NORWELL PUBLIC LIBRARY 64 South St, Norwell, MA 02061

Transcription

1 INSPECTION REPORT FOR HAZARDOUS BUILDING MATERIALS NORWELL PUBLIC LIBRARY 64 South St, Norwell, MA Prepared For: Mr. Rick Pomroy Pomroy Associates LLC Village Place 448 Turnpike Street, Suite 1-1 South Easton, MA Prepared By: Zachary Keefe Cashins & Associates 599 North Avenue, Suite 8 Wakefield, MA Job #: 6177 January 5, 2017 C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

2 Table of Contents 1. INTRODUCTION & EXECUTIVE SUMMARY Asbestos Containing Building Materials (ACBM) Lead-Based Paint Polychlorinated Biphenyls (PCBs) Mercury-Containing Components LIMITATIONS ASBESTOS Methodology Regulatory Guidance Analytical Results... 6 Table A: Materials Testing Positive for Asbestos...6 Table B: Materials Testing Negative for Asbestos Recommendations LEAD-BASED PAINT Methodology Regulatory Guidance Findings Recommendations POLYCHLORINATED BIPHENYLS (PCBs) Summary Findings Recommendations MERCURY-CONTAINING COMPONENTS Summary Findings Recommendations...12 APPENDIX A: Laboratory Analytical Results C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

3 Pomroy Associates Norwell Public Library Page 3 of INTRODUCTION & EXECUTIVE SUMMARY Pomroy Associates retained Cashins & Associates to conduct an inspection for asbestos containing building materials (ACBM), lead-based paint (LBP), polychlorinated biphenyls (PCBs) in light ballast and caulking, and mercury containing components at the Norwell Public Library, located at 64 South Street in Norwell, Massachusetts. A Massachusetts certified Asbestos Inspector and lead paint inspector from Cashins & Associates inspected the property on January 4 and 5, The scope of inspection included the interior and exterior of the building. Sampling of the roof was performed with the assistance of a licensed roofing contractor. No limited intrusive sampling techniques were employed in order to access behind fixed walls, above fixed ceilings, and beneath flooring materials. No penetrations were made in the exterior façade of the building. 1.1 Asbestos Containing Building Materials (ACBM) The following materials were found to contain at least 1% asbestos: Floor tile and associated mastic adhesive Joint compound associated with gypsum board walls Transite HVAC ductwork Window glazing compound Sink basin mastic These materials must be removed by a Massachusetts Licensed Asbestos Abatement Contractor prior to being disturbed by demolition work. 1.2 Lead-Based Paint Lead was detected in paint on some surfaces. Because detectable levels of lead were found on certain surfaces, certain precautions should be taken when torch cutting, sanding, or otherwise disturbing the surfaces of these components. Personal protective equipment as well as personal employee exposure monitoring is recommended if these surfaces are to be impacted in such a manner as to generate dust or fume. 1.3 Polychlorinated Biphenyls (PCBs) Labels affixed to representative light ballast indicated that they were PCBs-free. No suspect caulking materials were observed during this inspection. C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

4 Pomroy Associates Norwell Public Library Page 4 of Mercury-Containing Components Mercury-containing fluorescent light bulbs were identified in the building. These must be handled and disposed of in accordance with the 40 CFR part 273 Universal Waste regulatory requirements before they are disturbed by renovation or demolition work. 2. LIMITATIONS All asbestos inspections are inherently limited due to the fact that not all materials are able to be uncovered using standard inspection techniques. Factors such as accessibility, building occupancy, safety, lighting conditions, and physical limitations may cause some asbestoscontaining materials to remain unidentified following even the most thorough inspection. This inspection was of accessible building areas only. We did not attempt to access within machinery, sub floors, mechanical chases, trenches, or subterranean areas. Our inspection was limited to building materials only. No assessment of soil, debris, water, or other hazardous materials or wastes was conducted. No sampling was performed where the act of sampling would endanger the safety of the inspector. Demolition equipment was not used during this inspection. No penetrations were made in the exterior façade of the building. Hence, there may be additional suspect materials within or behind finishes, floors, and other components that were not identified. We recommend that an additional inspection be conducted when and if such equipment is available at the site. Due to limitations set by budgets, schedules, and practicality, not every piece of suspect material (e.g. ceiling tile, floor tile, wall panel) was sampled. Assumptions were made on-site regarding the uniformity and homogeneity of certain materials. It is possible, therefore, that other materials that seem to be homogenous are not, and as such may contain asbestos. Due to the above, Cashins cannot guarantee that all suspect asbestos containing materials were identified at the site, and shall not be held financially responsible for their abatement costs. It is likely that additional suspect materials will be uncovered during future renovation or demolition work. These materials should be considered to be asbestos-containing until they are sampled, analyzed, and confirmed to be otherwise. Project specifications should mandate that contractors stop work immediately should any such material be uncovered. C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

5 Pomroy Associates Norwell Public Library Page 5 of ASBESTOS 3.1 Methodology Zachary Keefe, a Massachusetts certified Asbestos Inspector (Cert. # AI ), performed the inspection on January 4 and 5, Suspect building materials were sampled by first spraying the material with water to reduce the potential for fiber release. Once adequately wet, small pieces of the materials were collected and placed into sealed plastic bags for transport to the laboratory. The type, color, and size of the suspect material were inventoried on chain-of-custody forms, and quantities of the materials were assessed and recorded. The bulk samples were analyzed by Asbestos Identification Laboratory, a fully accredited asbestos analytical laboratory. The laboratory analyzed the samples using Polarized Light Microscopy (PLM) in accordance with the requirements of 40 CFR Part 763, Subpart F, Appendix A. C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

6 Pomroy Associates Norwell Public Library Page 6 of Regulatory Guidance The following entities are responsible for regulating the handling of asbestos containing materials and for protecting workers who may be exposed to asbestos fibers as part of their occupation: The United States Environmental Protection Agency (EPA) Occupational Health & Safety Administration Massachusetts Department of Environmental Protection Massachusetts Department of Labor and Workforce Development (DLWD) These regulations stipulate how asbestos containing materials are to be identified prior to renovation or demolition. They also detail the proper engineering controls and work practices that must be employed during an asbestos abatement project. The National Emission Standard for Hazardous Air Pollutants (NESHAPS) subpart M is a national regulation that specifies how asbestos containing materials are to be removed while protecting the general public from airborne asbestos fiber release. The MA DEP is the local authority that enforces the NESHAP regulation as well as the Massachusetts DEP regulation 310 CMR 7.00, 7.09, and 7.15, which requires that an inspection for ACBM be conducted prior to renovation or demolition projects. It also stipulates that friable ACBM, or ACBM that will be made friable by demolition or renovation work, be removed prior to such activity. 3.3 Analytical Results In Table A we have listed the types of materials testing positive for asbestos, along with quantities, locations, and sample numbers. Table A: Materials Testing Positive for Asbestos Type Location Quantity Sample #(s) Black floor tile and associated mastic adhesive Gray window glazing compound White joint compound Kitchen area under carpet 200 sf A,B A,B Perimeter of window panes throughout Associated with gypsum walls throughout 50 windows A,B 10,500 sf A,B Black sink basin mastic Kitchen 1 sink A,B C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

7 Pomroy Associates Norwell Public Library Page 7 of 13 Table A: Materials Testing Positive for Asbestos Type Location Quantity Sample #(s) Transite ductwork Near adult graphic novels 24 lf (24 diameter) Assumed Transite ductwork 1 Throughout concrete slab TBD Assumed Black duct insulation wrap West side of roof on duct 10 lf A,B Note 1: It was reported by on-site staff that this ductwork exists throughout the concrete slab. The quantity is currently unknown. Table B: Materials Testing Negative for Asbestos Type Location Sample #(s) Beige carpet mastic Under carpet throughout A,B White gypsum board 2 Walls throughout A Gray 12 x 12 floor tile and associated clear mastic adhesive First floor bathroom A,B A,B White ceiling panels Ceilings throughout A,B Black window glazing compound Newer windows in isolated locations A,B Note 2: Because the joint compound tested positive for asbestos, the gypsum wallboard must be treated as asbestos containing. 3.4 Recommendations Asbestos containing building materials are present in the building. State and federal regulations require that these materials be removed if they are to be disturbed by renovation or demolition work. Removal must be conducted by a Massachusetts licensed Asbestos Abatement Contractor. This report must not be used as a project specification. Abatement work should be conducted in accordance with a site-specific asbestos abatement specification developed by a certified Asbestos Abatement Designer. Cashins & Associates can provide such a specification This inspection did not include penetrations of the exterior façade. Thus, there may be additional suspect ACBM that were not identified during this survey. If any suspect ACBM is discovered that are not addressed in this report, they must be sampled and analyzed prior to being impacted. C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

8 Pomroy Associates Norwell Public Library Page 8 of LEAD-BASED PAINT 4.1 Methodology Cashins & Associates collected paint chip samples from representative painted surfaces throughout the building. Samples were sent to ProScience Analytical Services, Inc., of Woburn, Massachusetts, where they were analyzed for asbestos content using Polarized Light Microscopy (PLM) in accordance with the requirements of 40 CFR Part 763, Subpart F, Appendix A. Surfaces tested included, but were not limited to, walls, ceilings, windows, doors, casings/jambs, trim, and other miscellaneous surfaces on a variety of substrates including wood and gypsum board. 4.2 Regulatory Guidance In all areas where LBP is disturbed by renovation or demolition work and where components covered by LBP are disposed of, all pertinent OSHA and EPA regulations apply. OSHA Renovation or demolition activities that disturb surfaces that contain lead must be conducted in accordance with the OSHA regulation 29 CFR Lead Exposure in Construction: Interim Final Rule. This regulation requires that a site-specific health and safety plan be prepared before conducting activities that create airborne lead emissions. Such a plan should include the identification of lead components, an exposure assessment, and, if applicable, the required work procedures and personnel protection to be used. An exposure assessment must be performed via personal air monitoring if there is the potential for employees to be exposed to lead due to the renovation or demolition activity. If demolition is being conducted that will disturb lead-based paints, the employer must assume that employee exposure is in excess of the Permissible Exposure Limit (PEL) of 50 micrograms per cubic meter of air (µg/m 3 ), until the exposure assessment is completed. If the PEL is exceeded, employees are required to use appropriate personal protective equipment (PPE). Furthermore, a written respirator program is required per 29 CFR The lead standard also requires the following protective measures be taken until the exposure assessment is completed: Isolation of the work area; appropriate personal protective clothing and equipment; change areas and hand washing facilities; biological monitoring; and C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

9 Pomroy Associates Norwell Public Library Page 9 of 13 training The results of the initial exposure assessment will determine the protective measures that must be followed for the remainder of the project. OSHA may allow air-monitoring data from previous projects conducted under conditions closely resembling the present project to be used for the exposure assessment. If the exposure assessment indicates that exposure levels are below the Action Level of 30 µ/m 3, there are no additional requirements under the standard if the conditions remain the same. EPA In addition to the worker protection requirements stipulated by OSHA, MA DEP and the EPA regulate the disposal of wastes that are potentially hazardous. Such wastes may include paint chips and residue generated during abatement or repainting work, or whole components, such as wood windows, doors, and trim that are coated with LBP and that are disposed of as the result of renovation or demolition work. Metal components are not regulated if they will be recycled and not disposed of in a landfill. To determine the required method for disposing of permeable items coated with LBP, the DEP and the EPA require representative sampling of the debris to determine the quantity of lead that would be expected to leach into the environment if the debris were disposed of in a landfill. The representative sample(s) must be analyzed by the Toxicity Characteristic Leaching Process (TCLP). If the result of this procedure indicates that the sample leaches a lead concentration below five parts per million (ppm), the debris is not regulated and can be disposed of in a traditional construction landfill. However, the debris must be disposed of as hazardous waste if the TCLP result exceeds 5 ppm. To minimize the total volume of hazardous waste, segregating hazardous from nonhazardous waste is advisable. 4.3 Findings Lead chip sample analysis showed that lead concentration in paint chips ranged from below detection limit to 1.6 percent by weight. The detectable concentration was only found on specific components the metal structural posts that run down the center of the building. No detectable levels of lead were found in any of the other samples. Personal protective equipment as well as personal employee exposure monitoring is recommended if these surfaces are to be impacted in such a manner as to generate dust or fume. Complete results of all testing are presented in Appendix A. C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

10 Pomroy Associates Norwell Public Library Page 10 of Recommendations 1. Lead concentrations were in most instances below the instrument's or laboratory's detection limit. Metal structural posts were found to have a lead percent of 1.6 by weight. 2. Handling of components that are covered by LBP may require compliance with the OSHA lead standard. To minimize exposure to airborne dust or fume, torch burning, cutting, grinding, or similar high impact work on components covered by LBP should be avoided. Such work would need to be conducted by properly trained workers using appropriate worker protection and engineering controls. 3. For work activities that may generate airborne lead, the contractor(s) should perform an initial exposure assessment via personal air monitoring for each individual task (e.g. demolition, abrasive blasting, and painting) that has the potential for causing worker exposure to be at or above the OSHA Action Level. In lieu of monitoring, historical data from similar operations may be used to comply with OSHA requirements. C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

11 Pomroy Associates Norwell Public Library Page 11 of POLYCHLORINATED BIPHENYLS (PCBs) 5.1 Summary Some older fluorescent light ballast contain PCBs. Newer fluorescent light ballast do not contain PCBs and are marked as such. Typically, if the label on the ballast does not include the No PCBs wording, it is assumed to be PCBs-containing and must be handled as hazardous waste and recycled in accordance with federal regulations. Available data suggests that caulking manufactured in the 1950s through 1970s will likely contain some levels of PCBs. Without testing it is unclear whether caulking in a given building may exceed EPA s definition of PCB bulk product waste of 50 parts per million (ppm) or greater. If it does, removal and disposal of the caulk is required in accordance with EPA s TSCA regulations (40 CFR 761). 5.2 Findings The No PCBs wording was observed on representative ballast. It is therefore assumed that the ballast do not contain PCBs. No caulkings were observed during this investigation; thus, no bulk samples were submitted for PCBs analysis. 5.3 Recommendations Representative light ballast inspected in the building were found to have the "No PCBs" wording; therefore, they are assumed to be non PCBs-containing. However, because not every ballast was inspected, each unit should be assessed prior to removal and disposal. C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

12 Pomroy Associates Norwell Public Library Page 12 of MERCURY-CONTAINING COMPONENTS 6.1 Summary Fluorescent light bulbs and older thermostat switches contain mercury. Consequently, they cannot be disposed of as normal construction waste, but rather must be handled and disposed of in accordance with the 40 CFR part 273 Universal Waste regulatory requirements. Fluorescent light bulbs were found to be present throughout the building. 6.2 Findings A total of 340 four-foot fluorescent bulbs were found in the building. 6.3 Recommendations The mercury-containing components must be handled and disposed of in accordance with the 40 CFR part 273 Universal Waste regulatory requirements before they are disturbed by renovation or demolition work. C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

13 Pomroy Associates Norwell Public Library Page 13 of 13 APPENDIX A Laboratory Analytical Results C:\Users\zkeefe\Desktop\Cashins\ Hazmat Inspection Norwell Public Library\POM6177.docx

14 Asbestos Identification Laboratory 165 New Boston St., Ste 227 Woburn, MA Web: Batch: January 05, 2017 Zach Keefe Cashins & Associates 599 North Ave Suite 8 Wakefield, MA Analysis Method: BULK PLM ANALYSIS EPA/600/R-93/116 Project Number: 6177 Project Name: Norwell Public Library #6177 Date Sampled: Work Received: Work Analyzed: Dear Zach Keefe, Asbestos Identification Laboratory has completed the analysis of the samples from your office for the above referenced project. The information and analysis contained in this report have been generated using the EPA /600/R-93/116 Method for the Determination of Asbestos in Bulk Building Materials. Materials or products that contain more than 1% of any kind or combination of asbestos are considered an asbestos containing building material as determined by the EPA. This Polarized Light Microscope (PLM) technique may be performed either by visual estimation or point counting. Point counting provides a determination of the area percentage of asbestos in a sample. If the asbestos is estimated to be less than 10% by visual estimation of friable material, the determination may be repeated using the point counting technique. The results of the point counting supersede visual PLM results. Results in this report only relate to the items tested. This report may not be used by the customer to claim product endorsement by NVLAP or any other U.S. Government Agency. Laboratory results represent the analysis of samples as submitted by the customer. Information regarding sample location, description, area, volume, etc., was provided by the customer. Asbestos Identification Laboratory is not responsible for sample collection activities or analytical method limitations. Unless notified in writing to return samples, Asbestos Identification Laboratory discards customer samples after 30 days. Samples containing subsamples or layers will be analyzed separately when applicable. Reports are kept at Asbestos Identification Laboratory for three years. This report shall not be reproduced, except in full, without the written consent of Asbestos Identification Laboratory. NVLAP Lab Code: Massachusetts Certification License: AA State of Connecticut, Department of Public Health Approved Environmental Laboratory Registration Number: PH-0142 State of Maine, Department of Environmental Protection Asbestos Analytical Laboratory License Number: LB-0078(Bulk) LA-0087(Air) State of Rhode Island and Providence Plantations. Department of Health Certification: AAL-121 State of Vermont, Department of Health Environmental Health License AL Thank you Zach Keefe for your business. Michael Manning Owner/Director

15 January 05, 2017 Zach Keefe Cashins & Associates 599 North Ave Suite 8 Wakefield, MA Analysis Method: BULK PLM ANALYSIS EPA/600/R-93/116 Project Number: 6177 Project Name: Norwell Public Library #6177 Date Sampled: Work Received: Work Analyzed: FieldID Material Location Color Non-Asbestos % Asbestos % LabID A Black Floor Tile 1st Floor Kitchen Under Carpet black Non-Fibrous 98 Detected Chrysotile B Black Floor Tile 1st Floor Kitchen Under Carpet black Non-Fibrous 98 Detected Chrysotile A Black Mastic On 01A black Non-Fibrous 95 Detected Chrysotile B Black Mastic On 01B black Non-Fibrous 95 Detected Chrysotile A Beige Carpet Mastic 1st Floor Technical Services yellow Non-Fibrous 100 None Detected B Beige Carpet Mastic 1st Floor Children's Area yellow Non-Fibrous 100 None Detected A Gray Window Glazing Compound 1st Floor Technical Services gray Non-Fibrous 95 Detected Chrysotile B Gray Window Glazing Compound 1st Floor at DVD's gray Non-Fibrous 95 Detected Chrysotile A White Gypsum Board 1st Floor Janitor's Closet gray Cellulose 20 Non-Fibrous 80 None Detected A Gray 12x12 Floor Tile 1st Floor Bathroom multi Non-Fibrous 100 None Detected B Gray 12x12 Floor Tile 1st Floor Bathroom multi Non-Fibrous 100 None Detected A Clear Mastic On 06A clear Non-Fibrous 100 None Detected B Clear Mastic On 06B clear Non-Fibrous 100 None Detected A White JT Compound Thursday 05 January 1st Floor Hallway at Janitor's Closet white Non-Fibrous 98 Detected Chrysotile 2 Page 1 of 2

16 FieldID Material Location Color Non-Asbestos % Asbestos % LabID B A B A B A Thursday 05 January White JT Compound White Ceiling Panels White Ceiling Panels Black Window Glazing Compound Black Window Glazing Compound Black Sink Basin Mastic 1st Floor Near Check Out 1st Floor at Storage Closet 1st Floor Near Bathrooms white Non-Fibrous 98 Detected Chrysotile 2 multi Cellulose 65 Non-Fibrous 35 multi Cellulose 70 Non-Fibrous 30 None Detected None Detected 1st Floor Audio Book Room black Non-Fibrous 100 None Detected 1st Floor at Work Stations 1st Floor Kitchen End of Report black Non-Fibrous 100 None Detected black Non-Fibrous 95 Detected Chrysotile 5 Page 2 of 2 Analyzed by: Batch: 18795

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26 Asbestos Identification Laboratory 165 New Boston St., Ste 227 Woburn, MA Web: Batch: January 05, 2017 Zach Keefe Cashins & Associates 599 North Ave Suite 8 Wakefield, MA Analysis Method: BULK PLM ANALYSIS EPA/600/R-93/116 Project Number: 6177 Project Name: Norwell Public Library #6177 Date Sampled: Work Received: Work Analyzed: Dear Zach Keefe, Asbestos Identification Laboratory has completed the analysis of the samples from your office for the above referenced project. The information and analysis contained in this report have been generated using the EPA /600/R-93/116 Method for the Determination of Asbestos in Bulk Building Materials. Materials or products that contain more than 1% of any kind or combination of asbestos are considered an asbestos containing building material as determined by the EPA. This Polarized Light Microscope (PLM) technique may be performed either by visual estimation or point counting. Point counting provides a determination of the area percentage of asbestos in a sample. If the asbestos is estimated to be less than 10% by visual estimation of friable material, the determination may be repeated using the point counting technique. The results of the point counting supersede visual PLM results. Results in this report only relate to the items tested. This report may not be used by the customer to claim product endorsement by NVLAP or any other U.S. Government Agency. Laboratory results represent the analysis of samples as submitted by the customer. Information regarding sample location, description, area, volume, etc., was provided by the customer. Asbestos Identification Laboratory is not responsible for sample collection activities or analytical method limitations. Unless notified in writing to return samples, Asbestos Identification Laboratory discards customer samples after 30 days. Samples containing subsamples or layers will be analyzed separately when applicable. Reports are kept at Asbestos Identification Laboratory for three years. This report shall not be reproduced, except in full, without the written consent of Asbestos Identification Laboratory. NVLAP Lab Code: Massachusetts Certification License: AA State of Connecticut, Department of Public Health Approved Environmental Laboratory Registration Number: PH-0142 State of Maine, Department of Environmental Protection Asbestos Analytical Laboratory License Number: LB-0078(Bulk) LA-0087(Air) State of Rhode Island and Providence Plantations. Department of Health Certification: AAL-121 State of Vermont, Department of Health Environmental Health License AL Thank you Zach Keefe for your business. Michael Manning Owner/Director

27 January 05, 2017 Zach Keefe Cashins & Associates 599 North Ave Suite 8 Wakefield, MA Analysis Method: BULK PLM ANALYSIS EPA/600/R-93/116 Project Number: 6177 Project Name: Norwell Public Library #6177 Date Sampled: Work Received: Work Analyzed: FieldID Material Location Color Non-Asbestos % Asbestos % LabID A Black Parapet Flashing North Roof black Non-Fibrous 100 None Detected B Black Parapet Flashing South Roof black Non-Fibrous 100 None Detected A B A B A Black Tar Flashing on Duct Insulation Black Tar Flashing on Duct Insulation Gray Tar Flashing on Ducy Insulation Gray Tar Flashing on Ducy Insulation Black Tar Flashing Roof Roof Roof Roof On Conduit Box black Non-Fibrous 80 Detected Chrysotile 20 black Non-Fibrous 80 Detected Chrysotile 20 black Fiberglass 5 Non-Fibrous 95 black Fiberglass 5 Non-Fibrous 95 None Detected None Detected black Non-Fibrous 100 None Detected B Black Tar Flashing On HVAC Base black Non-Fibrous 100 None Detected Thursday 05 January End of Report Page 1 of 1 Analyzed by: Batch: 18798

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