3a. Recent HazMat Investigation Report, dtd 23 Jan 19 (1).pdf

SUSTAINABLE ENVIRONMENT, ENERGY,

HEALTH & SAFETY PROFESSIONAL SERVICES

Https://Nortechinc.Sharepoint.Com/00-Jobs/2018/1026/Shared Documents/Reports/Drafts/Blackstartgenerator-Hazmatreport-Final.Docx

NORTECH, Inc.

Accounting Office:

2400 College Rd

Fairbanks, AK 99709 907.452.5688

907.452.5694 Fax

3105 Lakeshore Drive Suite A106

Anchorage, AK 99517 907.222.2445

907.222.0915 Fax

5438 Shaune Drive Suite B

Juneau, AK 99801 907.586.6813

907.586.6819 Fax

www.nortechengr.com

January 23, 2019 Sent via email to:

Electric Power Systems, Inc. jrowland@espinc.com 3305 Arctic Boulevard, Suite 200 Anchorage, AK 99503

Attn: Jason Rowland, PE

RE: Hazardous Materials Investigation and Design Repair Black Start Generator, Building 6203, EAFB CHPP / FTQW 12-1012

Jason:

NORTECH Sustainable Environment, Energy, Health & Safety Professional Services is pleased to provide Electric Power Systems (EPS) with this Limited Hazardous Materials Investigation Report for the Eielson Air Force Base (EAFB) Combined Heat and Power Plant (CHPP) Design Repair Black Start Generator Project. The following is a brief synopsis of the background, scope of work, methodology, field activities, and sampling results with discussion, including conclusions and recommendations where appropriate.

Background and Scope of Work EAFB selected the EPS team to perform the investigation and design of upgrades to the CHPP Black Start Generator. The specific goals of the project are to replace the existing Black Start Generator, repairing heating and ventilation in the Black Start room.

The 2.5 MW diesel-powered Black Start Generator is housed on the lower level, inside the CHPP on EAFB. This unit provides a “black start” capability for restoring electrical power without relying on the external electric power transmission network in the event of a total power outage. The current Black Start generator was manufactured by Electro-Motive Division (EMD) of the General Motors Corporation and was installed in 1987 as part of a major plant upgrade.

Due to excessive emissions, Eielson’s Air Permit includes operational limits for the unit. The Black Start generator is not allowed to consume more than 157,000 gallons of fuel in any rolling 12-month period and the peak output is limited to 1,800 kW. The current Black Start Generator was used for peak load shaving, but due to the fuel and output limits, the practice is no longer possible.

NORTECH’s scope of work is to provide limited hazardous material investigation services. This included sampling suspect asbestos containing building material, analyzing paint for lead content, and sampling settled dust for asbestos, and lead contamination within project areas of this phase of the project.

Methodology Project efforts were completed in accordance with NORTECH Hazardous Material Standardized Methodologies (v17). Project work was performed by an experienced Health and Safety Professional with current EPA AHERA inspector certification

Hazardous Materials Investigation and Design Repair Black Start Generator EAFB CHPP/ FTQW 12-1012

Page 2Https://Nortechinc.Sharepoint.Com/00-Jobs/2018/1026/Shared Documents/Reports/Drafts/Blackstartgenerator-Hazmatreport-Final.Docx utilizing industrial hygiene inspection practices dedicated to the anticipation, recognition, evaluation and control of those materials within workplaces. Work was reviewed and signed off by a registered Professional Engineer.

All samples were sent to EMSL Analytical, Inc. (EMSL), a laboratory certified through the National Voluntary Laboratory Accreditation Program (NVLAP). The suspected asbestos samples were analyzed by Phase Light Microscopy (PLM) using the EPA Method 600 or ASTM 6480. Lead dust samples were analyzed by Flame AAS (SW 846 3050B/7000B). This method measures lead loading, the amount of lead dust on a specific surface area.

Field Activities On October 19, 2018, Hilary Clifton and Jeanette Daniel of NORTECH completed the hazardous materials investigation for the CHPP Black Start Generator. The main scope of work for the project is to replace the existing Black Start Generator and repair the heating and ventilation system in the existing generator room. The following summarizes field activities by category of hazardous material.

Asbestos Containing Material (ACM) Sampling Building materials suspected of containing asbestos included joint compound, gypsum wallboard, generator caulking, floor covering and mastic, roof caulking, insulation, pipe wrap thermal system insulation (TSI) and pipe caulking. A total of 8 samples were collected from both interior and exterior locations and submitted for laboratory analysis to determine the percent content of asbestos by the polarized light microscopic (PLM) method. Sample locations are shown on Figure 3.

Lead Based Paint (LBP) A handheld NITON XLP-303A X-Ray fluorescence spectrometer (XRF) was used to analyze 21 various paint locations for lead in paint. This included the generator scheduled for replacement along with interior supporting structures such as I-beams and walls, and exterior components that will be affected. The specific locations, materials, and colors are shown in Figure 3.

Dust Sampling Visible accumulations of dust were observed on horizontal surfaces, including the floor inside of the Black Start generator room. Lead in settled dust was suspected due the facility burning coal and asbestos contamination was suspect due to the historical use of thermal systems insulation (TSI) and other ACM materials throughout the facility.

To quantify the amount of dust present, the inspector used a scale from 1 to 5 with the following descriptions:

1 – low to no visual dust or debris present 2 – low dust, substrate is visible 3 – moderate dust, substrate is partially obstructed 4 – heavy dust, substrate is no longer visible 5 – extensive dust, non-uniform distribution, accumulations of ≥ 0.25” of dust and debris

A visual assessment determined that a low to moderate amount of settled dust (rated 2-3) is present on top of horizontal surfaces throughout the facility scope of work area. A representative dust sample for lead was collected from the top of blue/green tank and the Black Start generator. A representative dust sample for asbestos was collected from the top of the blue metal compressor and from the Black Start Generator. Sample locations are shown on Figure 3.

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Universal Waste and Other Materials Requiring Special Handling Lighting in the Black Start room will require removal as part of this project. The lights could not be accessed for the inspection, however, based on lighting observed elsewhere in the CHPP, mercury fluorescent bulbs, high pressure sodium (HPS) lamps, HID, or LED fixtures may be present. Fluorescent tubes and HPS lamps contain mercury and light fixtures with magnetic ballasts can contain PCBs.

Environmental Concerns Soil and groundwater samples were not collected as part of this investigation. Information regarding previous investigations in the vicinity of the project area was provided by EAFB for review. Additional information available on the Alaska Department of Environmental Conservation (ADEC) Contaminated Sites online database was also reviewed. This information is summarized in the Sample Results and Discussion section below.

Sample Results with Discussion Sample locations and summary tables are depicted on the attached project figures. A copy of all laboratory results is attached. The following is a discussion of sample results with analysis by hazardous material type.

Asbestos No ACM was identified in the CHPP Black Start Generator scope of work area. No materials had an asbestos content in excess of 1%, the regulatory threshold of a building material to be considered ACM. ACM samples, descriptions, locations and results are presented in Figure 3.

Since no ACM is present, no abatement of ACM is necessary prior to construction and demolition (C&D). The waste stream will be considered non-ACM.

Demolition will be required to meet the general demolition NESHAP of no visible dust emissions during demolition.

Lead Based Paint XRF sample results above the EPA Housing and Urban Development (HUD) limit of 1.0 mg/cm2 were not observed. Sample results ranged from 0.0 to 0.11 mg/cm2. Due to the minimal amount of lead in paint observed, the debris waste stream is considered non-hazardous for leachable lead.

Painted surfaces and finishes that contain lead at any concentration also represent a potential hazard for workers who are performing lead trigger tasks such as burning, sanding or grinding.

Demolition design documents should provide contractor notification of the lead content of the lead containing materials as a potential work hazard. The approved demolition work plan should document lead hazard reduction practices, proper PPE used, lead awareness training for onsite workers, and other safety measures to be implemented during building demolition.

Settled Dust The dust samples collected within the Black Start Generator room are a non-detect for asbestos fibers. Precleaning of the Black Start Generator scope of work area can be completed without concern for asbestos exposure and cleaning material can be disposed of as non-asbestos containing.

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The current federal lead dust hazard and clearance standards (see below) were incorporated into regulations by the U.S. EPA Housing and Urban Development (HUD). The HUD lead hazard standard for floors is ≥ 40 µg/ft2. There are not currently lead standards for commercial and industrial buildings.

The surface dust samples collected from horizontal surfaces within the Black Start room indicate deposits of lead ranging from 21 µg/ft2 to 110 µg/ft2. The tabulated results and sample locations are shown in Figure 3.

In summary, dust on and around the Black Start Generator are non-detect for asbestos fibers but do contain low concentrations of lead. Additionally, previous sampling events throughout the CHPP building have confirmed the presence of RCRA-8 metals in dust as well.

In addition, OSHA regulations are set to protect worker inhalation exposure, and are not correlated to surface dust concentrations. The worker inhalation permissible exposure level for airborne lead is 50 µg/m3.

Electrical panels, transformers, conduit, the Black Start Generator and other horizontal surfaces with settled dust that will be disturbed during project efforts should be precleaned before demolition begins. Precleaning efforts should be performed by qualified workers who at a minimum have taken lead awareness training and avoid lead trigger tasks.

All dust, PPE, and other materials generated during the dust cleaning activities may be lead hazardous. A lead toxicity characteristic leaching procedure (TCLP) sample is recommended to characterize project PPE and cleaning materials following dust cleaning to determine appropriate handling and disposal requirements.

Universal Waste Universal waste was found to be consistent with items typically found in commercial and industrial buildings. Lighting in the building was observed to consist of fixtures that mercury containing fluorescent light bulbs and HPS lamps. These items should be removed from the project area as necessary and properly disposed of before renovation or demolition. All light ballasts and transformers should be inspected before disposal to ensure they say “no-PCB” or other markings indicating there is no PCB fluid in the ballast.

Environmental Concerns Project work will require the excavation of soil in the vicinity of the Black Start Generator for the installation of supplementary equipment for the new engine. Information provided by EAFB suggests that previous sampling events have identified contaminants in soil in areas likely to be impacted by the project work. The following is a summary of known conditions near the project area:

Based on drawings provided by EAFB dated October 2018, Source Area ST048 (ADEC File # 107.38.070) encompasses the exterior areas adjacent to the Black Start Generator room.

Contaminants of concern have been identified as fuel-related and include benzene, toluene, ethylbenzene, and xylenes (BTEX). Gasoline range organics (GRO) and diesel range organics (DRO) were also identified in groundwater in the area. The source of the contamination is former buried fuel pipelines that are no longer in use and were abandoned in place.

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Prohibitions and restrictions within Source Area ST048 state that any activity that may result in the disturbance of soil requires approval by Installation Management (CES/CEI). Completion of Form 103 (Base Civil Engineering Work Clearance), and approval prior to commencing any work. Contaminated soil removed from the Site must be treated or disposed in accordance with state and federal regulations. Source Area ST048 has a 200-foot buffer around it until better delineation of the release can be defined. A contaminated soil specification should be included in the project design documents.

Additionally, during a sewer line excavation performed in May 2016, it was determined through sampling that PAH compound benzo(a)pyrene is present above cleanup levels in that specific project area. This project was located relatively close to the proposed Black Start project area.

Conclusions and Recommendations Based on the findings of the hazardous material assessment, the following conclusions and recommendations have been developed regarding the EAFB Black Start Generator Upgrade Project:

Asbestos Containing Material

No ACM was identified

Lead Based Paint No LBP was observed in excess of 1.0 mg/cm2 Materials containing lower concentrations of lead are also present Lead trigger tasks and appropriate controls should be identified in the Contractor’s

Demolition Work Plan

Settled Dust

Dust on horizontal surfaces is non-detect for asbestos fibers Dust on horizontal surfaces show lead contamination both above and below the EPA

HUD standard o It is recommended horizontal surfaces are cleaned and abated/decontaminated using a project specific work plan o The work plan should include lead abatement work practices, engineering controls, HEPA filtration, no visible emissions and PPE Data collected in other areas of the CHPP indicates the presence of RCRA-8 metals in dust o All dust, PPE, and other materials generated during the cleaning activities may be lead/metal hazardous o A TCLP sample should be collected from project PPE and cleaning materials following dust cleaning to determine handling and disposal requirements

Universal Waste Mercury containing fluorescent light bulbs and HPS lamps, PCB light ballasts and transformers involved in the project work scope should be removed from the building and properly disposed of before renovation or demolition

Environmental Concerns

The project area is located within Source Area ST048 with known contamination and long term monitoring

Page 6Https://Nortechinc.Sharepoint.Com/00-Jobs/2018/1026/Shared Documents/Reports/Drafts/Blackstartgenerator-Hazmatreport-Final.Docx o This area has restrictions related to the disturbance of soil and/or groundwater The appropriate forms and permissions must be approved prior to beginning work A contaminated soil specification should be included in project design documents

This hazardous building materials assessment was conducted to identify the potential hazards in preparation of the EAFB Black Start Generator Upgrade Project. All information about hazardous material associated with the building should be made available to employees, contractors and/or abatement/demolition contractors associated with the renovation or demolition of the Black Start project. Specific abatement work practices may require additional sampling by the contractor to comply with OSHA worker exposure regulatory guidelines.

If you have any questions or require additional professional services or advice, please let us know. We thank you for the opportunity to work with you on this project and appreciate your confidence in our Firm.

Sincerely, NORTECH

Jeanette Daniel Peter Beardsley, PE Environmental Health & Safety Professional Principal

Attachments: Figures

Photo Pages Lab Results

Methodology

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AutoCAD SHX Text 2400 College Road, Fairbanks, AK. 99709, 907-452-5688

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ENVIRONMENT, ENERGY, HEALTH & SAFETY CONSULTANTS

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ENVIRONMENT, ENERGY, HEALTH & SAFETY CONSULTANTS

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< ²

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Lead Dust Data Table Surveyed by Nortech: October 2018

Sample ID Location Lead (μg/ft²)

L1 Square Station 110

L2 Generator 21

Lead Data Table Surveyed by Nortech: October 2018

Sample ID Color Location Substrate Lead 3242 Tan Wall Concrete 0.0

3243 Red Floor Concrete 0.0

3244 White I-Beam Steel 0.03

3245 Blue Compressor Metal 0.02

3246 Blue/Green Tank Metal 0.0

3247 Red Curb Concrete 0.0

3248 Blue Blackstart Metal 0.0

3249 Tan Bulletin Board Wood 0.0

3250 Tan Column Concrete 0.0

3251 Red Steps Concrete 0.0

3252 Tan Door Metal 0.0

3253 Tan Door Frame Metal 0.0

3255 Tan Door Frame Metal 0.0

3256 Yellow Battery Stand Metal 0.0

3257 Gray Blackstart Metal 0.01

3258 Tan Main Floor Control Metal 0.0

3259 Tan Siding Metal 0.0

3260 Tan Condenser Support Metal 0.11

3261 Tan Side of Condenser Metal 0.05

3262 Tan Bollard Concrete 0.0

3263 Red Overhang Metal 0.0

Asbestos Dust Data Table Surveyed by Nortech: October 2018

Sample ID Location Asbestos (structures/cm²)

A1 Square Station ND

A2 Generator ND

Asbestos Data Table Surveyed by Nortech: October 2018

Sample ID Description Result A3 gray caulking ND

A4 white floor sheet ND

A5 brown/white gwb ND

A6 black caulking ND

R1 gray caulking ND

R2 gray caulking ND

R3 gray/blue caulking ND

E1 gray insulation ND

E2 black pipe wrap ND

AutoCAD SHX Text LEAD BASED PAINT SAMPLE NEGATIVE (< 1 mg/cm²)(HUD) 1 mg/cm²)(HUD))(HUD)

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ASBESTOS SAMPLE LOCATIONS NEGATIVE (<1% ASBESTOS)

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ASBESTOS SAMPLE LOCATIONS POSITIVE ( 1% ASBESTOS)>= 1% ASBESTOS)

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NOTE: SAMPLE A5 WAS COLLECTED FROM THE MAIN FLOOR AT THE OPENING NEAR THE DAY TANK.

Https://Nortechinc.Sharepoint.Com/00-Jobs/2018/1026/Shared Documents/Reports/Drafts/Doc1.Docx

Black Start Generator EAFB CHPP/ FTQW 12-1012 Report

November 19, 2018

Photo 1: Black Start Generator inside of EAFB CHPP

Photo 2: Black Start Generator Insulated Asbestos Free Labeled Ducting

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Photo 3: Blue Metal Compressor, Asbestos Wipe Sample Area

Photo 4: Blue/Green Metal Tank, Lead Wipe Sample Area

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Photo 5: Black Start Generator, Lead Wipe Sample Area

Photo 6: Black Start Generator, Asbestos Wipe Sample Area

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Photo 7: CHPP Exterior Black Start Components

Photo 8: CHPP Exterior Black Start Components

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041831811EMSL Order:

Customer ID: NORT69

Customer PO: 18-1026

Project ID:

Attention: Phone:Jeanette Daniel (907) 452-5688

Fax:Nortech Environmental & Engineer Cnslt. (907) 452-5694

Received Date:2400 College Road 10/23/2018 9:20 AM

Analysis Date:Fairbanks, AK 99709 10/31/2018

Collected Date: 10/18/2018

Project:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

A3

041831811-0003

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Generator - Caulking

A4-Floor Sheet

041831811-0004

None DetectedNon-fibrous (Other)90%Synthetic10%White

Fibrous

Homogeneous

Floor Sheet

A4-Mastic

041831811-0004A

None DetectedNon-fibrous (Other)100%Yellow/Green

Non-Fibrous

Homogeneous

Yellow Mastic

A5

041831811-0005

None DetectedNon-fibrous (Other)77%Cellulose

Glass

15%

8%

Brown/White

Fibrous

Homogeneous

GWB

A6

041831811-0006

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Roof-Exterior Pipe

Caulking

R1

041831811-0007

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Roof Caulking

R2

041831811-0008

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Roof Caulking

R3

041831811-0009

None DetectedNon-fibrous (Other)100%Gray/Blue

Non-Fibrous

Homogeneous

Roof Caulking

E1

041831811-0010

None DetectedNon-fibrous (Other)20%Glass80%Gray

Fibrous

Homogeneous

Exterior Insulation

(Friable)

E2

041831811-0011

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Exterior-Pipe Wrap

Analyst(s)

Amy Johnson (10) Benjamin Ellis, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 "Interim

Method"), but augmented with procedures outlined in the 1993 ("final") version of the method. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations . Interpretation and use of test results are the responsibility of the client. All samples received in acceptable condition unless otherwise noted. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. EMSL recommends gravimetric reduction for all non -friable organically bound materials prior to analysis. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NYS ELAP 10872, NJ DEP 03036, PA ID# 68-00367

Initial report from: 10/31/2018 08:37:03

Page 1 of 1ASB_PLM_0008_0001 - 1.78 Printed: 10/31/2018 8:37 AM

200 Route 130 North Cinnaminson, NJ 08077

Phone/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

EMSL Analytical, Inc.

041831811EMSL Order:

NORT69Customer ID:

18-1026Customer PO:

Project ID:

Attention: Phone: (907) 452-5688Jeanette Daniel

Nortech Environmental & Engineer Cnslt. Fax: (907) 452-5694

2400 College Road Received Date: 10/23/2018 9:20 AM

Fairbanks, AK 99709 Analysis Date: 10/31/2018

Collected Date: 10/18/2018

Test Report: Asbestos Analysis of Dust Samples Using Method ASTM 6480

Sample ID

Area

Sampled

(cm²)

Asbestos

Type

Asbestos

Structures

Sensitivity

(str/cm²)

Concentration

(str/cm²) Comments

None

Detected

523 <1560<2.99A1 Due to excessive particulate the target analytical sensitivity of 260 str/cm² was not reached.

041831811-0001

None

Detected

250 <748<2.99A2

041831811-0002

Analyst(s):

Ted Young (2) Benjamin Ellis, Laboratory Manager or other approved signatory

EMSL maintains liability to cost of analysis . This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client. Samples received in good condition unless otherwise noted.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ

Initial report from: 10/31/2018 08:53:52

ASB_TEMMV_0014 Printed 10/31/2018 8:53:53AM Page 1 of 1

Client Sample Description ConcentrationLab ID Analyzed Area Sampled Lead

Collected

EMSL Analytical, Inc.

200 Route 130 North, Cinnaminson, NJ 08077 Phone/Fax: (856) 303-2500 / (856) 786-5974 http://www.EMSL.com cinnaminsonleadlab@emsl.com

Attn: Jeanette Daniel Nortech Environmental & Engineer Cnslt.

2400 College Road Fairbanks, AK 99709

Received: 10/23/18 10:00 AM Fax: (907) 452-5694 Phone: (907) 452-5688

10/18/2018Collected:

Test Report: Lead in Dust by Flame AAS (SW 846 3050B/7000B)*

201812361 CustomerID: NORT69 CustomerPO: 18-1026 ProjectID:

EMSL Order:

Site: Square Station 201812361-0001L1 1 110 µg/ft²ft²10/29/201810/18/2018

Site: Generator 201812361-0002L2 1 21 µg/ft²ft²10/29/201810/18/2018

Phillip Worby, Lead Laboratory Manager or other approved signatory

Test Report ChmSnglePrm/nQC-7.32.3 Printed: 10/30/2018 9:36:15 AM

*Analysis following Lead in Dust by EMSL SOP/ Determination of Environmental Lead by FLAA. Reporting limit is 10 µg/wipe. ug/wipe =µg/ft² x area sampled in ft². Unless noted, results in this report are not blank corrected. This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities (such as volume sampled) or analytical method limitations. Samples received in good condition unless otherwise noted. The lab is not responsible for data reported in µg/ft² which is dependent on the area provided by non-lab personnel. The test results contained within this report meet the requirements of NELAC unless otherwise noted. "<" (less than) results signifies that the analyte was not detected at or above the reporting limit. Measurement of uncertainty is available upon request. The QC data associated with the sample results included in this report meet the recovery and precision requirements unless specifically indicated otherwise. Definitions of modifications are available upon request.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NELAP Certifications: NJ 03036, NY 10872, PA 68-00367, AIHA-LAP, LLC ELLAP 100194, A2LA 2845.01

Initial report from 10/30/2018 09:36:15 http://www.EMSL.com mailto:cinnaminsonleadlab@emsl.com