Tab_B_-_Hazardous_Materials_Report.pdf

Warehouse 4 Docks and Slabs Renovation Defense Logistics Agency (DLA)

Defense Supply Center Richmond (DSCR) Richmond, VA

GER 130-7286

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

September 22, 2017

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

Attention: Mr. David Isbell

Subject: Hazardous Materials Study Warehouse 4 Docks and Slabs Renovation DLA/Defense Supply Center Richmond (DSCR) Richmond, VA WTS Project # 1303-KK

GER 130-7286

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 P17-130-6719 dated 7 August 2017. 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) Photographs

(5) 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

TABLE OF CONTENTS

Section 2 Bulk Sample Results/Laboratory Sheets

Section 1 Report

Section 3 Sample Location Map

Section 4 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

Warehouse 4 Docks and Slabs GER 130-7286 Page 1

PROJECT DESCRIPTION

It is our understanding that the project involves the renovations of the loading dock and slab in Warehouse #4. The design shall cover renovations to the architectural components of the warehouse.

This scope of work also calls for the design of repairs to finishes and renovations to the landscaping outside the warehouse.

Warehouse 4 is constructed of brick masonry and structural steel framing on a concrete foundation with a sloped roof. The building is comprised mostly open bays with several office build-outs.

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 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

Warehouse 4 Docks and Slabs GER 130-7286 Page 2

GER

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

PREVIOUS HAZMAT REPORT

No previous hazmat reports were provided by the government for Warehouse 4.

ASBESTOS BULK SAMPLING

In September of 2017, a total of ten (10) bulk samples of suspect (ACM) were collected by Brian T. Hyde, a Virginia Licensed Asbestos Inspector.

Samples were collected from accessible areas throughout Warehouse 4.

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.

Warehouse 4 Docks and Slabs GER 130-7286 Page 3

As the sample results indicate, no materials were determined to be asbestos-containing material

(ACM).

ASBESTOS DISCUSSION

The EPA defines ACM as any material which contains greater than 1% asbestos by weight. No asbestos-containing materials were identified in the project area.

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 four 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, cadmium and chromium in the existing painted surfaces scheduled to be disturbed by the work.

Paint samples were collected from doors, door frames, railings 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. Three 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

Warehouse 4 Docks and Slabs GER 130-7286 Page 4 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 three out of four 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 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 light fixtures indicated that the structure contained newer LED light fixtures on the exterior loading dock area.

The LED fixtures do not contain ballasts. All LED lamps are considered to be 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

Warehouse 4 Docks and Slabs GER 130-7286 Page 5

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, September of 2017, 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 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.

Warehouse 4 Docks and Slabs GER 130-7286 Page 6

SECTION 2

Bulk Sample Results / Laboratory Analysis Sheets

Table 1 - Asbestos Sample Results

Table 2 - Paint Sample Results

Warehouse 4 Docks & Slabs GER 130-7286

NO. SAMPLE LOCATION SAMPLE MATERIAL % & TYPE OF ASBESTOS

1 Exterior, loading dock Tar at expansion joint None detected

2 Exterior, loading dock Tar at expansion joint None detected

3 Interior, bay B Joint sealant on floor None detected

4 Interior, bay D Joint sealant on floor None detected

5 Interior, bay E Joint sealant on floor None detected

6 Interior, bay C Joint sealant on floor None detected

7 Exterior, loading dock Tar at expansion joint None detected

8 Interior, bay G Joint sealant on floor None detected

9 Interior, bay H Joint sealant on floor None detected

10 Interior, bay F Joint sealant on floor None detected

Table 1 - Asbestos Bulk Sample Results

Table 2: Paint Chip Sample Results

Warehouse 4 docks and slabs GER 130-7286

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

XXX0.00270.000240.062WhiteExterior, loading ramp, steel railingP4

XX2.1<0.0009615BrownExterior, steel doorP3

XXX1.30.001447BrownExterior, steel door frameP2

XXX1.90.001212YellowExterior, loading dock, structural steelP1

ChromiumCadmiumLead

> MDL%

CHROMIUM

CADMIUM% LEADCOLORSAMPLE LOCATIONNO

Phillip Worby, Environmental Chemistry Laboratory Director

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 9/11/2017. The results are tabulated on the attached data pages for the following client designated project:

130-7286

The reference number for these samples is EMSL Order #011707275. 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.

9/15/2017Attn: 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, CA ELAP 1877

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

EMSL Analytical, Inc.

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

011707275 CustomerID: GEOE25 CustomerPO: 130-7826 ProjectID:

EMSL Order:

Analytical Results

Attn: Brian Hyde GeoEnvironmental Resources 2712 Southern Blvd.

Suite 101 Virginia Beach, VA 23452

Received: 09/11/17 8:45 AM

130-7286

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

Project:

Client Sample Description Lab ID:P1 011707275-0001 Exterior, Loading Dock, Structural Steel

Collected:

Method Parameter Result Units Analysis Date AnalystRL

Prep Date Analyst

3050B/6010C Cadmium BB0.0012 % wt 9/12/20170.00092 9/12/2017 LY

3050B/6010C Chromium BB1.9 % wt 9/13/20170.023 9/12/2017 LY

3050B/6010C Lead BB12 % wt 9/13/20170.11 9/12/2017 LY

Client Sample Description Lab ID:P2 011707275-0002 Exterior, Steel Door Frame

Collected:

Method Parameter Result Units Analysis Date AnalystRL

Prep Date Analyst

3050B/6010C Cadmium BB0.0014 % wt 9/12/20170.00097 9/12/2017 LY

3050B/6010C Chromium BB1.3 % wt 9/13/20170.024 9/12/2017 LY

3050B/6010C Lead BB47 % wt 9/13/20170.24 9/12/2017 LY

Client Sample Description Lab ID:P3 011707275-0003 Exterior, Steel Door

Collected:

Method Parameter Result Units Analysis Date AnalystRL

Prep Date Analyst

3050B/6010C Cadmium BBND % wt 9/12/20170.00096 9/12/2017 LY

3050B/6010C Chromium BB2.1 % wt 9/13/20170.024 9/12/2017 LY

3050B/6010C Lead BB15 % wt 9/13/20170.24 9/12/2017 LY

Client Sample Description Lab ID:P4 011707275-0004 Exterior, Loading Ramp, Steel Railing

Collected:

Method Parameter Result Units Analysis Date AnalystRL

Prep Date Analyst

3050B/6010C Cadmium BB0.00024 % wt 9/13/20170.000094 9/12/2017 LY

3050B/6010C Chromium BB0.0027 % wt 9/13/20170.00023 9/12/2017 LY

3050B/6010C Lead BB0.062 % wt 9/13/20170.0023 9/12/2017 LY

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

Definitions:

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SECTION 3

Sample Location Maps

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SECTION 4

Photographs

Project:

Number:

Warehouse 4 Docks & Slabs Renovation DLA Defense Supply Center Richmond

Project # 130-7286

Photo 1: Typical view of loading dock and ramp to be removed at Warehouse 4.

No materials associated with the ramp and loading dock contained ACM.

Photo 2: Typical view of concrete slab in Warehouse 4. Sealant at floor joints does not contain asbestos.

Photo Sheet 1

Project:

Number:

Warehouse 4 Docks & Slabs Renovation DLA Defense Supply Center Richmond

Project # 130-7286

Photo 3: Typical view metal door at rear of Warehouse 4. Paint on door and door frame contain lead, cadmium and chromium.

Photo 4: Typical view of exterior LED lighting. The light fixtures do not contain ballasts. Lamps are assumed to contain mercury gas.

Photo Sheet 2

SECTION 5

Licenses