRA limits must be transported to a hazardous waste treatment, storage, or disposal facility. Precautions should be implemented to prevent the storage of any hazardous waste for more the 90 days. Specific permits are necessary to store hazardous waste in excess of 90 days.

POLYCHLORINATED BIPHENYLS (PCBS)

On January 1, 1979, the Environmental Protection Agency (EPA) banned the manufacturing of light ballasts which contain PCB’s and phased out most PCB uses. Therefore, all light ballasts manufactured prior to January 1, 1979 without “Non-PCB” markings must be considered PCB containing. The EPA’s actions subjects all substances containing more than 50 ppm PCBs to regulatory control (with the exception of PCB-contaminated waste oil which is prohibited at any level).

Our field investigation of existing fluorescent light fixtures indicated that the structure contained newer fluorescent light fixtures in the offices and bay area F.

All ballasts observed were labeled with “No-PCBs” markings. Light fixtures in bay area F were not accessible due to height. Ballast in newer light fixtures are anticipated to be Non PCB-containing and all fluorescent light tubes are considered mercury containing.

All PCB and lamp disposal work shall be performed in accordance with all local, state and Federal regulations to protect workers and the environment, including but not limited to:

40CFR761 - Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution In Commerce, and Use Prohibitions

9VAC 20-81 - Virginia Solid Waste Management Regulations

LIMITATIONS

This report has been prepared for the exclusive use of Waller Todd & Sadler 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 visible at the time of our site visit, March of 2016, and upon current industry standards. During our inspection, accessible areas were visually inspected for the presence of asbestos, lead based paints and PCBs. The findings at these locations area assumed to be representative throughout the impacted areas of the buildings. Inaccessible areas, such as inside HVAC equipment and ducts were not visually inspected. Areas inspected for the above-referenced materials were limited to those described in our report.

Under this scope of services, GER assumes no responsibility regarding response actions (e.g. O&M Plans, Remediation, Notifications, etc.) initiated as a result of these findings. GER assumes no liability for the duties and responsibilities of the Client with respect to compliance with local, state and Federal

Breezeway, 31F DLA GER 130-6935 Page 6 regulations. Compliance with regulations and response actions are the sole responsibility of the Client and should be conducted in accordance with local, state and Federal regulations and should be performed by appropriately licensed personnel, as warranted.

Breezeway, 31F DLA GER 130-6935 Page 7

SECTION 2

Bulk Sample Results / Laboratory Analysis Sheets

Table 1 - Asbestos Sample Results

Table 2 - Paint Sample Results

Breezeway - 31F GER 130-6935

NO. SAMPLE LOCATION SAMPLE MATERIAL % & TYPE OF ASBESTOS

1 Riser room 2'x4' ceiling tile None detected

2 Riser room 2'x4' ceiling tile None detected

3 Exterior wall Louver frame caulk 8% Chrysotile

4 Exterior wall Louver frame caulk 8% Chrysotile

5 Exterior office Door frame caulk None detected

6 Exterior office Door frame caulk None detected

7 Office 1 2'x4' ceiling tile None detected

8 Office 1 4" black base cove/mastic None detected

9 Office 1 Drywall None detected

10 Office 1 Joint compound None detected

11 Office 1 12" grey floor tile/mastic under carpet

None detected

12 Office 1 12" grey floor tile/mastic under carpet

None detected

13 Office 2 Drywall None detected

14 Office 2 Joint compound None detected

15 Office 2 4" black base cove/mastic None detected

16 Office 2 12" tan floor tile/mastic under carpet 3% Chrysotile - mastic

17 Office 2 12" tan floor tile/mastic under carpet 3% Chrysotile - mastic

Table 1 - Asbestos Bulk Sample Results

Table 2: Paint Chip Sample Results

Breezeway, 31F DLA GER 130-6935

Note: Highlighted blocks indicate concentrations above the laboratory’s reporting limit. BOLD concentration indicates lead based paint

XX0.00039<0.000120.056BrownOffice, exterior door frameP3

XXX0.0120.0001825RedBay F, Structural Steel ColumnP2

XXX0.110.00361.6WhiteRiser Room, Brick WallP1

ChromiumCadmiumLead

> MDL%

CHROMIUM

CADMIUM% LEADCOLORSAMPLE LOCATIONNO

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041606897EMSL Order:

Customer ID: GEOE25

Customer PO:

Project ID:

Attention: Phone:Brian Hyde (757) 463-3200

Fax:GeoEnvironmental Resources (757) 463-3080

Received Date:2712 Southern Blvd. 03/19/2016 10:00 AM

Analysis Date:Suite 101 03/22/2016

Collected Date:Virginia Beach, VA 23452

Project: 130-6935 / Breezeway - 31F

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

041606897-0001

Gray/White

Fibrous

Homogeneous

None DetectedRiser Room - 2'x4'

Ceiling Tile

50%

30%

Cellulose

Min. Wool

20% Non-fibrous (Other)

041606897-0002

Gray/White

Fibrous

Homogeneous

None DetectedRiser Room - 2'x4'

Ceiling Tile

60%

30%

Cellulose

Min. Wool

10% Non-fibrous (Other)

041606897-0003

Gray/Red

Non-Fibrous

Homogeneous

Exterior Wall - Louver

Frame Caulk

92% Non-fibrous (Other) 8% Chrysotile

041606897-0004

Gray

Non-Fibrous

Homogeneous

Exterior Wall - Louver

Frame Caulk

92% Non-fibrous (Other) 8% Chrysotile

041606897-0005

Black

Non-Fibrous

Homogeneous

None DetectedExterior Office - Door

Frame Caulk

100% Non-fibrous (Other)

041606897-0006

Black

Non-Fibrous

Homogeneous

None DetectedExterior Office - Door

Frame Caulk

100% Non-fibrous (Other)

041606897-0007

Gray/White

Fibrous

Homogeneous

None DetectedOffice 1 - 2'x4' Ceiling

Tile

60%

20%

Cellulose

Min. Wool

20% Non-fibrous (Other)

8-Base Cove

041606897-0008

Black

Non-Fibrous

Homogeneous

None DetectedOffice 1 - 4" Black

Base Cove

100% Non-fibrous (Other)

8-Mastic

041606897-0008A

Yellow

Non-Fibrous

Homogeneous

None DetectedOffice 1 - Mastic 100% Non-fibrous (Other)

041606897-0009

White

Fibrous

Homogeneous

None DetectedOffice 1 - Drywall 15%

5%

Cellulose

Glass

80% Non-fibrous (Other)

041606897-0010

White

Non-Fibrous

Homogeneous

None DetectedOffice 1 - Joint

Compound

100% Non-fibrous (Other)

11-Floor Tile

041606897-0011

Gray

Non-Fibrous

Homogeneous

None DetectedOffice 1 - 12" Grey

Floor Tile under

Carpet

100% Non-fibrous (Other)

11-Mastic

041606897-0011A

Yellow

Non-Fibrous

Homogeneous

None DetectedOffice 1 - Mastic 100% Non-fibrous (Other)

12-Floor Tile

041606897-0012

Gray

Non-Fibrous

Homogeneous

None DetectedOffice 1 - 12" Grey

Floor Tile under

Carpet

100% Non-fibrous (Other)

12-Mastic

041606897-0012A

Yellow

Non-Fibrous

Homogeneous

None DetectedOffice 1 - Mastic 100% Non-fibrous (Other)

041606897-0013

White

Fibrous

Homogeneous

None DetectedOffice 2 - Drywall 15%

5%

Cellulose

Glass

80% Non-fibrous (Other)

Initial Report From: 03/23/2016 07:18:46

Page 1 of 2PLM - 1.67 Printed: 3/23/2016 7:18 AM

200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041606897EMSL Order:

Customer ID: GEOE25

Customer PO:

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

041606897-0014

White

Non-Fibrous

Homogeneous

None DetectedOffice 2 - Joint

Compound

100% Non-fibrous (Other)

15-Base Cove

041606897-0015

Black

Non-Fibrous

Homogeneous

None DetectedOffice 2 - 4" Black

Base Cove

100% Non-fibrous (Other)

15-Mastic

041606897-0015A

Yellow

Non-Fibrous

Homogeneous

None DetectedOffice 2 - Mastic 100% Non-fibrous (Other)

16-Floor Tile

041606897-0016

Tan

Non-Fibrous

Homogeneous

None DetectedOffice 2 - 12" Tan

Floor Tile under

Carpet

100% Non-fibrous (Other)

16-Mastic

041606897-0016A

Black

Non-Fibrous

Homogeneous

Office 2 - Mastic 97% Non-fibrous (Other) 3% Chrysotile

17-Floor Tile

041606897-0017

Tan

Non-Fibrous

Homogeneous

None DetectedOffice 2 - 12" Tan

Floor Tile under

Carpet

100% Non-fibrous (Other)

17-Mastic

041606897-0017A

Black

Non-Fibrous

Homogeneous

Office 2 - Mastic 97% Non-fibrous (Other) 3% Chrysotile

Analyst(s)

Daniel Fricker (16)

Seri Smith (7)

Benjamin Ellis, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . This report relates only to the samples reported and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government . Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Samples received in good condition unless otherwise noted. Estimated accuracy, precision and uncertainty data available upon request. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Reporting limit is 1%

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NYS ELAP 10872, NJ DEP 03036, PA ID# 68-00367

Initial Report From: 03/23/2016 07:18:46

Page 2 of 2PLM - 1.67 Printed: 3/23/2016 7:18 AM

Phillip Worby, Chemistry Laboratory Manager

Reviewed and Approved By:

Fax: (757) 463-3080 Phone: (757) 463-3200

The following analytical report covers the analysis performed on samples submitted to EMSL Analytical, Inc. on 3/21/2016. The results are tabulated on the attached data pages for the following client designated project:

130-6935

The reference number for these samples is EMSL Order #011601555. Please use this reference when calling about these samples. If you have any questions, please do not hesitate to contact me at (856) 303-2500.

3/25/2016Attn: Brian Hyde GeoEnvironmental Resources 2712 Southern Blvd.

Suite 101 Virginia Beach, VA 23452

The test results contained within this report meet the requirements of NELAP and/or the specific certification program that is applicable, unless otherwise noted.

NELAP Certifications: NJ 03036, NY 10872, PA 68-00367

The samples associated with this report were received in good condition unless otherwise noted. This report relates only to those items tested as received by the laboratory. The QC data associated with the sample results meet the recovery and precision requirements established by the NELAP, unless specifically indicated. All results for soil samples are reported on a dry weight basis, unless otherwise noted. This report may not be reproduced except in full and without written approval by EMSL Analytical, Inc.

EMSL Analytical, Inc.

200 Route 130 North, Cinnaminson, NJ 08077 Phone: (856) 303-2500 Fax: (856) 858-4571 Email: EnvChemistry2@emsl.com

The QC sample duplicate RPD results for Cadmium and Chromium were outside method control limits. The final ICS recovery for Chromium was outside method control limits (high).

mailto:EnvChemistry2@emsl.com

200 Route 130 North, Cinnaminson, NJ 08077 Phone/Fax: (856) 303-2500 / (856) 858-4571 http://www.EMSL.com EnvChemistry2@emsl.com

011601555 CustomerID: GEOE25 CustomerPO:

ProjectID:

EMSL Order:

Analytical Results

Attn: Brian Hyde GeoEnvironmental Resources 2712 Southern Blvd.

Suite 101 Virginia Beach, VA 23452

Received: 03/21/16 9:00 AM

130-6935

Fax: (757) 463-3080 Phone: (757) 463-3200

Project:

Client Sample Description Lab ID:P-1 0001 Brick Wall (White)

Collected: 3/15/2016

12:00:00 PM

Method Parameter Result Units Analysis Date AnalystRL

Prep Date Analyst

3050B/6010C Cadmium JS0.0036 % wt 3/23/20160.000093 3/22/2016 SM

3050B/6010C Chromium JS0.11 % wt 3/24/20160.0012 3/22/2016 SM

3050B/6010C Lead JS1.6 % wt 3/24/20160.012 3/22/2016 SM

Client Sample Description Lab ID:P-2 0002 Steel Column (Red)

Collected: 3/15/2016

12:00:00 PM

Method Parameter Result Units Analysis Date AnalystRL

Prep Date Analyst

3050B/6010C Cadmium JS0.00018 % wt 3/24/20160.000090 3/22/2016 SM

3050B/6010C Chromium JS0.012 % wt 3/24/20160.00023 3/22/2016 SM

3050B/6010C Lead JS25 % wt 3/24/20160.23 3/22/2016 SM

Client Sample Description Lab ID:P-3 0003 Door Frame (Brown)

Collected: 3/15/2016

12:00:00 PM

Method Parameter Result Units Analysis Date AnalystRL

Prep Date Analyst

3050B/6010C Cadmium JSND % wt 3/24/20160.00012 3/22/2016 SM

3050B/6010C Chromium JS0.00039 % wt 3/24/20160.00031 3/22/2016 SM

3050B/6010C Lead JS0.056 % wt 3/24/20160.00031 3/22/2016 SM

ND - indicates that the analyte was not detected at the reporting limit RL - Reporting Limit

Definitions:

Page 2 of 2ChemSmplw/RDL/NELAC-7.21.0 Printed: 3/25/2016 8:02:37 PM http://www.EMSL.com mailto:EnvChemistry2@emsl.com

SECTION 3

Sample Location Maps

Sample Location Plan

PROJECT:PROJECT:

DRAWING 1 OF 1DRAWING 1 OF 1

NUMBER:NUMBER:BREEZEWAY, BUILDING 31F

DEFENSE LOGISTICS AGENCY

DEFENSE SUPPLY CENTER

RICHMOND, VIRGINIA

130-6935

DATE:DATE:

SCALE:SCALE: NONE

APRIL 2016

NOTE - THE LOCATION FROM WHICH THE SAMPLES WERE OBTAINED SHOULD

NOT BE INTERPRETED AS THE ONLY LOCATION WHERE THE MATERIAL EXISTS.

POSITIVE SAMPLE LOCATION FOR ASBESTOS

NEGATIVE SAMPLE LOCATION FOR ASBESTOS

LEGEND

PAINT SAMPLE LOCATION

TCLP SAMPLE LOCATION

P1

P2

P3

Warehouse 31 F Floor Plan

Bay F

Riser Room

Office #1

Office #2

SECTION 4

Previous Environmental Reports

HAZZMAT

Pr

T SUR

oposed D

Th

RVEY

DLA Aviat

Bu D

Terra he U.S. Ar

Terr R

Y RE

tion Oper uilding 31 efense S

Richm acon Proje rmy Corps No racon Con Raleigh, N

EPOR

ration Ce 1 (Bays A upply Ce ond, Virg May 4, 2 ect 70127

Prepared s of Engine orfolk, Virg

Prepared nsultants, North Caro

RT

nter A - E) nter ginia d For:

eers ginia d By:

Inc.

olina

Page No.

1.0 INTRODUCTION

1.1 PROJECT OBJECTIVE

2.0 BUILDING DESCRIPTION

3.0 FIELD ACTIVITIES

3.1 ASBESTOS

3.2 LEAD PAINT

3.3 VISUAL SURVEY FOR OTHER HAZARDOUS MATERIALS

4.0 REGULATORY OVERVIEW

4.1 ASBESTOS

4.2 LEAD PAINT

5.0 FINDINGS AND RECOMMENDATIONS

5.1 ASBESTOS

5.2 LEAD PAINT

5.3 OTHER HAZARDOUS MATERIALS

6.0 GENERAL COMMENTS

Appendix A Asbestos Survey Sample Summary Appendix B Identified Asbestos-Containing Materials Appendix C Asbestos Analytical Laboratory Data Appendix D XRF Paint Survey Summary

Responsive ■ Resourceful ■ Reliable 1

HAZMAT SURVEY REPORT

PROPOSED DLA AVIATION OPERATION CENTER

BUILDING 31 (BAYS A - E)

DEFENSE SUPPLY CENTER

RICHMOND, VIRGINIA

TERRACON PROJECT NO. 70127005

1.0 INTRODUCTION

Terracon conducted a HAZMAT survey at Building 31 (Bays A - E) of the Proposed DLA Aviation Operation Center located at the Defense Supply Center in Richmond, Virginia. This survey was conducted on February 10 and March 2, 2012 by a Commonwealth of Virginia Accredited Asbestos Building Inspector in general accordance with Terracon Proposal No.

Terracon Proposal No. 70120006-revised dated January 10, 2012 and Contract Number W91236-07-D-0029 dated January 10, 2012. Interior and exterior building components were surveyed and homogeneous areas of suspect asbestos-containing materials (ACM) and lead paint (LP) were visually identified and documented. At the client’s request, the roof was included in the scope of work. Other hazardous materials (PCB-containing items such as fluorescent light ballasts, switches, and transformers; mercury-containing thermostats and light bulbs; and refrigerant-containing equipment, such as air conditioning equipment and water coolers) were visually surveyed. Although reasonable effort was made to survey accessible suspect materials, additional suspect but un-sampled materials could be located in walls, in voids or in other concealed areas. Suspect ACM samples were collected in general accordance with the sampling protocols outlined in EPA regulation 40 CFR 763 (Asbestos Hazard Emergency Response Act, AHERA). Samples were delivered to an accredited laboratory for analysis by Polarized Light Microscopy.

Building components at Building 31 (Bays A - E) of the Proposed DLA Aviation Operation Center were inspected and unique sampling combinations of paint were visually…

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