QUL RCAG Asbestos Report 2014.pdf

Asbestos Lead-Based Paint and PCB Survey

Radio Communications Control Facility

(QUL RCAG)

Squaw Butte, Idaho

DATE PREPARED: October 14, 2015

Table of Contents

Page

Section 1.0 Introduction

Section 2.0 Scope Of Work

Section 3.0 Procedures

Section 4.0 Field Observations

Section 5.0 Asbestos-Containing Materials (ACM) Survey Summary

Section 6.0 Statement Of Compliance

Section 7.0 Lead-Based Paint Survey Summary

Section 8.0 PCB Light Ballast Inspection Summary

Appendix A Asbestos Sample Summary

Appendix B Lead-Based Paint Sample Summary

Appendix C Laboratory Analysis Data Sheets

Appendix D Sample Location Drawing and Photo’s

Appendix E Inspector Certifications

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1.0 INTRODUCTION

This report presents the results of the asbestos inspection performed by Lance Kiblinger, Safety and Environmental Compliance Manager of the Federal Aviation Administration, at the facility known as QUL RCAG building located in Squaw Butte, Idaho.

This report was prepared based on information obtained during a site visit conducted on September 3, 2014 and the laboratory results of bulk samples of suspect building materials collected during the site visit. This report is not intended to be used for any renovation or demolition activities, nor should be used as a design specification package. Materials that require destructive methods to sample were not sampled during this visit and should be assumed to contain asbestos until analysis can prove otherwise.

2.0 SCOPE OF WORK

The scope of services performed includes the following:

Perform a limited field survey to evaluate accessible suspect building materials in the interior and exterior of the structures on the property and document the existing site conditions in those areas. Sampling was done with limited destructive methods.

Collect bulk samples of all accessible suspect building materials for laboratory testing to identify ACM or non-ACM.

Asbestos-Containing Materials (ACM)

Bulk sampling and analysis of suspect asbestos-containing materials (ACM).

Quantity estimates of ACM’s.

Written descriptions of bulk samples including drawing(s) with sample locations if applicable.

Written report including sample logs, descriptions and drawings if applicable.

Lead-Based Paints (LBP)

Paint chip samples to determine if Lead-Based Paint is present within the structure.

Prepare final written report including: Sample descriptions, condition, locations and analytical results.

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3.0 PROCEDURES

All persons participating in asbestos inspections have received training as detailed in the Asbestos Hazard Emergency Response Act (AHERA), 29 CFR Part 763 and are accredited asbestos building inspectors.

Sample locations for this survey were chosen in a random fashion, with emphasis being placed on obtaining samples of each type of accessible suspect material without destructive methods.

Samples that were not sampled due to the destructive methods required to sample should be assumed to contain asbestos. Samples were collected by carefully removing small portions of the suspect material in a non-abrasive manner. If possible, samples were collected from existing damaged areas. Immediately after collection, samples were placed in plastic containers.

Sample containers were then placed in a large re-sealable plastic bag for transportation to the laboratory. Data pertinent to each sample such as date, sample number, material description, and material condition was recorded on a field data sheet.

Asbestos bulk samples were sent under appropriate chain-of-custody procedures to NVL Labs, Inc. in Seattle, Washington for analysis. The samples were analyzed using polarized light microscopy (PLM)/dispersion staining techniques in accordance with U.S. EPA Method 600/R- 93/116. Detection limits for this type of analysis are approximately one percent by volume.

Materials containing one percent asbestos or more are considered to be asbestos-containing materials. NVL Labs, Inc. participates in the National Voluntary Laboratory Accreditation Program (NVLAP) for quality control procedures.

Laboratory analysis reports are attached.

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4.0 FIELD OBSERVATIONS

The QUL Radio Communications Control (QUL RCAG) building was inspected for suspect materials in Squaw Butte, Idaho. The structure was built in 1963, was approximately 608 square feet of space, and is comprised of an equipment room, an emergency generator, a radio communications link room and an interior entry way. The interior equipment room (approximately 448 square feet) consisted of 9” green vinyl tile with black mastic under carpet on concrete subfloor, CMU walls with a black cove base lining the base of the walls, and a wood ceiling. The emergency generator room (approximately 192 square feet) consisted of concrete floor, wood paneling ceiling, and CMU walls. The radio communications link room (approximately 208 square feet) consisted of carpeted concrete floor, wood ceiling, and CMU walls. Penetrations for cabling were found in the walls with grey penetration putty to seal areas. Heat source within the building was ceiling mounted Markair electric heaters and exterior mounted air conditioning units.

The exterior of the building has a CMU walls with aluminum siding, concrete slab, with a possible rubber membrane roof. No windows were identified in the structure.

Presumed Asbestos Containing Materials (PACM) building materials that will be impacted by any future renovation and/or demolition consist of Roofing Material (assumed), Vermiculite insulation inside CMU wall cavities (assumed), and Transite conduit that leads to towers.

Note: This report is meant only to inventory accessible asbestos containing materials at the site. Some suspect materials (i.e. roofing) were not sampled due to the severe destructive methods needed to determine if the material is present or not or completely inaccessible at the time of the inspection.

Suspect asbestos-containing materials within the structure were identified and classified as either a surfacing material, thermal system insulation, or miscellaneous materials. Surfacing materials are those, which are either spray applied or troweled-on for acoustical, decorative, or fireproofing purposes. Thermal system insulation (TSI) is insulation used to inhibit heat transfer or to prevent condensation on pipes, boilers, tanks, ducts and various other components. Miscellaneous materials include all other materials not included in the above categories such as floor tile, ceiling tile, roofing felt, cementitious materials, wallboard systems and products such as caulkings, mastics and putties.

A total of eleven (11) samples of suspect building materials were collected and submitted for PLM analysis. Three materials, Roofing Material, Vermiculite Insulation, Transite conduit is Presumed Asbestos Containing Materials (PACM) but were unable to confirm due to the destructive methods required to sample. Vermiculite insulation is generally found inside CMU walls, attacks and walls and is considered asbestos containing without PLM analysis. One (1) of the miscellaneous materials sampled was found to contain greater than 1% asbestos.

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5.0 ASBESTOS-CONTAINING MATERIALS (ACM) SURVEY NARRATIVE

Bulk samples collected were submitted for sample analysis in accordance with method EPA- 600/R-93/116: “Method for the Determination of Asbestos in Bulk building Materials”. Analyses were performed in NVL Labs, Inc. NVLAP Accredited Laboratory. Materials are positive for asbestos if they are found to contain >1% asbestos according to EPA.

OSHA considers materials that contain any amount of asbestos to be asbestos containing building materials and is covered under 29 CFR 1926.1101. The percentage of asbestos in the building materials determines what requirements must be followed.

Thermal Systems Insulation (TSI)

If during the course of wall, ceiling or floor disturbance activities, any additional thermal insulation materials that are not listed in this report are uncovered (i.e. pipe insulation, hard elbow insulation, tank insulation, packing materials around exhaust pipe, kitchen vents, etc.), work must be stopped immediately and sampling must be performed to determine if asbestos is present in the material found.

Surfacing Materials

If during the course of wall, ceiling or floor disturbance activities, any additional surfacing materials that are not listed in this report are uncovered (i.e. painted mud texture on interior/exterior walls, skim coatings, stucco texture, fire proofing, etc.), work must be stopped immediately and sampling must be performed to determine if asbestos is present in the material found.

Miscellaneous Materials

Approximately 678 square feet of suspect 9” green vinyl tile with associated mastic was identified in the equipment room and RCL room under carpeting. The material was found to contain 6% Chrysotile Asbestos in the 9” green vinyl tile and 3% Chrysotile Asbestos in the associated black mastic.

If during the course of wall, ceiling or floor disturbance activities, any additional miscellaneous materials that are not listed in this report are uncovered (i.e. under sub-flooring, inside interstitial spaces, above ceilings, etc.), work must be stopped immediately and the SECM should be contacted for further guidance.

Any work that disturbs asbestos containing building materials other than drilling through floor tiles must be performed by accredited workers or supervisors that have been trained according to EPA’s Model Asbestos MAP accreditation requirements. Please review all Operation and Maintenance (O&M) documents for this facility along with the District’s “Asbestos Management Plan” prior to any disturbance of building materials.

In addition, all work that involves disturbing building materials within any facility must follow all processes listed in FAA’s orders 1050.20A and 3900.57A.

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6.0 STATEMENT OF COMPLIANCE

In accordance with local, state and federal regulations, the Federal Aviation Administration had an asbestos survey performed of the structure referred to as the QUL RCAG located. All persons entering the facility should be notified of the presence and locations of asbestos containing materials. Should employees or contract personnel encounter any suspect materials it is their responsibility to:

1. Contact a representative of the owner.

2. Consult the inspection report to determine whether or not the suspect material contains asbestos.

3. If the suspect material does not appear in the inspection report, then that material was not sampled and must be presumed to contain asbestos until proven otherwise by sampling and PLM analysis.

4. Ensure that all employees and contractors are informed and advised of the location and type of materials that contain asbestos.

The following asbestos-containing materials were identified at the subject property:

9” Green Vinyl Tile and Associated Black Mastic

Vermiculite Insulation (assumed)

Roofing Material (assumed)

Underground Cement Piping Conduit to Towers(assumed)

If building materials that are not listed in this report are discovered then work should stop immediately and contact the SECM for further guidance.

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7.0 LEAD-BASED PAINT SURVEY SUMMARY

On September 14, 2014, Lance Kiblinger, Safety and Environmental Compliance Manager for the Federal Aviation Administration, performed limited lead-based paint sampling of the painted surfaces in the interior and exterior of QUL Radio Communications Control (QUL RCAG) facility located in Squaw Butte, Idaho. The sampling was performed by acquiring paint chip samples approximately 1 square inch in size. The samples were then submitted, under chain of custody to NVL Labs, Inc. in Seattle, Washington for analysis. The samples were analyzed using EPA method 7000b, Flame Atomic Absorption Spectrophotometry (AAS). All paint chip sample were found to contain levels of lead and should follow specific procedures when disturbing the paint at this facility.

Federal OSHA regulations have not established a safe level of lead in paint when lead in construction standards do not apply. Workers wearing respiratory protection and who have received proper training in the handling of lead contaminated or containing materials must be used for any construction activities (including manual scraping, manual/power sanding, heat gun applications, general clean up, and demolition/renovation) that affect a paint film containing lead.

EPA/HUD standards use a criterion of 5,000 parts per million (ppm) dry weight, 1.00 mg/cm² or 0.5% lead by weight for establishing a positive or negative for lead-based paint reporting when sampling for targeted housing, child occupied housing and government subsidized housing but does not apply within our facilities.

If the building is to be renovated or remodeled there are procedures regarding the disturbance or removal of the lead-based paints. (I.e. initial air monitoring, clearance sampling, negative exposure assessments, etc.). These requirements are referenced in OSHA’s 29 CFR 1926 “Safety and Health Regulations for Construction” and 29 CFR 1910.1025 “Occupational Safety and Health Standards”.

Prior to disposal, the waste stream generated from the renovation or demolition of all structures must be analyzed using EPA Method 1311 - Toxicity Characteristic Leachate Procedure (TCLP) - Lead by Atomic Absorption Spectrophotometry. Waste found to have leachability greater than or equal to 5 ppm must be disposed of as hazardous waste; waste with a leachability of less than 5 ppm may be disposed of as solid waste. Disposal requirements should follow all federal, State or local agency’s having jurisdiction where the work will be performed including but limited to EPA Code of Federal Regulations Title 40, “Protection of the Environment”.

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8.0 PCB BALLAST SUMMARY

Before the EPA banned the manufacture of polychlorinated biphenyls (PCBs) in 1978, they were used in the manufacture of fluorescent light ballast and electrical transformers. Some fluorescent light fixtures may contain ballast units, which are composed of a small transformer to reduce incoming voltage and a small capacitor which may contain PCBs. PCBs are a regulated dangerous waste and should be handled and disposed of as such.

Many state certified “Asbestos Abatement Contractors” are equipped to remove and dispose of light fixtures that have PCB containing ballasts.

Light fixtures manufactured without PCB ballasts were tagged with a Non-PCB sticker. Only light fixtures marked with this sticker can be assumed to contain No PCBs. All other light fixture ballasts must be treated as PCB containing. The only other way of determining whether or not ballast contains PCBs is to take down its pertinent information and call the manufacturer directly to inquire.

The following are the results of the inspection for PCB containing ballasts.

Not all light ballasts were checked during this inspection. Based on the age of the building all light fixtures should be checked prior to disposal. However, until all ballasts are inspected and identified as Non-PCB they should be treated as PCB containing.

The following is the count of light fixtures, ballasts, and fluorescent tubes in the facility inspected:

34 Light Fixtures

34 Ballasts

68 Fluorescent tubes.

APPENDIX A

ASBESTOS SAMPLE SUMMARY

Sample Number Material Description Laboratory Results

F3.1 Green 9" Vinyl Tile with Mastic under Carpet Mastic

Tile-6% Chrysotile Asbestos, Mastic-

3% Chrysotile Asbestos

M12.1 Black 4" Cove Base with Mastic ND

M16.1 Grey Penetration Putty ND

M12.2 Black 3" Cove Base with Mastic ND

M8.1 Caulking Around Exterior Door Frame ND

S1.1 Texture Paint on Exterior Walls/Foundation ND

M16.2 Penetration Putty on Exterior Wall ND

PACM Vermiculite Insulation PACM

PACM Roofing Material PACM

PACM Undergraound Cement Piping Conduit to Towers PACM

NS = Material Not Sampled

ND = No Asbestos Detected

PACM = Presumed Asbestos Containing Material

Squaw Butte, Idaho

TABLE 1

SUMMARY OF MATERIALS SUSPECTED TO CONTAIN ASBESTOS

QUL RCAG

APPENDIX B

LEAD-BASED PAINT SAMPLE SUMMARY

L1.1 Interior Wall CMU White 0.0840 Yes

L1.2 EG Room Floor Concrete Grey 0.2400 Yes

L1.3 Interior Door Frame Metal Grey 0.5600 Yes

L2.1 Exterior Wall CMU White <0.0050 No

L2.2 Exterior Vent Metal Grey 0.5100 Yes

TABLE 3

IDENTIFIED PAINTED BUILDING COMPONENTS and ANALISYS RESULTS

QUL RCAG

Squaw Butte, Idaho

Lead Containing

Paint (Y/N) Results in %Paint ColorSubstrateBuilding Component

Sample

Number

Identified Materials and XRF Screening Results Page 1 of 2 Table 3

APPENDIX C

LABORATORY ANALYSIS DATA SHEETS

APPENDIX D

SAMPLE LOCATION DRAWING

APPENDIX E

INSPECTOR CERTIFICATIONS