05d SOW Attch_HBMS B455 and B456.pdf
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Department of the Army National Guard
About this file
This document is a Hazardous Building Materials Survey for Air National Guard Buildings 455 and 456 located at Paine Field in Everett, Washington. The survey was conducted in preparation for the planned demolition of the buildings.
The survey identified various asbestos-containing materials (ACM) in the buildings, including cement asbestos board siding, cove base and mastic, fire-stop materials, and wood eave caulk. The total quantity of ACM in the two buildings is estimated at approximately 8,000 square feet. The report also identified potential PCB-containing materials such as fluorescent light ballasts. Lead-based paint was not detected at actionable levels. The report provides detailed information on the types, locations, and quantities of hazardous materials present, as well as recommendations for proper abatement and disposal prior to demolition.
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HAZARDOUS BUILDING MATERIALS SURVEY
Air National Guard Buildings 455 and 456
215th EIS Squadron Paine Field
Everett, Washington
Submitted To:
Erik Prestegaard Helix Design
6021 12th Street East, Suite 201 Tacoma, Washington 98424
Prepared By:
Med-Tox Northwest
Post Office Box 1446
Auburn, Washington 98071-1446
Telephone: 253-351-0677
September 16, 2011 REV
Project Number: A-7187.2
Air National Guard, Buildings 455 and 456 Hazardous Building Materials Survey
September 16, 2011 ii Helix Design
Table of Contents
Acronyms ........................................................................................................................ iv
Survey Summary
Building Information
Asbestos Survey
Surfacing Materials
Thermal System Insulation
Miscellaneous Materials
Lead-Based Paint Summary
Lead in Painted Surfaces
Waste Designation Survey
Other Hazardous Building Materials
Chlorofluorocarbons
PCB Light Ballasts and Fluorescent Light Tubes
PCB in Caulking and Paint
Mercury Containing Switches
Laboratory Analytical Methods
Asbestos-Containing Materials
Lead-Based Paint
PCBs
Comments and Recommendations
Asbestos-Containing Materials
Lead-Based Paint
PCB
Other Hazardous Building Materials
Limitations
Appendix A AHERA Building Inspector and CTED Risk Assessor Certificates ............... A
Appendix B Building and Building System Photographic Documentation........................ B
Appendix C Summary of Materials Sampled for Asbestos .............................................. C
Appendix D National Voluntary Laboratory Accreditation Program Certificates .............. D
Appendix E Analytical Reports- Asbestos ....................................................................... E
Appendix F Analytical Reports- Lead .............................................................................. F
Appendix G EMSL Laboratory Certification .................................................................... G
Appendix H Analytical Reports- PCB .............................................................................. H
Appendix I On-Site Environmental Laboratory Certification ............................................. I
Appendix J Sample and Material Locations Drawings .................................................... J
September 16, 2011 iii Helix Design
Tables Table 1. Summary of Asbestos-Containing Materials
Table 2. Summary of Suspect Materials Determined Non-Asbestos Containing
Table 4. Summary of TCLP Sampling
Table 5. Summary of Fluorescent, HID, and Exit Lights
Table 6. Summary of PCB Sample Results
September 16, 2011 iv Helix Design
Acronyms
AAS atomic absorption spectroscopy ACM asbestos-containing materials AHERA Asbestos Hazard Emergency Response Act ASHARA Asbestos Schools Hazard Abatement Reauthorization Act
ASTM American Society of Testing and Materials CAB cement asbestos board CFC chlorofluorocarbons CFR Code of Federal Regulation CHR Chrysotile asbestos CTED Commercial, Trade and Economic Development DEHP Di (2-ethylhexyl) phthalate ECD electron capture detectors EPA U.S. Environmental Protection Agency f/cc fibers per cubic centimeters GC gas chromatography HBM hazardous building materials HID high intensity discharge HM homogeneous material LBP lead-based paint LF linear feet mg/cm2 milligrams per square centimeter mg/kg milligrams per kilogram mg/L milligrams per liter MTNW Med-Tox Northwest NVLAP National Voluntary Laboratory Accreditation Program OSHA Occupational Safety and Health Administration PCB polychlorinated biphenyl PLM polarized light microscopy ppm parts per million PSCAA Puget Sound Clean Air Agency RCRA Resource Conservation and Recovery Act SF square feet TCLP toxicity characteristic leaching procedure TSI thermal system insulation WAC Washington Administration Code WISHA Washington Industrial Safety and Health Administration WRD WISHA Regional Directive XRF X-Ray flourescence % wt percent in weight
September 16, 2011 1 Helix Design
Survey Summary
On August 15th and 16th, 2011, Anthony Fullerton of Med-Tox Northwest (MTNW) conducted a hazardous building materials (HBM) survey of buildings 455 and 456 owned by the Air National Guard at Paine Field, in Everett, Washington. This work was conducted in preparation for the planned demolition. The buildings were vacant at the time of the survey. This survey was conducted in accordance with Contract W912K3- 10-D-0001.
A building inspector accredited under the Asbestos Hazard Emergency Response Act (AHERA) and employed by Med-Tox Northwest, conducted the building material survey in accordance with federal, state, and local regulations to provide for an assessment of asbestos-containing materials (ACM) in the structure. The applicable regulations require the building owner to identify and dispose of the identified ACM prior to the start of demolition work.
This report identifies building materials that contain asbestos, estimates the quantity of ACM present and documents building materials that potentially contain polychlorinated biphenyls (PCBs) and other hazardous materials. Copies of the inspectors AHERA building inspector certificates and Commercial, Trade and Economic Development (CTED) Risk Assessor certificate are included in Appendix A.
Six (6) materials were identified as ACM in Building 455. These included: 4-inch gray cove base with residual ACM joint compound, cement asbestos board (CAB) siding, Wood eave caulk, white solid fire-stop, gray fibrous fire-stop, and vapor barrier under
CAB.
The joint compound in the un-textured gypsum wallboard system located in building 456 was both determined to contain 2% Chrysotile asbestos in the joint compound, but when composited as a system with gypsum wallboard and tape; the total overall asbestos is less than 1%.
Four (4) materials were identified as ACM in Building 456. These included: 4-inch brown cove base mastic, gray floor leveler with black mastic, and CAB siding, and wood eave caulk.
Except for gypsum wallboard joint compound, these materials must be legally removed and disposed of prior to demolition of the buildings; the wallboard system in 456 contains less than one percent asbestos content and does not require removal as an
ACM.
Med-Tox Northwest inspected the building for cooling systems with potential chlorofluorocarbons (CFC); none were identified.
September 16, 2011 2 Helix Design
Potential PCB-containing materials observed in the structure include fluorescent light ballasts. The fixtures in the buildings included:
Building 455
4 each, 8-foot, 2 bulb fixtures 21 each; 4-foot, 2 bulb fixtures 8 each; HID lights
Building 456
20 each; 4-foot, 2 bulb fixtures 8 each; HID lights
Building Information
Photographic documentation of the buildings and the major systems described herein are provided in Appendix B.
General and Structural: Buildings 455 and 456 occupy the parcel of property at the Snohomish County Airport (Paine Field) known as the West Parcel. The West Parcel consists of approximately 1.7 acres and is completely surrounded by four (4) paved roadways systems which serve as access to the parcel and surrounding businesses.
Building 455 is approximately 3690 square feet and is situated to the west of building 456 at the near center of the property. Building 456 is to the eastern side of the property and is approximately 2,269 square feet. The property is completely enclosed by a chain-link type fence with limited access. The two structures on the West Parcel were originally constructed as part of the Air Forces support operations on Paine Field and served as the unit's vehicle maintenance shops and motor pool. When the Air Force relinquished the user rights to the buildings to the Washington Air National Guard, the buildings remained in service as vehicle maintenance until the construction and completion of the new vehicle maintenance, now located on the North Parcel.
Both buildings were originally constructed in 1948 and/or 1949. They are wood framed with cement asbestos board siding covered with newer vinyl siding and soffit. The main portions of the buildings were utilized for vehicle maintenance; with support offices, conference rooms, restrooms and mechanical rooms taking up the remaining space.
The building is constructed slab on-grade. The roofs are pitched and have three tab composition shingles.
Heating and Mechanical Systems: Heat for the buildings is provided by gas fired furnaces located in their respective mechanical rooms. The associated duct work runs
September 16, 2011 3 Helix Design overhead with ceiling mounted or overhead diffusers. Ducting in the west offices of Building 455 is wall mounted. This ducting penetrates the walls and has wall mounted diffusers, so the main line feeds several rooms. Office 2 in Building 455 also has a wall mounted electric heater.
The hot water tank for Building 455 is located in the men’s restroom, the hot water tank in Building 456 is located above the restrooms in a mezzanine storage area. Both tanks were un-insulated and the associated pipes were also un-insulated.
Walls/Ceiling: Walls throughout both buildings are finished with un-textured gypsum wallboard systems.
Ceilings in both buildings are primarily open to reveal the wood framing in the main work areas. Office areas, mechanical room, and restrooms in Building 455 have un-textured gypsum wallboard system on the ceiling. In Building 456 the ceiling in the office areas, and conference room have acoustical ceiling tiles in a metal T-grid. Restrooms in Building 456 have un-textured gypsum wallboard systems.
Floor Systems: Floors throughout both buildings is slab on-grade concrete. Floors throughout the work areas have a gray epoxy type finish over the concrete. Office areas have glued down carpeting over concrete. In Building 455 the restrooms have 12-inch gray floor tile and mastic, in Building 456 there is 12-inch beige mottled vinyl tile and mastic in the conference room and sheet vinyl flooring in the restrooms.
Asbestos Survey
The AHERA regulation, 40 Code of Federal Regulations (CFR) 763, is the primary governing regulation when performing asbestos surveys. This regulation was originally enacted for school buildings, but has since been applied to public and commercial buildings by the Asbestos School Hazard Abatement Reauthorization Act (ASHARA) in 1994 and by the Occupational Safety and Health Administration’s (OSHA) worker protection regulations in 1995, specifically 29 CFR 1926.1101(k).
Puget Sound Clean Air Agency (PSCAA) also requires compliance with AHERA’s survey and sampling requirements. This applies to any renovation or demolition activities where suspect ACM may be disturbed. PSCAA is a local agency that receives statutory authority from the U.S. Environmental Protection Agency (EPA) to enforce environmental regulations.
AHERA divides suspect ACM into three categories; “surfacing materials” (i.e., sprayed fireproofing, popcorn ceiling texture, etc.), “thermal system insulation” (TSI) (i.e., pipe or building insulation, etc.), and “miscellaneous materials” (i.e., flooring material, roofing, construction mastics, etc.). The following sections summarize the potential ACMs
September 16, 2011 4 Helix Design identified and for each of these three categories. For a complete listing of suspect materials sampled, see Appendix C.
Homogeneous Material (HM) descriptions in the following text are provided to help correlate material descriptions provided in Appendix D.
Surfacing Materials
There were no surfacing materials identified as defined by 40 CFR 763.
Thermal System Insulation
There were three TSI materials identified in the buildings as defined by 40 CFR 763.
Interior ducting to GWB wall fire stop- white, solid (HM-14). This material was identified in room 3 in the west end offices. This material is found around the ductwork where it penetrates into the wall cavity. Two samples were collected and analyzed for asbestos content; this material was found to contain 90% Chrysotile asbestos.
Interior ducting to GWB wall fire stop- gray (HM-15). This material was identified in room 3 and 1. This material is found around the ductwork where it penetrates into the wall cavity. Two samples were collected and analyzed for asbestos content; this material was found to contain 3% Chrysotile asbestos.
Fiberglass insulation. There was fiberglass insulation identified in the buildings. This material was visually determined non-asbestos containing by the building inspector in accordance 40 CFR 763.
The pipes observed in the buildings were un-insulated.
Miscellaneous Materials
Building 455
Un-textured gypsum wallboard system (HM-01). This material was identified on most of the walls of Building 455. This system was observed to be homogeneous to the building. A total of three samples were collected and analyzed of this building system for asbestos content;
asbestos was detected in the joint compound in one of the samples. The joint compound was determined to contain 2% Chrysotile asbestos.
When this material is composited with all of the layers of the gypsum wallboard system, the total asbestos content is less than 1% Chrysotile.
Gray epoxy floor paint (HM-02). This material was identified on the concrete floor of the work area and mechanical room. Three samples
September 16, 2011 5 Helix Design were collected and analyzed for asbestos; this material was determined to be negative for asbestos.
Yellow carpet mastic with white leveling compound and residual black mastic (HM-03). This material was identified in the entry and office areas.
A total of three samples were collected and analyzed for asbestos content;
this material was determined to be negative for asbestos.
White window frame caulk- interior (HM-04). This material was identified around the frame of the windows on the inside of the building. A total of three samples were collected and analyzed for asbestos content; this material was determined to be negative for asbestos.
12-inch gray mottled floor tile and mastic (HM-05). This material was identified on the floor of the men’s and women’s restrooms. A total of three samples were collected and analyzed for asbestos content; this material was not found to contain asbestos.
Yellow wall carpet (HM-06). This material was identified on the walls of the south office area. A total of two samples were collected and analyzed for asbestos content; this material was not found to contain asbestos.
4-inch gray cove base and mastic (HM-07). This material was identified on the walls of the offices and restrooms. A total of three samples were collected and analyzed for asbestos content. The cove base and mastic were determined to be negative for asbestos, but one of the samples was analyzed to contain joint compound with 2% Chrysotile asbestos as one of the layers. If removed separately from the wall board system and the joint compound is disturbed, this material will require abatement by certified asbestos workers.
Cement asbestos board CAB (HM-08). This material was identified on the exterior walls underneath the vinyl siding. A total of two samples were collected and analyzed for asbestos content; this material was determined to contain 15% Chrysotile asbestos.
Wood eave caulk- under vinyl soffit (HM-09). This material was identified around the wood truss where it extends from the wall. This caulking seals the penetration between the truss and the wall. A total of three samples were collected and analyzed for asbestos content; this material was determined to contain 3% Chrysotile asbestos.
White wood window frame to vinyl siding caulk (HM-10). This material was identified around the wood window frames where the wood and vinyl meet. A total of three samples were collected and analyzed for asbestos content; this material was not found to contain asbestos.
September 16, 2011 6 Helix Design
Brown aluminum window frame to wood caulk (HM-11). This material was identified around the aluminum framed windows where the aluminum and wood meet. A total of three samples were collected and analyzed for asbestos content; this material was not found to contain asbestos.
Three-tab composition roofing (HM-12). This material was identified on the roof. One sample was collected and analyzed for asbestos content;
this material was not found to contain asbestos.
Vapor barrier (HM-13). This material was identified on the roof under the three-tab composition roofing. One sample was collected and analyzed for asbestos content; this material was not found to contain asbestos.
Vapor barrier under CAB (HM-16). This material was identified under the exterior vapor barrier. Three samples were collected and analyzed for asbestos content; this material was found to be negative for asbestos;
however, there was residual caulking on one of the samples and it was determined to contain 2% Chrysotile asbestos.
Building 456
Un-textured gypsum wallboard system (HM-17). This material was identified on most of the walls of Building 456. This system was observed to be homogeneous to the building. A total of three samples were collected and analyzed of this building system for asbestos content; this material was not found to contain asbestos.
4-inch brown cove base and mastic (HM-18). This material was identified on the walls of the conference room, entry, and the west wall of the main work area. A total of three samples were collected and analyzed for asbestos content. The cove base was determined to be negative for asbestos, but the brown mastic was determined to contain 3% Chrysotile asbestos.
2-inch cove base and mastic (HM-19). This material was identified on the walls of the restrooms. A total of three samples were collected and analyzed for asbestos content. The cove base and mastic were determined to be negative for asbestos.
Gray epoxy floor paint (HM-20). This material was identified on the concrete floor of the work area and mechanical room. Three samples were collected and analyzed for asbestos; this material was determined to be negative for asbestos
Gray sheet vinyl flooring (HM-21). This material was identified on the metal cap seams on the floor of the restrooms. A total of two samples were collected and analyzed for asbestos content; this material was not found to contain asbestos.
September 16, 2011 7 Helix Design
12-inch beige mottled vinyl floor tile and mastic (HM-22). This material was identified on the floor of the conference room. A total of three samples were collected and analyzed for asbestos content; this material was not found to contain asbestos.
Gray leveler on concrete under HM 22 (HM-23). This material was identified on the floor under HM 22 in the conference room. A total of three samples were collected and analyzed for asbestos content; the gray leveler was determined to negative for asbestos, however; there is a layer of residual black mastic under the leveler that was determined to contain 3% Chrysotile asbestos.
Light weight concrete patching material (HM-24). This material was identified on the floor of the work area. A total of two samples were collected and analyzed for asbestos content; this material was not found to contain asbestos.
Carpet mastic (HM-25). This material was identified on the floor of the offices. A total of two samples were collected and analyzed for asbestos content; this material was not found to contain asbestos.
2-x 4-foot acoustical ceiling tile- random crater and pin hole pattern (HM- 26). This material was identified on the ceiling of the conference room. A total of three samples were collected and analyzed for asbestos content;
this material was not found to contain asbestos.
Brown aluminum window frame to wood caulk (HM-27). This material was identified around the aluminum framed windows where the aluminum and wood meet. A total of three samples were collected and analyzed for asbestos content; this material was not found to contain asbestos.
White wood window frame to vinyl siding caulk (HM-28). This material was identified around the wood window frames where the wood and vinyl meet. A total of three samples were collected and analyzed for asbestos content; this material was not found to contain asbestos.
Cement asbestos board CAB (HM-29). The exterior walls still have CAB under the vinyl siding. The soffit area was also inspected for this material but was determined to be wood. A total of two samples were collected and analyzed for asbestos content; this material was determined to contain 10% Chrysotile asbestos.
Three-tab composition roofing (HM-30). This material was identified on the roof. One sample was collected and analyzed for asbestos content;
this material was not found to contain asbestos.
September 16, 2011 8 Helix Design
Vapor barrier (HM-31). This material was identified on the roof. One sample was collected and analyzed for asbestos content; this material was not found to contain asbestos.
Wood eve caulk- under vinyl soffit (HM-32). This material is around the wood truss where it extends from the wall. This caulking seals the penetration between the truss and the wall. Based on the similarity of construction and likeness of exterior materials to building 455, this material is assumed to contain asbestos.
Table 1 summarizes ACM identified in the structures surveyed by Med-Tox Northwest.
Friability was determined by conditions observed during the survey and by how the material behaves during mechanical demolition.
Table 1. Summary of Asbestos-Containing Materials
Material Location
Material Description Asbestos Type and Percentage
Friability/ Condition
Material Quantity1
Building
Exterior Cement asbestos board 15% CHR
Non-friable, Fair condition
4,300 SF
Exterior Wood eve caulk 3% CHR Non-friable, Good condition
150 LF
Interior Fire stop- white solid 90% CHR Friable; Good condition
6 LF
Interior Fire stop- gray 3% CHR Friable; Good condition
12 LF
Exterior Gray putty on vapor barrier under CAB
2% CHR Non-friable, good condition
4,300 SF
Building 456
Interior 4-inch brown cove base and mastic
3% CHR Non-friable, good condition
90 LF
Interior Residual black mastic associated with HM 23 gray leveler
3% CHR Non-friable, good condition
240 SF
Exterior Wood eve caulk Assumed Non-friable, Good condition
85 LF
Exterior CAB 10% CHR Non-friable, good condition
3,200 SF
1 Material quantities are approximate. CHR=Chrysotile, linear feet, SF=square feet
September 16, 2011 9 Helix Design
Note: This table is not to be used without the complete survey document including appendices for additional information. Material quantity is approximate, bidders shall field verify conditions and quantities prior to providing a bid for removal.
Table 2 lists all suspect materials sampled that have been determined to be non-asbestos containing.
Table 2. Summary of Suspect Materials Determined Non-Asbestos Containing
Material Description
Building 455
Un-textured gypsum wallboard Gray epoxy flooring
Yellow carpet mastic with white leveling compound and residual black mastic
White window frame caulking- interior
12-inch gray mottled floor tile and mastic Yellow wall carpet mastic
4-inch gray cove base and mastic White wood window frame to vinyl siding caulk
Brown aluminum window frame to wood caulk
Three tab roofing
Vapor barrier- roof Building 456
Un-textured gypsum wallboard 2-inch cove base and mastic
Gray epoxy flooring Gray sheet vinyl flooring
12-inch beige mottled vinyl floor tile and mastic
Light weight concrete patching material
Carpet mastic 2-x-4 foot acoustical ceiling tile- random crater and pin hole pattern
Brown aluminum window frame to wood caulk White wood to vinyl siding caulk
Three tab composition roofing Vapor barrier Note: This table is not to be used without the complete survey document including appendices for additional information.
Lead-Based Paint Summary
Lead was commonly used in most paint products until 1978, when it was banned from residential paints at concentrations greater than 600 parts per million (ppm); however, commercial applications with lead were still utilized and are still available. Lead is poisonous to the human body and presents a potential health hazard during any kind of disturbance (such as maintenance, including grinding, welding, and cutting) and if improperly disposed, where lead can enter drinking water supplies.
EPA defines lead-based paint as a concentration of 1.0 milligram per centimeter squared (mg/cm2) or greater by X-Ray fluorescence (XRF) or 0.5 percent by weight or
September 16, 2011 10 Helix Design greater by total lead analysis (equivalent to 5,000 milligram per kilogram [mg/kg]). This EPA action level triggers requirements for protection of the environment, maintenance workers, and building occupants. It also triggers training and certification requirements for inspectors, project designers, contractors, supervisors, and workers. Although the training requirements only apply to certain residential structures at this time, they could apply to this type of property sometime in the future.
Washington Industrial Safety and Health Administration (WISHA) worker protection regulations has not defined a minimum concentration for regulating lead, and has clarified that lead at any detectable concentration shall be considered regulated (Washington Administrative Code [WAC] 296-155-176, Lead).
Lead in Painted Surfaces
Interior and exterior painted surfaces were tested for lead-based paint (LBP) using bulk sample collection and chemical analysis. A total of six, (6) paint chip samples were collected. Analytical results are provided in Table 3.
Table 3. Summary of Bulk Paint Chip Sample Results.
Sample Number Location Component Substrate Color Result
(mg/kg*)
Building 455
7187.2-AF-01Pb Mechanical room Floor Concrete Gray 0.050
7187.2-AF-02Pb Exterior- south Window frame
Wood Brown 0.059
7187.2-AF-03Pb Work area Wall GWB White 0.029
7187.2-AF-04Pb South center work area
Wall cap Wood White <0.010
7187.2-AF-05Pb Work area Truss Wood Gray <0.023
7187.2-AF-06Pb Room 4 Door frame Wood White 4.2
7187.2-AF-07Pb Room 4 Window frame
Wood White 0.35
Building 456
7187.2-AF-08Pb Exterior- west Window frame
Wood Brown <0.010
7187.2-AF-09Pb Conference room Door frame Wood Brown 0.14
7187.2-AF-10Pb Interior Wall GWB White <0.010
7187.2-AF-11Pb Work area Floor Concrete Gray 0.22
7187.2-AF-12Pb Exterior Wall CAB White <0.059 Mg/kg= milligrams per kilogram. Bolded values – bulk paint chip samples with lead detected above the laboratory reporting limit have been bolded. The Washington Industrial Safety and Health Administration (WISHA) worker protection regulations have stated that lead at any detectable concentration shall be considered regulated (Washington Administrative Code [WAC] 296-155-176, Lead.
September 16, 2011 11 Helix Design
Waste Designation Survey
Buildings 455 and 456 wastes consist of all construction materials with the exception of metal and concrete products. There was (1) toxicity characteristic leaching procedure (TCLP) sample collected during this inspection and tested by TCLP analysis for Resource Conservation and Recovery Act (RCRA) metal – lead. Samples 7187.2-AF- TCLP 01 and 7187.2-AF-TCLP 02 are from Building 455, samples 7187.2-AF-TCLP 03 and 7187.2-AF-TCLP 04 are from Building 456. Samples 01 and 03 are from painted CAB, samples 02 and 04 are from all other building materials minus concrete materials and CAB that will make up the waste stream. The result for the TCLP samples are listed in Table 4:
Table 4. Summary of TCLP Sampling.
Sample Location and Composition Result (mg/L)
7187.2-AF-TCLP 01 Building 455 CAB only <0.40
7187.2-AF-TCLP 02 Building 455- Representative painted materials that will make up the waste stream minus any concrete and CAB
<0.40
7187.2-AF-TCLP 03 Building 456 CAB only <0.40
7187.2-AF-TCLP 04 Building 456-Representative painted materials that will make up the waste stream minus any concrete and CAB
<0.40 mg/L = milligrams per liter Note: Do not use this table without the complete survey document
Other Hazardous Building Materials
Chlorofluorocarbons
Med-Tox Northwest inspected the building for cooling systems with potential chlorofluorocarbons (CFC). There were no CFC’s identified in Buildings 455 and 456.
PCB Light Ballasts and Fluorescent Light Tubes
Older fluorescent light ballasts have small capacitors that may contain high concentrations of PCB. Nearly all ballasts manufactured before 1979 contain PCBs. All ballasts manufactured after July 1, 1978 that do not contain PCBs are required to be clearly marked "No PCBs". Unmarked ballasts or ballasts without a date code should be assumed to be PCB ballasts. PCBs are toxic chemicals according to the EPA.
While there is only a small amount, about one ounce, of PCBs in each light ballast capacitor, there are a large number of ballasts in the United States. About half of the one billion ballasts, estimated as currently installed, were manufactured before 1979 and usually contain PCBs. Ballasts manufactured after 1978 may contain a PCB
September 16, 2011 12 Helix Design replacement called Di (2-ethylhexyl) phthalate (DEHP), a probable human carcinogen.
In any case, ballasts should not be disassembled for disposal but collected and sent to a certified recycling/disposal facility.
Fluorescent light fixtures were observed throughout the building. These fixtures were not inspected for the presence of PCB light ballasts due to being in use and the likelihood that many have been replaced since 1978. Determining how many fluorescent lights actually contain PCB ballasts can only be verified economically and safely during demolition. Therefore, all light fixtures are assumed to contain PCB light ballasts; light tubes are assumed to contain mercury. Additionally, exit lights, high intensity discharge (HID) lamps, smoke and heat detectors, and fire extinguishers may be regulated as universal or hazardous waste and will require dismantling and special handling. Table 5 provides a summary of these items in the building:
Table 5. Summary of Fluorescent, HID, and Exit Lights.
Location/floor
HID
lights 8-foot, 2-bulb
4-foot, 2-bulb
5-foot, 2-bulb
Exit lights
Throughout 16 4 41 0 0
Total 16 4 41 0 0
Typically, there is one, ballast for every two, light tubes in a fluorescent light fixture;
accordingly, there are approximately twenty seven ballasts in the light fixtures (sixteen in the HID lights and forty five in the fluorescent fixtures) requiring recycling or PCB hazardous waste disposal. There are also approximately ninety light tubes from the fluorescent fixtures and sixteen HID light bulbs that will need to be disposed of prior to demolition.
PCB in Caulking and Paint
PCB’s were used in paint and caulk formulations as drying oils (resins) and plasticizers or softening agents (liquids). Concrete surfaces and equipment, as well as marine or waterproofing applications, used at Federal installations and in the manufacturing and industrial sectors may have painted surfaces containing PCBs.
Table 6 below provides a summary of PCB sample result.
Table 6. Summary of PCB Sample Results.
Sample Number Location Material Result
(mg/kg*)
Building 455
7187.2-AF-01PCB Interior door frame White paint 160
7187.2-AF-02PCB Exterior window frame Brown paint ND
September 16, 2011 13 Helix Design
7187.2-AF-03PCB Main work area- floor Gray paint 91
7187.2-AF-04PCB Exterior CAB siding White paint ND
Building 456 ND
7187.2-AF-05PCB East side exterior window frame
Window frame to vinyl siding caulk
3.4
7187.2-AF-06PCB Work area- floor Gray paint ND
Mg/kg= milligrams per kilogram, ND= none detected. Samples with PCBs detected above 50 mg/kg must be removed as a bulk product waste under Toxic Substance Control Act (TSCA) 40 CFR 761. If waste is under 50 mg/kg and the site is being demolished, the waste cannot be recycled and will have to go to a RCRA subtitle C landfill as remediation waste.
Mercury Containing Switches
Heating system thermostats were investigated for mercury containing systems. There were no mercury-containing thermostats identified in the buildings.
Laboratory Analytical Methods
Asbestos-Containing Materials
Bulk samples were analyzed by Polarized Light Microscopy (PLM) dispersion staining EPA Method 600/R-93/116 by Med-Tox Northwest (MTNW). MTNW are accredited through the National Voluntary Laboratory Accreditation Program (NVLAP) of the U. S.
Department of Commerce. This accreditation does not constitute endorsement, but rather a finding of laboratory competence. The NVLAP participant number for MTNW is 102201 (certification copy is located in Appendix D). Analytical results are in Appendix E.
Lead-Based Paint
Bulk paint chip samples were submitted to EMSL Analytical, Inc. (EMSL), for analysis.
A total of twelve, (12) paint chip samples were analyzed for lead using atomic absorption spectroscopy (AAS) to determine the presence and percentage of lead.
Procedures for analyzing metals are found in the American Society of Testing and Materials (ASTM) D-3335-78 and EPA Method Manual SW-846, Method 6010. (EMSL used SW 846 3050B*/7000B).
Four (4) TCLP samples were collected and submitted to EMSL Analytical, Inc. The extraction of the TCLP sample was performed using EPA Method 1311. The lead analysis was performed using EPA Method 6010.
September 16, 2011 14 Helix Design
Analytical results for paint chip and TCLP results are provided in Appendix F. EMSL Analytical, Inc., laboratory certification is attached in Appendix G.
PCBs
The bulk paint chip collected for PCBs was submitted to On-Site Environmental, Inc., for analysis using gas chromatography (GC) equipped with electron capture detectors
(ECD). The sample was analyzed using EPA Method SW-846 8081/8082. Analytical results are provided in Appendix H. On-Site Environmental, Inc. laboratory certification is attached in Appendix I.
Sample and Material location drawings are provided in Appendix J.
September 16, 2011 15 Helix Design
Comments and Recommendations
Asbestos-Containing Materials
Med-Tox Northwest recommends that this survey report be placed on-site during renovation and/or demolition and copies provided to the contractor(s) bidding and performing work. WISHA and PSCAA require that the report be on-site and available for review during the entire project duration.
Additional destructive investigation and sampling will be required prior to and during any demolition activities including the following:
1. The doors to the building were not suspect fire doors as they were hollow core wood, metal, roll-up metal, or glass; however, destructive sampling of the doors was not permitted. For verification purposes, prior to any activity that will impact the doors; drill into the doors and door frames to determine if suspect fire protection is located inside.
2. Perform inspection of every pipe penetration in the building prior to removal of pipe systems or demolition to verify all penetrations through any wall/floor material do not contain suspect asbestos materials. This will require destructive investigation.
3. The joint compound was determined to contain asbestos in Building 455. If the gray cove base is removed separately from the gypsum wallboard system, it will require abatement by a certified abatement contractor.
Gypsum wallboard systems containing less than 1% asbestos content as a composite analysis require training and an exposure assessment (at a minimum) during disturbance to ensure employees are not exposed above the permissible exposure limit (PEL) of 0.1 fibers per cubic centimeter (f/cc) as defined in WAC 296-62-077.
Additional documentation, engineering controls, medical evaluations etc., may also be required. Employers (building owner, tenant, and/or contractors) shall verify current regulatory interpretation regarding these materials prior to disturbance. If the gypsum wallboard systems are removed intact WISHA Regional Directive (WRD) 23.30 must be followed.
If complete abatement of ACM is not performed, periodic surveillance should be performed by an AHERA accredited building inspector at least once every three years.
In addition, bi-annual surveillance should be performed by maintenance personnel trained by an AHERA building inspector.
September 16, 2011 16 Helix Design
WISHA requires ACM be removed by trained and licensed contractors using certified asbestos abatement workers and supervisors (except for deregulated roofing sealants, mastics, and coatings). A 10-day prior notification is also required before abatement can begin. In addition, PSCAA requires notification and fees prior to beginning removal.
WISHA and PSCAA require this survey report to be placed on-site during renovation and/or demolition and copies provided to the contractor(s) bidding and performing work.
Med-Tox Northwest recommends third party oversight of asbestos and demolition activities by an AHERA accredited building inspector to ensure regulatory compliance and completion of the additional destructive methods recommended herein.
Additionally, Med-Tox Northwest recommends requesting unit pricing from abatement contractors during the bidding process to adjust pricing depending on actual quantities verified in the field.
Lead-Based Paint
All painted surfaces should be assumed to contain at least trace levels of lead in paint, therefore requiring compliance with WAC 296-155-176 during any disturbance of painted surfaces. This requirement will apply to all construction trades, unless painted surfaces are removed during demolition activities, which is typically cost prohibitive.
Lead in paint was not significant in the subject building and is not a concern regarding hazardous waste disposal.
The WISHA criteria are used to determine if materials are hazardous during a demolition. For lead; any percentage found in the material should be an assumed risk to human health. Disposal options are also determined by whether the material contains lead. Some landfills cannot accept lead-containing wastes, even if they pass the leachability test.
The waste streams for Buildings 455 and 456 were determined to be less than the regulated level of 5.0 mg/L. The waste from this project can be disposed of as general construction debris.
PCB
PCB-containing paint on the door frames and concrete floor in building 455 will require remediation as a bulk PCB material. Since no soil was exposed, it is un-likely that PCB contamination is present below the concrete slab. Any remnant concrete with one part per million or more will require removal and disposal as a remediation waste. Med-Tox Northwest recommends testing of concrete substrates after remediation. EPA requires notification prior to PCB remediation including approval of the remediation plan.
September 16, 2011 17 Helix Design
The Air National Guard will need to obtain an EPA/State identification number for legal disposal of PCB’s and the hazardous waste manifest used to track disposal in accordance with 40 CFR 761.50, 40 CFR 761.62, and WAC 173-303. Additionally, work procedures for proper removal and protection of workers should be provided to contractors in accordance with WAC 296-155 and WAC 296-841.
During demolition, the asbestos abatement contractor should be tasked with dismantling light fixtures, checking for PCB-free labels, and recycling the light tubes. Ballasts without PCB-free labels are considered PCB-containing and must be disposed as a hazardous waste; all other light ballasts can be recycled. Additionally, light tubes can be recycled as a universal waste for minimal cost.
Other Hazardous Building Materials
Fluorescent light tubes contain mercury and can be recycled as a universal waste for minimal cost. Any HID, mercury vapor, exit lights, smoke detectors and mercury thermostats should be collected and recycled/disposed appropriately.
September 16, 2011 18 Helix Design
Limitations
This report is an instrument of service prepared for the exclusive use of Helix Design, and its contractors and may not be reproduced or distributed without written authorization from Helix Design. The services described in this report were performed consistent with generally accepted professional consulting principles and practices and in accordance with the practices and service scope elements recommended by AHERA for an Asbestos-Containing Materials Building Survey. No other warranty, expressed or implied, is made. These services were performed in accordance to our contractual agreement with Helix Design This report was prepared solely for the use and information of Helix Design, or as otherwise noted. Unauthorized use of this report is strictly prohibited and Med-Tox Northwest assumes no liability for such use.
This report has been prepared in order to aid in the evaluation of Building 455 and 456 with regard to the potential for the presence of asbestos-containing materials at the time of these building inventories. The conclusions presented in this report were based on available information pertaining to various points in time and were presented by others for use by Med-Tox Northwest or were based on informal discussion with various personnel. Med-Tox Northwest does not warrant the accuracy of information supplied by others.
The conclusions in this report may rely on others credibility and, therefore, an alteration in documentation or verbal information obtained may result in the redirection of the conclusions presented in this report. The conclusions are also based on visual field observations performed within the property boundaries at this specific point in time and, therefore, do not include the potential for hazardous materials present within undocumented activities occurring on the subject property or adjacent properties.
Opinions presented herein may be based on analysis performed by others and, therefore, Med-Tox Northwest is not responsible for variations in analytical results or inaccuracies resulting from laboratory analysis provided by subcontracted analytical laboratories.
This report reflects Med-Tox Northwest's observations of the condition of the property during the time of field activities, and does not cover conditions that may be found at some later time on the property that were not visible during these field activities.
September 8, 2011 A Helix Design
Appendix A AHERA Building Inspector and CTED Risk
Assessor Certificates
Michael D. Thomas - Administrator
September 8, 2011 B Helix Design
Appendix B Building and Building System Photographic
Documentation
Washington Air National Guard Buildings 455 and 456
September 16, 2011
Photo 1: Front (north side) of Building 455.
Photo 2: East side of building. The building is of wood frame construction with vinyl siding. The original cement asbestos board (CAB) siding is underneath the vinyl siding.
Photo 3: South side of the building.
Photo 4: Mechanical room of Building 455. The heating system for the building has been updated and the original system has been removed.
Photo 5: View of CAB underneath exterior vinyl siding.
Photo 6: Wood eve caulk located above the vinyl soffit. This material was determined to contain asbestos.
Photo 6: Interior of Building 455.
Photo 7: Interior architectural finishes of the office spaces of Building 455.
Photo 8: View of white fire-stop located at the wall penetration. This material was determined to contain 90% Chrysotile asbestos.
Photo 9: Ductwork located in office 1 with gray fire-stop located where the ductwork penetrates the wall. This material was determined to contain 3% Chrysotile asbestos.
Photo 10: Building 456 southwest side. This building is of the same construction type as Building 455.
Photo 11: This is the southeast side of building 456. This building has CAB siding underneath the vinyl siding as well.
Photo 12: View of the main work area of building 456.
Photo 13: The conference room floor in building 456. There is residual asbestos-containing black mastic underneath the tile floor that was determined to contain 3% Chrysotile asbestos and the 4-inch brown cove base mastic was also determined to contain 3% Chrysotile asbestos.
September 8, 2011 C Helix Design
Appendix C Summary of Materials Sampled for Asbestos
Hazardous Building Materials Survey—Buildings 455 and 456
April 21, 2016 C-1 Helix
Sample Material Location AHERA Type HM Result
Building 455
7187.2-AF-01 Un-textured gypsum wallboard system
Northwest entry, room 4
Misc. 01 Layer 1: ND Layer 2: 2% CHR Layer 3: ND <1% ACM as a composite
7187.2-AF-02 Un-textured gypsum wallboard system
Center work area, south wall
Misc. 01 ND
7187.2-AF-03 Un-textured gypsum wallboard system
South office area Misc. 01 ND
7187.2-AF-04 Gray epoxy floor paint Center work area Misc. 02 ND 7187.2-AF-05 Gray epoxy floor paint Center work area Misc. 02 ND 7187.2-AF-06 Gray epoxy floor paint Center work area Misc. 02 ND 7187.2-AF-07 Yellow carpet mastic with white leveling compound and residual black mastic
Northwest entry area
Misc. 03 ND
7187.2-AF-08 Yellow carpet mastic with white leveling compound and residual black mastic
Room 1 Misc. 03 ND
7187.2-AF-09 Yellow carpet mastic with white leveling compound
South center office
Misc. 03 ND
7187.2-AF-10 White window frame caulk-interior
South center office area
Misc. 04 ND
7187.2-AF-11 White window frame caulk-interior
Room 2 Misc. 04 ND
7187.2-AF-12 White window frame caulk-interior
Work area, east wall
Misc. 04 ND
7187.2-AF-13 12-inch gray mottled floor tile and mastic
Men’s Restroom Misc. 05 ND
7187.2-AF-14 12-inch gray mottled floor tile and mastic
Women’s Restroom
Misc. 05 ND
7187.2-AF-15 12-inch gray mottled floor tile and mastic
Men’s Restroom Misc. 05 ND
7187.2-AF-16 Yellow wall carpet mastic South center office area
Misc. 06 ND
7187.2-AF-17 Yellow wall carpet mastic South center office area
Misc. 06 ND
7187.2-AF-18 4-inch gray cove base and mastic
Room 2 Misc. 07 ND
7187.2-AF-19 4-inch gray cove base and mastic
Men’s Restroom Misc. 07 Layer 1: ND Layer 2: ND Layer 3: NE Layer 4: 2% CHR
7187.2-AF-20 4-inch gray cove base and mastic
Work area, south wall
Misc. 07 ND
7187.2-AF-21 Cement asbestos board
(CAB)
Exterior- north Misc. 08 15% CHR
7187.2-AF-22 Cement asbestos board
(CAB)
Exterior- south Misc. 08 15% CHR
7187.2-AF-23 Wood eve caulk- under vinyl soffit
Exterior- north Misc 09 Layer 1: ND Layer 2: 3% CHR
7187.2-AF-24 Wood eve caulk- under vinyl soffit
Exterior- north Misc 09 Layer 1: ND Layer 2: 3% CHR
April 21, 2016 C-2 Helix
7187.2-AF-25 Wood eve caulk- under vinyl soffit
Exterior- south Misc 09 Layer 1: ND Layer 2: 3% CHR
7187.2-AF-26 White wood window frame to vinyl siding caulk
Exterior-- north Misc. 10 ND
7187.2-AF-27 White wood window frame to vinyl siding caulk
Exterior-- east Misc. 10 ND
7187.2-AF-28 White wood window frame to vinyl siding caulk
Exterior-- south Misc. 10 ND
7187.2-AF-29 Brown aluminum window frame to wood caulk
Exterior- north Misc. 11 ND
7187.2-AF-30 Brown aluminum window frame to wood caulk
Exterior- east Misc. 11 ND
7187.2-AF-31 Brown aluminum window frame to wood caulk
Exterior-south Misc. 11 ND
7187.2-AF-32 Three tab roofing Roof Misc. 12 ND 7187.2-AF-33 Vapor barrier Roof Misc. 13 ND 7187.2-AF-34 Interior ducting to GWB wall fire stop- white, solid Room 1 TSI 14 Layer 1: ND
Layer 2: 90% CHR
7187.2-AF-35 Interior ducting to GWB wall fire stop- white, solid
Room 3 TSI 14 Layer 1: ND Layer 2: 90% CHR
7187.2-AF-36 Interior ducting to GWB wall fire stop- gray fibrous
Room 3 TSI 15 Layer 1: ND Layer 2: 3% CHR
7187.2-AF-37 Interior ducting to GWB wall fire stop- gray fibrous
Room 3 TSI 15 Layer 1: ND Layer 2: 3% CHR
7187.2-AF-38 Vapor barrier under CAB Exterior Misc. 16 ND 7187.2-AF-39 Vapor barrier under CAB Exterior Misc. 16 ND 7187.2-AF-40 Vapor barrier under CAB Exterior Misc. 16 Layer 1: ND
Layer 2: ND Layer 3: 2% CHR
Building 456
7187.2-AF-41 Un-textured gypsum drywall system
Conference room
Misc. 17 ND
7187.2-AF-42 Un-textured gypsum drywall system
Office 2 room Misc. 17 ND
7187.2-AF-43 Un-textured gypsum drywall system
Men’s restroom Misc. 17 ND
7187.2-AF-44 4-inch brown cove base and mastic
Work area Misc. 18 Layer 1: ND Layer 2: 3% CHR
7187.2-AF-45 4-inch brown cove base and mastic
Entry Misc. 18 Layer 1: ND Layer 2: 3% CHR
7187.2-AF-46 4-inch brown cove base and mastic
Conference room
Misc. 18 ND
7187.2-AF-47 2-inch cove base and mastic Men’s restroom Misc. 19 ND 7187.2-AF-48 2-inch cove base and mastic Women’s restroom Misc. 19 ND
7187.2-AF-49 2-inch cove base and mastic Restroom hallway
Misc. 19 ND
7187.2-AF-50 Gray floor paint Work area Misc. 20 ND 7187.2-AF-51 Gray floor paint Entry Misc. 20 ND 7187.2-AF-52 Gray floor paint Mechanical room Misc. 20 ND
7187.2-AF-53 Gray sheet vinyl flooring Women’s restroom
Misc. 21 ND
7187.2-AF-54 Gray sheet vinyl flooring Men’s restroom Misc. 21 ND
April 21, 2016 C-3 Helix
7187.2-AF-55 12-inch beige mottled vinyl floor tile and mastic
Conference room
Misc. 22 ND
7187.2-AF-56 12-inch beige mottled vinyl floor tile and mastic
Conference room
Misc. 22 ND
7187.2-AF-57 12-inch beige mottled vinyl floor tile and mastic
Conference room
Misc. 22 ND
7187.2-AF-58 Gray leveler on concrete under HM 22
Conference room
Misc. 23 Layer 1: ND Layer 2: ND Layer 3: 3% CHR Layer 4: ND Layer 5: ND
7187.2-AF-59 Gray leveler on concrete under HM 22
Conference room
Misc. 23 Layer 1: ND Layer 2: ND Layer 3: 3% CHR Layer 4: ND Layer 5: ND
7187.2-AF-60 Gray leveler on concrete under HM 22
Conference room
Misc. 23 ND
7187.2-AF-61 Light weight concrete patching material
Work area Misc. 24 ND
7187.2-AF-62 Light weight concrete patching material
Work area Misc. 24 ND
7187.2-AF-63 Carpet mastic Office 1 Misc. 25 ND 7187.2-AF-64 Carpet mastic Office 2 Misc. 25 ND 7187.2-AF-65 2-x-4 foot Acoustical ceiling tile- random crater and pin hole pattern
Conference Misc. 26 ND
7187.2-AF-66 2-x-4 foot Acoustical ceiling tile- random crater and pin hole pattern
Conference Misc. 26 ND
7187.2-AF-67 2-x-4 foot Acoustical ceiling tile- random crater and pin hole pattern
Conference Misc. 26 ND
7187.2-AF-68 Brown aluminum window frame to wood caulk
Exterior- north Misc. 27 ND
7187.2-AF-69 Brown aluminum window frame to wood caulk
Exterior- east Misc. 27 ND
7187.2-AF-70 Brown aluminum window frame to wood caulk
Exterior-south Misc. 27 ND
7187.2-AF-71 White wood window frame to vinyl siding caulk
Exterior-- east Misc. 28 ND
7187.2-AF-72 White wood window frame to vinyl siding caulk
Exterior-- south Misc. 28 ND
7187.2-AF-73 White wood window frame to vinyl siding caulk
Exterior-- south Misc. 28 ND
7187.2-AF-74 Cement asbestos board siding
Exterior Misc. 29 10% CHR
7187.2-AF-75 Cement asbestos…
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