RFIs_2_through_7.pdf

U.S. General Services Administration 230 South Dearborn Street Chicago, IL 60543

REQUEST FOR INFORMATION (RFI) RESPONSE

Project: Bricker FB Public Restroom Renovation and Accessibility Upgrades Project No: 20328 / ROHOO195

RFI No: PRE-BID RFI 002 Date Submitted: 06/27/18

SUBJECT: ASBESTOS CONTAINING MATERIAL REPORT

TO: Johanna Nieves

230 S. Dearborn St. Suite 3600 Chicago, IL 60604

FROM: Cary Kubiak 230 S. Dearborn St. Suite 3600 Chicago, IL 60604

SCHEDULE IMPACT: SPECIFICATIONS:

COST IMPACT: DRAWINGS

REQUESTED ACTION: Clarification OTHER: Limited Hazardous Material Survey July 18, 2014

DESCRIPTION / QUESTION: (Describe the question or type of information requested)

Table of Contents list Owner Provide Documents Asbestos Containing Materials Report – July 18, 2014 This is not included in the Specifications as listed.

RECOMMENDATION: (Sender’s recommended solution, including cost and/or schedule consideration)

RESPONSE:

See attached CTL Engineering Of Ohio, Inc. Limited Hazardous Material Survey for the Subject project.

NAME AND TITLE (Type, Print or Stamp) SIGNATURE DATE

CARY M. KUBIAK, Project Manager - GSA

Cc To: NAME ORGANIZATION PHONE EMAIL Johanna Nieves GSA (312) 353-7659 Johanna.nieves@gsa.gov Roger Schulte GSA (330)375-5408 Roger.schulte@gsa.gov Scott Day GSA (937) 225-2714 Scott.day@gsa.gov Joseph Pfammatter GSA (513) 337-0839 Joseph.pfammatter@gsa.gov NOTE: This response is not an authorization to proceed with work involving additional cost, time or both. If any response requires change to the Contract Documents, a Change Order, Construction Change Directive or a Minor Change in the work must be executed in accordance with the Contract Documents.

06/28/18

CTL Engineering of Ohio, Inc.

2860 Fisher Road, P.O. Box 44548, Columbus, Ohio 43204-3538 Phone: 614/276-8123 Fax: 614/276-6377 Email: ctl@ctleng.com AN EMPLOYEE OWNED COMPANY

Offices: Ohio, Indiana, West Virginia

July 18, 2014

Attention: Mr. Jay Boone, AIA Partner Phone: (614) 461-4664 Email: JBoone@moodynolan.com

Reference: Limited Hazardous Materials Survey Project Name: J.W. Bricker Fed Building – Restroom Upgrade Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Proposal No. 14510658COL

Dear Mr. Boone:

In accordance with our contract, on behalf of Moody Nolan Ltd., Inc. (Client), CTL Engineering of Ohio, Inc. (CTL Engineering) performed a Limited Hazardous Materials Survey to include Asbestos, Lead-Based Paint, and Universal Waste materials for the Public Restrooms on each floor of the John W. Bricker Federal Building located at 200 North High Street in Franklin County; Columbus, Ohio 43215. The survey is termed ‘Limited’ since only the building portions that may potentially be disturbed by the proposed Public Restroom Renovation & Accessibility Upgrade project were surveyed for hazardous materials, including, Asbestos-Containing Materials (AMC’s), Lead-Based Paint (LBP), and Universal Waste materials that may require special disposal and/or handling if impacted during renovation activities. Only the Restrooms and Locker Rooms from the Seventh Floor down to the Basement were assessed as part of this survey.

We appreciate the opportunity to provide you with these professional services. If you should have any questions or require further information, please feel free to contact Mr. Rittenhouse at

(614) 276-8123, ext. 1259. Please refer to CTL Engineering Project No. 14510658COL in all future inquiries.

Respectfully submitted, CTL ENGINEERING of OHIO, INC.

Chris Rittenhouse, B.S.

Ohio Asbestos Hazard Evaluation Specialist No. 35305 Lead-Based Paint Inspector #LI9174 (Project Manager)

Consulting Engineers ● Testing ● Inspection Services ● Analytical Laboratories Established 1927

Moody/Nolan Ltd., Inc.

300 Spruce Street, Suite 300 Columbus, Ohio 43215

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 1 Site Name: J.W. Bricker Fed Building Restroom Upgrade Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

1.0 EXECUTIVE SUMMARY

In accordance with our contract, on behalf of Moody Nolan Ltd., Inc. (Client), CTL Engineering of Ohio, Inc. (CTL Engineering) performed a Limited Hazardous Materials Survey to include Asbestos, Lead-Based Paint, and Universal Waste materials for the Public Restrooms on each floor of the John W. Bricker Federal Building located at 200 North High Street in Franklin County; Columbus, Ohio 43215. The survey is termed ‘Limited’ since only the building portions that may potentially be disturbed by the proposed Public Restroom Renovation & Accessibility Upgrade project were surveyed for hazardous materials, including, Asbestos-Containing Materials (AMC’s), Lead-Based Paint (LBP), and Universal Waste materials that may require special disposal and/or handling if impacted during renovation activities. Only the Restrooms and Locker Rooms from the Seventh Floor down to the Basement were assessed as part of this survey.

Please note that the information provided in the Executive Summary is a brief summary of the findings and should be read in conjunction with the entire report.

1.1 Category I Non-Friable Asbestos-Containing Materials (ACM)

The following Category I non-friable asbestos-containing materials, exhibiting asbestos concentration above the regulatory threshold of 1%, were identified during the survey.

Homogeneous Sampling

Area

Description Location % Asbestos Condition Estimated Quantity

Black Mastic Associated with 12”x12” Brown Floor Tile

Men’s Restroom Closets Floors 3-7, Second Floor Vending Area

1.6% Chrysotile Good 325 SF

SF = Square-feet

If the 12”x12” brown floor tile with asbestos-containing black mastic will be impacted by building renovations, the black mastic and all associated flooring materials should be abated by a state certified Asbestos Abatement Contractor in accordance with the Asbestos NESHAPS, 40 CFR Part 61, as well as the work practices and prohibitions set forth in the OSHA Asbestos in Construction Standard, 29 CFR 1926.1101.

1.2 Presumed Asbestos-Containing Materials (PACM)

As not to damage or uninstall the FRP wall board through destructive sampling, the material was not sampled, but is presumed to contain asbestos.

Typically, fire rated doors contain an insulating core that may contain asbestos; however, in order to sample the core, destructive sampling is conducted. In this case, since the doors were in very good condition and could also be re-used, these were not sampled, but are presumed to contain asbestos.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 2

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

Homogeneous Sampling

Area Description Location % Asbestos Condition Estimated

Quantity

- *Mastic Behind FRP wall board

Basement – Men’s/Women’s Locker

Rooms PACM Good 150 S.F.

- *Fire Doors All Restrooms and Locker Rooms (Basement through

7th floor) PACM Good 36 Each

PACM = Presumed Asbestos Containing Material/ S.F. = Square-feet / * CAT II NF

The presumed asbestos-containing mastic behind the FRP board located in the Basement Men’s and Women’s Locker Rooms should be abated by a State Certified Asbestos Abatement Contractor or the material should be sampled by a certified Asbestos Evaluation Specialist prior to renovation activities to confirm whether or not the material contains asbestos.

If the PACM fire doors are not re-used and will be impacted by building renovations, these doors could be removed, wrapped and disposed of by a State certified Asbestos Abatement Contractor in accordance with the Asbestos NESHAPS, 40 CFR Part 61, as well as the work practices and prohibitions set forth in the OSHA Asbestos in Construction Standard, 29 CFR 1926.1101. In the alternative, these doors should be sampled by a certified Asbestos Evaluation Specialist to confirm whether or not these are asbestos-containing.

A Bulk Sample Summary table that identifies all suspect materials sampled, sample locations, corresponding photograph numbers, and analytical results is included in Appendix B, laboratory reports and chain-of-custody forms are included in Appendix C, and sample locations are identified on the design plans provided by the Client in Appendix D.

1.3 Lead-Based Paint (LBP)

Forty-two (42) representative painted surfaces were tested with a non-destructive XRF analyzer to determine their lead content. Of the forty-two (42) surfaces tested, none of the surfaces tested were found to contain lead concentrations above the EPA regulatory threshold of 1 mg/cm2.

Of the forty-two surfaces tested, twenty-four (24) surfaces were found to contain some concentrations of lead which were below the EPA regulatory threshold of 1 mg/cm2.

Surfaces that were found to contain lead concentrations below the EPA’s regulatory threshold are identified in the table below:

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 3

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

Reading No. Description Location Sampled Lead Content

(mg/cm2)

2 Beige Ceramic Wall 7th Floor Men’s R.R. 0.02 4 Brown Metal Door Jam 7th Floor Men’s R.R. 0.06 6 Beige Ceramic Wall 6th Floor Women’s R.R. 0.02 7 Gray Ceramic Floor 6th Floor Women’s R.R. 0.04 8 Brown Metal Door 6th Floor Women’s R.R. 0.05

11 Gray Ceramic Floor 5th Floor Men’s R.R. 0.01 12 Brown Metal Door 5th Floor Men’s R.R. 0.04 15 Beige Ceramic Wall 4th Floor Women’s R.R. 0.04 17 Brown Metal Door Jam 4th Floor Women’s R.R. 0.14 19 Beige Ceramic Wall 3rd Floor Men’s R.R. 0.01 20 Gray Ceramic Floor 3rd Floor Men’s R.R. 0.02 21 Brown Metal Door Jam 3rd Floor Men’s R.R. 0.09 25 Beige Ceramic Wall 2nd Floor Women’s R.R. 0.04 26 Gray Ceramic Floor 2nd Floor Women’s R.R. 0.03 27 Brown Metal Door 2nd Floor Women’s R.R. 0.03 28 Green Metal Wall Divider 2nd Floor Women’s R.R. 0.14 29 Dark Brown Metal Door Jam 1st Floor Unisex R.R. 0.15 32 Beige Ceramic Wall Basement Men’s L.R. 0.03 33 Gold Metal Wall Divider Basement Men’s L.R. 0.18 35 Yellow Concrete Bench Basement Men’s L.R. 0.02 36 Blue Ceramic Wall Basement Men’s L.R. 0.03 38 Medium Brown Ceramic Wall Basement Women’s L.R 0.03 40 Green Metal Lockers Basement Women’s L.R 0.50 42 Dark Brown Metal Door Jam Basement Women’s R.R. 0.14

A tabulation of all XRF readings is provided in Appendix E.

EPA and HUD regulations mandating lead-based paint abatement do not apply in a commercial setting; however, all contractors involved in the proposed renovation project must be notified of the presence of lead in some coatings in accordance with the OSHA Lead in Construction Standard, 29 CFR 1926.62. All aspects of the OSHA Lead in Construction Standard shall apply to contractors involved in the selective demolition or renovation of materials with detectable lead concentrations during the project.

1.4 Polychlorinated Biphenyls (PCBs) and Universal Wastes

1. Approximately 75 fluorescent light ballasts were observed in the building during the assessment. All fluorescent light ballasts should be removed and inspected for labels indicating the PCB content, or a date stamp indicating the year of manufacture (ballast with a stamp of 1980 or prior must be disposed of as PCB containing), and segregated accordingly.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 4

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

If the fluorescent light ballasts are not to be re-used, these should be carefully packaged before shipping, and records of invoices and receipts from transporters and the receiving recycling, treatment or disposal facility should be maintained at the facility. Any leaking PCB-containing ballasts must be disposed of in an approved incinerator or hazardous chemical landfill.

2. Approximately 150 universal waste lamps were observed in the restrooms and locker during the assessment. All universal waste lamps that will be removed during the renovation should be removed and packaged in a manner that prevents them from breaking. If the lamps are not to be re-used, these should be recycled in accordance with the Ohio EPA’s rules governing the disposal of Universal Wastes

(OAC 3745-273).

1.5 Other Hazardous Materials

Everyday cleaning products and maintenance materials were observed in the building during the assessment, primarily in utility closets. It is expected that these materials can be removed from the project areas during the renovation and stored and re-used elsewhere, and that the materials will not require disposal to accommodate the renovation.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 5

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

2.0 INTRODUCTION

In accordance with our contract, on behalf of Moody Nolan Ltd., Inc. (Client), CTL Engineering of Ohio, Inc. (CTL Engineering) performed a Limited Hazardous Materials Survey to include Asbestos, Lead-Based Paint, and Universal Waste materials for the Public Restrooms on each floor of the John W. Bricker Federal Building located at 200 North High Street in Franklin County; Columbus, Ohio 43215. The survey is termed ‘Limited’ since only the building portions that may potentially be disturbed by the proposed Public Restroom Renovation & Accessibility Upgrade project were surveyed for hazardous materials, including, Asbestos-Containing Materials (AMC’s), Lead-Based Paint (LBP), and Universal Waste materials that may require special disposal and/or handling if impacted during renovation activities. Only the Restrooms and Locker Rooms from the Seventh Floor down to the Basement were assessed as part of this survey.

3.0 ASBESTOS-CONTAINING MATERIALS

The term asbestos is a generic name given to a group of six naturally occurring minerals that have been used in various commercial products due to characteristics such as high tensile strength, flexibility, resistance to chemical and thermal degradation, and high electrical resistance, as well as their ability to be woven. Applications of ACM generally fall into one of the following three classes: Surfacing Materials, Miscellaneous Materials, or Thermal System Insulation.

Adverse human health effects due to asbestos exposure through inhalation have been extensively studies for many years, and are well documented. Diseases associated with long-term exposure include Asbestosis - scarring of the lung tissue, Lung Cancer - malignant tumor of the bronchi covering, and Mesothelioma - cancer of the lining of the abdominal wall (mesothelium). Other diseases are currently being studied to determine their relationship to asbestos exposure.

Bans on the use and manufacture of asbestos-containing products in the United States began in the 1970s, when the EPA’s Asbestos National Emission Standard for Hazardous Air Pollutants (NESHAPS) instituted a ban on spray-applied asbestos-containing materials and preformed block thermal system insulation. The EPA’s Asbestos Ban and Phase Out Rule of 1989 (ABPO) called for the banning of nearly all products containing asbestos over a ten (10) year period; however, pursuant to a court decision by the US Fifth Circuit Court of Appeals in 1991, much of the ABPO was vacated.

As a result, the ban on the manufacture and/or use of asbestos in commercial products in the United States currently extends only to spray-applied fireproofing, preformed block thermal system insulation, corrugated paper, roll board, commercial paper, specialty paper, flooring felts, and any other new uses of asbestos. No other materials are currently banned in the United States, and the EPA does not track the manufacture, processing, and distribution of asbestos-containing products.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 6

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

3.1 Asbestos Definitions

The technical terms defined below are listed here in order to enhance the reader’s understanding of this report.

Asbestos-Containing Building Material (ACBM): Surfacing ACM, thermal system insulation ACM, or miscellaneous ACM that is found in or on interior structural members or other interior parts of a building.

Asbestos-Containing Material (ACM): Any material containing more than 1% asbestos.

Chrysotile: The most commonly used type of asbestos that accounts for approximately 95% of the asbestos found in buildings in the United States.

Amosite: The second most common form of asbestos likely to be found in buildings, typically in thermal system insulation.

Crocidolite: A type of asbestos used in high temperature insulation and also common in acid resistant applications.

Anthophyllite, Tremolite, and Actinolite: These types of asbestos are of little commercial value; however, may be detected as contaminants in building materials.

Friable: A material containing greater than 1% asbestos that can be “crumbled, pulverized, or reduced to powder by hand pressure when dry.” Friable ACM is thought to release fibers into the air more readily than Non-friable ACMs.

Non-Friable: Material that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. Many types of non-friable ACM can still release fibers when disturbed.

Regulated Asbestos-Containing Materials (RACM): Regulated asbestos-containing materials include friable ACM, Category I non-friable ACM that has become friable, Category I non-friable ACM that will be subjected to sanding grinding, cutting, or abrading, or Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder.

Category I Non-Friable Asbestos-Containing Material: Includes asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing products that contain more than 1% asbestos. These materials, due to their extremely low probability of fiber release, are generally not required to be removed from buildings prior to demolition provided that they are in good condition and not friable.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 7

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

Category II Non-Friable Asbestos-Containing Material: Includes any other asbestos-containing materials, other than Category I non-friable ACMs, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Surfacing Materials: Materials that are sprayed-on, troweled on, or otherwise applied to surfaces (walls, ceilings, structural members) for acoustical, decorative, or fireproofing purposes. Surfacing materials commonly found to contain asbestos include acoustical plaster and fireproofing.

Thermal System Insulation (TSI): Insulating materials applied to hot and cold water system components and heating, ventilation, and air conditioning (HVAC) system components to inhibit heat transfer or prevent condensation. This includes lagging; pipe wrap; block, batt, and blanket insulation; cements and “muds;” and a variety of other products such as gaskets and ropes.

Miscellaneous Materials: Largely non-friable products and materials, such as floor tile, adhesives, roofing felts, concrete pipe, transite siding and shingles, and fabrics.

3.2 Asbestos Regulations

There are two primary sets of federal regulations that have been developed to govern the management of asbestos-containing materials in the United States. The first, developed and administered by the Environmental Protection Agency (EPA), is designed to protect public health and the environment. The second, developed and administered by the Occupational Safety and Health Administration (OSHA), is designed to protect workers from asbestos exposure in the workplace.

In addition to EPA and OSHA rules, the Department of Transportation regulates the transportation of asbestos-containing waste material. The Ohio Department of Health also has regulatory authority over asbestos work in the State of Ohio, and in some cases, local authorities may have requirements in addition to those imposed by Federal and State regulations.

A brief summary of the major Federal and State legislation that impacts the asbestos industry is provided below:

Asbestos National Emissions Standards for Hazardous Air Pollutants (NESHAPS);

40 CFR Part 61

The Asbestos NESHAPs was developed by the EPA under the authority of the Clean Air Act (CAA) in the 1970s. The Asbestos NESHAPs govern the work practices to be followed during demolition and renovation of buildings, and other activities that involve the processing, handling, and disposal of asbestos-containing material. This regulation requires that the EPA be notified of any demolition or major renovation activities, regardless of whether or not asbestos is present, at least ten (10) days prior to the beginning of a project.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 8

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

Asbestos Hazard Emergency Reduction Act (AHERA); 40 CFR Part 763

In 1986, the AHERA regulations were developed by the EPA as part of Title II of the Toxic Substance Control Act (TSCA). The AHERA regulations outline a detailed process intended to ensure the safe management of all asbestos-containing building materials (ACBM) in public school buildings.

AHERA included guidelines for accredited inspectors to conduct building surveys and sampling for asbestos-containing materials, which, although only legally required to be followed in school buildings, are used as guidelines to perform surveys of other commercial buildings as well

The Asbestos School Hazard Abatement Reauthorization Act (ASHARA), passed in 1990, developed the Asbestos Model Accreditation Plan that defines the requirements to obtain the accreditation(s) necessary to perform asbestos inspections, develop asbestos management plans, design asbestos abatement projects, and to perform asbestos abatement work.

OSHA Asbestos Standards; 29 CFR Part 1926.1101 (Construction) and 29 CFR Part 1910.1101 (General Industry)

The Occupational Safety and Health Administration (OSHA) has promulgated regulations under 29 CFR 1910.1101 and 1926 intended to ensure worker protection from asbestos exposure. The OSHA regulations establish strict Permissible Exposure Limits (PELs) for airborne asbestos fibers, require and/or prohibit certain work practices and procedures for asbestos abatement work, define the standards required for respiratory protection systems designed to protect workers from asbestos exposure, and set out requirements for employers regarding exposure assessment, medical surveillance, record keeping, and hazard communication.

Ohio EPA Asbestos Regulations (OAC 3745-20)

The Ohio EPA asbestos regulations are similar to the US EPA’s Asbestos NESHAPS, in that they are intended to govern the work practices utilized during demolition and renovation of buildings, activities that involve the processing, handling, and disposal of asbestos-containing material, and any other activities that may results in the release of asbestos fibers into the air. The 10-Day Notification forms required by the NESHAPS when facilities undergo demolition or major renovation activities are submitted to the Ohio EPA.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 9

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

Ohio Department of Health Asbestos Regulations (OAC 3701:34)

The Ohio Department of Health asbestos regulations govern the licensure of companies and individuals involved with the asbestos industry in the State of Ohio, and ensure that all individuals, companies, and training institutes involved in the asbestos industry meet the requirements set forth by the US EPA in the ASHARA Asbestos Model Accreditation Plan. The Ohio Department of Health also requires notification 10 days prior to all asbestos abatement projects that involve the removal of greater than 50 square-feet or 50 linear feet of RACM , and Ohio Department of Health personnel perform inspections and audits of asbestos abatement projects and training courses to ensure regulatory compliance.

4.0 LEAD-BASED PAINT (LBP)

Lead is a toxic metal that was used for many years in commercial products, such as paints, glazings, and other coatings. It is estimated that lead-based coatings were used in approximately two-thirds of buildings constructed prior to 1940, and in one-half of buildings built between 1940-1960. The prevalence of lead-base coatings declined significantly after 1960; however, all buildings constructed prior to 1978 should be assumed to contain lead-based paint until proven otherwise.

The U.S. Consumer Product Safety Commission (CPSC), an independent federal regulatory agency was created by Congress in 1972 and directed "protect the public against unreasonable risks of injuries and deaths associated with consumer products." In 1978, the CPSC phased out the sale and distribution of residential paint containing lead by lowering the legal lead content in paint to 0.06% (a trace amount), in order to be considered lead-free.

On August 14, 2009, the Consumer Product Safety Improvement Act (CPSIA) took effect, enacting even more stringent guidelines for acceptable lead levels in paint and other surface coatings. The CPSIA reduces acceptable lead levels in paints and other surface coatings from 600 parts per million (0.06%) to 90 parts per million (0.009%). Paints and other products subject to these limits may not be sold, offered for sale, imported or manufactured after August 14, 2009.

Lead from paint chips and lead dust can be serious hazards. Peeling, chipping, chalking, or cracking lead-based paint is a hazard and needs immediate attention. Lead dust can form when lead-based paint is dry scraped, dry sanded, or heated.

Ingestion or inhalation of lead-based paint and lead-based paint dust is a major source of lead poisoning for both adults and children. In adults, lead poisoning can cause irritability, poor muscle coordination, sensory and motor nerve damage, high blood pressure, and reproductive abnormalities. Lead poisoning in children can result in retarded mental and physical development, reduced attention span, and behavioral problems. Retarded fetal development can occur at even low blood lead levels.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 10

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

4.1 Lead-Based Paint Definitions

The technical terms defined below are listed here in order to enhance the reader’s understanding of this report.

Action Level: The level at which an employer must begin certain compliance activities outlined in the OSHA Lead Standard. The action level for the lead in construction standard is 30µg/m3, calculated as an 8-hour time-weighted average (TWA).

XRF Fluorescence Analyzer: An instrument which estimates lead concentration in mg/cm2 using the emission of X Rays from atoms produced by the impact of high-energy electrons.

Exposure Monitoring: The personal air monitoring of an employee’s breathing zone to determine the amount of lead to which he/she is being exposed.

Generator: Any person whose actions or operations produce hazardous waste identified or listed in 40 CFR Part 261, or whose actions cause a hazardous waste to come under regulation.

Hazardous Waste: Any waste, as defined in 40 CFR 261.3 (RCRA), which, because of its quantity, concentration, or physical, chemical or infectious characteristics may pose a substantial hazard to human health or the environment when improperly managed.

Lead-Based Paint (EPA definition): Paint or other surface coatings that contain lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight.

Lead-Based Paint (OSHA definition): Paint or other surface coatings that contain any measurable amount of lead.

Lead-Based Paint Hazard: Any condition that causes exposure to lead from lead-contaminated dust, soil, or paint that is deteriorated that would result in adverse human health effects.

Permissible Exposure Limit: The maximum worker exposure to lead allowed under the OSHA Lead in Construction Standard. No employee may be exposed to airborne concentrations of lead greater than 50 µg/m3 averaged over an 8-hour period.

Representative Sample: A sample of a whole that can be expected to exhibit the average properties of the whole. Representative samples must be collected from waste piles of building materials known to be coated with lead-based paint in order to determine the required waste management practices for the material(s).

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 11

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

4.2 Lead-Based Paint Regulations

There are two primary sets of federal regulations that have been developed to govern the management of lead-based paint in the United States. The first, developed and administered by the Environmental Protection Agency (EPA) and the Department of Housing and Urban Development (HUD), is designed to protect public health and the environment, with a primary focus on the prevention of lead poisoning in children.

The EPA also regulates the disposal of hazardous wastes, which can sometimes apply to construction and demolition debris from commercial buildings that is covered with lead-based coatings. The regulations developed and administered by the Occupational Safety and Health Administration (OSHA), are designed to protect workers from lead exposure in the workplace.

In addition to EPA and OSHA rules, the Department of Transportation regulates the transportation of hazardous wastes, and the Ohio Department of Health has regulations designed to assure all lead inspection and abatement activities are conducted in accordance with applicable federal and state regulations.

A brief summary of the major legislation is provided below:

Lead-Based Paint Poisoning Prevention in Certain Residential Structures; 40 CFR Part 745 (EPA) and Lead-based Paint Hazards in Federally owned and Assisted Housing; 24 CFR Part 35 (HUD)

These regulations, published jointly under the authority of the Residential Lead-Based Paint Hazard Reduction Act of 1992, contain lead hazard evaluation and hazard reduction requirements for federally owned and assisted housing, and also contain regulations for disclosure of known lead-based paint and lead-based paint hazards by home sellers and landlords. The regulations establish training standards for individuals involved in lead-based paint inspections, risk assessments, and lead-based paint abatement, as well as standards for laboratories engaged in the analysis of lead-based paint samples. The regulations generally do not apply in a commercial setting.

Hazardous Waste Regulations; 40 CFR Part 260 (EPA)

The EPA hazardous waste regulations published under the authority of the Resource Conservation and Recovery Act (RCRA) in 1976, regulate commercial businesses as well as federal, state, and local government facilities that generate, transport, treat, store, or dispose of hazardous waste. The regulations identify specific listed wastes as well as characteristic wastes that are subject to the hazardous waste management requirements.

Construction and demolition debris known to contain lead-based coatings that is generated from construction or demolition activities in commercial buildings must be evaluated for its hazardous characteristics to determine the proper method of disposal.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 12

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

OSHA Lead Standards; 29 CFR Part 1926.62 (Construction) and 29 CFR Part

1910.1025 (General Industry)

The Occupational Safety and Health Administration (OSHA) has adopted the viewpoint that ‘any measurable amount of lead’ contained within a coated surface is lead-based paint and is under regulatory requirement. OSHA regulations require that each employer who has a workplace or operation where there is the potential for lead exposure shall conduct an exposure assessment to determine if any employee may be exposed to lead at or above the Action Level. If the potential for exposure above the Action Level is present, the use of personal protective equipment and medical monitoring of employees is required.

Ohio Department of Health Lead Hazard Abatement; Licensing and Inspection Activities (OAC 3701-32) and Lead Hazard Abatement Training Courses;

Examinations and Laboratory Approval (OAC 3701-82)

The Ohio Department of Health Lead Poisoning Prevention Program licenses lead risk-assessors, lead-abatement contractors and workers, lead inspectors and lead abatement project designers and approves initial and refresher lead training courses for all disciplines. In addition, the program approves abatement systems and products, clinical laboratories that analyze blood lead levels in humans, and environmental lead analytical laboratories that analyze the amount of lead in the environment.

5.0 POLYCHLORINATED BIPHENYLS (PCBs)

PCBs are mixtures of man-made chemicals with similar chemical structures that can range from oily liquids to waxy solids. Due to desirable characteristics such as non-flammability, chemical stability, high boiling point and electrical insulating properties, PCBs were historically used in hundreds of industrial and commercial applications. Common applications include electrical, heat transfer, and hydraulic equipment; paints, plastics and rubber products; and pigments, dyes and carbonless copy paper. According to the EPA, more than 1.5 billion pounds of PCBs were manufactured in the United States prior to cessation of production in 1977.

Various types of oil, such as hydraulic and insulating oils, have been identified as a source of PCB contamination in the past. Thus, any machinery or equipment that utilized these types of oil has the potential to be PCB-containing. Electrical transformers installed prior to 1980 may contain PCB laden oil, as may the oil in ballasts and capacitors in fluorescent lighting systems. A guidance document published by the EPA on September 25, 2009 also identifies caulk in buildings constructed or renovated between 1950 and 1978 as a potential PCB-containing material.

PCBs are persistent, toxic pollutants that do not readily break down in our environment. PCBs have been demonstrated to cause a variety of adverse health effects, including cancer, and adverse effects to the immune system, reproductive system, nervous system, and endocrine system.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 13

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

5.1 PCB Definitions

The technical terms defined below are listed here in order to enhance the reader’s understanding of this report.

Capacitor: A device for accumulating and holding a charge of electricity and consisting of conducting surfaces separated by a dielectric.

Disposal: Intentionally or accidentally discarding, or otherwise terminating the useful life of PCBs and PCB Items. Disposal includes spills, leaks, and other uncontrolled discharges of PCBs as well as actions related to containing, transporting, destroying, degrading, decontaminating, or confining PCBs and PCB Items.

Excluded PCB Products: PCB materials with concentrations of less than 50 ppm.

Fluorescent light ballast: A device that electrically controls fluorescent light fixtures and that includes a capacitor containing 0.1 kg or less of dielectric fluid.

PCB Bulk Product Waste: Waste derived from manufactured products containing PCBs in a non-liquid state, where the concentration at the time of designation for disposal was ≥50 ppm PCBs. This includes caulking materials as well as fluorescent light ballasts that contain PCBs in the potting material.

PCB Capacitor: Any capacitor that contains ≥500 ppm PCB.

PCB Transformer: Any transformer that contains ≥500 ppm PCBs.

5.2 PCB Regulations

The management and disposal of PCBs and materials containing PCBs is primarily governed by regulations enacted by the EPA (40 CFR Part 761) under the authority granted by the Toxic Substances Control Act of 1976. These regulations govern all aspects of PCB management, including sampling for PCBs, transportation and disposal of PCB-containing wastes (including fluorescent light ballasts), spill clean-up procedures, and PCB-contaminated site revitalization.

There are presently no comprehensive OSHA regulations concerning PCB exposure;

however, Department of Transportation regulations on the transportation of hazardous materials may impact the transportation of PCB wastes.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 14

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

6.0 UNIVERSAL WASTES

The Ohio EPA classifies Universal Wastes as specific hazardous waste streams, typically generated in small quantities, which may be managed in an alternative manner in place of more complex hazardous waste requirements. The four categories of Universal Wastes specified by the Ohio EPA are fluorescent lamps, pesticides, mercury-containing thermostats and discarded batteries.

6.1 Universal Waste Definitions

Battery: A device consisting of one or more electrically connected electrochemical cells which is designed to receive, store, and deliver electric energy.

Universal Waste Lamp: The bulb or tube portion of an electric lighting device.

Examples of common universal waste electric lamps include fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps.

Large Quantity Handler of Universal Waste: A universal waste handler who accumulates five thousand kilograms or more total of universal waste (batteries, pesticides, thermostats, or lamps, calculated collectively) at any time.

Pesticide: Any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest, or intended for use as a plant regulator, defoliant, or desiccant.

Small Quantity Handler of Universal Waste: A universal waste handler who does not accumulate five thousand kilograms or more total of universal waste at any time.

Thermostat: A temperature control device that contains metallic mercury in an ampule attached to a bi-metal sensing element, and mercury-containing ampules that have been removed from these temperature control devices.

6.2 Universal Waste Regulations

The management and disposal of Universal Wastes is regulated by the Ohio EPA under OAC 3745-273. The regulations were created to provide an alternative management process for these materials in place of the more complex hazardous waste requirements, and are intended to promote recycling as well as proper disposal by easing certain regulatory requirements. The regulation governs the handling, transportation, and disposal requirements for Universal Wastes.

There are presently no OSHA regulations concerning Universal Wastes; however, the Department of Transportation regulations on the transportation of hazardous wastes may impact the transportation of Universal Wastes.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 15

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

7.0 OTHER HAZARDOUS MATERIALS

In addition to ACMs, PCBs, and Universal Wastes, the subject building was evaluated for the presence of other types of hazardous materials that could be classified as hazardous wastes, depending upon their regulatory waste status and the intent to discard or reuse.

8.0 SCOPE OF WORK and BUILDING DESCRIPTION

The project scope included a Limited Hazardous Materials Survey to include Asbestos, Lead- Based Paint, and Universal Waste materials for the Public Restrooms on each floor of the John W. Bricker Federal Building located at 200 North High Street in Franklin County; Columbus, Ohio 43215. The survey is termed ‘Limited’ since only the building portions that may potentially be disturbed by the proposed Public Restroom Renovation & Accessibility Upgrade project were surveyed for hazardous materials, including, Asbestos-Containing Materials (AMC’s), Lead-Based Paint (LBP), and Universal Waste materials that may require special disposal and/or handling if impacted during renovation activities. Only the Restrooms and Locker Rooms from the Seventh Floor down to the Basement were assessed as part of this survey.

General Site Description

The J.W. Bricker Fed Building is a seven-story structure with a basement constructed of mostly concrete and steel (Photograph No. 1). According to the Franklin County Auditor’s website, the building was constructed in 1978 and totals approximately 244,783 square-feet. It is being used as a government building with various offices and public restrooms.

Interior Construction Components

Floors: Floors are constructed of concrete which is typically finished with resilient floor tile, or ceramic floor tile.

Walls: Walls are typically finished with a combination of drywall, ceramic wall tile, and/or rfp wallboard.

Ceilings: Dropped ceilings with various styles of lay-in acoustical ceiling tiles are located in throughout. Spray-on Fireproofing was observed on the ceilings above the ceiling tiles.

Plumbing System: No suspect pipe insulation was observed during the survey. All plumbing insulation that could be observed was composed of fiberglass or foam which are not considered suspect materials.

HVAC System: No suspect HVAC materials were observed in assessable portions of the subject areas.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 16

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

9.0 ASBESTOS SURVEY

Survey Methodology

This Asbestos Survey was conducted to determine the type, quantity, condition, and the potential for disturbance of suspected ACM used in the construction of the subject building. The asbestos survey was conducted in accordance with the applicable regulations and general guidelines set forth in EPA’s Asbestos Hazardous Emergency Response Act (AHERA) and rules promulgated under 40 CFR 763, Subpart E.

Although these guidelines were originally prepared for educational agencies, the guidelines can be used for commercial facilities when required by lending institutions or state regulations.

These guidelines are also referenced in Occupational Safety and Health Administration (OSHA), 29 CFR 1926.1101.

Specifically, the project included the following tasks:

An attempt to collect and review any existing building plans and/or drawings, previous asbestos surveys, and related information indicating the presence or location of ACMs in the building, and records of previous abatement activities conducted in the building.

Survey of the building by a team of Certified Asbestos Hazardous Evaluation Specialists, as per OAC Rule 3701-34-06. The survey included an initial visual and physical examination of building materials to identify locations of known and/or suspect ACMs.

Suspect materials were then classified as homogeneous, according to their location within the building, installation date, color, texture, and/or hardness, as suggested by current EPA sampling protocols. The suspect materials were then divided into Homogenous Sampling Areas (HSAs) and each sample collected was identified with a unique sample identifier consisting first of a number that correlates to a Homogenous Sampling Area designation, and then by a letter which indicates the sample sequence within the HSA grouping.

For example, Sample No. 1A indicates the first sample collected from Homogenous Sampling Area 1, Sample 4B indicates the second sample collected from Homogenous Sampling Area 4, etc.

The number of samples to be collected from each type of suspect material was determined according to the following criteria:

· Surfacing Materials: The number of samples and sample locations were determined according to the EPA guidance publication, Simplified Sampling Scheme for Friable Surfacing Materials (EPA 560/5-85-030a, October, 1985), a recommended number of 9 samples per HSA or a minimum of 3, 5, or 7 based on the square footage of each

HSA.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 17

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

· Thermal System Insulation Materials: The number of samples and sample locations were determined according to the quantity of the material observed, and the Asbestos Hazard Evaluation Specialist’s judgment on the homogeneity of the insulation materials, based on field observations. A minimum of three (3) samples was collected from each type of suspect thermal system insulation identified.

Materials such as fiberglass and foam insulation are not considered suspect of containing asbestos, and, therefore, were not sampled.

· Miscellaneous Materials: The number of samples and sample locations were determined according to the quantity of the material observed, and the Asbestos Hazard Evaluation Specialist’s judgment on the homogeneity of the material.

Samples were collected “in a manner sufficient to determine whether the material is ACM or not ACM” in accordance with 40 CFR Part 763.86 (c-d).

Bulk samples were collected directly from exposed materials. Prior to sample collection, the surface was sprayed with a surfactant to reduce potential fiber release. A complete core or cross-section sample of each material was taken to ensure that each layer of suspect ACM was representative of the parent material. The samples were carefully placed in a labeled sample container and sealed, and the information recorded onto a chain-of-custody form. In addition, sampling locations were noted and suspect materials were photographed.

Appropriate safety precautions were taken, where and when necessary, such as the use of half-face respirators, protective clothing, latex gloves, etc.

Hazard Assessment

A hazard assessment for each confirmed asbestos-containing material/functional space is provided based upon the condition of the material as observed during the survey, and its potential for disturbance. The condition of each material is determined according to the following criteria:

General Damage Criteria AHERA Damage Category Criteria Good No Damage Not damaged

Fair Damage Up to 10% overall damage Up to 25% localized damage

Poor Significant Damage Over 10% overall damage Over 25% localized damage

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 18

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

The potential for disturbance for each Homogenous Sampling Area was determined based on the observations of the building during the Survey, and is ranked as High, Low, or Moderate based upon the following criteria:

Renovation plans Location within the building Accessibility Potential for Physical Disturbance Potential for Disturbance due to air erosion, vibration, water damage

In this case, since all the interior building components on the 2nd floor will be removed, the potential for disturbance is high.

Sample Analysis

All samples were initially analyzed in a laboratory accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) using Polarized Light Microscopy (PLM) and dispersion-staining techniques (EPA Method 600\R-93\116) according to the protocol outlined in 40 CFR 763, Appendix A to Subpart F.

Because the PLM method has been known to provide false positive or false negative results at low asbestos concentrations, i.e., less than 10%, low asbestos results cannot be guaranteed.

Therefore, when low concentrations are reported for suspect materials from the same Homogenous Sampling Areas, additional sample analysis by the following methods may be conducted at an additional cost upon approval from the Client:

Friable Materials: If the PLM method quantifies asbestos at or less than 10% in friable asbestos-containing materials, and if the sample results are inconsistent within a Homogenous Sampling Area, e.g., wallboard, piping insulation, ceiling tiles, elbows, mortar, the samples may be assumed to contain asbestos or recommended to be re-analyzed using the more accurate Point Count Method.

Non-Friable, organically bound (NOB) materials, e.g., floor tiles, mastic, joint compounds, roof tars should be prepared as NOB samples, using the gravimetric process, and then read by PLM. If the PLM method quantifies asbestos at or less than 10% in non-friable asbestos containing materials, the samples may be assumed to contain asbestos or recommended to be re-read using Transmission Electron Microscopy (TEM).

In some cases, particularly where there is little question about the homogeneity of samples collected from a Homogenous Sampling Area, if the first sample analyzed from the HSA is positive, the remaining samples may be assumed to contain asbestos and not be analyzed.

Limited Hazardous Materials Survey – Moody Nolan Ltd., Inc. Page 19

Site Location: 200 North High Street; Columbus, Ohio 43215 CTL Engineering Project No. 14510658COL

A Homogenous Sampling Area is determined to contain no asbestos when all samples from the Homogenous Sampling Area are analyzed via PLM method and found to contain no asbestos. If all samples collected from a Homogenous Sample Area exhibit no asbestos content whatsoever, no Point Count or TEM analysis is conducted.

If any one sample from a Homogenous Sampling Area is found to contain asbestos, the entire Homogenous Sampling Area must be assumed to contain asbestos unless additional analysis by Point Count or TEM is conducted, or if additional assessment and sampling can further delineate the extent of the ACM within the Homogenous Sampling Area.

9.1 Findings

Mr. Kent Blazier, Ohio Asbestos Hazard Evaluation Specialist #31798, conducted the survey on July 8, 2014.