Fw: Attorney General Building Carpet Update Scott Miller to: Debbie Jourdan 04/27/2012 08:47AM Hide Details From: Scott Miller/R4/USEPAIUS

To: Debbie Jourdan/R4/USEPAIUS@EPA

1 Attachment

April 26, 2012 Carpet Status letter.pdf

Debbie, Please save this to SDMS for Capitol City Plume. Thank you,

Scott Miller Remedial Project Manager Superfund Division Superfund Remedial Branch Section C U.S. EPA Region 4 61 Forsyth Street, SW Atlanta, GA 30303 Phone ( 404) 562-9120 Fax ( 404) 562-8896

-----Forwarded by Scott Miller/R4/USEPA/US on 04/27/2012 08:47AM----­To: Scott Miller/R4/USEPA/US@EPA From: "Ashley Cousins" < acousins@acessllc.com > Date: 04/26/2012 05:46PM Cc: "Buddy Smith" <asmith@bainbridgemims.com >, <RTambling@ago .state.al.us> Subject: Attorney General Building Carpet Update

(See attached file: April 26, 2012 Carpet Status letter.pdf)

Hi Scott-

Please find attached letter with an update on the carpet in the Attorney General Building.

Let me know if you have any questions or need additional information.

Ashley

Ashley Cousins Environmental Strategies & Solutions LLC

AC ESS

April 26, 2012

Mr. Scott Miller Remedial Project Manager, Superfund Division Superfund Remedial Branch, Section C U.S. EPA Region 4 61 Forsyth Street, SW Atlanta, GA 30303

Re: Capital City Plume Indoor Air Samples

DearScaty

Thank you for providing the results from the samples collected on the right-of-way adjacent to several State buildings in February and responses to my March 1, 2012 email with questions regarding the proposed additional sampling on State property. I have a few additional questions, particularly about the GORE analytical method and hope that we can discuss those at your convenience. In the meanwhile, I wanted to provide you with an update and clarification on the testing that the State has been performing related to the carpet in the Subbasement of the Attorney General's building.

As you are aware, the State of Alabama has been investigating the results of the indoor air samples collected by the USGS in August 2011 . EPA indoor air results indicated the presence of typical indoor air contaminants that were within background levels and pose no unacceptable risk to humans (EPA Press Release October 26, 2011 ). The indoor air samples contained concentrations of Total Petroleum Hydrocarbons (TPH), reported by the GORE laboratory as a "greater than" concentration, expressed as 1Jg/m3

. According to Jay Hodny at GORE laboratories, the calculated concentration may be biased low as the uptake rate slows, when the mass exceeds 50 !Jg, thus GORE reports TPH with a "greater than" symbol. All of the samples collected inside the Attorney General's building contained a mass of greater than 50 !Jg due to the one-week sample duration and the fact that the carpet in the area is emitting volatile organic compounds.

Based on the TPH results, the State evaluated potential indoor sources that were contributing to the indoor air quality and causing the "vinyl" odor in the Subbasement area. Initially, the cleanout to the sanitary sewer line was removed and a mulitgas meter was used to monitor for the presence of hydrogen sulfide, oxygen and LEL. There was no hydrogen sulfide detected and the LEL readings were all zero. The oxygen concentrations were normal. Manufacturers of

Mr. Scott Miller April 26, 2012 Page 2

the carpet tiles and the adhesive were contacted to determine if there had been similar conditions associated with their products. The adhesive manufacturer indicated that their

product did not contain volati le organic compounds. The carpet manufacturer offered to analyze the carpet tiles to determine if they were emitting volatile organic compounds (VOCs).

Analysis of the GlasBac carpet tiles using a chamber emission test indicated that the installed

carpet squares in the subbasement (Samples 1 and 2) were emitting about 190 and 493 1Jg/m2/hr of VOCs. Identified VOCs in the emissions tests are within the carbon range reported by GORE as Total Petroleum Hydrocarbons (C4-C20). A carpet tile from inventory (Sample 3)

was also analyzed, and shown to be emitting 92 1Jg/m2/hr of VOCs. Chromatograms of the

three carpet tile samples are included in Attachment A. It is apparent that Samples 1 and 2 have a similar pattern of peaks, whereas sample 3 has a different pattern. Samples 1 and 2 were both from installed tiles and sample 3 was from an inventory tile that had not been installed.

lnterfaceFLOR prepared a memo of the sample results (See Attachment B), wherein they reported the following:

The levels of alcohols and their derivatives present in sample 2 indicates a possible incompatibility between the carpet's vinyl backing and levels of moisture and pH in the concrete sub-floor. Prior to installation the concrete should have been tested for moisture and pH levels. In Situ probe relative humidity moisture emission rates should have been at or below 75% rH (ASTM F 2170) and pH should have been 7.0-9.0 (ASTM F 710). When installed over concrete with moisture in excess of 75% rH (ASTM F 2170) and alkalinity above 9.0 (ASTM F 71 0) the carpet 's vinyl backing can break down resulting in a solid phase reaction known as plasticizer degradation. This breakdown is a direct result of the carpet being in contact with concrete that was not within the specifications required under the installation instructions for lnterfaceFLOR's Glasbac backing.

2 The current VOC levels of Sample #2 are not above the threshold limit of 500 (pg/m lhr) but the levels of alcohols suggest concrete conditions are/have been most likely contributing to indoor air quality concerns as a result of an incompatibility between the carpet backing and the concrete being out of specification for installation of a vinyl backed carpet tile in regards to moisture and alkalinity.

The State performed preliminary moisture testing of the concrete in November 20 11 using

Wagner relative humidity probes, which indicated an exceedance of the moisture requirements. Independent testing was performed in February 2012, using both the Calcium Chloride test (ASTM F1869-11) and comparing two relative humidity probes (ASTM 2170-09) to determine

the moisture vapor emission rate (MVER) and the relative humidity (rH) of the concrete slab. Readings for both MVER and rH exceeded the manufacturer's recommendations in several

locations, however, there is no visual evidence of moisture damage. Results are summarized on Table 1.

The State has retained a textile chemist familiar with plasticizer degradation to evaluate the test

results and recommend appropriate treatment of the slab and a replacement product that will

Mr. Scott Miller April 26, 2012 Page 3

not continue to produce the "vinyl-smell" associated with the plasticizer degradation of the carpet backing. The general recommendations include:

• Remove of the existing carpet in the Subbasement area (approximately 5200 square feet)

• Physically remove the adhesive by scraping . No chemicals will be used for removal.

• Allow the concrete slab one to two weeks to breathe with increased air exchange rate.

• Qualitative testing and observations to determine if the odor is still present. • Determine if a surface treatment is needed to seal the floor (if odors still present

in concrete after breathing period)

• Install surface covering that does not contain plasticizer.

The State has retained an architect to prepare specifications based on the textile chemist's recommendations for removal of the existing carpet and replacement with a new product so that the project can be let for bid .

The Subbasement is the only area where odor complaints have been indicated and we are confident that we have isolated the carpet as a major source of the VOC emissions and TPH concentrations reported using the GORE method. There are currently no employees working in the Subbasement area and there have not been any additional complaints received from Attorney General employees. While we understand from your email yesterday that EPA wants to sample the uncarpeted areas of the Subbasement, we believe that TPH concentrations in indoor air samples will be biased by the carpet and the stored inventory tiles. Therefore, we would request that no testing be conducted until the carpet has been removed . In addition, we would request that such additional testing be performed using EPA method T0-15 in accordance with EPA guidance for collecting indoor air samples, and not the GORE method.

Please let me know if you have questions regarding the status of the carpet evaluation and replacement.

cc: Buddy Smith Robert Tambling

Table 1. Results of moisture and relative humidity testing, Attorney General's Building, 501 Washington Avenue, Montgomery, AL Testing by Stoner Services

3/1/12 Calcium In Situ-Probe Test pH Chloride Scarified

Test Wagner Delmhorst Carpet Manufacturer Recommendation 3.00 75% 75% Between 7-9

ID Location lbs/1000 sq ft/24 hours % rH % rH A Multi-purpose room 3.00 78% NA 9

B Multi-purpose room 3.00 NA 72.2% 8

c Mulit-purpose room 4.17 NA 77.3% 9

D Office SB23 2.83 77% NA 9

E Office SB21 4.02 NA 82.2% 10

F Reception SB15 3.02 82% 79.5% 9

G Lobby SB14 3.36 76% 73.2% 9

ATTACHMENT A

Da ta Path Da t a File Acq On Operator Sample Mise ALS V i a~

~Area Pe rcent Repo r t

C : \ MS DCh e m\ 1\ d a t a\ 2 01 110 1203.0 1 3 Oct 2 0 11 12 : 18

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Data Path Data File Acq On Op era tor Sample Mise Z\LS Vial

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T ES T 20 .M Thu Oct 13 11:0 6 :1 8 201 1 Page : 3

ATTACHMENT B

Interface FLoR·

To: WHOM IT MAY CONCERN

FROM: JIMMY GARRETT

DATE: 10/ 17/11

RE: ALABAMA STATE OFFICE BUILDING VOC

LAB LOG # T10460

Three carpet samples w ith GlasBac were received from Alabama State Office Building in Montgomery, AL for VOC testing. Customer complained of odor. The samples were individually wrapped in foil and plastic. Indoor air samples taken in the area indicated eleva ted leve ls of petroleum hydrocarbons and other aromatic compounds. No other infor mation was received.

Sample# 1: T ile from mechanical closet with adhesive on 1/z of t ile

Sample # 2: T ile from hallway in subbasement

Sample # 3: T ile from inventory stock

VOC Test: The samples were die cut and loaded in 50 liter ch amber for standard 24 hour VOC test.

# L #2 #3

Major VOC Components VOC voc VOC (l-!g/m2/ht·)

? (1-1g/m2 /hr) ( j.!g/m-/lu)

2-ethyl- L -Hexanol 3.2 9.4 L L. 8

3,7, 11-trimethy l-1-Dodecanol 13 .2

3-methyl-1-Hexene* 30.8

3,3,5-trimethyl- L -Hexene* 69.5

1

October 17, 2011

6-methyi-1-0ctanol 6 1.3 108.6

2-ethyi-Hexanoic acid* 4.8

3-ethyl-l-Pentene* 24.2

3,4-dimethyl- l-Pentanol 47.5

2,3-dimethyi-1-Pentene* 40.2 96.6

2-(2-butoxyethoxy)-Ethanol * 9.0

Caprolactam 26.0 3 L.5

Cyclododecane 18.3

Total VOC's ()..lg/m2/hr) 190.1 492.8 92.4

*Best Ltbrary Ftt

GC data files: 201 1101203, 2011101202,2011101201

Discussion:

The samples all contained VOC's within the allowable limits of the CRI Green Label Plus certification (~tg/m2/lu').

Note:

Sample tile # 2 -Sub Basement- The levels of alcohols and their derivatives present in this sample indicates a possible incompatibility between the carpet's vinyl backing and levels of moisture and pH in the concrete sub-floor. Prior to installation the concrete should have been tested for moisture and pH levels. In Situ probe relative humidity moisture emission rates should have been at or below 75% rH (ASTM F 2170) and pH should h ave been 7.0- 9.0 (ASTM F 710). When installed over concrete with moisture

2

October 17, 2011

in excess of 75% rH (ASTM F 2170) and alkalinity above 9.0 (ASTM F 710) the carpet's vinyl backing can break down resulting in a solid phase reaction known as plasticizer degradation. This breakdown is a direct result of the carpet being in contact with concrete that was not within the specifications required under the installation instructions for InterfaceFLOR's Glasbac backing.

The current VOC levels of Sample #2 are not above the threshold limit of 500 (~g/m2/lu·) but the levels of alcohols suggest concrete conditions are/have been most likely contributing to indoor air quality concerns as a result of an incompatibility between the carpet backing and the concrete being out of specification for installation of a vinyl backed carpet tile in regards to moisture and alkalinity.

InterfaceFLOR assumes no liability for issues relating to or resulting from installation over concrete containing moisture and alkalinity in excess of those levels required and noted in the Interface Installation Instruction.

3