FAA-QOO HAZMAT Report 01172023.2.pdf

January 17, 2023

Re: Limited Asbestos and Lead-Containing Paint Survey Letter Report

FAA-QOO

5213 US Highway 277 Anson, Tx 79501 Parson Project No: 748785-07530

Parsons conducted a limited asbestos and lead-containing paint survey at the FAA-QOO site located at 5213 Highway 277, Anson, Texas. Our scope of services included the collection of bulk samples of client identified suspect asbestos-containing materials (ACM) and lead-containing paint. The survey was limited to interior and exterior areas of the structure that may be impacted during planned construction activities.

LIMITED ASBESTOS SURVEY

Project Information The limited asbestos survey was performed in compliance with the United States Environmental Protection Agency (USEPA) regulation 40 CFR 61, Subpart M, National Emission Standards for Hazardous Air Pollutants (NESHAP) and Texas Department of Health and Human Services, prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities.

The asbestos NESHAP requires that potentially regulated asbestos-containing building materials be identified, classified, and quantified prior to planned disturbances or demolition/renovation activities.

Field Activities The limited asbestos survey was performed on January 5, 2023, by Mr. Don Pippin, AHERA accredited asbestos building inspector (Accreditation No. 189812). A copy of the inspector’s AHERA accreditation is included in the Attachment C.

Our survey activities began with visual observation of interior and exterior building materials to identify homogeneous areas of suspect ACM. A homogeneous area consists of building materials that appear similar throughout in terms of color and texture, with consideration given to the date of application.

The assessment was limited to client identified areas to be impacted by planned equipment installation activities. Building materials identified as glass, wood, metal, or rubber were not considered suspect ACM.

A physical assessment of each homogeneous area of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the USEPA as a material that can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

Based on results of the visual observation, bulk samples of suspect ACM were collected in general accordance with EPA regulation 40 CFR 763, the Asbestos Hazard Emergency Response Act (AHERA). Random samples of suspect materials were collected in each homogeneous area. The inspector collected bulk samples using wet methods as applicable, to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.

Forty-seven asbestos bulk samples were collected from homogeneous areas of suspect ACM.

Bulk samples were submitted under chain of custody to EMSL Analytical, Inc. (EMSL) of Houston, Texas for analysis by polarized light microscopy with dispersion staining techniques per USEPA’s Method for the Determination of Asbestos in Bulk Building Materials (600/R-93-116).

EMSL is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP Accreditation No. 102106-0-0).

Regulatory Overview The State of Texas utilizes the Department of Health and Human Services to regulate and enforce asbestos-related activity within the state. TDHS requires that all individual or company performing an asbestos-related abatements be accredited or licensed by the State of Texas, through the TDHS. The State requires each owner or operator of a demolition or renovation activity to notify at least 10 working days before asbestos stripping or removal work or any other activity begins that would break up, dislodge, or similarly disturb asbestos material. An asbestos-related activity consists of the disturbance (whether intentional or unintentional) or abatement of ACM, the performance of asbestos surveys, the development of management plans, asbestos project design, monitoring for airborne asbestos.

The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos NESHAP regulation also requires the identification and classification of existing ACM according to friability prior to demolition or renovation activity. Friable ACM is a material containing more than 1% asbestos that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. All friable ACM is considered regulated asbestos containing material (RACM).

The asbestos NESHAP regulation classifies ACM as either RACM, Category I non-friable ACM or Category II non-friable ACM. RACM includes all friable ACM, along with Category I and Category II non-friable ACM that has become friable, will be or has been subjected to sanding, grinding, cutting or abrading, or ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity. Category I non-friable ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II non-friable ACM and all other non-friable materials other than Category I non-friable ACM that contain more than 1% asbestos. Category II non-friable ACM generally includes but is not limited to cementitious material such as: cement pipes, cement siding, cement panels, glazing, mortar, and grouts.

The United States Occupational Safety and Health Administration (USOSHA) asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The USOSHA standard requires that employee exposure to airborne asbestos must not exceed 0.1 fibers per cubic centimeter of air (0.1 f/cc) as an eight-hour time weighted average (TWA) and not exceed 1.0 fibers per cubic centimeter of air (1.0 f/cc) over a 30-minute time-period known as an excursion limit (EL).

The TWA and EL are known as USOSHA’s asbestos permissible exposure limits (PELs). The USOSHA standard classifies construction and maintenance activities which could disturb ACM, and specifies work practices and precautions which employers must follow when engaging in each class of regulated work.

The State of Texas utilizes the TDHS to regulate and enforce asbestos-related activity within the state.

The state requires that an inspection be conducted by a person currently accredited as an AHERA asbestos inspector.

Texas Department of Health and Human Services NESHAP form is required to be submitted to the state 10 days prior to commencing demolition activities or any renovation activity, including asbestos abatement, affecting at least 160 square feet, 260 linear feet, or 35 cubic feet of regulated asbestos containing material. The form should be completed and signed by authorized site personnel and submitted to the State 10 days prior to the implementation of proposed renovation or demolition activities at the site.

Findings A summary of suspect ACM samples collected, and laboratory analytical results are included below in Table 1.

Table 1 – Summary of Asbestos Content in Bulk Materials

HA

Sample Number

Material Description

Material Location

Condition Lab Results

1-1 Blue Floor Tile and Yellow

Mastic Under Carpet

Equipment Shelter Good

None Detected

1-2 None Detected

1-3 None Detected

2-1

Wall/Ceiling Texture Equipment

Shelter Good

None Detected

2-2 None Detected

2-3 None Detected

3-1 Tan Baseboard

Mastic Equipment Shelter

Good

None Detected

3-2 None Detected

3-3 None Detected

4-1 Cream Floor Tile and Yellow Mastic Under Carpet

Equipment Building Good

None Detected

4-2 None Detected

4-3 None Detected

5-1 Brown Baseboard and Tan Mastic

Equipment Building

Good

None Detected

5-2 None Detected

5-3 None Detected

6-1

Exterior Duct Caulking

Good

None Detected

6-2 None Detected

6-3 None Detected

7-1 Insulation on

Outside Water Line

Equipment Building Good

None Detected

7-2 None Detected

7-3 None Detected

HA SampHAle Number

SamMatpleerialHA NDuemscbreiprtion Des

MatSaeriMatalmplere criNptiuLomonbcearti alHA MatCMatondiSaerermitaliialplHAone CondSamiMapltteiM n

D L i tii D L i

HA Sample Number

Material Description

Material Location

Condition Lab Results

8-1

12" Cream Floor Tile and Mastic

Engine Generator Building

Good

None Detected

8-2 None Detected

8-3 None Detected

9-1 Black Baseboard and Tan Mastic

Engine Generator Building

Good None Detected

9-2 None Detected

9-3 None Detected

Recommendations

Asbestos was detected in zero collected and analyzed as part of our sampling at this site.

It should be noted that suspect materials, other than those included and identified during this survey may exist within the structures or in the survey area. Should suspect materials other than those which were identified and sampled during this survey be uncovered during restoration activities, the material(s) must be assumed to contain asbestos and treated as such unless sampled by an accredited inspector and laboratory analysis determines otherwise.

LIMITED LEAD-CONTAINING PAINT SURVEY

Project Information

The limited lead-containing paint survey of the structure was performed utilizing paint chip bulk sampling techniques to identify lead concentrations in various painted surfaces. Lead is regulated by the USEPA and the United States Occupational Safety and Health Administration (OSHA). As such, lead safe work practices will be required if lead paints are identified.

USEPA regulations would also apply for disposal of lead-containing demolition waste. All occupational exposure to lead occurring, in the course of construction work, including renovation activities, painting, alteration and repairs is subject to the OSHA lead standard (29 CFR 1926.62).

Field Activities

The limited lead-containing paint survey included an evaluation of painted surfaces that may be impacted during the planned construction activities utilizing paint chip sampling techniques.

Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker. Parsons collected eighteen paint chip samples.

Bulk paint chips were collected from various surfaces/components and were submitted under chain of custody to EMSL Analytical, Inc. (EMSL) of Houston, Texas for lead analysis by USEPA SW-846 Methods 3050B Acid Digestion of Sediments, Sludges, and Soils and 7000B Flame Atomic Absorption Spectrophotometry. EMSL is accredited by the Environmental Lead Laboratory Accreditation Program (ELLAP Certificate Number 102575).

Findings

A summary of suspect lead-containing paint chip samples collected, and laboratory analytical results are included below in Table 2.

Table 2 – Lead-Containing Paint Sample Summary

Sample Number

Color Substrate Component Lead Concentration (Lead by %weight)

P-1 Brown Metal Equipment Shelter Door and Frame

<0.016

P-2 White Metal Equipment Shelter Column

<<0.100

P-3 Brown Stucco Equipment Shelter- Outside Base

<0.018

P-4 Green Metal Equipment Building Door

0.133

P-5 White Metal Equipment Building Wall 0.025

Sample Number

Color Substrate Component Lead Concentration (Lead by %weight)

P-6 White Metal Equipment Building Inside Duct

0.034

P-7 White Metal Equipment Building Door 0.048

P-8 White Metal Equipment Building Metal Siding

<0.0098

P-9 White Metal Equipment Building Exterior Door/Frame

00.076

P-10 White Metal Equipment Building Exterior Duct

<0.016

P-11 Cream Metal Equipment Generator Building Door/Frame

<<0.27

P-12 White Metal Equipment Generator Building Wall

<0.0094

P-13 Gray Metal Equipment Generator Building Door/Frame

<0.015

P-14 Yellow Metal Equipment Generator Building Pipe Frame Around Diesel

Tank

<<0.078

P-15 White Metal Equipment Generator Building Diesel Tank

<0.043

P-16 Red Concrete Equipment Generator Building Concrete Bollard

<0.024

P-17 White Concrete Equipment Generator Building Concrete Bollard

<0.028

P-18 White Metal Metal Storage Building Door/Siding

<<0.12

P-19 Red Metal Metal Storage Building Rafter 00.12

P-20 Gray Concrete Metal Storage Building Floor <0.0080

P-21 White Wood Metal Storage Building Table/Shelves

<0.023

P-22 Red Metal Radome Tower Columns/Girders

77.0

P-23 Red Metal Radome Tower Stairs 88.0

P-24 White Metal Radome Tower Stairs 00.72

P-25 Red Metal Radome Tower Frame Under Tower

44.1

The analytical results for lead ranged from <0.0080 to 8% lead by weight (wt). Eleven of the samples collected are identified as lead-containing paint.

Recommendations

OSHA does not define lead-containing coatings. Any detectable level of lead presents a potential source of exposure depending on how the material is disturbed. Therefore, Parsons recommends that potential contractors are made aware of the findings of this limited lead-containing paint survey.

Personnel and/or contractors should utilize work practices pursuant to the OSHA lead standard (29 CFR 1926.62) when impacting lead-containing components. The full OSHA lead standard should be referenced forcompliance.

GENERAL COMMENTS

This limited asbestos and lead-containing paint survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions, and recommendations expressed in this report are based on conditions observed during the limited asbestos survey. This letter report has been prepared on behalf of and exclusively for use and reliance by the Client. This report is not a bidding document. Contractors or consultants reviewing this limited sampling report must draw their own conclusions regarding further investigation or remediation deemed necessary. Parsons does not warrant the work of regulatory agencies, laboratories or other third parties supplying information, which may have been used in the preparation of this report. No warranty, express or implied is made.

Parsons appreciates the opportunity to provide this service. If you have any questions regarding this report, please contact the undersigned.

Sincerely, Don Pippin

Attachments:

Laboratory Analytical Reports Certifications Drawings

Sensitive

ATTACHMENT A

LABORATORY ANALYTICALREPORTS

851 E I-65 Service Road South, Suite 704 Mobile, Alabama 36606 (251) 243-9841 Fax: (251) 471-2341

ATTACHMENT B

Drawings

851 E I-65 Service Road South, Suite 704 Mobile, Alabama 36606 (251) 243-9841 Fax: (251) 471-2341

ATTACHMENT C

Certification