Environmental Consulting and Management Survey Report dated 20211015.pdf

October 15, 2021

US Army Corps of Engineers Attn: Travis Germano 40 Academy Drive Buzzards Bay, MA 02532

Re: ECM Project #210589 Telecommunication Building Sandwich, MA Asbestos and Lead Demolition Inspection Report

Dear Mr. Germano:

Enclosed are the analytical results, observations, and recommendations associated with the asbestos and lead demolition inspection performed by Environmental Consulting & Management Inc. (ECM) of the telecommunication Building located in Sandwich, MA buildings located at along the Cape Cod Canal in Sandwich, Massachusetts.

Methodology and Scope

On September 23, 2021 an asbestos demolition inspection, was conducted by Mr. Daniel J.

Simas (Lic. #AI040541) of ECM. During the course of the inspection ECM collected samples of suspect asbestos containing building materials (ACBM) that may be impacted by the demolition of the building. Both sides of the building was evaluated; this includes the tele-communication side as well as the generator site. Interior materials, exterior materials and roofing materials were surveyed as part of this inspection. Concealed or hidden materials may be present that the building inspector was not able to access at the time of the inspection. Destructive investigation to check above fixed ceilings, within wall cavities and pipe chases, and under hard finish floors (ceramic flooring, hard wood flooring, soft concrete, etc.) was conducted as part of this inspection. No sub-slab or below grade investigation was conducted as part of this inspection. The buildings were still in operation but were unoccupied at the time of the inspection. Only this building that were were escorted to was schedule for demolition was surveyed as part of this inspection. Other buildings may exist on the property but were not surveyed as part of this inspection. ECM made attempt to assess and sample various building materials as well as equipment components associated with the generator

181 Amaral Street O: 401.438.1360 Riverside, RI 02915 F: 401.438.1316 www.ecmne.com http://www.ecmne.com/ but since the generator was most likely going to be salvaged testing was limited and sampling was non-destructive in nature. Photos showing the building surveyed as part this inspection can be found in Attachment 3.

Asbestos

The survey consisted of collecting suspect ACBM within the interior, exterior and roofs of the building scheduled for demolition. These materials were then sent to a Massachusetts licensed asbestos analytical laboratory to be analyzed for asbestos content utilizing Polarized Light Microscopy (PLM) in accordance with Environmental Protection Agency (EPA) method 600/R-93/116. The materials collected, results, and location of ACBM have been denoted within this report. Please refer to Attachment 1 for the asbestos analytical results. Building photos showing the location of the asbestos containing materials can be found in Attachment

3. Below are charts of the samples collected.

Table 1: Sandwich Telecom Bldg – Asbestos Bulk Sampling Table SanAir ID# 21051603

Sample # Material Location Asbestos % Quantity

Sandwich Telecom Building

01A Fiberglass Insulation inside exterior metal wall panels

TeleCom Building Interior None Detected NA

02A-B Foundation Expansion Filler along cold Joint TeleCom Building Interior None Detected NA

03A Exterior Panel Paint TeleCom Building Exterior None Detected NA

04A-C Exterior grey caulking on electrical LB TeleCom Building Exterior

2-5% Chrysotile Asbestos

~1 sf at 6 locations

05A Newer exterior caulking on

AC unit frame TeleCom Building Exterior None Detected NA

06A Roof paint on Roofing and fasteners TeleCom Building Exterior None Detected NA

07A Roof Paint coating along roof edge TeleCom Building Exterior None Detected NA

08A Electrical duct-Seal near opening TeleCom Building Exterior None Detected NA

LF – Linear Feet SF – Square Feet NA – Not Applicable

Asbestos Conclusion:

Sandwich, MA – US Army Corps of Engineers - Telecommunication Building

The older grey caulking was found on the electrical fittings on the North, East and West side of the building; please refer to Attachment 1 for the asbestos analytical results.. the older grey caulking was identified as containing 2-5% Chrysotile asbestos. The Massachusetts Department of Environmental Protection (MADEP) considers materials containing any amounts of asbestos to be an asbestos containing waste material (ACWM). ACM must be handled, packaged and disposed in same manner as asbestos containing materials. There are 6 locations that this grey caulking was identified, totaling ~1 square feet of ACM caulk.

Any suspect materials not sampled within this report should be tested before being impacted.

Regulatory Compliance

All asbestos containing materials and asbestos containing waste materials identified within this report must be abated by a MA licensed asbestos abatement contractor, if the materials are to be disturbed in any way. The quantity is considered a spot repair per the MA Department of Labor and Standards, however the licensed contractor is required to notify the MA Department of Environmental Protection (MA DEP) 10 days prior to the start of any abatement project.

Once abated, a visual inspection would be required post remediation. The inspection must be performed by an independent MA licensed Project Monitor.

The building owner/operator of the facility or facility component shall maintain a copy of the written asbestos survey report available at the facility for review by or submittal to the Massachusetts Department of Environmental Protection upon request at all times during the asbestos abatement activities and shall preserve and maintain such report at the facility for at least two years following the completion of said activities. Since the site is slated to be demolished, the owner/operator shall preserve and maintain the written asbestos survey report at its regular place of business.

Lead

The following chart represents the results of the lead paint samples collected during the inspection as well as the general location and description of the samples.

Sample

ID

Description Location Lead Results

(ppm)

Pb1 White exterior wall paint on metal panels

Exterior paint <95.1

Pb2 Mauve/white exterior paint under Pb1

Exterior paint <176.4

Pb3 Grey Flooring paint thru-out Interior flooring paint 574.3

Pb4 Teal interior wall paint on metal panels Interior wall paint 1300

Pb5 Grey door paint Interior door paint 933.2

Lead: Recommendations and Summary

Several factors including worker protection, disposal, and childhood lead poisoning prevention may apply when considering a lead hazard.

The State of Massachusetts Childhood Lead Poisoning Prevention Program (CLPPP) and the United States Department of Housing and Urban Development (HUD) considers a dried paint with a lead level of 5,000 parts per million to be lead containing.

The Occupational Safety and Health Administration (OSHA) has set the maximum level of daily lead exposure or permissible exposure limit (PEL) of lead to 50 µg/m3 calculated as an 8-hour time weighted average and Action Level (the level at which the use of respirators is required) to 30 µg/m3, regardless of the lead concentration of the material.

Prior to disposal, construction waste suspected to contain lead must undergo Toxic Characteristic Leaching Procedure (TCLP) sampling for lead. The Environmental Protection Agency (EPA) specifies that waste containing greater than 5 mg/l of lead be disposed of as lead waste. But, since the building is slated for demolition and much of this building is painted metal the structure should be considered recyclable and the building with the painted components can be safely recycled without requiring lead remediation.

The paint sampled during the inspection was found to contain <5,000 ppm lead. But worker protection should be used to be compliant with the OSHA requirements.

Limitations

Components that could affect building operation and endanger the safety of the inspector such as active mechanical, electrical systems, or in areas of the building that were not safe to access were not scrutinized during this inspection unless otherwise noted. Any suspect materials not sampled and tested for the presence of asbestos must be handled and disposed of as if it were unless analytical data can prove otherwise.

This inspection was performed for the purpose of a NESHAP demolition inspection. However, additional sampling may be required if additional suspect materials are discovered that were not inspected or evaluated during the initial site visit.

This report was prepared under the request of US Army Corps of Engineers. This report should not be represented, reproduced, or disseminated without the written approval of Environmental Consulting and Management or our client. No warranties other than those expressed in the contract for this project are expressed or implied.

A hard copy of this report can be provided for your records via mail upon request. If you have any further questions feel free to contact myself at 401-304-6612.

Sincerely, Environmental Consulting & Management, Inc.

Daniel J. Simas ECM General Manager MA Inspector License: AI040541

Attachment 1 Asbestos Bulk Sample Results

SanAir ID#: 21051603

Project #: 210589

Project Name: Sandwich Telecom Bldg

Report Date: 9/27/2021

Analysis Report prepared for Environmental Consulting & Management Inc

Dear Daniel J. Simas, We at SanAir would like to thank you for the work you recently submitted. The 11 sample(s) were received on Friday, September 24, 2021 via FedEx. The final report(s) is enclosed for the following sample(s): 1A, 2A, 2B, 3A, 4A, 4B, 4C, 5A, 6A, 7A, 8A.

These results only pertain to this job and should not be used in the interpretation of any other job. This report is only complete in its entirety. Refer to the listing below of the pages included in a complete final report.

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

Final Report Includes:

- Cover Letter

- Analysis Pages

- Disclaimers and Additional Information

Sample conditions:

- 11 samples in Good condition.

1551 Oakbridge Dr. Suite B, Powhatan, VA 23139 | 804.897.1177 | Fax: 804.897.0070 | www.SanAir.com | IAQ@SanAir.com

210589Project Number:

P.O. Number:

Project Name: Sandwich Telecom Bldg

9/23/2021Collected Date:

9/24/2021 9:40:00 AMReceived Date:

9/27/2021 4:23:27 PM

21051603 SanAir ID Number

FINAL REPORT

Environmental Consulting & Management IncName:

Address: 50 Kickemuit Ave

Bristol, RI 02809

401-438-1360Phone:

Analyst: Li, Elizabeth

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

SanAir ID / Description Appearance % Fibrous % Non-fibrous Asbestos Fibers

1A / 21051603-001 Fiberglass Insulation Inside Panel

Various Fibrous

Homogeneous

98% Glass 2% Other None Detected

2A / 21051603-002 Foundation Expansion Filler (Cold Joint)

Black Fibrous

Heterogeneous

60% Cellulose 40% Other None Detected

2B / 21051603-003 Foundation Expansion Filler (Cold Joint)

Black Fibrous

Heterogeneous

60% Cellulose 40% Other None Detected

3A / 21051603-004 Exterior Panel Paint

White Non-Fibrous

Homogeneous

100% Other None Detected

4A / 21051603-005 Exterior Caulking On Electrical LB

Grey Non-Fibrous

Homogeneous

98% Other 2% Chrysotile

4B / 21051603-006 Exterior Caulking On Electrical LB

Grey Non-Fibrous

Homogeneous

98% Other 2% Chrysotile

4C / 21051603-007 Exterior Caulking On Electrical LB

Off-White Non-Fibrous

Homogeneous

95% Other 5% Chrysotile

5A / 21051603-008 Newer Caulking On AC Unit Penetration

Clear Non-Fibrous

Homogeneous

100% Other None Detected

6A / 21051603-009 Roof Paint On Roofing And Fasteners

Silver Non-Fibrous

Heterogeneous

100% Other None Detected

7A / 21051603-010 Roof Paint Along Roof Edge

Red Non-Fibrous

Heterogeneous

100% Other None Detected

Analyst:

Analysis Date: 9/27/2021 Date: 9/27/2021

Approved Signatory:

210589Project Number:

P.O. Number:

Project Name: Sandwich Telecom Bldg

9/23/2021Collected Date:

9/24/2021 9:40:00 AMReceived Date:

9/27/2021 4:23:27 PM

21051603 SanAir ID Number

FINAL REPORT

Environmental Consulting & Management IncName:

Address: 50 Kickemuit Ave

Bristol, RI 02809

Analyst: Li, Elizabeth

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

SanAir ID / Description Appearance % Fibrous % Non-fibrous Asbestos Fibers

8A / 21051603-011 Electrical Duct-Seal

Grey Non-Fibrous

Homogeneous

5% Cellulose 95% Other None Detected

Analyst:

Analysis Date: 9/27/2021 Date: 9/27/2021

Approved Signatory:

1551 Oakbridge Dr. Suite B, Powhatan, VA 23139 | 804.897.1177 | Fax: 804.897.0070 | www.SanAir.com | IAQ@SanAir.com

210589Project Number:

P.O. Number:

Project Name: Sandwich Telecom Bldg

9/23/2021Collected Date:

9/24/2021 9:40:00 AMReceived Date:

9/27/2021 4:23:27 PM

21051603 SanAir ID Number

FINAL REPORT

Environmental Consulting & Management IncName:

Address: 50 Kickemuit Ave

Bristol, RI 02809

Disclaimer

This report is the sole property of the client named on the SanAir Technologies Laboratory chain-of-custody (COC). Results in the report are confidential information intended only for the use by the customer listed on the COC. Neither results nor reports will be discussed with or released to any third party without our client's written permission. The final report shall not be reproduced except in full without written approval of the laboratory to assure that parts of the report are not taken out of context. The information provided in this report applies only to the samples submitted and is relevant only for the date, time, and location of sampling. The accuracy of the results is dependent upon the client’s sampling procedure and information provided to the laboratory by the client. SanAir assumes no responsibility for the sampling procedure and will provide evaluation reports based solely on the sample(s) in the condition in which they arrived at the laboratory and information provided by the client on the COC, such as: project number, project name, collection dates, po number, special instructions, samples collected by, sample numbers, sample identifications, sample type, selected analysis type, flow rate, total volume or area, and start stop times that may affect the validity of the results in this report. Samples were received in good condition unless otherwise noted on the report. SanAir assumes no responsibility or liability for the manner in which the results are used or interpreted. This report does not constitute and shall not be used to claim product certification, approval, or endorsement by NVLAP, NIST, or any other U.S. governmental agencies and may not be certified by every local, state, and federal regulatory agencies.

Samples are held for a period of 60 days. Fibers smaller than 5 microns cannot be seen with this method due to scope limitations.

For NY state samples, method EPA 600/M4-82-020 is performed.

NYELAP Disclaimer:

Polarized- light microscopy is not consistently reliable in detecting asbestos in floor covering and similar non-friable organically bound materials. Quantitative transmission electron microscopy is currently the only method that can be used to determine if this material can be considered or treated as non-asbestos containing.

Asbestos Certifications NVLAP lab code 200870-0 City of Philadelphia: ALL-460 PA Department of Environmental Protection Number: 68-05397 California License Number: 2915 Colorado License Number: AL-23143 Connecticut License Number: PH-0105 Massachusetts License Number: AA000222 Maine License Number: LB-0075, LA-0084 New York ELAP lab ID: 11983 Rhode Island License Number: PCM00126, PLM00126, TEM00126 Texas Department of State Health Services License Number: 300440 Commonwealth of Virginia 3333000323 Washington State License Number: C989 West Virginia License Number: LT000616 Vermont License: AL166318 Louisiana Department of Environmental Quality: 212253, Cert 05088

Revision Date: 8/14/2020

Page 1 of 1Page 5 of 6

Attachment 2 Lead Paint Chip Sample Results

SanAir ID#: 21051554

Project #: 210589

Project Name: Sandwich Telecom Bldg

Report Date: 9/28/2021

Analysis Report prepared for Environmental Consulting & Management Inc

Dear Daniel J. Simas, We at SanAir would like to thank you for the work you recently submitted. The 5 sample(s) were received on Friday, September 24, 2021 via FedEx. The final report(s) is enclosed for the following sample(s): PB1, PB2, PB3, PB4, PB5.

These results only pertain to this job and should not be used in the interpretation of any other job. This report is only complete in its entirety. Refer to the listing below of the pages included in a complete final report.

Sincerely, Abisola Kasali Metals Laboratory Director SanAir Technologies Laboratory

Final Report Includes:

- Cover Letter

- Analysis on Test Family AA

- Disclaimers and Additional Information

Sample conditions:

- 5 samples in Good condition.

1551 Oakbridge Dr. Suite B, Powhatan, VA 23139 | 804.897.1177 | Fax: 804.897.0070 | www.SanAir.com | IAQ@SanAir.com

210589Project Number:

P.O. Number:

Project Name: Sandwich Telecom Bldg

9/23/2021Collected Date:

9/24/2021 9:40:00 AMReceived Date:

9/28/2021 4:03:08 PM

21051554 SanAir ID Number

FINAL REPORT

Environmental Consulting & Management IncName:

Address: 50 Kickemuit Ave

Bristol, RI 02809

Analyst: Baird, Marti

Test Method: SW846/M3050B/7000B

Lead Paint Analysis PAINT µg Pb Sample Size Calculated Sample Sample

Sample Description In Sample (grams) RL Results Results

21051554 - 1 PB1 < 10 0.1052 95.1 <95.1 <0.010 %

Exterior White Paint On Metal Panels µg/g (ppm) By Weight

21051554 - 2 PB2 < 10 0.0567 176.4 <176.4 <0.018 %

Exterior Mauve/White Paint Under Sample 1 µg/g (ppm) By Weight

21051554 - 3 PB3 64 0.1109 90.2 574.3 0.057 %

Grey Flooring Paint On Concrete µg/g (ppm) By Weight

21051554 - 4 PB4 137 0.1051 95.1 1300 0.130 %

Teal Interior Wall Paint On Metal Panels µg/g (ppm) By Weight

21051554 - 5 PB5 60 0.0645 155 933.2 0.093 %

Grey Door Paint (Interior Side) µg/g (ppm) By Weight

Method Reporting Limit <10 µg/0.1 g paint

Signature:

Date: 9/28/2021 Date: 9/28/2021

Reviewed:

210589Project Number:

P.O. Number:

Project Name: Sandwich Telecom Bldg

9/23/2021Collected Date:

9/24/2021 9:40:00 AMReceived Date:

9/28/2021 4:03:08 PM

21051554 SanAir ID Number

FINAL REPORT

Environmental Consulting & Management IncName:

Address: 50 Kickemuit Ave

Bristol, RI 02809

Revision Date 10/20/2020

Disclaimer

SanAir Technologies Laboratory, Inc. participates in the Environmental Lead Accreditation Program (ELAP) administered by AIHA-LAP, LLC (Lab ID162952). Refer to our accreditation certificate or www.aihaaccreditedlabs.org for an up to date list of the Fields of Testing for which we are accredited. SanAir also participates in the State of New York’s DOH-ELAP (Lab Id 11983), and has met the EPA's NLLAP program standards. This report does not constitute endorsement by AIHA-LAP, LLC and/or any other U.S. governmental agencies; and may not be accredited by every local, state or federal regulatory agency.

This report is the sole property of the client named on the SanAir Technologies Laboratory chain-of-custody (COC).

Neither results nor reports will be discussed with or released to any third party without our client’s written permission. Final reports cannot be reproduced, except in full, without written authorization from SanAir

Technologies Laboratory, Inc. The information provided in this report applies only to the samples submitted and is relevant only for the date, time, and location of sampling. SanAir is not responsible for sample collection or interpretation made by others. SanAir assumes no responsibility for information provided by the client on the COC such as project number, project name, collection dates, po number, special instructions, samples collected by, sample numbers, sample identifications, sample type, selected analysis type, flow rate, total volume or area, and start stop times that may affect the validity of the results in this report. SanAir Technologies Laboratory, Inc only assures the precision and accuracy of the data it generates and assumes no responsibility for errors or biasing that occur during collection prior to SanAir’s receipt of the sample(s). SanAir’s Method Detection Limits (MDL) and Reporting Limits

(RL) have been derived using various materials meeting each accrediting agencies’ standards. All quality control results are acceptable unless otherwise noted. Results are not corrected for blanks. For Lead Exposure Limits in

Paint, refer to HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards and State and Federal

Regulations, where applicable.

http://www.aihaaccreditedlabs.org/

Attachment 3 Building Site Photos

1. Sample 4C – was taken to the left of the equipment side entrance; Exterior

2. Sample 4B – not shown in the photo, was taken from the East side entrance;

Exterior

2. Sample 4A – was taken from the back wall of the generator room, south east side; Exterior