1. WWTP Hazardous Materials Assessment, Nov 2024.pdf

HAZARDOUS MATERIALS ASSESSMENT

HAZARDOUS MATERIALS

ASSESSMENT

EIELSON WASTE WATER TREATMENT PLANT

REPAIR SCADA SYSTEM

EIELSON AFB, ALASKA

Surveyed November 5-7, 2024

Report Date

December 20, 2024

EHS-ALASKA, INC.

ENGINEERING, HEALTH & SAFETY CONSULTANTS

11901 BUSINESS BLVD., SUITE 208

EAGLE RIVER, ALASKA 99577-7701

EIELSON WASTE WATER TREATMENT PLANT REPAIR SCADA SYSTEM

TABLE OF CONTENTS

PAGE NO.

OVERVIEW

A. GENERALIZED REQUIREMENTS FOR HAZARDOUS MATERIALS

B. BUILDING DESCRIPTION

C. SAMPLING AND ANALYSIS

1. Asbestos-Containing Materials

2. Lead-Containing Materials

3. Testing of Paints and Sealants for PCB’s

D. SURVEY RESULTS

1. Asbestos-Containing Materials

2. Asbestos in Dusts

3. Lead-Containing Materials

4. PCB-Containing Materials

5. Mercury-Containing Materials

6. Other Hazardous Materials

E. REGULATORY CONSTRAINTS

1. Asbestos-Containing Materials

2. Dusts with Asbestos

3. Lead-Containing Materials

4. PCB-Containing Materials

5. Mercury-Containing Materials

6. Other Hazardous Materials

F. RECOMMENDATIONS

1. Asbestos-Containing Materials

2. Dusts with Asbestos

3. Lead-Containing Materials

4. PCB-Containing Materials

5. Mercury-Containing Materials

6. Other Hazardous Materials

G. LIMITATIONS

1. Accuracy of Information

2. Site Conditions

3. Changing Regulatory Constraints

APPENDICES

Appendix A ......................................................... Asbestos Bulk Field Survey Data Sheets and Lab Reports Appendix B ................................................... Bulk Product PCB Field Survey Data Sheets and Lab Reports Appendix C .......................................................................................................... Lead Analyzer Test Results Appendix D ..................................................................................................... Drawings of Sample Locations

EIELSON WASTE WATER TREATMENT PLANT REPAIR SCADA SYSTEM

OVERVIEW

The Waste Water Treatment Plant (B2316), Digester Building (B2317), Final Effluent Sampling House (B2320), Effluent Sampling Building (B2321), Miox Building (B2322), and the Blower Building (B2324), herein referenced as the Waste Water Treatment Plant buildings, located in Eielson Air Force Base, Alaska, were surveyed for the presence of asbestos-containing materials (ACM), and other potentially hazardous materials as a part of the design services for the Eielson Waste Water Treatment Plant Repair SCADA System Project for the United States Air Force. The survey also provided a “good faith” inspection for hazardous materials that may be disturbed during the construction. The proposed work includes the disturbance, demolition, removal and disposal of lead-containing paints and/or lead-containing materials that is incidental to the renovation and remodeling project. Mr. John H. Lamont of EHS-Alaska, Inc. (EHS-Alaska) conducted the inspections in November 2024. It will be the contractor’s responsibility to take this baseline data, and to conduct hazardous materials removal in compliance with all regulatory requirements. This assessment includes data from previous inspections of the facility.

A. GENERALIZED REQUIREMENTS FOR HAZARDOUS MATERIALS

Potentially hazardous materials have been identified in the Waste Water Treatment Plant buildings that will be affected by the proposed renovations. Those materials include asbestos, lead, polychlorinated bi-phenyls (PCBs), mercury, and radioactive materials. Not all materials were tested for potentially hazardous components, other potentially hazardous materials, including those exterior to the buildings, such as contamination from underground fuel tanks may be present, but are not part of this report.

Buildings or portions of buildings that were constructed prior to 1978 which are residences, or contain day care facilities, kindergarten classes or other activities frequently visited by children under 6 years of age are classified as child occupied facilities. All work which is NOT classified as “minor repair and maintenance activities” (as defined by the regulations), that takes place in the “child occupied” portions of facilities must comply with the requirements of 40 CFR 745. These buildings are not classified as a child occupied facilities and therefore the requirements of 40 CFR 745 are not applicable.

Only the materials that will be directly affected by this project are required to be removed. The quantities and types of materials are incorporated into the design documents for this renovation. The removal and disposal of potentially hazardous materials are highly regulated, and it is anticipated that removal and disposal of asbestos, lead and chemical hazards will be conducted by a subcontractor to the general contractor who is qualified for such removal. It is anticipated that the general contractor and other trades will be able to conduct their work using engineering controls and work practices to control worker exposure and to keep airborne contaminants out of occupied areas of the buildings.

Settled and concealed dusts in areas not subject to routine cleaning are present throughout the buildings, including the roof, and inside and on top of architectural, mechanical, electrical, and structural elements, and those dusts are assumed to contain regulated air contaminants. This should not be read to imply that there is an existing hazard to building occupants (normal occupants of the building as opposed to construction workers working in the affected areas). However, depending on the specific work items involved and on the means and methods employed when working in the affected areas, construction workers could be exposed to regulated air contaminants from those dusts in excess of the OSHA Permissible Exposure Limits (PELs).

The settled and concealed dusts were examined by an EPA Certified Building Inspector but were not sampled. The inspector determined that the dusts are not “asbestos debris” from an asbestos-containing building material (ACBM). Based on similar sampling from similar buildings, the inspector also determined that the dusts are unlikely to contain more than one percent (1%) asbestos by weight, and therefore are not an asbestos-containing material (ACM). Reference 40 CFR 763.83.

“Awareness training” (typically 2 hours) and possibly respiratory protection will be required for all Contractor Personnel who will be disturbing the dusts. The extent of the training and protective measures will depend upon the airborne concentrations measured during air monitoring of the contractors work force, which depends on the means and methods employed to control the dusts. The air monitoring may be discontinued following a “negative exposure assessment” showing that worker exposures are below the OSHA permissible exposure limits for the type of work and means and methods employed. Previous air monitoring from similar jobs with similar conditions may be used as historical data to establish a “negative exposure assessment”.

B. BUILDING DESCRIPTION

The Waste Water Treatment Plant was originally constructed in 1952, and the Digester Building was originally constructed in 1996, both with various upgrades and repairs through the years. EHS-Alaska was not provided the construction history on the other buildings (B2320, B2321, B2322, and B2324) related to the project.

Waste Water Treatment Plant Building 2316

The interior partitions were primarily of framed construction, concrete masonry unit (CMU) block walls, and poured concrete walls. The interior office area walls were typically of gypsum wallboard.

The exterior walls were of CMU block walls with an Exterior Insulation Finishing System (EIFS) on the exterior finish. The roofs were typically of concrete or steel beams and open web steel joists supporting a metal deck.

The corridor and office ceilings were typically of 2’ x 4’ acoustic ceiling tiles. The toilet rooms had gypsum wallboard ceilings. The rest of the building typically had exposed roof deck ceilings.

Floor finishes in the office and corridor areas were mainly of vinyl composition tile on concrete. The toilet rooms had glazed ceramic tiles. The rest of the building typically had exposed concrete floor finishes.

The building was heated by a hydronic heating system combined with various fan coil units supplying ventilation and heating. The heating and domestic water piping was typically insulated with fiberglass.

Digester Building 2317

The interior walls were primarily concrete masonry unit (CMU) block walls and poured concrete walls.

The exterior walls were of CMU block walls and poured concrete. The roof structure was typically of concrete. Ceilings were typically exposed concrete decking and floor finishes typically had exposed concrete floors. The building was heated by a hydronic heating system. The heating piping was typically insulated with fiberglass.

Final Effluent Sampling House Building 2320

The exterior walls were of CMU block walls and EIFS. The roof is assumed to be of wood joists supporting a plywood deck. The ceiling was unfinished plywood paneling, and the floor finishes were of exposed concrete. The building was heated by a hydronic heating system and the piping was insulated with fiberglass.

Effluent Sampling Building 2321

The lower portion (approximately 2 and a half feet from finish floor) of the exterior walls were of CMU block walls with the remaining upper portion being of framed construction and EIFS. The roof is assumed to be of wood joists supporting a plywood deck. The ceiling was unfinished plywood paneling, and the floor finishes were of exposed concrete. The building was heated by an electric unit heater.

Miox Building 2322

The exterior walls were of CMU block walls with an EIFS. The roof was of open web steel joists supporting a metal deck. Ceilings were exposed to the metal decking and the floor finishes were of exposed concrete. The building was heated by various electric unit heaters and had an air handling unit in the tank room.

Blower Building 2324

The exterior walls were of CMU block walls with an EIFS. The roof was of open web steel joists supporting a metal deck. Ceilings were exposed to the metal decking and the floor finishes were of exposed concrete. The building was heated by various electric unit heaters.

C. SAMPLING AND ANALYSIS

1. Asbestos-Containing Materials

The survey included sampling of suspect ACM materials that had not been sampled in prior asbestos surveys, or samples of materials where previous sampling had been inconsistent. Refer to the asbestos management plan available for review in the offices for information on previous sampling which is not included in this report. Additional testing of materials pertinent to the project, including asbestos and lead was conducted and is included in this report.

The samples were analyzed for the presence of asbestos using polarized light microscopy (PLM), analysis, as recommended by EPA, to determine the composition of suspected ACMs (EPA method 600/M4-82-020). Only materials containing more than 1% total asbestos were classified as “asbestos-containing” based on EPA and OSHA criteria. Samples analyzed to have less than 10% asbestos were “point-counted” by the laboratory for more accuracy. Samples listed as having a “Trace by Point Count” had asbestos fibers found in the material, but the fibers were not present at the counting grids. Table 1 in Part D below contains a summary list of the asbestos bulk samples and the applicable results.

The Bulk Asbestos samples were analyzed for asbestos content by International Asbestos Testing Laboratories (IATL), Mt. Laurel, New Jersey, a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory.

EPA regulations under 40 CFR 763 require the use of PLM to determine whether or not a material contains asbestos. While PLM analysis does a good job for most materials, it does have some limitations. Fibers may be undetectable if their small size prevents visibility under a standard optical microscope, or if they are bound in an organic matrix to the point that the fibers are obscured. At the discretion of the building inspector and the client, some types of samples may be analyzed or re-analyzed by what is called Transmission Electron Microscopy for Non-Friable Organically Bound (TEM NOB) materials. TEM NOB is the definitive method for determining if asbestos is present, but TEM NOB use is not required by the EPA. TEM NOB analysis was not done for this project.

Field survey data sheets and laboratory reports of the bulk samples are included in Appendix A.

Drawings showing sample locations are included as Appendix D.

2. Lead-Containing Materials

Nearly all surfaces in the building were coated with paint and most surfaces had been repainted. EHS- Alaska tested representative paints throughout the affected areas of the building using a SciAps X-550 Pb X-Ray Fluorescence (XRF) lead paint analyzer (Serial # 01052 with firmware version 2.6.1.4). The lead testing conducted was not a Lead-Based Paint Inspection or Screening as defined by Department of Housing and Urban Development (HUD) or EPA regulations, but was done to test surfaces that may be representative of those likely to be affected by this project. If surfaces and materials other than those tested are identified, the Contractor shall test and treat appropriately. Refer to the Lead Analyzer Test Results Table in Appendix C that identifies the surfaces tested, and the results. The Lead Test Locations are shown in Appendix D.

EPA and HUD have defined lead-based paint as any paint or other surface coating that contains lead equal to or in excess of 1.0 milligram per square centimeter (mg/cm2) or 0.5 percent by weight. XRF results are classified as positive (lead is present at 1.0 mg/cm2 or greater), negative (less than 1.0 mg/cm2 of lead was present) or inconclusive (the XRF could not make a conclusive positive or negative determination). Tests that were invalid due to operator error are shown as void tests.

A Performance Characteristic Sheet (PCS) for the SciAps X-550 Pb is available upon request. This PCS data provides supplemental information to be used in conjunction with Chapter 7 of the “HUD Guidelines”.

Performance parameters provided in the PCS are applicable when operating the instrument using the manufacturer’s instructions and the procedures described in Chapter 7 of the “HUD Guidelines”. The instrument was operated in accordance with manufacturer’s instructions and Chapter 7 of the HUD Guidelines. No substrate correction is required for this instrument. There is no inconclusive classification for this instrument when using the 1.0 mg/cm2 threshold.

3. Testing of Paints and Sealants for PCB’s

Representative paint and sealant samples were collected from throughout the Waste Water Treatment Plant (B2316 and B2317) and analyzed for total PCBs. Samples of paint were collected by scraping the paint down to bare substrate, or by cutting out a portion of the sealants. Samples were analyzed for total PCBs by EMSL Analytical, Inc, 200 Route 130 North, Cinnaminson, New Jersey. Results of the total PCB analysis for each sample was used to determine if the dried paint or sealants are considered PCB bulk product waste. Field Survey Data Sheets and Lab results are included in Appendix B. Drawings showing sample locations is provided in Appendix D.

D. SURVEY RESULTS

1. Asbestos-Containing Materials

Building 2316

The following Table 1A lists the samples taken in November 2024 in Waste Water Treatment Plant Building 2316, and the results of the laboratory analysis. Asbestos field survey data sheets and laboratory reports are included as Appendix A. Refer to Appendix D for sample locations.

TABLE 1A

SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B2316-2411- A01

White joint compound; with white tape

Office 104: West wall above suspended ceiling system on gypsum wall board. Photo 11 11/06

Both Layers None Detected

SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B2316-2411- A02

Red “Firestop” Office 104: West wall above suspended ceiling system at channel bracing penetration through gypsum wall board.

Photo 14 11/06

None Detected

B2316-2411- A03

Green “Firestop” Office 104B: West wall above suspended ceiling system at conduit penetration through gypsum wall board. Photo 16 11/06

None Detected

B2316-2411- A04

LCT-2: 2’x4’ straight edge acoustic ceiling tile with random 1/4" fissures and random 1/8” dense dots

Office 104: Acoustic ceiling tile in suspended ceiling system.

Photo 18 11/06

None Detected

B2316-2411- A05

White joint compound; with CB-1: beige 4” vinyl cove base; with cream mastic

Vestibule 101: South wall left side of exterior door, vinyl cove base over metal nosing over gypsum wall board. Photo 24 11/06

All Layers None Detected

B2316-2411- A06

FT-1: 12”x12” off-white with beige streaks vinyl floor tile;

with tan mastic

Vestibule 101: South wall left side of threshold, vinyl floor tile over concrete. Photo 26 11/06

Both Layers None Detected

B2316-2411- A07

White sealant Vestibule 101: South wall left side of exterior door, white sealant between metal door frame and gypsum wall board.

Photo 29 11/06

None Detected

B2316-2411- A08

White joint compound; with white gypsum wall board;

with CB-1: beige 4” vinyl cove base; with cream mastic

Corridor 102: South wall right side of door, vinyl cove base over gypsum wall board. Photo 35 11/06

All Layers None Detected

B2316-2411- A09

FT-1: 12”x12” off-white with beige streaks vinyl floor tile;

with tan mastic

Corridor 102: South wall right side of threshold, vinyl floor tile over concrete. Photo 36 11/06

Both Layers None Detected

B2316-2411- A10

Beige faux wood linoleum flooring; over light grey unknown vinyl floor tile; with tan mastic

Controls Room 104B: South wall left side of threshold to controls room, multiple layers of flooring over unknown substrate.

Photo 41 11/06

All Layers None Detected

B2316-2411- A11

CB-2: dark grey 4” vinyl cove base; with cream mastic; with tan mastic

Controls Room 104B: South wall left side of door, vinyl cove base over gypsum wall board.

Photo 42 11/06

All Layers None Detected

B2316-2411- A12

White sealant Bathroom 105: North wall left side of sink, sealant between ceramic sink and ceramic wall tile. Photo 54 11/06

None Detected

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B2316-2411- A13

Grey penetration putty Garage 103: North wall at conduit penetration through CMU block wall. Photo 69 11/06

None Detected

B2316-2411- A14

Hard black sealant Laboratory 109: Hard black sealant at black “Transite” countertop on south wall of room. Photo 105 11/06

None Detected

B2316-2411- A15

Black cementitious lab countertop

Laboratory 109: Black “Transite” countertop on west wall of room next to fume hood. Photo 110 11/06

None Detected

B2316-2411- A16

White semi-fibrous fume hood enclosure panel

Laboratory 109: White enclosure material inside of fume hood. Photo 114 11/06

None Detected

B2316-2411- A17

LCT-1: 2’x4’ straight edge acoustic ceiling tile with 1/4” to 1/2” random fissures and random 1/16” to 1/8” dense dots

Laboratory 109: Southeast corner of Lab, acoustic ceiling tile in suspended ceiling system.

Photo 116 11/06

None Detected

B2316-2411- A18

CB-3: maroon 4” vinyl cove base; with cream mastic

Laundry 111: East wall left side of door, vinyl cove base over gypsum wall board. Photo 122 11/06

Both Layers None Detected

B2316-2411- A19

FT-2: 12”x12” white with black speckles vinyl floor tile;

with cream mastic

Laundry 111: Left side of threshold to room, vinyl floor tile over concrete. Photo 123 11/06

Both Layers None Detected

B2316-2411- A20

Grey duct seam sealant Lower Level Clarifier Room:

East wall of lower room, sealant on rectangular metal duct.

Photo 143 11/06

None Detected

B2316-2411- A21

Red gasket material Utilidor Connecting Lower Clarifier Room to Lower Digester Room: Red gasket between metal flanges. Photo 151 11/06

None Detected

B2316-2411- A22

Grey cementitious grout Utilidor Connecting Lower Clarifier Room to Lower Digester Room: North wall closer to Clarifier Room, grout at penetration through concrete wall. Photo 154 11/06

None Detected

B2316-2411- A23

Black gasket material Lower Level Digester Room:

Black gasket between metal flanges. Photo 170 11/06

None Detected

B2316-2411- A24

Red gasket material Lower Level Digester Room:

Red gasket between metal flanges. Photo 172 11/06

None Detected

B2316-2411- A25

Silver sealant Middle Level Digester Room:

South wall, silver sealant on concrete wall. Photo 181 11/06

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B2316-2411- A26

Grey sealant Dry Well 114: North wall, left side of metal rectangular duct through concrete wall. Photo 191 11/06

None Detected

B2316-2411- A27

White duct wrap Boiler Room II 119: Rectangular metal duct through west wall of room, white duct wrap under silver foil over metal duct. Photo 248 11/07

None Detected

B2316-2411- A28

White sealant Generator Room 120: West wall at pipe penetration through CMU block wall. Photo 263 11/07

None Detected

B2316-2411- A29

Black rubber gasket Office 104: Window on east wall of room, rubber gasket between glazing and vinyl. Photo 437 11/07

None Detected

B2316-2411- A30

White sealant Office 104: South wall of office room, at chair rail and gypsum wall board. Photo 440 11/07

None Detected

B2316-2411- A31

Grey expansion joint sealant Garage 103: Expansion joint sealant between concrete pads.

Photo 445 11/07

None Detected

The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos containing, confirmation should be made by quantitative transmission electron microscopy (TEM).

The following materials in Building 2316 have been found to contain asbestos in this or previous surveys, or were assumed to contain asbestos.

1. Assumed hidden above ceilings, behind walls, and in pipe chases hard insulation at end caps of pipe valves and fittings (assumed asbestos-containing).

2. Exterior tarry damp-proofing (assumed asbestos-containing).

3. High temperature wiring insulation at lights (assumed asbestos-containing).

4. Boiler gaskets and stack insulation (assumed asbestos-containing).

5. Remnants of asbestos-containing patching tars and sealants (assumed asbestos-containing).

6. Flange gaskets on piping (assumed asbestos-containing).

The effects of the above asbestos-containing materials in Building 2316 on the proposed renovation are discussed below.

Pipe Insulation All piping inspected in the project areas were insulated with fiberglass insulation. Although no asbestos was detected, piping was concealed above ceilings and walls in some areas. Due to the age of construction, some concealed asbestos-containing insulation may be uncovered during demolition. If any concealed piping is found to have hard and chalky or other insulation suspected of containing asbestos, those materials shall be sampled prior to disturbance.

Exterior Foundation Wall Damp-proofing Sealant The foundation water-proofing is assumed to contain asbestos. The sealants are assumed to be not friable and in good condition. The tarry sealants are unlikely to be disturbed by this project.

High Temperature Wiring Insulation High Temperature Wiring Insulation is assumed have asbestos-containing insulation. The wiring was assumed to be present at older incandescent light fixtures, and at high temperature heating equipment.

Wiring insulation is typically not friable, and are unlikely to be disturbed by this project.

Boiler Gaskets and Sealants Due to their age, gaskets and sealants on the boilers are assumed to be asbestos-containing. These materials are difficult to sample without disassembly of equipment and consequently limited sampling was performed. These materials were in good condition but may become friable during removal for replacement. The gaskets and sealants are unlikely to be disturbed by this project.

Roofing Roofing over this portion of the building is a rubberized EPDM type roof which does not contain asbestos.

However residual mastic from the original roof may still exist beneath the newer roof on the roof deck and on flashing and other equipment penetrating the roof deck. The roofing materials are unlikely to be disturbed by this project.

Flange Gaskets and Valve Packing Due to their age, gaskets and valve packing on mechanical equipment throughout the buildings, but mostly in mechanical rooms are assumed to be asbestos-containing. These materials are difficult to sample without disassembly of equipment and consequently limited sampling was performed. These materials were in good condition but may become friable during removal for replacement. The gaskets and packings may be disturbed by this project.

Building 2317

Table 1B includes samples taken in November 2024 in Digester Building 2317, and the results of the laboratory analysis. Asbestos field survey data sheets and laboratory reports are included in Appendix A.

Refer to Appendix E for sample locations.

TABLE 1B

SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B2317-2411- A01

Black damp proofing Digester Utilidor: West wall adjacent to exit vestibule, black damp proofing on concrete wall.

Photo 285 11/07

None Detected

B2317-2411- A02

Black tar and black tar paper

**IGNORE YELLOW

INSULATION**

Digester Utilidor: Right side utilidor, first room on right, black tar and tar paper between concrete lid and insulation.

Photo 288 11/07

None Detected

B2317-2411- A03

Black tar; with tan tar paper Digester Utilidor: Right side utilidor, second room on the right, black tar adhering tar paper to insulation. Photo 290 11/07

Both Layers None Detected

B2317-2411- A04

Silver foil with white duct wrap

Digester Utilidor: Main room at rectangular metal duct on west wall of room. Photo 305 11/07

None Detected

B2317-2411- A05

Red gasket material; with black tar

Digestor Utilidor: Left side utilidor, room on the right, red gasket between metal flanges.

Photo 310 11/07

Both Layers None Detected

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B2317-2411- A06

Silver foil; with black tar and tan tar paper

Digestor Utilidor: Left side utilidor, room on the right, silver foil over insulation at concrete ceiling. Photo 313 11/07

Both Layers None Detected

The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos containing, confirmation should be made by quantitative transmission electron microscopy (TEM).

The following materials in Building 2317 have been found to contain asbestos in this or previous surveys,

1. High temperature wiring insulation at lights (assumed asbestos-containing).

2. Exterior tarry damp-proofing (assumed asbestos-containing).

3. Flange gaskets on piping (assumed asbestos-containing).

The effects of the above asbestos-containing materials in Building 2317 on the proposed renovation are

High Temperature Wiring Insulation High Temperature Wiring Insulation is assumed have asbestos-containing insulation. The wiring was assumed to be present at older incandescent light fixtures and at high temperature heating equipment.

Wiring insulation is typically not friable, and are unlikely to be disturbed by this project.

Exterior Foundation Wall Damp-proofing Sealant The foundation water-proofing is assumed to contain asbestos. The sealants are assumed to be not friable and in good condition. The tarry sealants are unlikely to be disturbed by this project.

Flange Gaskets and Valve Packing Due to their age, gaskets and valve packing on mechanical equipment throughout the building, but mostly in mechanical rooms are assumed to be asbestos-containing. These materials are difficult to sample without disassembly of equipment and consequently limited sampling was performed. These materials were in good condition but may become friable during removal for replacement. The gaskets and packings are unlikely to be disturbed by this project.

Building 2320

Table 1C includes samples taken in November 2024 in the Final Effluent Sampling House Building 2320 and the results of the laboratory analysis. Asbestos field survey data sheets and laboratory reports are included in Appendix A. Refer to Appendix E for sample locations.

TABLE 1C

SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B2320-2411- A01

White sealant Interior: Left side of door, sealant between CMU block wall and metal door frame. Photo 389 11/07

None Detected

B2320-2411- A02

Beige sealant Exterior: Right side of door, sealant between EIFS exterior wall and metal door frame. Photo 392 11/07

None Detected

The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos

The following materials in Building 2320 have been found to contain asbestos in this or previous surveys,

1. Exterior tarry damp-proofing (assumed asbestos-containing).

The effects of the above asbestos-containing materials in Building 2320 on the proposed renovation are discussed below.

Exterior Foundation Wall Damp-proofing Sealant The foundation water-proofing is assumed to contain asbestos. The sealants are assumed to be not friable and in good condition. The tarry sealants are unlikely to be disturbed by this project.

Building 2321

Table 1D includes samples taken in November 2024 in Effluent Pumping Building 2321, and the results of the laboratory analysis. Asbestos field survey data sheets and laboratory reports are included in Appendix A. Refer to Appendix E for sample locations.

TABLE 1D

SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B2321-2411- A01

Silver vapor barrier; with black tar paper

Controls Room: Left side of door, vapor barrio between gypsum wall board and EIFS.

Photo 324 11/07

None Detected

B2321-2411- A02

White sealant Controls Room: South wall, sealant between wood wall panels. Photo 326 11/07

None Detected

B2321-2411- A03

Grey sealant Control Room: Sealant at penetration at top of metal utility box on south side of room.

Photo 328 11/07

None Detected

B2321-2411- A04

Beige sealant Exterior: Left side of door, sealant between EIFS and metal door frame. Photo 332 11/07

None Detected

The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos

The following materials in Building 2321 have been found to contain asbestos in this or previous surveys,

2. Flange gaskets on piping (assumed asbestos-containing).

The effects of the above asbestos-containing materials in Building 2321 on the proposed renovation are

Exterior Foundation Wall Damp-proofing Sealant The foundation water-proofing is assumed to contain asbestos. The sealants are assumed to be not friable and in good condition. The tarry sealants are unlikely to be disturbed by this project.

Flange Gaskets and Valve Packing Due to their age, gaskets and valve packing on mechanical equipment throughout the building, but mostly in mechanical rooms are assumed to be asbestos-containing. These materials are difficult to sample without disassembly of equipment and consequently limited sampling was performed. These materials were in good condition but may become friable during removal for replacement. The gaskets and packings are unlikely to be disturbed by this project.

Building 2322

Table 1E includes samples taken in November 2024 in Miox Building 2322, and the results of the laboratory analysis. Asbestos field survey data sheets and laboratory reports are included in Appendix A.

Refer to Appendix E for sample locations.

TABLE 1E

SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B2322-2411- A01

Beige sealant Exterior: South entrance door, right side of door, sealant between EIFS and metal door frame. Photo 351 11/07

None Detected

B2322-2411- A02

White sealant South Room: South entrance door, right side of door, sealant between gypsum wall board and metal door frame. Photo 356 11/07

None Detected

B2322-2411- A03

Green gasket North Room: Metal piping on north wall of room, gasket between metal flanges. Photo 370 11/07

None Detected

B2322-2411- A04

Grey sealant North Room: Sealant at metal pipe fittings on north wall of room. Photo 372 11/07

None Detected

B2322-2411- A05

Off-white/grey sealant North Room: Sealant at metal pipe fittings on north wall of room. Photo 374 11/07

None Detected

B2322-2411- A06

White sealant North Room: North entrance door, right side of door, sealant between gypsum wall board and metal door frame. Photo 377 11/07

None Detected

The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos

The following materials in Building 2322 have been found to contain asbestos in this or previous surveys,

1. Flange gaskets on piping (assumed asbestos-containing).

2. Exterior tarry damp-proofing (assumed asbestos-containing).

3. Generator gaskets and sealants (assumed asbestos-containing).

4. Metal roofing sealants and patching tars (assumed asbestos-containing).

The effects of the above asbestos-containing materials in Building 2322 on the proposed renovation are

Metal Roofing Sealants and Patching Tars Roofing over the building is a standing seam roof. The roofing was not inspected, because it was not planned for disturbance. The standing seams are assumed to have asbestos-containing sealants.

Patching tars and sealants which are assumed to be present at flashings, vents, and other equipment penetrating the roofing are assumed to contain asbestos. The roofing materials are unlikely to be disturbed by this project.

Exterior Foundation Wall Damp-proofing Sealant The foundation water-proofing is assumed to contain asbestos. The sealants are assumed to be not friable and in good condition. The tarry sealants are unlikely to be disturbed will be partially removed by this project.

Generator Gaskets and Sealants Due to their age, gaskets and sealants on the generators are assumed to be asbestos-containing. These materials are difficult to sample without disassembly of equipment and consequently limited sampling was performed. These materials were in good condition but may become friable during removal for replacement. The gaskets and sealants are unlikely to be disturbed by this project.

Flange Gaskets and Valve Packing Due to their age, gaskets and valve packing on mechanical equipment throughout the buildings, but mostly in mechanical and fan rooms are assumed to be asbestos-containing. These materials are difficult to sample without disassembly of equipment and consequently limited sampling was performed. These materials were in good condition but may become friable during removal for replacement. The gaskets and packings are unlikely to be disturbed will be partially removed by this project.

Building 2324

Table 1F includes samples taken in November 2024 in Blower Building 2324, and the results of the laboratory analysis. Asbestos field survey data sheets and laboratory reports are included in Appendix A.

Refer to Appendix E for sample locations.

TABLE 1F

SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B2322-2411- A01

Beige sealant Exterior: North entrance door, right side of door between EIFS and metal door frame. Photo 337 11/07

None Detected

B2322-2411- A02

White gasket Middle Generator: White gasket between metal flanges.

Photo 345 11/07

70% Chrysotile

B2322-2411- A03

Red gasket North Generator: Red gasket between metal flanges. Photo 347 11/07

None Detected

The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos

The following materials in Building 2324 have been found to contain asbestos in this or previous surveys,

2. Metal roofing sealants and patching tars (assumed asbestos-containing).

3. Flange gaskets on piping (confirmed asbestos-containing).

The effects of the above asbestos-containing materials in Building 2324 on the proposed renovation are

Exterior Foundation Wall Damp-proofing Sealant The foundation water-proofing is assumed to contain asbestos. The sealants are assumed to be not friable and in good condition. The tarry sealants are unlikely to be disturbed by this project.

Metal Roofing Sealants and Patching Tars Roofing over the building is a standing seam roof. The roofing was not inspected, because it was not planned for disturbance. The standing seams are assumed to have asbestos-containing sealants.

Patching tars and sealants which are assumed to be present at flashings, vents, and other equipment penetrating the roofing are assumed to contain asbestos. The roofing materials are unlikely to be disturbed by this project.

Flange Gaskets and Valve Packing Gaskets and valve packing on mechanical equipment throughout the building are confirmed to be asbestos-containing. These materials are difficult to sample without disassembly of equipment and consequently limited sampling was performed. These materials were in good condition but may become friable during removal for replacement. The gaskets and packings are unlikely to be disturbed by this project.

2. Asbestos in Dusts

The settled and concealed dusts were examined by an EPA Certified Building Inspector but no samples for asbestos in dusts were authorized for this project. Based on their visual inspection and experience from similar buildings, the inspector determined that the typical settled and concealed dusts are not “asbestos debris” from an asbestos-containing building material (ACBM). Based on similar sampling from similar buildings, the inspector also determined that the dusts are unlikely to contain more than one percent (1%) asbestos by weight, and therefore are not an asbestos-containing material (ACM).

3. Lead-Containing Materials

Lead-Testing EHS-Alaska tested paint and other materials throughout the affected areas of the building using a SciAps XRF lead paint analyzer. Lead in paints tested varied from a trace amount to 2.5 mg/cm2. Lead in other materials tested varied from a trace amount to 0.19 mg/cm2. Refer to the Lead Analyzer Test Results Table in Appendix C that identifies the surfaces tested, and the results. The Lead Test Locations are shown in the Drawings in Appendix D.

Paints There were varying lead contents found in the paints, based on what surfaces they are on, with most surfaces containing little lead (but are still classified as lead-containing materials by OSHA). The highest levels of lead were found on original concrete walls and original cement masonry unit block walls, with lower levels on walls and other painted surfaces, and lowest levels on pre-finished materials.

Lead based paints (paint containing more than 1.0 mg/cm2 of lead) were identified in the project on the original construction concrete walls and cement masonry unit block walls. It is anticipated that other older walls may be painted with lead-based paint. It is anticipated that other walls, floors and ceilings may be painted with lead-based paint. Lead was detected at very low levels in most of the painted floor, newer wall and newer ceiling surfaces. XRF testing is not able to “prove” that “no” lead exists in the paint. Low levels of lead found by XRF testing does not mean that the paints are free of lead, the paints may contain lead. At least an initial exposure determination of potential worker exposures for all disturbance of lead-containing materials is required unless laboratory analysis shows that there is zero detectable lead in the materials being disturbed (which requires special analysis). However, these paints may not present a hazard to occupants or workers performing renovation or demolition if lead-safe work practices are followed.

Metallic Lead in Batteries, Pipe Solder and Flashing Metallic lead items identified in the building included lead soldering at the lead solder at copper piping, and poured lead sealants at bell and spigot joints of waste and vent piping and lead acid batteries in emergency lights and other battery backup equipment. If removed during renovation or demolition they should be recycled or disposed of as hazardous waste.

Lead Dusts The settled and concealed dusts were examined but no samples for lead in dusts were authorized for this project. Based on their visual inspection and similar sampling from similar buildings, the inspector also determined that the dusts are likely to have measurable concentrations of lead in the dusts.

4. PCB-Containing Materials

Light Ballasts Older fluorescent lights typically have PCB-containing ballasts. PCB-containing ballasts in fluorescent lights were banned in 1978, but manufacturers were allowed to use up existing stocks, and lights may have been reused from other facilities. The survey included examination of what were considered to be representative light fixtures, but not all fixtures were able to be accessed. All lights shall be inspected during removal or relocation. Unless ballasts were marked “No PCBs,” they must be assumed to contain PCBs and must be disposed of as a hazardous waste when removed for disposal. Fluorescent light fixtures with PCB-containing ballasts are assumed to be present in the building. The fluorescent light fixtures are unlikely to be disturbed by this project.

Older HID lights may have PCB-containing ballasts. Due to height restrictions and sealed ballast enclosures, the HID fixtures were not able to be accessed. All HID lights shall be inspected during removal or relocation. If ballasts are not marked “No PCBs,” we suggest contacting the manufacturer of the lights to determine if the ballasts contain PCB’s, or assume that they contain PCB’s and be disposed of as a hazardous waste. The HID light fixtures are unlikely to be disturbed by this project.

Bulk Products Representative paint and sealant samples were collected from the Waste Water Treatment Plant Building 2316 and 2317.

The following Table 2A summarizes the PCB Bulk samples taken November 2024 by EHS-Alaska, Inc.

Field Survey Data Sheets and Lab results are included in Appendix B. Refer to Appendix E for sample locations.

TABLE 2A

SAMPLE

NUMBER MATERIAL LOCATION TOTAL PCB

CONCENTRATION

B2316-2411-

PCB01

White paint on gypsum wall board

Office 104: North wall above suspended ceiling system adjacent to Controls 104B, paint on gypsum wall board. Photo 31 11/06

None Detected

B2316-2411-

PCB02

White paint on CMU block wall

Garage 103: East wall, painted CMU block wall. Photo 63 11/06

None Detected

B2316-2411-

PCB03

White paint over beige paint over blue paint over grey paint over green paint on concrete wall

UPS Room 112: East wall, painted concrete wall. Photo 86 11/06

3.53 ppm

NUMBER MATERIAL LOCATION TOTAL PCB

CONCENTRATION

B2316-2411-

PCB04

White paint over beige paint over silver paint on concrete wall

Lab 109: East wall above suspended ceiling system, paint on concrete wall. Photo 96 11/06

110 ppm

B2316-2411-

PCB05

Grey sealant at metal duct and concrete wall

Lab 109: East wall above suspended ceiling system, sealant at duct penetration through concrete wall. Photo 99 11/06

None Detected

B2316-2411-

PCB06

Dark red “Firestop” sealant at concrete deck

Lab 109: East side of room above door to Corridor II 109 above suspended ceiling system at penetration through concrete deck. Photo 101 11/06

None Detected

B2316-2411-

PCB07

White paint over beige paint over teal paint over blue paint on CMU block wall

Clarifier 115: East wall next to Primary Clarifier 3, paint on CMU block wall. Photo 130 11/06

4.1 ppm

B2316-2411-

PCB08

White paint over beige paint over yellow paint over blue paint on CMU block wall

Clarifier 115: Northeast wall next to Primary Clarifier 1, paint on CMU block wall.

Photo 134 11/06

2.3 ppm

B2316-2411-

PCB09

White paint over beige paint over silver paint on concrete wall

Sludge Pump Room: East wall, painted concrete wall.

Photo 146 11/06

5.0 ppm

B2316-2411-

PCB10

White paint over beige paint over green paint over silver paint on concrete wall

Utilidor from B2316 to B2317:

North wall, painted concrete wall. Photo 158 11/06

4.0 ppm

B2316-2411-

PCB11

White paint over beige paint over silver paint on concrete wall

Main Digester Level: South wall, painted concrete wall.

Photo 181 11/06

2.4 ppm

B2316-2411-

PCB12

Grey sealant under white paint over beige paint over blue paint at metal duct and concrete wall

Dry Well 114: North wall, painted sealant at duct penetration through concrete wall. Photo 191 11/06

None Detected

B2316-2411-

PCB13

Brown paint over white paint over grey paint on concrete wall

Boiler Room I 118: South wall, painted concrete wall.

Photo 199 11/06

2.8 ppm

B2316-2411-

PCB14

Clear sealant at wood soffit and metal deck

Boiler Room II 119: Roof access hatch at platform in Boiler Room, sealant between wood soffit and metal deck.

Photo 249 11/07

None Detected

B2316-2411-

PCB15

White sealant at patched penetration through CMU block wall

Generator Room 120: East wall left side of generator, patched penetration through CMU block wall. Photo 263 11/07

NUMBER MATERIAL LOCATION TOTAL PCB

CONCENTRATION

B2316-2411-

PCB16

Black tar paper over yellow insulation over black tarry vapor barrier on concrete deck

Utilidor at B2317: First room on the right side of the utilidor, tar paper, insulation, vapor barrier on concrete deck. Photo 290 11/07

None Detected

Total PCB’s listed herein includes the sum of all cogeners of PCB’s. Refer to the laboratory reports for the concentrations of the various cogeners of PCBs found in the samples.

One of the samples had PCB concentrations above 50 ppm which would be classified by the EPA as PCB Bulk Product Wastes. Seven samples contained more than 1 ppm PCBs detected but had concentrations of PCB’s that were less than 50 ppm. Eight samples had no PCBs detected. Refer to Regulatory Constraints discussion below for more information.

5. Mercury-Containing Materials

Fluorescent Lamps Fluorescent lamps use mercury to excite the phosphor crystals that coat the inside of the lamp. These lamps contain from 15 to 48 milligrams of mercury depending on their age and manufacturer. No fluorescent light fixtures are scheduled to be replaced by this project.

Thermostats Older thermostats or other electrical switches that may contain mercury were noted in the building.

High Intensity Discharge Lamps High Intensity Discharge (HID) lamps use mercury and sodium vapors in the lamp, and also typically have lead-containing solders at the bases. These lamps contain varying amounts of mercury depending on their age and manufacturer. No HID light fixtures are scheduled to be replaced by this project.

All mercury-containing items being removed by this project are required to be disposed of as hazardous waste or recycled.

6. Other Hazardous Materials

Smoke Detectors Several radioactive smoke detectors were found in the renovation area. If any radioactive items are removed by this project, they are required to be disposed of as hazardous waste or recycled.

Soil Contamination The scope of work for EHS-Alaska, Inc. did not include investigation of soils for petroleum or other contaminations.

Refrigerants Refrigerators, freezers, and water coolers were identified in the building that may contain ozone depleting refrigerants. Air conditioning units are also present. Ozone depleting substances (ODS) are regulated by the EPA and must be removed by certified technicians prior to equipment disposal.

Heat Transfer Fluids The existing heating system is assumed to contain heat transfer fluids, including glycol or other boiler treatment chemicals. Any heat transfer fluids removed from the heating system shall be recovered and properly disposed of or recycled. The heating system is unlikely to be disturbed by this project.

E. REGULATORY CONSTRAINTS

1. Asbestos-Containing Materials

The Federal Occupational Safety and Health Administration (29 CFR 1926.1101) and the State of Alaska Department of Labor (8 AAC 61) have promulgated regulations requiring testing for airborne asbestos fibers; setting allowable exposure limits for workers potentially exposed to airborne asbestos fibers;

establishing contamination controls, work practices, and medical surveillance; and setting worker certification and protection requirements. These regulations apply to all workplace activities involving asbestos-containing materials. No asbestos-containing materials are anticipated to be affected by this project.

The EPA regulations, issued as Title 40 of the Code of Federal Regulations, Part 61 (40 CFR 61), Subpart M under the National Emission Standards for Hazardous Air Pollutants (NESHAP), established procedures for handling ACM during asbestos removal and waste disposal. It is recommended that clearance sampling which complies with the EPA’s Asbestos Hazard Emergency Response Act (AHERA) protocol be required following removal of asbestos-containing materials to document that the asbestos has been properly removed.

The EPA regulations require an owner (or the owner's contractor) to notify the EPA of asbestos removal operations and to establish responsibility for the removal, transportation, and disposal of asbestos-containing materials.

The disposal of asbestos waste is regulated by the EPA, the Alaska Department of Environmental Conservation, and the disposal site operator. Wastes being transported to the disposal site must be sealed in leak tight containers prior to disposal and must be accompanied by disposal permits and waste manifests.

2. Dusts with Asbestos

Settled and concealed dusts above ceilings, and at other areas that are not routinely cleaned (such as inside ducts and at roofs, etc.) are assumed to have measurable concentrations of asbestos. Based on sampling of similar settled and concealed dusts at similar buildings, those dusts are assumed to contain less than 1 percent asbestos. Normal settled and concealed dusts are distinct and treated differently from debris resulting from damaged asbestos-containing materials.

Background levels of asbestos in dusts for a…