ASBESTOS and LEAD-BASED PAINT INVESTIGATION TOWN OF ST. PAUL WILLIS BUILDING ST. PAUL, VIRGINIA

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1 ASBESTOS and LEAD-BASED PAINT INVESTIGATION TOWN OF ST. PAUL WILLIS BUILDING ST. PAUL, VIRGINIA May 22, 2013 Robert R. Jones, Ph.D., REM, AHERA Asbestos Inspector, 5/22/13 Signature Date Asbestos Virginia Inspector License: Sustainable Development Consulting International (SDCI), Inc. Robert R. Jones, Ph.D., REM 103 Sunset Drive, Lebanon, VA USA Phone: P a g e

2 Introduction SDCI is pleased to provide this Report of an asbestos investigation of the Willis Building located in the Town of St. Paul, Virginia. This building is located at the northwest corner of the intersection of 4 th Avenue and Russell Street. The building is proposed for major renovation and concerns over the potential for asbestos containing building materials (ACBM) were raised by the Owner (Town of St. Paul). On 04, 11 and 18 April 2013 Robert R. Jones, PhD., Registered Environmental Manager (REM), AHERA certified Asbestos Inspector (AHERA Inspector Certification No ) and Virginia Department of Professional and Occupational Regulation (DPOR No ) performed an inspection of all accessible areas of the building (excluding the roof area). The roof inspection was completed as part of a separate roof renovation project being completed on behalf of the St. Paul Industrial Development Authority (IDA). He was assisted by William Ickes, AHERA Inspector and Virginia DPOR licensed Asbestos Inspector. Building materials were visually inspected and representative samples were obtained unless they were visually verified to not contain asbestos (i.e., metal flashing, wood, masonry, etc.). Building materials such as wood, porcelain, fiberglass and metal were not sampled. Samples were sealed in containers and labeled for shipping to Scientific Analytical Institute (SAI), Inc., for analysis by polarized light microscopy (PLM) per the EPA Method 600/R-93/116 and 600/M SAI is a member of the National Volunteer Laboratory Accreditation Program (NVLAP). The laboratory report is included as an Appendix to this Report. The results of the survey are contained in this report in Table 1.1 and the laboratory report is included in Appendix A. Background SDCI is aware that the Willis Building is proposed for substantial renovation and in order to determine if there are environmental health concerns related to asbestos or the presence of lead-based paint SDCI was engaged by the Town to perform environmental testing services for those areas that are accessible and/or planned for renovation. It is the Owner s responsibility to provide this information to the prospective buyers, developers or contractors engaged to perform work so that appropriate precautions can be taken to remove any regulated material prior to renovation activities or take steps to reduce the risk to employees and the general public from accidental exposures. Scope of Work SDCI conducted site inspections for the presence of asbestos containing building materials and lead-based paint during April of All visible and accessible suspect materials were sampled excluding the roof where access was not possible due to the deteriorating condition of the roof structure. Samples of homogeneous building materials were collected, labeled, 2 P a g e

3 measured and assessed for friability. All samples were sent to a certified NAVLAP laboratory for asbestos analysis by PLM methodology (see laboratory report in Appendix A). Table 1.1 indicates the results of the survey. Results A total of 52 suspect building materials were collected and sent for laboratory analysis. The samples were labeled and shipped to SAI laboratory for asbestos analysis by PLM. Appendix A is a copy of the certified laboratory report. A total of six samples were reported positive for asbestos content (above 1 percent) per the laboratory analysis. Table 1.1 below identifies only those samples that tested positive for asbestos. The boiler located in the northern end of the basement contains an asbestos containing pipe insulation and jacket insulation. The joint compound within the sheetrock mounted above the boiler is also above the regulated limit for asbestos content while the sheetrock itself is non-regulated (none detected). One other location was identified as containing asbestos on the third floor (apartment #21 and #29). The beige sheet vinyl floor covering also tested positive for asbestos and is located in the hallway and one room of apartment #21 and within two rooms of apartment #29. 3 P a g e

4 Table 1.1: Samples testing positive for asbestos (per report by SAI) Sample ID Description / Color Location Friable Results WBTSI-1 Gray TSI Jacket Basement top of boiler Y 50% Chrysotile WBTSI-2 Gray Pipe TSI Basement above boiler Y 5% Chrysotile WBTSI-3 Gray TSI layer under boiler jacket Basement boiler jacket Y 35% Chrysotile WBSR-1 White sheet rock joint compound Basement above boiler Y 3% Chrysotile (joint compound) WB3VSF-4 Beige sheet flooring 3rd floor, apartment #21 & #29 N 15% Chrysotile This report recommends these materials be removed by a licensed asbestos contractor and disposed of at an approved asbestos waste disposal facility prior to the general demolition of the building. 4 P a g e

5 Lead Paint Survey SDCI completed a lead-based paint (LBP) survey of the Willis Building on the same dates as the asbestos inspection. The purpose of the LBP survey was to determine if the existing paint layers contained lead and could be considered as a hazardous material/waste subject to Environmental Protection Agency (EPA) or Commonwealth of Virginia regulations. This inspection does NOT constitute lead risk assessment per Virginia Department of Environmental Quality (DEQ) standards for residential occupation of buildings built prior to If the building is proposed for residential use a Virginia qualified lead assessor will need to inspect the building to determine if any additional measures are required. Each of the six first floor commercial spaces and the upper floor former apartments were tested using a 3M LeadCheck TM swab kit. The rear restroom of Unit 1 and rear wall of Unit 5 (see sketch) tested positive for lead. Apartment 2 (second floor) tested positive on a door frame, and Apartment 4 tested positive in a closet space. Apartment 22 on the third floor tested positive in a restroom closet. Overall these positive tests represent relatively minor locations in terms of square footage. The presence of LBP should be made available to potential buyers, developers and contractors working on the building. The locations may require scraping prior to renovation with the resulting paint disposed of as a hazardous material. Alternatively the material may be tested under the TCLP (toxicity characteristic leachate procedure) requirements of the EPA to determine its hazardous classification. Generally painted surfaces with LBP paint, if disposed of in their entirety, do not qualify as a hazardous waste and can thus be disposed of as general construction debris. Relevant Regulations for Asbestos Asbestos containing materials (ACM) are defined by the Occupational Safety and Health Administration (OSHA) as any material containing greater than one percent of asbestos. The U.S. Code of Federal Regulations (CFR) 29 CFR 1926 regulates activities that may disturb ACM. In addition, the U.S. Environmental Protection Agency (USEPA) also regulates asbestos under the Toxic Substances Control Act (TSCA). The Commonwealth of Virginia regulates asbestos in accordance with federal laws, rules and procedures as well. The following definitions are excerpted from the federal OSHA regulations and pertain to this building: Class II asbestos work means activities involving the removal of ACM which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics. 29 CFR (b) 5 P a g e

6 Disturbance means activities that disrupt the matrix of ACM or PACM (presumed asbestos containing material), crumble or pulverize ACM or PACM, or generate visible debris from ACM or PACM. Disturbance includes cutting away small amounts of ACM and PACM, no greater than the amount which can be contained in one standard sized glove bag or waste bag in order to access a building component. In no event shall the amount of ACM or PACM so disturbed exceed that which can be contained in one glove bag or waste bag which shall not exceed 60 inches in length and width. The following information is obtained from the Virginia Department of Labor and Industry website: 1. Which government agencies regulate asbestos in Virginia? The Virginia Department of Labor and Industry (DOLI) regulates asbestos through enforcement of the Virginia Occupational Safety and Health (VOSH) regulations, enforcement of the Environmental Protection Agency's National Emission Standards for Hazardous Air Pollutants (NESHAPS), and enforcement of the Asbestos Notification regulations found in the Labor Laws of Virginia ( ). Agency locations and regulations can be found on the agency Web site The Virginia Department of Professional and Occupational Regulation (DPOR) is responsible for all company and individual licensure in Virginia. Licensure and regulatory information can be found on DPOR's Web site. The Virginia Department of Environmental Quality is responsible for the regulation of landfills in Virginia. Information on the disposal of asbestos in Virginia landfills can be obtained from the DEQ Web site at 2. When is an asbestos notification required? Under Virginia regulations, a notification is required for any asbestos abatement project greater than ten linear or ten square feet. Notifications are also required for essentially all demolition projects, regardless of whether asbestos containing materials are not present in the structure. 3. When is a notification not required? 6 P a g e

7 A notification is not required for nonfriable asbestos containing, roofing, flooring and siding materials which when installed, encapsulated or removed do not become friable. If the material is in good shape and removed using OSHA's compliant work practices, then notification is not generally required. If the material is not in good shape, the matrix binding the asbestos fibers has deteriorated, or mechanical means are used to remove the material, resulting in more than incidental breakage, then notification is required. Activities such as grinding, mechanical chipping, sawing or drilling can make the asbestos containing material friable and would require notification. Demolition of residential structures which do not meet the NESHAPS definition of facility does not require notification. 4. Is there a notification and permit fee? Yes, an asbestos project permit fee must be submitted with the completed project notification for non-residential structures. The fee is in accordance with the following schedule: a. $50 for each project equal to or greater than 10 linear feet or 10 square feet up to and including 260 linear feet and 160 square feet. b. $160 for each project equal to or greater than 260 linear feet or 160 square feet up to and including 2600 linear feet and 1600 square feet. c. $470 for each project equal to or greater than 2600 linear feet or 1600 square feet. d. If the amount of the asbestos is reported in both linear feet and square feet the amounts will be added and treated as if the total were in all square feet for this subsection. e. $15 for each amended notification. 5. Is there a form or format for notification? Yes, there is a form for notifications. You can obtain this form from the Department of Labor and Industry Web site or by contacting the Department. 7 P a g e

8 6. How do I notify? Notifications required by the Department of Labor and Industry regulations shall be sent to the address above by certified mail or hand delivery. Notifications shall be postmarked or delivered twenty calendar days before the beginning of any project. Notifications may also be sent by facsimile transmission for projects that do not require a fee or projects with fees paid by credit card. Notifications required by the United States Environmental Protection Agency's NESHAPS regulation must be sent to the Department as described above except the notification period is 10 working days. *Note: EPA does not allow facsimile transmission. NESHAPS required notifications must also be sent to EPA. 7. When do I receive the asbestos permit to start work? The Department will generally issue the permit within seven working days of the receipt of the completed notification form and permit fee. The notification does not become effective until a complete form is submitted and the proper permit fee is enclosed with the completed form or the credit card payment has been approved. Relevant Regulations for Lead-based Paint The Virginia Department of Professional Occupational Regulations (DPOR) stipulates the appropriate registration and training requirements for lead abatement contractors. If the interior renovation includes the removal and disposal of the entire section of building material, and the material does not qualify as a hazardous waste after subjected to TCLP testing, then the work does not qualify as a lead abatement project and a general contractor may be utilized using lead safe practices and property trained employees (Residential Renovation Procedures). If the LBP surfaces is stripped prior to demolition than the work may qualify as a lead abatement project and a properly licensed contractor is required. The final determination will be made by the renovation contractor, project manager and architect in consultation with the building owner and local codes officials. Recommendations SDCI recommends that the Owner, developer, architect/engineer and contractor review this information thoroughly before performing any activities on site that have the 8 P a g e

9 potential to disturb the identified ACM or LBP. The building should remain secured from access by the public and any Town employee or other individuals permitted to enter the building should be made aware of the locations of asbestos and their responsibilities to NOT disturb the materials for any reason. The relevant local Code Official should be contacted to determine any specific local requirements for building renovation or demolition activities. In addition, this survey was performed on the readily accessible portions of the building. Work that uncovers or reveals areas previously not accessible should be discontinued until proper inspections for potential ACM are performed. A qualified and properly licensed contractor should be engaged to remove the identified ACM prior to general renovation, repair or demolishing of any portions of the building. The Owner may wish to contract with a properly licensed firm to remove the ACM material from the building prior to general demolition/renovation work in order to deliver a building free of any known environmental liabilities to a potential developer or purchaser. Summary In its current condition the Willis Building represents a minor risk to the public resulting from the presence of asbestos containing materials and lead-based paint. The locations of these materials, as identified in this Report are isolated and access is controlled. The complete removal of the ACM is recommended prior to general demolition or renovation activities. The identified LBP is minor in scope and should be removed by a general contractor in-tact with the underlying wood surfaces for disposal as general waste subject to the results of TCLP testing. No further actions are recommended or warranted at this time. 9 P a g e

10 Appendix A: SAI Laboratory Report and Chain of Custody from SDCI 10 P a g e

11 11 P a g e

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