Asbestos Inspection Report - FCC Tucson.pdf

4 March 2021

ASBESTOS INSPECTION

FEDERAL CORRECTIONAL INSTITUTION (FCI)

TUCSON, ARIZONA

ASBESTOS INSPECTION REPORT

Prepared for:

U.S. DEPARTMENT OF JUSTICE

Federal Bureau of Prisons Western Region 7338 Shoreline Drive Stockton, CA 95219

Prepared by:

J.C. CHANG & ASSOCIATES, INC.

Engineers ■ Architects ■ Planners 385 Van Ness Avenue, Suite 208 Torrance, California 90501 Phone: (310) 212-7644 www.jccainc.com and

NorBay Consulting Logical ■ Environmental ■ Solutions 2400 Las Gallinas Avenue, Suite 110 San Rafael, California 94903 Phone: (415) 507-9786

JCCA 20610-2

NorBay Consulting

LOGICAL ENVIRONMENTAL SOLUTIONS

2400 Las Gallinas Avenue, Suite 110 Phone: (415) 507-9786 San Rafael, California 94903 Fax: (415) 507-9760

October 27, 2020

Mr. Tim Kelly J.C. Chang & Associates, Inc.

385 Van Ness Avenue, Suite 208 Torrance, CA 90501

SUBJECT: ASBESTOS INSPECTION REPORT

FCI TUCSON, ARIZONA

8901 S. WILMOT ROAD, TUCSON, ARIZONA

Dear Mr. Kelly:

NorBay Consulting is pleased to provide the results from the asbestos inspection and sample analysis conducted at FCI Tucson, located at 8901 S. Wilmot Road in Tucson, Arizona. It was our understanding that only buildings constructed prior to 1990 which have not been completely remodeled were to be inspected. Per our conversation with FCI Tucson representatives Mr. Clark and Mr. Harbour, we were able to determine the following buildings/areas fit the description of those assumed to possibly contain asbestos.

Commissary Storage Room (former Laundry Area);

Law Library;

Education Building (former library).

The inspection included the visual observation of suspect asbestos containing building materials, collection of suspect building materials to determine asbestos content, if any, laboratory analysis, and generation of a final report. Included as an attachment to this report are the laboratory reports and associated chain of custody forms for the samples collected during our site visit.

NorBay Consulting appreciates the opportunity to provide you with these services. If you have any questions regarding this report or if you require additional information, please do not hesitate to contact me at (415) 507-9786.

Respectfully, NORBAY CONSULTING

Bob Gerhold

Bob Gerhold EPA Building Inspector #1343

Federal Correctional Institution (FCI) Asbestos Inspection Tucson, Arizona Asbestos Survey Report

JCCA 20610-2 i Table of Contents

TABLE OF CONTENTS

SECTION

1.0 EXECUTIVE SUMMARY

2.0 SURVEY PROCEDURES

3.0 SAMPLE ANALYSIS

4.0 RESULTS

5.0 FRIABLE MATERIAL

6.0 REGULATORY CONSIDERATIONS

7.0 COST

8.0 LIMITATIONS

APPENDIX

A. LAB REPORTS

B. CHAIN OF CUSTODY

C. SITE PLAN

D. BOP PREVIOUS ASBESTOS REPORT

JCCA 20610-2 Page 1-1 Section 1.0 Executive Summary

SECTION 1.0

EXECUTIVE SUMMARY

1.1 General

A. NorBay Consulting conducted an asbestos inspection at FCI Tucson located at

8901 S. Wilmot Road in Tucson, Arizona. Only buildings/areas constructed prior to 1990 which have not undergone major renovations were inspected.

Mr. Bob Gerhold, EPA Building Inspector #1343 and Mr. Mike Gerhold, EPA

Building Inspector #44537 performed the inspection on September 30, 2020.

This Executive Summary is provided solely for the purpose of overview. Any party who relies on this report must read the entire report. The Executive Summary may have omitted important details, anyone of which could be crucial to the proper understanding and risk assessment of the subject matter.

Previous documentation had indicated that the flooring mastic in the former library

(now commissary storage room) and former laundry (now education building) was assumed to contain asbestos. Samples of the mastic were collected in these areas by NorBay Consulting and analytical results indicated no asbestos was present in the mastic.

JCCA 20610-2 Page 2-1 Section 2.0 Asbestos Survey Procedures

SECTION 2.0

ASBESTOS SURVEY PROCEDURES

2.1 Procedures

A. Homogeneous areas of materials, which were suspected of containing asbestos were identified. A homogeneous area, for bulk sampling purposes, is one that seems by texture, color and wear to be uniform and applied during the same general time period. After the homogeneous areas had been identified, representative bulk sample(s) are collected for laboratory analysis. Because asbestos- containing building materials have compositional variability, it is possible to obtain different laboratory results for samples from the same homogeneous area. Therefore, a homogeneous area with at least one positive sample for will result in the entire homogeneous area being designated as an asbestos containing material.

B. The sampling strategy was partially based on guidelines established by the

Environmental Protection Agency (EPA) for school buildings (40 CFR Part 763, AHERA) which require that samples be collected from each homogeneous area of suspected ACM. Upon completion of the inspection and bulk sampling, the samples were delivered under chain of custody protocol to SGS Forensic

Analytical of Hayward, California for analysis by Polarized Light Microscopy

(PLM).

JCCA 20610-2 Page 3-1 Section 3.0 Sample Analysis

SECTION 3.0

SAMPLE ANALYSIS

3.1 Analysis

A. Bulk samples were examined by Polarized Light Microscopy (PLM) in accordance with EPA Test Method 600/R-93/116, “Method for the Determination of Asbestos in Bulk Building Materials”. The percentage of asbestos is determined by visual estimation. Laboratory results are reported based on the percentage of asbestiform minerals identified within each sample layer. The lower limit of reliable detection by PLM is 1% by volume. When asbestos or other minerals are observed in concentrations believed to be less than the reliable detection limit (less than 1%) the results are usually indicated as TRACE.

B. Upon analysis the analytical results are compared to government agency standards. Currently,the Environmental Protection Agency (EPA) define material with contains more than one percent asbestos to be an asbestos containing material (ACM).

JCCA 20610-2 Page 4-1 Section 4.0 Survey Results

SECTION 4.0

SURVEY RESULTS

4.1 Results

A. Analytical results for all samples collected during our inspection can be found in the following table.

Sample ID Material Location Results

C-VFT-1-1 & 1-2 12” vinyl floor tile with mastic and leveling compound

Commissary Storage (former laundry), raised

No Asbestos Detected

C-VFT 2-1 & 2-2 12” vinyl floor tile with mastic and leveling compound

Commissary Storage (former laundry) flat

No Asbestos Detected

LL-VFT-1-1 & 1-2 12” vinyl floor tile, white w/brown streaks & mastic Law Library No Asbestos

Detected

E-VFT 1-1 & 1-2

12” vinyl floor tile, white w/multi- colored streaks & mastic

Education (former library), lower room

No Asbestos Detected

JCCA 20610-2 Page 5-1 Section 5.0 Friable Material

SECTION 5.0

FRIABLE MATERIAL

5.1 Friable Material

A. The ability of an asbestos-containing material (ACM) to release fibers is called its friability. The legal definition of friable ACM is one “that can be crumbled, pulverized or reduced to powder by hand pressure when dry.”

Typical friable ACM’s can include but may not be limited to insulation on pipes, boilers, tanks and ducts, structural fireproofing, acoustical “popcorn” ceiling, fibrous backing on sheet vinyl flooring, acoustical ceiling tiles, and drywall/taping mud.

Typical non-friable ACM’s can include but may not limited to vinyl floor tile, asbestos cement products known by the trade name “transite”, mastics and asphalt saturated roofing products. Please note that non-friable ACM’s can become friable over time depending on exposure or usage.

It is the responsibility of the accredited inspector to determine whether a material is considered friable by either visual observations or by touch. In situations where

ACM’s are inaccessible, such as behind walls or above hard ceilings its friability should be assumed based on the type of material it is.

B. No asbestos containing materials were located during our inspection of the

Commissary Storage Room (former Laundry Area), Law Library and Education

Building (former Library) at FCI Tucson.

JCCA 20610-2 Page 6-1 Section 6.0 Regulatory Considerations

SECTION 6.0

REGULATORY CONSIDERATIONS

6.1 General

A. Current EPA National Emissions Standards for Hazardous Air Pollutants

(NESHAP) regulations require that most ACM be removed prior to demolition or renovation activities. Other regulations apply to construction activities and notification requirements for projects involving ACM. At both the federal and state levels, these include, but are not limited to Federal OSHA regulation 29

CFR 1910 and 1926.

B. As previously mentioned in this the Environmental Protection Agency (EPA) define material which contains more than one percent asbestos to be an asbestos containing material (ACM).

C. Analytical results indicated that the flooring mastics previously suspected to contain asbestos did not contain asbestos. No other suspected asbestos containing materials were noted in previous documentation.

JCCA 20610-2 Page 7-1 Section 7.0 Estimated Remediation Costs

SECTION 7.0

ESTIMATED REMEDIATION COSTS

7.1 Costs

A. This section is not applicable to this report.

JCCA 20610-2 Page 8-1 Section 8.0 Limitations

SECTION 8.0

LIMITATIONS

8.1 General

A. NorBay Consulting conducted this inspection and prepared this report for the sole and exclusive use of J.C. Chang & Associates, Inc. the only intended beneficiary of our work. NorBay Consulting has performed this inspection in a substantial and workmanlike manner, in accordance with generally accepted methods and practices of the profession, and consistent with that level of care and skill ordinarily exercised by reputable environmental consultants under similar conditions and circumstances.

B. NorBay Consulting did not attempt to dissemble mechanical equipment nor was a subsurface investigation conducted to determine if asbestos cement “transite” water, sewer or electrical utilities were present. Regardless of the thoroughness of an inspection, the possibility exists that some areas containing asbestos containing materials were not identified or inaccessible such as behind hard walls or hard ceilings.

JCCA 20610-2 Appendix A Lab Reports

APPENDIX A

LAB REPORTS

Final Report

(EPA Method 40CFR, Part 763, Appendix E to Subpart E and EPA 600/R-93-116, Visual Area Estimation) Bulk Asbestos Analysis

NVLAP Lab Code: 101459-0 3982Client ID:NorBay Consulting B308936Report Number:Robert Gerhold

Date Received:2400 Las Gallinas 10/07/20Date Analyzed:Suite 110 10/07/20Date Printed:San Rafael, CA 94903

First Reported:

39827641 - FCI Tucson, 8901 S. Wilmot Road, Tucson, AZ SGSFL Job ID:Job ID/Site:

Date(s) Collected: 09/30/2020 8Total Samples Submitted:

Total Samples Analyzed: 8

10/05/20

10/07/20

Sample ID Lab Number Asbestos

Type Percent in

Layer Asbestos AsbestosPercent in Percent in

Type TypeLayer Layer

C-VFT-1-1 12345314

Layer: White Tile ND Layer: Yellow Mastic ND Layer: Grey Non-Fibrous Material ND Layer: Black Mastic ND Layer: Beige Fibrous Material ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (10 %)

C-VFT-1-2 12345315

Layer: White Tile ND Layer: Yellow Mastic ND Layer: Black Mastic ND Layer: Beige Fibrous Material ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (10 %)

C-VFT-2-1 12345316

Layer: Black Mastic ND Layer: White Tile ND Layer: Grey Semi-Fibrous Material ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace)

C-VFT-2-2 12345317

Layer: Black Mastic ND Layer: White Tile ND Layer: Grey Semi-Fibrous Material ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace)

LL-VFT-1-1 12345318

Layer: White Tile ND Layer: Yellow Mastic ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace)

3777 Depot Road, Suite 409, Hayward, CA 94545 / Telephone: (510) 887-8828 (800) 827-FASI / Fax: (510) 887-4218

Report Number: B308936 Date Printed: 10/07/20Client Name: NorBay Consulting

Sample ID Lab Number Asbestos

Type Percent in

Layer Asbestos AsbestosPercent in Percent in

Type TypeLayer Layer

LL-VFT-1-2 12345319

Layer: White Tile ND Layer: Yellow Mastic ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace)

E-VFT-1-1 12345320

Layer: White Tile ND Layer: Yellow Mastic ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace)

E-VFT-1-2 12345321

Layer: White Tile ND Layer: Yellow/Black Mastic ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace)

Analytical results and reports are generated by SGS Forensic Laboratories (SGSFL) at the request of and for the exclusive use of the person or entity (client) named on such report.

Results, reports or copies of same will not be released by SGSFL to any third party without prior written request from client. This report applies only to the sample(s) tested.

Supporting laboratory documentation is available upon request. This report must not be reproduced except in full, unless approved by SGSFL. The client is solely responsiblefor the use and interpretation of test results and reports requested from SGSFL. SGSFL is not able to assess the degree of hazard resulting from materials analyzed. SGS Forensic Laboratories reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified. All samples were received in acceptable condition unless otherwise noted.

Note: Limit of Quantification ('LOQ') = 1%. 'Trace' denotes the presence of asbestos below the LOQ. 'ND' = 'None Detected'.

Tad Thrower, Laboratory Supervisor, Hayward Laboratory

3777 Depot Road, Suite 409, Hayward, CA 94545 / Telephone: (510) 887-8828 (800) 827-FASI / Fax: (510) 887-4218

JCCA 20610-2 Appendix B Chain of Custody

APPENDIX B

CHAIN OF CUSTODY

JCCA 20610-2 Appendix C Site Plan

APPENDIX C

SITE PLAN

JCCA 20610-2 Appendix D BOP Previous Asbestos Report

APPENDIX D

BOP PREVIOUS ASBESTOS REPORT

30 October 2009

Federal Bureau of Prisons

WESTERN REGION

Prepared for:

DEPARTMENT OF JUSTICE

Federal Bureau of Prisons 500 First Street NW Washington, District of Columbia 20534

Prepared by:

J.C. CHANG & ASSOCIATES, INC.

Engineers Architects Planners 385 Van Ness Avenue, Suite 208 Torrance, California 90501 Telephone: (310) 212-7644 Facsimile: (310) 212-5272 www.jccainc.com

In association with:

MEC, INC.

4708 Angola Road Toledo, Ohio 43615

JCCA 09600-3

Department of Justice Asbestos Reports Federal Bureau of Prisons

ASBESTOS REVIEW AND REPORT

TABLE OF CONTENTS

WESTERN REGION

Lompoc FCI/FPC/ICC/USP Safford FCI San Diego MCC Terminal Island FCI Tucson FCI

JCCA 09600-3 Table of Contents Western Region bop37654 Highlight

FRIABLE NON-FRIABLE TOTAL

$1,211,900.00 $413,600.00 $1,625,500.00

SAFFORD FCI $165,000.00 $0.00 $165,000.00

SAN DIEGO MCC $185,000.00 $3,000.00 $188,000.00

$112,250.00 $67,500.00 $179,750.00

$0.00 $16,300.00 $16,300.00

$1,674,150.00 $500,400.00 $2,174,550.00

WESTERN REGION

FACILITY NAME

TERMINAL ISLAND FCI

TUCSON FCI

J.C. CHANG & ASSOCIATES, INC.

SUBTOTAL - WESTERN REGION

LOMPOC FCI/FPC/ICC/USP

bop37654 Highlight bop37654 Highlight

30 October 2009

FCI TUCSON, ARIZONA

Federal Bureau of Prisons, Western Region Review Date: July 15, 2009

ASBESTOS REVIEW

AND REPORT

Prepared for:

DEPARTMENT OF JUSTICE

Federal Bureau of Prisons 500 First Street NW Washington, District of Columbia 20534

Prepared by:

J.C. CHANG & ASSOCIATES, INC.

Engineers Architects Planners 385 Van Ness Avenue, Suite 208 Torrance, California 90501 Telephone: (310) 212-7644 Facsimile: (310) 212-5272 www.jccainc.com

In association with:

MEC, INC.

4708 Angola Road Toledo, Ohio 43615

JCCA 09600-3

FCI Tucson, Arizona Review Date: July 15, 2009

INTRODUCTION

This Asbestos Review and Report provides an estimate of the extent of friable and non-friable Asbestos Containing Materials (ACM) remaining in each of the buildings at the

Federal Correctional Institution at Tucson, Arizona as well as a cost estimate associated with the abatement of these materials.

The review was carried out by a multi-disciplinary team of professionals comprised of environmental consultants, architects, and a mechanical engineer. The team was accompanied by FBOP representatives and assisted by the FCI Tucson Staff.

The team reviewed the existing asbestos survey completed in 2005. After the team’s preliminary review of the reports the team spoke with Mr. T. Cook (Facilities) and Mr. W.

Hammock (Facilities) to determine if any abatement had taken place between the date of the survey and July 15, 2009.

The team then walked through the buildings reported to contain ACM to verify whether or not the asbestos still remained in the building. The teams also noted the extent and locations of asbestos not included in the original asbestos survey.

The team representing J.C. Chang & Associates, Inc. consisted of Mr. Seung H. Lee.

The team representing Midwest Environmental Control, Inc. consisted of Mr. Dale Bruhl

III.

The team was accompanied by Ms. Marie Ferritto from the Federal Bureau of Prisons.

JCCA 09600-3 Introduction

FCI Tucson, Arizona

CLARIFICATIONS

The cost estimates provided by J.C. Chang & Associates, Inc. incorporate the following clarifications, information and computing methods:

1. The estimates are based on the assumption that the BOP will undertake an asbestos abatement project that is comprehensive and complete in scope for each building. The assumption is that an entire building or a substantial portion of each building will be vacated and abated in one to four phases. This cost estimate cannot be considered accurate if the asbestos removal project is drawn out over a period of years with numerous phases.

2. Due to the particular structural characteristics of some facility buildings, there exists concealed asbestos materials in the form of piping and pipe fittings behind walls and ceilings. These materials are not identified in many of the original asbestos surveys and therefore cannot be accurately quantified. In order to budget for the removal of these materials, we have added a “concealed piping” cost factor where applicable and have identified this cost as a separate line item for each building. It must be noted that this is an estimate and cannot be relied on as 100% accurate.

3. The cost estimates are based on standard Federal EPA/OSHA asbestos abatement regulations and work procedures. There are some states such as California and New York with stricter regulations that could affect these numbers by a factor of up to 5%.

4. The estimates incorporate BOP costs related to abatement specification development, costs of project bidding, third party project over-site and air sampling and analysis. Estimates do not take into consideration varying prevailing wage rates. The allocated cost is based on national standards and could vary by region and State. (Approximately $33.00 per hour for asbestos workers).

5. Estimates do not include work relating to windows, (potential asbestos containing caulk), or roofing materials. Transite roofing and siding are included in the estimate.

6. No cost factor has been considered to include potential Historical Building compliance issues.

JCCA 09600-3 Clarifications

FACILITY NAME: DATE:

SURFACING FLOORING

BLDG LF SF SF LF SF FRIABLE NON-FRIABLE TOTAL

Laundry

J.C. CHANG & ASSOCIATES, INC.

FACILITY SUMMARY

PRESUMED ASBESTOS CONTAINING BUILDING MATERIALS:

Tucson FCI 10/30/2009

SFSF

FRIABLE

COSTCOMMENTSMISC

NON - FRIABLE

TSI FIREPROOF TRANSITE

$3,500.00 assumed mastic assumed mastic

Library $0.00

$12,800.00

$3,500.00

$0.00

$3,500.00

$12,800.00 $12,800.00

$16,300.00$16,300.00

GRAND TOTAL

(ALL BUILDINGS)

$0.00

* Cost includes third party oversight. 1 of 1 10/30/2009