HAZARDOUS MATERIALS BUILDING INSPECTION ARTS AND SCIENCE CENTER PROJECT NEW RIVER COMMUNITY & TECHNICAL COLLEGE LEWISBURG, WEST VIRGINIA

Transcription

1 HAZARDOUS MATERIALS BUILDING INSPECTION ARTS AND SCIENCE CENTER PROJECT NEW RIVER COMMUNITY & TECHNICAL COLLEGE LEWISBURG, WEST VIRGINIA DECEMBER, 2011 JANUARY,

2 HAZARDOUS MATERIALS BUILDING INSPECTION Conducted For: WEST VIRGINIA HIGHER EDUCATION POLICY COMMISSION NEW RIVER COMMUNITY & TECHNICAL COLLEGE LEWISBURG, WEST VIRGINIA DECEMBER, 2011 JANUARY, 2012 Prepared By: Project Manager Reviewed By: Daniel O. Chute, CIH, CSP Project Certified Industrial Hygienist 2

3 TABLE OF CONTENTS EECUTIVE SUMMARY INTRODUCTION Asbestos-Containing Materials Lead-Containing Materials Lead Drinking Water Testing Radon Testing Mercury, Polychlorinated Biphenyl, Nickel-Cadmium, Radioactive Source Containing Components SUMMARY OF RESULTS DISCUSSION OF RESULTS AND RECOMMENDATIONS Asbestos-Containing Materials Lead-Containing Materials Lead Drinking Water Testing Radon Testing Polychlorinated Biphenyl Testing Mercury-Containing Fluorescent Lamps, Lead-Acid Batteries, and Smoke Detectors LIMITATIONS AND CONSIDERATIONS 16 TABLES Table 1 Table 2 Table 3 Table 4 Table 5 Table 6 Table 7 Table 8 Table 9 Identified Hazardous Material Component Summary Hazardous Material Building Inspection Attachment Index Asbestos-Containing Material Bulk Sample Summary Gravimetric Reduction Bulk Sample Summary For Select Asbestos-Containing Material Lead-Containing Material Bulk Sample Summary Renovation Debris Waste Characterization Sample Results Lead Drinking Water Sample Results Radon Sample Results Polychlorinated Biphenyl Sample Results 1

4 ATTACHMENTS Attachment A Hazardous Materials Building Inspection Task Outline Attachment B Functional Space Inventory of All Affected Hazardous Building Materials Attachment C Asbestos Inventory Attachment D Hazardous Material Inventory Attachment E Asbestos Bulk Sample Log Attachment F Lead Bulk Sample Log Attachment G Lead Drinking Water Sample Log Attachment H Radon Sample Log Attachment I Asbestos Bulk Sample Laboratory Report Attachment J Lead-Containing Material Bulk Sample Laboratory Report Attachment K Renovation/Construction Debris Waste Characterization Laboratory Results Attachment L Lead Drinking Water Sample Laboratory Report Attachment M Radon Sample Laboratory Report Attachment N Polychlorinated Biphenyl Laboratory Report Attachment O Laboratory Credentials Attachment P Orion Consulting, LLC Survey Personnel Credentials 2

5 EECUTIVE SUMMARY Orion Consulting, LLC (Orion) was retained by the West Virginia Higher Education Policy Commission (WVHEPC) to conduct a Hazardous Materials Inspection of New River Community & Technical College s (NRCTC) Arts and Crafts Center building, located in Lewisburg, West Virginia. The scope of this survey included a review of relevant historical documentation, pending construction drawings, interviews with NRCTC facility personnel, and building inspection to determine the presence of asbestos and lead-containing materials, mercury, polychlorinated biphenyl, nickel-cadmium, lead-acid, and radioactive source-containing components. In addition, radon testing was also conducted. Attachment A contains an outline of the inspection and testing methodology utilized for this project. On-site assessments were conducted between December 27 th, 2011 and January 6 th, Identified hazardous materials for each floor are summarized in the Functional Space Inventory tables provided in Attachment B Detailed Asbestos and Hazardous Materials Inventory tables can be found in separate Attachments of this report. Lead Drinking Water results are presented in Attachment G. Radon test results are provided in Attachment H. During the survey, asbestos-containing building materials (ACBM) were identified on every floor. These materials included plumbing gaskets, floor tile mastic, and skylight panels. On the exterior of the building, window glazing and caulking, and masonry caulking were found to contain asbestos. Suspect asbestos-containing material consisted of boiler internal parts and pipe gaskets, and pool piping gaskets. The report provides tabular summaries of the type, location and approximate quantities of identified ACBM to assist with ongoing facility management and construction planning. In addition, other potentially hazardous materials were identified throughout the building which should require well-defined control measures during maintenance, renovation, or construction activities. These components included lead-containing materials and paint on various building fixtures, mercury in fluorescent lighting systems and HVAC thermostats, and lead-acid batteries. Results of water quality testing for lead in drinking fountains and kitchenette sinks, and radon testing are also provided. 3

6 Recommendations include the development and implementation of Management Programs for identified materials/components. Program elements are provided in Section 3.0. Radon testing results indicate that airborne concentrations are between 40 and 47 picocuries per liter (pci/l). Orion recommends that WVHEPC conduct confirmation testing, as per EPA guidelines (EPA "A Citizen's Guide to Radon [402-K , January 2009]) in order to validate radon levels. 4

7 1.0 INTRODUCTION Orion Consulting, LLC (Orion) was retained by the West Virginia Higher Education Policy Commission (WVHEPC) to conduct a Hazardous Materials Inspection of New River Community & Technical College s (NRCTC) Arts and Crafts Center building, located in Lewisburg, West Virginia. The inspection task outline utilized for this project in included in Attachment A. The current building was originally constructed by the Greenbrier College for Women in the mid-1950's to support physical education programs, and included a gymnasium, pool, and classrooms. It has most recently utilized by the West Virginia Division of Highways as the District Nine Headquarters, and the West Virginia Department of Health. Orion employees Todd Schwarz, David George, and Tracy Smith conducted site activities between December 27 th, 2011 and January 6 th, Historical documentation reviewed during this project included the following. West Virginia Division of Highways Plan Drawings from January and July, 1995 West Virginia Department of Health Plan Drawings from March, percent construction drawings for the pending renovation project compiled by E. T. Boggess Architect, Incorporated in October, Interviews were also conducted with the following individuals regarding knowledge of building systems and components. Roger Griffith, Dean, New River Community & Technical College Nathan Turner, Architect, E. T. Boggess Architect, Incorporated Richard Donovan, West Virginia Higher Education Policy Commission Specific elements of this inspection included the following. 1.1 Asbestos-Containing Materials An inspection of the building was conducted in order to assist compliance with OSHA s Construction Standard for Occupational Exposure to Asbestos (29 CFR ) in the event that maintenance activities or renovations to the property impact asbestos-containing materials. Components of this survey consisted of the following: 1. Site walk-through to verify locations of accessible suspect materials. 2. Collection of bulk samples in accordance with section (k) of the OSHA standard. 3. Quantification of suspect asbestos-containing material (ACM). 5

8 4. Submittal of bulk samples to a NVLAP-accredited laboratories, Schneider Laboratories, Incorporated, and AmeriSci, Incorporated. 5. Preparation of findings, including tabular summary of identified asbestos-containing materials. Survey assessment and bulk sampling was conducted on the basis of observed homogeneous materials. Homogeneous means alike in color, texture, appearance, and apparent age. Building materials can also be considered homogeneous. For example, a specific type of thermal system insulation (TSI) may be utilized on a section of piping. Given this, we would consider the TSI homogeneous. Conversely, more than one type of vinyl composition tile (VCT) may exist as floor covering. In this case, each type of VCT would be considered separate, homogeneous material, and sampled accordingly. 1.2 Lead-Containing Materials Accessible facility components that may have suspect lead-containing material or coatings were tested by collection of bulk samples. Testing parameters incorporated methods included in the United States Department of Housing and Urban Development document Guidelines for the Evaluation and Control of Lead-Based Paint in Housing, (June, 1995). Samples were analyzed in Orion s AIHA/ELLAP-accredited contract laboratory, Schneider Laboratories, Incorporated. Test results will assist in determining which relevant portions of OSHA s Interim Standard for Lead in Construction (26 CFR ) would apply for maintenance or renovation activities. Emergency lighting units and fire alarm panels were also assessed to determine if they contained lead-acid batteries. Orion characterized the anticipated waste stream from pending renovation activities (dry wall and paint chips) in order to determine proper disposal methods. Representative samples were collected and analyzed in Orion's WVDEP-approved contract laboratory, REIC Laboratories, Incorporated. 1.3 Lead Drinking Water Testing Public/occupant water fountains and kitchenette sink taps were tested for lead content. Sample methodology followed the testing protocol for first draw, as defined by laboratory instructions and EPA s guidance document, Lead in Drinking Water in Schools and Non-Residential Buildings. Samples were analyzed in Orion s NELAC-accredited laboratory, Schneider Laboratories, Incorporated. 6

9 1.4 Radon Testing Background radon levels were assessed by collection of samples over a 48-hour period in multiple areas of the basement. Radon testing media (Charcoal Absorption Test Kits) and analysis were provided by Orion s NEHA/NRPP-accredited contract laboratory, Alpha Energy Laboratories, Incorporated. Testing protocols were conducted in accordance with laboratory directions and guidelines stipulated in the EPA document Radon Measurement in Schools. 1.5 Mercury, Polychlorinated Biphenyl, Lead-Acid, Nickel-Cadmium, and Radioactive Source-Containing Components In order to determine the existence and location of the referenced components, Orion personnel conducted a review of historical drawings and current architectural plans, and interviewed NRCTC facility maintenance personnel. In addition, suspect components were noted during the asbestos inspection phase of the building inspection. The following table summarizes relevant items identified during this survey. Table 1 Identified Hazardous Materials Component Summary Material Mercury Lead-Acid Component Fluorescent and High Intensity Discharge Lamps, HVAC Thermostats Exit Signs, Emergency Lighting, and Fire Alarm Panel Batteries Mercury fluorescent and high intensity discharge lamp locations were identified by consulting historical and current construction drawings. An inventory of lamps was developed by conducting a walkthrough of building functional spaces. Orion personnel accessed the interior ballast of one T-8 and a T-12 fluorescent lamp fixture, both of which were labeled non-polychlorinated biphenyl (PCB). Several HVAC thermostats were observed and are assumed to contain mercury. WVHEPC also requested that Orion inspect a floor drain located in the western portion of the Lower Level Mechanical in order to determine if any residual mercury was present from a recent spill in that area. Exit signs within the facility are either hard-wired to the electrical system, or powered by leadacid batteries. Orion confirmed sign power source type and location during the inspection process. 7

10 Several lead-acid battery powered exit sign/emergency light units and single emergency light fixtures were also identified. The presences of potential radioactive sources were determined by interviews with building maintenance personnel. Suspect smoke detectors (Simplex Model ) were located on the lower and main levels. Orion accessed the interior of one detector, which was labeled as not having a radioactive source. 2.0 SUMMARY OF RESULTS A tabular summary of survey results are provided as an attachment to this report. The following information is included: Table 2 Hazardous Material Building Inspection Attachment Index Attachment B C D E F G H I J K L M N O Description Functional Space Inventory of All Affected Hazardous Building Materials Asbestos Inventory Hazardous Material Inventory Asbestos Bulk Sample Log. Summary table of suspect ACM sampled in accessible areas of functional spaces included in this inspection. The table identifies sample number, location, description, and analytical results. Lead Bulk Sample Log. Summary table of suspect lead-containing material samples, including sample number, location, description, and analytical results. Lead Drinking Water Sample Log. Summary table of lead drinking water samples, including sample number, location, description, and analytical results. Radon Sample Log. Summary table of radon samples, including sample number, location, description, and analytical results. Asbestos Bulk Sample Laboratory Reports Lead-Containing Material Bulk Sample Laboratory Reports Lead Drinking Water Sample Laboratory Reports Radon Sample Laboratory Report Polychlorinated Biphenyl Laboratory Report Laboratory Credentials Orion Consulting, LLC Survey Personnel Credentials 8

11 3.0 DISCUSSION OF RESULTS AND RECOMMENDATIONS 3.1 Asbestos-Containing Materials Suspect building components identified as ACM are summarized in Table 3, which identifies sample number and description. Attachment C provides a floor-by-floor summary of identified ACM, with quantities. Attachment B includes locations of identified ACM by functional space. For certain suspect building materials (i.e., floor tile mastic, window glazing and caulking) additional sample analysis was conducted by gravimetric reduction transmission electron microscopy. Test results are presented in Table 4. Table 3 Asbestos-Containing Material Bulk Sample Summary Sample Number NRCA-001 NRCA-009 NRCA-013 NRCA-014 NRCA-043 NRCA-045 NRCA-046 Material Description Lower Level, Building & Grounds Fire Door Core Lower Level, Mech., 6-inch Scrap Flange Gasket Lower Level, 119 Mechanical, Floor Tile Mastic Lower Level, 125, Floor Tile Mastic Upper Level, Skylight Panel Exterior, Window Glazing Exterior, Lower Level, Southeast Corner of Building, Masonry Caulk Sample Number NRCA-013 Table 4 Gravimetric Reduction Bulk Sample Summary For Select Asbestos-Containing Materials Material Description ACM Non-ACM Lower Level, 119 Mechanical, Floor Tile Mastic. PLM Results - Mastic 5% Chrysotile. Gravimetric Reduction Results Mastic 7.6%. NRCA-014 Lower Level, 125, Floor Tile Mastic. PLM Results - Mastic 5% Chrysotile. Gravimetric Reduction Results Mastic 2.4%. NRCA-045 Exterior, Window Glazing. PLM Results - Glazing 3% Chrysotile. Gravimetric Reduction Results Glazing 3.8%. NRCA-046 Exterior, Lower Level, Southeast Corner of Building, Masonry Caulk. PLM Results - Caulk 3% Chrysotile. Gravimetric Reduction Results Caulk 4.1%. 9

12 Based upon our findings, Orion recommends the following: Develop and implement an Asbestos Management Plan in accordance with EPA Asbestos Hazard Emergency Response Act (AHERA) requirements (40 CFR Part ). Specific program elements should consist of the following. General Information List of the names and addresses of the affected building. Whether the buildings contain friable ACBM, nonfriable ACBM, assumed friable ACBM or assumed nonfriable ACBM. Designated Person Information Name, address, and telephone number of the designated person. Course name, dates, and hours of training taken by the designated person. Inspector Information Date of inspection or reinspection. Name and signature of each accredited person making the inspection or reinspection. State and accreditation number of each accredited person making the inspection or reinspection (or copy of accreditation). Information on Sampling/Assumed ACBM Blueprint, diagram, or written description of each building that identifies clearly each location and approximate square or linear footage of homogeneous areas where material was sampled for ACBM. Exact location where each bulk sample was collected. Date of collection of each bulk sample. Homogeneous areas where friable suspected ACBM is assumed to be ACBM. Homogeneous areas where nonfriable suspected ACBM is assumed to be ACBM. Description of the manner used to determine sampling locations. Name and signature of each accredited inspector collecting samples. State of accreditation and accreditation number of each accredited inspector collecting samples (or copies of the accreditation certificates). Analysis of Samples Copy of the analyses of any bulk samples collected and analyzed. Name and address of any laboratory that analyzed bulk samples. Statement that any laboratory used meets the accreditation requirements of The West Virginia Asbestos Abatement Licensing Rule (64 CSR 63). State of West Virginia Laboratory License certificate. Dates of any analyses performed. Name and signature of the person performing each analysis. 10

13 Physical Assessment Information Description of the assessments, as described in of the AHERA Rule of all friable ACBM and suspected ACBM assumed to be ACM. Name and signature of each accredited person making the assessments. State of accreditation and accreditation number of each accredited person making the assessment (or copies of the accreditation certificates). Response Action Information Recommendations made to NRCTC by (an) accredited management planner(s) regarding response actions. Name and signature of each person making the recommendations. State of accreditation and accreditation number of each person making the recommendations (or copies of the accreditation certificates). Detailed description of preventive measures and response actions to be taken, including methods to be used, for any friable ACBM. Locations where such measures and actions will be taken. Reasons for selecting the response action or preventive measure. Schedule for beginning and completing each preventive measure and response action. Information on ACBM Remaining after Response Actions A blueprint, diagram, or written description of any ACBM or suspected ACBM assumed to be ACBM that remains in the building once response actions are undertaken. This should be updated as soon as response actions are completed. Information on Future Activities A plan for reinspection, as described in of the AHERA Rule. A plan for operations and maintenance (O&M) activities, as described in of the AHERA Rule. A plan for periodic surveillance, as described in of the AHERA Rule. Description of the management planner recommendations regarding additional cleaning, as described in (c)(2) of the AHERA Rule as part of an O&M program. The response of NRCTC to any recommendation for additional cleaning. Information on Required Notifications Copies of the notifications and description of steps taken to inform workers and building occupants (and their guardians) about inspections, reinspections, response actions, and post-response actions, including periodic surveillance, and the location and availability of the management plan on an annual basis. Periodic Surveillance Inspection Reports Cost Estimates Evaluation of the resources needed to complete response actions and carry out reinspection, O&M activities, periodic surveillance and training. Consultant Information Name of each consultant who contributed to the management plan and accreditation certificates. 11

14 Optional Information NRCTC may require each management plan to contain a statement signed by an accredited management plan developer that such person has prepared or assisted in the preparation of such plan, or has reviewed such plan, and that such plan is in compliance with AHERA. The statement should not be signed by a person who, in addition to preparing or assisting in preparing the management plan, also implements (or will implement) the management plan. Ensure that all in-house employee asbestos activities are conducted in accordance with EPA s Worker Protection Rule (40 CFR Part 763). Please note that this rule contains the same provisions as OSHA s Construction Standard for Asbestos (29 CFR ). Develop and implement a labeling system for identified and suspect ACM in all mechanical rooms. 3.2 Lead-Containing Materials Suspect building components identified as lead-containing material are summarized in Table 5, which identifies sample, location, and description. Attachment B includes locations of identified lead-containing material by functional space. Table 5 Lead-Containing Material Bulk Sample Summary Sample Number NRCLP-001 NRCLP-002 NRCLP-007 NRCLP-012 NRCLP-020 Material Description Lower Level, Fire Door Building & Grounds Shop (Beige) Lower Level, Mechanical Metal Support Post (Red) Lower Level, Interior Fire Door at Stairwell Lower Level, 105, Wall (Flat White) Main Level, 234-A Wall (Yellow) Based upon inspection results, Orion recommends the following: Consider adopting provisions of OSHA s Interim Standard for Lead in Construction (29 CFR ) for employee maintenance or renovation activities which may impact leadcontaining materials. Develop and implement a Lead-Containing Material Management Program, consisting of the following provisions. Policy statement Glossary of Terms Applicable Regulations Duties and Responsibilities Assessment of Conditions 12

15 Monitoring, Testing, and Analysis Exposure Monitoring Training Medical Surveillance Personal Hygiene Practices Respiratory Protection Occupant Safety Signage and Labeling Work Practices Operations and Maintenance Large Scale Interior and Exterior Maintenance Contract Work Recordkeeping Waste Disposal Notifications Program Evaluation Appendices Regulations Deminimus Activities Non-Assessed Tasks Work Practices Characterization of the anticipated renovation waste stream indicated that lead content is less than the EPA's Resource Conversation and Recovery Act (RCRA) limit of 5 parts per million (ppm). As such, construction debris may be disposed of in a permitted C&D landfill. Table 6 Renovation Debris Waste Characterization Sample Results Sample Number Description Results (ppm) NRCWC-001 Lead-containing renovation/construction debris ND ND: None Detected 3.3 Lead Drinking Water Testing The following sample results contained in Table 7 indicate that lead water concentrations were less than the EPA recommended Action Level of 15 parts per billion (ppb). 13

16 Table 7 Lead Drinking Water Sample Results Fountain/Tap Description/Location Sample Number Results (ppb) Lower Level, Concession Stand Sink NRCLW-001 < 5.0 Lower Level, Water Fountain, South Wing NRCLW-002 < 5.0 Main Level, Water Fountain, South Wing NRCLW-003 < 5.0 Main Level, 217 Sink NRCLW-004 < Radon Testing Radon testing results indicate that airborne concentrations are between 40 and 47 picocuries per liter (pci/l). Orion recommends that WVHEPC conduct confirmation testing, as per EPA guidelines (EPA "A Citizen's Guide to Radon [402-K , January 2009]) in order to validate radon levels. Sample Number Table 8 Radon Sample Results Description Results (pci/l) AE Lower Level, Mechanical Adjacent South Boiler AE Lower Level, Middle of 116A AE Lower Level, Middle of Polychlorinated Biphenyls (PCB's) Exterior pole mounted electrical transformers servicing the building are assumed to be non-pcb containing, according to NRCTC facility supervision. Sample results (see Table 9) for suspect window glazing and putty, and masonry caulking indicate concentrations below the laboratory limit of quantification. 14

17 Table 9 Polychlorinated Biphenyl Sample Results Sample Number NRCPCB-001 NRCPCB-002 NRCPCB-003 NRCPCB-004 Description Building Exterior, Lower Level, Window Glazing Aroclor-1016 Aroclor-1221 Aroclor-1232 Aroclor-1242 Aroclor-1248 Aroclor-1254 Aroclor-1260 Aroclor-1268 Aroclor-1262 Building Exterior, Lower Level, Window Glazing Aroclor-1016 Aroclor-1221 Aroclor-1232 Aroclor-1242 Aroclor-1248 Aroclor-1254 Aroclor-1260 Aroclor-1268 Aroclor-1262 Building Exterior, Lower Level, Window Putty Aroclor-1016 Aroclor-1221 Aroclor-1232 Aroclor-1242 Aroclor-1248 Aroclor-1254 Aroclor-1260 Aroclor-1268 Aroclor-1262 Building Exterior, Lower Level, Southeast Corner, Masonry Caulk Aroclor-1016 Aroclor-1221 Aroclor-1232 Aroclor-1242 Aroclor-1248 Aroclor-1254 Aroclor-1260 Aroclor-1268 Aroclor-1262 > QL ug/kg < QL ug/kg 15

18 3.6 Mercury-Containing Fluorescent and High Intensity Discharge Lamps, HVAC Thermostats, and Lead-Acid Batteries For components identified in Attachment B, Orion recommends the development and implementation of a Management Program containing the following elements. Facility Assessment and Documentation State and Federal Requirements for Managing Fluorescent Lamps, and Lead-Acid Batteries. Recycler and Disposal Site Selection Used Lamp and Battery Management Handling and Storage Broken Lamp Response Transport/Shipping of Components to Recycler or Disposal Site as per EPA Requirements Employee Education Recordkeeping Program Budget Planning Orion also assessed the interior of a floor drain, located in the western portion of the Lower Level Mechanical, to determine if mercury may have migrated into the drain from a recent spill in the area. Orion observed mercury residue in the top section of the drain (underneath the cover) and in the trap. Orion recommends that the WVHEPC retain an environmental remediation contractor to remove and dispose of this material. 4.0 LIMITATIONS AND CONSIDERATIONS Although a detailed and conscientious effort was put forth to conduct an accurate survey, certain variables may effect inspection findings to a degree. The following items should be considered when reviewing this document: Survey evaluations and sampling were conducted in exposed and/or accessible areas only. Unidentified suspect hazardous building materials may be present behind walls or in mechanical chases. Physical disruption of sampled suspect materials was limited, where possible, to previously damaged material. Estimated quantities of hazardous building materials are for information purposes only and are based on the best information available at the time of the site inspection. Users of this information shall satisfy themselves as to the actual quantities. 16

19 ATTACHMENTS 17

20 ATTACHMENT A HAZARDOUS MATERIALS BUILDING INSPECTION TASK OUTLINE 18

21 ASBESTOS INSPECTION Prior to initiating assessment activities, the inspection team will attend a site-specific safety orientation. Review relevant West Virginia Higher Education Policy Commission (WVHEPC) and NRCTC records, including previous asbestos inspection reports and other pertinent historical data, to identify materials confirmed or presumed to be asbestos-containing material (ACM/PACM) or asbestos-free material. Obtain copies of available building drawings, plot plans, piping and instrument diagrams (P&ID s), and mechanical plans. Document material identified by WVHEPC/NRCTC as asbestos-containing and asbestosfree materials. Note: Orion recommends that in situations where historical documentation or knowledge is in doubt, WVHEPC/NRCTC treat suspect ACM as presumed asbestos-containing material (PACM), or as an alternative, demonstrate that PACM does not contain asbestos by sampling, as per OSHA s General Industry requirements (29 CFR (j)). Conduct an on-site survey to confirm the location and quantities of previously identified ACM/PACM. For presumed or previously unidentified suspect exposed/accessible ACM, Orion personnel will: Identify homogenous sampling areas for all suspect/presumed materials to be sampled; Collect samples in accordance with EPA s AHERA sampling protocol, as referenced in section (j) of the OSHA General Industry Standard. Access for sampling suspect/presumed materials in elevated locations will be limited to areas which can be reached by a standard step or extension ladder; Destructive sampling will be limited, where practical, to previously damaged suspect materials, or inconspicuous places. Note: Orion recommends that for previously confirmed non-acm, a review of historical documentation be conducted in order to verify that a sufficient number of samples were collected, as per OSHA requirements. Additional samples will be collected in accordance with the referenced sampling protocol, as required. Identify (by unique identification numbers) all sampled suspect/presumed materials, and log location in the appropriate functional area of the facility floor plan; and, Patch damaged material, as needed. A summary of the AHERA sampling protocol is presented in the following table. 19

22 Activity Surfacing Material Thermal System Insulation Miscellaneous Material Friable Friable/ Non-friable Friable Nonfriable Nonfriable Inspection and Documentation Yes Yes Yes Yes Yes Sampling Between 3 and 7 random samples As determine d by the accredited inspector At least 3 random samples of most TSI 1 sample of patched TSI if it is < 6 linear or square feet As determined by an accredited inspector As determined by an accredited inspector for mudded joints or fittings Estimate quantities of suspect/presumed ACM. Verify quantities of previously identified ACM/PACM; Provide bulk sample analysis through Orion s NVLAP-accredited contract laboratory. A positive stop will be instituted for homogenous materials identified as asbestos containing, which are collected from within a specific functional space; Orion will also conduct the following quality assurance measures in order to verify field data during the course of this project: Conduct random reinspections and assessments for 10% of the areas surveyed; and, Review inspection records and drawings on a frequent basis throughout the course of the inspection phase, and the preparation of the draft and final reports. Prepare and submit the final report, detailing inspection and findings, including the following: A narrative description of the purpose of the survey and methodology; A spreadsheet detailing survey results, including: 20

23 - Sample number, component description, and location; - Analytical results (ACM or non-acm); - Estimated quantities of identified ACM; and, - Estimated abatement costs Drawings of the building structure and floor plan, based upon WVHEPC/ NRCTC provided drawings (where available) or Orion generated CAD drawings, indicating the location where each sample was obtained. The drawing will indicate the approximate building and floor dimensions; Analytical results detailing the type and percentage of asbestos present; Survey personnel and laboratory credentials; and Documentation of Certified Industrial Hygienist (CIH) review. LEAD BASED PAINT INSPECTION Review of historical WVHEPC/NRCTC records to identify building components confirmed or presumed to be Lead-Based Paint (LBP). Identify confirmed and presumed LBP components. Conduct an on-site survey to confirm the location of previously identified LBP. For presumed or suspect exposed/accessible LBP on facility components, Orion will collect paint chip samples. Testing will be conducted in accordance with U. S. Housing and Urban Development (HUD) Guidelines. Destructive sampling will be limited, where practical, to previously damaged materials, or inconspicuous places. suspect Provide paint chip sample analysis through Orion s AIHA/ELLAP-accredited contract laboratory. Prepare and submit the final report, detailing inspection and findings, including the following: A narrative description of the purpose of the survey and methodology; A spreadsheet detailing survey results, including: - Sample number, component description, and location; - Analytical results (LBP or non-lbp); 21

24 Drawings of the building structure and floor plan, based upon WVHEPC/NRCTC provided drawings (where available) or Orion generated CAD drawings, indicating the location where each sample was obtained. Paint chip analytical results detailing the percentage of lead present; Survey personnel and laboratory credentials; and Documentation of Certified Industrial Hygienist (CIH) review. RADON EVALUATION Review historical WVHEPC/NRCTC documentation, including previous radon testing records. Consult Federal, State, and local resources to identify relative background levels of radon for comparison to previous test results. Develop and implement a radon assessment strategy order to accurately characterize current conditions, as required. Prepare and submit the final report, detailing inspection and findings and recommendations for corrective action, as required. ADDITIONAL HARZARDOUS MATERIALS INSPECTION Evaluate the following building components for the presence of the referenced materials: 22

25 Material Mercury Polychlorinated Biphenyls (PCB s) Lead Nickel-Cadmium Tritium Component Fluorescent Lamps, Thermostats, Mercury Vapor Lamps, Metal Halide Lamps, High Pressure Vapor Sodium Lamps, Mercury Gages, Light Switches, Mercury Float Control Switches, Flow Meters with Mercury Switches, Flame Sensors, Fire Alarms, Safety Valves Fluorescent and HID Lighting Ballasts, Capacitors, Transformers, Rectifiers, Elevator Hydraulic Fluid, Window/Door Glazing and Caulking Domestic Plumbing Systems, Roof Flashing, Emergency Lighting and Exit Sign Batteries Emergency Lighting and Exit Sign Batteries Exit Signs For mercury, lead, nickel-cadmium, and tritium-containing materials, Orion will review relevant building records, including construction, renovation, and maintenance documents, and interview WVHEPC/NRCTC personnel in order to determine locations of confirmed and suspect materials. Orion will generate an inventory list containing amounts and locations of the referenced materials. For polychlorinated biphenyl (PCB)-containing lighting components and elevator hydraulic fluids, identify items manufactured prior to Review documents and conduct personal interviews as referenced above. For polychlorinated biphenyl (PCB)-containing transformers, capacitors, and rectifiers, review WVHEPC/NRCTC EPA registration documentation and other relevant building records and interview knowledgeable WVHEPC/NRCTC personnel. Orion will generate an inventory list containing amounts and locations of the referenced materials. For polychlorinated biphenyl (PCB)-containing caulking material, Orion will review documents and conduct personal interviews as referenced above. For suspect materials, Orion will collect representative bulk samples and sample analysis through Orion s AIHA-accredited contract laboratory. Prepare and submit the final report, detailing inspection and findings and recommendations for corrective action, as required. 23

26 ATTACHMENT B FUNCTIONAL SPACE INVENTORY OF ALL AFFECTED HAZARDOUS BUILDING MATERIALS 24

27 Functional Space Inventory LOWER LEVEL - SOUTH WING & POOL STORAGE Affected Materials Building & Grounds Shop Main Mechanical Pool Stor. Toilet Storage Maint. Office Men's RR Women's RR Maint. Corridor 117 SE Stairwell Asbestos Fire Door Core Scrap Piping Flange Gasket Floor Tile Mastic Transite Skylight Panel Window Glazing Masonry Caulking Suspected Asbestos Boiler and Pool Piping Flange Gaskets Internal Boiler Components Lead-Containing Material Structural Steel & Supports 1 Sprinkler System Piping 2 Boiler System Piping 2 Electrical Panel 2 Radiator Cover 2 Fire Door Paint (Beige) Flat White Paint Wall Paint (Yellow) Exit Sign/Emergency Lighting Lead-Acid Battery Emergency Lighting Lead-Acid Battery Fire Alarm Panel Lead- Acid Battery Mercury- Containing Components Fluorescent Lamps HVAC Thermostats Concession Stand Mech. 25

28 Affected Materials Functional Space Inventory LOWER LEVEL - WEST & NORTH HALLWAY OFFICES 125 North Foyer Asbestos Fire Door Core Flange Gasket Floor Tile Mastic Transite Skylight Panel Window Glazing Masonry Caulking Suspected Asbestos Boiler Pipe Flange Gaskets Internal Boiler Parts Lead-Containing Material Structural Steel & Supports 1 Sprinkler System Piping 2 Boiler System Piping 2 Radiator Cover 2 Fire Door Paint (Beige) Flat White Paint 3 3 Wall Paint (Yellow) Exit Sign/Emergency Lighting Lead-Acid Battery Emergency Lighting Lead-Acid Battery Fire Alarm Panel Lead - Acid Battery Mercury- Containing Components Fluorescent Lamps HVAC Thermostats

29 Functional Space Inventory LOWER LEVEL - EAST HALLWAY OFFICES Affected Materials A 109 Lower Level Corridor Asbestos Fire Door Core Flange Gasket Floor Tile Mastic Transite Skylight Panel Window Glazing Masonry Caulking Suspected Asbestos Boiler Pipe Flange Gaskets Internal Boiler Parts Lead-Containing Material Structural Steel & Supports 1 Sprinkler System Piping 2 Boiler System Piping 2 Radiator Cover 2 Electrical Panel 2 Fire Extinguisher Cabinet 2 Fire Door Paint (Beige) Flat White Paint Wall Paint (Yellow) Exit Sign/Emergency Lighting Lead-Acid Battery Emergency Lighting Lead-Acid Battery Fire Alarm Panel Lead -Acid Battery Mercury- Containing Components Fluorescent Lamps HVAC Thermostats 27

30 Affected Materials Asbestos Fire Door Core Flange Gasket Floor Tile Mastic Transite Skylight Panel Window Glazing Masonry Caulking Functional Space Inventory LOWER LEVEL - CORE OFFICES 110 Suspected Asbestos Boiler Pipe Flange Gaskets Internal Boiler Parts Lead-Containing Material Structural Steel & Supports 1 Sprinkler System Piping 2 Boiler System Piping 2 Fire Door Paint (Beige) Flat White Paint Wall Paint (Yellow) Exit Sign/Emergency Lighting Lead-Acid Battery Emergency Lighting Lead-Acid Battery Fire Alarm Panel Lead - Acid Battery Mercury- Containing Components Fluorescent Lamps HVAC Thermostats A

31 Affected Materials Men's Toilet Functional Space Inventory MAIN LEVEL - SOUTH WING & POOL Women's Toilet Main Corridor Asbestos Fire Door Core Flange Gasket Floor Tile Mastic Transite Skylight Panels Window Glazing Masonry Caulking Suspected Asbestos Boiler Pipe Flange Gaskets Internal Boiler Parts Lead-Containing Material Structural Steel & Supports 1 Sprinkler System Piping 2 Boiler System Piping 2 Radiator Cover 2 Fire Extinguisher Cabinet 2 Electrical Panel 2 Air Handing Units 2 Fire Door Paint (Beige) Flat White Paint 1 Wall Paint (Yellow) Exit Sign/Emergency Lighting Lead-Acid Battery Emergency Lighting Lead-Acid Battery Mercury- Containing Components Fluorescent Lamps High Intensity Discharge Lamps HVAC Thermostats 234-A Pool 29

32 Affected Materials Electrical Functional Space Inventory MAIN LEVEL - WEST & NORTH HALLWAY OFFICES 208 Asbestos Fire Door Core Flange Gasket Floor Tile Mastic Transite Skylight Panel Window Glazing Masonry Caulking Suspected Asbestos Boiler Pipe Flange Gaskets Internal Boiler Parts Lead-Containing Material Structural Steel & Supports 1 Sprinkler System Piping 2 Boiler System Piping 2 Radiator Cover 2 Fire Extinguisher Cabinet 2 Fire Door Paint (Beige) Flat White Paint Wall Paint (Yellow) Exit Sign/Emergency Lighting Lead-Acid Battery Emergency Lighting Lead-Acid Battery Mercury- Containing Components Fluorescent Lamps High Intensity Discharge Lamps HVAC Thermostats Main Lobby

33 Affected Materials A 223 Functional Space Inventory MAIN LEVEL - EAST HALLWAY OFFICES Corridor Asbestos Fire Door Core Flange Gasket Floor Tile Mastic Transite Skylight Panel Window Glazing Masonry Caulking Suspected Asbestos Boiler Pipe Flange Gaskets Internal Boiler Parts Lead-Containing Material Structural Steel & Supports 1 Sprinkler System Piping 2 Boiler System Piping 2 Fire Door Paint (Beige) Flat White Paint 5 Wall Paint (Yellow) Exit Sign/Emergency Lighting Lead-Acid Battery Emergency Lighting Lead-Acid Battery Mercury- Containing Components Fluorescent Lamps High Intensity Discharge Lamps HVAC Thermostats 31

34 Affected Materials Functional Space Inventory MAIN LEVEL - CORE OFFICES Asbestos Fire Door Core Flange Gasket Floor Tile Mastic Transite Skylight Panel Window Glazing Masonry Caulking Suspected Asbestos Boiler Pipe Flange Gaskets Internal Boiler Parts Lead-Containing Material Structural Steel & Supports 1 Sprinkler System Piping 2 Boiler System Piping 2 Fire Door Paint (Beige) Flat White Paint Wall Paint (Yellow) Exit Sign/Emergency Lighting Lead-Acid Battery Emergency Lighting Lead-Acid Battery Mercury- Containing Components Fluorescent Lamps High Intensity Discharge Lamps HVAC Thermostats

35 Functional Space Inventory UPPER LEVEL Affected Materials Storage Office Area Asbestos Transite Skylight Panels Lead-Containing Material Structural Steel & Supports 1 Sprinkler System Piping 2 Boiler System Piping 2 Air Handing Units 2 Fire Door Paint (Beige) Wall Paint (Flat White) Wall Paint (Yellow) Emergency Lighting Lead-Acid Battery Mercury- Containing Components Fluorescent Lamps HVAC Thermostats 33

36 Functional Space Inventory STAIRWELLS Affected Materials Asbestos SE Stairwell SW Main to Upper Level NE Main to Upper Level Lead-Containing Material Structural Steel & Supports 1 Sprinkler System Piping 2 Boiler System Piping 2 Air Handler Fire Door Paint (Beige) Stairway Stringer, Risers, Pan Paint (Cream) Wall Paint (Flat White) Wall Paint (Yellow) Emergency Lighting Lead-Acid Battery Mercury- Containing Components Fluorescent Lamps 34

37 Functional Space Inventory BUILDING ETERIOR Affected Materials Main Roof East Canopy's Main Lobby Entrance Windows Exterior Brick Asbestos Window Glazing Window Caulking Masonry Caulking Lead-Containing Material Ramp Railing Exit Sign/Emergency Lighting Batteries Mercury- Containing Components Fluorescent Lamps 35

38 Functional Space Inventory Footnotes: 1 Structural steel is located through-out this area. 2 Boiler and sprinkler system piping, radiator covers, fire extinguisher cabinets, electrical panels, and air handler units are assumed to contain lead-based paint. Flat white paint conditions: 1). Walls 2). Door Frames and Baseboards 3). Walls, Door Frames and Baseboards 4). Baseboards 5). Walls and Baseboards 36

39 ATTACHMENT C ASBESTOS INVENTORY 37

40 LOWER LEVEL ASBESTOS CONTAINING MATERIALS Material Description Unit Quantity Comments Piping Flange and Valve Gaskets Multiple size diameter piping components (4 to 8-inch) stored in northwest corner of area EA Spools 14 Elbows 16 Tee s 6 Valves 7 Building and Grounds Floor Tile Mastic Black SF Mechanical in s 119, 125 Fire Doors Beige SF doors in Mechanical and Corridor, Maintenance Office, SE Stairwell, North, and NE Exits LOWER LEVEL SUSPECT ASBESTOS CONTAINING MATERIALS Material Description Comments Piping Flange Gaskets #1 and #2 Boiler Internal Components Boiler Distribution Piping Flange and Valve Gaskets Pool Water Piping in valve pits and distribution piping Pool Storage Building and Grounds. Internal components not accessible. Building and Grounds 38

41 MAIN LEVEL ASBESTOS CONTAINING MATERIALS Material Description Unit Quantity Comments Transite Panels Skylight Panels SF skylights in South Wing Main Corridor SF skylights in Pool Area Fire Doors Beige SF doors in South Corridor and Lobby 39

42 UPPER LEVEL ASBESTOS CONTAINING MATERIALS Material Description Unit Quantity Comments Transite Panels Skylight Panels SF skylights in Storage Area 40

43 BUILDING ETERIOR ASBESTOS CONTAINING MATERIALS Material Description Unit Quantity Comments Glazing Windows LF 4,308 Aluminum window units Caulk Windows and Louver Frames LF 1,248 Aluminum window units and Louver frame adjacent to Mechanical Entrance Caulk Masonry LF 24 Exterior brick SE side of building 41

44 ATTACHMENT D HAZARDOUS MATERIAL INVENTORY 42

45 LOWER LEVEL & SOUTH EAST STAIRWELL HAZARDOUS BULDING MATERIALS Material Description Quantity Comments Mercury- Fluorescent Lamps 346 Containing Components HVAC Thermostats 4 Lead-Acid Batteries Exit Sign/ Emergency Lights Emergency Lights 5 Fire Alarm Panel

46 MAIN LEVEL HAZARDOUS BULDING MATERIALS Material Description Quantity Comments Mercury- Containing Components Lead-Acid Batteries Fluorescent Lamps 420 High Intensity Discharge Lamps HVAC Thermostats 3 Exit Sign/ Emergency Lights Emergency Lights

47 UPPER LEVEL HAZARDOUS BULDING MATERIALS Material Description Quantity Comments Mercury- Fluorescent Lamps 30 Containing Components HVAC Thermostat 1 45

48 ATTACHMENT E ASBESTOS BULK SAMPLE LOG 46

49 New River Community & Technical College Arts & Science Center Asbestos Bulk Sample Results DATE SAMPLE # Description Positive Negative 12/27/11 NRCA-001 Lower Level, Building & Grounds Fire Door Core 12/27/11 NRCA-002 Lower Level, Mech., Water Line TSI Canvas Cover at Gas Line Riser 12/27/11 NRCA-003 Lower Level, Mech., Water Line TSI Fitting at Storage 12/27/11 NRCA-004 Lower Level, Mech., Water Line TSI Canvas Cover at Storage 12/27/11 NRCA-005 Lower Level, Mech., Water Line TSI Canvas Cover, Middle of 12/27/11 NRCA-006 Lower Level, Mech., Water Line TSI Fitting, Middle of 12/27/11 NRCA-007 Lower Level, Mech., Water Line TSI Fitting at Building & Grounds Door 12/27/11 NRCA-008 Lower Level, Mech. Rest, Beige VCT/Mastic 12/27/11 NRCA-009 Lower Level, Mech., 6-inch Scrap Flange Gasket 12/27/11 NRCA-010 Lower Level, Mech. Corridor 2 2 Ceiling Tile 12/27/11 NRCA-011 Lower Level, Maintenance Office, VCT 12/27/11 NRCA-012 Lower Level, South Wing, Corridor Carpet Mastic 12/27/11 NRCA-013 Lower Level, 119 Mechanical, Floor Tile Mastic 12/27/11 NRCA-014 Lower Level, 125, Floor Tile Mastic 12/27/11 NRCA-015 Lower Level, 119, Carpet Mastic 12/27/11 NRCA-016 Lower Level, 102, Carpet Mastic 12/27/11 NRCA-017 Exterior, Lower Level Window Glazing 12/27/11 NRCA-018 Exterior, Lower Level Window Putty 12/27/11 NRCA-019 Exterior, Main Roof Above South Wing, Tar Paper, Bottom Layer 12/27/11 NRCA-020 Exterior, Main Roof Above South Wing, Tar Paper, Top Layer 12/27/11 NRCA-021 Main Level, South Wing, Men's Rest, Beige VCT 12/27/11 NRCA-022 Main Level, South Wing, Men's Rest, Beige VCT Mastic 12/27/11 NRCA-023 Main Level, South Wing, 234, Carpet Mastic 12/27/11 NRCA-024 Main Level, South Wing, 236, Carpet Mastic 12/27/11 NRCA-025 Main Level, South Wing, 233, Carpet Mastic 12/27/11 NRCA-026 Main Level, South Wing, Men's Rest, 1 1 Ceiling Tile 12/27/11 NRCA-027 Main Level, South Wing, 234, 2 2 Ceiling Tile 12/27/11 NRCA-028 Main Level, South Wing, Main Corridor, 2 2 Ceiling Tile 12/27/11 NRCA-029 Main Level, 214, Carpet Mastic 12/27/11 NRCA-030 Main Level, 212, Carpet Mastic 12/27/11 NRCA-031 Main Level, 206, Carpet Mastic 12/27/11 NRCA-032 Main Level, 234-A, Ceiling Joint Compound 12/27/11 NRCA-033 Main Level, 234-A, Ceiling Joint Compound 12/27/11 NRCA-034 Main Level, 234-A, Ceiling Joint Compound 12/27/11 NRCA-035 Main Level, West Corridor Adjacent 212, Drywall Tape 12/27/11 NRCA-036 Main Level, West Corridor Adjacent 212, Drywall Tape 12/27/11 NRCA-037 Main Level, West Corridor Adjacent 207, Drywall 12/27/11 NRCA-038 Main Level, West Corridor, Adjacent 216, Drywall 12/27/11 NRCA-039 Lower Level, East Corridor Adjacent 116, Drywall 47

50 New River Community & Technical College Arts & Science Center Asbestos Bulk Sample Results DATE SAMPLE # Description Positive Negative 12/27/11 NRCA-040 Lower Level, East Corridor Adjacent 114, Drywall 12/27/11 NRCA-041 Lower Level, East Corridor Adjacent 106, Drywall 12/27/11 NRCA-042 Upper Level, HVAC Vibration Damper 12/27/11 NRCA-043 Upper Level, Skylight Panel 12/27/11 NRCA-044 Upper Level, Office Ceiling Tile 12/27/11 NRCA-045 Exterior, Window Glazing 12/27/11 NRCA-046 Exterior, Lower Level, Southeast Corner of Building, Masonry Caulk 48

51 ATTACHMENT F LEAD BULK SAMPLE LOG 49

52 New River Community & Technical College Arts & Science Center Lead-Based Paint Bulk Sample Results DATE SAMPLE # Description Positive Negative 12/29/11 NRCLP-001 Lower Level, Fire Door Building & Grounds Shop (Beige) 12/29/11 NRCLP-002 Lower Level, Mechanical Metal Support Post (Red) 12/29/11 NRCLP-003 Lower Level, Mechanical Masonry Wall (Cream) Resampled 1/6/12 (NRCLP-027) 12/29/11 NRCLP-004 Lower Level, Maintenance Office Wall (Green) 12/29/11 NRCLP-005 Lower Level, Maintenance Office Door Frame (Cream) 12/29/11 NRCLP-006 Lower Level, Men's Rest Metal Door 12/29/11 NRCLP-007 Lower Level, Interior Fire Door at Stairwell 12/29/11 NRCLP-008 Lower Level, Men's Rest 1" Ceramic Floor Tile 12/29/11 NRCLP-009 Lower Level, 119, Wall (Medium Blue) 12/29/11 NRCLP-010 Lower Level, 119, Door Frame (White Semi-Gloss) 12/29/11 NRCLP-011 Lower Level, 121, Wall (Sky Blue) 12/29/11 NRCLP-012 Lower Level, 105, Wall (Flat White) 12/29/11 NRCLP-013 Lower Level, 113, Wall (Light Purple) 12/29/11 NRCLP-014 Lower Level, 116A, Wall (Light Grey) 12/29/11 NRCLP-015 Main Level, 235, Floor (Grey) 12/29/11 NRCLP-016 Main Level, 233, Trim (Dark Grey) 12/29/11 NRCLP-017 Main Level, Pool Ceramic Tile 12/29/11 NRCLP-018 Main Level, Pool Wall Ceramic Tile 12/29/11 NRCLP-019 Main Level, South Wing, Main Corridor Ceramic Floor Tile 12/29/11 NRCLP-020 Main Level, 234-A Wall (Yellow) 12/29/11 NRCLP-021 Main Level, 201 Wall (Beige) 12/29/11 NRCLP-022 Main Level, 215 Wall (Light Beige) 12/29/11 NRCLP-023 Main Level, 223 Wall (Yellow) 12/29/11 NRCLP-024 Main Level, 224 (Pink) 12/29/11 NRCLP-025 Upper Level, Northeast Stairwell Tread (Grey) 12/29/11 NRCLP-026 Building Exterior, North Entrance, Handrail (Black) 1/6/11 NRCLP-027 Lower Level, Maintenance Office Door Frame (Cream) 50

53 ATTACHMENT G LEAD DRINKING WATER SAMPLE LOG 51

54 New River Community & Technical College Arts & Science Center Lead Water Sample Results DATE SAMPLE # Description > 5 ppb < 5 ppb 12/29/11 NRCLW-001 Lower Level, Concession Stand Sink 12/29/11 NRCLW-002 Lower Level, Water Fountain, South Wing 12/29/11 NRCLW-003 Main Level, Water Fountain, South Wing 12/29/11 NRCLW-004 Main Level, 217 Sink 52

55 ATTACHMENT H RADON SAMPLE LOG 53

56 New River Community & Technical College Arts & Science Center Radon Sample Results DATE SAMPLE # Description Results (pci/l) 12/28-30/11 AE Lower Level, Mechanical Adjacent South Boiler /28-30/11 AE Lower Level, Middle of 116A /28-30/11 AE Lower Level, Middle of

57 ATTACHMENT I ASBESTOS BULK SAMPLE LABORATORY REPORTS 55

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66 ATTACHMENT J LEAD-CONTAINING MATERIAL BULK SAMPLE LABORATORY REPORTS 64

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71 ATTACHMENT K RENOVATION/CONSTRUCTION DEBRIS WASTE CHARACTERIZATION LABORATORY REPORTS 69

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73 ATTACHMENT L LEAD-DRINKING WATER SAMPLE LABORATORY REPORTS 71

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75 ATTACHMENT M RADON SAMPLE LABORATORY REPORTS 73

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79 ATTACHMENT N POLYCHLORINATED BIPHENYL SAMPLE LABORATORY REPORTS 77

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84 ATTACHMENT O LABORATORY CREDENTIALS 82

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92 ATTACHMENT P ORION CONSULTING, LLC SURVEY PERSONNEL CREDENTIALS 90

93 91