Hazardous_Mat'ls_Survey_for_PREBID.pdf

Final Report

COMPREHENSIVE HAZARDOUS MATERIALS

SURVEY REPORT

NATIONAL AERONAUTICS AND SPACE

ADMINISTRAION (NASA)

4800 LILLY AVENUE,

EDWARDS, CA

AEG Project No. 2K16016

Prepared for:

NASA

Mr. Robert Callahan

4800 Lilly Avenue Edwards, CA 93523

Prepared by:

Advanced Environmental Group, Inc.

1530 Via Tulipan San Clemente, California 92673

February 17, 2017

TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................................................................ I

1.0 INTRODUCTION

2.0 SCOPE OF WORK AND LIMITATIONS

2.1 SCOPE OF WORK

2.2 LIMITATIONS

3.0 SAMPLING PROCEDURES AND ANALYTICAL METHOD

3.1 BULK SAMPLING PROCEDURE

3.1.1 Bulk Sample Analysis – Asbestos

3.1.2 Bulk Sample Analysis – Lead

3.2 LEAD PAINT ANALYZER

3.3 METHOD OF TESTING AND PROTOCOL

4.0 SUMMARY OF MATERIALS EVALUATED

4.1 ASBESTOS

4.2 LEAD XRF AND PAINT CHIP

5.0 REGULATIONS

5.1 ASBESTOS

5.2 LEAD

6.0 DISCUSSION

6.1 ASBESTOS

6.2 LEAD

7.0 CONCLUSIONS AND RECOMMENDATIONS

7.1 ASBESTOS

7.2 LEAD

8.0 ENGINEERING COST ESTIMATE

FIGURES 1 - 22

TABLE 1 SUMMARY OF HOMOGENEOUS BUILDING MATERIAL AREAS EVALUATED

TABLE 2 SUMMARY OF XRF MEASUREMENTS

TABLE 3 SUMMARY OF BULK LEAD ANALYSIS

APPENDIX A FINAL INSPECTION REPORT FOR BUILDING 4822

APPENDIX B LABORATORY ANALYTICAL RESULTS – BULK ASBESTOS

APPENDIX C LABORATORY ANALYTICAL RESULTS – BULK LEAD

APPENDIX D CHECKLIST FOR ASBESTOS HAZARD ASSESSMENT FORMS

APPENDIX E PHOTOGRAPHS

APPENDIX F POTENTIAL DISTURBANCE FACTORS

APPENDIX G CLASSIFICATION OF HAZARD POTENTIAL

APPENDIX H PRIORITY RESPONSE ACTIONS

APPENDIX I XRF PRINTOUT

APPENDIX J ENGINEERING COST ESTIMATES

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EXECUTIVE SUMMARY

Advanced Environmental Group, Inc. (AEG) was retained by the National Aeronautics and Space Administration (NASA)/Armstrong Flight Research Center (AFRC) on September 12, 2016 to conduct a limited asbestos and lead survey of building 4822 specifically the northern two-thirds followed by a tank berm area, emergency back-up generators/fuel tanks, and building/structures: 4990, 4985, 4835A, 4838 1ST and 2ND floor mechanical rooms, 4832, 4874, 4875 A & B, NB-121, 4803, 4806, 4805, T-20, 4807, 4808, 4809 and 4850 all located on the

AFRC campus at 4800 Lilly Avenue, Edwards, CA. The survey was conducted over 16 days from

October 3 – 6, 11 – 13, 17 – 21, and, 24 – 27, 2016. A separate report dated October 21, 2016 was prepared for Building 4822 and is presented in Appendix A. Building 4822 results are not included in this report.

This Executive Summary is provided solely for the purpose of overview. Any party who relies on this report must read the entire report. The Executive Summary may have omitted important details, anyone of which could be crucial to proper understanding and risk assessment of the subject matter.

The remaining body of this report elaborates upon these salient items with details relative to the management of asbestos-containing building materials (ACBM), paint coatings and other building materials containing lead.

Asbestos

AEG identified homogeneous building materials, which were suspected of containing asbestos. Homogeneous areas for bulk sampling purposes are areas one that seems by texture, color, and wear to be uniform and applied during the same general time period. After the homogeneous areas, had been identified, representative bulk samples were collected for laboratory analysis.

Because ACBM have compositional variability, it is possible to obtain different laboratory results for samples from the same homogeneous area. Therefore, a homogeneous area with at

2K16016 ii least one positive sample for asbestos will result in the entire homogeneous area being designated as an asbestos-containing material (ACM).

ACBM are categorized into surfacing ACM, thermal system insulation (TSI) ACM, or miscellaneous ACM that is found in a building. In addition, the condition, approximate quantities and whether ACBM is friable or non-friable ACM was determined during the survey. Friable asbestos material means any material containing more than 1 percent asbestos as determined using the method specified in Appendix E, subpart E, 40 CFR part 763 section 1, Polarized Light

Microscopy, that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

AEG identified a total of 135 homogeneous building materials following a visual inspection of interior and or exteriors of 22 structures (not including Building 4822), forty-three (43) of which were identified as ACBM. Asbestos bulk sample results are presented in Table 1 and Appendix

B. The homogeneous area is summarized hereafter in three action item groups.

GROUP A - IMMEDIATE INTERDICTION / ABATEMENT

(Regulated Carcinogen Spill, Highly Deteriorated Materials) The following areas contain materials either in highly deteriorated condition, or have been disturbed to the extent that ACBM has been spilled onto building, equipment or environmental surfaces; it is recommended that immediate interdiction of potential personal exposure be implemented, and the contamination be abated immediately by removing it under contract with an asbestos abatement contractor registered with the State of California, Department of Industrial Relations/Division of Occupational Safety and Health (DIR/DOSH) Carcinogen Control Unit, with third-party industrial hygiene site supervision to assure maximal limitation of liability.

Building 4806

White drywall and joint compound running north and south on the west side of the building. There is approximately 2825 square feet of material, which is in fair condition.

Broken piece of drywall on the south side of building to be removed and repaired.

Building 4809

Hard pack elbows (TSI) on 2" dia. hot water line running N S within Garage RM 14 north side adj. to Woman's Restroom RM 12 running south to Telecom room adj. to RM 27. There are approximately 9 – 4” dia. elbows, which are in good condition except one elbow in Telecom room adj. to Room 27 is in poor condition to be removed or repaired.

GROUP B - ADDITIONAL ANALYTICAL SURVEILLANCE

(Required to Validate Inconclusive and or Irregular Results)

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The following areas contain materials which when sampled produced analytical results which were inconclusive, or non-replicated in comparative samples; it is recommended that the materials be re-sampled to adequately characterize the material.

None reported

GROUP C - CONVENTIONAL PROCEDURES

(Regulatory Notification / Periodic Surveys / Operations & Management Plan) The following materials, which appear to retain their structural integrity, either contained ACBM or PACM, which if left undisturbed may not create an exposure. These materials are in conformance with State of California carcinogen regulations, but will require periodic survey and notification of possibly exposed persons/employees. If the structure is occupied without full abatement of the materials, Operations and Management Plans should be development and implemented including periodic visual inspection and area air monitoring. Mandatory ACM property conveyance regulations would also apply if property ownership changes.

Building 4990

12" x 12" Light Beige floor tile located Interior - Switch Room - Floors - North side;

South side; Southwest corner; middle at cabinet. There is approximately 850 square feet of material, which is in good condition.

Black mastic located on the roof of the exterior structure. There is approximately 114 square feet of material, which is in good condition.

Building 4985

Black mastic located on the roof of the exterior structure. There is approximately 1550

Building 4838A

Black mastic, rolled felt and asphalt on the roof. There is approximately 700 square

Gasket at metal flange located on rooftop. There is approximately 2 square feet of material, which is in good condition.

Gasket on 10” diameter pipe flange located within interior room. There is approximately 2 square feet of material, which is in good condition.

Building 4838

Gaskets on exposed flanges located within 1ST floor mechanical room. There is

Building 4832

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White caulking at base of building and along the exterior foundation. There is approximately 400 linear feet of material, which is in good condition.

12” x 12” Beige streak floor tile with a second layer below located within Men’s Bathroom; Janitor’s closet; and, Women’s bathroom. There is approximately 200

Brown mastic behind 4" Brown Top set coving located within the Men’s Bathroom;

Janitor’s closet; and, Women’s bathroom. There is approximately 60 linear feet of

White joint compound within the Men’s Bathroom; Janitor’s closet; Women’s bathroom. There is approximately 705 square feet of material, which is in good condition.

Building 4875 A & B

Grey white Caulking at penetration on wall of Building 4875 A. There is approximately 3 square feet of material, which is in good condition.

Black mastic on rooftop of Building 4875 B. There is approximately 5 square feet of

Building 4803

White caulking at exterior window; door; and shed siding. There is approximately 50 linear feet of material, which is in good condition.

Grey mastic at exterior wall penetration; Roof – Catwalk; and, air handling units. There is approximately 75 linear feet of material, which is in good condition.

Black mastic at vent penetration on the roof. There is approximately 15 linear feet of

Grey joint compound on the Office walls. There is approximately 180 square feet of

White wrap on fire sprinkler pipe within the Hydro Shop. There is approximately 10 square feet of material, which is in fair condition.

White window putty on interior surfaces. There is approximately 6 square feet of

Hard packed elbows, thermal system insulation (TSI) on ½” dia. hot water line running through Battery Recharge; Main area outside men’s restroom; and, crawl space north room. There are approximately 16 elbows, which are in good condition.

Hard packed insulation/TSI on ½” dia. cold water line running through Battery Recharge; adjacent to office; Main area T-fitting; and, crawl space north room. There is approximately 280 linear feet of this material, which is in good condition.

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12” X 12” Beige and brown speckled floor tile/Black and Tan Mastic within the Office area. There is approximately 210 square feet of this material, which is in good

White putty at the exterior corrugated metal paneling vertical seams. There is approximately 2912 linear feet of this material, which is in good condition.

Black mastic at roof penetrations beneath elastomeric/foam coating. There is approximately 60 square feet of this material, which is in good condition.

Grey mastic on building exterior. There is approximately 5 square feet of this material, which is in good condition.

Building 4805

Black mastic on roof. There is approximately 10 square feet of material, which is in good condition.

Building T-20

Off-white and black mastic on roof. There is approximately 15 square feet of material, White putty at roof penetrations. There is approximately 1 square foot of material, Building 4807

Gasket on forced air heater located within the Storage area. There is approximately 5

Grey window putty on interior surfaces. There is approximately 8 square feet of

White/grey putty at the exterior corrugated metal paneling vertical seams. There is approximately 1691 linear feet of this material, which is in good condition.

TSI hard pack elbows on ½” diameter piping located above drop ceiling within the Life Support work area. There are approximately 8 elbows, which are in good condition.

12” X 12” blue floor tiles over 9” X 9” green floor tiles/Black and Tan Mastic within the Life Support work area. There is approximately 1392 square feet of this material, which is in good condition.

approximately 30 square feet of this material, which is in good condition.

Building 4808

White window putty on interior surfaces. There is approximately 432 linear feet of

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12” X 12” beige floor tiles/Black Mastic within the women’s restroom located in the southeast corner of the warehouse area. There is approximately 100 square feet of this material, which is in good condition.

White drywall and joint compound within the women’s restroom located in the southeast corner of the warehouse area. There is approximately 580 square feet of material, which is in fair condition.

12" X 12" Beige with brown and white striations floor tile/black mastic at entry vestibule flooring located within the CMU Office. There is approximately 48 square feet of

12" X 12" Light beige with tan and white striations floor tile/black mastic at corridor flooring located within the CMU Office. There is approximately 96 square feet of

9" X 9" Taupe with striations floor tile/black mastic at corridor/hallway running north south and Room 10 located within the CMU Office. There is approximately 317 square

12" X 12" Off-white textured floor tile at Room 6 lunch room and parts located within the CMU Office. There is approximately 1294 square feet of material, which is in good

Joint compound and skimcoat within the CMU office area. There is approximately 6376

12" X 12" Beige marble-like peel n stick floor tile/black mastic within Room 11 within the CMU Office area. There is approximately 132 square feet of material, which is in

Drywall, Tape Joint Compound Knockdown Finish within the CMU Office, RM 11.

There is approximately 356 square feet of material, which is in good condition.

Drywall, Tape, Joint Compound unfinished within the Garage area above RM 14 covering a wall gap on the west side 12" wide. There is approximately 60 square feet of material, which is in good condition.

Vermiculite insulation (TSI) noted within hollow cells of CMU of the newer building addition south end. Very small amount of approximately 1.2 cubic feet within 28 hollow cells.

The Eastern Kern Air Pollution Control District (EKAPCD) District Rule 423, requires owners of buildings and or their contractors to make notification to the State and or Environmental

Protection Agency (EPA) Regional Office prior to all demolition or renovation of facilities where asbestos material will be disturbed. Notification must be postmarked at least ten working days

2K16016 vii prior to the start of any demolition or renovation activity that will disturb asbestos. Notification is mandatory for building demolition; and, renovation jobs which involve the disturbance of friable or regulated asbestos containing material (RACM) meeting or exceeding the minimum of 260 linear feet; 160 square feet; or 35 cubic feet. An asbestos removal fee is paid along with the notification in accordance with District Rule 306.

Lead

AEG conducted a LBP survey in accordance with Unites States Environmental Protection

Agency (EPA), State of California, Department of Public Health (CDPH) and Housing and Urban

Development (HUD) LBP risk assessment guidelines. This document is prepared for the sole use of the property owner. The scope of service, property description, inspector’s qualifications, method of testing and protocols, results and inspectors’ limitation are presented below.

The purpose of this risk assessment was to identify and assess if any LBP was present on the painted components. Painted components consisted of accessible interior and exterior painted or coated surfaces, including safety bollards, enclosures, tanks, cabinets, paint striping, other floor markings, wash basins/sinks, ceramic tiles, and T-Bar grid framework.

To comply with EPA, CDPH and HUD lead inspection guidelines; interior and exterior painted and varnished surfaces were tested for the presence of LBP with a Heuresis PB200i X-ray fluorescence (XRF) Lead Paint Analyzer. The intent was to ascertain the presence of LBP above specified action level of 1.0 mg/cm2 set by U.S. EPA and State of California Department of

Health Services.

In addition to 1005 XRF measurements, a total of eleven (10) paint samples were collected from the identified 22 structures where paint damage e.g. peeling or flaking was noted. The samples were submitted to Forensic Analytical Laboratories, which were analyzed for the presence of lead. XRF and paint chip Lead results are presented in Tables 2, 3 and Appendix C.

XRF measurements ranged from 0.0 to 22.8 mg/cm2. A leaded pipe joint and a lead door stop at

Building 4806 were measured at 20.1 and 54 mg/cm2, respectively. The analyzed paint samples collected from damaged paints ranged from < 0.002 to 12 % or <20 to 120,000 PPM.

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California Department of Public Health (CDPH) regulates Lead under Title 17 CCR

Division 1, Chapter 8 §35001 - §36100. This rule applies to firms and individuals conducting regulated lead abatement activities at target housing, childcare facilities and contract documents specifying certified abatement activities. Since lead was reported above detection within certain areas that may be remediated or renovated in the future, Title 17 reporting requirements will apply.

DOSH does regulate lead in California (NASA/AFRC may fall under Federal OSHA) whenever present in materials handled while performing specific tasks within Construction and or General

Industry under the following standards:

Title 8 CCR 1532.1 (Lead Construction);

Title 8 CCR 5198 (Lead General Industry);

These regulations address potential employee exposures when performing construction work on surfaces specifically containing lead. Potential exposure to lead may occur when performing work, referred to as trigger tasks, that create airborne particulates or fumes (such as sawing, sanding, torch cutting, etc.), or during handling of the waste materials.

If performing construction work on such materials, the CFRs requires initial exposure assessment (air monitoring) of employees to determine potential exposure. Until it is demonstrated that levels of airborne dust or fumes will not exceed the action limit of each specific metal, the use of personal protective equipment, including NIOSH approved respirators and

Tyvek, should be used. In addition, a work clothing change area, hand washing facilities, biological monitoring (blood lead and zinc protoporphyrin levels), and awareness level training

Title 8 CCR 1532.1 (l) (1) (A) should be provided during work involving disturbance of lead containing paints or other materials.

Where Lead levels exceed regulatory guidelines, disposal of demolition waste as construction debris may not be exempt.

2K16016 1

1.0 INTRODUCTION

On October 3, 2016, AEG conducted a limited building survey of building 4822 specifically the northern two-thirds followed by a tank berm area, emergency back-up generators/fuel tanks, and building/structures: 4990, 4985, 4835A, 4838 1ST and 2ND floor mechanical rooms, 4832, 4874, 4875 A & B, NB-121, 4803, 4806, 4805, T-20, 4807, 4808, 4809 and 4850 all sited on the

National Aeronautics and Space Administration (NASA)/Armstrong Flight Research Center

(AFRC) campus located at 4800 Lilly Avenue, Edwards, CA. The field survey was conducted over 16 days from October 3 – 6, 11 – 13, 17 – 21, and, 24 – 27, 2016, at the request of Mr.

Robert Callahan, Project Manager with NASA/ARFC Facilities. A separate report dated October

21, 2016 was prepared for Building 4822 and is presented in Appendix A. Building 4822 results are not included in this report. The purpose of the survey was to characterize potentially hazardous building materials scheduled for demolition and renovation activities. Asbestos containing building materials (ACBM), and lead containing paint coatings in areas that would be disturbed during renovation activities, were the focus of this survey. AEG collected bulk samples for subsequent asbestos and lead determination as well as XRF Lead Paint Analyzer measurements.

The survey was performed by Mr. Lev Michaelian, Certified Industrial Hygienist (CIH)

Certification Number 2415/Certified Asbestos Consultant, (CAC) DOSH Certification Number 93-

0913, Matthew Michaelian, CAC DOSH Certification Number 16-5628, California Department of

Public Health (CDPH) Sampling Technician Certification Number 136179; Ms. Linda Cassidy, CDPH Lead Inspector/Assessor Certification Number 1762; and, Mr. Neil Connolly, Certified Site

Surveillance Technician (CSST) DOSH Certification Number 11-4723.

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2.0 SCOPE OF WORK AND LIMITATIONS

2.1 Scope of Work

Conduct a survey to assess the existence of friable and non-friable ACBM, lead in paint coatings and ceramic tile;

Provide laboratory analysis utilizing Polarized Light Microscopy (PLM) for asbestos and, Atomic Absorption (AA) for lead in bulk samples; and

Provide a report to include comments on disturbance of any ACM, lead discovered, location of such materials, discussion, and conclusion.

2.2 Limitations

Recommendations and conclusions contained in this report are based on evaluation of technical information which was made available and reviewed during the course of this survey.

Our work product and judgments rendered meet or exceed the standard of care of our profession at this time. The number of samples taken from a construction material depended upon the amount present, its friability and accessibility, as well as the professional judgment of the inspector conducting the survey. No other warranty is made, expressed or implied. All quantities are approximates only and should not be used for bidding purposes. Contractor shall confirm quantities in the field.

Note: No sub-grade investigations were conducted for waterproofing materials, utilities or other materials which may contain asbestos. If the abovementioned materials or any other inaccessible, untested suspect materials (e.g. concrete) are encountered, they should be tested as asbestos containing materials and not disturbed, unless sampling and analysis of the materials proves otherwise.

Evaluations of the relative risk of exposure to lead identified during this inspection are based on conditions observed at the time of the inspections. AEG cannot be responsible for changing conditions that may alter relative exposure risk or for future changes in accepted methodology.

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3.0 SAMPLING PROCEDURES AND ANALYTICAL METHOD

3.1 Bulk Sampling Procedure

Samples were obtained from representative areas which were accessible. Field data and hazard assessments were documented in field notes Appendix D and photos see Appendix E.

The following guidelines would be used for sample collection and are designed to minimize both damage to the ACBM and paint coatings and subsequent fiber release or paint chipping.

The surface of the materials to be sampled were wetted with an amended water mist from a spray bottle;

Bulk samples of suspect materials were collected and transferred to a single-use sample container such as 25 millimeter (mm) plastic vial or sealable plastic bag;

When applicable, samples were collected down to the substrate to assure that all layers of the material were penetrated;

The container was labeled with the unique sample identification (ID) number; and

After use, all equipment was cleaned to prevent cross-contamination using wet towels, and debris was discarded in double plastic bags.

3.1.1 Bulk Sample Analysis – Asbestos

Samples collected were submitted to Forensic Analytical Laboratories of Rancho

Dominquez, California and were examined by Polarized Light Microscopy (PLM) in accordance with EPA Test Method 600/M4-82-020, "Area Estimation Method". The percentage of asbestos is determined by visual estimation. Laboratory results are reported based on the percentage of asbestiform minerals identified within each sample layer. The lower limit of reliable detection by

PLM is 1 percent by volume. When asbestos or other minerals are observed in concentrations believed to be less than the reliable detection limit (less than 1 percent) the results are usually indicated as TRACE. Asbestos National Emissions Standard for Hazardous Air Pollutants

(NESHAP) 400-point count analysis is performed on friable ACM samples reported Trace – ≤10%

(asbestos by volume), for a more reliable detection limit. Furthermore, samples reported at 1%

(asbestos by weight) may require a 1000-point count analysis to achieve a reporting limit of 0.1%

(asbestos by weight) depending on regulatory jurisdiction. Upon analysis, the analytical results

2K16016 4 are compared to government agency standards.

Currently, both the California Occupational Safety and Health Administration (Cal/OSHA) and the Environmental Protection Agency (EPA) define material which contains more than one percent asbestos to be an asbestos containing material (ACM). In addition, Cal/OSHA defines any manufactured construction material containing more than 0.1 % by weight as asbestos containing construction materials (ACCM). Cal/OSHA also requires notification and registration of the contractor when disturbing materials with more than one-tenth of one percent and regulates worker protection whenever materials containing any detectable levels of asbestos are to be disturbed.

3.1.2 Bulk Sample Analysis – Lead

Samples collected were submitted to Forensic Analytical Laboratories of Rancho

Dominguez, California for lead analysis. Analysis was performed according to EPA Methods

3050B/6010B by inductively coupled plasma (ICP). Quality control samples included method blanks, spiked matrix samples, matrix matched National Institute of Standards and Technology

(NIST) external standards, and matrix matched NIST traceable internal standards.

3.2 Lead Paint Analyzer

Heuresis PB200i X-ray fluorescence (XRF) Lead Paint Analyzer uses a thermoelectrically-cooled, CdTe diode detector with a 57Co sealed radioactive source, 5mCi (185 MBq). The XRF analysis is performed when a sample is excited by high–energy photons (x-rays) and the sample’s approximate elemental chemistry is determined nondestructively and rapidly by measuring the characteristic fluorescent x–rays emitted by Lead in the sample.

Positive or negative determination at 1.0 mg lead/cm2 with 2–sigma confidence with a measurement time of 1-3 nominal seconds on most lead paint samples. Detects lead at

0.1mg/cm2 with 2-sigma confidence with a measurement time of 1 second on most samples. The

XRF is calibrated before and during the day by reading a reference sample. The calibration check limit range is 0.8 to 1.2 mg/cm2 (inclusive).

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3.3 Method of Testing and Protocol

LBP testing and sampling was conducted in accordance with the EPA, DHS, and HUD

Guidelines. A hand-held XRF instrument, PB200i XRF Lead Paint Analyzer, manufactured by

Heuresis Corporation, Serial Number 1206, Radioisotope 57Co Source model A3901-2, Source number N7-688 manufactured by Eckert & Ziegler was used. The instrument source was last leak tested on August 3, 2016 (< 0.005 mCi). The instrument was calibrated to a National Institute of

Standards and Testing (NIST) Standard Reference Material of 1.02 mg/cm2 in accordance with the manufacturer’s specifications. The calibration was periodically verified (i.e., at the beginning and end of each work period). In each room one representative surface of each painted or varnished component was tested. Additionally, the exterior of the property and common areas were sampled in the same manner. For the purpose of this report the standard of 1.0 mg/cm2 was used as the threshold level for this survey. However, AEG reported any reading above 0.4 mg/cm2 as suspect requiring paint chip and or waste stream profiling addressing OSHA trigger tasks and waste disposal.

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4.0 SUMMARY OF MATERIALS EVALUATED

4.1 Asbestos

AEG identified homogeneous areas of materials, which were suspected of containing asbestos. Homogeneous areas, for bulk sampling purposes is one that seems by texture, color, and wear to be uniform and applied during the same general time period. After the homogeneous areas had been identified, representative bulk sample(s) are collected for laboratory analysis. A debris field for example would not be considered a homogeneous area since materials are mixed and randomly disbursed.

Because ACBM have compositional variability, it is possible to obtain different laboratory results for samples from the same homogeneous area. Therefore, a homogeneous area with at least one positive sample for will result in the entire homogeneous area being designated as an

ACM.

ACBM were categorized into surfacing ACM, thermal system insulation (TSI) ACM, or miscellaneous ACM that is found in a building. In addition, the condition, approximate quantities and whether ACBM is friable or non-friable ACM was determined during the survey. Friable asbestos material means any material containing more than 1 percent asbestos as determined using the method specified in Appendix E, subpart E, 40 CFR part 763 section 1, Polarized Light

Microscopy, that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

If the asbestos (friable) content is less than 10 percent as determined by a method other than point counting by polarized light microscopy (PLM), verify the asbestos content by point counting using PLM.

All suspected ACBMs were evaluated and the findings are presented in Table 1. Asbestos bulk laboratory reports are presented in Appendix B. The tables present each homogeneous area assessed and identify the type of material such as surfacing, TSI or other, and whether the material is considered friable or non-friable. Approximate quantities were measured and or calculated and reported in either square feet (SF), linear feet (LF), or cubic feet (CF), respectively.

Bulk sample identification numbers are listed with total composite results reported in percent

2K16016 7 concentration on the next line. Subsequent lines reflect material layers identified and type of asbestos, such as Chrysotile or Amosite, and respective percent concentration, where applicable.

The remaining information presented in the table describes the material condition and potential for disturbance. Potential for disturbance factors are presented in Appendix F. Classification of hazard potential is determined from the ratings found on the tables and applying them to a decision tree presented in Appendix G. Priority response actions based on hazard rankings are presented in Appendix H. All field Checklist for Asbestos Hazard Assessment forms are presented in Appendix D.

Building 4990

Out of a total of eleven (11) homogeneous building materials identified on October 17, 2016 following a visual inspection of the exterior and interior, two (2) were listed as ACBM. A total of thirty-seven (37) samples were collected from the areas inspected.

Building 4985

Out of a total of six (6) homogeneous building materials identified on October 17, 2016 following a visual inspection of the exterior and interior, one (1) was listed as ACBM. A total of twenty-nine (29) samples were collected from the areas inspected.

Building 4835A

Out of a total of eight (8) homogeneous building materials identified on October 18, 2016 following a visual inspection of the exterior and interior, three (3) were listed as ACBM. A total of twenty-four (24) samples were collected from the areas inspected.

Building 4838 1ST and 2ND floor mechanical rooms

Out of a total of five (5) homogeneous building materials identified on October 18, 2016 following a visual inspection of the exterior and interior, one (1) was listed as ACBM. A total of fifteen (15) samples were collected from within the areas.

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Out of a total of nine (9) homogeneous building materials identified on October 19, 2016 following a visual inspection of the exterior and interior, two (2) were listed as ACBM, and two (2) were assumed ACBM. A total of thirty-one (31) samples were collected from the areas.

Building 4874

Out of a total of four (4) homogeneous building materials identified on October 19, 2016 following a visual inspection of the exterior and interior, none were listed as ACBM, and one (1) was listed as suspect ACBM. A total of nine (9) samples were collected from the areas.

Building 4875 A & B

Out of a total of six (6) homogeneous building materials identified on October 4, and 19, 2016 following a visual inspection of the exterior and interior, two (2) were listed as ACBM. A total of eighteen (18) samples were collected from within the areas.

NB-121

Out of a total of one (1) homogeneous building materials identified on October 19, 2016 following a visual inspection of the exterior and interior, none were listed as ACBM. A total of three (3) samples were collected from within the areas.

Building 4803

Out of a total of thirteen (13) homogeneous building materials identified on October 19, 2016 following a visual inspection of the exterior and interior, five (5) were listed as ACBM. A total of thirty-nine (39) samples were collected from within the areas.

Building 4806

Out of a total of nineteen (19) homogeneous building materials identified on October 20, 2016 following a visual inspection of the exterior and interior, eight (8) were listed as ACBM. A total of seventy (70) samples were collected from within the areas.

Building 4805

Out of a total of six (6) homogeneous building materials identified on October 20, 2016 following a visual inspection of the exterior and interior, one (1) was listed as ACBM. A total of eighteen (18) samples were collected from within the areas.

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Out of a total of eight (8) homogeneous building materials identified on October 21, 2016 following a visual inspection of the exterior and interior, two (2) were listed as ACBM. A total of twenty-four (24) samples were collected from within the areas.

Building 4807

Out of a total of seventeen (17) homogeneous building materials identified on October 21, 2016 following a visual inspection of the exterior and interior, six (6) were listed as ACBM. A total of fifty-six (56) samples were collected from within the areas.

Building 4808

Out of a total of Sixteen (16) homogeneous building materials identified on October 24, 2016 following a visual inspection of the exterior and interior, three (3) were listed as ACBM. A total of fifty-eight (58) samples were collected from within the areas.

Building 4809

Out of a total of Twenty-two (22) homogeneous building materials identified on October

24, 25 and 27, 2016 following a visual inspection of the exterior and interior, eight (8) were listed as ACBM. A total of seventy-two (72) samples were collected from within the areas.

Building 4850

Out of a total of ten (10) homogeneous building materials identified on October 26, 2016 following a visual inspection of the exterior and interior, none were listed as ACBM. A total of forty (40) samples were collected from within the areas.

Emergency Generator – Building 4981

No suspect asbestos containing materials were observed during inspection.

Emergency Generator – Building 4825

No suspect asbestos containing materials were observed during inspection.

Emergency Generator – Building 4871

No suspect asbestos containing materials were observed during inspection.

Emergency Generator – Building 4887

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No suspect asbestos containing materials were observed during inspection.

Gas Tank Berm and Oil Separator

Out of a total of one (1) homogeneous building material identified on October 3, 2016 following a visual inspection of the exterior, none were listed as ACBM. A total of three (3) samples were collected from the area.

Hydraulic Tank Control Panel Building 4802

No suspect asbestos containing materials were observed during inspection.

Sample locations for each building are shown in Figure 1.

CMU Inspections

Concrete masonry units (CMU) or cement block building materials were inspected on

October 27, 2016, where hollow or non-grouted CMU cells may have been filled with vermiculite insulation. Vermiculite is a naturally-occurring mineral composed of shiny flakes, resembling mica.

When heated to a high temperature, flakes of vermiculite expand as much as 8-30 times their original size. The expanded vermiculite is a light-weight, fire-resistant, and odorless material and has been used in numerous products, including insulation for attics and walls. Sizes of vermiculite products range from very fine particles to large (coarse) pieces nearly an inch long. A mine near

Libby, Montana, was the source of over 70 percent of all vermiculite sold in the United States from 1919 to 1990. There was also a deposit of asbestos at that mine, so the vermiculite from

Libby was contaminated with asbestos. Vermiculite from Libby was used in the majority of vermiculite insulation in the United States and was often sold under the brand name Zonolite.

Additional information can be found at https://www.epa.gov/asbestos/protect-your-family-asbestos-contaminated-vermiculite-insulation

An office building constructed of CMU is attached to and is part of building 4809. The office was expanded south (34’) as indicated in drawings and confirmed in the field. Access holes were drilled into the CMU to determine whether the cell was hollow. If hollow an electronic borescope was used to visually inspect the interior. If there was evidence that vermiculite may be present another hole was drilled at 45 degrees so that a tool could be inserted to collect a bulk sample.

https://www.epa.gov/asbestos/protect-your-family-asbestos-contaminated-vermiculite-insulation https://www.epa.gov/asbestos/protect-your-family-asbestos-contaminated-vermiculite-insulation

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All drilling was performed with local exhaust ventilation (LEV). A hood was configured and attached to a HEPA vacuum via a flex hose. Seven initial holes were drilled. One hollow cell with no evidence of vermiculite with the remaining holes documenting solid or grouted cells. Two of the holes were drilled in the newer construction from the south end of the building. A very small amount of vermiculite was found at the base of both hollow CMU cells 32” on center. Two samples

LM102716-1 and 2 were reported at ND and Trace Actinolite, respectively. Sample LM102716-2 was further analyzed by NESHAP 400-point count. Results are pending laboratory reporting.

Since there was a very small amount of vermiculite noted in the cells there may be this insulation within the attic space, which was inaccessible.

Buildings 4838A, two holes were drilled into the CMU block to inspect for vermiculite. No material was observed within CMU block at building 4838A.

Building 4985 – CMU was inspected for the presence of vermiculite insulation within the wall. CMU was drilled at four locations. All inspected wall locations indicated that the CMU was grouted solid with concrete.

Building 4806 – CMU was inspected for the presence of vermiculite insulation within the walls. Hollow cells within the CMU were noted, however all inspected areas were determined not to be insulated.

4.2 Lead XRF and Paint Chip

Painted components consisted of accessible interior and exterior painted or coated surfaces, including but not limited to safety bollards, enclosures, tanks, cabinets, paint striping, other floor markings, wash basins/sinks, ceramic tiles, and T-Bar grid framework. Each side of the Buildings were numbered A – D going in a clockwise direction. The interior spaces were also numbered. Measurements were generally taken in a clockwise fashion A side then B, C, and D, if accessible. Walls are measured, then window frames, window sash, window sill, door, door jamb etc. The substrate whether metal or wood is recorded along with the condition intact or good, deteriorated or bad. This information is imputed into the XRF and is saved to the internal database. An excel spreadsheet can be printed out at the completion of the survey. This

2K16016 12 instrument generated spreadsheet is presented in Appendix I. The summary of results is presented in Table 2.

Paint chip samples were collected where damage was noted e.g. loose and flaking paint, where applicable. The summary of results is presented in Table 3. The laboratory results of the metals analysis are presented in Appendix C. Sample locations are shown in Figure 1.

Building 4990

Out of a total of thirty-two (32) XRF test shots collected on October 5, 2016 following a visual inspection of the exterior and interior, two (2) coatings were reported as LCP and two (2) were reported as LBP. No bulk paint coating samples were collected.

Building 4985

Out of a total of eighteen (18) XRF test shots collected on October 5, 2016 following a visual inspection of the exterior and interior, one (1) coating was reported as LCP and none were reported as LBP. No bulk paint coating samples were collected.

Building 4835A

Out of a total of twenty-two (22) XRF test shots collected on October 5, 2016 following a visual inspection of the exterior and interior, two (2) coatings were reported as LCP and none were reported as LBP. No bulk paint coating samples were collected.

Building 4838 1ST and 2ND floor mechanical rooms

Out of a total of twenty-six (26) XRF test shots collected on October 5, 2016 following a visual inspection of the exterior and interior, four (4) coatings were reported as LCP and two (2) were reported as LBP. No bulk paint coating samples were collected.

Building 4832

Out of a total of sixty-three (63) XRF test shots collected on October 5, 2016 following a visual inspection of the exterior and interior, one (1) coating was reported as LCP and one (1) was reported as LBP. No bulk paint coating samples were collected.

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Building 4874

Out of a total of twelve (12) XRF test shots collected on October 4, 2016 following a visual inspection of the exterior and interior, one (1) coating was reported as LCP and none were reported as LBP. No bulk paint coating samples were collected.

Building 4875 A & B

Out of a total of twenty-four (24) XRF test shots collected on October 4, 2016 following a visual inspection of the exterior and interior, no coatings were reported as LCP or LBP. No bulk paint coating samples were collected.

NB-121

Out of a total of five (5) XRF test shots collected on October 6, 2016 following a visual inspection of the exterior and interior, one (1) coating was reported as LCP and none were reported as LBP. No bulk paint coating samples were collected.

Building 4803

Out of a total of twenty-three (23) XRF test shots collected on October 6 and 13, 2016 following a visual inspection of the exterior and interior, three (3) coatings were reported as LCP and five (5) materials were reported as LBP. No bulk paint coating samples were collected.

Building 4806

Out of a total of one hundred thirty-six (136) XRF test shots collected on October 6 and

13, 2016 following a visual inspection of the exterior and interior, three (3) coatings were reported as LCP and five (5) materials were reported as LBP. Two (2) bulk paint coating samples were collected.

Building 4805

Out of a total of eighteen (18) XRF test shots collected on October 6, 2016 following a visual inspection of the exterior and interior, one (1) coating was reported as LCP and no coatings were reported as LBP. No bulk paint coating samples were collected.

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Out of a total of twenty-two (22) XRF test shots collected on October 6, 2016 following a visual inspection of the exterior and interior, one (1) coating was reported as LCP and one (1) coating was reported as LBP. No bulk paint coating samples were collected.

Building 4807

Out of a total of one hundred six (106) XRF test shots collected on October 11 and 13, 2016 following a visual inspection of the exterior and interior, thirteen (13) coatings were reported as LCP and seven (7) coatings were reported as LBP. No bulk paint coating samples were collected.

Building 4808

Out of a total of fifty (50) XRF test shots collected on October 6 and 13, 2016 following a visual inspection of the exterior and interior, six (6) coatings were reported as LCP and one (1) coatings were reported as LBP. One bulk paint coating sample was collected.

Building 4809

Out of a total of two hundred and sixty-five (265) XRF test shots collected on October 6 and 13, 2016 following a visual inspection of the exterior and interior, eight (8) coatings were reported as LCP and nine (9) coatings were reported as LBP. Two bulk paint coating samples were collected.

Building 4850

Out of a total of one hundred forty-eight (148) XRF test shots collected on October 3 and

4, 2016 following a visual inspection of the exterior and interior, one (1) coating was reported as

LCP and one (1) coating was reported as LBP. Three (3) bulk paint coating samples were collected.

Emergency Generator – Building 4981

Out of a total of four (4) XRF test shots collected on October 5, 2016 following a visual inspection of the exterior and interior, one (1) coating was reported as LCP and one (1) coating was reported as LBP. No bulk paint coating samples were collected.

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Emergency Generator – Building 4825

Out of a total of six (6) XRF test shots collected on October 4, 2016 following a visual inspection of the exterior and interior, no coatings were reported as LCP or LBP. No bulk paint coating samples were collected.

Emergency Generator – Building 4871

Out of a total of eight (8) XRF test shots collected on October 4, 2016 following a visual inspection of the exterior and interior, one (1) coating was reported as LCP and none were reported as LBP. One (1) bulk paint coating samples were collected.

Emergency Generator – Building 4887

Out of a total of five (5) XRF test shots collected on October 4, 2016 following a visual inspection of the exterior and interior, no coatings were reported as LCP or LBP. No bulk paint coating samples were collected.

Gas Tank Berm and Oil Separator

Out of a total of four (4) XRF test shots collected on October 4, 2016 following a visual inspection of the exterior and interior, no coatings were reported as LCP and one (1) material was reported as LBP. One (1) bulk paint coating sample was collected.

Hydraulic Tank Control Panel Building 4802

Out of a total of thirteen (13) XRF test shots collected on October 4, 2016 following a visual inspection of the exterior and interior, two (2) coatings were reported as LCP and five (5) materials were reported as LBP. One (1) bulk paint coating sample was collected.

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5.0 REGULATIONS

5.1 Asbestos

California Occupational Safety and Health Administration (Cal/OSHA) regulates asbestos under Title 8 California Code of Regulations (CCR) §1529 and, §5208 which address Construction and General Industry, respectively. NASA/AFRC campus is regulated by Federal OSHA standard

29 Code of Federal Regulation (CFR) §1910.1001 and, §1926.1101, respectively. Upon analysis of bulk samples, analytical results are compared to government agency standards. Currently, Cal/OSHA) and the EPA define material with contains more than one percent asbestos to be an asbestos containing material. Cal/OSHA also includes a definition for Asbestos Containing

Construction Material (ACCM) as material containing more than 0.1% asbestos by weight.

The Eastern Kern Air Pollution Control District (EKAPCD) requires owners of buildings and or their contractors to make notification prior to all demolition or renovation of facilities where asbestos material will be disturbed as per District Rule 423 which adopts the National Emission

Standard for Hazardous Air Pollutants (NESHAPS) for Asbestos 40 CFR Chapter 61 Subpart M.

Notification must be postmarked at least ten working days prior to the start of any demolition or renovation activity that will disturb asbestos. Notification is mandatory for renovation jobs which involve the disturbance of friable or regulated asbestos containing material (RACM) meeting or exceeding the minimum of 260 linear feet; 160 square feet; or 35 cubic feet. Cal/OSHA local district office is required to be notified when material disturbed is equal to or more than 100 square feet, where applicable.

Removal of ACM must be performed in accordance with all applicable federal, state and local health and safety regulations and policies. These include the following:

29 CFR §1926.1101 (Construction Standard)

29 CFR §1910.1001 (General Industry)

Title 8 CCR §1529(Construction Standard)

Title 8 CCR §5208 (General Industry)

EKAPCD District Rule 423 which adopts the NESHAPS for Asbestos 40 CFR Chapter 61 Subpart M

Department of Transportation (DOT) Parts 171 and 172

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5.2 Lead

California Department of Public Health (CDPH) regulates Lead under Title 17 CCR

Division 1, Chapter 8 §35001 - §36100. This rule applies to firms and individuals conducting regulated lead inspection, assessment, project designing, project monitoring and/or abatement activities at target housing, childcare facilities, public facilities, and contract documents specifying certified abatement activities. The EPA and CDPH define paint or other coating with lead levels of 1.0 mg/cm2 or 0.5%, Lead-Based Paint.

Cal/OSHA and OSHA also regulates Lead in Construction and General Industry Safety

Orders under the following regulations:

Title 8 CCR 1532.1 / 29 CFR 1926.62, Lead in Construction;

Title 8 CCR 5198 / 29 CFR 1910.1025, Lead in General Industry

These regulations address potential employee exposures when performing construction work on surfaces containing any concentration of Lead. Potential exposure to these metals may occur when performing work, referred to as trigger tasks, that create airborne particulates or fumes (such as sawing, sanding, torch cutting, etc.), or during handling of the waste materials.

If performing construction work on such materials, OSHA regulations requires initial exposure assessment (air monitoring) of employees to determine potential exposure. Until it is demonstrated that levels of airborne dust or fumes will not exceed the action limit of each specific metal, the use of personal protective equipment, including NIOSH approved respirators and

Tyvek, should be used. In addition, a work clothing change area, hand washing facilities, biological monitoring (blood lead and zinc protoporphyrin levels), and awareness level training 29

CFR 1926.62 (l) (1) (i) should be provided during work involving disturbance of lead containing paints or other materials.

Where Lead levels exceed regulatory guidelines, disposal of demolition waste as construction debris may not be exempt.

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6.0 DISCUSSION

Based on the visual survey and suspect ACM samples collected from 22 identified building/structures, AEG identified a total…