AMD0002 - USDAARS_DSPWB_SD_Asbestos Lead Ltd Mold Report.pdf

ENGINEERING AND ENVIRONMENTAL CONSULTING:

ASBESTOS, LEAD COATINGS, AND MOLD ASSESSMENT

DUBOIS WATER WELL AND OTHER BUILDINGS REPAIRS

19 OFFICE LOOP

DUBOIS, IDAHO 83423

Prepared For:

Cushing Terrell

800 W Main Street, Suite 800 Boise, ID 83702

Prepared By:

Air Water Soil, LLC

1321 8th Avenue North Great Falls, Montana 59401 406.315.2201

AWS Project 23006.1

June 12, 2023

Engineering and Environmental Consulting: Asbestos, Lead Coatings, and Mold Assessment

Dubois Water Well and Other Building Repairs – 19 Office Loop, Dubois, ID 83423

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TABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY

2.0 INTRODUCTION

2.1 Site Location

2.2 Project Area

2.3 Scope of Work

3.0 REGULATORY CONSIDERATIONS

3.1 Asbestos

3.2 Lead Coatings

3.3 Mold

4.0 METHODS

4.1 Asbestos Inspection

4.2 Lead Coatings Inspection

4.3 Limited Mold Assessment

5.0 RESULTS

5.1 Asbestos Inspection

5.2 Lead Coatings Inspection

5.3 Limited Mold Assessment

6.0 CONCLUSIONS AND RECOMMENDATIONS

6.1 Asbestos

6.2 Lead Coatings

6.3 Limited Mold Assessment

7.0 LIMITATIONS

APPENDICES

Appendix A – Figures

Appendix B – Documentation of Accreditation

Appendix C – Mold Assessment Photographs

Appendix D – Data Summary Tables

Appendix E – Analytical Data Reports

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1.0 EXECUTIVE SUMMARY

Air Water Soil, LLC (AWS) completed a variety of environmental consulting services at the United

States Department of Agriculture (USDA) Range Sheep Production Efficiency Research Unit located at 19 Office Loop, Dubois, Idaho 83423 (the site). The completed services included asbestos inspections and lead coatings inspections of select portions of 4 structures at the site.

A limited mold assessment was also completed within 1 of the 4 structures. The on-site portions of the work were completed from May 1 and 2, 2023.

The site location and project areas for each of the 4 structures are illustrated on Figures 1 through

18 (Appendix A). The inspection was completed at the request of Mr. Gary Glassing, Architect at

Cushing Terrell, in support of Cushing Terrell’s Dubois Water Well and Other Building Repairs project at the site, which they are completing on behalf of the USDA.

The inspection was completed in accordance with the Standard Form of Agreement between

Cushing Terrell and AWS, dated March 23, 2023, which was approved by Mr. Glassing on April

6, 2023. The scope of the inspection was developed by AWS, through coordination with Cushing

Terrell, to comply with applicable asbestos and lead regulations – and additional mold considerations – relating to the planned Water Well and Other Building Repairs project at the site.

The overall scope of work for the inspection included completion of asbestos inspections and lead coatings inspections within 4 structures at the site – as well as a limited mold assessment within

1 of the 4 structures – and preparation of this report. This is discussed in greater detail in Section

2.2 below.

The on-site portions of the scope of work were conducted concurrently, and the results of all portions of the scope of work are collectively summarized in this report. AWS’s overall scope of work for the project also includes well engineering support services, which will be provided and summarized separately from the environmental consulting services discussed in this report.

A total of 61 separate homogeneous areas (HAs) of building materials were identified as being suspect asbestos-containing materials (ACM) within the portions of the 4 structures included in the overall project area. Seven (7) HAs of flooring materials and associated mastics, laboratory counter tops, construction adhesives, and roofing sealants were confirmed to be ACM through sampling and analysis. One (1) additional HA of electrical wire insulation could not be safely sampled and was therefore presumed to be ACM. Two (2) additional HAs of wallboard and surface texture were confirmed to contain detectable amounts of asbestos beneath the regulatory criterion for ACM and were therefore categorized as asbestos-contaminated.

Sampling and laboratory analysis of material samples from the remaining 51 HAs of suspect ACM indicated the materials did not contain detectible concentrations of asbestos; these materials have been determined to be non-ACM with no special handling and/or disposal considerations relating to asbestos (unless contaminated by ACM, as mentioned above).

Note that degradation from wear, exposure to the elements (“weathering”), or disturbance during renovation or demolition activities may render some types of ACM friable, making them regulated asbestos-containing materials (RACM) as defined by US Environmental Protection Agency

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(EPA). ACM and asbestos-contaminated wastes must be removed, transported, and disposed in accordance with applicable federal, state, and local asbestos regulations, including those established by the EPA, the Occupational Safety and Health Administration (OSHA), and the

Idaho Department of Environmental Quality (DEQ). Depending on the quantity of RACM impacted, this may include, but may not be limited to, utilizing an EPA-accredited abatement contractor and submitting asbestos renovation/demolition notification to Region 10 of the EPA at least 10 business days prior to initiation of project activities.

Non-ACM materials which contain detectable concentrations of asbestos (including materials which may only be contaminated by ACM before or during removal) are not regulated by the EPA;

however, activities which may disturb these materials and result in potential worker exposure hazards are regulated by OSHA. Additionally, all materials containing asbestos must be properly disposed in accordance with applicable solid waste requirements.

A total of 116 separate HAs of suspect lead-containing surface coatings were identified and tested within the overall project area during this inspection, 19 of which were confirmed to contain lead at concentrations at or above the Housing and Urban Development (HUD) lead-based paint (LBP) criterion of 1 milligram per square centimeter (1.0 mg/cm2). Additionally, 32 other HAs of coatings were determined to contain lead at concentrations from 0.10 and 0.99 mg/cm2, which AWS conservatively reports as lead-containing paint (LCP).

Assessment of leachable lead in the anticipated project waste streams for 3 of the 4 structures included in AWS’s inspection project area indicated there would be no special requirements pertaining to lead disposal, based on the assumptions noted in this report. An assessment of leachable lead could not be made for the remaining structure (Building 15) because the potential remediation/renovation plan had not been finalized. Additional assessment of leachable lead in

Building 15 may be required following finalization of the remediation/renovation plan.

In any case, materials coated with LCP/LBP should be handled in accordance with applicable

OSHA worker protection and EPA disposal regulations.

As noted above, AWS’s limited mold assessment was conducted only within 1 structure at the site (Building 15). Visual evidence of previous moisture damage and suspect mold growth were observed in multiple locations within the residence. The likely sources of moisture were determined to include condensation on exterior walls and windows due to thermal bridging;

deterioration of a shower surround; improper/insufficient venting; splashing/overspray near a utility sink; negative exterior surface drainage combined with lack of gutters/downspouts; and potential snow-melt infiltration over an under-eave entry awning.

Contact samples from areas of suspect mold growth confirmed the presence of mold, but building materials throughout the structure (including adjacent to visible mold growth) were within acceptable moisture concentrations at the time of the assessment. Air samples collected throughout the residence indicated the presence of airborne mold spores, but concentrations were generally lower than would be expected in areas with substantial and widespread mold growth or mold contamination.

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Consideration should be given to retaining a weatherization specialist to evaluate Building 15 to determine if additional insulation, ventilation, and/or dehumidification is needed to prevent condensation from thermal bridging. Additional corrective actions may also be required to prevent other sources of moisture intrusion.

Remediation of moisture- and mold-affected materials is recommended and is expected to include removal and replacement of wall materials and underlying insulation from select areas. The extents of removal will need to be evaluated at the time of remediation.

AWS’s recommendations, based on the findings of this assessment, are presented in Section 6 of this report. A copy of this report, and any subsequent report or addendum relating to additional asbestos assessment, should be kept at the site during any future renovation or demolition activities which may impact the project areas as described in this report.

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2.0 INTRODUCTION

Cushing Terrell requested AWS perform asbestos and lead coatings inspections to identify materials potentially containing asbestos and lead within 4 structures included in the project area at the site. An additional, limited mold assessment was also requested for 1 of these structures.

2.1 Site Location

The USDA Range Sheep Production Efficiency Research Unit (the site) is located at 19 Office

Loop, Dubois, Idaho 83423 (see Figure 1, Appendix A).

2.2 Project Area

The “project area” was established by AWS and Cushing Terrell based on the USDA’s project requirements as established in their January 4, 2023, Project Requirements Document – Dubois

Water Well and Other Building Repairs. The project area was defined in the Standard Form of

Agreement between Cushing Terrell and AWS and included all safely and readily accessible building materials within specific portions of the site structures identified in the list below. All other structures or areas of structures not listed below were excluded from the project area. Based on information provided by the USDA and/or Cushing Terrell, AWS understood the following site structures/areas were expected to be disturbed by planned renovation. The project area for

AWS’s asbestos inspections, lead coatings inspections, and limited mold assessment were therefore established as follows:

Building 4 – Auxiliary Well Building. Included in Cushing Terrell’s scope of work for the project, but disturbance of building materials not anticipated. Excluded from AWS’s scope of work by Cushing Terrell.

Building 15 - Residence. Dimensions and age of construction not provided. Wood frame construction on a concrete basement foundation, with a partial crawlspace area. Includes a finished main level, finished upper level, and a partially finished basement. Structure appears to have been constructed prior to 1979, with some interior finish and exterior façade upgrades. Requested work includes investigation of mold type, extent, and source, along with provision of repair and remediation strategies. USDA will reportedly complete mold remediation separately, along with limited updates to interior finishes (for example, repainting, etc.). AWS’s scope of work included completion of a limited mold assessment, asbestos inspection, and a lead coatings inspection. Since the extents of potential renovation are unknown, the asbestos and lead coatings inspections were inclusive of all safely and readily accessible interior and exterior building materials.

Building 66 – Physiology Lab. 5,630 square feet. Constructed 1975. Primarily single-level, metal frame construction, with an unfinished mezzanine area. Concrete slab-on-grade construction, with no crawlspace or basement areas. Includes unfinished shop area and finished office/laboratory areas. Small entry way at the southeast corner appears to be an addition. Extensive interior renovations planned, along with potential exterior renovations. Asbestos and lead coatings inspections were inclusive of all safely and readily accessible interior and exterior building materials. Roofing materials are not expected to be impacted – and were not readily accessible – and were therefore excluded from the project area, as planned.

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Building 71 – Main Water Well Building. The date of construction of the well building was not provided. However, the well was installed in 1937, and the structure is likely of the same vintage. A partial concrete basement encloses the well, pump controls, and chlorination system. Disturbance of building materials will reportedly be limited to foundation walls within the partial basement. Asbestos and lead coatings inspections were inclusive of all safely and readily accessible interior and exterior foundation materials, as well as coatings on pipes within the basement area. All other building areas and materials were excluded.

Building 92 – Metabolism Barn. 3,000 square feet. Constructed in 1979. Single-level, metal frame construction. Concrete slab-on-grade foundation, with no crawlspace or basement areas. Small addition at west side of building. Partially finished office area at north end, with remainder being mostly unfinished. Addition to be removed. New siding to be placed over existing siding. Roofing materials to be removed and replaced. Extensive interior renovations to be completed. Although buildings constructed after 1978 are less likely to contain lead coatings, AWS recommended testing coatings for lead. Asbestos and lead coatings inspections were inclusive of all safely and readily accessible interior and exterior building materials.

The site structures included in the project area are illustrated in Figures 2 through 18 (Appendix

A). It is important to note that some materials documented as being within the project area are – or may be – present in other site structures which are outside the project area and are therefore not discussed in this inspection report. Similarly, other materials not discussed in this report may also be present at the site in locations which were not safely or readily accessible at the time of

AWS’s assessment, or which were outside the project area.

2.3 Scope of Work

The scope of work for this project included inspection of building materials and components throughout safely and readily accessible portions of the project area within the 4 structures identified above, including visual assessment, sampling, and documentation of suspect and confirmed/presumed ACM and lead-containing surface coatings within the project area, as well as assessment of the anticipated project waste stream for leachable lead, where applicable. The scope of work also included a limited mold assessment of 1 of these structures, as discussed above.

AWS’s scope of work for this phase of the project did not include preparation of abatement plans/specification documents; solicitation of abatement bids; or completion of abatement, oversight, or clearance monitoring activities. AWS understands these additional services may be requested at a later date.

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3.0 REGULATORY CONSIDERATIONS

AWS presents the following regulatory considerations pertaining to asbestos-containing materials and lead-containing coatings. AWS’s inspection methods and recommendations are based on applicable regulatory requirements for each of these materials, respectively.

3.1 Asbestos

The State of Idaho DEQ only regulates abatement and disposal of asbestos relating to large industrial sources, which are subject to their Tier I air quality operating permit program. Smaller, non-industrial projects are subject to the EPA National Emissions Standards for Hazardous Air

Pollutants (NESHAP) regulation, which is established in Title 40, Part 61, of the Code of Federal

Regulations (40 CFR 61.141). Additionally, DEQ does not operate an asbestos training program.

Current asbestos accreditation from other states which meets EPA’s training and accreditation standards, as set forth in the Asbestos Hazard Emergency Response Act (AHERA) standard (40

CFR 763, Subpart E), is acceptable to conduct asbestos work in Idaho.

The EPA defines ACM as material containing more than 1% asbestos based on laboratory analysis of the material using the EPA Method 600/R-93/116 (“Method for the Determination of

Asbestos in Bulk Building Materials”) by Polarized Light Microscopy (PLM). Three categories of

ACM have been defined in the NESHAP, as follows:

Category I Non-friable ACM means asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than one (1) percent (%) asbestos as determined using the method specified in appendix E, subpart E, 40 CFR

763, section 1 (PLM).

Category II Non-friable ACM means any material, excluding Category I Non-friable ACM, containing more than 1% asbestos as determined using the method specified in appendix E, subpart E, 40 CFR 763, section 1, PLM that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated ACM (RACM) means a) friable asbestos material; b) Category I Non-friable

ACM that has become friable; c) Category I Non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by the subpart.

The definition of RACM includes all ACM associated with a structure or space which will be impacted by renovation and/or demolition activities. In other words, even non-friable

Category I and Category II ACM may become RACM if disturbed during demolition or renovation activities.

Prior to undertaking a renovation or demolition project, EPA requires an asbestos inspection to be performed for the structure or portion of the structure to be included in the renovation or demolition project, in accordance with the NESHAP. RACM exceeding project totals of 260 lineal feet (pipes), 160 square feet, or 35 cubic feet must be removed from structures prior to initiation

Air Water Soil, LLC 7 of renovation or demolition activities. Notification of asbestos renovation or demolition activities must be submitted to EPA Region 10 at least 10 days prior to initiation of such activities.

EPA regulates the transport and disposal of asbestos wastes under the NESHAP, AHERA, and

Resource Conservation and Recovery Act (RCRA) regulations. Asbestos waste must be transported in leak-tight containers and disposed at landfills meeting EPA requirements. It is advisable to make arrangements with the landfill prior to initiation of abatement and/or demolition activities, as individual landfill requirements may vary.

Handling of RACM, ACM, and non-ACM materials which contain detectable asbestos is regulated by the Occupational Safety and Health Administration (OSHA), as stipulated in 29 CFR

1926.1101. At all times, such materials must be handled in generally the same fashion as RACM unless a negative exposure assessment is completed to document workers will not be exposed to airborne fiber concentrations in exceedance of the OSHA permissible exposure limit (PEL) of

0.1 fibers per cubic centimeter (f/cc) as an eight-hour time-weighted average (8-hour TWA) and the 30-minute, short term excursion limit (STEL) of 1.0 f/cc.

3.2 Lead Coatings

The purpose of a lead inspection is to identify lead-containing surface coatings and to characterize the overall concentration of leachable lead in an anticipated renovation or demolition waste stream. Identification of lead-containing coatings and/or LBP is necessary to determine whether renovation/demolition workers may potentially be exposed to airborne lead concentrations exceeding permissible exposure limits established by the OSHA. Characterization of leachable lead in the overall potential waste stream is necessary to determine proper handling and disposal of renovation waste materials as required by the RCRA.

The US Department of Housing and Urban Development (HUD) defines LBP as a surface coating containing lead in a concentration equal to or greater than (≥) 1.0 milligram per square centimeter

(mg/cm2) or 0.5% by weight. The presence of LBP on surfaces scheduled to be impacted during renovation activities increases the potential for workers to be exposed to airborne lead in concentrations greater than the OSHA PEL of 50 micrograms per cubic meter (µg/m3), which is established in 29 CFR 1926.62. However, the presence of lead-containing surface coatings (i.e., coatings which contain lead at concentrations less than the HUD criterion of 1.0 mg/cm2) may also present a potential exposure hazard for renovation workers. AWS conservatively considers coatings which contain ≥ 0.10 mg/cm2 to be lead-containing paint (LCP) for this purpose.

When disturbing LCP or LBP, an employer must assume workers will be exposed to lead concentrations above the PEL, and worker protection must be provided in accordance with 29

CFR 1926.62. Alternatively, a negative exposure assessment may be completed to document the potential for exposure to airborne lead during renovation/demolition activities, on a per-task basis.

Relating to disposal of lead-containing waste, RCRA regulatory criteria for “total” lead in a waste stream is established in 40 CFR 261, Subpart C. The regulatory criteria are listed in milligrams per liter (mg/l) of dissolved lead in a solution (“wet basis”), as determined using the Toxicity

Characteristic Leaching Procedure (TCLP) by EPA Method 1311. Rule-of-thumb RCRA criteria

Air Water Soil, LLC 8 are listed in milligrams per kilogram (mg/kg) of solid metal in the material sample (“dry basis”) and assume the entire mass of the analyte will enter solution. They are therefore conservative values;

however, when the analyte concentration approaches or exceeds the rule-of-thumb value for a metal, the TCLP method should be used to determine the actual leachable concentration of the analyte in the sample.

The RCRA rule-of-thumb criteria for total lead is 100 mg/kg (0.1% by weight), and the TCLP regulatory criteria for leachable lead is 5.0 mg/l, as established in 40 CFR 261.24. A waste stream with a leachable lead concentration determined to be greater than 5.0 mg/l using the TCLP analytical method is defined as a “hazardous waste” and must be transported by a hazardous waste transporter and disposed at a hazardous waste disposal facility.

For the purpose of a renovation or demolition project, a composite sample representative of the overall anticipated waste stream for the project may be collected and analyzed for leachable lead concentration. RCRA solid waste regulations set forth in 40 CFR 260.10 define a representative sample as “a sample of a universe or whole (e.g., waste pile, lagoon, groundwater) which can be expected to exhibit the average properties of the universe or whole.” If analytical data indicate the leachable lead concentration for the representative sample is less than the regulatory criteria of

5.0 mg/l, then the entire waste stream may be disposed as non-hazardous waste with regard to lead.

Materials containing 5.0 mg/l of lead or more as defined by a TCLP analysis are regulated by

RCRA as hazardous waste. Material determined to be hazardous waste must be transported in accordance with Department of Transportation (DOT) regulations, as stipulated in 49 CFR 171.3.

Hazardous waste must be handled and disposed in accordance with 40 CFR 260 – 265.

3.3 Mold

There are currently no EPA, OSHA, or DEQ standards or regulations relating to airborne concentrations of mold or mold spores. Exposure to mold can cause a variety of adverse health effects and symptoms. The severity of symptoms can be influenced by a wide variety of factors and may vary greatly between individuals. Symptoms experienced by sensitive individuals may include – but may not be limited to – stuffy nose, wheezing, or eye/skin irritation. Individuals with mold allergies may also experience shortness of breath or other difficulty breathing. Mold infections may occur in individuals with chronic lung disease or weakened immune systems.

Sources of water intrusion/leaks should be corrected and mold growth promptly mitigated from within structures, especially when occupied. Mold- and water-affected materials should be promptly disposed or properly cleaned, as feasible.

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4.0 METHODS

AWS’s methods for the asbestos inspection, lead coatings inspection, and limited mold assessment are described below. The inspections/assessment were completed by experienced members of AWS’s industrial hygiene staff who held current US EPA/AHERA accreditation as

Asbestos Inspectors during completion of the inspection, and who have experience conducting lead coatings inspections and mold assessments. Documentation of AWS’s applicable accreditations for onsite project personnel is presented in Appendix B. Access to the portions of the site included in the project area was provided by USDA’s on-site personnel. The on-site portions of the inspection were completed on May 1 and 2, 2023.

4.1 Asbestos Inspection

AWS completed the asbestos inspection in accordance with the requirements of the NESHAP regulation, as set forth in 40 CFR 61.141. In addition to complying with the NESHAP requirements, AWS’s sampling methods generally conformed to the requirements set forth in the Asbestos

Hazard Emergency Response Act (AHERA) as outlined in 40 CFR 763.86; the AHERA sampling methods are generally accepted as the industry standard for asbestos inspections.

Visible damage at sample locations was limited where feasible, and care was taken to avoid damage to exterior façade systems, where applicable. Additionally, temporary repairs were made at select sample locations to limit further degradation of sampled materials, and/or to limit the potential for fiber exposures, as appropriate. Sample locations for suspect ACM are presented on

Figures 2 through 5 (Appendix A).

Bulk samples of suspect ACM were placed in pre-labeled zip-top bags and shipped to Eurofins

CEI Laboratory (CEI) in Cary, North Carolina, using chain-of-custody protocol. AWS requested that CEI analyze the samples using the EPA Method 600/R-93/116 by polarized light microscopy

(PLM), which has an analytical sensitivity of 1% asbestos by visual estimate. Where appropriate, AWS also requested that samples found to contain asbestos in concentrations less than 1% be further analyzed using the 400 Point Count stipulation of the EPA PLM method to achieve an analytical sensitivity of 0.25%.

Depending on the sample matrix, some samples are prepared using the Gravimetric Reduction stipulation of the EPA Method. Transmission Electron Microscopy (TEM) bulk sample analysis may be used in lieu of gravimetric reduction and 400 Point Count analysis when recommended by the laboratory – typically for non-friable organically bound (NOB) sample matrices.

All samples were analyzed using positive stop analysis. AWS requested standard analytical turnaround time (TAT) for the samples. CEI is accredited by the National Institute of Standards and Technology’s (NIST) National Voluntary Laboratory Accreditation Program (NVLAP) for PLM analysis and therefore conforms to industry standards for analytical proficiency.

4.2 Lead Coatings Inspection

AWS identified HAs of suspect lead surface coatings on surfaces throughout the project area;

surfaces on building materials which were discernably newer than 1979 were typically excluded

Air Water Soil, LLC 10 from the inspection, as established in the Work Order. The lead coatings inspection was completed in general accordance with portions of the American Standard for Testing and

Materials (ASTM) Method E 1729-05 and/or Chapter 7 of the HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing. The lead inspection was not intended to adhere to HUD requirements for child-occupied facilities.

AWS’s inspector distinguished HAs of suspect LBP visually and through field review of analytical data obtained using a Viken Pb200i x-ray fluorescence (XRF) analyzer. The XRF utilizes an ionizing radiation source and internal calculations to provide direct-read lead data. Analytical data obtained from a field calibrated XRF are accepted as accurate by the EPA and HUD. AWS’s XRF was calibrated on-site and checked for accuracy against NIST certified paint standards, following the manufacturer’s guidelines, prior to usage each day. The instrument was again checked against the NIST standards throughout the testing period (approximately once every 4 hours) and following completion of testing each day, to ensure analytical accuracy was maintained during the inspection.

If deemed appropriate by the inspector, multiple tests were taken within a given HA; in such instances, the highest observed concentration for tests representing a respective HA were reported. Observations and test locations were recorded on field forms and site diagrams. XRF test locations for suspect LCP/LBP are illustrated on Figure 6 through 9 (Appendix A).

Leachable lead considerations, per structure, were made as follows:

Building 15 - Residence. The scope of potential mold remediation and/or renovation work which may disturb lead-based paints is unknown. Calculation of leachable lead cannot be completed until the remediation/renovation plan is finalized.

Building 66 – Physiology Lab. LBP identified at Building 66 was limited to the original coating on metal cabinets, and paint on a single pipe serving an eye wash station. AWS understands metal cabinets are likely to be reused at the site and are not scheduled for disposal. Accordingly, completion of a leachable lead assessment was determined to be unwarranted.

Building 71 – Main Water Well Building. LBP identified in Building 71 included paint on exterior concrete foundation walls and paint on an interior wood wall section. AWS understands a hole is expected to be cut through the concrete foundation wall for a new pipe penetration, but the wood wall is not scheduled for removal. AWS calculated the

“total” lead concentration of the anticipated waste stream at this building based on these assumptions. The approximate mass of lead in the LBP foundation coating which is anticipated to be impacted was divided by the approximate non-lead mass of the concrete foundation wall in the same area. The calculated “total” lead concentration was low enough to demonstrate the lead concentration in the anticipated waste stream would be beneath the RCRA “Rule-of-Thumb” criterion of 100 mg/Kg. Collection of a sample for laboratory analysis of TCLP lead was not warranted.

Building 92 – Metabolism Barn. Several of the same metal cabinets identified in Building

66, as mentioned above, were also present in Building 92. No other LBP was identified at

Building 92. Completion of a leachable lead assessment was determined to be unwarranted.

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4.3 Limited Mold Assessment

AWS’s limited mold assessment was completed for Building 15 only and included a preliminary visual assessment, air monitoring, and tape lift sampling. Completion of a wall cavity assessment was not requested or completed.

Interior finishes were visually assessed to identify areas displaying evidence of suspect mold and signs of unacceptable moisture infiltration. Select building materials were evaluated for relative moisture content using an electronic moisture meter. The visual assessment also included evaluation of potential sources of moisture intrusion along the exterior of the basement (for example, negative surface drainage, damaged gutters and down spouts, etc.). Observations and field data were recorded on field forms, and photographs were taken to document areas exhibiting evidence of water intrusion and/or visible mold.

Following completion of the visual assessment, tape lift samples were collected from select areas of visible mold within Residence 15. Samples were collected in accordance with the requirements of the analytical method, as relayed by the laboratory. This generally included using transparent tape to lightly contact the surface of suspect mold growth, followed by placement of the tape lift sample into a new, pre-labeled zip-top bag.

Relative moisture readings were taken at multiple locations throughout the residence, including at each tape-lift sample location, using GE Protimeter Moisture Measurement System (MMS).

Moisture concentrations were displayed within a range of 60 to 1000, along with a qualitative indication of whether the material was DRY, AT RISK, or WET. These results may be indirectly correlated to Moisture Content (or Wood Moisture Equivalent) ranges for DRY (≥ 8% but < 17%), AT RISK (≥ 17% but < 20%), or WET (≥ 20%) substrates.

AWS completed quantitative sampling of the air to determine the presence and/or extent of mold contamination within Residence 15. Air sample locations were selected based on site observations. To accomplish this component of the assessment, Air-O-Cell™ cassettes were used. These non-culturable air samples are generally collected for time intervals ranging from approximately 3 to 7 minutes, depending on the inferred level of airborne particulate within the respective areas. Shorter sample durations are used for areas with anticipated higher particulate concentrations in order to help prevent occlusion of sample media. All samples were collected at flow rates of approximately 15 liters per minute (L/min).

Air flow measurement quality control prior to and following completion of air sample collection was achieved using a TSI 4146 calibration device (primary standard) and/or a rotameter calibration device (secondary standard). The rotameter, if used, was calibrated against the primary standard and corrected for elevation as appropriate. The GE Protimeter MMS was used to measure the percentage of relative humidity (% RH), temperature in degrees Celsius (°C), and dew point (°C) proximate to each air sample location. Measurements were recorded on a field form.

Air-O-Cell™ and tape-lift samples were labeled, packaged, and shipped to Eurofins EMLab P&K

(EMLab) in Phoenix, Arizona, using chain-of-custody protocol. AWS requested standard

Air Water Soil, LLC 12 analytical turnaround. EMLab is an American Industrial Hygiene Association (AIHA) accredited environmental microbiology laboratory.

Observations and field data were recorded on field forms. Tape-lift sample locations, building material relative moisture test locations, and air sample locations are illustrated on Figure 10

(Appendix A), along with notes pertaining to other pertinent observations. Photographic documentation is provided in Appendix C.

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5.0 RESULTS

The following sections summarize the results and findings from our asbestos and lead coatings inspections, as well as the limited mold assessment. Approximate locations of confirmed or presumed materials of concern throughout the project area are illustrated on Figures 11 through

14 (asbestos) and Figures 15 through 18 (lead coatings), in Appendix A. Select field data and observations relating to the limited mold assessment are illustrated in Figure 10, also in Appendix

A. Photographic documentation of observations relating to the limited mold assessment is presented in Appendix C. Asbestos, lead, and mold data summary tables are presented in

Appendix D, and analytical data reports are presented in Appendix E.

5.1 Asbestos Inspection

Asbestos inspection results are shown below for each of the 4 buildings included in the overall project area. A total of 61 HAs of suspect ACM were identified throughout the portions of the 4 buildings included in the project area. Individual summaries of the HAs of Confirmed ACM, Presumed ACM, and Non-ACM Determined to be ACM-Contaminated identified within the project area for each respective building are provided below.

Building 15 – Residence:

2 HAs of Confirmed ACM (determined to be > 1% asbestos) o F1.5 – White vinyl sheet floor, mosaic pattern with paper backing and black underlayment. No definitive mastic layer observed at the time of sampling.

Observed in Basement closets. Small amount observed at ceiling joist above Mech

Room sink (flooring only, no mastic or underlayment). 20% Chrysotile (sheet floor);

2% Chrysotile (mastic); 15% Chrysotile (underlayment). Non-friable in place, but the paper backing is anticipated to become friable during removal. RACM, unless removed intact.

o F3.1 – Yellow vinyl sheet floor with paper backing and amber mastic. Observed in

First Floor Bathroom and hallway closets. 20% Chrysotile (sheet floor); 2%

Chrysotile (mastic). Non-friable in place, but the paper backing is anticipated to become friable during removal. RACM, unless removed intact.

1 HA of Presumed ACM (assumed to contain > 1% asbestos) o M7.1 – Silver coated cloth wire insulation. Observed in Basement and Attic areas

(presumed throughout). Could not be safely sampled. Non-friable in place.

Presumed Category II ACM.

1 HA of Non-ACM Determined to be ACM-Contaminated o G1.3 – GWB system with joint compound. Observed throughout walls and ceilings.

Presumed to be present behind paneling in First Floor NE Bedroom. Joint compound contains 2.0% Chrysotile, but the overall GWB system is < 1%

Chrysotile. Overall system is Non-ACM per NESHAP, but the material must still be handled per OSHA and solid waste rules.

Building 66 – Physiology Lab:

2 HAs of Confirmed ACM (determined to be > 1% asbestos)

Air Water Soil, LLC 14 o F2.3 – 12-in x 12-in light green vinyl floor tiles, yellow smears with black mastic.

Observed in Lab 1, Lab 2, and Lab 3. 2% Chrysotile (mastic only). Non-friable in place. Category I ACM unless rendered friable.

o M1.1 – Black lab counter tops. Observed in Lab 1, Lab 3, and Lab 6 (also observed in Building 92). 15% Chrysotile. Non-friable in place. Category II ACM, if removed intact.

0 HAs of Presumed ACM (assumed to contain > 1% asbestos)

1 HA of Non-ACM Determined to be ACM-Contaminated o T1.1 – White surface texture on ceiling. Observed in Lab 6. < 0.25% Chrysotile.

Non-friable in place but anticipated to become friable during removal. Non-ACM but must still be handled per OSHA and solid waste rules.

Building 71 – Main Water Well Building:

0 HAs of Confirmed ACM (determined to be > 1% asbestos)

0 HAs of Presumed ACM (assumed to contain > 1% asbestos)

0 HAs of Non-ACM Determined to be ACM-Contaminated

Building 92 – Metabolism Barn:

3 HAs of Confirmed ACM (determined to be > 1% asbestos) o M1.1 – Black lab counter tops. Observed in Lab 1 and Open Work (also observed in Building 66). 15% Chrysotile. Non-friable in place. Category II ACM, if removed intact.

o M2.2 – Gray construction adhesive at roof panel seams. Observed throughout the original roof area. 3% Chrysotile. Non-friable in place. Category I ACM, unless rendered friable.

o M2.3 – White putty around roof penetrations. Observed on original roof. 5%

Chrysotile. Non-friable in place. Category I ACM, unless rendered friable.

0 HAs of Presumed ACM (assumed to contain > 1% asbestos)

0 HAs of Non-ACM Determined to be ACM-Contaminated

Asbestos was not present at detectible concentrations in material samples from the remaining 51

HAs, which have therefore been determined to be non-asbestos. However, it is important to note that any non-ACM materials determined to be inseparable from ACM (e.g., non-ACM floor tiles over ACM mastic) should be considered to be ACM-contaminated. Such materials should be handled in the same fashion as the ACM from which they are contaminated.

Complete summaries, per building, of all HAs of suspect ACM are presented in Table 1. The summary table includes descriptive locations of where each material was observed or presumed to be located throughout the project area; an assessment of the in-place condition of each material at the time of the inspection; and the classification and anticipated condition of the material during planned renovation or demolition activities.

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Locations of materials presumed to contain asbestos are also illustrated on Figures 11 through

14, based on areas where they were actually observed as well as locations where they are inferred to be. These and/or other materials may be present in other locations which were not accessible for full evaluation at the time of the inspection, or in other portions of the site outside the project area.

5.2 Lead Coatings Inspection

Lead coatings inspection results are shown below for each of the 4 buildings included in the overall project area. A total of 116 separate HAs of suspect lead-containing surface coatings were identified and tested with the XRF throughout the portions of the 4 buildings included in the project area. Individual summaries of the HAS of LCP and LP identified with the project area for each respective building are provided below.

Building 15 – Residence:

16 HAs of LCP (confirmed to contain > 0.10 mg/cm2 but < 1.0 mg/cm2 lead) o Pb-57 – Green paint on metal roofing. Exterior.

o Pb-58 – White paint on metal siding, fascia, and soffit. Exterior.

o Pb-66 – White paint on wood trim. First Floor throughout.

o Pb-67 – White paint on wood window sills. First Floor throughout.

o Pb-68 – White paint on wood window shelf. First Floor Basement stairwell.

o Pb-69 – White paint on wood door casing. First Floor throughout (except Pb-70).

o Pb-71 – White paint on wood door slabs. First Floor Bathroom, NE Bedroom, and

NW Bedroom.

o Pb-72 – White over yellow paint on wood built-in cabinets. First Floor Bathroom, Laundry, and hall.

o Pb-74 – White paint on GWB walls and ceilings. First Floor (except NE Bedroom));

Basement stairwell ceiling.

o Pb-85 – White paint on concrete. Basement Storage (N, E) and Mech (E).

o Pb-88 – Cream paint on GWB walls. Basement closets.

o Pb-92 – Light gray paint on concrete floor. Basement Mech.

o Pb-93 – Dark gray paint on concrete floor. Basement Bedroom.

o Pb-94 – White paint on metal drain pipe. Basement Mech.

o Pb-96 – White paint on GWB walls and ceilings. Second Floor N and S Bedrooms, Storage, hall, and stairwell to First Floor.

o Pb-101 – White over yellow paints on wood built-in cabinets. Second Floor

Bedrooms.

14 HAs of LBP (confirmed to contain ≥ 1.0 mg/cm2 lead) o Pb-59 – Presumed paint on original siding behind metal siding. Exterior throughout. (Note: lead concentrations > 1.0 mg/cm2 were recorded for shots on metal siding in locations where original painted siding was presumed to be located beneath. However, lead concentrations for shots on the same metal siding in locations where no original paint was present beneath all resulted in lead concentrations < 1.0 mg/cm2. See Pb-58 above.)

o Pb-61 – White paint on wood windows. Exterior Basement (S-2; W-4).

Air Water Soil, LLC 16 o Pb-62 – White paint on wood soffits. Exterior – visible over E entry awning;

presumed throughout.

o Pb-63 – White paint on wood thresholds. Exterior E and W entry doors.

o Pb-70 – White paint on wood door casing. First Floor at NE Bedroom/Basement stairwell and at Laundry/Basement Stairwell.

o Pb-79 – White glazing on metal bathtub and sink. First Floor Bathroom.

o Pb-80 – Light blue paint on wood stair banisters and risers. Stairwell to Second

Floor.

o Pb-86 – Aqua paint on wood cabinets. Basement Storage.

o Pb-89 – Dark brown paint on wood stairs. Basement stairs.

o Pb-97 – White paint on wood trim. Second Floor throughout.

o Pb-98 – White paint on wood door casing. Second Floor throughout.

o Pb-99 – White paint on wood door slab. Second Floor throughout.

o Pb-102 – White paint on wood window sill. Second Floor throughout.

o Pb-103 – Dark brown jute-backed flooring. Basement Storage, Basement stairs, Second Floor Storage.

Building 66 – Physiology Lab:

8 HAs of LCP (confirmed to contain > 0.10 mg/cm2 but < 1.0 mg/cm2 lead) o Pb-21 – Gray paint on metal door casing. Lab 6 exit (E).

o Pb-22 – Gray paint on metal door slab. Lab 6 exit (E).

o Pb-23 – White paint on GWB walls and ceilings. E entry vestibule (N, E, S).

o Pb-34 – Cream paint on wood door case/slab. Hall 2/Lab 2 and Hall 1 (mid).

o Pb-48 – Yellow paint on metal siding. Exterior original building.

o Pb-50 – Brown paint on metal windows. Exterior at Open Storage (S-2).

o Pb-51 – Silver paint on metal bracket. Exterior, on siding (SW, NE).

o Pb-55 – Gray paint on metal shelf bracket. Lab 6 (N).

2 HAs of LBP (confirmed to contain ≥ 1.0 mg/cm2 lead) o Pb-19 – Orange paint (original) on metal cabinets. Beneath newer cream paint in places. Lab 1, Lab 2, Lab 3, Lab 5, Lab 6, Restroom, Storage 7 (also observed in

Building 92; see Pb-18 below).

o Pb-54 –Orange over yellow paint on metal pipe. Eye wash in Lab 6.

Building 71 – Main Water Well Building:

4 HAs of LCP (confirmed to contain > 0.10 mg/cm2 but < 1.0 mg/cm2 lead) o Pb-109 – Silver paint on metal pipes and valves. Interior.

o Pb-111 – Red paint on metal valve wheel. Interior.

o Pb-114 – Red paint on metal valve. Interior.

o Pb-116 – Black paint on metal wall heater. Interior (E).

2 HAs of LBP (confirmed to contain ≥ 1.0 mg/cm2 lead) o Pb-105 – White paint on concrete. Exterior foundation.

o Pb-107 – White over silver paint on wood wall. Interior (N).

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Building 92 – Metabolism Barn:

4 HAs of LCP (confirmed to contain > 0.10 mg/cm2 but < 1.0 mg/cm2 lead) o Pb-01 – Green factory paint on metal roof. Exterior, original building.

o Pb-02 – White factory paint on metal siding. Exterior, original building.

o Pb-07 – White paint on metal fence. Exterior (E, W).

o Pb-17 – Gray paint on metal fence. Open Work.

1 HA of LBP (confirmed to contain ≥ 1.0 mg/cm2 lead) o Pb-18 – Orange paint (original) on metal cabinets. Beneath newer cream paint in places. Lab 1 and Open Work (also observed in Building 66; see Pb-19 above).

Complete summaries, per building, of all HAs of suspect LCP/LBP are presented in Table 2. The summary table includes descriptive locations of where each material was observed or presumed to be located throughout the project area. Confirmed and assumed LCP/LBP locations are also illustrated on Figures 15 through 18, based on areas where they were actually observed as well as locations where they are inferred to be. These and/or other materials may be present in other locations which were not accessible for full evaluation at the time of the inspection, or in other portions of the site which were outside the project area.

As noted in Section 4.2 above, a leachable lead assessment was not completed for Building 15 because the remediation/renovation plan could not be finalized at the time of preparation of this report, and completion of leachable lead assessments was not warranted for Building 66 or

Building 92.

A leachable lead assessment was completed for Building 71. The calculated mass of lead in the anticipated project waste stream is approximately 2,633 mg, and the calculated non-lead mass of primary components within the anticipated project waste stream (i.e., concrete) is approximately

103 Kg. The conservative “total” lead concentration for the anticipated waste stream, as calculated by dividing the mass of lead waste by the mass of non-lead waste, is approximately

25.6 mg/Kg, which is well beneath the RCRA rule-of-thumb criterion of 100 mg/Kg for lead. This calculated total lead concentration is based on the limitations and assumptions inherent with calculating the mass of lead and non-lead in a construction waste stream. Collection and analysis of a leachable lead (TCLP) sample was determined to be unwarranted and was therefore not completed for the anticipated project waste stream.

5.3 Limited Mold Assessment

AWS’s environmental personnel made the following observations during the limited mold assessment of Building 15:

Weather included a clear sky, southeast winds at approximately 10 miles per hour, and an exterior temperature of approximately 72 degrees Fahrenheit (°F) at the beginning of the assessment. Exterior surfaces in the vicinity of Residence 15 were generally dry, with residual patches/piles of snow in some places nearby. Conditions did not change substantially during completion of on-site activities.

Although relative humidity observed at all interior sample locations was higher than at the exterior sample location, all sampling areas were dry at the time of the assessment.

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Visible evidence of previous moisture damage and existing mold growth were observed at multiple locations throughout all levels of the residence, as illustrated on Figure 10.

These included:

o Localized moisture damage and mold growth at lower exterior wall corners in the

First Level Living Room, NW Bedroom, NE Bedroom, top of Basement stairs, and

Laundry Room, as well as in the Second Level N Bedroom.

o Localized moisture damage and mold growth along the ceiling and exterior wall in the First Level Laundry Room and at the top of the Basement stairs.

o Localized moisture damage and mold growth along the base of the First Level

Bathroom shower surround, and at the ceiling over the shower.

o Localized mold growth on interior walls in the Basement Storage room (W, very light) and Mech Room (N, near the sink).

o Localized mold growth along windows in the First Level NW Bedroom, top of

Basement Stairs, and Laundry Room, as well as windows throughout the Second

Level. Moisture damage ranged from minimal (most windows) to significant

(Second Floor N Bedroom).

o Water intrusion along the concrete foundation wall in the Basement Storage room

(W). No visible mold was observed in this location.

Despite visible evidence of moisture damage in the areas noted above, all building materials were visibly dry during the assessment. Relative moisture readings taken on building materials along walls and ceilings ranged from 75 to 99, all of which fall within the

DRY range as reported by the GE Protimeter MMS. There were no moisture readings indicating AT RISK or WET substrate conditions.

Water damage around the bathtub in the First Level Bathroom appeared likely to have been related to deterioration of the shower surround.