Final Environmental Compliance Due Diligence Activities ...€¦ · EnvironmentalCompliance Due...

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FINAL Executive Summary Report Environmental Compliance Due Diligence Activities Report U.S. Coast Guard Housing Site 3022 Bernhardt Drive Port Arthur, Texas 77642 Contract No. GS-10F-0230J / GS-00P-14-CY-A-0003 / Order No. GS-P-00-16-CY-7127 Prepared For: United States General Services Administration Office of Real Property Utilization and Disposal 1800 F Street, NW Washington, DC 20405 Prepared By: Amec Foster Wheeler Environment & Infrastructure, Inc. 46850 Magellan Drive, Suite 190 Novi, Michigan 48377 April 2017 Amec Foster Wheeler Project No: 32106D009.0002 Date of Site reconnaissance: September 13, 2016 Erica Geasler-Bromley, P.E. Project Manager Lauren Bugdalski Geologist

Transcript of Final Environmental Compliance Due Diligence Activities ...€¦ · EnvironmentalCompliance Due...

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FINALExecutive Summary Report

Environmental Compliance Due Diligence Activities Report

U.S. Coast Guard Housing Site3022 Bernhardt Drive

Port Arthur, Texas 77642

Contract No. GS-10F-0230J / GS-00P-14-CY-A-0003 / Order No. GS-P-00-16-CY-7127

Prepared For:

United States General Services AdministrationOffice of Real Property Utilization and Disposal

1800 F Street, NWWashington, DC 20405

Prepared By:

Amec Foster Wheeler Environment & Infrastructure, Inc.46850 Magellan Drive, Suite 190

Novi, Michigan 48377

April 2017

Amec Foster Wheeler Project No: 32106D009.0002

Date of Site reconnaissance: September 13, 2016

Erica Geasler-Bromley, P.E.Project Manager

Lauren BugdalskiGeologist

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T AB L E O F C O N T E N T S

ACRONYM AND ABBREVIATION LIST......................................................................................II 1.0 INTRODUCTION..........................................................................................................1-1

1.1 SITE LOCATION AND DESCRIPTION.............................................................1-1

2.0 PHASE I ENVIRONMENTAL DUE DILIGENCE AUDIT OVERVIEW............................2-1

3.0 ACM SURVEY AND CONDITION/RISK ASSESSMENT REVIEW ...............................3-1

4.0 LEAD-BASED PAINT INSPECTION AND RISK ASSESSMENT OVERVIEW..............4-1

5.0 LEAD IN SOIL SAMPLING OVERVIEW .......................................................................5-1

6.0 MOLD SAMPLING OVERVIEW....................................................................................6-1

7.0 ENVIRONMENTAL INFORMATION AND NEPA DATA GATHERING OVERVIEW......7-1

8.0 CONCLUSIONS AND RECOMMENDATIONS.............................................................8-1 8.1 CONCLUSIONS................................................................................................8-1 8.2 RECOMMENDATIONS.....................................................................................8-2 8.3 LIMITATIONS ...................................................................................................8-3

9.0 REFERENCES.............................................................................................................9-1

T AB L E S

Table 1 Summary of Site Information

F I G U R E S

Figure 1 Site Location MapFigure 2 Site Layout Map

AP P E N D I C E S

Appendix A Phase I EDDA ReportAppendix B Asbestos Containing Material Survey ReportAppendix C Lead-Based Paint (LBP) Inspection and Risk Assessment ReportAppendix D Lead in Soil Sampling ReportAppendix E Mold Sampling ReportAppendix F Environmental Information and NEPA Data Gathering Report

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ACRONYM AND ABBREVIATION LIST

ACM Asbestos Containing MaterialAmec Foster Wheeler Amec Foster Wheeler Environment & Infrastructure, Inc.ASTM American Society for Testing and Materials

bgs below ground surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CEQ Council on Environmental QualityCFATF Civilian Federal Agency Task ForceCFR Code of Federal Regulations

EAL Environmental Action LevelEDDA Environmental Due Diligence AuditEO Executive OrderESA Endangered Species Act

FEMA Federal Emergency Management Agency

GSA General Services AdministrationGuidance Guide on Evaluating Environmental Liability for Property Transfers

HUD Housing and Urban Development

IPaC USFWS’ Information, Planning, and Conservation System

LBP lead-based paint

mg/kg milligram per kilogram

NEPA National Environmental Policy Act NHPA National Historic Preservation Act

OSHA Occupational Safety and Health Administration

PLM Polarized Light Microscopyppm parts per million

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REC Recognized Environmental ConditionRSL Reginal Screening Level

SFHA Special Flood Hazard AreaSHPD State Historic Preservation DivisionSIHP State Inventory of Historic PlacesSite 3022 Bernhardt Drive, Port Arthur, TexasSOW Scope of Work

TCEQ Texas Commission on Environmental QualityTNRIS Texas Natural Resources Information System TPWD Texas Department of Parks and Wildlife

U.S. United StatesUSC United States CodeUSCG United States Coast GuardUSEPA U.S. Environmental Protection AgencyUSFWS United States Fish and Wildlife Service

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1.0 INTRODUCTION

Amec Foster Wheeler Environment and Infrastructure, Inc. (Amec Foster Wheeler) was retained by the United States (U.S.) General Services Administration (GSA) to perform Environmental Compliance Due Diligence Activities in support of the United States Coast Guard (USCG) housing sales. The Environmental Compliance Due Diligence Activities included a Phase I Environmental Due Diligence Audit (EDDA), lead- based paint (LBP) survey, asbestos containing material (ACM) survey, lead in soil sampling, mold sampling, and sensitive environmental area review, including National Environmental Policy Act (NEPA) and National Historic Preservation Act (NHPA) data gathering. The Environmental Compliance Due Diligence Activities were conducted for the USCG Housing Site located at 3022 Bernhardt Drive, Port Arthur, Texas (Site) (Figure 1). Amec Foster Wheeler was authorized to conduct these activities under the U.S. GSA Contract Number GS-10F-0230J / GS-00P-14-CY-A-0003 and Award Number GS-P-00-16-CY-7127. Amec Foster Wheeler’s representatives Mr. Leonard Gilbert and Mr. Alan Luwe performed the site reconnaissance on September 13, 2016. Access to the Site was granted by Mr. Phillip Reaves,Chief Warrant Officer 3, USCG. It is Amec Foster Wheeler’s understanding that the USCG performed these environmental activities in preparation for divestiture of the property.

1.1 SITE LOCATION AND DESCRIPTION

The Site is located at 3022 Bernhardt Drive, Port Arthur, Jefferson County, Port Arthur, Texas (Figure 1). Figure 2 shows the site layout. The Site is located in a Residential Zoned Area. Table 1 below summarizes the site information. Copies of select site photographs are included in Attachment A.

Table 1: Summary of Site Information

Address Year BuiltUnit Size(square

feet)

Lot Size(acre)

Unit Description Occupied

3022 Bernhardt Drive

Approx. 1951

Approx. 1,200 0.21

Three-bedroom, 1.5-bathroom

houseNo

Amec Foster Wheeler conducted a site reconnaissance on September 13, 2016. The property located at 3022 Bernhardt Drive was observed to be a single-story, three-bedroom, 1.5-bath single family home constructed on a crawlspace and home on pilings foundation. The approximately 1,200 square foot house is constructed with wood framing, with an exterior consisting of vinyl and wood siding and a shingle roof. Flooring consists of hardwood, ceramic tile, carpet, and vinyl flooring. A concrete driveway was present, with a detached two-car garage. The housing unit was observed to be in poor condition, with structural damage to the back porch and roof. Mold was observed on the ceilings of bedrooms 1, 2 and 3, the bathroom, patio, and hallway. Municipal sewer connection is provided by the City of Port Arthur. Electricity and natural gas are available at the Site, but currently shut off. Minimal bare soil areas were observed under

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trees in the lot. This did not appear to be an environmental concern, rather, it appeared to be due to shade from the trees.

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2.0 PHASE I ENVIRONMENTAL DUE DILIGENCE AUDIT OVERVIEW

The Phase I EDDA was performed in general accordance with the Civilian Federal Agency Task Force (CFATF) Guide on Evaluating Environmental Liability for Property Transfers, dated August 1998 (Guidance), the American Society of Testing and Materials (ASTM) Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process E 1527-13was used as a reference for conducting the EDDA, and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as detailed in Section 120(h)(4)(A)(i) to (vii).

As specified under these standards, certain responsibilities lie with the “user” of the assessment.The “user” is defined as the party who intends to use the Guidance to perform an assessment.The “user” is generally the purchaser, owner, lender, property manager, or potential tenant, and, for the purposes of this project, is considered to be the U.S. GSA. Under the Guidance, it is the responsibility of the “user” to verify whether any environmental liens exist with regard to the property, and provide this information to the environmental professional preparing the assessment. Additionally, the “user” must make the professional aware of any specialized knowledge or experience that is material to identifying environmental liability concerns in connection with the property.

In conducting this assessment, Amec Foster Wheeler’s work was performed consistent with that level of care and skill ordinarily exercised by members of the profession currently practicing in the same locality under similar conditions. Information provided to Amec Foster Wheeler by client representatives and site contacts has been accepted in good faith and is assumed to be accurate unless written documentation or visual observations were contradictory. Amec Foster Wheeler’s findings are based on observations and data collected at one point in time. Assessment results are based upon conditions and operations at the time of the site reconnaissance. A change in any of these factors may alter the findings and conclusions expressed by Amec Foster Wheeler.

A Phase I EDDA, by nature, is limited in its ability to fully assess potential environmental liabilities or concerns associated with a property. Further investigation would be required to identify potential environmental liabilities that may be present at the Site, but were beyond detection by performance of the scope of the Phase I EDDA. State and Federal laws and regulations, if referenced in this report, are provided for informational purposes and should not be construed as legal opinion or recommendation.

This Phase I EDDA was completed under the direction of Amec Foster Wheeler’s client, the U.S. GSA, for use by the U.S. GSA and the USCG. By definition, a Phase I EDDA consists of a limited records search and site reconnaissance to identify potential environmental issues at the Site. To completely delineate any potential environmental issue at the Site, further work beyond the scope of a Phase I EDDA may be necessary. Use of this report by any parties other than Amec Foster Wheeler, the U.S. GSA, and USCG is expressly prohibited.

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Amec Foster Wheeler’s scope of services for the Phase I EDDA consisted of the following activities:

Review certain federal and state regulatory agency databases for the Site and properties within a 1/8 to one-mile radius around the Site;

Review and evaluate readily available historical records, including topographical maps, historical aerial photographs, and historical fire insurance maps;

Research information publicly available and reasonably ascertainable to determine site usage since first development, or 1940, whichever is earlier;

Contact various city and/or county agencies for environmental information pertaining tothe Site;

Conduct site reconnaissance to evaluate current site conditions and note visual evidence of recognized environmental conditions (RECs);

Conduct visual reconnaissance of properties within 1/2 mile of the Site;

Interview people with significant knowledge of the Site;

Review and detail the sources of information outlined in CERCLA 120(h)(4)(A)(i)-(vii);

Identify any RECs as defined by ASTM 1527-13 Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process; and,

Prepare this report summarizing Amec Foster Wheeler’s findings.

The complete Phase I EDDA report, tables, and figures are included in Appendix A.

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3.0 ACM SURVEY AND CONDITION/RISK ASSESSMENT REVIEW

Information provided by the USCG indicates that an asbestos survey has not been previously conducted at the Site. Amec Foster Wheeler performed an ACM survey to identify, based on visual inspection and industrial knowledge, and sample suspected ACM associated with building materials. It is important to note that this was a non-destructive survey, and inaccessible areas (e.g. within wall cavities, above drop-ceilings, beneath the top flooring layer, etc.) were not surveyed. This survey documents only general locations of suspect materials and does not determine the exact boundaries of ACM. ACM may be present on-site in locations beyond what is described here-in.

ACMs are fibrous hydrated silicates, and can be found in building materials as either “friable” or “non-friable” asbestos products. Friable asbestos refers to materials, which can be readily crumbled using hand pressure, separating asbestos fibers from the binding materials with which they are associated. Friable asbestos is commonly found in boiler and pipe insulation. Non-friable material refers to asbestos, which is associated with a binding agent (such as tar or cement), preventing ready release of airborne fibers, and are separated into two categories. Category I non-friable ACMs are asbestos-containing resilient floor coverings (like vinyl asbestos tile), asphalt roofing products, packing’s, and gaskets. These materials rarely become friable because the asbestos is locked securely into the material. All other non-friable ACMs are considered category II non-friable ACM. Category II non-friable ACMs are more likely to become friable because they are not as resistant to crushing or pulverizing.

The use of friable ACMs was discontinued in the United States in the late 1970s to early 1980s, although non-friable asbestos is still found in recent building materials such as ceiling tiles, floor tiles, asbestos cement, and in certain types of cementaceous pipe materials. Asbestos may become an issue during renovation, alteration, maintenance or demolition activities, or when ACMs are taken out-of-service. Materials identified as containing asbestos, and which are in poor condition, should immediately be managed either by proper encapsulation or removal.

In commercial buildings where a building owner has knowledge of the presence of ACM or an asbestos inspection has revealed/confirmed the presence of ACMs, the building owner is required to properly communicate the ACM hazard to all employees, workers, contractors, and occupants, and manage the ACM in accordance with 29 CFR 1926.1101 and the Asbestos Standard for the Construction Industry, Occupational Safety and Health Administration (OSHA) 3096. ACM is defined by OSHA as any material containing more than 1% asbestos. If analysis identifies a sampled material as containing an amount greater than 1% asbestos, this material is deemed a regulated asbestos containing material and must be handled and disposed of accordingly.

Amec Foster Wheeler completed an ACM survey at the Site. The ACM survey was conducted by Mr. Leonard Gilbert, a licensed asbestos inspector. Bulk samples collected during the site survey were analyzed by Polarized Light Microscopy (PLM) coupled with dispersion staining in accordance with U.S. Environmental Protection Agency (USEPA) Method 600/R-93/116. PLM is an analytical method for asbestos identification, which depends on the unique optical properties of mineral forms in the samples and specifically identified the various asbestos types.

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Twenty-two (22) samples of suspect ACM were obtained during this survey from the USCG SiteAnalytical results indicate that ACM was detected above 1% in some building materials sampled.ACM was detected in seven of the samples. The ACM was noted to be non-friable and located in the white drywall in the living room; tan drywall and joint compound in the hall; black tar paper and sealant in the attic; and tank sheet vinyl on the rear porch.

A destructive asbestos building survey and condition/risk assessment was not conducted. ACMs may be present in inaccessible areas such as wall cavities. Based on the intended use of the property, no further action related to ACM is necessary at this time. A copy of the full Asbestos Survey and Condition/Risk Assessment report is included in Appendix B.

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4.0 LEAD-BASED PAINT INSPECTION AND RISK ASSESSMENTOVERVIEW

Prior to the late 1970s many paints contained lead. When these paints become damaged, i.e., peeling or flaking, or the painted surface is renovated or demolished, lead can be released into the environment constituting an environmental and worker health hazard. Depending on the age of structures, LBP be either exposed or covered over with other paints or materials as a result of subsequent renovation. Flaking or peeling paint that could be lead-based should be removed or encapsulated appropriately.

Federal law, 20 CFR Part 35 and 40 CFR Part 745, requires sellers or lessors of residential units constructed prior to 1978, except housing for the elderly or persons with disabilities (unless any child who is less than six years of age resides or is expected to reside in such housing) or any zero-bedroom dwelling to disclose and provide a copy of a Lead Risk Assessment Report to new purchasers or lessees before they become obligated under a lease or sales contract. Property owners and sellers are also required to distribute an educational pamphlet approved by the USEPA and include standard warning language in sales contracts or in or attached to lease contracts to ensure that parents have the information they need to protect children from LBP hazards.

Information provided by the USCG indicates that a LBP inspection and risk assessment has not been previously conducted at the Site. Based on the age of the Site, it is possible that LBP was used for painting the interior and/or exterior of the structure. Therefore, Amec Foster Wheeler completed a LBP Inspection and Risk Assessment during the Environmental Compliance Due Diligence Activities. The objective of the LBP inspection was to determine where LBP exists on the property and the concentration on each painted surface.

Amec Foster Wheeler obtained 83 (including two calibration tests) test readings on interior and exterior coated surfaces. This testing was conducted on September 13, 2016, by Mr. Leonard Gilbert using Chapter 7 of HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (1997 revision), to document whether lead-based coatings were present.

Lead was detected above the USEPA/HUD definition of lead based paint (at or above 1.0 mg/cm2)at four of the 83 tested locations. The remaining tested component coatings were below theUSEPA/HUD definition of lead based paint or below the detection limit of the instrument. The painted surfaces appeared to be in good condition with no peeling or flaking. The risk assessment concluded that a LBP hazard is not present. The LBP Inspection and Risk Assessment report is included in Appendix C.

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5.0 LEAD IN SOIL SAMPLING OVERVIEW

Prior to the late 1970s many paints contained lead. When these paints become damaged, i.e., peeling or flaking, or the painted surface is renovated or demolished, lead can be released into the environment constituting an environmental and worker health hazard. Depending on the age of structures, LBP may exist, either exposed or covered over with other paints or materials as a result of subsequent renovation. Flaking or peeling paint that could be lead-based should be removed or encapsulated appropriately. Based on the age of the Site, it is possible that LBP was used for painting the interior and exterior walls of the structures.

In accordance with the Scope of Work (SOW), Amec Foster Wheeler collected two soil samples per exterior structure wall. Soil sample locations were within five feet (drip line) of each exterior wall. A total of eight soil samples were collected. At each location, samples were collected at the surface (zero inches below ground surface [bgs]) and six inches bgs. The samples were containerized and shipped under standard chain of custody procedures to CT Laboratories, Inc. located in Baraboo, Wisconsin for total lead analysis by USEPA SW-846 Method 6010C.

Following receipt of the analytical laboratory report, Amec Foster Wheeler compared the soil analytical results to the USEPA Residential Direct Contact Cleanup Level Criterion of 400 milligram per kilogram (mg/kg) (ppm), and the Texas Commission on Environmental Quality(TCEQ) Tier I Residential Protective Concentration Level (PCL) of 500 ppm. Soil analytical results indicate that lead was detected in concentrations ranging between 20.9 mg/kg and 157 mg/kg, which do not exceed the applicable USEPA or TCEQ residential criteria. The Lead in Soil sampling report is included in Appendix D.

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6.0 MOLD SAMPLING OVERVIEW

According to USEPA, molds are part of the natural environment, but mold growth should be avoided indoors. Molds have the potential to cause health problems and produce allergens, irritants, and in some cases potentially toxic substances. Inhaling or touching mold or mold spores may cause allergic reactions in sensitive individuals.

Direct microscopic examination tape lift samples were collected via an acid free bio tape in all suspect mold areas. Bio tape samples were shipped to Quantem Laboratories in Oklahoma City, Oklahoma.

There are no USEPA Residential Regional Screening Level (RSL) or TCEQ guidance for mold concentrations. Mold was detected in samples collected from the ceiling of bedroom #1 and bedroom #3.

The mold sampling report is included in Appendix E.

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7.0 ENVIRONMENTAL INFORMATION AND NEPA DATA GATHERINGOVERVIEW

Analysis of the potential effects of federal actions are required pursuant to the National Environmental Policy Act of 1969 (NEPA; 42 U.S. Code [USC] §4321 et seq.) and Council on Environmental Quality (CEQ) Regulations Implementing the Procedural Provisions of NEPA (40 Code of Federal Regulations [CFR] 1500-1508). During a NEPA analysis, all applicable federal, state, and local regulations and requirements are considered that could apply to the federal action. CEQ regulations encourage federal agencies to integrate all of the required environmental reviews into the environmental documents that are prepared pursuant to NEPA. Other environmental reviews may include statutory requirements set forth under the Endangered Species Act (ESA; 16 USC §1531 et seq.), National Historic Preservation Act (NHPA; 16 USC §470 et seq.), Executive Orders (EOs), or other federal, state, and local laws and regulations.

CEQ regulations further require intergovernmental notifications prior to making any detailed statement of environmental impacts, and EO 12372 (Intergovernmental Review of Federal Programs), requires federal agencies to cooperate with and consider state and local views and comments in implementing a federal proposal. Consideration of the views and information of all interested persons promotes open communication and enables better decision-making.

The U.S. Coast Guard (USCG) is proposing to sell one housing unit located on approximately 0.2 acres of land at 3022 Bernhardt Drive in Port Arthur, TX (Site). To support the development of the USCG’s NEPA analysis and to ensure compliance with other statutory requirements related to special status species and habitat, wetlands, floodplains, and historical and cultural resources on or in the vicinity of the Site, a desktop review of these resource areas was conducted for this action.

The following sections include a summary of applicable statutory requirements that pertain to special status species and habitat, wetlands, floodplains, and historical and cultural resources, and provides a description of the existing conditions within and in the vicinity of the Site in Port Arthur, TX. The summary is based on the review of available information from the USCG and other agencies as well as a site reconnaissance. No agency consultation under Section 7 of the ESA or Section 106 of the NHPA was conducted as part of the data gathering process. However, data was solicited from agencies as appropriate to gather the necessary environmental information.

Special Status Species and Habitat

There are 66 federally listed wildlife species and 30 federally listed plant species identified within the State of Texas. Of the 96 federally listed species of plants and wildlife known to occur within the State of Texas, based on habitat requirements, range, and geography the USFWS Information, Planning, and Conservation (IPaC) System (USFWS 2016b) identified four endangered wildlife species and three threatened wildlife species with the potential to occur within

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the Site. Of the seven federally listed species with potential to occur on the Site, five of these species, including the West Indian Manatee (Trichechus manatus) and four sea turtles require aquatic habitat such as gulf and bay systems or open marine coastal waters, which do not occur within or immediately adjacent to the Site. Consequently, these species would not occur on the Site. Additionally, the Site is located in a developed residential area and does not support coastal habitats or mud and salt flats necessary to support the Red Knot (Calidris canutus rufa) or Piping Plover (Charadrius melodus). Therefore, these species would not occur on the Site as residents and any potential occurrence of these federally listed bird species would likely be transitory.

The USFWS IPaC system also identified 37 migratory birds protected under the Migratory Bird Treaty Act that could potentially nest in the vegetation on or near the Site. A complete list of species obtained from USFWS IPaC System for initial scoping purposes is included in the Environmental Information and NEPA Data Gathering Report prepared by Amec Foster Wheeler dated April 2017.

The Texas Department of Parks and Wildlife (TPWD) and the Texas Natural Resources Information System (TNRIS) listed the following state-designated species in Jefferson County: five endangered, 23 threatened, and 17 species of special concern. However, based on the development of the Site and lack of native habitats as well as the surrounding residential uses it is unlikely that any state-designated wildlife or plant species would occur as within the Site. Amec Foster Wheeler did not identify any federal or state-designated threatened or endangered species during the site reconnaissance.

Wetlands

The Site is located within a developed area that is surrounded by residential uses and undeveloped land to the southwest. The nearest mapped wetlands are located approximately one mile from the Site and include lakes, freshwater emergent, freshwater forested/shrub, and riverine wetlands. Wetland areas were not observed on the Site during the site reconnaissance.

Floodplains

The Site is located within Flood Insurance Rate Map (FIRM) Panel 4854990035E (FEMA 1984). The Site, along with the immediately surrounding areas, is mapped as Zone B which is defined by FEMA as areas between the limits of the 100-year floodplain and the 500-year floodplain; or certain areas subject to 100-year flooding with average depths of less than one foot, or areas protected by levees from the base flood. The nearest mapped water feature is the Sabine-Neeches Canal, located approximately two miles southeast of the Site. In 1981, an improved levee system was built around Port Arthur with an elevated seawall drive along Sabine-Neeches Canal. No discrepancies were noted between the information from the desktop survey and the observations made during the site reconnaissance.

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Historic and Cultural Resources

A historic and cultural resources record search was conducted on November 1, 2016, and did not identify any archaeological resources at or within a one-mile radius of the Site. The record search indicated that the Site itself has not been previously surveyed for archaeological resources and that no previously recorded archaeological resources exist within the Site boundaries. Additionally, the record search indicated that two archaeological surveys have been conducted within a one-mile radius of the Site, and it appears as though no archaeological resource were documented during these surveys. However, two historic cemeteries are indicated within a mile radius of the Site, one of which includes a grave site which has been memorialized by the State of Texas with a Historical Marker.

No architectural resources are located within the Site itself. However, two historic structures are indicated within a one-mile radius of the Site. The structures include the Hughen School building (Atlas Number 5507016300), located approximately 0.96 miles to the southwest of the Site. No further information, with the exception of locational data and the identification number, is available for the Hughen School building. A second structure, located 0.39 miles to the southwest of the Site, is the childhood home of American singer Janis Lyn Joplin. A Port Arthur native, Janis Joplin is noted for her contribution to the musical styles of Port Arthur and Austin, Texas, as well as for her role in bringing the music styles of east Texas to national and international audiences.

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8.0 CONCLUSIONS AND RECOMMENDATIONS

Amec Foster Wheeler performed this Phase I EDDA in conformance with the scope and limitations of the Guidance for the USCG Housing Site located at 3022 Bernhardt Drive, Port Arthur, Jefferson County, Texas (Site). This Environmental Compliance Due Diligence Activities Report revealed the following findings related to potential contamination or other environmental/historic considerations in connection to the Site.

8.1 CONCLUSIONS

No RECs, as defined by ASTM Standard Practice E 1527-13, were identified in connection with the Site. RECs are “the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment. De minimus conditions are not recognized environmental conditions.”

Sampling of select building materials for asbestos was completed at the Site. Twenty-two(22) samples of suspect ACM were obtained during this survey. Analytical results indicate that ACM was present above 1% in some building materials sampled. The ACM was noted to be non-friable and located in the white drywall in the living room; tan drywall and joint compound in the hall; black tar paper and sealant in the attic; and tank sheet vinyl on the rear porch.

The LBP inspection and risk assessment indicated that lead was present in paint at or above the USEPA/HUD definition of LBP at four locations. As painted surfaces were in-tact with no peeling or flaking, the risk assessment concluded that a hazard does not exist related to LBP.

The results of soil sampling performed around the exterior of the housing unit indicated that no exceedances of USEPA Residential Soil Regional Screening Level or TCEQCriteria for lead in soil.

Mold was detected on the ceilings of bedroom #1 and bedroom #3.

While there are numerous federal and state-listed species identified in the State of Texas,it is unlikely these species reside within the Site or would be affected by the property transfer due to a lack of suitable habitat within or in the immediate vicinity of the Site.

The Site is located within a developed area that is surrounded by residential properties.The nearest mapped wetlands are located approximately 0.1 miles south of the Site and include lakes, freshwater emergent, freshwater forested/shrub, and riverine wetlands.

The Site, along with the immediately surrounding areas, is mapped as Zone B which is defined by FEMA as areas between the limits of the 100-year floodplain and the 500-year floodplain; or certain areas subject to 100-year flooding with average depths of less than one foot, or areas protected by levees from the base flood.

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The nearest mapped water feature is the Sabine-Neeches Canal, located approximately two miles southeast of the Site.

A historic and cultural resources record search did not identify any archaeological resources at or within a one-mile radius of the Site. The record search indicated that the Site itself has not been previously surveyed for archaeological resources and that no previously recorded archaeological resources exist within the Site boundaries.

No architectural resources are located within the Site itself, however two historic structures are indicated within a one-mile radius of the Site.

8.2 RECOMMENDATIONS

Based on the conclusions outlined above, Amec Foster Wheeler recommends the following to the USCG for consideration with respect to the Site.

Based on the results of ACM inspection and sampling, an Asbestos Management Plan is required if any disturbance or other renovation work is conducted at the Site. If any disturbance or renovation of the ACM occurs, proper asbestos abatement procedures must be implemented prior to commencement of work, and the building owner is required to properly communicate the ACM hazard to all employees, workers, contractors, and occupants, and manage the ACM in accordance with 29 CFR 1926.1101 and the Asbestos Standard for the Construction Industry, OSHA 3096.

If renovation or demolition activities are planned for the Site, the disturbance of lead-containing painted surfaces should be performed in accordance with the USEPA-Lead; Renovation, Repair and Painting Program (40 CFR 745.80, Subpart E). Other actions may also be required under the USEPA/HUD Residential Lead-Based Paint Hazard Reduction Act of 1992 (Public Law 102-550), the HUD Lead Safe Housing Rule (24 CFR Part 35, Subparts B-R), and/or the Disclosure of Known Lead-Based Paint and/or Lead-Based Paint Hazards Upon Sale or Lease of Residential Property (24 CFR Part 35, Subpart A).

Interior surfaces should be cleaned to remove mold prior to divestment of the Site. A follow up investigation should be performed by an industrial hygienist.

Consultation with the Texas State Historic Preservation Division (the State Historic Preservation Office) to determine the need for archaeological investigations pursuant to state and federal regulations is recommended prior to construction-related ground disturbance.

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8.3 LIMITATIONS

The conclusions of the report are professional opinions based solely upon visual site observations, and interpretations of analyses as described in this report. The opinions presented within this report apply to the site conditions existing at the time of the investigations, and interpretation of current regulations. Therefore, opinions and recommendations provided within this report might not apply to future conditions that may exist at the Site.

We declare to the best of our knowledge and belief that we meet the definition of Environmental Professional as defined in 40 CFR 312.10. We have the specific qualifications based on education, training, and experience to assess a subject property of the nature, history, and setting of the subject property. We have developed and performed all appropriate inquiries in general conformance with the standards and practices set forth in 40 CFR Part 312 and attest to the completeness and accuracy of the information contained in this report.

Erica Geasler-Bromley, P.E.Project Manager

Lauren BugdalskiGeologist

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9.0 REFERENCES

Federal Emergency Management Agency (FEMA). 1984. FEMA Flood Insurance Rate Map, Panel 4854990035E. Accessed: 23 August 2016. Retrieved from: http://map1.msc.fema.gov

National Marine Fisheries Service (NMFS). 2017. Texas' Threatened and Endangered Species.Accessed: 19 January 2017. Retrieved from: http://sero.nmfs.noaa.gov/protected_resources/section_7/threatened_endangered/Documents/texas.pdf

NMFS. 2016 GIS Data for Critical Habitat. Accessed: 10 August 2016. Retrieved from: http://sero.nmfs.noaa.gov/maps_gis_data/protected_resources/critical_habitat/index.html

Texas Parks and Wildlife Department (TPWD). 2017. Federal and State Listed Species in Texas. Accessed: 19 January 2017. Retrieved from: http://tpwd.texas.gov/huntwild/wild/wildlife_diversity/nongame/listed-species/

TPWD. 2016. Rare, Threatened, and Endangered Species of Texas by County. Accessed: 24 January 2017. Retrieved from: http://tpwd.texas.gov/gis/rtest/

TPWD. 1994. Texas Wetlands Conservation Plan. Accessed: 11 August 2016. Retrieved from: http://tpwd.texas.gov/publications/pwdpubs/media/pwd_pl_r2000_0005_textonly.pdf

Texas Water Development Board (TWDB). 2017. National Flood Insurance Program. Accessed: 19 January 2017. Retrieved from: http://www.twdb.texas.gov/flood/insurance/index.asp

United States Fish and Wildlife Service (USFWS). 2016a. National Wetlands Inventory. Accessed: 10 August 2016. Retrieved from:https://www.fws.gov/Wetlands/Data/Mapper.html

USFWS 2016b. Information, Planning, and Conservation (IPaC) System. Accessed: 10 August 2016. Retrieved from: https://ecos.fws.gov/ipac/gettingStarted/map

USFWS. 2016c.Threatened and Endangered Species Active Critical Habitat Report. Accessed:10 August 2016. Retrieved from: https://ecos.fws.gov/ecp/report/table/critical-habitat.html

USFWS. 2015. Listed Species Believe to or Known to Occur in Texas. Accessed: 24 January 2016. Retrieved from: https://ecos.fws.gov/ecp0/reports/species-listed-by-state-report?state=TX&status=listed

U.S. Geological Survey (USGS). 2016. USGS TNM Hydrography 2.0 Viewer. Accessed: 22 August 2016. Retrieved from: http://viewer.nationalmap.gov/viewer/nhd.html?p=nhd

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FIGURES

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PROJ: GSA-32106D009

US Coast Guard

Site Location MapUS Coast Guard Site

3022 Bernhardt DrPort Arthur, TX 77642

FIGURE 1:

Path: G:\GSA\a_MXD\USCG Housing Due Diligence Phase III 2016_32106D009\Port Aruthur TX\Fig 1 3022 Bernhardt Dr. Port Arthur Texas.mxd

Date: January 2017

Legend

_̂ Site Location

±0 10,0005,000

Feet

46850 Magellan DriveNovi, Michigan 48377(248) 926-4008

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US Coast Guard

Site Layout MapUS Coast Guard Site

3022 Bernhardt DrPort Arthur, TX 77642

FIGURE 2:

Path: P:\Federal\GSA\USCG Housing Due Diligence Phase III 2016\GIS\MXD\Fig 2 3022 Bernhardt Dr. Port Arthur Texas.mxd

Date: January 2017

LegendApproximate Site Boundary

±0 5025

Feet

Bernhardt Dr3022

Twin CIty Highway

46850 Magellan DriveNovi, Michigan 48377(248) 926-4008