5_HMA_Redacted.pdf

RE: Pre-demolition Hazardous Materials Assessment

Glennallen Log Bunkhouse – Old DM House, Glennallen, Alaska is pleased to provide you with Limited Hazardous Materials Assessment for the Old DM House in

Glennallen, Alaska. The following is a brief synopsis of the background, scope of work, methodology, field activities, sampling results with discussion including conclusions and recommendations.

Background and Scope of Work

The Bureau of Land Management (BLM) has contracted for a hazardous materials survey to be conducted prior to the demolition of the Old DM House at the Glennallen

Administrative Site in Glennallen, Alaska. The original construction was in the 1960s as a house for the district manager. The building has been used as office space, a bunkhouse, and other uses as needed throughout the years. The pre-demolition assessment was to identify building materials which would require special handling and/or disposal during demolition. The scope of work excluded assessment of current/former utilities.

Previous Investigations

An asbestos survey of the Old DM House was completed by Archer in June 2011.

Laboratory samples were collected of eleven suspect building materials for asbestos analysis, including sheet vinyl, mastics, cove base, felt, and exterior log chinking. The chinking was identified as containing 15% asbestos and other materials were non-detect for asbestos.

Methodology

Hazardous material identification was accomplished using information from a previous investigation, a visual inspection, and sampling in accordance with

. Project staff included two EPA-certified AHERA Asbestos Inspectors and an EPA-certified Lead Paint Inspector. The assessment was overseen by a Professional Engineer.

Field Sampling Activities

The structure was inspected by on March 29, 2022. The Old DM House is a two story, wood-log structure with a metal roof constructed in 1960. Interior

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A non-redacted version will provided to the awardee, if desired

Pre-Demolition Hazardous Materials Assessment

Old DM House, Glennallen, Alaska

April 25, 2022 finishes were primarily wood with sheet vinyl flooring and carpet, some gypsum wallboard walls, and cove base. A second story attic/storage space was accessed through an exterior metal ladder on the north side of the building or by drop-down stairs in the main interior hallway.

Asbestos

During the March 2022 visual inspection, the materials observed in 2011 were confirmed to remain in similar condition and were sampled to confirm the previous results. Additional samples were collected of materials not previously identified as sampled. These included exterior window caulking, carpet and carpet adhesive, shower liner mastic, and wall mud behind wallpaper.

No suspect materials were identified in the second story space.

Lead-Based Paint performed an Environmental Protection Agency/Housing and Urban Development

(EPA/HUD) compliant LBP assessment of all painted surfaces. Work was completed with a

Thermo Fisher NITON XLp-303A, x-ray fluorescent (XRF) spectrum analyzer. In accordance with the instrument’s Performance Characteristic Sheets (PCS), substrate corrections were not needed.

Before beginning the assessment, noted the time and date on the Calibration Check

Test Results datasheet (Appendix 4) and performed the manufacturer’s recommended warm up procedures. used the National Institute of Standard and Technology’s Standard

Reference Material (NIST SRM) 2573 (1.04 ± 0.04 mg/cm2 lead content) film to perform all necessary equipment calibration checks. The film was placed at least 12 inches from any painted surface and took three calibration check readings. The readings were then averaged and compared to the NIST SRM. Averages between 0.8 mg/cm2 and 1.2 mg/cm2 are considered to be within calibration standards using the 2573 film.

The XRF was checked for calibration compliance before beginning the LBP inspection, at the completion of the LBP inspection, and every four hours during use. The Calibration Check Test

Results datasheet was completed for each calibration check. The XRF remained within calibration for the duration of the inspection (see completed datasheets in Appendix 2).

recorded each component type within each room equivalent on the Single-Family

Housing LBP Testing Datasheet (Appendix 4). Readings from different room equivalents were recorded on different datasheet, with the room equivalent clearly marked at the top of the datasheet. As the PCS indicates substrate correction is not needed, all XRF readings greater than or equal to 1.0 mg/cm2 were considered positive results for LBP.

Other Items Requiring Special Handling

The structure was inspected for other materials and items that may require special handling and disposal if encountered or disposed of. These items include fluorescent tubes, thermostats with mercury switches, portable fire extinguishers, lead acid batteries, refrigeration units, smoke detectors, exit signs with radioactive source, and other potentially hazardous materials.

Results with Discussion

Asbestos

ACM samples, descriptions, locations, and results are presented on Figure 2. The exterior log chinking was identified as ACM and is estimated at 2,500 linear feet. The exterior window

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April 25, 2022 caulking was identified as less than 1% asbestos. The wallpaper mud was identified as 2% asbestos, but the more rigorous point count indicated that asbestos was not present. The results of the inspection is summarized below:

Asbestos Containing Materials (ACM)

• Friable None Detected

• Non-Friable (Category I None Detected

• Non-Friable (Category II) o Black exterior log chinking 2,500 linear feet

ACM is divided into friable and non-friable materials for the purposes of abatement. Non-friable ACM is divided into Category I and Category II materials. The non-friable Category II ACM material identified will require demolition by certified asbestos workers using Class II OSHA methods and disposed of as ACM debris. Category II asbestos materials do not require segregation from the renovation debris, but the demolition will be considered a Class II activity and all waste will be considered ACM for disposal purposes if the ACM is left in place during demolition. If the Class II ACM is abated prior to demolition, the remaining building may be demolished using standard demolition methods and the waste will be considered non-ACM construction and demolition debris.

These ACM results should be provided to the demolition contractor as part of the demolition procurement package. Class II abatement (or demolition) must be completed under an approved work plan with properly trained workers to minimize the potential for asbestos exposure or release.

Lead-Based Paint collected a total of 43 XRF readings for 11 room equivalents. Tested components included interior walls, ceilings, kitchen cabinets, and storage shelves. Painted surfaces were not observed on the exterior of the building or in the storage/attic space on the second floor of the building. Sample IDs, Photo IDs, substrates, components, paint colors, test locations, XRF readings, and results were recorded on the LBP Testing Data Sheets (Appendix 4). Sample locations, descriptions, materials, and results are also shown in Figure 3, Appendix 1. Based on valid XRF readings, the LBP assessment identified four positive results and 39 negative results.

identified LBP within the following room equivalents and testing combinations:

• Kitchen o Upper cabinets o Lower cabinets

Paints with any lead concentration, even below the HUD standard, represent a potential hazard for workers who are completing work practices involving lead trigger tasks such as burning, sanding, or grinding. Disposal of these materials at a landfill will require a Toxicity Characteristic

Leaching Procedure (TCLP) to be performed on the waste stream by an appropriate laboratory to determine RCRA characterization. The waste stream will be dependent on the methods employed for paint removal and may require additional testing, characterization, and segregation if chemical abatement is employed.

TCLP

Due to the limited quantity of lead containing paint, a theoretical TCLP calculation was performed to characterize the demolition was as hazardous or non-hazardous for lead. ASTM

Standard E 1908-10 was used as guidance and 100% of the lead in paint was assumed to be leachable. The calculated demolition waste consisted of wallboard walls, wood log structure, flooring, roofing, and other miscellaneous materials typical of a residence.

The total quantity of lead in paint is calculated to be 749,316 mg. The total weight of the building is estimated at 23,000 kg. The ratio of lead to the weight of the anticipated waste stream is approximately 32.6 mg of lead per kg of waste. Based on the above calculations, the mass concentration of lead is less than the 20:1 rule criteria of 100 mg/kg for solid waste. This whole-building waste stream is considered non-hazardous for leachable lead in paint and may be disposed of as standard construction and demolition (C&D) waste.

In this analysis, the weight of the chinking does not significantly change the outcome of the theoretical TCLP, so the chinking could be abated without the need for additional evaluation.

Other changes in the waste stream (salvage of roofing, logs, etc) would significantly alter the weight of the waste stream(s) and may warrant a laboratory TCLP analysis to evaluate each waste stream that contains the cabinets.

Other Items Requiring Special Handling

The following potentially hazardous items were observed during the field inspection:

• Fluorescent bulbs 11 each

• Fluorescent tubes 10 each

• Smoke detector 4 each

Consider reusing lighting components. If not reused, then they need to be properly disposed of.

Conclusions and Recommendations has completed a pre-demolition hazardous materials assessment of the Old DM

House at the BLM facility in Glennallen, Alaska. Based on the field observations and laboratory results, the following conclusions and recommendations have been developed:

• Non-friable Category II ACM was identified in the exterior log chinking o This material may be demolished in place or abated prior to demolition o Abatement/demolition of Category II ACM must be completed using Class II work practices o Any demolition waste stream with Category II ACM must be disposed of as ACM

• Painted cabinets within the kitchen contain lead in concentrations above the HUD limit of

1mg/cm2 o Other paint in the building does not contain lead o A theoretical TCLP indicates the whole-building waste stream that includes the cabinets is not hazardous for lead o Segregation of the waste streams (except abatement of the ACM chinking) will require additional TCLP evaluation for the waste stream that includes the cabinets

• Fluorescent lamps and smoke detectors should be reused or disposed of in a legal manner

• A work plan for abatement and demolition activities that documents compliance with applicable regulations should be provided by the contractor prior to commencing demolition

This pre-demolition hazardous material assessment was conducted to identify the potential hazards and associated regulatory constraints involved with management, abatement, and disposal of materials identified. All information about hazardous material associated with the building should be made available to employees, contractors, and abatement contractors associated with the renovation or demolition of the building. Specific management, abatement, and/or demolition work practices may require additional sampling to comply with OSHA worker exposure regulatory guidelines.

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

Sincerely, Attachments: Figure 1-3

Photo Log

Laboratory Report

LBP Field Notes (Testing Datasheets)

Hazardous Material Standardized Methodology v19

Attachment 1 Figures

PROJECT

LOCATION

PROJECT

LOCATION

0 1/2 MILE 1 MILE 0 100' 200'

PROJECT

LOCATION

GLENN HIGHWAY

SA

SH

A D

R

IV

E Redacted vendor details Redacted

A-14A-15

ROOF

A-13

A-11

A-12

A-10A-6

A-8A-9

A-7A-2

A-1

A-4

INTERIOR

Asbestos Sample Results (Method EPA 600/R-93/116)

Sample ID Description Result

A-1 blue & tan kitchen floor squares ND

A-2 tan cove base ND

A-2 tan mastic ND

A-4 tan cove base ND

A-4 yellow mastic ND

A-6 brown/white wallboard covering ND

A-6 black mastic ND

A-7 white & tan bathroom floor ND

A-8 white & tan vinyl floor sheet ND

INTERIOR

Asbestos Sample Results (Method EPA 600/R-93/116)

Sample ID Description Result

A-8 white/beige mastic & leveler ND

A-9 white shower liner ND

A-9 tan mastic ND

A-10 brown carpet ND

A-10 carpet pad ND

A-11 brown/tan carpet ND

A-11 carpet backing ND

A-12 baseball wallpaper ND

A-12 pink/beige mud <0.25% Chrysotile

EXTERIOR

Asbestos Sample Results (Method EPA 600/R-93/116)

Sample ID Description Result

A-13 black exterior chinking 8% Chrysotile

A-14 roof core ND

A-15 tan window caulk - exterior <1% Chrysotile

ASBESTOS SAMPLE LOCATIONS

NEGATIVE (<1% ASBESTOS)

ASBESTOS SAMPLE LOCATIONS

POSITIVE (>1% ASBESTOS)0123

SEE ASBESTOS TABULATED

RESULTS FOR ACM SAMPLE

NUMBER

LEGEND

ASBESTOS CONTAINING CHINKING

LBP-7

LBP-8

LBP-6

LBP-4

LBP-9

LBP-15

LBP-5

LBP-10

LBP-13

LBP-12

LBP-11

LBP-3

LBP-14

LBP-2

LBP-19

LBP-17

LBP-18LBP-16

LBP-25

LBP-26

LBP-24

LBP-29

LBP-28

LBP-27

LBP-36 LBP-43

LBP-37

LBP-31

LBP-30

LBP-1

LBP-45

LBP-44

LBP-32

LBP-33

LBP-42

LBP-41

LBP-40

LBP-39

LBP-38

LBP-23

LBP-22

LBP-20 LBP-21

LEAD BASED PAINT SAMPLE

(<1mg/cm sq)(HUD)

LEAD BASED PAINT SAMPLE

(>1mg/cm sq)(HUD)

SEE LEAD BASED PAINT

TABULATION RESULTS FOR

CONCENTRATION FOR

LEAD SAMPLE NUMBER

LEGEND

INTERIOR

Lead Sample Results

Number Color Surface Substrate Result (mg/cm²)

LBP-1 white ceiling wood 0.01

LBP-2 white ceiling wood 0.03

LBP-3 white cabinet door wood 1.6

LBP-4 white cabinet door wood 1.5

LBP-5 white cabinet door wood 1.8

LBP-6 white cabinet wood 0.8

LBP-7 white window wood 0.09

LBP-8 white window wood 0.08

LBP-9 white cabinet wood 2.3

LBP-10 white window wood 0.07

LBP-11 white window metal 0.02

LBP-12 white window wood 0.07

LBP-13 white window metal 0.06

INTERIOR

Lead Sample Results

Number Color Surface Substrate Result (mg/cm²)

LBP-14 white trim wood 0.09

LBP-15 white ceiling wood 0.09

LBP-16 white wall wood 0.01

LBP-17 white wall wood 0.06

LBP-18 white shelves wood 0.00

LBP-19 white shelves wood 0.01

LBP-20 white wall wood 0.05

LBP-21 white wall wood 0.05

LBP-22 white window wood 0.01

LBP-23 white window metal 0.03

LBP-24 white wall wood 0.00

LBP-25 white wall wood 0.00

LBP-26 white ceiling wood 0.03

LBP-27 white wall wood 0.00

LBP-28 white wall wood 0.00

INTERIOR

Lead Sample Results

Number Color Surface Substrate Result (mg/cm²)

LBP-29 white ceiling wood 0.00

LBP-30 white wall wood 0.00

LBP-31 white wall wood 0.00

LBP-32 white wall wood 0.01

LBP-33 white wall wood 0.00

LBP-36 white wall wood 0.06

LBP-37 white wall wood 0.14

LBP-38 white wall wood 0.00

LBP-39 white wall wood 0.02

LBP-40 white ceiling wood 0.00

LBP-41 white wall wood 0.01

LBP-42 white wall wood 0.03

LBP-43 white wall wood 0.00

LBP-44 white wall wood 0.00

LBP-45 white ceiling wood 0.00

Attachment 2 Photo Log

Photo 1: Living room, example of non-gypsum wallboard interior paneling.

Photo 2: Bedroom 1, example of gypsum wall board interior walls and celling

Photo 3: Close-up of chinking between exterior logs. Chinking contained 8% Chrysotile and is considered ACM.

Photo 4: Kitchen cabinets (upper and lower) had XRF results between 1.5 mg/100 cm2 and 2.3 mg/100 cm2 and are considered to contain lead-based paint.

Photo 5: Second floor/attic children’s play area. No painted surfaces or potential ACM was identified in this area.

Photo 6: Second floor, non-play area of the attic space.

Attachment 3 Laboratory Report

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

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

A-1

512200879-0001

None DetectedNon-fibrous (Other)80%Cellulose

Glass

15%

5%

Beige

Fibrous

Homogeneous

Blue and Tan

Squares, Kitchen

Floor

A-2-Cove Base

512200879-0002

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Tan Cove Base, Kitchen

A-2-Mastic

512200879-0002A

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

Tan Cove Base, Kitchen

A-4-Cove Base

512200879-0003

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Tan Cove Base, Storage Room

A-4-Mastic

512200879-0003A

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Tan Cove Base, Storage Room

A-6-Fiber Board

512200879-0004

None DetectedNon-fibrous (Other)5%Cellulose95%Brown/White

Fibrous

Homogeneous

White Wall Board

Covering, Laundry

Room

A-6-Mastic

512200879-0004A

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

White Wall Board

Covering, Laundry

Room

A-7

512200879-0005

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

Non-Fibrous

Homogeneous

White and Tan

Geometric, Bathroom

1 Floor

A-8-Vinyl Sheet Flooring

512200879-0006

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

Non-Fibrous

Homogeneous

White and Tan

Geometric, Bathroom

2 Floor

A-8-Mastic & Leveler

512200879-0006A

None DetectedNon-fibrous (Other)98%Cellulose2%White/Beige

Non-Fibrous

Heterogeneous

White and Tan

Geometric, Bathroom

2 Floor

Analysis includes inseperable mastic and leveler.

A-9-Plastic Sheet

512200879-0007

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

White Shower Liner, Bathroom 2 Shower

Liner

A-9-Mastic

512200879-0007A

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

White Shower Liner, Bathroom 2 Shower

Liner

A-10-Carpet

512200879-0008

None DetectedNon-fibrous (Other)25%Synthetic75%Brown

Fibrous

Homogeneous

Carpet, Bedroom/Master

A-10-Pad

512200879-0008A

None DetectedNon-fibrous (Other)100%Various

Non-Fibrous

Homogeneous

Carpet, Bedroom/Master

A-11-Carpet

512200879-0009

None DetectedNon-fibrous (Other)30%Synthetic70%Brown/Tan

Fibrous

Homogeneous

Carpet, Bedroom 3

A-11-Backing

512200879-0009A

None DetectedNon-fibrous (Other)45%Cellulose

Glass

45%

10%

Tan

Fibrous

Heterogeneous

Carpet, Bedroom 3

Initial report from: 04/06/2022 15:40:44

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

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

Analysis includes paper, mesh, and glue.

A-12-Wallpaper

512200879-0010

None DetectedNon-fibrous (Other)20%Cellulose80%Various/Blue

Fibrous

Homogeneous

Baseball Wallpaper, Bedroom 2

A-12-Mud

512200879-0010A

2% ChrysotileNon-fibrous (Other)98%Pink/Beige

Non-Fibrous

Homogeneous

Baseball Wallpaper, Bedroom 2

A-13

512200879-0011

8% ChrysotileNon-fibrous (Other)92%Black

Fibrous

Homogeneous

Black Chinking, Outside Chinking

A-14

512200879-0012

None DetectedNon-fibrous (Other)90%Glass10%Black

Fibrous

Homogeneous

Roof Core, Roof Core

Front Porch

A-15

512200879-0013

<1% ChrysotileNon-fibrous (Other)100%Tan

Fibrous

Homogeneous

Window Caulk, Front

Porch

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

Polarized Light Microscopy. Quantitation using 400 Point Count Procedure

Sample Description Appearance % Fibrous % Non-Fibrous % Type

Non-Asbestos Asbestos

Pink/Beige

Non-Fibrous

Homogeneous

Baseball Wallpaper, Bedroom 2

A-12-Mud

512200879-0010A

Non-fibrous (Other)100.0% <0.25%Chrysotile

Inseparable paint / coating layer included in analysis

Attachment 4 LBP Field Notes

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Attachment 5 Hazardous Materials Standardized

Methodology

SUSTAINABLE ENVIRONMENT, ENERGY,

HEALTH & SAFETY PROFESSIONAL SERVICES

HAZARDOUS MATERIALS

STANDARDIZED METHODOLOGY

Version 19 June 2021

Objective and Management hazardous materials assessment methodologies are developed to comply with currently applicable regulations utilizing standard industrial hygiene practices designed for the anticipation, recognition, evaluation, and control of those factors or stressors arising in or from the workplace that may cause sickness, impaired health and well-being, or significant discomfort among workers or citizens of the community. Qualified personnel with current certifications and experience conduct field assessment inspections and sampling efforts. All work completed is managed, reviewed, and signed off on by a board Certified Industrial Hygienist (CIH) or Professional Engineer.

Scope of Work provides a variety of hazardous material services as necessary to meet project specific needs cost effectively. In order to minimize costs, has developed the following standardized hazardous material assessment scopes of work.

Limited Hazardous Material Assessment: The assessment scope of work is limited to specifics as specified by the client in the written contract and/or project communications.

Limitations may include/exclude contaminants, destructive testing, costs, and/or areas to be assessed.

Pre-Renovation Hazardous Material Assessment: The assessment is limited to a specific project renovation scope.

Pre-Demolition Hazardous Material Assessment: The assessment is in preparation for an entire building demolition.

Hazardous materials included in this standard are:

Asbestos Containing Materials (ACM) o Building Materials o Naturally Occurring Asbestos (NOA)

Asbestos in Dust Silica in Dust Lead Based Paint (LBP) Lead in Soil Universal Wastes Polychlorinated Biphenyls (PCBs) o Bulk Materials o Wipe Samples o Air Samples o TSCA Regulated Materials

RCRA Eight Heavy Metals Other Wastes Requiring Special Handling

Definition of Hazardous Materials Hazardous materials are defined as any material requiring special handling or disposal during demolition or renovation. Of particular interest are asbestos containing building materials

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Hazardous Materials Standardized Methodology

(ACBM), lead based paint (LBP), RCRA eight heavy metals and other hazardous materials including polychlorinated biphenyls (PCBs), radioactive materials in smoke detectors & self-illuminating exit signs, lead-acid batteries, wastewater, water intrusion fungal amplification, petroleum oils and lubricants (POLs) mercury containing equipment (switches, bulbs etc.) and other chemical and biological contaminants.

Universal Waste EPA's universal waste regulations set forth in 40 CFR part 273 streamline hazardous waste management standards for federally designated "universal wastes," which include:

Batteries Paints & pressurized containers Chemicals & pesticides Mercury in switches and fluorescent light tubes

The regulations govern the collection and management of these widely generated wastes.

These regulations are designed to improve hazardous material handling and disposal of universal wastes by easing the regulatory burden on generators and facilitating disposal program development.

Regulatory The hazardous material surveys are conducted to comply with the asbestos survey requirements of the Occupational Safety and Health Administration (OSHA) found in 29 CFR 1926. These regulations state that before authorizing or allowing any construction, demolition, renovation, or remodeling, the owner, owner's agent, or employer, must notify contractors or other persons of the location and quantities of ACM within the work area.

U.S. Environmental Protection Agency National Emissions Standards for Hazardous Air Pollutants (NESHAP) requires a thorough inspection for friable and non-friable ACM by an accredited Asbestos Hazard Emergency Response Act (AHERA) inspector prior to any renovation or demolition activity (40 CFR 61.145). NESHAP also requires notification for removal or abatement of regulated quantities of ACM (>260 square feet, >160 linear feet, or >35 cubic feet of regulated asbestos containing material (RACM)).

Asbestos Containing Materials The asbestos sampling collection technique used during the survey generally follows the AHERA method as defined in 40 CFR 763. Laboratory analysis of samples are completed by a laboratory certified through the National Voluntary Laboratory Accreditation Program (NVLAP) to perform asbestos analysis by polarized light microscopy (PLM) according to EPA method 600/R-93/116 to determine the percent concentration by weight as required by the current OSHA standard. Building material containing 1% or greater asbestos content is considered asbestos containing material.

Asbestos containing building materials with sample results less than 5% asbestos are analyzed by 400-point count EPA 600/R-93/116 method. Analysis by 400-point count has a detection limit of 0.25% and can provide greater accuracy, especially for sample results on the margin of 1%.

Alternatively, for non-friable organically bound materials such as vinyl flooring, roofing, mastics, and caulking, gravimetric preparation of the sample is an additional process to the 400 point count EPA 600/R-93/116 method. Asbestos present in those materials are typically tightly bound and not easily identified by microscopy and thus may require additional sample preparation.

It is a common practice to measure asbestos concentration in air if you suspect that asbestos fibers may be present. Sampling is performed if asbestos was discovered in a particular area, if you accidentally disturbed an asbestos-containing material, or when asbestos was removed, and abatement team needs to verify that no residual asbestos is left in the air. Asbestos concentration in air is strictly regulated. Asbestos concentration in the air of a working zone cannot exceed 0.1 fiber per centimeter cube (f/cc). For asbestos abatement clearance test, this level is: 0.01 f/cc. The most common method for asbestos testing in air is a method developed by National Institute of Occupational Safety and Health (USA): NIOSH

Asbestos in Dusts Protocol for determining asbestos containing material (ACM) in dust collection requires analysis by TEM (Transmission Electron Microscopy) by a laboratory certified through the National Voluntary Laboratory Accreditation Program (NVLAP) to perform TEM analysis. Dust collection for lab testing may either involve dust wipe collection using a laboratory supplied “Ghostwipe”™ and sized template, or by utilizing a laboratory supplied 37 mm TEM air cassette inline with a pump and plastic tubing and vacuuming a known amount of surface area coated in dust.

With regard to lab analysis of samples collected, there are no standards for asbestos in settled dust against which one can compare results. However, the literature (Millette and Hays, 1994) has provided some general conclusions regarding interpretation of sampling data on the level of asbestos in settled dust and is based on extensive field data, observation, and experience. They report that a level of less than 1,000 asbestos structures/cm2 is low, while levels above 10,000 s/cm2 are considered generally above background. Levels greater than 100,000 s/ cm2 are indicative of elevated concentrations of asbestos fibers with significant risk of exceeding the OSHA permissible exposure level (PEL) for most work tasks.

Silica in Dusts Air Sample Collection: Sampling for silica is performed by using 37mm PVC filters utilizing an air sampling cyclone. A minimum of 2.7 liters/minute of air is required to achieve a laboratory limit of detection compatible to the OSHA PEL and Action Level. Both NIOSH Method 7500 and NIOSH Method 7602 are comparioble for laboratory analysis of airborn silica. NIOSH 7500 uses X-Ray Diffraction while NIOSH 7602 uses the Fourier Transform Infared Spectroscopy. The determination of laboratory method should be by comparing any known or suspected interferences in the sample, such as phosphates, potash, or zircon and choosing the analysis that does not contain known interferences with those identified during sampling. Laboratory sensitivity for both tests of 5 μg/m3, which is 10% of the PEL.

Wipe Sample Collection: Wipe sampling of silica on horizontal surfaces, a modified NIOSH 7500 or modified NIOSH 7602 is performed during laboratory testing utilizing a ghost wipe as the preferred sampling media. A minimum of 50 milligrams of settled dust is required from an area of 1 ft2 to be placed in to a sealed container.

Workers’ exposures would be limited to a PEL of 50 micrograms of respirable crystalline silica per cubic meter of air (μg/m3), averaged over an 8-hour day. An Action Level of 25 μg/m3 was established where exposure control methods, respiratory protection, and regulated areas with a a written control plan with exposure assessment should be performed. The Action Level and PEL are the same in both general industry, maritime, and construction. There is currently no standard to compare settled silica dust concentrations against potential respirable concentrations. The presence of silica contamination in dust is a worker exposure issue if the dust becomes airborne and is inhaled.

Lead Based Paint (LBP) Quantification of lead-based paint is performed according to NIOSH 7702, using a Thermo Fisher NITON XLp-303A, x-ray fluorescent (XRF) spectrum analyzer, providing EPA accepted real-time, on-site sample results. A Performance Characteristics Sheet (PCS), that routinely accompanies the NITON analyzer, provides supplemental information to be used in conjunction with Chapter 7 of the HUD guidelines. The PCS indicates that substrate corrections are not required for this instrument when operated in accordance with the manufacturer’s instructions and HUD guidelines. Environmental Protection Agency/Department of Housing and Urban Development (EPA/HUD) protocol for the inspection of LBP in residential structures is generally followed.

Lead analysis of paint may also be determined by scrape sample and lab analysis.

Representative paint scrape samples of the building’s construction materials are collected from each representative paint type and color. Paint scrapes are collected within a 10 cm2 area and sent to lab for analysis by percentage of lead per weight of paint collected.

All paint may contain a measurable amount of lead, however, EPA and HUD consider paint containing 1.0 mg/cm2 (XRF analysis) or 0.5 percent (5,000 ppm) by weight (lab analysis) and higher to be LBP. These guidelines may not be directly applicable to this project, but are a good reference for evaluating the investigation’s sample results. Paint with lower concentrations of lead than these thresholds may still pose an OSHA health hazard if mishandled. The LBP assessment is completed by qualified personnel with current EPA lead inspector certification.

EPA guidance lists documented methodologies that are appropriate for the work practice standards, including U.S. Housing and Urban Development (HUD) guidelines and certain EPA methodologies, and states that “other equivalent methods” are acceptable.

Lead in Soil EPA defines lead hazards in soils depending on the land use (40 CFR 745.65 (c) & Section 403 of Title X of the Toxic Substance Control Act (TSCA)). Bare soils meeting or exceeding the following limits are considered hazardous:

Residential and children’s high contact play areas 400 mg/Kg Commercial – non-residential, 800 mg/Kg Bare soil in industrial settings, 1200 mg/Kg

EPA regulates bare soils in excess of 1,200 mg/Kg as industrial, and restricts access by children. Soils in excess of 5,000 mg/Kg fall under the TCLP rule for hazardous wastes and would require abatement or permanent encapsulation.

The ADEC published residential soil cleanup level for lead is 400mg/Kg of soil dry weight.

ADEC specific cleanup criteria language for lead in soils provided in Note 11 of Table B1 in 18 AAC 75.341 states:

Lead cleanup levels must be determined on a site-specific basis, based on land use.

For residential land use, the soil cleanup level is 400 mg/kg. For commercial or industrial land use, as applied in 18 AAC 75.340(e)(3), the soil cleanup level is 1,000 mg/kg.

Through an approved site-specific risk assessment, conducted according to the Risk Assessment Procedures Manual, adopted by reference at 18 AAC 75.340, approved exposure models may be used to evaluate exposure to a child resident or an adult worker; a responsible person may also propose an alternative cleanup level, through a site-specific risk assessment conducted according to the Manual, and based on a chemical speciation of the lead present at the site. For soils contaminated with lead more than 15 feet below ground surface, lead cleanup levels will be determined on a site-specific basis.

Polychlorinated Biphenyls (PCB) Bulk sample collection: Bulk material testing for PCBs collects a representative sample of a material to be sent for laboratory analysis. Materials should be carefully collected independently to prevent potential contamination from other surfaces in direct contact with the suspected material. For porous materials, such as concrete, brick, and wood, a minimum of 2 cm deep and 2cm wide of material shall be collected as a cores sample rather than a traditional surface bulk sample. Best practices are utilized in the core sampling procedure to minimize dust generation and potential area contamination. A minimum of 10 grams of material is placed in a glass jar for laboratory analysis by EPA SW-846 3540C/8082A. Samples will be placed, stored, and shipped in a cooled container to maintain a temperature of <4°C. The reporting limit for this method of detection is 0.5 mg/Kg.

Wipe sample collection: For non-porous unpainted surfaces and materials, such as metals, a wipe sample is used to determine potential PCB contamination. A acetone/hexane moistened wipe is used to thoroughly rub a surface with an area of 100 cm² or 10 cm by 10 cm. The wipe sample is placed in a glass jar for laboratory for analysis by EP SW-846 3550B/8082A. Samples will be placed, stored, and shipped in a cooled container to maintain a temperature of <4°C. The reporting limit for this method is 0.50 μg/100 cm².

Indoor air sample collection: For Aroclor 1242 and Aroclor 1254, OSHA has a PEL of 1.0 mg/m³ and 0.5 mg/m³ respectively. For alaysis by NIOSH Method 5503, a Florisil tube with a Swinnex pre-filter is used to collect the air sample. The reporting limit for this method of analysis is 0.5 μg/m³ based on 50 liters of air. For analysis by EPA TO-10A, a polyurethane foam plug sorbent tube is used with a flow rate of up to 5 liters per minute. This analysis method has a reporting limit of 0.05 μg/m³ based on 1000 liters of air. A high flow air sample can also be utilized by EPA TO-4A analysis. A high flow air sample may be used with a flow rate up to 225 liters per minute and maintains the same sampling media, albeit of a larger sizing, as the EPA TO-10A method along with the same reporting limit.

Toxic Substances Control Act (TSCA): TSCA regulations state that any liquid containing PCBs at a concentration of greater than 50 ppm and solids containing a concentration greater 500 ppm are PCB containing and require proper disposal. Surface contamination of materials are applicable for materials that contain a surface concentration of PCBs greater than 100 μg/100 cm² and pertain to all applicaple regulations for solid materials greater than 500 ppm. For mineral oil-filled equipment manufactured before July 2, 1979, it must be assumed to be PCB containing unless a permanent label or other documentation from the manufacturer indicates the PCB concentration at the time of manufacture. For transformers, this assumption is only required when the transformer contains a minimum of 3 pounds of fluid other than mineral oil or the type of fluid is unknown. TSCA regulations state that cleanup levels of contamination are determined by the occupancy rate of the given area. For High occupancy areas, a cleanup level of less than 10 μg/100 cm² is required. For low occupany areas, a level of less than 100 μg/100 cm² is acceptable.

RCRA Eight Heavy Metals Determination of the demolition waste toxicity for the RCRA eight heavy metals (Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, Selenium and Silver) is based on a certified lab performing the Toxicity Characteristic Leaching Procedure (TCLP) (EPA SW846, Method-1311) analysis of a representative composite sample of the structure’s building materials.

During the field effort, a visual inspection is conducted to identify the presence of each of the RCRA eight heavy metals and approximate percent by weight of each expected to be in the building debris waste stream. A representative sample of the entire waste stream, including the RCRA metals present, is collected and homogenized into a composite sample of the entire project’s debris/waste stream and then analyzed at a certified lab in accordance with TCLP procedure. The TCLP test measures the potential for the eight metals identified in the Resource Conservation and Recovery Act (RCRA) to leach from a representative composite sample of the debris/waste stream under simulated landfill conditions. RCRA regulations allow for calculating the TCLP result from a composite sample with total metals using the “20:1 Rule” that account for the dilution of metals concentrations during the analysis.

Another alternative method is to calculate a Theoretical TCLP based on the observed quantities of construction materials with regard to potential heavy metals. Assuming all paint associated with the structure is lead-based paint, a theoretical calculation of the ratio between paint to construction debris waste can be used in place of a representative waste stream (TCLP) sampling to determine whether the project waste stream will be hazardous for lead and heavy metals in accordance with hazardous waste standard. This method involves using project specific knowledge to calculate the concentration of lead in the entire quantity of debris as follows:

If a waste is 100% solid, as defined by the TCLP method, then the results of the total constituent analysis may be divided by twenty to convert the total results into the maximum leachable concentration. This factor is derived from the 20:1 liquid-to-solid ratio employed in the TCLP. If a waste has filterable liquid, then the concentration of the analyte in each phase (liquid and solid) must be determined.

The following equation may be used to calculate this value:

[A x B] + [C x D] ___________________ = E

B + [20 (L/kg) x D]

Where:

A = Concentration of the analyte in liquid portion of the sample (mg/L) B = Volume of the liquid portion of the sample (L).

C = Concentration of the analyte in solid portion of the sample (mg/kg) D = Weight of the solid portion of the sample (kg) E = Maximum theoretical concentration in leachate (mg/L)

The value obtained (E) can be used to show that the maximum theoretical concentration in a leachate from the waste could not exceed the concentration specified in the toxicity characteristic (TC) (40 CFR 261.24).

In addition, if the total constituent analysis results themselves are below the TC limits without dividing by 20, then the same argument holds true, i.e., the maximum theoretical concentration in the leachate could not exceed the TC limits.

The 100 milligrams per kilogram value used in the determination is based on the 20:1 rule which represents the lowest possible mass analysis concentration, which could leach out greater than

5.0 milligrams per liter in a TCLP test. This is due to the 20:1 dilution ratio of the TCLP test protocol and also assumes that 100% of the lead in the sample will leach out. In most circumstances, 100% of the lead would rarely leach out. However, this assumption must be made in the place of actual TCLP laboratory results. This "worst-case" assumption adds a "safety factor" to compensate for errors in the data or in calculating the mass of the structure. If the initial test results show that the average weight percent of lead in the lead-based paint, the average paint thickness, or the average paint density varies widely from one part of the structure to another, it may be better to do separate "mass of lead-based paint" or "mass of lead in the lead-based paint" calculations for each part of the structure with similar values. The individual results for the different parts of the structure can then be summed before dividing by the mass of the entire structure.

The presence or absence of suspect RCRA 8 hazardous metals is verified by visually inspecting the structure, testing multiple like components with a NITON XRF, or collecting paint chip samples for laboratory analysis during the investigation. If no RCRA 8 suspect materials or suspect conditions are observed, the total lead in milligrams (mg) can be calculated for the materials (paint and substrate) in which LBP concentrations are assumed to be greater than EPA/HUD’s standard of <0.5% or <1mg/cm2 limit for what can be considered non-lead based paint. The calculations use the highest average lead value for each painted surface. Not all surfaces of the structure are painted, nor are openings & voids accounted for in the square footages calculated. Multiplying the average value of LBP (in mg/cm2) by the total square footage area (in cm2) of all painted surfaces, a total amount of milligrams of lead in the paint is estimated. A total (minimum) expected mass of kilograms of demolition debris is then calculated for the waste stream. The final calculation of the theoretical TCLP then uses the total milligrams of lead divided by the kilograms of demolition debris which equals the mass (mg/kg) of lead in the demolition waste stream. If the mass concentration of lead is less than the 20:1 rule criteria of 100 mg/kg, the debris waste stream is considered either non-hazardous. If the calculated concentration is higher than 100 mg/kg than additional assessment may be recommended. or hazardous for leachable lead.

Other Hazardous Materials Determination of other hazardous materials involves the processes described by EPA as follows:

Is the material a solid waste? (See: 40 CFR Part 261.2) Is the waste specifically excluded from RCRA? (See: 40 CFR Part 261.4) Is the waste a listed hazardous waste? (See: 40 CFR Part 261.30) Does the waste exhibit a characteristic of hazardous waste? (See: 40 CFR Part 261.20)

During structure investigation, other hazardous materials posing an environmental concern or health risk are watched for and where visually observed are noted in the report findings.

Determinations of other hazardous materials were based on the above EPA guidelines. These other hazardous materials include:

Mastics Caulks Lead containing building materials Stored chemicals, heating oils, hydraulic oils, automotive fuel products & lubricants

Radioactive materials in smoke detectors & self-illuminating emergency exit signs Lead-acid batteries in emergency lighting and emergency exit signs Mercury in thermostats, fluorescent light tubes & HID mercury vapor lighting PCB containing power transformers & PCB containing fluorescent light ballasts Stored, unidentified or flammable liquids, paints or pressurized containers Freon gas canisters Fire extinguishers & HALON fire suppression systems.

Limitations provides a level of service that is performed within the standard of care and competence found within this practice and the engineering profession. It must be recognized that limitations in a hazardous material inspection and assessment exist. The data presented should be considered representative of only the time and observances of our inspection. In addition, changes in the condition of the materials within the facility can occur with the passing of time, due to natural processes and/or from human activities. has performed the work, made the findings, and proposed recommendations in accordance with generally accepted environmental engineering practices using the best technology available at the time the work was performed.

has based its conclusions and recommendations on our current understanding of regulatory policies. The regulations concerning hazardous materials are constantly changing, including the interpretations of regulating agencies. If changes in regulations or their interpretation occur, then reserves the right to amend or revise conclusions and/or recommendations.

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