AppL_Hazardous Materials Survey Report for Pier 11.pdf

APPENDIX L

HAZARDOUS MATERIALS SURVEY REPORT FOR PIER 11

5000 E. Spring Street, Suite 720 • Long Beach, CA • (562) 740-1060 Office • (562) 740-1070 Fax

March 10, 2009

Mr. Todd Graham

KPFF Consulting Engineers

400 Oceangate, Suite 500

Long Beach, California 90802

Subject: Hazardous Building Materials Survey Report

Sonar Pier

Pier T, West Basin, IR Site 7 Sediment Cleanup

Port of Long Beach, California

Dear Mr. Graham:

Essentia Management Services, LLC (Essentia) is pleased to provide this letter report summarizing the hazardous building materials survey (HBMS) conducted for the Sonar Pier, Pier T, West Basin, at the Port of Long Beach. It is our understanding that the Port of Long

Beach is proposing to demolish the Sonar Pier as part of a sediment cleanup project. In order to prepare project demolition bid specifications, hazardous materials such as asbestos-containing materials (ACMs), lead-based paints (LBPs), and treated wood waste (TWW) were identified. The HBMS was conducted in March and July of 2008 and consisted of the following tasks:

! Asbestos survey;

! Lead-based paint survey; and

! Treated wood sampling.

The following sections summarize the field activities, survey results, and our conclusions and recommendations. Attachment 1 contains tables that summarize the results of our survey.

Table 1 presents the results of the ACM survey. Table 2 presents a summary of the x-ray fluorescence (XRF) readings above 0.7 milligrams per square centimeter (mg/cm2), and

Table 3 presents a listing of all of the XRF readings. Tables 4 through 8 present a summary of analytical testing results for treated wood waste. Attachments 2 and 3 present the chain-of-custody records and laboratory analytical reports.

SITE DESCRIPTION

The subject site consists of an approximately 330-foot-long Access Pier that is accessed by a connection with the Navy Mole Pier. Access Pier construction consists of a wood frame structure with wooden hand rails on top of concrete piles. The site also includes an

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Hazardous Building Materials Survey

Mr. Todd Graham

KPFF Consulting Engineers

March 10, 2009 approximately 240-foot-diameter Circular Pier. An approximately 200-foot-long Timber Pier and Control Building, that formerly connected the Access Pier with the Circular Pier, has reportedly collapsed and remains submerged at this location. For this reason, the Circular

Pier was not accessible for this survey. From Essentia’s vantage point, the Circular Pier appeared to be constructed of painted metal decking and hand rails on top of concrete piles.

FIELD ACTIVITIES

The following paragraphs describe the asbestos, lead-based paint, and treated wood waste sampling activities. The surveys were conducted in March and July 2008.

Asbestos Survey

Asbestos-containing material (ACM) is defined as material containing greater than one percent (1%) asbestos by the Asbestos Hazard Emergency Response Act (AHERA), United

States Environmental Protection Agency (USEPA) National Emissions Standards for

Hazardous Air Pollutants (NESHAPS), and the South Coast Air Quality Management District

(SCAQMD) regulations. The California Occupational Safety and Health Administration

(Cal-OSHA) also requires that contractors and consultants working with building materials with an asbestos content greater than 0.1 percent be registered or certified by the State of

California.

The purpose of the asbestos survey is to assess whether ACM is present in construction materials of the site buildings, infrastructure, or utilities. This information is used to identify the location of ACM such that contractors or individuals associated with renovation or demolition can handle, remove, and/or dispose of it to comply with regulatory requirements.

An asbestos survey was conducted to visually identify areas that potentially contained ACM.

The survey was conducted by a California Certified Asbestos Consultant.

During the survey, locations were visually assessed to identify areas with accessible homogeneous materials that were suspected to contain ACM. A homogeneous area is defined as containing material that is uniform in color, texture, and function. Samples of the

ACM were collected using a razor knife, putty knife, chisel, pliers, forceps, or other tools as required. Samples were collected without causing excessive damage or fiber release from the pier materials. The sampling tools were decontaminated after each sample was collected to reduce the potential of cross contamination. Decontamination procedures consisted of rinsing and wiping the sampling tools clean with a disposable wet towel.

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Essentia collected 10 bulk samples of suspect ACMs from various locations on the pier.

Materials that were presumed to contain asbestos, but not sampled, were recorded by

Essentia as presumed asbestos-containing materials (PACMs). Following collection, each sample of suspect ACM was assessed according to type, condition, and sample location, as summarized in Table 1 (Attachment 1). The samples are identified on the chain-of-custody records and laboratory analytical reports provided as Attachment 2.

The bulk samples of friable and non-friable suspect ACM were placed in plastic bags, sealed, and labeled with a sample identification number. The bulk samples were transported under chain-of-custody protocol to AmeriSci Laboratory located in Carson, California, for analysis according to 40 Code of Federal Regulations (CFR) 763, Subpart F, Appendix A.

Lead-Based Paint Survey

The primary purpose of the LBP survey was to assess whether paint of various substrates at the site contain lead, and if so, at what concentrations. The intended use of this information is to identify the location of LBP or lead-coated materials (LCM) such that contractors and/or individuals associated with renovation, abatement and/or demolition can handle, remove, and/or dispose of it in accordance with regulatory requirements.

LBP is defined by the Housing and Urban Development (HUD) guidelines, 24 CFR part 38 and 40 CFR Part 745, as paint containing 0.5 percent (5,000 parts per million [ppm], or 1 milligram per square centimeter [mg/cm2]) or greater (using HUD’s conversion factor). LBP is alternatively defined by the Los Angeles Department of Health Services (LADHS) as paint containing 0.7 mg/cm2 when using an X-ray fluorescence (XRF) spectrum analyzer or 600 milligrams per kilogram (mg/kg) when using laboratory methods to analyze bulk samples such as paint chips. In the State of California, the California Department of Health Services

(DHS) (Title 17 California Code of Regulations [CCR], Division 1, Chapter 8) and the Cal-

OSHA (Title 8, CCR, Section 1532.1) oversee matters related to LBP abatement and/or demolition. DHS essentially defines LBP in the same manner as HUD. Cal-OSHA essentially defines any surface coating or material containing lead at any concentration to require worker protection. It also considers lead occurring at concentrations greater than

0.06% by weight (600 ppm) in a material to be subject to specific regulations with regards to allowed work practices (e.g. trigger tasks). The term lead-coated materials (LCM) refers to materials that have coatings with detectable concentrations of lead.

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In March 2008, the pier was inspected for the presence of LBP according to the 1995 HUD guidelines as modified for demolition in commercial/industrial settings. The LBP survey was completed by a California-certified Lead Inspector/Assessor using a Niton 309 hand-held XRF Spectrum Analyzer with a detection limit of approximately 0.01 mg/cm2 (50 ppm).

The survey included representative paint analyzed from exterior surfaces and metal features such as pipes, posts, and flashing. The inclusion metal features is pertinent to demolition activities where dust and/or fumes (from metal cutting) may present significant worker safety, airborne dust and/or soil contamination issues, in addition to those related to the presence of LBP.

Treated Wood Waste

Because the treated wood materials may contain chemical contaminants, disposal of treated wood waste (i.e., TWW) is restricted by the Federal Resource Conservation and Recovery

Act (RCRA) and the California Hazardous Waste Control Law (CCR Title 22). In addition, California has developed Alternative Management Standards (AMS) for handling and disposal of TWW.

The AMS for TWW are described in a fact sheet titled “Requirements for Generators of

Treated Wood Waste (TWW)” that was prepared by the Department of Toxic Substances

Control, and dated January 2008. According to the AMS, generators can presume their

TWW to be a California-hazardous waste in order to avoid extensive laboratory testing.

However, the AMS do not apply to RCRA-hazardous waste. Therefore it is necessary to rely on generator knowledge, or conduct analytical testing, to confirm that TWW is not a RCRA-hazardous waste. The AMS also indicate that the TWW can be disposed of at specific non-hazardous waste landfills, and that the waste becomes non-hazardous after acceptance by the landfill.

The Access Pier consisted of concrete piles that supported a timber frame, deck, and hand rails. The first type of TWW on the Access Pier consists of the support stringers that support the catwalk. The stringers appear to be treated with an oil-type system. The second type of wood comprises the hand rails and supports, which showed a slight greenish discoloration suggesting that the wood had been chemically treated with a waterborne (i.e., metals) system.

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Essentia contacted Waste Management (operator of hazardous and non-hazardous waste landfills) to review potential handling and disposal options. According to Waste

Management, the treated wood waste will be presumed to be a California Hazardous Waste at any of their landfills. However, a determination was needed to be made regarding whether the wood is a RCRA-hazardous waste. The requirements state that a determination can be made by collecting five representative samples for the first 1,000 cy of each homogenous material type, and one additional sample per each additional 1,000 cy of waste. The samples should then be analyzed for soluble metals by using the Toxicity Characteristic Leaching

Procedure (TCLP), volatile organic compounds (VOCs) by EPA method 8260B, and semi-volatile organic compounds (SVOCs) by EPA method 8270C. Additional testing required by this landfill included total petroleum hydrocarbons by EPA method 8015M.

Based on the characteristics of the wood observed during the inspection, Essentia collected samples and conducted laboratory analyses of the two types of wood in general accordance with the Port of Long Beach’s “Guideline for Managing Chemically Treated Wood Waste,” dated August 22, 2007. The samples were concentrated in accessible areas near the shore, but were judged to be representative of the wood observed. The samples were collected using a hand-held drill fitted with a core bit. The core bit was advanced to approximately one-half the width of the wood being sampled, and the shavings were collected in re-sealable plastic bags. The sample bags were then sealed in a metal container and shipped to Cal Tech

Environmental Laboratories of Paramount, California.

Five samples of the oil-type treated wood were given the identifiers listed below.

! SUPPORT BEAM 1/SUPPORT BEAM 1A

! SUPPORT BEAM 2 SUPPORT BEAM 2A

! SUPPORT BEAM 3/SUPPORT BEAM 3A

! SUPPORT BEAM 4

! SUPPORT BEAM 5

Six samples of the water-borne system treated wood were given the identifiers listed below.

! DECK BOARD 1/DECK BOARD 1A

! DECK BOARD 2/DECK BOARD 2A

! DECK BOARD 3/DECK BOARD 3A

! HAND RAIL 1/HAND RAIL 1A

! HAND RAIL 2/HAND RAIL 2A

! HAND RAIL 3/HAND RAIL 3A

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The samples were analyzed for TPH by EPA method 8015M, VOCs by EPA method 8260B, SVOCs by EPA method 8270C, and for California Title 22 by EPA method 6010B/7000 series.

RESULTS

This section summarizes the results of the asbestos survey, lead-based paint survey, and the other hazardous materials survey.

Asbestos Survey

Asbestos was detected in various materials throughout the site. Results of the asbestos sampling, including the material sampled, location, concentration, and estimated quantity are presented in Table 1. The locations for samples with detectable concentrations were previously provided to KPFF and will reportedly be illustrated on the final versions of Sheets

HD_10-1997-HD1 and HD_10-1997-HD2. Chain-of-custody records and laboratory analytical results are provided as Attachment 2.

Lead-Based Paint Survey

Thirteen of the 37 surfaces tested contained concentrations of lead above the 0.05 mg/cm2 detection limit. Results of the XRF testing including sample location, site feature, substrate, color, and XRF reading are presented in Tables 2 (Lead-Based Paint) and 3 (All Readings).

on. The lead sampling locations were previously provided to KPFF and will reportedly be illustrated on the final versions of Sheets HD_10-1997-HD1 and HD_10-1997-HD2.

Treated Wood Waste

The laboratory analytical results revealed detectable concentrations of TPH, VOCs, SVOCs, and metals in the TWW samples. The results of the sampling are summarized in Tables 4 through 8, with analytical laboratory reports included as Attachment 3.

CONCLUSIONS AND RECOMMENDATIONS

Based on the results of our surveys, the following conclusions and recommendations are provided.

Asbestos Survey

Asbestos was detected in various materials from throughout the site. The presence of ACMs does not necessarily mean that the health of the occupants is endangered. If ACM remains in good condition and is not disturbed, exposures to asbestos fibers are expected to be negligible. However, when ACM deteriorates, is disturbed, or damaged, such as during

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March 10, 2009 renovation or demolition operations, asbestos fibers may be released creating a potential health hazard for building occupants and construction personnel.

Prior to the planned demolition, a licensed abatement contractor should remove the identified

ACMs. Essentia recommends the following:

! Adhere to the applicable requirements contained in Specification HD-S2319, Pier T, West Basin, IR Site 7 Sediment Clean-up.

! Remove and properly package prior to demolition or renovation.

! Characterize and dispose of ACMs in accordance with federal, state, and local regulations.

A state-certified asbestos abatement contractor should perform the removal of asbestos (Title

8, CCR, Article 2.5, Sections 314.6-341.14). A third party should provide oversight to ensure that the contractor complies with the specifications and regulations, uses the proper personnel protective equipment and air control measures, and follows proper disposal procedures.

Lead-Based Paint Survey

Detectable concentrations of lead were found on the surfaces of the interior and exterior areas of the site. Federal and California OSHA consider any concentration of lead in paint to require management when conducting renovation or demolition activities. Since many of the representative readings were found to contain lead, the disturbance, renovation, or demolition of these or other similar lead-containing surfaces are covered under the Federal and

California OSHA Lead Construction Standards, found in 29 CFR 1926.62 and 8 CCR

1532.1, respectively. Both Federal and California OSHA consider paint to contain lead if the results show any detectable levels. However, 600 ppm is the concentration limit applicable to several “trigger tasks” commonly associated with renovation and demolition activities such as torching, manual demolition, or using non-HEPA (high-efficiency particulate air) equipped tools or vacuums. Renovation or demolition of architectural or structural components coated with LBP or other lead-containing materials (e.g. glazed ceramic tiles) will require workers who are properly certified, trained, and employ proper work methods and protective equipment to minimize exposure to themselves and the surrounding environment.

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Under the Cal-OSHA standard, the Permissible Exposure Limit (PEL) for lead is 50 micrograms per liter (ug/cm3) on an 8-hour time-weighted average (TWA). Unless an acceptable Negative Exposure Assessment (NEA) has been completed, workers must wear respirators when the disturbance of LCMs or LBPs has the potential to exceed the PEL.

Blood lead level (BLL) monitoring must be made available to workers exposed to airborne lead at or above the action level of 30 ug/cm3. In addition, air monitoring for worker exposure must resume even if an NEA has been previously established, to confirm the results of the NEA. The contractor must also be aware that the Cal-OSHA Standard specifies the medical removal of workers whose BLL exceeds certain levels. A BLL of 50 micrograms per deciliter or greater requires that the worker be removed from the work area immediately.

Painted surfaces in areas not accessible, and which were not tested for LBP, cannot be presumed to be free of lead. Therefore, if renovation or demolition activities reveal paint types that were not sampled, additional LBP sampling would be required prior to activities that would disturb the painted surfaces unless those surfaces are presumed to be LBP.

The California Department of Health Services (DHS) and California Environmental

Protection Agency (Cal EPA) Department of Toxic Substances Control (DTSC) oversee matters related to the renovation or demolition of materials coated with LBP and lead-containing materials on behalf of the Federal EPA. California Code of Regulations (CCR), Title 17 (Title 17) addresses the requirements of training, certification, and work practices of individuals associated with activities that are likely to disturb LBP or otherwise represent a lead hazard in residential or public buildings. It includes references and requirements related to activities likely to disturb lead-containing materials, and for clearance dust and soil sampling. Where applicable, inspection and work practices referenced in Title 17 generally specify or follow those in the HUD Guidelines.

CCR Title 22 specifies procedures for testing and other matters related to the disposal of wastes in California. These are in addition to those specified by the Federal EPA in the

Resource Conservation and Recovery Act (RCRA). Chips of LBP and/or dust generated from the removal of lead-containing materials, when tested, are often classified as RCRA hazardous waste and need to be disposed of accordingly. In addition, due to recent changes in the application of law by the Cal-EPA, building materials coated with intact LBP are no longer exempt from hazardous waste testing, handling, and disposal requirements.

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Representative samples of building materials that contain lead should be collected and analyzed to determine whether the material is a hazardous waste, and if so, what handling and disposal requirements are applicable. In general, properly sampled bulk building materials samples from demolition, when tested, will be classified as non-hazardous waste.

Other major regulations that may be pertinent include State Bill (SB) 460 which, among other things, prohibits the migration of lead-containing dust onto adjoining properties from any activity. This Bill allows for enforcement from any level of government including state, county, and/or municipal entities.

Appropriate respiratory protection must be used during any activity that could exceed the permissible exposure limit (PEL). Examples that are likely to exceed the PEL include activities such as the torch cutting of metal coated with lead-containing paint, or the breaking of ceramic materials coated with lead-containing glaze. Medical surveillance records, including blood lead results for samples collected within the past 12 months, should be provided for each worker that has the potential to be exposed to lead above the action level of

30 ug/cm3. These actions should be performed in accordance with local and state regulations.

Treated Wood Waste

Based on a comparison of analytical testing results to the hazardous waste thresholds listed by the State of California and RCRA, the TWW does not appear to be a RCRA hazardous waste. However, the TWW should be disposed of in accordance with the AMS described in

CCR, Title 22, Division 4.5, Chapter 34, and all other Local, State, and Federal requirements for the proper waste loading, transportation, and disposal of TWW materials. Prior confirmation for disposal of TWW should be received from the solid waste facility before hauling.

It should be noted that available building plans show that the treated wood associated with the Timber Pier was installed more recently than the wood on the Access Pier. For this reason, the samples from the Access Pier are not considered representative of the submerged

Timber Pier. The Timber Pier wood should be tested for chemical contaminants after removal but prior to disposal.

Other issues of potential environmental concern include the protection of the marine environment during demolition. This includes preventing debris from entering the water as

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March 10, 2009 the pier structure is disassembled. Floating booms surrounding the work area may provide additional protection.

We appreciate the opportunity to assist with this important project. Please feel free to contact

Travis Stravasnik at (858) 217-5309 if you have any questions.

Sincerely, Essentia Management Services, LLC

Travis L. Stravasnik

Certified Asbestos Consultant, CAC#07-4236

Thomas Zdeb

DHS Certified Lead Inspector #6882

Attachments:

Attachment 1 Tables 1 through 8

Attachment 2 AmeriSci Laboratory Analytical Report and Chain-of-Custody Record

Attachment 3 Cal Tech Laboratory Analytical Report and Chain-of-Custody Record

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ATTACHMENT 1

TABLES 1 THROUGH 8

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ATTACHMENT 2

AMERISCI LABORATORY ANALYTICAL REPORT AND

CHAIN-OF-CUSTODY RECORD

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ATTACHMENT 3

CAL TECH LABORATORY ANALYTICAL REPORT AND

CHAIN-OF-CUSTODY RECORD

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