Bricker Fire Alarm Upgrade - Resource HazMat Report Bid Amendment 2.pdf

Planning, Engineering, Construction Management, Technology 6350 Presidential Gateway, Columbus, Ohio 43231

P 614.823.4949

JOHN W. BRICKER FEDERAL BUILDING

FIRE ALARM & NOTIFICATION SYSTEM

REPLACEMENT

COLUMBUS, OHIO

PRE-RENOVATION HAZARDOUS

MATERIALS SURVEY

Prepared for:

Metro CD Engineering, LLC 3510 Snouffer Road

Suite 200 Columbus, Ohio 43235

Prepared By:

Resource International, Inc.

6350 Presidential Gateway

Columbus, Ohio 43231

Rii Project # W-22-094

August 2022

RESOURCE INTERNATIONAL, INC.

6350 Presidential Gateway Columbus, Ohio 43231 Ph: 614.823.4949 Fx: 614.823.4990

Columbus, Cleveland, Cincinnati, Newark, Ohio Indianapolis, Indiana Louisville, Kentucky Pittsburgh, Pennsylvania Palm Beach, Flo

Planning

Engineering

Construction Management

Technology

August 4, 2022

Michael Chow, PE, CEM, CxA, LEED AP BD+c

3510 Snouffer Road Columbus, Ohio 43235 e-mail: mchow@metrocdengineering.com

Re: Pre-Renovation Hazardous Materials Survey Fire Alarm & Notification System Replacement John W. Bricker Federal Building, Columbus, Ohio Rii Project # W-22-094

Dear Mr. Chow:

Resource International, Inc. (Rii) is submitting this Pre-Renovation Hazardous Material Survey of the Fire Alarm and Notification System Replacement project located in the John W. Bricker Building and Garage at 200 North High Street in Columbus, Ohio 43215.

Our conclusions and recommendations are presented in their entirety in Section 5.0.

The entire report should be read to obtain a more complete understanding of the information provided, and to aid in any decisions made or actions taken based on our findings and conclusions.

If you have any questions concerning this report, please contact Michelle Eckels at 614- 823-4949 or email at michellee@resourceinternational.com.

Sincerely, RESOURCE INTERNATIONAL, INC.

Michelle L. Eckels, CPG Vice President – Environmental Services

Attachment: Pre-Renovation Hazardous Materials Report

Pre-Renovation Hazardous Materials Survey Resource International, Inc.

Fire Alarm & Notification System Replacement Engineering Consultant Rii Project #W-22-094 – August 4, 2022 i

TABLE OF CONTENTS

EXECUTIVE SUMMARY .............................................................................................................................. II

1.0 INTRODUCTION

1.1 GENERAL

1.2 SITE SUMMARY

1.3 HISTORICAL DOCUMENTATION

2.0 ASBESTOS SURVEY

2.1 REGULATORY FRAMEWORK AND SURVEY APPROACH

2.2 ANALYTICAL RESULTS

2.3 ASBESTOS CLASSIFICATIONS

3.0 LEAD PAINT SURVEY

3.1 PAINT CHIP SAMPLING

3.2 LEAD PAINT RESULTS

3.3 LIMITATIONS

4.0 QUALITY ASSURANCE/QUALITY CONTROL

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 ASBESTOS

5.1.1 RECOMMENDATION

5.1.2 REGULATORY NOTIFICATION OF RENOVATION/DEMOLITION

5.2 LEAD PAINT SURVEY

5.2.1 WORKER PROTECTION

5.2.2 WASTE DISPOSAL

5.2.3 SCRAP METAL RECYCLING

6.0 RELIABILITY OF REPORT - DISCLAIMER

7.0 SIGNATURE OF ENVIRONMENTAL PROFESSIONAL

LIST OF APPENDICES

APPENDIX A FIGURES

APPENDIX B SITE PHOTOGRAPHS

APPENDIX C ANALYTICAL RESULTS & CHAINS-OF-CUSTODY

APPENDIX D CERTIFICATIONS AND LABORATORY ACCREDITATIONS

APPENDIX E NOTIFICATION FORMS

APPENDIX F HISTORICAL DOCUMENTATION

Fire Alarm & Notification System Replacement Engineering Consultant Rii Project #W-22-094 – August 4, 2022 ii

EXECUTIVE SUMMARY

Metro CD Engineering, LLC (Metro CD) retained Resource International, Inc. (Rii) to conduct a Pre-Renovation Hazardous Materials Survey as part of the Fire Alarm and Notification System Replacement project located in the John W. Bricker Federal Building and Garage, at 200 North High Street in Columbus, Ohio 43215. The hazardous materials survey included the assessment for the presence of asbestos-containing materials (ACM), and lead-based paint (LBP) identified during the sampling and evaluation that potentially will be disturbed as part of renovation activities.

ASBESTOS SURVEY

A total of nineteen (19) homogeneous suspect ACMs from the facility were visually inspected and sampled during 2022 field inspection. When using the PLM method of analysis, the building materials identified in Tables 4 and 5 were identified as having detectable asbestos fibers. Copies of the analytical results can be found in Appendix C.

TABLE 4 – 2022 ACM RESULTS

Location ACM

HA

Code

ACM

Cat**

JOHN W. BRICKER FEDERAL BUILDING

Throughout Building Insulating cement on pipe ends

6 RACM

Throughout Building Duct sealant - brown 7 Cat. II

Throughout Building Black mastic associated with floor tile 14 Cat. I

JOHN W. BRICKER FEDERAL GARAGE

6th, 7th & 8th Floors Insulating cement on pipe ends

6 RACM

Throughout Garage Yellow/brown caulk on ceiling/floor penetrations 19 Cat. II

TABLE 5 – HISTORICAL ACM RESULTS

ACM

Cat**

Throughout Building Mastic associated with floor tile Cat. I

Throughout building Duct sealant Cat. II

Throughout building Joint compound on drywall systems Cat. II

Throughout Garage Insulating cement on pipe ends

RACM

Air Handling Room - Penthouse

Sealant on air handling units

Cat. II

Air Handling Room - Penthouse

Chilled water tank insulation (assumed)

RACM

Throughout Building Sink undercoating

(assumed) Cat. II

Fire Alarm & Notification System Replacement Engineering Consultant Rii Project #W-22-094 – August 4, 2022 iii

Location ACM

ACM

Cat**

Roof of Building Roofing materials

Cat. I

The leveling compound in Fire Panel Rooms was identified to contain less than 1% asbestos.

Trace levels of asbestos, or less than 1%, are not regulated by the Ohio EPA. However, these levels are regulated by OSHA and must be abated or demolished in a manner that will limit exposure. OSHA regulates all worker activities which impact materials with any amount of asbestos, including materials less than 1% asbestos containing. Thus, the contractor must abate or demolish the material in a method that will limit exposure and comply with OSHA regulations.

To the extent practicable, ACM having concentrations of less than 1% should be handled in a manner which prevents the emission of airborne fibers to levels in excess of the workers permissible exposure limit (PEL). Removal/demolition procedures used to satisfy OSHA should include wet methods for demolition. These methods also prohibit the use of high-speed abrasive disc saws or compressed air for cutting and materials removal. Please refer to OSHA guidance for applicable exposure limit regulations and demolition procedures associated with ACM

The ACM insulating cement on pipe ends was observed throughout the Building and on the 6th, 7th and 8th Floors of the Garage. The ACM insulating cement on pipe ends was not observed on Floors B through 5 in the Garage.

Additional materials that were suspected to contain asbestos were observed within the structure but were not sampled due to the location of the material, the potential danger to the sample collector and/or because of the integrity of the equipment/building component would have been compromised. If these items are to be dismantled, the components should be assumed as ACM or analyzed prior to disposal. Below is a list of items that are suspect to contain ACM:

• Transite board in electrical panels; and

• Electrical wiring, tape and equipment.

LEAD PAINT SURVEY

The US Environmental Protection Agency (EPA) defines lead-based paint (40 CFR 745.103) as paint containing lead levels equal to or greater than 1.0 mg/cm2 when measured by field XRF analyzers, 5,000 ppm or 0.5% by weight when analyzed by atomic absorption spectroscopy (AAS). The Occupational Safety and Health Administration (OSHA) does not define lead-based paint, nor does it acknowledge any intrinsically safe levels of lead in paint.

Testing for lead-based paint was performed on a representative number of painted components in the areas scheduled for renovation. The paint chip results were below the threshold levels of 5,000 ppm or 0.5% by weight set by the EPA HUD Guideline Threshold limits. However, paint with trace levels of lead at low levels (less than 0.5% or 5,000 ppm by weight) was identified on various components throughout the building. These components may create lead dust if the paint is turned into dust by abrasion, scraping or sanding. The complete lead-based paint results are located in Appendix C.

Please refer to Section 5.0 for conclusions and recommendations for proper management and disposal of the materials. The entire report should be read to obtain a full understanding in order

Fire Alarm & Notification System Replacement Engineering Consultant Rii Project #W-22-094 – August 4, 2022 iv to make informed business decisions about the structures.

Fire Alarm & Notification System Replacement Resource International, Inc.

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

1.0 INTRODUCTION

1.1 GENERAL

Metro CD Engineering, LLC (Metro CD) retained Resource International, Inc. (Rii) to conduct a Pre-Renovation Hazardous Materials Survey as part of the Fire Alarm and Notification System Replacement project located in the John W. Bricker Federal Building and Garage, at 200 North High Street in Columbus, Ohio 43215. Refer to the site location maps as Figures 1 and 2 in Appendix A. The hazardous materials survey included the assessment for the presence of asbestos-containing materials (ACM), and lead-based paint (LBP) identified during the sampling and evaluation that potentially will be disturbed as part of renovation activities.

1.2 SITE SUMMARY

The John W. Bricker Federal Building was originally constructed in 1977 and is a 7-story office building. The project involves replacement of the fire alarm system in the Bricker Federal Building and the associated garage building. The scope of work included assessing building materials within the proposed project area as depicted on the construction documents provided by Metro CD. The remaining areas of the buildings that will not be disturbed by this project were not assessed as part of this survey.

1.3 HISTORICAL DOCUMENTATION

Metro CD provided historical documentation from a previous assessment conducted by Versar, Inc., of Lombard, Illinois, in February 2006. The Versar inspection was conducted on October 5, 2005, and their assessment had incorporated data from a previous inspection conducted by URS Corporation (URS) of Columbus, Ohio. The URS data was collected during a period from November 2004 to October 2005. The following materials were historically found to be asbestos-containing or assumed to be ACMs:

• Mastic associated with floor tile;

• Duct sealant;

• Joint compound on drywall systems;

• Boiler breeching insulation (abated prior to 2006);

• Insulating cement on pipe ends;

• Sealant on air handling units;

• Chilled water tank insulation (assumed);

• Sink undercoating (assumed); and

• Roofing materials (assumed).

Sampling results and data from the historical documentation were utilized in this assessment in developing the conclusions and recommendations, and are included in Appendix F.

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

2.0 ASBESTOS SURVEY

2.1 REGULATORY FRAMEWORK AND SURVEY APPROACH

The asbestos building survey was conducted to determine if asbestos-containing material (ACM) is present within the structures to be disturbed during renovation and to comply with the National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR 61 Subpart M – National Emission Standard for Asbestos), the Occupational Safety and Health Administration (OSHA) asbestos standard (29 CFR 1910.1001), and the Ohio Environmental Protection Agency (Ohio EPA) Ohio Asbestos Emission Control Rules (Ohio Administrative Code [OAC] 3745-20). The NESHAP requires an asbestos survey prior to demolition or renovation, and classification of suspect materials into Category I nonfriable ACM, Category II nonfriable ACM, or Regulated ACM (RACM).

The Ohio EPA requires notification when buildings are demolished and when renovation activities disturb specific quantities of ACM. For regulatory purposes, a material is considered ACM by EPA if it contains more than 1% asbestos, and a material is considered as asbestos-containing by OSHA if it contains any percent of asbestos, including less than 1% asbestos.

Building materials per area suspect to be asbestos-containing were inspected and grouped as homogeneous if uniform in texture, color, date of application, and appears identical in other respects. A total of nineteen (19) homogeneous area ACMs from the structures were visually inspected and sampled during the 2022 field inspection. The following table is a list of homogeneous building materials initially suspect to be ACM.

TABLE 1 – SUSPECT ASBESTOS-CONTAINING MATERIALS

Material Code Homogeneous Material Description

1 Spray-on fireproofing

2 Cove base – brown

3 Tan mastic associated with cove base

4 Joint compound

5 Drywall

6 Insulating cement on pipe ends

7 Duct sealant – brown

8 Fire stop - red

9 Door gasket – black

10 Gray caulk – on louver

11 Pipe valve gasket – black

12 Leveling compound

13 12”x12” Floor tile – tan

14 Black mastic associated with floor tile

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

Material Code Homogeneous Material Description

15 Ceramic tile mastic - tan

16 Tan/white caulk

17 Concrete

18 Gray caulk – garage wall seam

19 Yellow-brown caulk

Interior materials suspected of containing asbestos must be categorized in accordance with Asbestos Hazard Emergency Response Act (AHERA, 40 CFR Part 763) as one (1) of the following three (3) types:

1. Surfacing Materials – Interior ACM that has been sprayed on, troweled on, or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes.

2. Thermal System Insulation (TSI) – Insulation applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes.

3. Miscellaneous Materials – Interior building materials on structural components, structural members or fixtures, such as floor ceiling tiles. "Miscellaneous materials" do not include TSI or surfacing materials.

AHERA requires a minimum number of samples to be collected based on linear and square footage to demonstrate that a homogeneous area is non-ACM. The following bulk sampling requirements were used in determining the number of samples necessary to obtain from a homogeneous material.

BULK SAMPLING REQUIREMENTS

Type of Material Minimum Samples Recommended

Friable Surfacing Material

• Area ≤ 1,000 sq ft

• Area 1,000 sq ft but ≤ 5,000 sq ft

• Area 5,000 sq ft

Thermal System Insulation (TSI)

• Homogeneous area of TSI

• Patched TSI (if patched section < 6 linear or sq ft

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

BULK SAMPLING REQUIREMENTS

Type of Material Minimum Samples Recommended

• Each insulated area of insulating cement (mudded fittings such as elbows, tees or valves)

Sufficient number of samples determined by Inspector (usually 2-3)

Friable Miscellaneous Material Sufficient number of samples determined by Inspector (usually 2-3)

Nonfriable Suspected ACM Sufficient number of samples determined by Inspector (usually 2-3)

In accordance with AHERA, the quantity of friable surfacing materials determines the minimum number of samples that the inspector must obtain for the survey.

2.2 ANALYTICAL RESULTS

Two (2) certified Asbestos Hazard Evaluation Specialists (AHES) visually inspected the suspect materials, identified to determine the presence of ACM. The AHES inspectors included Kristy Engel-Shepard (Certificate #ES34846) and Michelle Eckels (Certification #ES33141). The field sampling was conducted on July 15 & 22, 2022. Materials identified as suspect ACM were bulk sampled for laboratory analysis to determine asbestos content, in accordance with 40 CFR 763.86. The survey was conducted on only the portion of the structures proposed for demolition/renovation as part of this project.

Each suspect ACM was touched to determine whether the material was friable or nonfriable, and the condition of each suspect ACM was documented. Whenever possible, reasonably ascertainable quantities of suspect ACM were visually observed and recorded.

The bulk samples were placed in plastic bags, sealed and labeled with a unique sample identification number and a description of material. Refer to Table 2 for a summary of the asbestos samples that were obtained during the 2022 field inspection and the location of the samples.

The bulk samples were submitted to EMSL Analytical, Inc. (EMSL) in Cinnaminson, New Jersey, for analysis using polarized light microscopy (PLM). EMSL is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for conducting asbestos analysis using PLM. The PLM analysis was performed in accordance with the Environmental Protection Agency (EPA) Method 600/R-93/116, as outlined in 40 CFR

763.109 Appendix A. A chain-of-custody was prepared to accompany bulk samples to the laboratory.

When a bulk sample has tested positive for the presence of asbestos, and the percentage is 10% or lower, the point count method can be performed on the sample. Point counting

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022 provides a determination of the area percentage of asbestos in a sample, with a detection limit of 0.25% asbestos.

A summary of the samples taken are listed in Table 2. Copies of all the analytical results can be found in Appendix C.

TABLE 2 – ASBESTOS SAMPLE SUMMARY

Sample

ID

Location Sample Material

HA

Code % Asbestos*

JOHN W. BRICKER FEDERAL BUILDING

7th Floor Construction

Area – North Spray-on fireproofing 1 NAD

7th Floor Construction

Area – North Spray-on fireproofing 1 NAD

7th Floor Construction

Area – North Spray-on fireproofing 1 NAD

004 Basement - Room 040 Spray-on fireproofing 1 NAD

005 Basement - Room 040 Spray-on fireproofing 1 NAD

006 Basement - Room 040 Spray-on fireproofing 1 NAD

007 Basement - Room 040 Spray-on fireproofing 1 NAD

7th Floor Construction

Area – North Cove base – brown

Tan mastic

NAD

NAD

7th Floor Construction

Area – North Cove base – brown

Tan mastic

NAD

NAD

7th Floor Construction

Area – North Joint compound

Drywall

NAD

NAD

7th Floor Construction

Area – North Joint compound

Drywall

NAD

NAD

7th Floor Construction

Area – North Insulating cement on pipe ends 6 4% Chrysotile

7th Floor Construction

Area – North Insulating cement on pipe ends 6 3% Chrysotile

7th Floor Construction

Area – North Duct sealant - brown 7 3% Chrysotile

7th Floor Construction

Area – North Duct sealant - brown 7 3% Chrysotile

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

Sample

ID

Location Sample Material

HA

Code % Asbestos*

7th Floor Construction

Area – North Fire stop - red 8 NAD

7th Floor Construction

Area – North Fire stop - red 8 NAD

018 Penthouse – 9th Floor Insulating cement on pipe ends 6 4% Chrysotile

019 Penthouse – 9th Floor Insulating cement on pipe ends 6 5% Chrysotile

Penthouse – 9th Floor on

Air Handling Unit Door gasket - black 9 NAD

Penthouse – 9th Floor on

Air Handling Unit Door gasket - black 9 NAD

Penthouse – 9th Floor on

Louver opening Gray caulk 10 NAD

Penthouse – 9th Floor on

Louver opening Gray caulk 10 NAD

024 Penthouse – 9th Floor Pipe valve gasket - black 11 NAD

025 Penthouse – 9th Floor Pipe valve gasket - black 11 NAD

6th Floor Fire Panel

Room Leveling compound 12 0.5% Chrysotile**

6th Floor Fire Panel

Room Leveling compound 12 0.5% Chrysotile**

6th Floor Fire Panel

Room Fire stop - red 8 NAD

6th Floor Fire Panel Room – in Men’s

Room

12”x12” Floor tile – tan Black mastic

NAD

4% Chrysotile

6th Floor Fire Panel Room – in Men’s

Room

12”x12” Floor tile – tan Black mastic

NAD

4% Chrysotile

2nd Floor Fire Panel room – Janitor Closet Ceramic tile mastic - tan 15 NAD

2nd Floor Fire Panel room – Janitor Closet Ceramic tile mastic - tan 15 NAD

JOHN W. BRICKER FEDERAL GARAGE

8th Floor SW – Pull Box

Conduit Tan/white caulk 16 NAD

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

Sample

ID

Location Sample Material

HA

Code % Asbestos*

8th Floor NE – Pull Box

Conduit Tan/white caulk 16 NAD

8th Floor NE – Conduit

Sleeve Fire stop - red 8 NAD

8th Floor SW – Conduit

Sleeve Fire stop - red 8 NAD

005 8th Floor NE - Floor Concrete 17 NAD

006 4th Floor SW – Wall Concrete 17 NAD

7th Floor – Near Parking

Spot 7-1 Insulating cement on pipe ends

6 NAD

6th Floor – Near

Parking Spot 6-43 Insulating cement on pipe ends 6 <1% Chrysotile

009 6th Floor – Wall Seam Gray caulk 18 NAD

010 6th Floor – Wall Seam Gray caulk 18 NAD

3rd Floor NE – Conduit

Ceiling Penetration Yellow/brown caulk 19 8% Chrysotile

3rd Floor NE – Conduit

Ceiling Penetration Yellow/brown caulk 19 10% Chrysotile

*NAD - No Asbestos Detected **Point Count Result

During this investigation using the PLM method of analysis, five (5) homogeneous materials from the portions of the building assessed during the 2022 field inspection were identified as having detectable asbestos fibers.

2.3 ASBESTOS CLASSIFICATIONS

ACMs are classified as either Category I nonfriable, Category II nonfriable, or Regulated Asbestos-containing Material (RACM) in accordance with the Ohio Administrative Code (OAC) 3745-20-01 and the NESHAP 40 CFR Part 61.141, Subpart M. Refer to below for a definition of each classification:

• Category I Nonfriable ACM – Asbestos-containing packings, gaskets, resilient floor covering and asphalt roofing products containing more than 1 percent asbestos as determined using Polarized Light Microscopy, as specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1.

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

• Category II Nonfriable ACM – Any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos as determined using Polarized Light Microscopy, as specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

• Regulated ACM (RACM) –

a) Friable asbestos material;

b) Category I nonfriable ACM that has become friable;

c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or

d) Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by 40 CFR Part 61.

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

3.0 LEAD PAINT SURVEY

The paint survey was conducted July 15 & 22, 2022 by Kristy Engel-Shepard (Certified Lead Risk Assessor LA#9350) and Michelle Eckels. The survey was conducted on only the portion of the structure proposed for demolition as part of this project. The inspection was performed in accordance with GSA Region 5 Pre-Alteration Assessment for Asbestos- Containing Materials and Lead-Based Paint Guidelines, revised June 2018. These guidelines require that paint chip samples shall be analyzed using either Atomic Absorption Spectroscopy (AAS) or Inductively Coupled Plasma-Atomic Emission Spectroscopy (ICP-AES) in accordance with ASTM ES-1613-94 or equivalent method.

3.1 PAINT CHIP SAMPLING

Paint chip samples were collected and submitted to a third-party laboratory for analysis.

In order to collect a paint sample, a heat gun was used to soften the paint enough to use a putty knife and remove the paint from the surface. The paint sample was properly containerized and labeled, then sent to the laboratory for analysis. The use of a respirator is recommended for the inspector during the paint sampling process due to possible exposure of lead fumes being released with the use of the heat gun

3.2 LEAD PAINT RESULTS

The US Environmental Protection Agency (EPA) defines lead-based paint (40 CFR 745.103) as paint containing lead levels equal to or greater than 1.0 mg/cm2 when measured by field XRF analyzers, 5,000 ppm or 0.5% by weight when analyzed by atomic absorption spectroscopy (AAS). The Occupational Safety and Health Administration (OSHA) does not define lead-based paint, nor does it acknowledge any intrinsically safe levels of lead in paint.

Testing for lead-based paint was performed on a representative number of painted components in the areas scheduled for renovation.

TABLE 3 - LEAD PAINT CHIP SAMPLE RESULTS

No.

Location Lead-Containing

Material

Laboratory Results % by wt

HUD Guidelines Threshold % by wt

9th Floor Penthouse

– Duct damper Gray paint

100 ppm or 0.265% w/w

5,000 ppm or 0.5% w/w

9th Floor Penthouse

– AHU concrete curb Yellow paint

140 ppm or 0.291% w/w

5,000 ppm or 0.5% w/w

9th Floor Penthouse

– Louver vents Gray paint

450 ppm or 0.265% w/w

5,000 ppm or 0.5% w/w

Garage 6th Floor –

Stairway wall Tan paint

<80 ppm or 0.263% w/w

5,000 ppm or 0.5% w/w

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

Sample No.

Location Lead-Containing

Material

Laboratory Results % by wt

HUD Guidelines Threshold % by wt

Garage 8th Floor –

Stairway wall White paint

<80 ppm or 0.268% w/w

The paint chip results were below the threshold levels of 5,000 ppm or 0.5% by weight set by the EPA HUD Guideline Threshold limits. However, paint with trace levels of lead at low levels (less than 0.5% or 5,000 ppm by weight) was identified on various components throughout the building. These components may create lead dust if the paint is turned into dust by abrasion, scraping or sanding. The complete lead-based paint results are located in Appendix C.

3.3 LIMITATIONS

The scope of this inspection is limited to building components that were visible to the inspector/risk assessor at the time of the inspection. The project scope does not include components that may have been concealed from sight by irregular construction practices, or hidden by temporary procedures used to secure the unit or other circumstances that would prevent visual inspection of the component. These areas should be considered to contain lead paint, unless tested otherwise, and be treated and handled as such during future renovation/demolition activities.

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

4.0 QUALITY ASSURANCE/QUALITY CONTROL

Rii utilizes several procedures to ensure a high standard of care throughout the project.

Such procedures include:

• Field staff includes a minimum of two (2) asbestos inspectors present during all site visits.

• All asbestos inspectors are State Certified Asbestos Hazard Evaluation Specialists.

• AHERA sampling procedures are followed, which includes strict protocols usually intended for educational facilities.

• Disposable nitrile gloves and new, sealable, plastic bags are used to minimize cross-contamination of samples.

• Sampling equipment is cleaned between uses with wet methods.

• Chain-of-custodies are completed after each survey, prior to transporting the samples to a laboratory for analysis.

• The laboratory used for the project is accredited by the National Institute of Standards and Technology under the National Voluntary Laboratory Accreditation Program (NVLAP).

• Laboratory staff checks the sample numbers with the chain-of-custody.

• A written report is developed by the team leader, and peer-reviewed by the project manager.

• The XRF instrument was calibrated by the rental company, IE Monitoring Equipment, prior to receipt.

• Rii standardized the instrument in the field prior to and after use.

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 ASBESTOS

This Asbestos Survey was conducted in order to comply with the National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR 61 Subpart M) and the Ohio Environmental Protection Agency (Ohio EPA) Ohio Asbestos Emission Control Rules (Ohio Administrative Code [OAC] 3745-20). Refer to the Figures 1 and 2 in Appendix A for the site location.

The Ohio EPA requires notification when buildings are demolished and when renovation activities disturb specific quantities of ACM. For regulatory purposes, a material is considered ACM by EPA if it contains more than 1% asbestos, and a material is considered as asbestos-containing by OSHA if it contains any percent of asbestos, including less than 1% asbestos.

ASBESTOS SURVEY

A total of nineteen (19) homogeneous suspect ACMs from the facility were visually inspected and sampled during 2022 field inspection. When using the PLM method of analysis, the building materials identified in Tables 4 and 5 were identified as having detectable asbestos fibers. Copies of the analytical results can be found in Appendix C.

TABLE 4 – 2022 ACM RESULTS

HA

Code

ACM

Cat**

JOHN W. BRICKER FEDERAL BUILDING

Throughout Building Insulating cement on pipe ends

6 RACM

Throughout Building Duct sealant - brown 7 Cat. II

Throughout Building Black mastic associated with floor tile 14 Cat. I

JOHN W. BRICKER FEDERAL GARAGE

6th, 7th & 8th Floors Insulating cement on pipe ends

6 RACM

Throughout Garage Yellow/brown caulk on ceiling/floor penetrations 19 Cat. II

TABLE 5 – HISTORICAL ACM RESULTS

ACM

Cat**

Throughout Building Mastic associated with floor tile

Throughout building Duct sealant Cat. II

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

Location ACM

ACM

Cat**

Throughout building Joint compound on drywall systems Cat. II

Throughout Garage Insulating cement on pipe ends

RACM

Air Handling Room - Penthouse

Sealant on air handling units

Cat. II

Air Handling Room - Penthouse

Chilled water tank insulation (assumed)

RACM

Throughout Building Sink undercoating

(assumed) Cat. II

Roof of Building Roofing materials

When using the PLM method of analysis, the leveling compound in Fire Panels Rooms was identified as having detectable asbestos fibers of less than 1%; and therefore, is only regulated by OSHA. Copies of the analytical results can be found in Appendix C.

The project includes a limited hazardous materials survey of existing building materials in portions of the facility that will be undergoing renovations. During the site visit, additional materials that were suspected to contain asbestos were observed within the structures but were not sampled due to the location of the material, the potential danger to the sample collector and/or because of the integrity of the equipment/building component would have been compromised. In addition, the electrical could not be de-energized for sampling. If these items are to be dismantled, the components should be assumed as ACM or analyzed prior to disposal. Below is a list of items that are suspect to contain ACM:

• Transite board in electrical panels; and

• Electrical wiring, tape and equipment.

The materials identified above as suspect ACM should be evaluated during construction to identify the presence of ACM if the material is to be disturbed. The construction documents should be developed to address the contractor’s procedures for conducting any further evaluation, if determined necessary based on the scope of the construction.

5.1.1 RECOMMENDATION

The ACM insulating cement on pipe ends was observed throughout the Building and on the 6th, 7th and 8th Floors of the Garage. The ACM insulating cement on pipe ends was not observed on Floors B through 5 in the Garage.

As the identified ACM is to be disturbed, proper asbestos abatement procedures should be implemented prior to the commencement of all renovation/demolition work. All materials

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022 identified as RACM, or may become RACM during renovation/demolition activities, and will be disturbed must be abated by a State of Ohio licensed abatement contractor, transported, and disposed of at an EPA licensed asbestos landfill.

OSHA Regulated ACM

The leveling compound in Fire Panel Rooms was identified to contain less than 1% asbestos. Trace levels of asbestos, or less than 1%, are not regulated by the Ohio EPA.

However, these levels are regulated by OSHA and must be abated or demolished in a manner that will limit exposure. OSHA regulates all worker activities which impact materials with any amount of asbestos, including materials less than 1% asbestos containing. Thus, the contractor must abate or demolish the material in a method that will limit exposure and comply with OSHA regulations. To the extent practicable, ACM having concentrations of less than 1% should be handled in a manner which prevents the emission of airborne fibers to levels in excess of the workers permissible exposure limit (PEL). Removal/demolition procedures used to satisfy OSHA should include wet methods for demolition. These methods also prohibit the use of high-speed abrasive disc saws or compressed air for cutting and materials removal. Please refer to OSHA guidance for applicable exposure limit regulations and demolition procedures associated with ACM.

5.1.2 REGULATORY NOTIFICATION OF RENOVATION/DEMOLITION

Per Ohio Environmental Protection Agency (Ohio EPA) regulations, A Notification of Demolition and Renovation Form must be completed and submitted at least ten (10) working days prior to the following activities:

• every demolition of a facility requires notification, regardless of whether asbestos is involved.

• every renovation of a facility must be submitted when the amount of regulated asbestos-containing material (RACM) stripped, removed, dislodged, cut, drilled, or similarly disturbed exceeds 260 linear feet on pipes or 160 square feet on other facility components or 35 cubic feet of other facility components.

• every abatement, when the activity involves the removal, renovation, enclosure, repair or encapsulation of friable asbestos-containing material in an amount greater than 50 linear feet on pipes or 50 square feet on other facility components.

Thus, if disturbance of ACM is proposed for this project, the owner of the facility must follow the Ohio EPA standards for notification of demolition and renovation work. A copy of the Ohio EPA Notification of Demolition and Renovation Form is provided in Appendix E.

5.2 LEAD PAINT SURVEY

The paint survey was conducted July 15 & 22, 2022 by Kristy Engel-Shepard (Certified

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

Lead Risk Assessor LA#9350) and Michelle Eckels. The inspection was performed in accordance with GSA Region 5 Pre-Alteration Assessment for Asbestos-Containing Materials and Lead-Based Paint Guidelines, revised June 2018.

The US Environmental Protection Agency (EPA) defines lead-based paint (40 CFR 745.103) as paint containing lead levels equal to or greater than 1.0 mg/cm2 when measured by field XRF analyzers, 5,000 ppm or 0.5% by weight when analyzed by atomic absorption spectroscopy (AAS). The Occupational Safety and Health Administration (OSHA) does not define lead-based paint, nor does it acknowledge any intrinsically safe levels of lead in paint.

Testing for lead-based paint was performed on a representative number of painted components in the areas scheduled for renovation.

TABLE 6 - LEAD PAINT CHIP SAMPLE RESULTS

No.

Location Lead-Containing

Material

Laboratory Results % by wt

HUD Guidelines Threshold % by wt

9th Floor Penthouse

– Duct damper Gray paint

100 ppm or 0.265% w/w

5,000 ppm or 0.5% w/w

9th Floor Penthouse

– AHU concrete curb Yellow paint

140 ppm or 0.291% w/w

5,000 ppm or 0.5% w/w

9th Floor Penthouse

– Louver vents Gray paint

450 ppm or 0.265% w/w

5,000 ppm or 0.5% w/w

Garage 6th Floor –

Stairway wall Tan paint

<80 ppm or 0.263% w/w

5,000 ppm or 0.5% w/w

Garage 8th Floor –

Stairway wall White paint

<80 ppm or 0.268% w/w

The paint chip results were below the threshold levels of 5,000 ppm or 0.5% by weight set by the EPA HUD Guideline Threshold limits. However, paint with trace levels of lead at low levels (less than 0.5% or 5,000 ppm by weight) was identified on various components throughout the building. These components may create lead dust if the paint is turned into dust by abrasion, scraping or sanding. The complete lead-based paint results are located in Appendix C

5.2.1 WORKER PROTECTION

Worker safety should be as per OSHA Safety and Health Regulations for Construction, Lead Rule, 29 CFR 1926.62. The contractor should be made aware of the presence of lead and the field results should be made available. The contractor should also follow lead-safe work practices to reduce potential exposure to high levels of lead. Additionally, disposal and handling of the LBP material should be in accordance with all applicable governmental regulations.

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

The implications of lead paint existing in a building are related to the future use of the facility and the need to impact these painted surfaces during the renovation/demolition process. Renovations and/or demolition will require the contractor and subcontractors to address worker exposure where the surfaces coated with lead paint are going to be disturbed.

The OSHA Lead in Construction Standard located at 29 CFR 1926.62 regulates workers in construction, demolition, and maintenance who may be occupationally exposed to lead-containing products. Lead-related construction work involves any construction, repair, painting, decorating, demolition, renovation, removal or encapsulation, alteration, installation of lead products, emergency cleanup, transportation, disposal, storage, containment, and maintenance work whereby the lead-containing material could be disturbed resulting in lead exposure.

OSHA defines any detectable concentration of lead paint coating as a potential lead exposure hazard to workers doing construction/demolition-type work on these surfaces as even small concentrations of lead can result in unacceptable employee exposures depending upon the method of removal and other workplace conditions. Since these conditions can vary greatly, the standard requires all employers to make an initial determination of whether any employee’s exposure to lead exceeds the action level of 50 micrograms per cubic meter of air (µg/m3) averaged over an 8-hour day.

The exposure assessment involves sampling the air in the worker’s breathing zone to determine exposure. Employee exposure is that exposure which would occur if the employee were not using a respirator. This initial determination requires the employer to monitor workers’ exposures unless the employer has objective data that can demonstrate conclusively that no employee will be exposed to lead in excess of the action level. Where objective data is used in lieu of actual monitoring, the employer must establish and maintain an accurate record, documenting its relevancy in assessing exposure levels for current job conditions. If such objective data is available, the employer need proceed no further on employee exposure assessment until such time that conditions have changed and the determination is no longer valid.

However, if this initial determination shows that a reasonable possibility exists that any employee may be exposed, without regard to respirators, over the action level; the employer must set up an air monitoring program to determine the exposure level representative of each employee exposed to lead in the workplace.

OSHA states that until the employer performs an exposure assessment (or can supply prior data regarding the same type of work which may exempt them from the standard) and documents that employees are not exposed above the permissible exposure limit (PEL), the employer must treat employees as if they were exposed above the PEL for the

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022 following operations:

• manual demolition of structures, manual scraping, manual sanding, and use of heat gun where hazardous coatings or paints are present;

• abrasive blasting enclosure movement and removal;

• power tool cleaning;

• lead burning;

• using hazardous mortar or spray paint;

• abrasive blasting, rivet busting, or welding, cutting, or burning on any structure where hazardous coatings or paint are present;

• cleanup activities where dry expendable abrasive are used; and

• any other task the employer believes may cause exposure in excess of the PEL.

This means providing respiratory protection, protective work clothing and equipment, change areas, hand washing facilities, biological monitoring, and training until an exposure assessment has determined that the work activity will result in an exposure below the PEL.

Additional requirements under this standard include a written compliance program as well as record keeping.

5.2.2 WASTE DISPOSAL

Waste disposal is governed by the Federal Resource Conservation and Recovery Act (RCRA) regulations, which distinguish between solid wastes and hazardous wastes. Solid wastes include general construction debris and are subject to minimum handling, transportation, and landfill disposal requirements under RCRA regulations. Hazardous wastes are subject to restrictions designed to prevent the hazardous materials from entering the environment.

As of December 21, 2017, Ohio EPA’s Ohio-Specific Universal Waste rules allow hazardous paint-related waste to be classified as a universal waste in Ohio under OAC Chapter 3745-273. A universal waste is a unique category of hazardous waste that may be managed under less burdensome handler and transport requirements in the state of Ohio. The hazardous paint-related waste would not need to be managed and transported as hazardous waste. Quantities would not count towards the hazardous waste generator status; which includes conditionally exempt small quantity generators (CESQGs), small quantity generators (SQGs) and large quantity generators (LQGs). Thus, hazardous waste manifesting would also not be required.

Under the Ohio EPA’s Ohio-Specific Universal Waste rules, there are two classes of handlers. A Small Quantity Handler of Universal Waste (SQHUW) may store less than 5000 kg of UW at any time and a Large Quantity Handler of Universal Waste (LQHUW) may store 5000 kg or more of UW. The handler’s management activities are limited to those specified in OAC rule 3745-273-13 for SQHUW and OAC rule 3745-273-33 for

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

LQHUW. A Universal Waste Transporter must transport the waste in accordance with all U.S. DOT requirements.

For disposal purposes, hazardous paint-related waste must still be classified as hazardous or non-hazardous, based on the results of the Toxic Characteristic Leachate Procedure (TCLP) testing, to determine the destination facility (non-hazardous or hazardous disposal facility). The leachability test measures whether or not lead leaches from the waste in excess of the regulated level of 5.0 mg/L. If the results of the TCLP analysis exceed this level, the waste must be handled, transported and disposed as a hazardous waste in an approved waste site, reclamation facility or incinerator site.

EPA’s regulations require the TCLP to be performed so that it represents the matrix and material of the waste stream. For the project, this can be in the form of a representative sample of debris taken either before or after the project begins. Since waste disposal is made up of a matrix of all debris that is to be disposed, combining painted surfaces with low XRF results with those surfaces with higher XRF results may classify the waste as non-hazardous for disposal purposes.

5.2.3 SCRAP METAL RECYCLING

Metal components that will be removed which contain lead are exempt from the requirements of RCRA if sent to a scrap facility for recycling and are, therefore, not considered waste. It is recommended that the owner receive a receipt or bill of lading from the scrap facility stating that the scrap metal was accepted and purchased by the scrap facility.

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

6.0 RELIABILITY OF REPORT - DISCLAIMER

This report has been prepared to document findings of the hazardous material survey only, not for abatement design. Abatement design should be performed by appropriately experienced and credentialed personnel. Additional reconnaissance work, which may include minor demolition to access hidden areas and further sampling/analyses, should be expected as part of abatement design.

Our inspection excluded areas that require significant demolition of building surfaces and structures for access; therefore, should suspect asbestos-containing materials (e.g., pipe insulation, vermiculite, etc.) be discovered above fixed ceiling systems or within wall systems and inaccessible pipe chases, these materials should be properly sampled and removed by an abatement contractor if necessary

The opinions, conclusions, and recommendations presented in this report are put forth for a specific and proposed purpose and for the specific site discussed. Rii is not responsible for any other application, whether of purpose or location, of our opinions, conclusions, or recommendations, other than as specifically indicated in this report.

Conclusions reached in this report are based upon the objective data available to Rii at the time of forming the opinions as presented in this report. The accuracy of this report depends upon the accuracy of the data. The conclusions reached herein represent our opinions. Rii is not responsible for actual conditions proven to be materially at variance with the data that was available to them and upon which they relied, as presented in this report.

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

7.0 SIGNATURE OF ENVIRONMENTAL PROFESSIONAL

The state licenses of the personnel involved in this survey are provided in Appendix D.

The environmental professionals responsible for the Hazardous Material Survey are as follows:

Kristy Engel-Shepard Environmental Project Manager Certified Asbestos Hazard Evaluation Specialist – No. ES34846 Certified Asbestos Hazard Abatement Project Designer – No. PD60776 Certified Lead Risk Assessor – No. LA9350

Zachary B. Hamilton, CPG, PG, LPG Environmental Geologist Certified Asbestos Hazard Evaluation Specialist – No. ES34150 Certified Asbestos Hazard Abatement Project Designer – No. PD60880

Michelle L. Eckels, CPG Vice President – Environmental Services Certified Asbestos Hazard Evaluation Specialist – No. ES33141 Certified Asbestos Hazard Abatement Project Designer – No. PD60600

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

DEFINITION OF TERMS

Abatement – Procedures to control fiber release from Asbestos-Containing Materials (ACM). Includes removal, encapsulation, and enclosure.

Asbestos – A generic name given to a number of naturally occurring hydrated mineral silicates that possess a unique crystalline structure, are incombustible in air, and separate into fibers. Asbestos includes the asbestiform varieties of chrysotile (serpentine); crocidolite (riebeckite); amosite (cummingtonite-grunerite);

anthophyllite; tremolite, and actinolite, in any combination.

ACM - Asbestos-Containing Material – Any material containing more than 1% by weight of asbestos of any type or mixture of types (AHERA, OSHA definition).

Asbestos Fiber – A particle of asbestos, 5 micrometers or longer, with a length-to-diameter ratio of at least 3 to 1 (OSHA definition).

Ballasts – Both magnetic and electronic ballasts used to regulate the current and power to a fluorescent and HID lamps. Magnetic ballasts may or may not include capacitors containing PCBs. Prior to 1978, ballasts were commonly manufactured with PCBs in the capacitor oil and in a tar-like substance that surrounds ballast components called “potting compound”. Ballasts with no PCBs, will have an identifying sticker “No PCB”.

Category I nonfriable ACM – Asbestos-containing packings, gaskets, resilient floor covering and asphalt roofing products containing more than 1 percent asbestos as determined using Polarized Light Microscopy, as specified in appendix E, subpart E, 40 CFR part 763, section 1.

Category II nonfriable ACM – Any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos as determined using Polarized Light Microscopy, as specified in appendix E, subpart E, 40 CFR part 763, section 1, that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

EPA – Environmental Protection Agency.

Fluorescent Lamps – Low intensity discharge lamps that contain mercury and are commonly used in commercial and industrial lighting. Fluorescent lamps include tubes, circular and compact fluorescent lighting products, whether they use separate or integral ballast.

Friable Asbestos-Containing Material – Material that contains more than 1% asbestos by weight and that can be crumbled, pulverized, or reduced to powder, when dry, by hand pressure (ODH definition).

Pre-Renovation Hazardous Materials Survey Engineering Consultant Rii Project #W-22-094 – August 4, 2022

Hazardous Substance - a substance defined as a hazardous substance pursuant to CERCLA 42 USC part 9601(14), as interpreted by EPA regulations and the courts:

(A) any substance designated pursuant to section 1321(b)(2)(A) of Title 33, (B) any element, compound, mixture, solution, or substance designated pursuant to 42 USC part 9602, (C) any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal Act (42 USC part 6921), (D) any toxic pollutant listed under section 1317(a) of Title 33, (E) any hazardous air pollutant listed under section 112 of the Clean Air Act (42 USC part 7412), and (F) any imminently hazardous chemical substance or mixture with respect to which the EPA Administrator has taken action pursuant to section 2606 of Title 15.